Protest Version EA Sept2019

U.S.
Department of the Interior

Bureau of Land Management
July 2019
September 2019 Competitive Oil and Gas Lease Sale

Monticello Field Office
DOI-BLM-UT-0000-2019-0003-OTHER NEPA -MtFO-EA

365 North Main
PO Box 7
Monticello, UT 84535
DOI-BLM-UT-0000-2019-0003_Other NEPA-MtFO-EA
July 2019
Table of Contents
Chapter 1 Purpose & Need .................................................................................................................... 4
1.1 Project Location and Legal Description........................................................................................ 4
1.2 Introduction ................................................................................................................................... 4
1.3 Background ................................................................................................................................... 4
1.4 Purpose and Need ......................................................................................................................... 6
1.5 Decision to be Made ..................................................................................................................... 6
1.6 Plan Conformance Review............................................................................................................ 6
1.7 Relationship to Statutes, Regulations, Policies or Other Plans ..................................................... 9
1.8 Issues Identified .......................................................................................................................... 10
1.9 Issue Statement Rationale for Not Further Discussing in Detail in the EA ................................ 11
1.10 Public Comment Period .............................................................................................................. 18
Chapter 2 Description of Alternatives ................................................................................................. 19
2.1 Introduction ................................................................................................................................. 19
2.2 Analysis Assumptions ................................................................................................................. 19
2.2.1 Reasonably Foreseeable Development Scenario ................................................................ 19
2.3 Alternative A – Proposed Action ................................................................................................ 20
2.4 Alternative B – No Action .......................................................................................................... 21
2.5 Other Alternatives Considered but Not Analyzed in Detail........................................................ 21
2.5.1 No Leasing Alternative (Designating the Parcels as Closed to Leasing) ............................ 21
2.5.2 Deferring Specific Parcels from the Sale ............................................................................ 21
2.5.3 Adding Stipulations Beyond those Required by the Management Plan ............................. 22
Chapter 3 Affected Environment ......................................................................................................... 23
3.1 Introduction ................................................................................................................................. 23
3.2 General Setting............................................................................................................................ 23
3.3 Resources/Issues Brought Forward for Analysis ........................................................................ 25
3.3.1 Issue 1: What are the Potential Impacts to Air Quality ....................................................... 25
3.3.1.1 Affected Environment ..................................................................................................... 25
3.3.1.2 Environmental Consequences ......................................................................................... 28
Impacts of the Proposed Action ..................................................................................................... 28
Impacts of the No Alternative Action ............................................................................................ 30
3.3.1.3 Required Design Features ............................................................................................... 30
3.3.1.4 Cumulative Impacts ........................................................................................................ 31
3.3.2 Issue 2: What are the Potential Impacts of Oil and Gas Leasing to Climate
Change/Greenhouse Gases? ............................................................................................................... 34
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3.3.2.1 Affected Environment ..................................................................................................... 34

3.3.2.2 Environmental Consequences ......................................................................................... 36
Impacts of the Proposed Action ..................................................................................................... 36
Impacts of the No Alternative Action ............................................................................................ 38
3.3.2.3 Required Design Features/Mitigation Measures ............................................................. 38
3.3.2.4 Cumulative Impacts ........................................................................................................ 39
Chapter 4 Consultation and Coordination ........................................................................................... 45
4.1 Introduction ................................................................................................................................. 45
4.2 Persons, Groups, and Agencies Contacted/Consulted ................................................................ 45
4.2.1 Endangered Species Act of 1973 ........................................................................................ 45
4.2.2 National Historic Preservation Act (NHPA) of 1966.......................................................... 45
4.3 Public Participation ..................................................................................................................... 50
4.3.1 Modifications Based on Public Comment and Internal Review ......................................... 50
4.4 Preparers ..................................................................................................................................... 51
Chapter 5 Appendices .......................................................................................................................... 52
Appendix A – Parcel List with Stipulations and Notices ................................................................... 53
Appendix B – Stipulations and Notices ............................................................................................. 70
Stipulation Summary Table ........................................................................................................... 70
Notice Summary Table .................................................................................................................. 81
Threatened and Endangered Species Notices ................................................................................ 89
Appendix C – Figures/Maps .............................................................................................................. 97
Appendix D – Interdisciplinary Parcel Review Team Checklist...................................................... 100
Appendix E – References ................................................................................................................. 113
Appendix F – Acronyms/Abbreviations........................................................................................... 117
Appendix G – Reasonable Foreseeable Development of Leases Scenario ...................................... 119
5.1.1 Well Drilling and Completion Operations ........................................................................ 119
5.1.2 Production Operations....................................................................................................... 121
5.1.3 Produced Water Handling ................................................................................................. 121
5.1.4 Maintenance Operations ................................................................................................... 122
5.1.5 Plugging and Abandonment .............................................................................................. 122
Appendix H – Comments and Responses ........................................................................................ 123
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List of Tables
Table 1. Issues Identified for Detailed Analysis ......................................................................................... 10
Table 2. Issues not included in Further Detail in the Environmental Assessment ...................................... 12
Table 3. Leasing Category Acreages for Monticello Field Office. ............................................................. 24
Table 4. Leasing Category Acreages by Parcel. ......................................................................................... 24
Table 5. AQI Index Summary Statistics by County.................................................................................... 26
Table 6. 2015-2017 Criteria Pollutant Design Values ................................................................................ 26
Table 7. 2014 Criteria Air Pollutant Emissions (tpy) by Source for San Juan County ............................... 27
Table 8. Triennial Inventory of HAPs (2014). ............................................................................................ 27
Table 9. Emissions Inventory Estimate....................................................................................................... 29
Table 10. Climate Trends ............................................................................................................................ 35
Table 11. GHG Emission in Million Metric Tons (CO2e) .......................................................................... 36
Table 12. Single Well GHG Emissions Based on the Moab MLP FEIS Inventory .................................... 36
Table 13. Production of Oil and Gas for a Single Well and Associated GHG Combustion Emissions ..... 37
Table 14. Estimates Annual GHG Emissions from Existing and Reasonably Foreseeable Oil and Gas
Wells. .......................................................................................................................................................... 40
Table 15. Comparison of Total Annual Emissions with State and National Emissions ............................. 40
Table 16. Expected wells from Each Field Office RMP, and Corresponding GHG Emissions ................. 40
Table 17. Undeveloped Portion of RMP RFD Scenarios and Corresponding Potential GHG Emissions for
Each Field Office ........................................................................................................................................ 41
Table 18. List of Contacts and Findings. .................................................................................................... 47
Table 19. Preparers of This EA. .................................................................................................................. 51
List of Figures
Figure 1. ARMS predicted ozone design values with on the books controls for oil and gas emissions in the
year 2021..................................................................................................................................................... 32
Figure 2. ARMS predicted PM2.5 design values with on the books controls for oil and gas emissions in
the year 2021. .............................................................................................................................................. 33
Figure 3. Potential for climate change impacts for the Colorado Plateau ................................................... 43
Figure 4. Lease Sale Parcel Overview. ....................................................................................................... 98
Figure 5. Hovenweep Viewshed Analysis .................................................................................................. 99
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Environmental Assessment
DOI-BLM-UT-0000-2019-0003-OTHER_NEPA_MtFO-EA
Chapter 1 Purpose & Need
1.1 Project Location and Legal Description

The preliminary parcel list contained 19 parcels covering 32,067.42 acres for the September 2019
Competitive Oil and Gas Lease Sale (lease sale) and are located on public lands administered by the
Bureau of Land Management’s (BLM) Monticello Field Office (MtFO). All 19 parcels were deferred
from the March 2019 Sale (DOI-BLM-UT-Y020-2019-0004-DNA) 1. The legal descriptions of the
nominated parcels are in Appendix A.
1.2 Introduction
The Utah State Office (UTSO) has prepared this environmental assessment (EA) to disclose and analyze
the environmental consequences for the selling of parcels and subsequent lease issuance to successful
bidders from the lease sale. This EA is an issue-base, site specific analysis of potential impacts that could
result from the implementation of a proposed action or alternative to the proposed action. The EA assists
the BLM in project planning and ensures compliance with the National Environmental Policy Act
(NEPA), and in making a determination as to whether any significant impacts could result from the
analyzed actions. 2 This EA provides evidence for determining whether to prepare an Environmental
Impact Statement (EIS) or a statement of Finding of No Significant Impact (FONSI). If the decision
maker determines this project has significant impacts following the analysis in the EA, than an EIS would
be prepared. If not, a Decision Record (DR) may be signed for the EA approving the selected alternative,
either the proposed action or another alternative. A DR, including a FONSI statement, for this EA would
document the reasons why implementation of the selected alternative would not result in significant
environmental impacts (effects) beyond those already addressed in the governing land use plan (LUP) as
amended (Section 1.6).
1.3 Background
This EA analyzes 19 nominated parcels comprising of 32,067.42 acres for the lease sale that are under the
administration of the MtFO. The 19 parcels were determined to be open to leasing for oil and gas
development under the applicable plans. The mineral rights for these parcels are owned by the federal
government and administered by the MtFO. The legal descriptions of the nominated parcels are in
Appendix A.
During the land use planning process the BLM decides which public lands and minerals are open for
leasing and under what terms and conditions. In accord with Resource Management Plans (RMPs), lands
can be deemed open to leasing under standard terms and conditions, closed to leasing, or open under
special operating constraints identified as lease stipulations at the lease stage. Lease stipulations are used
to mitigate potential impacts to resources. Any surface management of non- BLM administered land
overlaying federal minerals is determined by the BLM in consultation with the appropriate surface
management agency or the private surface owner.
The Mineral Leasing Act of 1920 (MLA), as amended [30 U.S.C. 181 et seq.], and the Federal Onshore
Oil and Gas Leasing Reform Act of 1987 (FOOGLRA), require the BLM UTSO to conduct quarterly,
competitive lease sales to offer available oil and gas lease parcels in Utah. Expressions of Interest (EOI)
1
The DNA and all documents pertaining to the March 2019 analysis can be found on BLM’s ePlanning site at
http://go.usa.gov/xPfJg
2 Significance is defined by NEPA, and is found in 40 Code of Federal Regulations (CFR) 1508.27
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to nominate parcels for leasing by the BLM are submitted by the public. From these EOIs, the BLM
prepares the parcels and determines whether or not the existing analyses in the LUPs, as amended,
provide basis for leasing oil and gas resources within these parcels or if additional NEPA analysis is
needed before making a leasing decision.
In the process of preparing a lease sale, the UTSO compiles a list of lands nominated by the public,
legally available for leasing, and sends a preliminary parcel list to the appropriate District Office where
the parcels are located. Field Office staff reviews the legal descriptions of the parcels to determine if they
are in areas open to leasing under the relevant RMP, ensures appropriate stipulations have been applied
and identify any special resource conditions of which potential bidders should be made aware. Standard
lease terms also provide for reasonable measures to minimize adverse impacts to specific resource values,
land uses, or users (Standard Lease Terms are contained in Form 3100-11, Offer to Lease and Lease for
Oil and Gas, U.S. Department of the Interior, BLM, October 2008 or later edition). Compliance with
valid, nondiscretionary statutes (laws) is included in the standard lease terms.
Once the Field Offices completed the interdisciplinary parcel review (IDPR), the BLM determined that
preparation of an EA was necessary for considering the parcels within MtFO. This EA and an unsigned
FONSI are made available to the public, along with the list of available parcels and stipulations and
notices, for a 30-day public comment period on the BLM’s NEPA Register 3 (also known as ePlanning).
The UTSO Oil and Gas Leasing webpage 4 is also updated and maintained for the lease sale. Additional
information regarding the BLM’s leasing process is also made available for public review and reference.
At the end of the public comment period, the BLM analyzes and incorporates the comments, where
appropriate, into the EA and/or parcel list. The final parcel list with stipulations and notices is made
available to the public through a Notice of Competitive Lease Sale (NCLS), which starts a 30-day protest
period, and includes the revised EA and unsigned FONSI. If any changes to the parcels or
stipulations/notices result from the protests, an erratum to the NCLS would be posted to the BLM website
and on NEPA Register to notify the public of the change, prior to the lease sale. The parcels would be
available for sale at an online auction held by the BLM, tentatively scheduled for September 11, 2019.
If the parcel is not purchased at the lease sale by through the competitive bidding process, it may still be
leased non-competitively within two years after the initial offering at the minimum bid cost. Parcels
obtained non-competitively may be re-parceled by combining or deleting other previously offered lands.
Mineral estate that is not leased within a two-year period after an initial offering will no longer be
available and must go through another separate competitive lease sale process prior to being leased.
An issued lease may be held for ten years, after which the lease expires unless oil or gas is produced in
paying quantities (43 CFR 3107.2). A producing lease can be held indefinitely by economic production.
The act of leasing does not authorize any development or use of the surface of lease lands without further
application by the operator and approval by the BLM. In the future, operators must submit an Application
for Permit to Drill (APD) (Form 3160-3) to the BLM for approval and must possess an approved APD
prior to any surface disturbance in preparation for drilling. 5 An APD may only be approved when an
operator complies with any stipulations and/or notices attached to the standard lease form. If an APD is
received, the BLM would conduct additional site-specific NEPA analysis before deciding whether to
approve the APD, and what conditions of approval (COA) should apply.
Following BLM’s approval of an APD, a lessee may produce oil and gas from the well in a manner
approved by the BLM in the APD or in subsequent sundry notices. The operator must notify the
3
The NEPA Register is a BLM environmental information internet site and can be accessed online at: https://bit.ly/2Z5PlYd
4 UTSO Oil and Gas Leasing program webpage can be accessed at: http://go.usa.gov/xXk8c
5
Additional Information regarding the BLM’s oil and gas management program can be accessed online at:
https://www.blm.gov/programs/energy-and-minerals/oil-and-gas/
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appropriate BLM authorized officer 48 hours before starting any surface disturbing activity approved in
the APD.
Standard lease terms provide for reasonable measures to minimize adverse impacts to specific resource
values, land uses, or users. Compliance with valid, nondiscretionary statutes (laws) is included in the
standard lease terms. Nondiscretionary actions include the BLM’s requirements under federal
environmental protection laws, such as Clean Water Act, Clean Air Act, Endangered Species Act,
National Historic Preservation Act, and Federal Land Policy and Management Act, which are applicable
to all actions on federal lands, including split estate. Also included in all leases are two mandatory
stipulations for the statutory protection of cultural resources and threatened or endangered species
(Handbook H-3120-1).
Once the lease has been issued, the lessee has the right to use as much of the leased land as necessary to
explore for, drill for, extract, remove, and dispose of oil and gas deposits located under the leased lands,
subject to the standard lease terms and additional restrictions attached to the lease in the form of lease
stipulations (S) (43 CFR 3101.1-2) and lease notices (LN) (43 CFR 3101.1-3). Even if no restrictions are
attached to the lease, the operations must be conducted in a manner that avoids unnecessary or undue
degradation of the environment and minimizes adverse impacts to the land, air, water, cultural, biological,
and visual elements of the environment, as well as other land uses or users.
1.4 Purpose and Need
The purpose of this action is for the UTSO to respond to the nominations or expressions of interest for oil
and gas leasing on specific federal mineral estate through a competitive leasing process and either lease or
defer from leasing, pending additional information. The need for the Proposed Action is established by
the BLM’s responsibility under the MLA of 1920, as amended, the Mining and Minerals Policy Act of
1970 as amended, the Federal Onshore Oil and Gas Leasing Reform Act of 1987 (Reform Act) as
amended, and Federal Land Policy and Management Act of 1976 as amended, and to promote the
development of oil and gas on the public domain. Parcels may be nominated by the public, the BLM or
other agencies. The MLA establishes that deposits of oil and gas owned by the United States are subject
to disposition in the form and manner provided by the MLA under the rules and regulations prescribed by
the Secretary of the Interior, where consistent with FLPMA and other applicable laws, regulations, and
policies.
1.5 Decision to be Made
Following the completion of the NEPA process the BLM would determine whether or not to lease the
nominated parcels and, if so, under what lease terms and conditions (stipulations and/or notices). In order
to make an informed decision, the BLM is using this EA to identify the environmental impacts of the
Proposed Action and its alternatives. This EA analyzes two alternatives. The first alternative analyzed is
the Proposed Action, the second is Alternative B, the No Action Alternative.
1.6 Plan Conformance Review

The statutes, regulations, policies, and plans utilized in preparing this EA include, but are not limited to
the following:
Statutes (As Amended)
• Federal Land Policy and Management Act of 1976 (FLMPA)
• Mineral Leasing Act of 1920 (MSA)
• Mining and Minerals Policy Act of 1970 (MMPA)
• Federal Onshore Oil and Gas Leasing Reform Act of 1987 (FOOGLRA)
• National Historic Preservation Act of 1966 (NHPA)
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• Bald and Golden Eagle Protection Act of 1962 (BGEPA)

• Endangered Species Act of 1973 (ESA)
• Migratory Bird Treaty Act of 1918 (MBTA)
• Clean Water Act of 1972 (CWA)
Regulations
• 40 CFR Part 93 Subpart E
• 43 CFR 1600
• 43 CFR 3100
• 40 CFR 1500 – 1508
• 40 CFR 104
• 36 CFR 800
• 36CFR 60.4
Manuals6
• BLM Manual 6840 – Special Status Species
• BLM Manual 3120 – Competitive Leasing
• BLM Manual 6310 - Conducting Wilderness Characteristics Inventory of BLM Lands
• BLM Manual 6320 - Considering Lands with Wilderness Characteristics in the BLM Land Use
Planning Process
Handbooks 7
• Competitive Leasing Handbook (H-3120-1)
Policies/Instruction Memoranda (IM) 8
• Updating Oil and Gas Leasing Reform – Land Use Planning and Lease Parcel Reviews (WO IM
2018-034)
• Directional Drilling into Federal Mineral Estate from Well Pads on Non-Federal Locations (WO
IM 2018-014)
• Oil and Gas Leasing Program NEPA Procedures Pursuant to Leasing Reform (UT IM 2014-006)
• Utah Riparian Management Policy (2006)
• Utah’s Standards for Rangeland Health (1997)
• Utah BLM Drinking Water Source Protection Zone (2010)
• Secretarial Order 3355 Streamlining NEPA (2017)
• Secretarial Memorandum August 6, 2018, Streamlining Environmental Assessments
• Protection of Ground Water Associated with Oil and Gas Leasing, Exploration and Development
(BLM UT IM 2010–055)
• BLM Utah Guidance for Lands with Wilderness Characteristics Resource (UT IM 2016-027)
• Updated BLM Sensitive Species Lists for Utah (UT IM 2019-005)
6
BLM manuals can be accessed online at: https://www.blm.gov/media/blm-policy/manuals.
7
BLM handbooks can be accessed online at: https://www.blm.gov/media/blm-policy/handbooks.
8
BLM instruction memoranda and information bulletins can be accessed online at:
https://www.blm.gov/media/blm-policy/instruction-memorandum and https://www.blm.gov/media/blm-
policy/information-bulletin.
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Agreements
• MOU Among the United States Department of Agriculture, the United States Department of
Interior and the United States Environmental Protection Agency Regarding Air Quality Analysis
and Mitigation for Federal Oil and Gas Decisions through the NEPA Process (2011)
• State Protocol Agreement Between the Utah State Director of the Bureau of Land Management
and the Utah State Historic Preservation Officer Regarding the Manner in which the BLM Will
Meet its Responsibilities Under the National Historic Preservation Act and the National
Programmatic Agreement Among the BLM, the Advisory Council on Historic Preservation and
the National Conference of State Historic Preservation Officers (2001)
• MOU between the USDI BLM and USFWS to Promote the Conservation and Management of
Migratory Birds (April 2010)
State of Utah Plans/Rules

• Utah Wildlife Action Plan (2015)
• The Utah Oil and Gas Conservation Act (1955)
• The Utah Oil and Gas Conservation General Rules
• The State of Utah Resource Management Plan (State of Utah 2018)
BLM Activity Plans/Strategies/Practices

• T&E Habitat Management Plan (BLM 1990)
• Utah Air Resource Management Strategy (BLM 2018)
• Air Resource Management Program Strategy 2015-2020 (BLM 2015)
• Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development, The
Gold Book (USDI and USDA 2007)
• Executive Order 13186: Responsibilities of Federal Agencies to Protect Migratory Birds
• Utah Partners in Flight Avian Conservation Strategy Version 2.0 (Parrish et al., 2002)
• Birds of Conservation Concern 2002 (USFWS 2008)
BLM Land Use Plans

• Moab Field Office Master Leasing Plan, July 2016, (Moab MLP) as maintained, Moab. (BLM
2016)
• Record of Decision and Moab MLP Approved RMP Amendments for Moab and Monticello Field
Offices. (BLM 2016)
• Reasonable Foreseeable Development Scenario for Oil and Gas in the Moab MLP Area, Canyon
Country District. (BLM 2012)
• Monticello Field Office RMP, August 2008, (MtFO RMP) as Maintained, Monticello (BLM
2008)
• Monticello Record of Decision and Approved RMP (BLM 2008)
• Monticello Reasonable Foreseeable Development Scenario for Oil and Gas (BLM 2005)
The alternatives described below are in conformance with the governing LUPs (as amended). Pursuant to
40 CFR 1508.28 and 1502.21, this EA is tiered to and incorporates by reference the information and
analysis contained in the current RMPs and RMP Amendments and their EIS. Specifically, proposed
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actions align with the following BLM Land Use Plans within the designated Field Office boundaries (43
CFR 1610.5, BLM 1617.3).
Monticello RMP, October 2008, as amended

Record of Decision (ROD) The RMP designated approximately 1,290,919.00 acres of federal mineral
estate open for continued oil and gas development and leasing (see RMP/FEIS Table 4.121 on page 4-431
and RMP page 16). The RMP (with associated amendments and plan maintenance) also describes specific
stipulations that would be attached to new leases offered in certain areas. Under the Proposed Action,
parcels to be offered would be leased subject to stipulations prescribed by the RMP (see RMP MIN-6
through MIN-27 on page 80-81). Therefore, the Proposed Action conforms to the fluid mineral leasing
decisions in the RMP and subsequent amendments, and are consistent with the RMP’s goals and
objectives for natural and cultural resources. It is also consistent with RMP decisions and their
corresponding goals and objectives related to the management of (including but not limited to) air quality,
cultural resources, recreation, riparian, soils, water, vegetation, fish & wildlife and Areas of Critical
Environmental Concern (ACEC).
Moab Master Leasing Plan and RMP, December 2016, as maintained

The RMP does not revise all management decisions in the Moab RMP, but it does amend certain
decisions pertaining to oil/gas and potash leasing. The Moab MLP updates leasing decisions in portions
of the existing RMPs for the Moab and Monticello Field Offices (see RMP decisions MIN-OG-1, MIN-
OG-2, MIN-OG-4 to 8 on page 17 through 19). Approximately 230, 765 acres are open to oil and gas
leasing, subject to CSU/TL stipulations, 305,899 acres are subject to NSO stipulation, 145, 284 acres are
closed to leasing (See RMP Appendix A, and Appendix B). Approximately 103, 619 acres within the
Potash Leasing Areas are open to oil and gas leasing subject to CSU/TL or NSO stipulations. The
Proposed Action conforms to the fluid mineral leasing decisions in the RMP and subsequent amendments,
and are consistent with the RMP’s goals and objectives for natural and cultural resources. It is also
consistent with RMP decisions and their corresponding goals and objectives related to the management of
(including but not limited to) air quality, cultural resources, recreation, riparian, soils, water, vegetation,
fish & wildlife and Areas of Critical Environmental Concern (ACEC).
1.7 Relationship to Statutes, Regulations, Policies or Other Plans

The alternatives described below are also consistent with the LUPs decisions related to the management
of the following resources/uses, including but not limited to: fire/fuels, geology/mineral resources,
invasive species/noxious weeds, lands, livestock grazing, recreation, socio economics,
travel/transportation, soil/vegetation, visual resources, and forestry. Other NEPA documents and relevant
studies that are applicable to this analysis include:
• Inventory of Onshore Federal Oil and Natural Gas Resources and Restrictions to Their
Development 2008 Phase III inventory-Onshore United States
• 2008 MtFO ROD (BLM 2008) and RMP/FEIS (BLM 2008) as amended
• 2007 Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17
Western States Programmatic Environmental Impact Statement and Record of Decision (BLM
2007)
• 2009 Canyons of the Ancients National Monument Proposed Resource Management Plan and
Final Environmental Impact Statement. (BLM 2009)
• 2018 March 2018 Competitive Oil and Gas Lease Sale (DOI-BLM-UT-Y010-2017-0240-EA)
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(BLM 2018)
• 2008 Biological Opinion for the MtFO RMP 9 (BLM 2008)
• March 2019 Lease Sale Cultural Resources Report (Utah SHPO Case No. 19-0235) (BLM 2019)
In order to reduce redundant paperwork and analysis in the NEPA process (See 40 CFR 1502.20 and
1502.21) the previous documents and their associated information or analysis are hereby incorporated by
reference. The attached IDPR Checklist, Appendix D was also developed after consideration of these
documents and their contents.
1.8 Issues Identified
Identification of issues, concerns, and potential impacts that require detailed analysis was accomplished
through internal review/discussion. The UTSO sent letters/ memorandum to the following stakeholders:
the National Park Service (NPS), the United States Fish and Wildlife Service (USFWS), the United States
Forest Service (USFS), the State of Utah’s Public Lands Policy Coordination Office (PLPCO), Division
of Wildlife Resources (UDWR), and the School Institutional Trust Lands Administration (SITLA) to
notify them of the pending lease sale, and solicit comments and concerns on the preliminary parcel list.
The BLM also provided GIS shapefiles depicting the proposed sale parcels to contacts within the NPS
and UDWR. Consultation and coordination efforts are summarized in Chapter 4, Table 18.
The UTSO received the September 2019 lease sale parcel nomination list on April 1, 2019.
Internal scoping was initiated on April 5, 2019 when the nominated lease parcels for the September 2019
competitive oil and gas lease sale were presented to the MtFO Interdisciplinary (ID) Team. Resource
specialists on the ID teams helped identify the following issues through coordination, and meetings.
The key issues identified through the scoping process were developed using the guidelines set forth in
section 8.3.3 of the BLM NEPA Handbook and EA are summarized in Table 1 and Table 2, below.
Table 1. Issues Identified for Detailed Analysis
Issue Issue Statement Impact Indicator
Air Quality What quantity of air pollutants would be Tons per year of PM-10,
produced based on the reasonably PM-2.5, NO X, SO2, CO,
foreseeable development (RFD) scenario? VOCs, HAPs.
How would air pollutant emissions from
subsequent development of leased parcels
affect air quality?
Greenhouse What quantity of greenhouse gas emissions Metric tons (MT) or million
Gas/Climate Change (GHG) would be generated from subsequent metric tons (MMT) per year of
oil and gas development of leased parcels carbon dioxide equivalents
based upon the RFD scenario? How do these (CO2eq)
amounts compare to other sources of GHGs?
9
MtFO ROD, RMP/FEIS is located on ePlanning at https://eplanning.blm.gov/epl-front-
office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentPageId=98873
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1.9 Issue Statement Rationale for Not Further Discussing in Detail in the EA 10
Where resources are present but not determined to be impacted or resources are determined not to be
present, a rationale for not considering them further is provided in the Interdisciplinary Parcel Review
Team (IDPRT) checklist (Appendix D), and in the external coordination as described in Table 18. Table 2
highlights key issues evaluated and not discussed in further detail in this EA for the resources the BLM
commonly receives public comments and/or interests. These resources are described below in Table 2.
10
Refer to the IDPRT checklist (Appendix D – Interdisciplinary Parcel Review Team Checklist) for the complete
rational for resources identified for analysis and resources not considered for further detailed analyses.
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Table 2. Issues not included in Further Detail in the Environmental Assessment

Issue Issue Statement Rationale for Not Further Discussing in Detail in the EA
T&E Species What are the potential The parcels involved in the September 2019 lease sale were analyzed individually within each field office
impacts to federally-listed for occurrence of federally-listed species, in coordination with the USFWS. The Threatened and
threatened and Endangered Species Act Stipulation is applied across all lease parcels which states that if any parcel is
endangered species or found to contain plants, animals or their habitats determined to be threatened, endangered or special
habitats in areas related to status species, the BLM may recommend modifications to exploration and development proposals to
oil and gas development? further its conservation and management objective. Under this stipulation, the BLM may also require
modifications to or disapprove proposed activity that is likely to result in jeopardy to the continued
existence of a proposed or listed threatened or endangered species, or result in destruction or adverse
modification of a designated or proposed critical habitat.
As appropriate, BLM attaches stipulations or notices to the lease which give notice to the lessor/operator
of potential for occurrence of federally-listed species, and measures that may be required to mitigate
impacts.
The BLM will not approve any ground-disturbing activity that may affect any such species or critical
habitat until it completes its obligations under applicable requirements of the Endangered Species Act as
amended, 16 U.S.C. § 1531 et seq., including completion of any required procedure for conference or
consultation.
BLM Sensitive What are the potential BLM Manual 6840 requires conservation of special status species and the ecosystems upon which they
Species impacts to BLM sensitive depend on BLM-administered lands. BLM special status species are those listed or proposed for listing
(Wildlife and species (wildlife and under the ESA, and species requiring special management consideration to promote their conservation
Plants) plants) or their habitats and reduce the likelihood and need for future listing under the ESA. Instructional Memorandum No. UT
from oil and gas IM-2019-005 provides the plant and wildlife Species lists for BLM-administered public lands in Utah and
development? these species have been evaluated for potential impacts from the proposed lease sale, as documented by
the checklist found in Appendix D of this EA.
The Utah BLM has several lease notices that protect sensitive species statewide (see UT-LN-49 Utah
Sensitive Species in Appendix A of this document) or on a species specific basis (see UT-LN-107: Bald
Eagle). For the Monticello Field Office, September 2019 lease sale, the BLM analysis of potential for
impacts to sensitive wildlife and plants or their habitat, and determined that application of the following
lease notices was appropriate for every parcel in the sale: UT-LN-49 (Utah Sensitive Species).
The application of sensitive species protections contained in UT-LN-49: Utah Sensitive Species tells the
lessee/operator that no surface use or otherwise disruptive activity would be allowed that would result in
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direct disturbance to populations or individual special status plant and animal species, and that
modifications to the Surface Use Plan of Operations may be required to protect these resources from
surface disturbing activities.
In addition, multiple parcels contained sensitive habitat for game species such as elk, mule deer or
pronghorn antelope. The application of these stipulations and notices is discussed in detail in Appendix D
of this EA, under “Game Species.”
Leasing of the proposed leases would not, by itself, authorize any ground disturbance; however, the
proposed lease sale has the potential to impact habitat through future oil and gas development. Although
site-specific effects cannot be analyzed until an exploration or development application is received,
attachments of stipulations and notices to leases will assure the opportunity to make adjustments, such as
design modifications, at the site specific level when an Application for Permit to Drill is received, to
address specific wildlife and plant resources.
Migratory Birds What are the potential The Migratory Bird Treaty Act (MBTA) protects migratory birds; Instructional Memorandum No. 2008-
impacts to migratory 050 requires the BLM to Address the potential effects of the project son migratory bird populations and
birds from oil and gas their habitat, and implement best management practices to avoid or minimize the possibility of impacts,
development? through such measures as timing limitations during nesting seasons, surveys for bird nests, and
monitoring (https://www.blm.gov/policy/im-2008-050).
The Utah BLM has several lease notices that implement this policy during lease sales, ranging from those
applied statewide (UT-LN-45: Migratory Birds, found in Appendix B of this document) to species
specific (see UT-LN-107L Bald Eagle and UT-LN-44 Raptors). In addition, several migratory birds have
been designated as BLM Sensitive Species, and these may have additional protections through notices to
potential buyers of potential for occurrence on a given parcel (see UT-LN-49).
For the Monticello Field Office, September 2019 lease sale, the BLM analysis of potential for occurrence
indicated that application of the following lease notices was appropriate for every parcel in the sale, UT-
LN-43 Raptors, and UT-LN-45: Migratory Birds.
UT-LN-43 provides that raptor habitat exists in a given parcel, and that surveys will be required to
identify any nesting birds. UT-LN-45 gives prospective buyers notice that surveys for nesting migratory
birds may be required during migratory bird breeding season whenever surface disturbances and/or
occupancy is proposed in association with fluid mineral exploration and development within priority
habitats. Based on these surveys, buffers and timing limitations may be applied. In combination these
lease notices provide mitigation measures which will mitigate impacts to migratory birds, by allowing the
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opportunity to make adjustments, such as design modifications, at the site specific level when an
Application for Permit to Drill is received.
Paleontology What are the potential Fossils uncovered during ground disturbing activities would be protected owing to the standard discovery
impacts on the integrity requirements. Additionally, should a parcel be located in an area that has high potential for
of paleontological paleontological resources, COAs would be applied at the APD stage. The proponent is required to notify
resources associated with the BLM of any discoveries they come across during construction following the APD stage.
oil and gas disturbance?
Lands With What are the potential The Monticello RMP, 2008 decision WC-1 (page 85) identified which lands identified at the time as
Wilderness impacts to Lands With having wilderness characteristics would be managed to “Protect, maintain and preserve wilderness
Characteristics Wilderness characteristics.” The inventories current at the time identified three non-contiguous areas adjacent to the
Characteristics? Squaw and Papoose Canyons WSA as possessing wilderness characteristics, These areas are not “stand
alone” units due to being less than 5000 contiguous acres but could increase the size of the WSA,
however the RMP decision was to not manage the units to protect the wilderness characteristics.
Parcel 420, 421, 422 and 423 intersect 1852 Acres of the Squaw and Papoose Canyons Wilderness
Characteristic Units. No existing leases intersect the units.
According to the 2008 MtFO RMP FEIS: “Based on the percentage of non-WSA lands with wilderness
characteristics and the existing and pending leases within those areas, the highest potential for leasing and
development would be in Comb Ridge, Cross Canyon, and Squaw and Papoose Canyon. Given that the
projection for drilling for oil and gas is three wells per year for all of the public lands within the Blanding
Subbasin area, and that just over 9% of the development area includes non-WSA lands with wilderness
characteristics open to leasing under standard stipulations, CSU, or TL stipulations, it is still anticipated
that up to one well per year would be drilled in the non-WSA lands with wilderness characteristics
because the Blanding Sub-basin area contains oil and gas fields and the majority of existing wells within
the Monticello PA. This would disturb up to 9.6 acres per year, or approximately 144 acres over the next
15 years…Leasing and development within these non-WSA lands with wilderness characteristics would
cause the affected portion to lose its natural characteristics. Loss of opportunities for solitude and
primitive recreation due to exploration for and development of oil and gas resources would be broader
than just for the 144 acres of direct surface-disturbing activities, and could impact these values for up to
one-half mile from the ongoing activity. However, it is not anticipated that any of the areas would lose
their wilderness characteristics in totality because of the small amount of acreage projected to be
disturbed and the few projected wells in this development area over the next 15 years.”
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On October 21, 2014, the Southern Utah Wilderness Alliance (SUWA) submitted information
suggesting the presence of wilderness characteristics in the Tin Cup Mesa Central and Monument
Canyon units. BLM conducted an analysis and lands within these units were found to possess wilderness
character (WC) as determined by the Documentation of BLM Wilderness Characteristics Inventory
Findings: The Tin Cup Mesa Unit was found to have 9,743 acres of Wilderness Characteristics, and the
Monument Canyon Unit was found to have 17,200 acres, adding a total of 26,953 acres of identified
acres of WC within the Blanding Subbasin area. At the time the RMP FEIS was prepared, there were
38,540 acres of identified acres of wilderness characteristics, however since that time the Fish and Owl
Creeks, Lime Creek, Road Canyon, San Juan River and Comb Ridge, Unit, consisting of 33,260 acres,
have been incorporated into the Bears Ears National Monument and is no longer available for lease,
leaving 32,233 acres of wilderness characteristics available for lease, or a 20% decrease in lands with
wilderness characteristics within the Blanding Subbasin available for lease. Thus, the RMP FEIS
projection of a total loss of 144 acres of wilderness characteristics with no totality of loss in any one unit
is still valid.
Since the Monument Canyon and Tin Cup Mesa Units were found to possess wilderness characteristics
subsequent to the RMP, they are not subject to RMP decision WC-1 to “Protect, maintain and preserve
wilderness characteristics…” However the March 2018 Oil and Gas Lease EA disclosed the possible
impairment of the Units, and the decision was made to lease several parcels within the units. This lease
sale will increase the acreage leased in both Units, to a total of about 80% leased for the Monument
Canyon Unit and 100% leased for the Tin Cup Mesa Unit. These numbers cannot be extended out to the
projected acres of wilderness characteristics that may be impacted beyond saying that the Units may
experience a decrease of no, some or all of their wilderness characteristics.
National What are the potential On December 13, 2018, staff from the Hovenweep and Natural Bridges National Monuments submitted
Historic impacts to Hovenweep comments on the DNA initially prepared for the parcels considered in this EA. They brought forth the
Trails/Units of National Monument? following concerns for Hovenweep National Monument:
the National 1. Air Quality in the Monument from Ozone production and Dust emissions
Park Service 2. Vibrations from Heavy Equipment on roads in the immediate vicinity of the Monument
3. Viewshed
4. Night Skies
5. Soundscapes
6. Drinking Water Quality
7. Earthquakes Induced from Oil and Gas Activity
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Reason the concerns are not considered in detailed analysis
Concerns 1 and 6:
Air Quality and Drinking Water are statutorily protected, regardless of the concern is inside or outside the
Monument. Air Quality is being analyzed in detail for this proposal, and drinking water sources are
protected through the measures operators must take to prevent contamination of potable aquifers and
surface waters.
Concern 2
The concern that vibrations from heavy equipment could damage historic structures within the
Monument. Again, Sites eligible for inclusion in the National Historic Registry, whether inside or outside
the Monument, are statutorily protected. At the time of development, operators disclose the routes they
propose to use to access their drill sites. At that time, the proximity of the route to any fragile historic
structure can be assessed, and the operator required to find an alternate access route.
Concern 3
The BLM overlayed a GIS viewshed analysis from several points within the Monument. The parcels did
not fall within the viewshed of any of those points (Figure 5. Hovenweep Viewshed The NPS
confirmed the BLM’s findings in an email dated May 17, 2019.
Concerns 4 and 5
A lease notice UT-LN-125 informing the potential lessee of the possible need to use sound and light
reducing measures have been added to all the parcels.
Concern 7
The concern is that earthquakes could be induced from oil and gas activity as has happened in other
regions in the United States, and that the earthquakes would damage sensitive historic structures. As
explained in the Mineral Resources/Energy Production section of Appendix D, induced earthquakes are
unlikely to occur in Utah. More site specifically, there are currently well over a hundred enhanced oil
recovery water injection wells within 25 miles of the Monument on BIA lands. The injection of water
under for oil recovery is much less likely to induce earthquakes as are water disposal wells, as has been
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demonstrated by the lack of induced earthquakes from the highly developed are south west of the
Monument.
Cultural What are the potential The BLM has conducted a literature search using survey and site information from the CURES
Resources impacts from ground geodatabase, Preservation Pro, DAM, GLO maps, and Field Office records to identify currently known
disturbing oil and gas sites within the lease parcels, and to determine whether these sites could be avoided or mitigated through
activities on cultural standard archaeological practices at the APD stage.
resources? The Cultural Resources and Tribal Consultation Stipulation (H 3120-1) is applied across all lease parcels.
This stipulation states that the lease area may be found to contain historic properties and/or resources
protected under the National Historic Preservation Act (NHPA), American Indian Religious Freedom
Act, Native American Graves Protection and Repatriation Act, Executive Order 13007, or other statutes
and executive orders. The BLM will not approve any ground-disturbing activities that may affect any
such properties or resources until it completes its obligations (e.g., State Historic Preservation Officer
(SHPO) and tribal consultation) under applicable requirements of the NHPA and other authorities.
The BLM may require modification to exploration or development proposals to protect such properties,
or disapprove any activity that is likely to result in adverse effects that cannot be successfully avoided,
minimized, or mitigated. Moreover, prior to granting APDs on Federal surface or split-estate lands,
cultural resource inventories are required.
Additional cultural resource analysis was completed in March 2018 EA (BLM 2018).
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1.10 Public Comment Period

The preliminary EA and the unsigned FONSI is subject to a public comment period, which will be held
from May 30, 2019 through July 1, 2019. (Appendix H).
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Chapter 2 Description of Alternatives
2.1 Introduction
This EA addresses two alternatives (Alternative A – Proposed Action and Alternative B – No Action, No
Leasing).
Other alternatives were not considered in detail because the issues identified during scoping or the
alternatives identified during the comment period did not indicate a need for additional alternatives or
protective measures beyond those contained in the Proposed Action. The No Action alternative is
considered and analyzed to provide a baseline for comparison of the impacts of the Proposed Action.
Leasing is an administrative action that does not directly cause environmental consequences. However,
leasing is considered to be an irretrievable commitment of resources because the BLM generally cannot
deny all surface use of a lease unless the lease is issued with a no surface occupancy (NSO) stipulation.
Potential oil and gas exploration and production activities, committed to in a lease sale, could impact
other resources and uses in the planning area. Direct, indirect, or cumulative effects to resources and uses
could result from future levels of lease exploration or development, however these future levels are
uncertain and undetermined.
2.2 Analysis Assumptions
2.2.1 Reasonably Foreseeable Development Scenario
The Reasonably Foreseeable Development Scenario (RFDS) is a planning tool to provide a reasonable
estimate of what oil and gas exploration and development activities might be proposed, should a decision
be made to lease the area. The RFDS is a 20-year forward-looking estimation of oil and gas exploration
and development that is exclusive of other concerns that might compete for use of land in a multiple-use
scenario. The MtFO has classified lands within the district boundary. The parcels are located in San Juan
County, and are classified as high potential for occurrence of oil and gas but with a lower level of
certainty of production. It is estimated that 59 percent of the wells drilled in MtFO will be capable of
production and 41 percent is estimated to be a dry hole. If relevant resource conditions have changed
(e.g., establishment of wells capable of producing oil or gas in paying quantities per 43 CFR 3107.2-3),
the MtFO would re-evaluate the RFDS to address the new geologic information.
Although at this time the BLM does not know when, where, or if future well sites or roads might be
proposed on any leased parcel. Should a lease be issued, site specific analysis of individual wells or roads
would occur when a lease holder submits an APD.
When and if an APD is submitted for any of the leases, BLM would adhere to numerous IMs (as revised
through the life of an active lease) including specific instructions for directional drilling, split estate,
bonding, and other laws (such as NHPA, ESA). Some of these IMs include:
• Approval of Notice of Intent to Conduct Geophysical Exploration to Federal Oil and Gas Lessee
on Split Estate (WO IM 2009-121)
• Cultural Resources Requirements for Split Estate Oil & Gas Development (WO IM-2009-027)
• Split Estate Report to Congress--Implementation of Fluid Mineral Leasing and Land Use
Planning Recommendations (WO IM 2007-165)
• Permitting Oil & Gas on Split Estate Lands (WO IM 2003-131)
• Legal Responsibilities on Split Estate Lands (WO IM 1989-201)
• Directional Drilling into Federal Mineral Estate from Well Pads on Non‑Federal Locations (WO
IM 2018-014).
Management provisions would adhere to the Gold Book best management practices (United States
Department of the Interior and United States Department of Agriculture 2007). In general, activities are
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anticipated to take place as described in Appendix G – Reasonable Foreseeable Development of

Leases Scenario This appendix provide a general discussion of possible post-leasing RFDS activities.
All of these activities would require additional NEPA review when a lease holder submits an APD.
RFDS for the MtFO
The 2005 RFD (BLM 2005) to the MtFO RMP predicted that over 15 years, on average, 3 wells will be
drilled each year. It is recognized there would be some years with less than 3 wells, and some years with
more than 21 wells (Table 4.1 in RMP).
Seismic Activity:
• 1,230 miles of seismic lines for a total disturbance of 2,236 acres
Exploration Activity:
• Anticipate 195 well pads in 15 years
• Average disturbance is projected to be 9.6 acres per well.
• Anticipate 115 producing wells
RFDS Assumption for Analysis in this EA
For the analysis of the 19 nominated parcels encompassing 32,067.42 acres, the MtFO estimated a
maximum of 4 wells 11 would be drilled, and the maximum new disturbance will be 4 wells totaling 38.40
acres (one well pad and access road disturbance at 9.6 acres). This scenario would occur rarely, if at all.
Over the last three years (2015-2018) 12, six wells have been drilled in San Juan County. Out of those six
wells, only 1 well was capable of production. Statistically, it is more probable that three wells would be
drilled for the nominated MtFO parcels.
2.3 Alternative A – Proposed Action

Alternative A would offer for lease the 19 nominated parcels (covering 32,067.42 acres) which have been
proposed for inclusion in this lease sale. The leases would include the standard lease terms and conditions
for development of the surface of oil and gas leases provided in 43 CFR 3100 (BLM Form 3100-11)
along with all stipulations mandated by policy (such as the Competitive Leasing Handbook, H-3120-1)
and by the governing Land Use Plans (LUP). Legal land descriptions along with corresponding
stipulations as well as notices added to address resource issues found through review and analysis that
would be attached to each parcel are located within Appendix A – Parcel List with Stipulations and
Notices. All stipulations from the governing LUP(s) and necessary notices being applied to the parcels
are detailed in Appendix B – Stipulations and Notices. The parcel acreages would be offered for sale in
the following categories:
Open (Category 1 – Standard Lease Terms) 29,799.69 acres
Controlled Surface Use/Timing Limitations (Category 2 – Moderate Constraints) 1,884.40 acres
No Surface Occupancy (Category 3 – Major Constraints) 383.31 acres
11
The RMP (page 4-112) states 42 wells on federally managed subsurface encompassing 405, 664 acres would be
drilled over the next 15 years. Approximately, only 31 percent could be capable of production in this area. The
nominated parcels cover 32,067.42 acres which is 8 percent of the area. The RFD calculation was
(405,664/32,067.42) equaling 8 percent. Then 8 percent of the 42 wells equaling 4 wells for all the 19 nominated
parcels.
12
Statistical information can be found on Utah Division of Oil, Gas and Mining website.
https://oilgas.ogm.utah.gov/oilgasweb/statistics/spuds-by-cnty.xhtml
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Areas offered for oil and gas leasing would be subject to measures necessary to mitigate adverse impacts,
according to the categories, terms, conditions, and stipulations identified in the land use plans, as
amended.
BLM regulations at 43 CFR 3101.1-2 allow for the relocation of proposed oil and gas leasing operations
up to 200 meters and/or timing limitations up to 60 days to provide additional protection to ensure that
proposed operations minimize adverse impacts to resources, uses, and users.
Additional measures would be applied to some leases to further protect specific resources (Appendices A
and Appendix B – Stipulations and Notices). In addition to the stipulations provided for by the
governing LUPs (as amended) and BLM policies, Lease Notices have been developed for conservation
measures and would be applied on specific parcels as warranted by subsequent IDPRT review. The
addition of prescribed notices would be applied to all leasing categories detailed in Appendix B –
Stipulations and Notices
At the leasing stage it is uncertain whether development on all leased parcels will move forward;
however, for the purposes of this analysis, and in order to assess potential impacts, Reasonably
Foreseeable Development (RFD) is assumed wherein all 19 nominated parcels will be developed. The
Reasonably Foreseeable Development used for analysis assumptions under this alternative is described in
Section 2.2.1.
2.4 Alternative B – No Action
The No Action Alternative would not offer any of the nominated parcels in the lease sale. The parcels
could be considered for inclusion in future lease sales. Surface management would remain the same and
ongoing oil and gas development would continue on surrounding private, state, and existing federal
leases.
2.5 Other Alternatives Considered but Not Analyzed in Detail
Other alternatives to the Proposed Action were not identified that would meet the purpose and need of
agency action.
The Interior Board of Land Appeals has held that subsumed in a no action alternative is consideration of
not leasing any or all parcels (Biodiversity Conservation Alliance et al., 183 IBLA 97, 124 (2013)). The
No Action alternative allows the authorized officer to resolve resource conflicts by deferring or removing
parcels from the lease sale, before offering those parcels for sale. The alternatives carried forward
represent those necessary for a reasoned choice (40 CFR 1502.14) and are based on the issues that were
identified by the IDPRT.
2.5.1 No Leasing Alternative (Designating the Parcels as Closed to Leasing)
A no leasing alternative was considered but eliminated because it is inconsistent with the management
plans for the area, and therefore is outside the purpose and need of this EA. This alternative would require
a RMP Plan Amendment because the areas in question were found suitable for leasing by the governing
RMPs and preceding management plans. The RMPs as amended also identified the lands as available for
leasing subject to a range of constraints, and reject a no leasing alternative. This alternative was dismissed
from detailed consideration.
2.5.2 Deferring Specific Parcels from the Sale
Since each parcel is an independent, though similar, action the BLM at the end of the EA process could
choose to either lease or defer any parcel in the EA’s decision record. Therefore this alternative to defer
for specific resource concerns was not considered in detail because it is substantially a combination of the
proposed action and no action and does not improve the range of alternatives. Offering or deferring any
particular parcel in this EA is within the range of alternatives already considered in detail in this EA, and
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can be implemented at the discretion of the Authorized Officer, as the need is identified in the NEPA
analysis.
2.5.3 Adding Stipulations Beyond those Required by the Management Plan
This alternative to add additional stipulations beyond those identified by the applicable Management Plan
to the nominated parcels was not considered in detail because it would require a plan amendment, which
is outside the scope of this EA. A plan maintenance was done to the Monticello RMP (BLM 2017)
Maintenance Change 102 to adopt the Moab MLP notices. Therefore, those notices in the MLP can be
applied to the parcels in Appendix A – Parcel List with Stipulations and Notices. However, deferral of
any particular parcel due to unresolved resource conflicts is within the range of alternatives considered in
detail in this EA, and can be implemented at the discretion of the Authorized Officer, or as the need is
identified in the NEPA analysis.
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Chapter 3 Affected Environment
3.1 Introduction
This chapter presents the potentially affected existing environment (i.e., the physical, biological, social,
and economic values and resources) of the impact area as identified in the IDPRT Checklist as found in
Appendix D and introduced in Chapter 1 of this EA. Only those aspects of the affected environment that
are potentially impacted are described in detail. Only those aspects of the affected environment related to
the issues presented in Table 1 and discloses any potential direct, indirect and cumulative impacts on the
resources identified as issues. Once issues are identified, impact indicators are selected to assess the
impacts of alternatives and are used as a basis for future monitoring (Table 1).
The CEQ Regulations state that NEPA documents “must concentrate on the issues that are truly
significant to the action in question, rather than amassing needless detail” (40 CFR 1500.1(b)). While
many issues may arise during scoping, not all of the issues raised warrant analysis in an EA. Issues will
be analyzed if: 1) an analysis of the issue is necessary to make a reasoned choice between alternatives; or
2) if the issue is associated with a significant direct, indirect, or cumulative impact, or where analysis is
necessary to determine the significance of the impacts. To see which resources were determined to not be
present or not expected to be impacted by the Proposed Action please refer to Appendix D.
Assumptions for analysis
The act of leasing nominated parcels in and of itself would have no immediate impacts on resources in the
Monticello Field Office. However, for the purposes of this analysis, a framework of RFD is assumed
wherein all parcels under each alternative are leased and developed.
While an appropriate level of NEPA for wells or roads would occur when a leaseholder submits an APD,
reasonable development assumptions for lease development will be used in the analysis of impacts in this
EA to inform the decision since leasing results in a commitment resources unless the lease is allowed to
expire without development.
Cumulative impacts include the combined effect of past projects, ongoing projects, and other reasonably
foreseeable future actions.
3.2 General Setting

Currently the MtFO has 243,736 authorized leased acres 13 (Table 3). The Monticello Field Office RMP,
as amended by the GRSG ARMPA (BLM 2015 and 2019) designates 432,296 acres in the planning area
as open to leasing with standard stipulations where approximately 23% (99,051 acres) have been leased.
An additional 586,736 acres are open to leasing with moderate stipulations (CSU/TL) where
approximately 16% (92,143 acres) have been leased. Major stipulations, such as No Surface Occupancy
(NSO), has been designated across 82,216 acres and approximately 18% (14,553 acres) of these acres
have been leased. The September 2019 lease sale would make approximately an additional 6% (27,896
acres) acres with standard stipulations, < 1% (2,005 acres) acres with moderate stipulations, and no acres
with major stipulations available for leasing. Currently there are 243,736 leased acres within the MtFO
boundary and the lease sale would make an additional 32,067 acres available for lease. If all parcels are
13
ArcGIS data displaying land status by surface management agency and existing oil and gas leases on federal lands
can be found at: https://bit.ly/2Uy8TpF.
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sold in the lease sale then total leased acres for the MtFO would cumulatively increase to 275,803 acres or
25% leased acres. This would be a cumulative increase of 3% compared to current leased acres (Table 3).
The State of Utah School and Institutional Trust Lands Administration (STILA) held a competitive
mineral lease offerings in January 2019 which offered 20 leases located in San Juan County. Only 8
leases (40 percent) were acquired. These parcels are not adjacent or approximate to the 19 public-
nominated parcels analyzed in this EA.
Table 3. Leasing Category Acreages for Monticello Field Office.

Authorized Sept 2019 % Sept 2019
Designated % Leased Proposed
Leasing Category Lease Proposed
Acres Acres Acres
Acres1 Acres
432,296 99,051 23% 27,896 6%

Standard Stipulations (Open)
586,736 92,143 16% 2,005 < 1%

Moderate Stipulations (CSU and TL)
82,216 14,553 18% 0 0%

Major Stipulations (NSO)
NA 37,754 NA 2,1664 NA
No Leasing Decision Category
682,286 235 NA 0 0
Closed2
1,101,2483 243,736 22% 32,067 3%

TOTAL
1
Leased acres are calculated as of March 2019 and include the previous NCLS lease sale acres sold on March 25 -
26, 2019. Acres calculated using GIS data and are therefore a close approximation of actual leased acres. All
calculations were rounded to the nearest whole number.
2
Authorized leases, held by production.
3
Designated acres total only includes the leasable designated acres and excludes the 682,286 closed acres.
4
Surface is private ownership.
The proposed action would result in additional leasing of 32,067.42 acres in San Juan County. 14
Table 4. Leasing Category Acreages by Parcel.
Number Standard Moderate Major Acreage Private Federal
Stipulations Constraints Constraints Total Surface Surface
(CSU/TL) 15 (NSO)
406 2,232.30 - - 2,232.30 120.23 2,112.07
407 2,227.00 - - 2,227.00 160.56 2,066.44
14
Calculations of acreages leased were calculated from GIS Utah Oil and Gas Lease layer. The acreages are subject
to change.
15
The BLM approved a land use plan amendment that added leasing stipulations for important resources, such as
wildlife species. The planning area encompasses the parcels included in this lease sale. The amendment categorized
these parcels as "open, with special stipulations," which is equivalent to "moderate constraints (CSU/TL)." These
stipulations would only apply to those portions of the parcels that have the resource present.
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Number Standard Moderate Major Acreage Private Federal

Stipulations Constraints Constraints Total Surface Surface
(CSU/TL) 15 (NSO)
408 1,741.30 - - 1,741.30 - 1,741.30
409 480.00 1,440.00 - 1,920.00 - 1,920.00
410 1,533.25 - 383.31 1,916.56 - 1,916.56
411 1,280.00 - - 1,280.00 - 1,280.00

412 1,920.00 - - 1,920.00 - 1,920.00
413 241.64 - - 241.64 241.64 -
414 1,373.21 444.40 - 1,817.61 40.00 1,777.61
415 1,600.00 - - 1,600.00 321.43 1,278.57
416 1,600.00 - - 1,600.00 - 1,600.00
417 1,320.00 - - 1,320.00 - 1,320.00
418 1,440.00 - - 1,440.00 79.20 1,360.80
419 1,600.00 - - 1,600.00 199.14 1,400.86
420 1,129.95 - - 1,129.95 - 1,129.95
421 2,480.56 - - 2,480.56 319.37 2,161.19
422 1,840.00 - - 1,840.00 558.26 1,281.74
423 1,840.48 - - 1,840.50 - 1,840.48
424 1,920.00 - - 1,920.00 - 1,920.00
Total 29,799.690 1,884.40 383.31 32,067.42 2,039.83 30.027.57
CSU = Controlled Surface Use, TL = Timing Limitations, NSO = No Surface Occupancy
3.3 Resources/Issues Brought Forward for Analysis

The affected environment of the proposed action and no action alternatives, and their potential
environmental effects were considered and analyzed by the IDPRT as documented in the IDPRT
Checklist, Appendix D – Interdisciplinary Parcel Review Team Checklist The checklist indicates
which resources of concern are either not present in the project area or would not be impacted to a degree
that requires detailed analysis. Resources which could be impacted to a level requiring further analysis are
described in this chapter and impacts to these resources are analyzed below.
3.3.1 Issue 1: What are the Potential Impacts to Air Quality
3.3.1.1 Affected Environment
Additional information on air quality in this leasing area is contained in the 2018 BLM Utah Air
Monitoring Report (AMR) (BLM 2019) and the Monticello Field Office RMP (BLM 2008) to which this
analysis tiers and incorporates by reference. This document summarizes technical information related to
air resources and includes the methodology and assumptions used for analysis.
Air Quality
The Environmental Protection Agency (EPA) has the primary responsibility for regulating air quality,
including six nationally regulated ambient air pollutants including carbon monoxide (CO), nitrogen
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dioxide (NO2), ozone (O3), particulate matter (PM10 & PM2.5), sulfur dioxide (SO2) and lead (Pb). EPA
has established National Ambient Air Quality Standards (NAAQS) for criteria pollutants (Section 2.2.1,
AMR). The NAAQS are protective of human health and the environment. Compliance with the NAAQS
is typically demonstrated by monitoring for ground-level atmospheric air pollutant concentrations. All
areas within the Monticello Field Office are currently designated by the EPA as attainment or
unclassifiable for all NAAQS pollutants.
Air quality in a given region can be measured by its Air Quality Index value (AQI). The AQI is reported
according to a 500-point scale for each of the major criteria air pollutants, with the worst denominator
determining the ranking. For example, if an area has a CO value of 132 on a given day and all other
pollutants are below 50, the AQI for that day would be 132. The AQI scale breaks down into six
categories: good (AQI<50), moderate (50-100), unhealthy for sensitive groups (100-150), unhealthy
(>150), very unhealthy and hazardous. The AQI is a national index, therefore the air quality rating and the
associated level of health concern is the same throughout the country. The AQI is an important indicator
for populations sensitive to air quality changes (USEPA, 2018c).
When the AQI value is in the good range, pollutant concentrations are well below the NAAQS and air
pollution poses little or no risk. Moderate AQI values occur when pollution is below but near the NAAQS
and voluntary emission reduction measures are encouraged. The AQI is considered unhealthy when the
NAAQS is exceeded and major pollution sources are often required to implement mandatory emission
reduction measures. Counties without AQI data usually have fewer air pollutant sources and are assumed
to have good air quality.
AQI data for San Juan County is presented in Table 5. At least 81% of days were rated as good, with only
one day rated as unhealthy during the 2015-2017 timeframe. The pollutants primarily determining the
AQI over the three year period were ozone and PM2.5. Additional AQI data for the rest of the state is
provided in the AMR (BLM 2019).
Table 5. AQI Index Summary Statistics by County
# of Days When AQI was… % of Days Rated …

# Days
County with AQI Good Moderate Unhealthy Good Moderate Unhealthy
San Juan County, UT 1058 852 205 1 81% 19% 0%
Ozone and PM2.5 are identified in the AQI data as the primary pollutants determining air quality in the
area. Air pollutant concentrations can be reported using design values. A design value is a statistic that
describes the air quality status of a given location relative to the level of the National Ambient Air Quality
Standards (NAAQS). Design values are typically used to designate and classify nonattainment areas, as
well as to assess progress towards meeting the NAAQS. Design values are provided in Table 6. No design
value for PM2.5 is reported for San Juan County, so values from the nearest representative county (Mesa
County, CO) is presented. Reported ozone and PM2.5 concentrations are below the NAAQS.
Table 6. 2015-2017 Criteria Pollutant Design Values
Pollutant Location Averaging Time Concentration NAAQS
O3 San Juan County 8-hour 0.064 ppm 0.070 ppm
PM2.5 Mesa County, CO Annual 6.1 µg/m3 12.0 µg/m3
PM2.5 Mesa County, CO 24-hour 19 µg/m3 35 µg/m3
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The Utah Division of Air Quality (DAQ) compiles statewide emission inventories to assess the level of
pollutants released into the air from various sources. The latest inventory is summarized in the AMR
(BLM 2019), and in Table 7. Only emissions from San Juan County are listed since this is where lease
parcels are located. On-road mobile sources are the highest human emission source for CO and NOx, with
area source the highest for PM, and oil and gas sources the highest emitters of SOx, and VOCs.
Table 7. 2014 Criteria Air Pollutant Emissions (tpy) by Source for San Juan County
Source CO NOx PM10 PM2.5 SOx VOCs
Area Sources 384.42 649.79 4,252.57 524.24 2.72 218.46
Area Sources Oil and

296.09 199.29 2.39 2.38 0.93 11,840.05
Gas
Non-Road Mobile 1,718.66 103.03 21.12 19.67 0.42 535.85
On-Road Mobile 1,551.00 747.70 239.52 78.86 2.89 153.20
Point Sources 240.37 357.52 234.93 88.63 505.93 60.30
Biogenics 15,795.81 0.00 0.00 0.00 0.00 72,896.61
Wildfires 1.35 0.04 0.16 0.15 0.00 0.23
County Total 19,987.7 2,057.37 4,750.69 713.93 512.89 85,704.70
Hazardous air pollutants (HAPs) are known or suspected to cause cancer or other serious health effects, or
adverse environmental effects, so they are also regulated by the EPA. Examples of listed HAPs emitted
by the oil and gas industry include benzene, toluene, ethyl benzene, mixed xylenes, formaldehyde,
normal-hexane, acetaldehyde, and methanol. A list of HAP point source emissions by County is published
by the Utah Division of Air Quality (UDAQ 2018), and is incorporated by reference. A summary of
existing HAP emissions in San Juan County is presented in Table 8.
Table 8. Triennial Inventory of HAPs (2014).
HAPS (tpy) San Juan
County
Benzene 3.525
Toluene 0.745
Ethylbenzene 0.044
Xylenes 0.121
n-Hexane 0.954
Formaldehyde 0.242
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HAPS (tpy) San Juan

County
Acetaldehyde 0.001
Naphthalene 0.001
The parcels in this lease sale occur within Prevention of Significant Deterioration Class II areas and do
not occur adjacent to National Parks or other sensitive areas. The closest Class I areas are Canyonlands
and Mesa Verde National Parks to the northwest and southeast respectively. Lease parcels are farther than
50 kilometers (approximately 30 miles) from the Class I area, which is the transition point from near-field
to far-field analysis. Additional Air Quality Related Values (AQRVs) include visual air quality (haze),
and acid (nitrogen and sulfur) deposition. AQRVs do not have threshold standards, but Federal land
managers have identified levels of concern. Current visibility and deposition information for nearby Class
I areas is summarized in the AMR (BLM 2019).
3.3.1.2 Environmental Consequences
Impacts of the Proposed Action
Leasing the subject tracts would have no direct impacts to air quality. Any potential effects to air quality
from the sale of lease parcels would occur at such time that any issued leases are developed. Please note,
this proposed action does not authorize or guarantee specific development scenarios. If leased, drilling of
wells on a lease would not be permitted until the BLM approves an Application for Permit to Drill (APD).
Any APDs received would be subject to additional site specific NEPA review. However development
assumptions have been made in this EA to inform the decision since an issued lease must be developed to
keep it from expiring. This discussion remains qualitative as variations in emission control technologies
as well as construction, drilling, and production technologies used by various operators make it difficult
to accurately estimate potential air quality impacts from modeling at this time. Well development would
likely be exploratory and impacts from construction and drilling would be temporary or short-term and
would cease after the associated activities.
During well development, there could be emissions from earth-moving equipment, vehicle traffic,
drilling, and completion activities. NO2, SO2, and CO would be emitted from vehicle tailpipes. Fugitive
dust concentrations would increase with additional vehicle traffic on unpaved roads and from wind
erosion in areas of soil disturbance. Drill rig and fracturing engine operations would result mainly in NO2
and CO emissions, with lesser amounts of SO2. These temporary emissions would be short-term during
the drilling and completion times.
During well production there could be continuous emissions from separators, condensate storage tanks,
and daily tailpipe and fugitive dust emissions from operations traffic. During the operational phase of the
Proposed Action, NO2, CO, VOC, and HAP emissions would result from the long-term operation of
condensate storage tank vents, and well pad separators. Additionally, road dust (PM10 and PM2.5) would
be produced by vehicles servicing the wells.
An emissions inventory (EI) estimate for an oil and gas well for this lease sale is shown in Table 9. Due
to the very small level of anticipated development and lack of information regarding potential emissions
control technologies an operator may use, the EI is based on the following assumptions:
• Each oil and gas well would cause 6.8 acres of surface disturbance. This acreage includes access.
• Construction activity for each well is assumed to be 10 days. It is further assumed that, based on
the acreage disturbed, 4.5 days would be spent in well pad construction and 5.5 days would be
spent in road and pipeline construction.
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• Control efficiency of 25% for dust suppression would be achieved as a result of compliance with
Utah Air Quality regulation R307-205.
• Post construction particulate matter (dust) emissions are likely to occur on a short term basis due
to loss of vegetation within the construction and staging areas. Assuming appropriate interim
reclamation, these emissions are likely to be minimal to negligible and will not be considered in
this EA.
• Drilling operations would require 14 days.
• Completions and testing operations would require 3 days.
• Off-road mobile exhaust emissions from heavy equipment during construction activities and on-
road mobile emissions would not be considered as they are dispersed, sporadic, temporary, and
not likely to cause or contribute to exceedances of the NAAQS.
Table 9. Emissions Inventory Estimate.
1 2 3 4
PM10 NOX CO VOC VOC NOX CO PM10 NOX CO VOC PM10
O&G Well 0.34 13.31 1.83 0.23 0.85 0.07 0.07 0.00 0.11 0.09 6.44 0.07
PM10 NOX CO VOC

Activity
0.34 13.37 1.89 1.08
(5) Tons
Production
6.44 0.11 0.09 0.07
(6) tpy
1 - Construction Emissions (Tons)
2 - Drilling Emissions (Tons)
3 - Completions Emissions (Tons)
4 - Ongoing Production Emissions (Tons/Year)
5 - Activity Emissions (Total emissions for drilling and completion the well)
6 - Production Emissions (Ongoing annual emissions for the well)
Emission factors for activities of the proposed action were based on and production emissions from oil storage
tanks was estimated based on information available at: https://www.epa.gov/air-emissions-factors-and-
quantification/ap-42-compilation-air-emission-factors.
Emissions from a well would include particulate matter of less than 10 micrometers in diameter (PM10),
nitrogen oxides (NOX), carbon monoxide (CO), and volatile organic compounds (VOCs). Emissions of
sulfur dioxide (SO2) and lead (Pb) from oil and gas development activities are minor and are not included.
PM2.5 is not specifically included as it is a component of PM10.
Emission factors for activities of the proposed action were based on information contained in the EPA’s
Emission Factors & AP 42, Volume I, Fifth Edition (EPA 1995). Production emissions from oil storage
tanks were estimated based on the emission factor contained in the Colorado Department of Public Health
and Environment PS Memo 05-01, Oil & Gas Atmospheric Condensate Storage Tank Batteries
Regulatory Definitions and Permitting Guidance (APCD 2017)
For total foreseeable emissions, multiply the amounts in the table by the total number of foreseeable wells
(4). However, it is not reasonable to assume that all wells will be drilled in a single year because the
lessee has 10 years to establish production on a lease, and historically most leases never have production
attempted or established 16. If production is not attempted within the 10 year timeframe, the lease will be
16
See GAO’s October 2008 finding that for leases issued from 1987 through 1996, development occurred on 6% of
onshore leases and production was achieved on 5%. https://www.gao.gov/new.items/d0974.pdf
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terminated with no development or production emissions occurring. If production is not established

within the 10 year timeframe, the lease will be terminated with no production emissions occurring.
Based on the emissions estimates contained in Table 9, the area being in compliance with all NAAQS,
and considering the location of the parcels relative to population centers and Class I areas, substantial air
resource impacts are not anticipated as a result of this leasing action, and no further analysis or modeling
is warranted for the leasing decision. Emissions resulting from the sale of these parcels are not likely to
result in major impacts to air quality nor are they likely to cause a violation of the NAAQS. As identified
in notice UT-LN-102 additional analysis may be required when parcels are developed.
Potential impacts to visibility to Arches and Canyonlands National Parks was analyzed for the Cane
Creek Project (Golder 2010). The VISCREEN model was used to assess the change in color difference
index (ΔE) and plume contrast (C) against the background sky and terrain. In every case the VISCREEN
results were less than the default criteria, indicating no adverse effect on visibility from the proposed
projects to the two National Parks. Visibility impacts to Class I areas from potential development from
this lease sales are likely to be less than those identified for the Cane Creek Project since parcels are much
farther from the National Parks.
If exploration occurs, short-term impacts would be stabilized or managed rapidly (within two to five
years) and long-term impacts are those that would substantially remain for more than five years.
Impacts of the No Alternative Action
Under the No Action Alternative, BLM would continue to manage these lands based on the objectives
outlined in their class categories. No new attendant infrastructure associated with oil and gas development
would be built under the No Action Alternative. No new emissions of pollutants would occur.
3.3.1.3 Required Design Features
Application Stipulations UT-S-01 and Notices UT-LN-96, UT-LN-99, UT-LN-101 and UT-LN-102
would be adequate for the leasing stage to disclose potential future restrictions and to facilitate the
reduction of potential impacts.
The BLM does look to mitigate pollutants via lease stipulations and notices and further NEPA actions
throughout the lease process. Stipulations and notices would be applied to leases when issued to notify the
operator of what would be required (stipulation) and what could potentially be required (notice) at the
APD stage. This allows the potential lessee, at the time of bidding on the parcel, to be informed of the
range of requirements that could be expect when lease rights are exercised. Additional air quality control
measures may be warranted and imposed at the APD stage (such as mitigation measures, best
management practices, and an air emissions inventory). The BLM would do this in coordination with the
EPA, UDAQ and other agencies that have jurisdiction on air quality. By applying stipulations and
notices, leasing would have little impact on air quality. At the APD stage, further conditions of approval
(COAs) could be applied based on the environmental analysis for the APD. These control measures are
dependent on future regional modeling studies or other analysis or changes in regulatory standards.
Application of these notices would be sufficient to notify the lease holder of additional air quality control
measures that are necessary to ensure protection and maintenance of the NAAQS.
The BLM requires industry to incorporate and implement BMPs, which are designed to reduce impacts to
air quality by reducing emissions, surface disturbances, and dust from field production and operations.
Typical measures include: adherence to BLM’s waste prevention regulations, flare hydrocarbon gases at
high temperatures to reduce emissions of incomplete combustion; water dirt roads during periods of high
use to reduce fugitive dust emissions; collocate wells and production facilities to reduce new surface
disturbance; implementation of directional drilling and horizontal completion technologies whereby one
well provides access to petroleum resources that would normally require the drilling of several vertical
wellbores; suggest that vapor recovery systems be maintained and functional in areas where petroleum
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liquids are stored; and perform interim reclamation to revegetate areas of the pad not required for
production facilities and to reduce the amount of dust from the pads.
In addition, the BLM encourages industry to participate in the Gas STAR program that is administered by
EPA. The Natural Gas STAR program is a flexible, voluntary partnership that encourages oil and natural
gas companies to adopt proven, cost-effective technologies and practices that improve operational
efficiency and reduce natural gas emissions. The EPA has promulgated air quality regulations for
completion of hydraulically fractured gas wells. These rules require air pollution mitigation measures that
reduce the emissions of volatile organic compounds during gas well completions.
Southeastern Utah has been identified as an area susceptible to wind erosion (Duniway et. al 2019). BMPs
to reduce fugitive dust include use of speed mitigation techniques, use of over-sized or low pressure tires,
directional drilling to reduce the number of well pads, and application of soil stabilization techniques
(Duniway et. al 2019).
3.3.1.4 Cumulative Impacts
The cumulative impact analysis area (CIAA) for air quality is Southeast Utah, specifically San Juan
County. The CIAA also includes regional Class I areas and other environmentally sensitive areas (e.g.,
national parks and monuments, wilderness areas, etc.) nearest to the parcels. No recent cumulative
modeling analysis has been performed for the CIAA area. However, modeling domains from the Moab
MLP (BLM 2016) and BLM’s Air Resource Management Strategy (ARMS) Modeling Project (BLM
2014) overlap with the CIAA. While emissions from lease parcels were not included in these analysis, the
RFD for the lease sale is a tiny fraction of the total wells analyzed in the modeling. As a result these
modeling analysis provide a reference for potential cumulative impacts due to regional oil and gas
development. It is important to note that the ARMS model performance evaluation of ozone indicated a
negative model bias (under predicts) during the winter and a positive model bias (over predict) during the
summer in the 4 km domain. The model performance evaluation for PM2.5, indicated a negative model
bias (under predict) throughout the year in the 4 km domain (BLM 2014).
Emissions
Past and present actions that have affected and would likely continue to affect air quality in the CIAA
include surface disturbance resulting from oil and gas development and associated infrastructure,
geophysical exploration, ranching and livestock grazing, range improvements, recreation (including OHV
use), authorization of ROWs for utilities and other uses, and road development. Past and present actions
in CIAA that have affected and would likely continue to affect air quality are too numerous to list here
but would include the development of power plants; the development of energy sources such as oil, gas,
and coal; the development of highways and roads; and the development of various industries that emit
pollutants. These types of actions and activities can reduce air quality through emissions of criteria
pollutants (including fugitive dust), VOCs, and HAPs, as well as contribute to deposition impacts and to a
reduction in visibility.
Past, present, and reasonably foreseeable oil and gas development is listed in the Utah Division of Oil Gas
and Mining’s Well Counts statistical report (UDOGM 2018). At the end of 2018 there were 719 active
producing wells (mostly tribal wells) in San Juan County. This number is down from 767 producing wells
when the Monticello RMP was approved, and down from 754 producing wells during the 2014 emission
inventory year. Emissions from the 5 wells estimated for this lease sale would add to the emissions from
the existing 719 wells. However, total oil and gas emissions are anticipated to be lower than those listed
Table 7.
The Moab MLP analysis included far-field modeling to evaluate impacts on NAAQS and AQRVs from
multiple sources over the entire MLP area. Technical details for this modeling are incorporated from
Appendix F of the MLP FEIS. The modeling analysis evaluated three scenarios based on the range of
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alternatives in the MLP FEIS. Modeling results show no exceedances of the NAAQS for any pollutant for
any of the modeled scenarios (BLM 2016). Emissions from this lease sale would slightly increase
modeled concentrations, but pollutant concentrations are likely to remain below the NAAQS due to the
low RFD.
In Class I and Class II areas outside the Uinta Basin ARMS study area, O3 concentrations are highest
during the summer period (BLM 2014). The ARMS model determined that in the 2021 future year, all
assessment areas are within the applicable PSD increments for annual NO2, 3-hour SO2, annual SO2, and
annual PM10, while most assessment areas exceed the 24-hour PM2.5 and PM10 PSD increment (BLM
2014). Figure 1 shows that the ARMS predicted ozone design values for the CIAA are below the
NAAQS, with concentrations generally between 0.055 to 0.065 ppm. However, areas near Arches and
Canyonlands National Parks are approaching the NAAQS standard of 0.070 ppm. The modeling results
are likely conservative due to the over prediction of summertime O3 in the ARMS model and due to
background levels listed in Table 6 being 0.064 ppm. If background O3 levels rise additional analysis may
be needed when plans of development are submitted for the lease parcels. Exceedances of the O3 NAAQS
occur outside the CIAA in the Uinta Basin and Salt Lake City metropolitan area. Predicted PM2.5 design
values are shown in Figure 2, with annual concentrations in the CIAA generally in the 4-8 µg/m3 range.
Although a hotspot is identified near the town of Blanding, with concentrations nearing the NAAQS. This
area is identified as being susceptible to wind erosion (Duniway et. al 2019), so implementation of dust
mitigation BMP’s is important for keeping PM concentrations down.
Figure 1. ARMS predicted ozone design values with on the books controls for oil and gas emissions
in the year 2021.
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Figure 2. ARMS predicted PM2.5 design values with on the books controls for oil and gas emissions
in the year 2021.
In 2013, the WRAP WestJump Air Quality Modeling Study was completed (WRAP 2013)This study was
intended to initiate the next generation of regional technical analysis and support for ozone transport and
attainment demonstrations for the intermountain West. The project incorporated all of the recent western
modeling analyses into a single modeling database, and went through a comprehensive model
performance evaluation in an open technical forum independent of any specific project or regulatory
activity. One of the functions of the modeling platform is the ability to perform a comprehensive source
apportionment analysis to evaluate local source, western regional, natural and international impacts of
elevated ozone impacts (both rural and urban) across the west and at specific locations within the
modeling domain.
For purposes of the analysis for the MLP EIS, Canyonlands National Park was chosen as a source
receptor to evaluate both local and regional emission sources impacts on ozone, PM2.5, and visibility.
The WestJump source apportionment tool was used to specify source contributions by type; for instance
mobile, point, oil and gas and fires. Mobile sources (cars and trucks) make up the largest single source
category, followed by natural sources (primarily vegetative volatile organic compound [VOC] emissions),
and point sources (e.g., power plants). Oil and gas emissions account for less than 1 percent of the
regional source category emissions (WRAP 2013).
Based on the relatively minor levels of emissions associated with this proposed development, and the
application of BMPs, it is unlikely emissions from any subsequent development of the proposed leases
would contribute to regional ozone formation in the project area, nor is it likely to contribute or cause
exceedances of any NAAQS. Other emission contributors would continue at present rates such as
construction, urban development, and personal vehicle use.
Exceptional events such as a dust storm or major large wildfires could result in very high PM10 values
across the area. Data of such events would likely be reviewed by the EPA under the exceptional event
rules.
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Air Quality Related Values

The MLP analyzed changes to visibility conditions by modeling the number of days there was a change in
deciviews, which is a unit of measurement to quantify human perception of visibility. It is derived from
the natural logarithm of atmospheric light extinction coefficient. One (1) deciview is roughly the smallest
change in visibility (haze) that is barely perceptible. Modeled visibility impacts ranged from greater than
0.5 dv impacts on almost half the year (159 days) at Canyonlands National Park during the 2008
meteorological year for the high emissions scenario, to no visibility impacts greater than 1.0 dv at any
park for any meteorological year under the low emissions scenario. Coarse particulate (PM10), primarily
road dust from truck traffic on unpaved roads, was the dominate pollutant of concern under both high and
medium emissions scenarios. Under the low emissions scenarios nitrogen oxides play a greater role in
visibility impacts. The specific meteorological year used in the analysis also had a significant influence on
modeled impacts. Meteorology in 2008 had substantially greater levels of impacts across the board
compared to the previous two years of meteorological data. This indicates sensitivity to meteorological
variability, and given the large role particulates play, adverse visibility impacts can most likely be tied to
drier, hotter, and/or windier conditions (BLM 2016). Development of lease sale parcels would slightly
increase the impacts to visibility, but are not likely to be perceptible.
All MLP modeled values of sulfur and nitrogen deposition were near or below the Deposition Analysis
Thresholds of 0.005 kg/ha/yr for total nitrogen and total sulfur for all the modeled alternatives, with the
exception of the high and medium emissions scenarios for nitrogen deposition in Arches and
Canyonlands National Park for the 2008 meteorological year (BLM 2016). Development of lease parcels
has the potential to slightly add to the deposition rate.
The proposed action, in concert with other past, present, and reasonably foreseeable actions may
contribute to an increase of emissions through direct and indirect impacts, but it would not be expected to
increase cumulative effects to levels that would compromise the viability of air quality within or near the
CIAA. Visibility and deposition conditions in Class I and Class II areas would follow current trends as
described in the AMR (BLM 2019).
Hazardous Air Pollutants
The Past and present projects which contribute HAPs to the CIAA are detailed in the Utah Division of Air
Quality’s 2014 Point Source Emissions Inventory (UDAQ 2018). The BLM is unaware of any foreseeable
point source projects. The 2014 Triennial Inventory of HAPs (cumulative inventory of point source
HAPs) for the project area is summarized in Table 8. The EPA has determined that for the cumulative
impact area the total cancer risk is 13 to 19 in 1 million (EPA 2019). This cancer risk is within the
acceptable range of risk published by the EPA of 1 to 100 in a million as discussed in the National
Contingency Plan, 40 CFR 300.430.
The proposed action of leasing would not directly contribute to cumulative HAPs emissions or cancer
risk. Future potential development of the leases would contribute to HAPs emissions and cancer risk.
However, the HAPs emission contribution is not meaningful in the context of point source emissions
ongoing in the CIAA.
The No Action alternative would not contribute to criteria pollutant emissions, HAP emissions, or AQRV
impacts because the leases would not be issued and no development could occur.
3.3.2 Issue 2: What are the Potential Impacts of Oil and Gas Leasing to Climate
Change/Greenhouse Gases?
3.3.2.1 Affected Environment
Climate is the composite of generally prevailing weather conditions of a particular region throughout the
year, averaged over a series of years such as temperature and precipitation. The 2018 BLM Utah Air
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Monitoring Report (BLM 2019) discusses the current climate conditions in Utah, and is incorporated by
reference. The report presents the three-decade average and trends of temperature and precipitation for
each of the seven climate divisions in Utah.
Parcels included in this lease sale are within the Southeast Utah climate divisions. The Southeast climate
division on generally has warmer and drier conditions than the other climate divisions in Utah. Average
annual temperature and precipitation information for the climate division is presented in Table 10.
Additional details on climate in the leasing area and the rest of Utah are provided in the 2018 BLM Utah
Air Monitoring Report (BLM 2019).
Table 10. Climate Trends
1895-2017 Mean 1981-2010 Trend
Climate Division Temp (ºF) Precip (in.) Temp (ºF) Precip (in.)
7, Southeast 51.5 9.8 + 0.5 -0.51
In November 2018 the Fourth National Climate Assessment (NCA4) Volume II was published.
Compared to previous reports, NCA4 provides greater detail on regional scales as impacts and adaptation
tend to be realized at a more local level. The Southwest region (Arizona, California, Colorado, New
Mexico, Nevada, and Utah) encompasses diverse ecosystems, cultures, and economies, reflecting a broad
range of climate conditions, including the hottest and driest climate in the United States. The average
annual temperature of the Southwest increased 1.6°F (0.9ºC) between 1901 and 2016. Moreover, the
region recorded more warm nights and fewer cold nights between 1990 and 2016, including an increase
of 4.1°F (2.3°C) for the coldest day of the year. Each NCA has consistently identified drought, water
shortages, and loss of ecosystem integrity as major challenges that the Southwest confronts under climate
change. Since the last assessment, published field research has provided even stronger detection of
hydrological drought, tree death, wildfire increases, sea level rise and warming, oxygen loss, and
acidification of the ocean that have been statistically different from natural variation, with much of the
attribution pointing to human-caused climate change (USGCRP 2018).
Climate change includes both historic and predicted climate shifts that are beyond normal weather
variations. Climate change may be due to natural internal processes or external forces. Earth’s atmosphere
has a natural greenhouse effect wherein naturally occurring gases such as water vapor, carbon dioxide
(CO2), methane (CH4), nitrous oxide (N2O) and fluorinated gases absorb and retain heat (EPA 2018). A
number of activities contribute to the phenomenon of climate change, including emissions of GHGs
(especially CO2 and methane) from fossil fuel development, large wildfires, activities using combustion
engines, changes to the natural carbon cycle, and changes to radiative forces and reflectivity (albedo).
Current atmospheric concentrations of GHG’s are presented in the Specialist Report on GHG Analysis for
BLM Utah Oil and Gas Leasing (BLM 2019). Atmospheric concentration of CO2 is 406 ppm and is
increasing at a rate of 2.2 ppm/yr.
It is important to note that GHGs will have a sustained climatic impact over different temporal scales due
to their differences in global warming potential (described above) and lifespans in the atmosphere. For
example, CO2 may last 50 to 200 years in the atmosphere while methane has an average atmospheric life
time of 12 years. Each GHG has a global warming potential (GWP) that accounts for the intensity of each
GHG’s heat trapping effect and its longevity in the atmosphere. GWP allows for different gases to be
represented as an equivalent amount of CO2. As discussed in the Specialist Report on GHG Analysis for
BLM Utah Oil and Gas Leasing (BLM 2019), the BLM uses GWP that represent the current state of
science with the 100 year time horizon to allow for a direct comparison with national and global
emissions.
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State, national, and global GHG emissions are reported in Table 11. Additional details about these GHG
emissions are discussed in the GHG Analysis for BLM Utah Oil and Gas Leasing (BLM 2019) report and
is incorporated by reference.
Table 11. GHG Emission in Million Metric Tons (CO2e)
Utah US Energy United Global

Sector States
35.0 5,424.8 6,456.7 46,423.3
Source: EPA Inventory of US Greenhouse Gases Emission and Sinks 1990-2017 (EPA 2019)
EPA GHG Reporting Program FLIGHT tool (EPA 2018)
Fossil CO2 & GHG Emissions of all World Countries, recent year 2012 (Janssens-Maenhout, et al. 2017)
3.3.2.2 Environmental Consequences

Impacts of the Proposed Action
While the leasing action itself would not generate any GHG emissions, the BLM recognizes that the
reasonably foreseeable consequence of leasing may lead to oil and gas development, and that such
development could result in an increase in GHG emissions due to well development and operations, and
from downstream uses of the petroleum products produced from these parcels. Methods and assumptions
used for estimating GHG emissions from the development of lease parcels are described in the GHG
Analysis for BLM Utah Oil and Gas Leasing (BLM 2019) report and are incorporated by reference.
Emissions from Parcel Development
Direct emissions of GHGs occur during both the construction and operation phase of a well. Estimates of
GHG emissions are calculated for a single well from the Moab Master Lease Plan (MLP) FEIS (BLM
2016) high emissions scenario. Single well annual emissions were computed by taking the total annual
GHG emissions from the Moab MLP FEIS high emissions scenario and dividing by the number of wells
constructed each year for the construction emissions, and divided by the number of producing wells for
the operations emissions. Emissions were also converted from short tons to metric tons, and the CO2e was
updated using GWP from the IPCC Fifth Assessment Report. Construction emissions occur from heavy
equipment and vehicle exhaust, drill rigs, completion equipment including fracturing engines, venting,
and flaring. Operation emissions occur from storage tank breathing and flashing, truck loading, pump
engines, heaters and dehydrators, pneumatics, fugitives, vehicle exhaust, and reclamation. Additional
information on single well emissions estimates are provided in the GHG specialist report (BLM 2019).
Table 12 shows the estimated emissions from a single oil or gas well.
Table 12. Single Well GHG Emissions Based on the Moab MLP FEIS Inventory
Single Well Emissions Metric Tons per year

Development Phase CO2 CH4 N2O CO2e
Construction 2485.0 8.44 0.044 2733.0
Operations 374 50.41 0.009 1788.4
Total 2859.4 58.86 0.053 4521.4
Total estimated GHG emissions from operating the RFD of 4 wells is 7,154 MT CO2e/yr. Using the 20 year
GWP time horizon, operation emissions are 18,446 MT CO2e/yr. Total construction emissions are estimated
at 10,932 CO2e, or 12,823 MT CO2e with the 20 year GWP.
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Emissions from Combustion of Produced Oil or Gas

If lease parcels are developed and if the resulting well produces oil or gas it is foreseeable that indirect
GHG emissions will result from the end-use of the fossil fuel. Estimates of downstream emissions are
assumed to come from the combustion of oil or gas for domestic heating or energy production. However,
the BLM has no authority to direct or regulate the end-use of the produced products and an actual end-use
may differ from the assumption used for calculating downstream GHG emissions.
Calculations of indirect emissions from downstream combustion can be made by multiplying the
produced number of barrels (bbl) of oil and thousand cubic feet (mcf) of gas with GHG emission factors
from the EPA Greenhouse Gases Equivalencies Calculator – Calculations and References website (EPA,
2019). These emission factors are used because they provide an easy calculation of the amount of
equivalent amount of CO2 produced from a bbl of oil or mcf of gas. The emission factors also follow
IPCC guidance by accounting for 100% oxidation of carbon in the fossil fuel to CO2, regardless if the
carbon atom is part of a CO2, CH4, or other hydrocarbon molecule.
Existing oil and gas annual production data is obtained from the Utah Division of Oil, Gas and Mining
(UDOGM, 2018). It is assumed that future wells will produce oil and gas in similar amounts as other
existing nearby wells. Annual data from 2008 to 2018 is used to determine the average production per
well. However, some wells may produce more or less than the average. To better inform decision makers
and the public a low and high production estimates are also used to calculate a range of downstream
combustion emissions. Details on estimating production and downstream emissions are found in the GHG
Analysis for BLM Utah Oil and Gas Leasing (BLM 2019) report. Table 13 lists the estimated annual
GHG emissions per well. The lease total is calculated by multiplying the RFD (4 wells) with the single
well emissions. While a range of combustion emissions is presented, for simplicity, the average is used
when discussing total lease sale emissions.
Table 13. Production of Oil and Gas for a Single Well and Associated GHG Combustion
Emissions
2008-2018 Range of Oil 2008-2018 Range of Gas Range of Emissions per
Production (bbl/well) Production (mcf/well well (metric tons CO2e/yr)
Field Office Low Ave High Low Ave High Low Ave High
Monticello 4,753 5,555 6,356 10,264 13,635 17,006 2,609 3,140 3,670
EPA Emission factors: 0.43 metric tons CO2e/bbl, and 0.0551 metric tons CO2e/mcf. (EPA 2019).
Production data obtained from the Utah Division of Oil, Gas and Mining (UDOGM 2018).
Projected average annual combustion GHG emissions from all of the parcels considered is 12,559 MT
CO2e/yr. GHG emissions may range from 10,437 MT CO2e/yr, to 14,681 MT CO2e/yr, depending on
realized production rates, control technology, and physical characteristics of any oil produced.
As climate change is a response to global emissions of GHGs, it is difficult to assign a “significance”
value or impact based on a single action. Emissions estimates themselves are presented for disclosure
purposes and as a proxy for impacts from the proposed action. Emissions can be compared to annual state
and national emissions listed in Table 11 to provide a measure of the relative impact. The total estimated
GHG emissions from construction (10,932 MT CO2e), operations (7,154 MT CO2e/yr), and combustion
(12,559 MT CO2e /yr) from development on the parcels considered is 30,645 MT CO2e/yr, which is
0.09% of Utah major industrial sources. To express GHG emissions on a scale relatable to everyday life
the EPA GHG equivalency calculator can be used (https://www.epa.gov/energy/greenhouse-gas-
equivalencies-calculator). The projected total emissions (30,645 MT CO2e/yr) are equivalent to 6,506
passenger vehicles driven for one year, or energy use for 5,344 homes for one year. Climate change
impacts are further discussed in the cumulative impacts section of this document.
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Lifetime GHG emissions from the parcels considered can be estimated by multiplying well production
life with the operation and combustion emissions and adding the one-time construction emissions.
Assuming an average well life of 30 years, the total gross emissions from the parcels analyzed would be
0.60 MMT CO2e. However, assuming the production life of a well is somewhat speculative at the leasing
stage. Individual wells could be dry or have shorter or longer production lifespans, resulting in lower or
higher lifetime emissions.
While the BLM provides an estimate of direct and indirect GHG emissions from the potential
development of lease parcels, there is significant uncertainty due to unknown factors including actual
production, life expectancy of a well, how produced minerals are used, the form of regulation of GHG
parameters by delegated agencies, and whether any Best Available Control Technologies are utilized at
the upstream or downstream emission location(s). Statewide, the range of combustion emissions alone has
an uncertainty of nearly 340% based on if a well is low or high producing. This uncertainty is
compounded when accounting for other factors listed above.
Impacts of the No Alternative Action
Under the No Action Alternative, the parcels would not be leased so no future development could occur.
As a result, no GHG emissions from the development of these lease parcels would occur and there would
be no addition to the existing national and global emissions that influence climate change.
3.3.2.3 Required Design Features/Mitigation Measures

The BLM regulates portions of natural gas and petroleum systems identified in the EPA Inventory of U.S.
Greenhouse Gas Emissions and Sinks report (EPA, Inventory of U.S. Greenhouse Gas Emissions and
Sinks 1990-2017 2019). In carrying out its responsibilities, BLM has developed a list of best management
practices (BMPs) designed to reduce emissions from field production and operations. Analysis and
approval of future development on the lease parcels may include application of BMPs within BLM’s
authority, as Conditions of Approval, to reduce or mitigate GHG emissions. Additional measures
developed at the project development stage also may be incorporated as applicant-committed measures by
the project proponent, or added to necessary air quality permits.
BMPs to reduce the impacts of climate change and GHG emissions may include, but are not limited to:
• Flare hydrocarbon and gases at high temperatures in order to reduce emissions of incomplete
combustion through the use of multi-chamber combustors;
• Require that vapor recovery systems be maintained and functional in areas where petroleum liquids
are stored;
• Installation of liquids gathering facilities or central production facilities to reduce the total number
of sources and minimize truck traffic;
• Use of natural gas fired or electric drill rig engines;
• The use of selective catalytic reducers and low-sulfur fuel for diesel-fired drill rig engines; and,
• Implementation of directional and horizontal drilling technologies whereby one well provides
access to petroleum resources that would normally require the drilling of several vertical wellbores;
Additionally, the BLM encourages natural gas companies to adopt proven cost-effective technologies and
practices that improve operation efficiency and reduce natural gas emissions, to reduce the ultimate
impact from the emissions.
In October 2012, the EPA promulgated air quality regulations for completion of hydraulically fractured
gas wells. These rules require air pollution mitigation measures that reduce the emissions of VOCs during
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gas well completions. Mitigation includes a process known as “green completion” in which the recovered
products are sent through a series of aboveground, closed, separators which negates the need for flowing
back into surface pits as the product is immediately sent to gas lines and the fluids are transferred to
onsite tanks.
EPA Inventory data show that by adopting the BMPs proposed by the EPA Natural Gas Energy Star
program, the industry has reduced emissions from oil and gas exploration and development: “During
calendar year 2018, Partners submitted an annual report detailing their efforts in 2017 to reduce methane
emissions from their operations. These voluntary activities consisted of 45 technologies and practices and
resulted in emissions reductions of 96.8 Bcf for the year. These methane emissions reductions have cross-
cutting benefits on domestic energy supply, industrial efficiency, revenue generation, improved air
quality, and greenhouse gas emissions reductions. The emission reductions are equivalent to additional
revenue of approximately $291 million in natural gas sales (assumes an average natural gas price of $3.00
per thousand cubic feet).” (EPA 2019)
Specifically, EPA reports that 89% of the methane reductions came from the oil and gas production
sector, by utilizing a variety of technologies including: reducing blow down frequency, installing vapor
recovery units, and converting gas-driven pumps to electric, mechanical, or solar driven pumps. The BLM
will continue to work with industry to promote the use of the relevant BMPs for operations proposed on
Federal mineral leases where such mitigation is consistent with agency authorities and policies, and is
supported by BLM’s NEPA analysis.
In addition to efforts to better respond and adapt to climate change, other Federal initiatives are being
implemented to mitigate climate change. The Carbon Storage Project was implemented to develop carbon
sequestration methodologies for geological (i.e., underground) and biological (e.g., forests and
rangelands) carbon storage. The project is a collaboration of Federal and nonfederal stakeholders to
enhance carbon storage in geologic formations and in plants and soils in an environmentally responsible
manner. The Carbon Footprint Project (Carbon 2019) is an effort to develop a unified GHG emission
reduction program for the DOI, including setting a baseline and reduction goal for the Department’s GHG
emissions and energy use.
3.3.2.4 Cumulative Impacts

Even though the Proposed Action of leasing would not contribute to cumulative effects on air resources,
future foreseeable development could contribute to cumulative GHG emissions and therefore climate
change. Cumulative GHG emissions from existing and foreseeable oil and gas wells within the
Monticello Field Office boundaries from well operation and downstream combustion are calculated in the
GHG Analysis for BLM Utah Oil and Gas Leasing Specialist Report (BLM, 2019) and is incorporated by
reference. Emissions from well construction, operations, and downstream combustion of existing wells
and foreseeable wells from current APDs and other recent leasing actions are included in the cumulative.
Estimated annual GHG emissions from existing and foreseeable oil and gas sources are presented in
Table 14. Additionally, foreseeable oil and gas related emissions are projected based on the field office
RMPs (see Table 16) and the undeveloped portion of the RMP development scenarios (see Table 17).
Emissions from well development are listed separately as they would only occur one time during
construction, drilling, and completion of new wells and not be an ongoing emission.
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Table 14. Estimates Annual GHG Emissions from Existing and Reasonably Foreseeable Oil
and Gas Wells.
Metric Tons CO2e/yr
Total Foreseeable
Existing Existing Foreseeable Foreseeable
Field Office Annual One-Time
Direct Indirect Direct Indirect
Emissions Emissions
Monticello 1,280,509 2,214,643 60,806 106,752 3,662,710 92,922
Statewide Total 7,347,577 32,143,717 896,712 5,740,329 46,420,735 1,312,457
The parcels considered are estimated to annually produce 19,713 MT CO2e/yr (7,154 MT CO2e/yr
operation from Table 12 plus 12,559 MT CO2e/yr combustion from Table 13), which would contribute
0.5% of the total annual oil and gas emissions in the field office (3,662,710 MT CO2e/yr; Table 14).
Total annual emissions are 4.49% of the annual Utah major industrial source (35 MMT, Table 11) plus
oil and gas (46 MMT, Table 14) emissions, and 0.06% of the 2017 U.S. total emissions, see Table 15.
The statewide comparison is conservative since the total doesn’t include emissions from agriculture,
transportation, and waste management sectors which are substantial sources of GHG emissions. Current
emissions information for these sectors is not available. The Utah Greenhouse Gas Inventory and
Reference Case Projections (Strategies 2007) report projected that in 2020 agriculture, transportation, and
waste management emissions in Utah would be 5.8 MMT CO2e, 22.4 MMT CO2e, and 4.7 MMT CO2e
respectively. Adding the projections for these sectors with the reported major source and oil and gas
estimated emissions results in 114 MMT CO2e total GHG emissions estimate for the State of Utah.
Table 15. Comparison of Total Annual Emissions with State and National Emissions
Major
Sources + Percent of Utah
Total Annual Percent of Percent of
Field Office O&G (Major + O&G)
Emissions U.S. Energy U.S. Total
Emissions Emissions
Monticello 3,662,710
3,662,710 4.49% 0.07% 0.06%
Statewide 81,493,931
46,420,735 56.96% 0.86% 0.72%
BLM also considered potential annual GHG emissions for the field office planning area throughout the
life of the management plans. The Resource Management Plan (RMP) for the field office planning area
includes an RFD scenario describing the number of expected wells over the life of the plan. These
expected wells can be used to estimate the potential total GHG emissions for all of the lands open to
leasing (past, present and future lease sales) in each planning area. Planning-area-wide emissions are
estimated by multiplying the expected number of wells by the single well construction, operation, and
combustion emissions, assuming all lands would be leased, and fully developed concurrently (Table 16).
Table 16. Expected wells from Each Field Office RMP, and Corresponding GHG Emissions
Construction Average
RMP Expected Operation (MT
Field Office Combustion (MT
wells (MT CO2e) CO2e/yr)
CO2e/yr)
Moab MLP 128 349,823 228,918 115,663
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Construction Average
RMP Expected Operation (MT
Field Office Combustion (MT
wells (MT CO2e) CO2e/yr)
CO2e/yr)
Monticello 189 532,934 348,742 612,253
BLM Utah 9,687 6,975,421 4,449,851 39,583,936
Some oil and gas development has occurred since the implementation of the RMP. Table 17 lists the
remaining number of estimated wells from the RMP that have not yet been developed, and the estimate of
GHG emissions that are foreseeable from future development in the field office. The estimates are made
by multiplying the remaining number of wells projected in the respective RMPs by the average GHG
emissions from single well construction, operation, and combustion of the average quantity of produced
oil or gas. These estimates represent the foreseeable emissions from undeveloped leases and future
leasing actions.
Table 17. Undeveloped Portion of RMP RFD Scenarios and Corresponding Potential GHG
Emissions for Each Field Office
Undeveloped Average
Construction Operation (MT
Field Office Portion of RMP Combustion (MT
(MT CO2e) CO2e/yr)
RFD 17 CO2e/yr)
Moab MLP 125 341,624 223,553 112,952
Monticello 125 516,536 338,011 593,414
Statewide 6,129 5,249,289 3,396,028 29,810,154
The U.S. Geological Survey (USGS) has produced estimates of the greenhouse gas emissions resulting
from the extraction and end-use combustion of fossil fuels produced on Federal lands in the United States,
as well as estimates of ecosystem carbon emissions and sequestration on those lands (USGS 2018). In
2014, nationwide GHG emissions from fossil fuels extracted from Federal lands was 1,332.1 MMT CO2e.
Emissions from fossil fuels produced on Federal lands represent, on average, 23.7 percent of national
emissions for CO2, 7.3 percent for CH4, and 1.5 percent for N2O over the 10 years included in this
estimate (USGS 2018). Uncertainty associated with emission estimates is 2-5% for combustion, 25-42%
for fugitives, and 12-15% for degassed CH4 emissions from coal mines. Trends and relative magnitude of
emissions are roughly parallel to production volumes.
Utah Federal fossil-fuel-related gross emissions in 2014 were 46.75 MMT CO2e, approximately 3.5% of
the estimate of national emissions from Federal fossil fuels (USGS 2018). Emissions from the adjacent
fossil fuel producing states of Colorado, New Mexico, and Wyoming were 55.78, 91.63, and 744.2 MMT
CO2e, respectively, in 2014.
Federal lands also uptake carbon in vegetation, soils, and water. In 2014, carbon storage on Federal lands
was 83,600 MMT CO2e nationally and 3,611 MMT CO2e in Utah. Soils stored 63% of carbon with
vegetation and dead organic matter storing 26% and 11% respectively. The national rate of net carbon
17 This number represents the estimated wells from the most recent, respective RMP RFD minus the number of wells developed
since the adoption of that RMP.
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uptake (sequestration) varies from 475 MMT CO2e/yr. to a source (emission) of 51 MMT CO2e due to
changes in climate/weather, land use, land cover change, wild fire frequency, and other factors. From
2005 to 2014, terrestrial ecosystems on Federal lands sequestered an average of 195 MMT CO2e/yr,
offsetting about 15% of emissions resulting from Federal fossil fuel extraction and combustion nationally.
In Utah, the annual average ecosystem carbon storage is 3,581 MMT CO2e, with soils accounting for
about 70%. In Utah, the annual average sequestration over the ten years was 8.6 MMT CO2e/yr, offsetting
about 18% of extraction and combustion emissions from fossil fuels produced on Federal lands in Utah.
Carbon emissions from Utah ecosystems due to land-use and land-cover change, including
surface disturbing activities such as well pad construction, averaged 1.3 MMT CO2e/yr from
2005 to 2014 (USGS 2018). While surface disturbance from well pad construction contributes to
ecosystem carbon emission and a reduction in the lands ability to store carbon, these impacts are
anticipated to be temporary during the life of a well, as reclamation requirements should return
the land to a condition approximately equal to that which existed prior to the disturbance (BLM
2007).
As mentioned earlier, climate change is driven in part by GHG emissions from human activities.
Emissions from the lease sale would contribute incrementally to the cumulative national and global
emissions that influence climate change. BLM prepared several Rapid Ecoregional Assessments (REA) to
predict future conditions, including climate change, in various regions. The leasing area is within the
Colorado Plateau REA (Bryce 2012) analysis area. Past, present, and reasonably foreseeable activities in
the analysis include energy development, agricultural development, urban and road development, and
recreation development. The assumption details and modeling methodology are incorporated by
reference. The Colorado Plateau REA depicts the data sources for potential oil and gas leasing,
development and production, and oil shale and tar sand extraction. Modeled average annual future
temperatures in the Colorado Plateau REA are generally predicted to increase. Average annual
precipitation predicted by the model in general are predicted to decrease (drier) through 2030 and increase
(wetter) through 2060. Figure 3 shows the potential for climate related change and is a composite of
predicted changes to temperature, precipitation, runoff, and vegetation. Potential for climate related
change in the Colorado Plateau area generally predicted to be mostly moderate or lower (about 70%),
areas with high or very high (approximately 30%) potential for change are generally seen in higher
elevations. Lease parcels are generally located in areas with moderate or greater potential for climate
related change. Due to inherent uncertainties described in the Colorado Plateau REA, caution should be
used for interpreting climate change potential at site specific scales (Bryce 2012).
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Figure 3. Potential for climate change impacts for the Colorado Plateau
“Social cost of carbon” estimates are one approach that an agency can take to examine climate
consequences from greenhouse gas emissions resulting from a proposed action. However, leasing action
Environmental Assessments provide no quantitative monetary estimates of any benefits or costs. The
National Environmental Policy Act (NEPA) does not require an economic cost-benefit analysis (40
C.F.R. § 1502.23), although NEPA does require consideration of “effects” that include “economic” and
“social” effects (40 C.F.R. 1508.8(b)). Quantifying only the costs of oil and gas development by using the
social cost of carbon metrics but not the benefits (as measured by the economic value of the proposed oil
and gas development and production generally equaling the price of oil and gas minus the cost of
producing, processing, and transporting the minerals) would yield information that is both inaccurate and
not useful for the decision-maker, especially given that there are no current criteria or thresholds that
determine a level of significance for social cost of carbon monetary values.
Instead, BLM’s approach to GHG and climate change impacts analysis is to include calculations to show
estimated direct, indirect, and cumulative GHG emissions from potential future development. BLM’s
approach recognizes that there are adverse environmental impacts related to climate change associated
with the development and use of fossil fuels, provides potential GHG emission estimates, and discusses
potential climate change impacts qualitatively. This effectively informs the decision-maker and the public
of the potential for GHG emissions and the potential implications of climate change. This approach
presents the data and information in a manner that follows many of the guidelines for effective climate
change communication developed by the National Academy of Sciences (Council 2010) by making the
information more readily understood and relatable to the decision-maker and the general public.
The proposed action, in concert with other past, present, and reasonably foreseeable actions may
contribute to incremental increases to GHG emissions through direct and indirect impacts. There are
currently no established significance thresholds for GHG emissions that BLM can reference in NEPA
analyses, but all GHGs contribute incrementally to the climate change phenomenon. When determining
NEPA significance for an action, BLM is constrained to the extent that cumulative effects (such as
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climate change) are only considered in the determination of significance when such effects can be
prevented or modified by decision-making (refer to BLM NEPA Handbook, pg.72). While GHG
emissions resulting from individual decisions can certainly be modified or potentially prevented by
analyzing and selecting reasonable alternatives that appropriately respond to the action’s purpose and
need, BLM has limited decision authority to meaningfully or measurably prevent the cumulative climate
change impacts that would result from global emissions.
The No Action alternative would not contribute to the cumulative emissions or climate change because
the leases would not be issued and no development would occur.
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Chapter 4 Consultation and Coordination
4.1 Introduction
The issues included in Section 1.8 identifies those that are analyzed in detail in Chapter 3. The IDPRT
Checklist (Appendix D) provides the rationale for issues that were considered but not analyzed further.
The issues were identified through the public and agency involvement process described in Sections 4.3
below.
4.2 Persons, Groups, and Agencies Contacted/Consulted
Persons, agencies, and organizations that were contacted or consulted during the preparation this EA are
identified in Table 18.
4.2.1 Endangered Species Act of 1973
The effects of Oil and Gas leasing development on T&E species were analyzed through Section 7
consultation on existing Utah BLM resource Management Plans was completed in 2008 (Cons. # 6-UT-
08-F-0024). This action is in compliance with T&E species management outlined in accordance with the
requirements under the FLMPA and the NEPA.
While Federal regulations and policies require the BLM to make its public land and resources available
on the basis of the principle of multiple-use, it is BLM policy to conserve special status species and their
habitats, and to ensure that actions authorized by the BLM do not contribute to the need for the species to
become listed as T&E by the USFWS.
Consultation on Oil and Gas leasing occurred in 2007, for existing RMP’s such as that for the Cedar City
jurisdictional area. For lease sales conducted on listed species covered by this consultation action, the
BLM regularly coordinates with the USFWS to assure agreement that the Proposed Action (leasing): 1)
does not exceed the impacts analyzed in the PRMP and BA/BO; and 2) would not exceed the effects
contained in the associated USFWS biological opinion(s) concurring with BLM’s Not Likely to
Adversely Affect (NLAA) determinations. Many of the parcels in the September 2019 lease sale were
deferred from the December 2018, March 2019 and June 2019 lease sales. The following is a summary of
dates associated with coordination with the USFWS on these sales:
• March 2019
o Lease notice provided to USFWS: December 13, 2018
o NLAA Agreement: February 25, 2019
• September 2019
o Lease notice provided to USFWS: April 17, 2019
o NLAA Agreement Confirmation Old Parcels: Consultation is ongoing
o NLAA Agreement New Parcels: Consultation is ongoing
The BLM is working with USFWS to confirm their agreement with BLM determinations. The BLM will
complete coordination on the September 2019 lease sale with the USFWS prior to issuance of the leases
for all parcels contained in the September 2019 lease sale, if offered. When or if disturbance is proposed
for parcels (APD stage) that contain or affect ESA species, further evaluation and Section 7 consultation
of these ESA species with the USFWS will occur as necessary.
4.2.2 National Historic Preservation Act (NHPA) of 1966
The BLM prepared a cultural resources report to document its reasonable and good faith effort to identify
effects this undertaking may have on historic properties, as required by Section 106 of the National
Historic Preservation Act of 1966 (54 U.S.C 306108).
The Advisory Council for Historic Preservation’s (ACHP) document titled Meeting the “Reasonable and
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Good Faith” Identification Standards in Section 106 Review, from

https://www.achp.gov/sites/default/files/guidance/2018-05/reasonable_good_faith_identification.pdf
outlines the steps to determine when a reasonable and good faith identification effort has been met. The
ACHP states:
• Prior to beginning the identification stage in the Section 106 process, the regulations (at 36 CFR §
800.4) require the federal agency to do the following:
• Determine and document the APE [Area of Potential Effect] in order to define where the agency
will look for historic properties that may be directly or indirectly affected by the undertaking;
• Review existing information on known and potential historic properties within the APE, so the
agency will have current data on what can be expected, or may be encountered, within the APE;
• Seek information from others who may have knowledge of historic properties in the area. This
includes the State Historic Preservation Officer (SHPO)/Tribal Historic Preservation Officer
(THPO) and, as appropriate, Indian tribes or Native Hawaiian organizations who may have
concerns about historic properties of religious and cultural significance to them within the APE.
Following these initial steps, the regulations (36 CFR § 800.4(b) (1)) set out several factors the agency
must consider in determining what is a “reasonable and good faith effort” to identify historic properties:
Take into account past planning, research and studies; the magnitude and nature of the
undertaking and the degree of federal involvement; the nature and extent of potential effects on
historic properties; and the likely nature and location of historic properties within the APE. The
Secretary of the Interior’s standards and guidelines for identification provide guidance on this
subject. The agency official should also consider other applicable professional, state, tribal, and
local laws, standards, and guidelines. The regulations note that a reasonable and good faith effort
may consist of or include ‘background research, consultation, oral history interviews, sample
field investigation, and field survey.’
For lease sales, BLM’s identification efforts include: (1) completing a comprehensive "records review,"
which is an intensive review and analysis of available pertinent cultural resource records and information
for each parcel and the surrounding areas that are included in the undertaking APE; and (2) proactively
seeking information from others who may have knowledge of historic properties in the area. The BLM's
identification efforts that are described in this report for the March 2019 lease sale undertaking are
consistent with the direction provided in multiple Interior Board of Land Appeals (IBLA)
decisions/orders, including Mandan, Hidatsa, and Arikara Nation, 164 IBLA 343 (2005), Southern Utah
Wilderness Alliance, IBLA 2008-264 (2009), and Southern Utah Wilderness Alliance, IBLA 2002-334.
On November 5, 2018 the BLM sent invitations to participate in government to government consultations
to: The Confederated Tribes of the Goshute, The Northwest Band of the Shoshone Nation, The Hopi
Tribe, Kaibab Band of Paiute Indians, Navajo Nation, Navajo Nation – Oljato Chapter, Navajo Nation –
Red Mesa Chapter, Navajo Utah Commission, Ohkay Owingeh, Paiute Indian Tribe of Utah, All Pueblo
Council of Governors, Pueblo of Acoma, Pueblo of Cochiti, Pueblo of Isleta, Pueblo of Jemez, Pueblo of
Kewa, Pueblo of Laguna, Pueblo of Nambe, Pueblo of Picuris, Pueblo of Pojoaque, Pueblo of San Felipe,
Pueblo of San Ildefonso, Pueblo of Sandia, Pueblo of Santa Ana, Pueblo of Santa Clara, Pueblo of Taos,
Pueblo of Tesuque, Pueblo of Zia, Pueblo of Zuni, Skull Valley Band of Goshutes, Southern Ute Tribe,
Uintah and Ouray Ute Tribe, Ute Mountain Ute Tribe, White Mesa Ute.
On November 15, 2018 UTSO BLM posted data and instructions on ePlanning for consulting parties to
request consulting party status on the March 2019 Lease Sale Cultural Resource Report. BLM UTSO
consulted with Friends of Cedar Mesa, Southern Utah Wilderness Alliance, Box Elder County, Uintah
County, San Juan County, and Golden Spike National Park. BLM UTSO received comments and
concerns from SUWA and FOCM, supplemental data incorporated into the report from FOCM, and a
letter of support from San Juan County.
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Table 18. List of Contacts and Findings.

Name Purpose & Authorities Findings & Conclusions
for Consultation or
Coordination
National Park Service Coordinated with as Letter transmitting the preliminary list was sent on October 24, 2018 and April
leasing program partner. 17, 2019. A map and GIS shapefiles were sent to the NPS on October 26, 2018
through May 5, 2019 via email. Coordination is ongoing. UTSO sent an
additional letter via email to Golden Spike National Park on December 20,
2018, with the draft March 2019 Lease Sale Cultural Resources Report.
United States Fish and Wildlife Service Coordinated with as Letter transmitting the preliminary list was sent April 17, 2019. Emails were
leasing program partner. sent on April 3 and April 25, 2019 transmitting the corresponding shapefiles.
United States Forest Service Coordinated with as Letter transmitting the preliminary list was sent on October 24, 2018 and April
leasing program partner. 17, 2019. Comments or concerns were not expressed.
Public Lands Policy Coordination Office Coordinated with as Letter transmitting the preliminary list was sent on October 24, 2018 and April
leasing program partner. 17, 2019. An e-mail with GIS shape-files was sent to UDWR to satisfy the
requirements of IM-2012-43 on October 26, 2018, March 27, 2019 and April
3, 2019.
Utah Division of Wildlife Resources Coordinated with as Letter transmitting the preliminary list was sent on October 24, 2018 and April
leasing program partner. 17, 2019. An early email was sent on October 26, 2018, March 27, 2019, and
April 3, 2019 transmitting the corresponding shapefiles.
State Institutional Trust Lands Coordinated with as Letter transmitting the preliminary list was sent on October 24, 2018 and April
Administration leasing program partner. 17, 2019.
State Historic Preservation Office Consultation as required On October 24, 2018 and March 13, 2019, a no adverse effect on historic
by NHPA (16 USC 470) properties determination was mailed to the SHPO. On October 25, 2018 and
March 25, 2019 SHPO concurrence was received.
The Hopi Tribe, Kaibab Band of Paiute Consultation as required On November 5, the MtFO archaeologist sent an invitation to consult letter to
Indians, Navajo Nation, Navajo Nation – by the American Indian each tribe. On November 8th the MtFO discussed the anticipated consultation
Oljato Chapter, Navajo Nation – Red Religious Freedom Act timetable with the Pueblo of Santa Clara. On November 23rd the Hope Tribe
Mesa Chapter, Navajo Utah Commission, of 1978 (42 USC 1996) requested consultation on the March 2019 Lease. On November 26 the MtFO
Ohkay Owingeh, Paiute Indian Tribe of and NHPA (16 USC received a letter from the Hopi, an email from the Pueblo of Isleta to arrange
Utah, All Pueblo Council of Governors, 470) consultation, had the consultation meeting with the Pueblo of Isleta, and
Pueblo of Acoma, Pueblo of Cochiti, exchanged emails with the White Mesa Ute about parcels. On December 3rd
47
July 2019

for Consultation or
Coordination
Pueblo of Isleta, Pueblo of Jemez, Pueblo the MtFO responded to the White Mesa Ute, and received a letter to consult
of Kewa, Pueblo of Laguna, Pueblo of from the Pueblo of Santa Clara; both of which were responded to on the same
Nambe, Pueblo of Picuris, Pueblo of day. On December 12th the MtFO received a letter from the Pueblo of Acoma.
Pojoaque, Pueblo of San Felipe, Pueblo On December 14th the MtFO received a letter from the Southern Ute
of San Ildefonso, Pueblo of Sandia, requesting additional information and to participate in consultation. On
Pueblo of Santa Ana, Pueblo of Santa January 15th the MtFO received a letter from the Pueblo of Acoma demanding
Clara, Pueblo of Taos, Pueblo of a halt to APD processing during government shutdown, and noted that BLM
Tesuque, Pueblo of Zia, Pueblo of Zuni, has not announced timeline extensions for the March and June Lease sales. On
Southern Ute Tribe, Uintah and Ouray January 22nd the MtFO received an email from the Southern Ute Tribe stating
Ute Tribe, Ute Mountain Ute Tribe, that BLM cannot make determinations without tribal consultation, and
White Mesa Ute recommending the BLM send the Southern Ute Tribe the Cultural Report. On
January 28th the MTFO received a letter attached to an email from the Navajo
Nation with a statement that the lease sale will have no adverse effect to
Navajo TCP’s, as well as a request to consult on the lease. On February 5th, the
MtFO received an email from the Hopi Tribe reiterating the request from
December 10 that the BLM cancel the March lease sale, further asserting that
energy development results in adverse effects, RFD acreage. On February 11th
the MtFO received a letter from the Pueblo of Santa Clara noting the draft
report was received, and requested BLM postpone all lease activities until the
end of the shutdown, with a requested for more information and further
consultation; as well as an email from the Southern Ute reiterating response
letter that the Southern Ute Tribe wishes to engage in consultation for the lease
sale, and that they request a list of sites in the parcels. On February 15th, the
MtFO emailed the Hopi Tribe, Kaibab Band of Paiute Indians, Navajo Nation,
Navajo Nation – Oljato Chapter, Navajo Nation – Red Mesa Chapter, Navajo
Utah Commission, Ohkay Owingeh, Paiute Indian Tribe of Utah, All Pueblo
Council of Governors, Pueblo of Acoma, Pueblo of Cochiti, Pueblo of Isleta,
Pueblo of Jemez, Pueblo of Kewa, Pueblo of Laguna, Pueblo of Nambe,
Pueblo of Picuris, Pueblo of Pojoaque, Pueblo of San Felipe, Pueblo of San
Ildefonso, Pueblo of Sandia, Pueblo of Santa Ana, Pueblo of Santa Clara,
Pueblo of Taos, Pueblo of Tesuque, Pueblo of Zia, Pueblo of Zuni, Southern
Ute Tribe, Uintah and Ouray Ute Tribe, Ute Mountain Ute Tribe, and the
White Mesa Ute informing the tribes of the coming certified mail invitation to
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July 2019

for Consultation or
Coordination
consulting meetings on February 25th and 26th at the Monticello Field Office.
On February 19th the MtFO received an email from the Uintah and Ouray
Tribes informing the BLM that a representative would not attend the meeting.
On February 20th the MtFO send a letter to the Hopi Tribe, Kaibab Band of
Paiute Indians, Navajo Nation, Navajo Nation – Oljato Chapter, Navajo Nation
– Red Mesa Chapter, Navajo Utah Commission, Ohkay Owingeh, Paiute
Indian Tribe of Utah, All Pueblo Council of Governors, Pueblo of Acoma,
Pueblo of Cochiti, Pueblo of Isleta, Pueblo of Jemez, Pueblo of Kewa, Pueblo
of Laguna, Pueblo of Nambe, Pueblo of Picuris, Pueblo of Pojoaque, Pueblo of
San Felipe, Pueblo of San Ildefonso, Pueblo of Sandia, Pueblo of Santa Ana,
Pueblo of Santa Clara, Pueblo of Taos, Pueblo of Tesuque, Pueblo of Zia,
Pueblo of Zuni, Southern Ute Tribe, Uintah and Ouray Ute Tribe, Ute
Mountain Ute Tribe, and the White Mesa Ute inviting the tribes to a consulting
parties meeting February 25th and 26th at the Monticello Field Office. On
February 25th the MtFO hosted a teleconference consultation meeting. The
Pueblo of Pojoaque was in attendance. Discussed the lease sale and the section
106 process, and the Pueblo of Pojoaque requested a copy of the draft section
106 report, which was delivered that day. On February 25th, 2019 the Mtfo had
a phone discussion with the Pueblo of San Felipe and the Monticello Field
Office. Discussed Lease sale, authority of phased approach, determination of
effect, the trust relationship, tribal difficulty with traveling to consultation, and
the best way to keep communication open. Coordination and consultation will
continue up until the lease auction, at the request of any tribe.
Box Elder County Commission, Uintah Representatives of local On December 20th, 2018, the UTSO emailed a copy of the March 2019 Lease
County Commission, San Juan County governments, per 36 Sale Cultural Resources Report to Box Elder County Commission, Uintah
Commission, C.F.R. 800 (2)(C)(3) County Commission, San Juan County Commission requested their comments
and input. On January 28th, 2019, the UTSO received a letter of support for the
March 2019 lease from San Juan County.
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4.3 Public Participation

Scoping Period
The UTSO sent letters/memorandum to the following stakeholders: the National Park Service (NPS), the
United States Fish and Wildlife Service (USFWS), the United States Forest Service (USFS) and the State
of Utah’s Public Lands Policy Coordination Office (PLPCO), Division of Wildlife Resources (UDWR)
and the School Institutional Trust Lands Administration (SITLA) to notify them of the pending lease sale,
solicit comments and concerns on the preliminary parcel list. The BLM also provided GIS shapefiles
depicting the proposed sale parcels to contact points within the NPS and UDWR. Consultation and
coordination efforts are summarized in Table 18.
Comment Period
As introduced in Section 1.2, the preliminary EA and the unsigned Finding of No Significant Impact
(FONSI) were posted and made available for a 30-day public review and comment period on May 30,
2019. This announced the 30-day comment period (05/30/2019-07/01/2019) for this lease sale. The
documents were made available online at the Utah State Office’s Oil and Gas Leasing Webpage and the
BLM’s NEPA Register.
Section 4.3.1 will identify changes to this EA that were made as a result of public comments and internal
review. Comments and BLM’s responses to each of the comment letters will be shown in Appendix H.
Twenty four comment letters were received, the comment letters and BLM’s responses to the points made
in the letters are contained in Appendix H. Some comments did cause updates and changes to be made in
this EA and is documented in section 4.3.1.
NHPA Coordination
The BLM utilized and coordinated the NEPA public participation requirements to assist the agency in
satisfying the public involvement requirements under Section 106 of the National Historic Preservation
Act (NHPA) [16 U.S.C. 470(f) pursuant to 36 CFR 800.2(d) (3)]. The information about historic and
cultural resources within the area potentially affected by the proposed project/action/approval will assist
the BLM in identifying and evaluating impacts to such resources in the context of both NEPA and Section
106 of the NHPA. The BLM will consult with Indian tribes on a government-to-government basis in
accordance with Executive Order 13175 and other policies, if requested by any Tribe. If Tribal concerns
are identified, including impacts on Indian trust assets and potential impacts to cultural resources, they
will be given due consideration.
On May 28, 2019, BLM also provided a copy of the draft cultural report to individuals and/or
organizations who participated as a Consulting Party.
4.3.1 Modifications Based on Public Comment and Internal Review
The public comment period and corresponding internal review identified necessary corrections or
clarifications to this EA.
1. Appendix E was updated to correct formatting issues.
2. The project number was corrected to DOI-BLM-UT-000-2019-0003_Other NEPA-EA
3. Cultural Resources section in Appendix D was updated.
4. Minor grammar, spelling and formatting changes were fixed in the document.
5. Public comments resulted in updates to section 2.2.1, section 3.3.2.2, Table 12, Table 14, Table
15, Table 17, Appendix D (IDPR-cultural resources), and Appendix B.
6. BLM responded to ACHP’s review of the March 2019 Lease Sale Cultural Resource Report
formally through the Section 106 consultation process. This letter is available to the public at:
http://go.usa.gov/xPfnq
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July 2019
7. Per Southern Utah Wilderness Alliance comments, sections 3.2, 3.3.2.2, and 3.3.2.3, and Table
12, 14, and 15.
8. Appendix A and Appendix B were updated to reflect the final stipulations and notices for the
nominated parcels.
4.4 Preparers
An IDPRT prepared the document and analyzed the impact of the proposed action upon the various
resources (Table 19). They considered the affected environment and documented their determination in
the IDPRT Checklist (Appendix D – Interdisciplinary Parcel Review Team Checklist). Only those
resources that would likely be impacted were carried forward into the body of the EA for further analysis.
Table 19. Preparers of This EA.
Name Title Responsible for the Following Section(s) of this
Document
Leah Waldner Natural Resource Project Lead, Oil and Gas Leasing Program Coordinator
Specialist
Glenn Stelter Archaeologist Oil and Gas Leasing Program, NHPA Compliance
Karen Cathey Wildlife Biologist Oil and Gas Leasing Program, USFWS Consultation
Angela Wadman Natural Resource Oil and Gas Leasing Program, NEPA Compliance
Specialist
Ken Bradshaw Hydrologist Oil and Gas Leasing Program
Aaron Roe Botanist Oil and Gas Leasing Program, USFWS Consultation
Erik Vernon Air Quality Specialist Oil and Gas Leasing Program, Air Quality; Greenhouse
Gases.
Robin Naeve Acting Senior Leasing Oil and Gas Leasing Program Review and Oversight
Specialist
All specialists that reviewed the parcels are identified in Appendix D – Interdisciplinary Parcel Review
Team Checklist.
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Chapter 5 Appendices
A. Parcel List with Stipulations and Notices
B. Stipulations and Notices
C. Figures (Maps)
D. Interdisciplinary Parcel Review Team Checklist
E. References
F. Acronyms/Abbreviations
G. Reasonable Foreseeable Development Scenario
H. Comments and Responses
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Appendix A – Parcel List with Stipulations and Notices

In addition to the parcel specific Stipulations and Notices listed below, the stipulations and notices
presented in this table would be applied to ALL parcels:
Stipulations Notices
Cultural Resources Protection (Handbook H- Notice to Lessee (MLA)
3120-1)
Threatened & Endangered Species Act
(Handbook H-3120-1)
UT0319 – 406
T. 38 S., R. 23 E., SLM
Sec. 17: All;
Sec. 19: Lots 1, 2, NE, E2NW;
Secs. 20 and 21: All.
2,232.30 Acres
San Juan County, Utah
STIPULATIONS
UT-S-01: Air Quality
UT-S-106: CSU – Fragile Soils/Slopes 21-40 Percent
UT-S-128: NSO – Floodplains, Riparian Areas, Springs, and Public Water Reserves
UT-S-170: CSU – Cultural
UT-S-182: NSO – Critical Habitat of the Endangered Colorado River Fishes
UT-S-234: TL – Crucial Deer Winter Range
UT-S-288: CSU/TL – Mexican Spotted Owl
UT-S-290: CSU/TL – Southwestern Willow Flycatcher
UT-S-294: CSU/TL - California Condor
UT-S-297: CSU/TL – Yellow-billed Cuckoo
NOTICES
T&E-06 Mexican Spotted Owl
T&E-07: Southwestern Willow Flycatcher
T&E-11: California Condor
T&E-26: Southwestern Willow Flycatcher Habitat– Riparian Areas
T&E-27: Yellow-billed Cuckoo
T&E-28 California Condor – Potential Habitat
UT-LN-25: White-Tailed and Gunnison Prairie Dog
UT-LN-43: Raptors
UT-LN-44: Raptors
UT-LN-45: Migratory Bird
UT-LN-49: Utah Sensitive Species
UT-LN-67: Historical and Cultural Resource Values
UT-LN-68: Notification & Consultation Regarding Cultural Resources
UT-LN-69: High Potential for Cultural Resources
UT-LN-70: High Potential for Cultural Resource Occurrence
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UT-LN-72: High Potential Paleontological Resources

UT-LN-96: Air Quality Mitigation Measures
UT-LN-99: Regional Ozone Formation Controls
UT-LN-102: Air Quality Analysis
UT-LN-113: Western Yellow Billed Cuckoo
UT-LN-125: Light and Sound – Sensitive Resources
UT-LN-128: Floodplain Management
UT0319 – 407
T. 38 S., R. 23 E., SLM
Secs. 28, 29 and 30: All;
Sec. 31: E2.
2,227.00 Acres
STIPULATIONS
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
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UT0319 – 408
T. 39 S., R. 23 E., SLM
Sec. 5: Lots 3, 4, S2NW, SW;
Secs. 6 and 7: All;
Sec. 8: NW.
1,741.30 Acres
STIPULATIONS
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
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UT0319 – 409
T. 36 S., R. 25 E., SLM
Sec. 25: S2;
Sec. 26: S2;
1,920.00 Acres
STIPULATIONS
UT-S-98: NSO – Fragile Soils/Slopes Greater than 40 Percent
NOTICES
UT-LN-04: Crucial Mule Deer and Elk Winter Habitat
UT-LN-43: Raptors
UT-LN-44: Raptors
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July 2019
UT0319 – 410
T. 37 S., R. 25 E., SLM
Secs. 1, 11 and 12: All.
1,916.56 Acres
STIPULATIONS
UT-S-288: CSU/TL - Mexican Spotted Owl
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 411
T. 37 S., R. 25 E., SLM
1,280.00 Acres
STIPULATIONS
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NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 412
T. 37 S., R. 25 E., SLM
1,920.00 Acres
STIPULATIONS
NOTICES
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UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 413
T. 38 S., R. 25 E., SLM
Sec. 4: Lots 2, 3, SWNE, SENW, NESW, NWSE.
241.64 Acres
STIPULATIONS
NOTICES
T&E-28: California Condor – Potential Habitat
UT-LN-25: White-Tailed and Gunnison prairie Dog
UT-LN-43: Raptors
UT-LN-44: Raptors
UT-LN-37: Bald Eagle Habitat
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UT0319 – 414
T. 38 S., R. 25 E., SLM
Sec. 5: SW, SWSE;
Sec. 6: Lots 3-7, SENW, E2SW, SE;
Sec. 7: Lots 1, 2, E2, E2NW;
Sec. 8: All.
1,777.61 Acres
STIPULATIONS
UT-S-17: CSU – Alkali Ridge ACEC
UT-S-242: TL – Crucial Elk Winter Range
UT-S-275: CSU/TL – Bald Eagles
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
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UT0319 – 415
T. 38 S., R. 25 E., SLM
Sec. 10: S2;
1,600.00 Acres
STIPULATIONS
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
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UT0319 – 416
T. 38 S., R. 25 E., SLM
Secs. 12 and 13: All;
Sec. 14: S2.
1,600.00 Acres
STIPULATIONS
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 417
T. 38 S., R. 25 E., SLM
Sec. 23: NE, E2SE;
Sec. 24: All;
Sec. 25: E2, N2NW, SENW.
1,320.00 Acres
STIPULATIONS
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UT-S-297: CSUTL – Yellow-billed Cuckoo
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 418
T. 38 S., R. 25 E., SLM
Sec. 26: SW;
1,440.00 Acres
STIPULATIONS
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NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 419
T. 38 S., R. 25 E., SLM
Sec. 33: N2;
1,600.00 Acres
STIPULATIONS
NOTICES
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UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 420
T. 37 S., R. 26 E., SLM
Sec. 4: All;
Sec. 5: Lot 1, SENE, E2SE;
Sec. 8: W2E2NW, W2NW, SW, NWSWSE, S2S2SE.
1,129.95 Acres
STIPULATIONS
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
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UT0319 – 421
T. 37 S., R. 26 E., SLM
Secs 6: Lots 1-4, SWNE, S2NW, SW, W2SE, SESE;
2,480.56 Acres
STIPULATIONS
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 422
T. 37 S., R. 26 E., SLM
Sec. 19: All;
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July 2019
Sec. 20: W2NWNW, SWNW, W2SENW, W2E2SW, W2SW;

Sec. 30: W2NE, W2;
Sec. 31: W2NE, SENE, W2, SE.
1840.00 Acres
STIPULATIONS
NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 423
T. 37 S., R. 26 E., SLM
Sec. 33: SESE;
T. 38 S., R. 26 E., SLM
Sec. 4: Lot 1, S2NE, S2NW, S2;
Secs. 5 and 6: All.
1,840.48 Acres
STIPULATIONS
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NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
UT0319 – 424
T. 38 S., R. 26 E., SLM
1,920.00 Acres
STIPULATIONS
UT-S-297: CSUTL – Yellow-billed Cuckoo
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NOTICES
UT-LN-43: Raptors
UT-LN-44: Raptors
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Appendix B – Stipulations and Notices

Stipulation Summary Table
NUMBER UTAH STIPULATIONS
AIR QUALITY
All new and replacement internal combustion gas field engines of less than or equal to 300 design-rated horsepower shall not
emit more than 2 grams of NOx per horsepower-hour.
Exception: This requirement does not apply to gas field engines of less than or equal to 40 design-rated horsepower.
UT-S-01 Modification: None
2008 RMPs Only Waiver: None
(Outside of AND
Moab MLP) All new and replacement internal combustion gas field engines of greater than 300 design rated horsepower must not emit
more than 1.0 gram of NOx per horsepower-hour.
Exception: None
Modification: None
Waiver: None
CONTROLLED SURFACE USE – ALKALI RIDGE ACEC
Cultural properties eligible for or listed on the National Register of Historic Places shall be surrounded by an avoidance area
sufficient to avoid direct and indirect impacts. When siting oil and gas facilities, avoidance may require that a facility be
moved farther than allowed under the standard lease terms and conditions.
UT-S-17
Exceptions: An exception could be granted if the BLM authorized officer determines that avoidance of direct and indirect
Monticello
impacts to historic properties is not feasible (e.g. avoidance may cause unacceptable damage to other public land resources or
affect valid existing rights).
Modification: None
Waiver: None
CONTROLLED SURFACE USE – HOVENWEEP ACEC
(AREA EXCLUSIVE VISUAL EMPHASIS ZONE)
UT-S-18
Monticello
sufficient to avoid direct and indirect impacts. When siting oil and gas facilities, avoidance may require that a facility be
moved farther than allowed under the standard lease terms and conditions.
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Modification: None
Waiver: None
NO SURFACE OCCUPANCY – FRAGILE SOILS/SLOPES GREATER THAN 40 PERCENT
No new surface-disturbing activities allowed on slopes greater than 40% to protect soils, avoid erosion, and maintain public
UT-S-98 health and safety in sloped embankments.
Monticello Exception: If after an analysis the authorized officer determines that it would cause undue or unnecessary degradation to
(Outside of pursue other placement alternatives; surface occupancy in the NSO may be authorized. Additionally, a plan would be
MLP) submitted by the operator and approved by BLM prior to construction and maintenance.
Modification: None
Waiver: None
CONTROLLED SURFACE USE – FRAGILE SOILS/SLOPES 21-40 PERCENT
No new surface disturbance/construction on slopes between 21-40% without a BLM approved site plan that is prepared for
UT-S-106 any surface disturbing or construction activity. This plan would include an erosion control strategy, survey and design, and
Monticello reclamation plan.
(Outside of
Exception: None
MLP)
Modification: None
Waiver: None
NO SURFACE OCCUPANCY – FLOODPLAINS, RIPARIAN AREAS, SPRINGS, AND PUBLIC WATER
RESERVES
UT-S-128 No surface-disturbing activities are allowed in active floodplains, public water reserves or within 100 meters of riparian areas
Monticello along perennial streams and springs.
(Outside of Exception: An exception could be authorized if: (a) there are no practical alternatives, (b) impacts could be fully mitigated,
MLP) or (c) the action is designed to enhance the riparian resource values.
Modification: None
Waiver: None
UT-S-170 CONTROLLED SURFACE USE – CULTURAL
Monticello
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sufficient to avoid impacts. (Although oil and gas activity must also meet this standard, a CSU lease stipulation is not
necessary since this can be accomplished under the terms of the standard lease form.)
Modification: None
Waiver: None
NO SURFACE OCCUPANCY – CRITICAL HABITAT OF THE ENDANGERED COLORADO RIVER FISHES
Surface-disturbing activities will not be allowed within the 100-year floodplain of the Colorado River and San Juan River or
lands within this watershed that contains tributaries with designated critical habitat for the Colorado River fish (bonytail,
humpback chub, Colorado pike minnow, and razorback sucker) listed as endangered under the Endangered Species Act.
Critical habitat was designated for the four endangered Colorado River fishes on March 21, 1994 (59 FR 13374-13400).
Designated critical habitat for all the endangered fishes includes those portions of the 100-year floodplain that contain
primary constituent elements necessary for survival of the species. Avoidance or use restrictions may be placed on portions
of the lease. The following avoidance and minimization measures have been designed to ensure activities carried out on the
lease are in compliance with the Endangered Species Act. Integration of, and adherence to these measures will facilitate
review and analysis of any submitted permits under the authority of this lease. Following these measures could reduce the
scope of Endangered Species Act, Section 7 consultation at the permit stage.
UT-S-182
Monticello Current avoidance and minimization measures include the following:
(Outside of 1. Surveys will be required prior to operations unless species occupancy and distribution information is complete and
MLP) available. All surveys must be conducted by qualified individual(s).
2. Lease activities will require monitoring throughout the duration of the project. To ensure desired results are being
achieved, minimization measures will be evaluated and, if necessary, Section 7 consultation reinitiated.
3. Water production will be managed to ensure maintenance or enhancement of riparian habitat.
4. Avoid loss or disturbance of riparian habitats.
5. Where technically and economically feasible, use directional drilling or multiple wells from the same pad to reduce
surface disturbance and eliminate drilling in suitable riparian habitat. Ensure that such directional drilling does not
intercept or degrade alluvial aquifers.
6. Conduct watershed analysis for leases in designated critical habitat and overlapping major tributaries in order to
determine toxicity risk from permanent facilities.
7. Implement the Utah Oil and Gas Pipeline Crossing Guidance (from BLM National Science and Technology Center).
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8. Drilling will not occur within 100-year floodplains of rivers or tributaries to rivers that contain listed fish species or
critical habitat.
9. In areas adjacent to 100-year floodplains, particularly in systems prone to flash floods, analyze the risk for flash floods to
impact facilities, and use closed loop drilling, and pipeline burial or suspension according to the Utah Oil and Gas
Pipeline Crossing Guidance, to minimize the potential for equipment damage and resulting leaks or spills.
Water depletions from any portion of the Upper Colorado River drainage basin above Lake Powell are considered to
adversely affect or adversely modify the critical habitat of the four resident endangered fish species, and must be evaluated
with regard to the criteria described in the Upper Colorado River Endangered Fish Recovery Program. Formal consultation
with USFWS is required for all depletions. All depletion amounts must be reported to BLM.
Additional measures to avoid or minimize effects to the species may be developed and implemented in consultation with the
USFWS between the lease sale stage and lease development stage to ensure continued compliance with the ESA.
Exception: An exception may be granted by the authorized officer if: 1) There is no practical alternative, and 2) The
development would enhance riparian/aquatic values. This exception would require consultation with the USFWS. The
authorized officer may also grant an exception if an environmental analysis indicates that the nature or the conduct of the
actions, as proposed or conditioned, would not impair the primary constituent element determined necessary for the survival
and recovery of the Endangered Colorado River Fishes.
Modification: The authorized officer may modify the boundaries of the stipulation area if an environmental analysis
indicates, and USFWS (through applicable provisions of the ESA) determines a portion of the area is not being used as
Critical Habitat.
Waiver: A waiver may be granted if the Endangered Colorado River Fishes are de-listed and the Critical Habitat is
determined by USFWS as not necessary for the survival and recovery of the Endangered Colorado River Fishes.
TIMING LIMITATION – CRUCIAL DEER WINTER RANGE
No surface-disturbing activities within crucial deer winter range from November 15 to April 15 to minimize stress and
disturbance to deer during crucial winter months.
UT-S-234 Exception: The authorized officer may grant an exception if, after an analysis, the authorized officer determines that the
Monticello animals are not present in the project area or the activity can be completed so as to not adversely affect the animals. Routine
(Outside of operation and maintenance is allowed.
MLP) Modification: The authorized officer may modify the boundaries of the stipulation area if a portion of the area is not being
used as deer winter range.
Waiver: May be granted if the deer winter range is determined to be unsuitable or unoccupied and there is no reasonable
likelihood of future use of the deer winter range.
UT-S-242 TIMING LIMITATION – CRUCIAL ELK WINTER RANGE
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Monticello No surface-disturbing activities within crucial elk winter range from November 15 to April 15 to minimize stress and
(Outside of disturbance to elk during crucial winter months.
MLP) Exception: The authorized officer may grant an exception if, after an analysis, the authorized officer determines that the
animals are not present in the project area or the activity can be completed so as to not adversely affect the animals. Routine
operation and maintenance is allowed.
Modification: The authorized officer may modify the boundaries of the stipulation area if a portion of the area is not being
used as elk winter range.
Waiver: May be granted if the elk winter range is determined to be unsuitable or unoccupied and there is no reasonable
likelihood of future use of the elk winter range.
CONTROLLED SURFACE USE/TIMING LIMITATION – BALD EAGLES
Bald eagles would be protected as outlined in the Bald Eagle Protection Act of 1940 (16 U.S.C. 668-668d, 54 Stat. 250, as
amended). Activities on BLM lands that contain nesting or winter roosting habitat for the bald eagle would be avoided or
restricted, depending on the duration and timing of the activity. Bald eagles would be managed according to the Best
Management Practices for Raptors and their Associated Habitats in Utah (BLM 2006c). These management requirements
would include restrictions and avoidance measures, including required surveys prior to activity, possible monitoring during
the activity, implementation of seasonal and spatial buffers during the breeding season (January 1 – August 31), and
avoidance of disturbance in riparian areas unless impracticable. No future ground-disturbing activities would be authorized
within a 1.0-mile radius of known bald eagle nest sites year-round. Deviations may be allowed only after appropriate levels
of consultation and coordination with the USFWS/UDWR. In addition, no permanent above-ground structures would be
UT-S-275 allowed within a 0.50-mile radius of a winter roost site if the structure would result in the habitat becoming unsuitable for
Moab, future winter roosting by bald eagles.
Monticello These requirements would help to mitigate the adverse impacts of human disturbance on bald eagles during breeding and
(Outside of roosting seasons.
MLP) 1. Surveys will be required prior to operations unless species occupancy and distribution information is complete and
available. All surveys must be conducted by qualified individual(s), and be conducted according to protocol.
achieved, minimization measures would be evaluated.
4. Temporary activities within 1.0 mile of nest sites will not occur during the breeding season of January 1 to August 31,
unless the area has been surveyed according to protocol and determined to be unoccupied.
5. Temporary activities within 0.5 miles of winter roost areas, e.g., cottonwood galleries, will not occur during the winter
roost season of November 1 to March 31, unless the area has been surveyed according to protocol and determined to be
unoccupied.
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6. No permanent infrastructure will be placed within 1.0 mile of nest sites.
7. No permanent infrastructure will be placed within 0.5 miles of winter roost areas.
8. Remove big game carrion within 100 feet of lease roadways occurring within Bald Eagle foraging range.
9. Avoid loss or disturbance to large cottonwood gallery riparian habitats.
surface disturbance and eliminate drilling in suitable habitat. Utilize direction drilling to avoid direct impacts to large
cottonwood gallery riparian habitats. Ensure that such direction drilling does not intercept or degrade alluvial aquifers.
11. All areas of surface disturbance within riparian areas and/or adjacent uplands should be re-vegetated with native species.
Additional measures may also be employed to avoid or minimize effects to the species between the lease stage and lease
development stage. These additional measures will be developed and implemented in coordination with the USFWS/UDWR
to ensure continued compliance with the Bald Eagle Protection Act.
Exception: An exception may be granted by the authorized officer if authorization is obtained from USFWS/UDWR. The
authorized officer may also grant an exception if an analysis indicates that the nature of the conduct of the actions, as
proposed or conditioned, would not impair the habitat and physical requirements determined necessary for the survival of the
Bald Eagles.
Modification: The authorized officer may modify the boundaries of the stipulation area if an analysis indicates, and
USFWS/UDWR determines that a portion of the area is not being used as Bald Eagle nesting or roosting territories or if
additional nesting or roosting territories are identified.
Waiver: May be granted if there is no reasonable likelihood of site occupancy over a minimum 10 year period.
CONTROLLED SURFACE USE/TIMING LIMITATION – MEXICAN SPOTTED OWL
In areas that contain suitable habitat for MSO or designated Critical Habitat, actions would be avoided or restricted that may
cause stress and disturbance during nesting and rearing of their young. Appropriate measures would depend on whether the
action is temporary or permanent and whether it occurs within or outside the owl nesting season. A temporary action is
completed prior to the following breeding season leaving no permanent structures and resulting in no permanent habitat loss.
UT-S-288 A permanent action continues for more than one breeding season and/or causes a loss of owl habitat or displaces owls
Monticello through disturbances, i.e., creation of a permanent structure. The following avoidance and minimization measures have been
(Outside of designed to ensure activities carried out on the lease are in compliance with the Endangered Species Act. Integration of, and
MLP) adherence to these measures, will facilitate review and analysis of any submitted permits under the authority of this lease.
Following these measures could reduce the scope of Endangered Species Act, Section 7 consultation at the permit stage.
Current avoidance and minimization measures include the following:
1. Surveys will be required prior to implementation of the proposed action. All surveys must be conducted by qualified
individual(s) acceptable to the BLM.
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2. Assess habitat suitability for both nesting and foraging using accepted habitat models in conjunction with field reviews.
Apply the conservation measures below if project activities occur within 0.5 mile of suitable owl habitat. Determine
potential effects of actions to owls and their habitat.
a. Document type of activity, acreage and location of direct habitat impacts, type and extent of indirect impacts relative
to location of suitable owl habitat.
b. Document if action is temporary or permanent.
achieved, minimization measures will be evaluated, and, if necessary, Section 7 consultation reinitiated.
4. Any activity that includes water production will be managed to ensure maintenance or enhancement of riparian habitat.
surface disturbance and eliminate drilling in canyon habitat suitable for MSO nesting.
6. For all temporary actions that may impact owls or suitable habitat:
a. If the action occurs entirely outside of the owl breeding season from March 1 through August 31, and leaves no
permanent structure or permanent habitat disturbance, the action can proceed without an occupancy survey.
b. If the action will occur during a breeding season, a survey for owls is required prior to commencing the activity. If
owls are found, the activity shall be delayed until outside of the breeding season.
c. Rehabilitate access routes created by the project through such means as raking out scars, re-vegetation, gating access
points, etc.
7. For all permanent actions that may impact owls or suitable habitat:
a. Survey two consecutive years for owls according to accepted protocol prior to commencing activities.
b. If owls are found, no disturbing actions will occur within 0.5 mile of an identified site. If nest site is unknown, no
activity will occur within the designated current and historic Protected Activity Center (PAC).
c. Avoid permanent structures within 0.5 mile of suitable habitat unless surveyed and not occupied.
d. Reduce noise emissions (e.g., use hospital-grade mufflers) to 45 dBA at 0.5 mile from suitable habitat, including
canyon rims. Placement of permanent noise-generating facilities should be contingent upon a noise analysis to ensure
noise does not encroach upon a 0.5 mile buffer for suitable habitat, including canyon rims.
e. Limit disturbances to and within suitable habitat by staying on designated and/or approved routes.
f. Limit new access routes created by the project.
U.S. Fish and Wildlife Service between the lease sale stage and lease development stage to ensure continued compliance with
the ESA.
Modifications to the Surface Use Plan of Operations may be required in order to protect the MSO and/or habitat in
accordance with Section 6 of the lease terms, the Endangered Species Act, and the regulations at 43 CFR 3101.1-2.
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Exception: An exception may be granted by the authorized officer if authorization is obtained from USFWS (through
applicable provisions of the ESA). The authorized officer may also grant an exception if an analysis indicates that the nature
or the conduct of the actions would not impair the primary constituent element determined necessary for the survival and
recovery of the MSO and USFWS through consultation concurs with this determination.
Modification: The authorized officer may modify the boundaries of the stipulation area if an analysis indicates and USFWS
(through applicable provisions of the ESA) determines a portion of the area is not being used as Critical Habitat.
Waiver: A waiver may be granted if the MSO is de-listed and the Critical Habitat is determined by USFWS as not necessary
for the survival and recovery of the MSO.
CONTROLLED SURFACE USE/TIMING LIMITATION – SOUTHWESTERN WILLOW FLYCATCHER
In areas that contain riparian habitat within the range for the Southwestern Willow Flycatcher, actions would be avoided or
restricted that may cause stress and disturbance during nesting and rearing of their young. Appropriate measures will depend
on whether the action is temporary or permanent, and whether it occurs within or outside the nesting season. A temporary
action is completed prior to the following breeding season leaving no permanent structures and resulting in no permanent
habitat loss. A permanent action continues for more than one breeding season and/or causes a loss of habitat or displaces
flycatchers through disturbances, i.e., creation of a permanent structure. The following avoidance and minimization measures
have been designed to ensure activities carried out on the lease are in compliance with the Endangered Species Act.
Integration of, and adherence to these measures, will facilitate review and analysis of any submitted permits under the
authority of this lease. Following these measures could reduce the scope of Endangered Species Act, Section 7 consultation
UT-S-290 at the permit stage.
Monticello Current avoidance and minimization measures include the following:
(Outside of 1. Surveys will be required prior to operations unless species occupancy and distribution information is complete and
MLP) available. All surveys must be conducted by qualified individual(s) and be conducted according to protocol.
2. Activities will require monitoring throughout the duration of the project. To ensure desired results are being achieved,
minimization measures would be evaluated and, if necessary, Section 7 consultation reinitiated.
5. Activities will maintain a 300 feet buffer from suitable riparian habitat year long.
6. Activities within 0.25 mile of occupied breeding habitat would not occur during the breeding season of May 1 to August
15.
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7. Ensure that water extraction or disposal practices do not result in change of hydrologic regime that would result in loss or
degradation of riparian habitat.
8. Re-vegetate with native species all areas of surface disturbance within riparian areas and/or adjacent land.
applicable provisions of the ESA). The authorized officer may also grant an exception if an environmental analysis indicates
that the nature of the conduct of the actions, as proposed or conditioned, would not impair the primary constituent element
determined necessary for the survival and recovery of the Southwestern Willow Flycatcher and USFWS concurs with this
determination.
indicates, and USFWS (through applicable provisions of the ESA) determines that a portion of the area is not being used as
Southwestern Willow Flycatcher habitat.
Waiver: May be granted if the Southwestern Willow Flycatcher is de-listed and the Critical Habitat is determined by
USFWS as not necessary for the survival and recovery of the Southwestern Willow Flycatcher.
CONTROLLED SURFACE USE/TIMING LIMITATION – CALIFORNIA CONDOR
In areas that contain habitat for California Condors, actions will be avoided or restricted if the area is known or suspected to
be used by condors that may cause stress and disturbance to condors. Application of appropriate measures will depend on
whether the action is temporary or permanent, and whether it occurs within or outside potential habitat. A temporary action is
completed prior to the following important season of use, leaving no permanent structures and resulting in no permanent
habitat loss. This would include consideration for habitat functionality. A permanent action continues for more than one
season of habitat use, and/or causes a loss of condor habitat function or displaces condors through continued disturbance (i.e.
creation of a permanent structure requiring repetitious maintenance, or emits disruptive levels of noise).
UT-S-294
The following avoidance and minimization measures have been designed to ensure activities carried out on the lease are in
Monticello,
compliance with the Endangered Species Act. Integration of, and adherence to these measures will facilitate review and
Moab
analysis of any submitted permits under the authority of this lease. Following these measures could reduce the scope of
Endangered Species Act, Section 7 consultation at the permit stage. Current avoidance and minimization measures include
the following:
1. Surveys will be required prior to operations unless species occupancy and distribution information is complete and
available. All Surveys must be conducted by qualified individual(s) approved by the BLM, and must be conducted
according to approved protocol.
2. If surveys result in positive identification of condor use, all lease activities will require monitoring throughout the
duration of the project to ensure desired results of applied mitigation and protection. Minimization measures will be
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evaluated during development and, if necessary, Section 7 consultation may be reinitiated.
3. Temporary activities within 1.0 mile of nest sites will not occur during the breeding season.
4. Temporary activities within 0.5 miles of established roosting sites or areas will not occur during the season of use,
August 1 to November 31, unless the area has been surveyed according to protocol and determined to be unoccupied.
6. No permanent infrastructure will be placed within 0.5 miles of established roosting sites or areas.
7. Remove big game carrion to 100 feet from on lease roadways occurring within foraging range.
surface disturbance and eliminate drilling in suitable habitat Utilize directional drilling to avoid direct impacts to large
cottonwood gallery riparian habitats. Ensure that such directional drilling does not intercept or degrade alluvial aquifers.
9. Re-initiation of section 7 consultation with the Service will be sought immediately if mortality or disturbance to
California condors is anticipated as a result of project activities. Additional site-specific measures may also be employed
to avoid or minimize effects to the species. These additional measures will be developed and implemented in
consultation with the U.S. Fish and Wildlife Service to ensure continued compliance with the ESA.
Additional measures may also be employed to avoid or minimize effects to the species between the lease sale and lease
development stages. These additional measures will be developed and implemented in consultation with the U.S. Fish and
Wildlife Service to ensure continued compliance with the Endangered Species Act.
applicable provisions of the ESA). The authorized officer may also grant an exception if an analysis indicates that the nature
of the conduct of the actions, as proposed or conditioned, would not impair the primary constituent element determined
necessary for the survival and recovery of the California Condor and USFWS concurs with this determination.
Modification: The authorized officer may modify the boundaries of the stipulation area if an analysis indicates, and USFWS
(through applicable provisions of the ESA) determines that a portion of the area is not being used as California Condor
nesting or roosting territories.
Waiver: May be granted (through applicable provisions of the ESA) if there is no reasonable likelihood of site occupancy
over a minimum 10-year period.
CONTROLLED SURFACE USE/TIMING LIMITATION – YELLOW-BILLED CUCKOO
UT-S-297
No surface-disturbing activities will be conducted within 100 meters of Yellow-billed Cuckoo habitat (riparian areas) from
Moab,
May 15th through July 20th.
Monticello
(Outside of Exception: An exception may be granted by the authorized officer if authorization is obtained from USFWS (through
MLP) applicable provisions of the ESA). The authorized officer may also grant an exception if an environmental analysis indicates
that the nature of the conduct of the actions, as proposed or conditioned, would not impair the primary constituent element
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determined necessary for the survival and recovery of the Yellow-billed Cuckoo and USFWS concurs with this
determination.
indicates, and USFWS (through applicable provisions of the ESA) determines that a portion of the area is not being used as
Yellow-billed Cuckoo habitat.
Waiver: May be granted if the Yellow-billed Cuckoo is de-listed and if USFWS determines it is not necessary for the
survival and recovery of the Western Yellow-billed Cuckoo.
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Notice Summary Table
NUMBER UTAH LEASE NOTICES

CRUCIAL MULE DEER AND ELK WINTER HABITAT
The lessee/operator has been given notice that the area has been identified as containing crucial deer
UT-LN-04 winter range. Exploration, drilling and other development activities would be restricted from
Moab, Monticello November 15 through April 15. Modifications including seasonal restrictions may be required to the
Surface Use Plan of Operations in order to protect the winter range. This limitation does not apply to
operation and maintenance of producing wells.
CRUCIAL ELK CALVING AND DEER FAWNING HABITAT
UT-LN-10 The lessee/operator is given notice that lands in this lease have been identified as containing crucial
elk calving or deer fawning habitat. Exploration, drilling and other development activities may be
Monticello
restricted from May 1 through June 15 to protect calving / fawning. Modifications may be required in
Outside of MLP the Surface Use Plan of Operations including seasonal timing restrictions to protect the species and its
habitat.
WHITE-TAILED AND GUNNISON PRAIRIE DOG
UT-LN-25
The lessee/operator is given notice that this lease parcel has been identified as containing white-tailed
Moab, Monticello, Vernal,
or Gunnison prairie dog habitat. Modifications to the Surface Use Plan of Operations may be required
Price (Outside of Moab
in order to protect white-tailed or Gunnison prairie dog from surface disturbing activities in
MLP)
accordance with the Endangered Species Act and 43 CFR 3101.1-2.
BALD EAGLE HABITAT
UT-LN-37 The lessee/operator is given notice that lands in this lease have been identified as containing Bald
Eagle Habitat. Modifications to the Surface Use Plan of Operations may be required in order to
Statewide
protect the Bald Eagle and/or habitat from surface disturbing activities in accordance with Section 6 of
the lease terms, Endangered Species Act, and 43 CFR 3101.1-2.
RAPTORS
UT-LN-43 The lessee/operator is given notice that this lease has been identified as containing raptor habitat.
Surveys will be required whenever surface disturbances and/or occupancy is proposed in association
Statewide
with fluid mineral exploration and development within potential raptor nesting areas. Field surveys
will be conducted as determined by the authorized officer of the Bureau of Land Management. Based
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on the result of the field survey, the authorized officer will determine appropriate buffers and timing
limitations. Modifications to the Surface Use Plan of Operations may be required in accordance with
section 6 of the lease terms and 43CFR3101.1-2.
RAPTORS
Appropriate seasonal and spatial buffers shall be placed on all known raptor nests in accordance with
Utah Field Office Guidelines for Raptor Protection from Human and Land use Disturbances (USFWS
2002) and Best Management Practices for Raptors and their Associated Habitats in Utah (BLM 2006).
All construction related activities will not occur within these buffers if pre-construction monitoring
indicates the nests are active, unless a site-specific evaluation for active nests is completed prior to
construction and if a BLM wildlife biologist, in consultation with USFWS and UDWR, recommends
UT-LN-44 that activities may be permitted within the buffer. The BLM will coordinate with the USFWS and
Statewide UDWR and have a recommendation within 3-5 days of notification. Any construction activities
authorized within a protective (spatial and seasonal) buffer for raptors will require an on-site monitor.
Any indication that activities are adversely affecting the raptor and/or its' young the on-site monitor
will suspend activities and contact the BLM Authorized Officer immediately. Construction may occur
within the buffers of inactive nests. Construction activities may commence once monitoring of the
active nest site determines that fledglings have left the nest and are no longer dependent on the nest
site. Modifications to the Surface Use Plan of Operations may be required in accordance with section
6 of the lease terms and 43CFR3101.1-2.
MIGRATORY BIRD
The lessee/operator is given notice that surveys for nesting migratory birds may be required during
UT-LN-45 migratory bird breeding season whenever surface disturbances and/or occupancy is proposed in
association with fluid mineral exploration and development within priority habitats. Surveys should
Statewide
focus on identified priority bird species in Utah. Field surveys will be conducted as determined by the
authorized officer of the Bureau of Land Management. Based on the result of the field survey, the
authorized officer will determine appropriate buffers and timing limitations.
UTAH SENSITIVE SPECIES
UT-LN-49 The lessee/operator is given notice that no surface use or otherwise disruptive activity would be
Statewide allowed that would result in direct disturbance to populations or individual special status plant and
animal species, including those listed on the BLM sensitive species list and the Utah sensitive species
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list. The lessee/operator is also given notice that lands in this parcel have been identified as containing
potential habitat for species on the Utah Sensitive Species List. Modifications to the Surface Use Plan
of Operations may be required in order to protect these resources from surface disturbing activities in
accordance with Section 6 of the lease terms, Endangered Species Act, Migratory Bird Treaty Act and
43 CFR 3101.1-2.
HISTORICAL AND CULTURAL RESOURCE VALUES
70UT-LN-67 The lessee/operator is given notice that lands in this lease may contain significant Historical and
Statewide Cultural Resources. Modifications to the Surface Use Plan of Operations may be required for the
protection of these resources.
NOTIFICATION & CONSULTATION REGARDING CULTURAL RESOURCES
The lease area may now or hereafter be found to contain historic properties and/or resources protected
under the National Historic Preservation Act (NHPA), the Archaeological Resources Protections Act
(ARPA), the Native American Graves Protection and Repatriation Act (NAGPRA), the American
Indian Religious Freedom Act (AIRFA), other statues and Executive Order 13007, and which may be
UT-LN-68 of concern to Native American tribes, interested parties, and the State Historic Preservation Officer
Statewide (SHPO). BLM will not approve any ground disturbing activities as part of future lease operations until
it completes applicable requirements of the National Historic Preservation Act (NHPA), including the
completion of any required procedure for notification and consultation with appropriate tribe(s) and/or
the SHPO. BLM may require modifications to exploration and development proposals to further its
conservation and management objectives on BLM-approved activities that are determine to affect or
impact historic or cultural properties and/or resources.
HIGH POTENTIAL FOR CULTURAL RESOURCES
This parcel is located in an area of high concentrations of cultural resources. Known cultural sites are
UT-LN-69 fragile and many are buried under sandy deposits which migrate due to their susceptibility to wind.
These sites, or large portions, are not visible from the surface. Therefore, the following mitigation
Statewide (Outside of
measures may be applied to any surface disturbance of this parcel: 1) pre-surface disturbance cultural
Moab MLP)
resource inventories; 2) pre-surface disturbance subsurface testing; 3) monitoring of ground
disturbance; and 4) post-disturbance monitoring identifying resources as the soils stabilize around a
project.
UT-LN-70 HIGH POTENTIAL FOR CULTURAL RESOURCE OCCURRENCE
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Statewide The lessee/operator is given notice that lands in this lease contain significant Cultural Resources.
Modifications to the Surface Use Plan of Operations may be required for the protection of these
resources. Class III level block inventories may be required to determine resource location and
possible impact to the resource.
HIGH POTENTIAL PALEONTOLOGICAL RESOURCES
The lessee/operator is given notice that lands in this lease have been identified as having high
UT-LN-72 potential for paleontological resources. Surveys will be required and modifications to the Surface Use
Statewide Plan of Operations may be required in order to protect paleontological resources from surface
disturbing activities in accordance with Section 6 of the lease terms and 43 CFR 3101.1-2. In addition,
monitoring may be required during surface disturbing activities.
AIR QUALITY MITIGATION MEASURES
The lessee is given notice that the Bureau of Land Management (BLM) in coordination with the U.S.
Environmental Protection Agency and the Utah Department of Air Quality, among others, has
developed the following air quality mitigation measures that may be applied to any development
proposed on this lease. Integration of and adherence to these measures may help minimize adverse
local or regional air quality impacts from oil and gas development (including but not limited to
construction, drilling, and production) on regional ozone formation.
• All internal combustion equipment would be kept in good working order.
• Water or other approved dust suppressants would be used at construction sites and along roads, as
UT-LN-96 determined appropriate by the Authorized Officer.
Statewide • Open burning of garbage or refuse would not occur at well sites or other facilities.
• Drill rigs would be equipped with Tier II or better diesel engines.
• Vent emissions from stock tanks and natural gas TEG dehydrators would be controlled by routing
the emissions to a flare or similar control device which would reduce emissions by 95% or
greater.
• Low bleed or no bleed pneumatics would be installed on separator dump valves and other
controllers.
• During completion, flaring would be limited as much as possible. Production equipment and
gathering lines would be installed as soon as possible.
• Well site telemetry would be utilized as feasible for production operations.
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• Stationary internal combustion engine would comply with the following standards: 2g NOx/bhp-
hr for engines <300HP; and 1g NOx/bhp-hr for engines >300HP.
Additional site-specific measures may also be employed to avoid or minimize effects to local or
regional air quality. These additional measures will be developed and implemented in coordination
with the U.S. Environmental Protection Agency, the Utah Department of Air Quality, and other
agencies with expertise or jurisdiction as appropriate based on the size of the project and magnitude of
emissions.
REGIONAL OZONE FORMATION CONTROLS
To mitigate any potential impact oil and gas development emissions may have on regional ozone
formation, the following Best Management Practices (BMPs) would be required for any development
projects:
UT-LN-99 • Tier II or better drilling rig engines
Statewide • Stationary internal combustion engine standard of 2g NOx/bhp-hr for engines <300HP and 1g
NOx/bhp-hr for engines >300HP
• Low bleed or no bleed pneumatic pump valves
• Dehydrator VOC emission controls to +95% efficiency
• Tank VOC emission controls to +95% efficiency
AIR QUALITY ANALYSIS
The lessee/operator is given notice that prior to project-specific approval, additional air quality
UT-LN-102 analyses may be required to comply with the National Environmental Policy Act, Federal Land Policy
Management Act, and/or other applicable laws and regulations. Analyses may include dispersion
Statewide
modeling and/or photochemical modeling for deposition and visibility impacts analysis, control
equipment determinations, and/or emission inventory development. These analyses may result in the
imposition of additional project-specific air quality control measures.
WESTERN YELLOW-BILLED CUCKOO
The Lessee/Operator is given notice that the lands in or adjacent to this parcel contain potentially
UT-LN-113 (Outside of suitable habitat that falls within the range for western yellow-billed cuckoo, a federally listed species.
Moab MLP and Vernal) Avoidance or use restrictions may be placed on portions of the lease. Application of appropriate
measures will depend upon whether the action is temporary or permanent, and whether it occurs
within or outside the breeding and nesting season. A temporary action is completed prior to the
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following breeding season leaving no permanent structures and resulting in no permanent habitat loss.
A permanent action could continue for more than one breeding season and/or cause a loss of habitat or
displace western yellow-billed cuckoos through disturbances. The following avoidance and
minimization measures have been designed to ensure activities carried out on the lease are in
compliance with the Endangered Species Act. Integration of, and adherence to, these measures will
facilitate review and analysis of any submitted permits under the authority of this lease. Following
these measures could reduce the scope of Endangered Species Act, Section 7 consultation at the
permit stage. Avoidance and minimization measures include the following:
1. Habitat suitability within the parcel and/or within a 0.25 mile buffer of the parcel will be
identified prior to lease development to identify potential survey needs.
2. Protocol Breeding Season Surveys will be required in suitable habitats prior to operations unless
species occupancy and distribution information is complete and available. All Surveys must be
conducted by permitted individual(s), and be conducted according to protocol.
3. For all temporary actions that may impact cuckoo or suitable habitat:
a. If action occurs entirely outside of the cuckoo breeding season (June 1 – Aug 31), and leaves
no structure or habitat disturbance, action can proceed without a presence/absence survey.
b. If action is proposed between June 1 and August 31, presence/absence surveys for cuckoo will
be conducted prior to commencing activity. If cuckoo are detected, activity should be delayed
until September 1.
c. Eliminate access routes created by the project through such means as raking out scars,
revegetation, gating access points, etc.
4. For all permanent actions that may impact cuckoo or suitable habitat:
a. Protocol level surveys by permitted individuals will be conducted prior to commencing
activities.
b. If cuckoos are detected, no activity will occur within 0.25 mile of occupied habitat.
c. Avoid drilling and permanent structures within 0.25 mile of suitable habitat unless absence is
determined according to protocol level surveys conducted by permitted individual(s).
d. Ensure noise levels at 0.25 mile from suitable habitat do not exceed baseline conditions.
Placement of permanent noise-generating facilities should be determined by a noise analysis to
ensure noise does not encroach upon a 0.25 mile buffer for suitable habitat.
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5. Temporary or permanent actions will require monitoring throughout the duration of the project to
ensure that western yellow-billed cuckoo or its habitat is not affected in a manner or to an extent
not previous considered. Avoidance and minimization measures will be evaluated throughout the
duration of the project.
6. Water produced as a by-product of drilling or pumping will be managed to ensure maintenance or
enhancement of riparian habitat.
7. Where technically and economically feasible, use directional drilling or multiple wells from the
same pad to reduce surface disturbance and eliminate drilling in suitable habitat. Ensure that such
directional drilling does not intercept or degrade alluvial aquifers.
8. Ensure that water extraction or disposal practices do not result in change of hydrologic regime
that would result in loss or degradation of riparian habitat.
9. Re-vegetate with native species all areas of surface disturbance within riparian areas and/or
adjacent uplands.
Additional measures to avoid or minimize effects to the species may be developed and implemented
in consultation with the U.S. Fish and Wildlife Service between the lease sale stage and lease
development stage to ensure continued compliance with the ESA.
LIGHT AND SOUND - SENSITIVE RESOURCES
The lessee/operator may be required to utilize best management practices and the best available
technology in order to minimize/mitigate noise and light pollution impacts. In accordance with section
6 of the lease terms and 43 CFR 3101.1-2, modifications to Surface Use Plan of Operations may be
required to minimize the impacts to the values of silence and night skies to visitors of parks,
UT-LN-125 monuments, river corridors and other destinations where light and/or sound impacts would mar the
visitor experience. For example, the lessee/operator may be required to install multi-cylinder pumps,
MbFO and MtFO
hospital sound reducing mufflers, and/or place exhaust systems in manner that directs noise away
(Outside MLP)
from or reduces noise at the area. Additionally, the lessee/operator may be required to utilize such
methods such as limiting the height of light poles, limiting wattage intensity, constructing light shields
and/or adhering to prescribed restrictions on the timing for conducting artificially illuminated
operations in order to minimize/mitigate light pollution impacts. However, the above described
requirements will not be applicable when their implementation would adversely affect human health
and safety.
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FLOODPLAIN MANAGEMENT
The lessee/operator is given notice that, in accordance with Executive Order 11988, to avoid adverse
UT-LN-128 impact to floodplains 1) facilities should be located outside the 100 year floodplain, or 2) would be
minimized or mitigated by modification of surface use plans within floodplains present within the
lease.
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Threatened and Endangered Species Notices
NUMBER THREATENED & ENDANGERED SPECIES NOTICES

MEXICAN SPOTTED OWL
The Lessee/Operator is given notice that the lands in this parcel contain suitable habitat for Mexican spotted owl, a federally
listed species. The Lessee/Operator is given notice that the lands in this lease contain Designated Critical Habitat for the
Mexican spotted owl, a federally listed species. Critical habitat was designated for the Mexican spotted owl on August 31,
2004 (69 FR 53181-53298). Avoidance or use restrictions may be placed on portions of the lease. Application of appropriate
measures will depend whether the action is temporary or permanent, and whether it occurs within or outside the owl nesting
season.
A temporary action is completed prior to the following breeding season leaving no permanent structures and resulting in no
permanent habitat loss. A permanent action continues for more than one breeding season and/or causes a loss of owl habitat
or displaces owls through disturbances, i.e. creation of a permanent structure.
compliance with the Endangered Species Act. Integration of, and adherence to these measures, will facilitate review and
T&E-06 analysis of any submitted permits under the authority of this lease. Following these measures could reduce the scope of
(Outside Endangered Species Act, Section 7 consultation at the permit stage. Current avoidance and minimization measures include
Moab MLP) the following:
available. All Surveys must be conducted by qualified individual(s).
2. Assess habitat suitability for both nesting and foraging using accepted habitat models in conjunction with field reviews.
Apply the conservation measures below if project activities occur within 0.5 mile of suitable owl habitat. Determine
potential effects of actions to owls and their habitat.
a. Document type of activity, acreage and location of direct habitat impacts, type and extent of indirect impacts relative
to location of suitable owl habitat.
b. Document if action is temporary or permanent.
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July 2019

surface disturbance and eliminate drilling in canyon habitat suitable for Mexican spotted owl nesting.
6. For all temporary actions that may impact owls or suitable habitat:
a. If the action occurs entirely outside of the owl breeding season (March 1 – August 31), and leaves no permanent
structure or permanent habitat disturbance, action can proceed without an occupancy survey.
b. If action will occur during a breeding season, survey for owls prior to commencing activity. If owls are found,
activity must be delayed until outside of the breeding season.
c. Rehabilitate access routes created by the project through such means as raking out scars, re-vegetation, gating access
points, etc.
7. For all permanent actions that may impact owls or suitable habitat:
a. Survey two consecutive years for owls according to accepted protocol prior to commencing activities.
b. If owls are found, no actions will occur within 0.5 mile of identified nest site. If nest site is unknown, no activity will
occur within the designated Protected Activity Center (PAC).
c. Avoid drilling and permanent structures within 0.5 mi of suitable habitat unless surveyed and not occupied.
d. Reduce noise emissions (e.g., use hospital-grade mufflers) to 45 dBA at 0.5 mile from suitable habitat, including
canyon rims. Placement of permanent noise-generating facilities should be determined by a noise analysis to ensure
noise does not encroach upon a 0.5 mile buffer for suitable habitat, including canyon rims.
e. Limit disturbances to and within suitable habitat by staying on approved routes.
f. Limit new access routes created by the project.
U.S. Fish and Wildlife Service between the lease sale stage and lease development stage to ensure continued compliance
with the Endangered Species Act.
SOUTHWESTERN WILLOW FLYCATCHER
The Lessee/Operator is given notice that the lands in this parcel contains riparian habitat that falls within the range for
southwestern willow flycatcher (Empidonax traillii extimus), a federally listed species. Avoidance or use restrictions may be
T&E-07 placed on portions of the lease. Application of appropriate measures will depend whether the action is temporary or
permanent, and whether it occurs within or outside the nesting season. A temporary action is completed prior to the
(Outside
following breeding season leaving no permanent structures and resulting in no permanent habitat loss. A permanent action
Moab MLP)
continues for more than one breeding season and/or causes a loss of habitat or displaces flycatchers through disturbances, i.e.
creation of a permanent structure. The following avoidance and minimization measures have been designed to ensure
activities carried out on the lease are in compliance with the Endangered Species Act. Integration of, and adherence to these
measures, will facilitate review and analysis of any submitted permits under the authority of this lease. Following these
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July 2019

measures could reduce the scope of Endangered Species Act, Section 7 consultation at the permit stage. Current avoidance
and minimization measures include the following:
available. All Surveys must be conducted by qualified individual(s), and be conducted according to protocol.
5. Drilling activities will maintain a 300 ft. buffer from suitable riparian habitat year long.
6. Drilling activities within 0.25 mile of occupied breeding habitat will not occur during the breeding season of May 1 to
August 15.
7. Ensure that water extraction or disposal practices do not result in change of hydrologic regime that would result in loss
or degradation of riparian habitat.
8. Re-vegetate with native species all areas of surface disturbance within riparian areas and/or adjacent uplands.
with the ESA.
CALIFORNIA CONDOR
The Lessee/Operator is given notice that the lands located in this parcel contain potential habitat for the California Condor, a
federally listed species. Avoidance or use restrictions may be placed on portions of the lease if the area is known or
suspected to be used by condors. Application of appropriate measures will depend on whether the action is temporary or
permanent, and whether it occurs within or outside potential habitat. A temporary action is completed prior to the following
important season of use, leaving no permanent structures and resulting in no permanent habitat loss. This would include
T&E-11
consideration for habitat functionality. A permanent action continues for more than one season of habitat use, and/or causes a
(Outside
loss of condor habitat function or displaces condors through continued disturbance (i.e. creation of a permanent structure
Moab MLP)
requiring repetitious maintenance, or emits disruptive levels of noise).
compliance with the Endangered Species Act. Integration of, and adherence to these measures will facilitate review and
analysis of any submitted permits under the authority of this lease. Following these measures could reduce the scope of
Endangered Species Act, Section 7 consultation at the permit stage. Current avoidance and minimization measures include
the following:
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July 2019

available. All Surveys must be conducted by qualified individual(s) approved by the BLM, and must be conducted
according to approved protocol.
2. If surveys result in positive identification of condor use, all lease activities will require monitoring throughout the
duration of the project to ensure desired results of applied mitigation and protection. Minimization measures will be
3. Temporary activities within 1.0 mile of nest sites will not occur during the breeding season.
4. Temporary activities within 0.5 miles of established roosting sites or areas will not occur during the season of use,
August 1 to November 31, unless the area has been surveyed according to protocol and determined to be unoccupied.
6. No permanent infrastructure will be placed within 0.5 miles of established roosting sites or areas.
7. Remove big game carrion 100 feet from lease roadways occurring within foraging range.
surface disturbance and eliminate drilling in suitable habitat. Utilize directional drilling to avoid direct impacts to large
9. Re-initiation of section 7 consultation with the Service will be sought immediately if mortality or disturbance to
California condors is anticipated as a result of project activities. Additional site-specific measures may also be
employed to avoid or minimize effects to the species. These additional measures will be developed and implemented in
consultation with the U.S. Fish and Wildlife Service to ensure continued compliance with the ESA.
development stages. These additional measures will be developed and implemented in consultation with the U.S. Fish and
Wildlife Service to ensure continued compliance with the Endangered Species Act.
SOUTHWESTERN WILLOW FLYCATCHER HABITAT – RIPARIAN AREAS
The lessee/operator is given notice that the lands in this parcel contains riparian habitat within the range for southwestern
willow flycatcher. In order to protect southwestern willow flycatcher habitat and avoid negative impacts to the species,
T&E-26 actions would be avoided or restricted that may cause stress and disturbance during nesting and rearing of their young.
Appropriate measures would depend on whether the action is temporary or permanent, and whether it occurs within or
(Moab MLP)
outside the nesting season. A temporary action is completed prior to the following breeding season leaving no permanent
structures and resulting in no permanent habitat loss. A permanent action continues for more than one breeding season
and/or causes a loss of habitat or displaces flycatchers through disturbances, i.e., creation of a permanent structure. Current
avoidance and minimization measures include the following:
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July 2019

1. Surveys would be required prior to operations unless species occupancy and distribution information is complete and
available. All surveys must be conducted by qualified individual(s) and be conducted according to protocol.
2. Activities would require monitoring throughout the duration of the project. To ensure desired results are being achieved,
minimization measures would be evaluated and, if necessary, Section 7 consultation reinitiated.
3. Water production would be managed to ensure maintenance or enhancement of riparian habitat.
5. Activities would maintain a 330 feet buffer from suitable riparian habitat year long.
6. Activities within 0.25-mile of occupied breeding habitat would not occur during the breeding season of April 15 to
August 15.
7. Noise emissions within 0.25-miles of suitable habitat for the southwestern willow flycatcher will not exceed baseline
conditions during the breeding season of April 15 to August 15.
8. Ensure that water extraction or disposal practices do not result in change of hydrologic regime that would result in loss
or degradation of riparian habitat.
9. Re-vegetate with native species all areas of surface disturbance within riparian areas and/or adjacent land.
10. Avoid loss or disturbance of riparian habitats.
YELLOW-BILLED CUCKOO
The lessee/operator is given notice that the lands in or adjacent to this parcel contain potentially suitable habitat that falls
within the range for western yellow-billed cuckoo, a Federally listed species. Avoidance or use restrictions may be placed on
portions of the lease. Application of appropriate measures will depend whether the action is temporary or permanent, and
whether it occurs within or outside the breeding and nesting season. A temporary action is completed prior to the following
T&E-27 breeding season, leaving no permanent structures and resulting in no permanent habitat loss. A permanent action could
(Moab MLP) continue for more than one breeding season and/or cause a loss of habitat or displace western yellow-billed cuckoos through
disturbances. The following avoidance and minimization measures have been designed to ensure activities carried out on the
lease are in compliance with the Endangered Species Act (ESA). Integration of and adherence to these measures will
facilitate review and analysis of any submitted permits under the authority of this lease. Following these measures could
reduce the scope of ESA, Section 7 consultation at the permit stage. Avoidance and minimization measures include the
following:
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July 2019

1. Habitat suitability within the parcel and/or within a 0.5-mile buffer of the parcel will be identified prior to lease
development to identify potential survey needs. Habitat suitability should be determined in accordance with Guidelines
for the identification of suitable habitat for WYBCU in Utah.
2. Protocol Breeding Season Surveys will be required in suitable habitats prior to operations unless species occupancy and
distribution information is complete and available. All Surveys must be conducted by permitted individual(s), and be
conducted according to protocol.
3. For all temporary actions that may impact cuckoo or suitable habitat:
a. If action occurs entirely outside of the cuckoo breeding season (June 1 to August 31), and leaves no structure or
habitat disturbance, action can proceed without a presence/absence survey.
b. If action is proposed between June 1 to August 31, presence/absence surveys for cuckoo will be conducted prior to
commencing activity. If cuckoo are detected, activity should be delayed until September 1.
c. Eliminate access roads created by the project through such means as raking out scars, revegetation, gating access
points, etc.
4. For all permanent actions that may impact cuckoo or suitable habitat:
a. Protocol level surveys by permitted individuals will be conducted prior to commencing activities.
b. If cuckoos are detected, no activity will occur within 0.25-mile of occupied habitat.
c. Avoid drilling and permanent structures within 0.25-mile of suitable habitat unless absence is determined according
to protocol level survey conducted by permitted individual(s).
d. Ensure noise levels at 0.25-mile from suitable habitat do not exceed baseline conditions. Placement of permanent
noise-generating facilities should be determined by a noise analysis to ensure noise does not encroach upon the 0.25-
mile buffer for suitable habitat.
5. Temporary or permanent actions will require monitoring throughout the duration of the project to ensure that western
yellow-billed cuckoo or its habitat is not affected in a manner or to an extent not previously considered. Avoidance and
minimization measures will be evaluated throughout the duration of the project.
6. Water produced as by-product of drilling or pumping will be managed to ensure maintenance or enhancement of
riparian habitat.
7. Where technically or economically feasible, use directional drilling or multiple wells from the same pad to reduce
surface disturbance and eliminate drilling is suitable habitat. Ensure that such directional drilling does not intercept or
degrade alluvial aquifers.
8. Ensure that water extraction or disposal practices do not result in a change of hydrologic regime that would result in loss
or degradation of riparian habitat
9. Re-vegetate with native species all areas of surface disturbance within riparian areas and/or adjacent uplands.
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July 2019

with the ESA.
CALIFORNIA CONDOR – POTENTIAL HABITAT
The lessee/operator is given notice that the lands located in this parcel contain potential habitat for the California condor.
Avoidance or use restrictions may be placed on portions on areas known or suspected to be used by condors. Application of
appropriate measures would depend on whether the action is temporary or permanent, and whether it occurs within or
outside potential habitat. A temporary action is completed prior to the following important season of use, leaving for habitat
functionality. A permanent action continues for more than one season of habitat use, and/or causes a loss of condor habitat
function or displaces condors through continued disturbance (i.e., creation of a permanent structure requiring repetitious
maintenance or emits disruptive levels of noise).
Current avoidance and minimization measures include the following:
1. The Peregrine Fund will be contacted early and throughout project design and implementation to determine and monitor
the locations and status of California condors in or near the project area.
2. Surveys would be required prior to operations in suitable habitat, unless species occupancy and distribution information
is complete and available. All Surveys must be conducted by qualified individual(s) approved by the BLM and must be
T&E-28 conducted according to approved protocols.
(Moab MLP) 3. All workers will be informed about potential condor presence.
4. If condors are present within the project area the Peregrine Fund will be contacted. If there is any potential that the
project will affect condors the USFWS will be contacted immediately.
5. The project area will be kept clean (e.g., trash disposed of, tools and materials picked up) in order to minimize the
possibility of condors accessing inappropriate materials.
6. To prevent water contamination and potential condor poisoning, a hazardous material (including vehicle fluids) leakage
and spill plan will be developed and implemented. The plan will include provisions for immediate clean-up of any
hazardous substance, and will outline how each hazardous substance will be treated in case of leakage or spill. The plan
will be reviewed by the district biologist to insure that condors are adequately addressed.
7. If surveys result in positive identification of condor use, all lease activities would require monitoring throughout the
duration of the project to ensure desired results of applied mitigation and protection. Minimization measures would be
8. Temporary activities within 1.0-mile of nest sites would not occur during the breeding season.
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July 2019

9. Temporary activities within 0.5-miles of established roosting sites or areas would not occur during the season of use,
which is from August 1 to November 30; unless the area has been surveyed according to protocols consulted on with
USFWS and determined to be unoccupied.
10. No permanent infrastructure would be placed within 1.0-mile of nest sites.
11. No permanent infrastructure would be placed within 0.5-miles of established roosting sites or areas.
12. Remove big game carrion to 100 feet from on lease roadways occurring within foraging range.
surface disturbance and eliminate drilling in suitable habitat Utilize directional drilling to avoid direct impacts to large
14. Re-initiation of Section 7 consultation with the USFWS would be sought immediately if mortality or disturbance to
California condors is anticipated as a result of project activities. Additional site-specific measures may also be employed
to avoid or minimize effects to the species. These additional measures would be developed and implemented in
consultation with the USFWS to ensure continued compliance with the ESA.
development stages. These additional measures would be developed and implemented in consultation with the USFWS to
ensure continued compliance with the ESA.
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Appendix C – Figures/Maps
• Lease Sale Parcel Overview
• Hovenweep Viewshed Analysis
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Figure 4. Lease Sale Parcel Overview.
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July 2019
Figure 5. Hovenweep Viewshed Analysis
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July 2019
Appendix D – Interdisciplinary Parcel Review Team Checklist

DETERMINATION OF STAFF:
NP = not present in the area impacted by the proposed or alternative actions
NI = present, but not affected to a degree that detailed analysis is required
PI = present with potential for relevant impact that need to be analyzed in detail in the EA
Determination Resource Rationale for Determination* Parcel Reviewer
Leasing itself would not have impacts to air quality. However, should development
occur on issued leases, activities related to exploration, construction, drilling,
completion, testing, and production of an oil or gas well may affect air quality All
parcels are in areas designated as attainment or unclassifiable for all criteria air
pollutants.
Erik Vernon
PI Air Quality
4/16/2019
Air Quality Stips and LNs to be applied to all parcels:
UT-S-1: Air Quality
LN-96: Air Quality Mitigation Measures
LN-99: Regional Ozone Formation Controls
LN-102: Air Quality Analysis
John Chmelir
Areas of
(Cultural)
Critical
NP None of the parcels are within ACECs. 4/15/2019
Environmental
Jason Byrd
Concern
4/15/2019
BLM Natural Misti Haines
NP None of the parcels are within BLM Natural Areas
Areas 4/15/2019
BLM archaeologists have compiled cultural resources data from the Monticello field
office cultural resource libraries, GIS data (CURES), and the Preservation Pro
database area. These data sources contain information of all of the recorded cultural
resource sites and cultural resource survey data for the area available to BLM and the
Utah Division of State History. In addition, the BLM is using the field office cultural
resources planning model to help provide cultural resources information for areas not
previously surveyed (Beck et al. 2017).
The MFO planning area contains one of the richest records of prehistoric archaeology
in the United States. After more than 10,000 years of occupation by hunter-gatherers
of the Paleoindian and Archaic periods, people in the region added domesticated
crops to their diets, beginning an approximately two-millennium-long period known
as the Formative. Formative period Ancestral Puebloan sites comprise by far the
largest part of the planning area’s archaeological record and provide a very detailed John Chmelir
perspective on events in the ancient Southwest such as population movements and 4/15/2019
Cultural
NI the development of variable, sometimes far-reaching, social interaction networks. Glenn Stelter
Resources
The record is dominated by the remains of structures and cultural material from the 4/17/2019
Ancestral Puebloan, who occupied the area from ca. A.D. 1 to A.D. 1300, although
previous occupation by “preceramic” foragers and farmers is abundant (e.g., (Davis
1989) (Matson 2014); (Robins 1997)). The area also shows considerable evidence of
occupation by Protohistoric and Historic peoples, both Native American and Euro-
American, after the Ancestral Puebloans left the area in the late A.D. 1200s (e.g.,
(Hurst and Robinson 2014); (McPherson 1995)). In fact, researchers have
demonstrated the existence in San Juan County of archaeological materials
representing every time period from the present back to the waning years of the
Pleistocene epoch (Hurst and Robinson 2014, 23)
Archaeologist use this data to determine if oil and gas development could occur
within each parcel while avoiding know cultural sites. The parcels are reviewed for
the application of stipulations and lease notices as required by the Monticello RMP.
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July 2019
The preliminary analysis using the cultural resources planning model (Beck et. Al.,
2017) indicates that, in the vast majority of the Monticello FO parcels, there is a high
probability of the presence of cultural resources.
The Monticello RMP requires stipulation UT-S-170: CSU – Cultural to be attached
to all parcels.
BLM received concurrence with its finding of No Adverse Effect to Historic
Properties from the Utah State Historic Preservation Officer on March 25, 2019.
BLM’s consultation with Native American Tribes, is ongoing.
For future undertakings related to this lease sale, BLM will not approve any ground
disturbing activities until it completes its obligations to consider cultural resources
under NEPA, NHPA and other authorities specific to those future undertakings.
Consideration of impacts to cultural resources and adverse effects to historic properties
will be taken into account during the review stage of site specific development plans.
From the cultural resource report for the March 2019 Oil and Gas Lease Sale, a total of
598 sites were identified within the parcels. 1006 sites were identified outside of the
parcels within a 1/2 buffer. The report identified cultural resources eligible to the
National Register of Historic Places (NRHP) as well as cultural resources that are not
eligible to the NRHP. The amount of cultural resource survey within the parcel area
ranges from 4.38% to 60.68%.
Cultural: Resource Stipulations and Lease Notices:

Cultural Resource Stipulation as required by Handbook H-3120-1, UT-S-170, UT-
LN-67 (Historical and Cultural Resource Values), UT-LN-68 (Notification and
Consultation Regarding Cultural Resources), UT-LN-69 (High Potential For Cultural
Resources) and UT-LN-70 (High Potential for Cultural Resource Occurrence) to all
parcels.
Greenhouse Gases (GHG) are composed mostly of CO2, CH4, N2O, HFCs, PFCs, &
Greenhouse SF6. Primary sources of GHG emissions include fossil fuel combustion for well
Erik Vernon
PI Gas/Climate construction and operation, fugitive CH4, and combustion of produced oil and gas. A
4/16/2019
Change representative emissions inventory of GHGs for parcel development, contribution to
cumulative emissions, and impacts to climate change should be presented.
Minority and low income populations do exist in the Monticello FO area. The
PRMP/FEIS, 2008 adequately assessed impacts to environmental justice population
as defined in Executive Order 12898 and it was determined that no BLM action
proposed across all alternatives or the Proposed Plan would target or cause any
disproportionate impacts to any minority or low income segments of the population
(Monticello PRMP/FEIS, 2008 p. 4-421).
Environmental All citizens can file an expression of interest or participate in the bidding process (43 CGiffen
NI
Justice CFR §3120.3-2). The stipulations and notices applied to the subject parcels do not 4/10/2019
place an undue burden on these groups.
Potential impacts to Environmental Justice from oil and gas leasing are adequately
analyzed and documented in the environmental analysis prepared for the Monticello
RMP. Actions and impacts are not changed from those disclosed in the existing
NEPA documents.
The impacts of oil and gas development on general wildlife and big game and general
wildlife species and their habitats were fully analyzed in the Monticello RMP, 2008
Fish and
and the March 2018 EA. Actions and impacts are not changed from those disclosed
Wildlife Melissa Wardle
in these NEPA documents. See Wildlife and Botany Resources Leasing Assessment
Excluding 4/15/2019
NI for detailed species and habitat information.
USFWS Karen Cathey
The following stipulation will be attached, as noted to all parcels:
Designated 05/06/2019
Species
• UT-S-234: TL – Crucial Deer Winter Range
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July 2019
This proposed sale and issuance of an oil and gas leases would not authorize any
ground disturbances which could affect these resources. Leasing is an administrative
action that does not result in any surface disturbance. Site-specific effects cannot be
analyzed until an exploration or development application is received, after leasing has
occurred. The applied lease stipulations and notices will notify buyers during sale of
leases and allow for the opportunity to make adjustments at the site specific level when
an APD is received and will ensure impacts are addressed. Future development
proposals on the leases would be subject to the standard lease terms, and all applicable
laws, regulations and onshore orders in existence at the time of lease issuance.
Additional detailed analysis in this EA is not necessary.
Oil and Gas development that may occur as a result of this lease sale may affect
floodplains. The decision to lease is connected to these impacts; however it does not
affect floodplains to a degree that detailed analysis is required. If an APD is filed,
SOPs required by regulation and design features would be sufficient to isolate and
protect all usable ground or surface water sources before drilling or exploration begin.
The SOPs include the requirements for disposal of produced water contained in
Onshore Oil and Gas Order (O.O.) No. 7 and the requirements for drilling operations
contained in O.O No. 2. Potential fresh water aquifers zones would be protected by the
requirement of casing and cementing the drill hole to total depth. The casing would be
pressure tested to ensure integrity prior to drilling out the surface casing shoe plug.
Executive Order 11990 directs federal agencies to avoid short and long term impacts
to wetlands to the extent possible; Executive Order 11988 directs federal agencies to
avoid similar impacts through modification of floodplains, and to restore and preserve
the natural and beneficial values served by floodplains. The BLM Manual 1737 – Jed Carling
Riparian-Wetland Area Management, Riparian-Wetland Initiative provides direction 04/11/19
NI Floodplains for planning and management actions related to riparian areas, and Instructional
Memorandum No UT 2005-091 provides specific guidance to Utah BLM riparian Ken Bradshaw
lands while supporting all BLM national guidance directives. 04/18/2019
RMP RIP 5 – No surface disturbing activities are allowed in active floodplains,

public water reserves, or within 100 meters of riparian areas unless it can be shown
that: a) There is no practicable alternative or b) All long-term impacts can be fully
mitigated or, c) The activity will benefit and enhance the riparian area.
UT-S-128: NSO -- Floodplains, Riparian Areas, Springs, and Public Water Reserves
will be attached to the following parcels: 406, 407, 408, 409, 410, 411, 412, 414, 415,
419, 423, and 424.
Given the executive directives, Stipulations, Lease Notices and mitigation measures
(e.g., BMPs and SOPs) discussed above, impacts to floodplains would be mitigated
and detailed analysis is not required in this EA.
Impacts to Fire and Fuels Management from leasing are adequately analyzed in the
Monticello RMP. Actions and impacts are not changed from those disclosed in these
NEPA documents. The implementation of appropriate reclamation standards at the
Fuels/Fire P. Plemons
NI APD stage would prevent an increase of hazardous fuels. Fuels and fire management
Management 04/15/19
would not be impacted by the lease process. Fuels projects planned for the parcels
proposed for competitive leasing would still be able to be implemented. BMPs, SOPs
and site specific mitigation may be applied at the APD stage as COAs.
The proposed action would not exceed the level of activity predicted in the
T. McDougall
Mineral Reasonably Foreseeable Development Scenario (RFDS) prepared for the 2008
4/11/19
NI Resources/Ener Monticello Field Office Resource Management Plan (RMP). The RFDS is
Angela Wadman
gy Production documented at Appendix G. Potential impacts to mineral resources and energy
4/25/2019
production from oil and gas leasing and development are adequately analyzed and
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July 2019
documented in the Proposed RMP and Final Environmental Impact Statement

(FEIS). Actions and impacts are not changed from those disclosed in the existing
NEPA document.
Oil and gas exploration could lead to an increased understanding of the geologic
setting, as subsurface data obtained through lease operations may become public
record. This information promotes an understanding of mineral resources as well as
geologic interpretation. While conflicts could arise between oil and gas operations
and other mineral operations, these could generally be mitigated under 43 CFR
3101.1-2 and under standard lease terms (Sec. 6) where sitting and design of facilities
may be modified to protect other resources.
The majority of flow back water from hydraulic fracturing in Utah is recycled and
used in future hydraulic fracturing completions. Therefore, the underground injection
of hydraulic fracturing flow back in Utah is very limited and presents little potential
for inducing seismic activity. In fact, there has been no reported induced seismicity in
Utah that was from water injected into Class II wells. Oil and gas wells produce a
great amount of wastewater. The majority this water has high salt brine content and
must be disposed of in an environmentally safe manner. In Utah, a majority (95%) of
this produced water is pumped into Class II injection wells. In certain parts of the
country, water injection /waste water disposal has caused some induced seismicity in
the form of small earthquakes. Two major factors play a role in induced seismicity
from water injection. First, the amount of water being injected. Secondly, the local
geology of the water injection site. In Utah, the volumes are lower than those states
experiencing induced seismicity. Also, the geology is different than those states
experiencing induced seismicity. The injection zones are stratigraphically thousands
of feet above the basement rock that may contain large unknown faults. Therefore, at
this time it appears that induced seismicity from water injection is not a problem in
the oil fields of Utah. (Personal communication from John Rogers, Utah Division of
Oil, Gas and Mining (UDOGM) to Angela Wadman, March 27, 2018 (BLM 2018)).
In conclusion, there would be no negative affects to mineral resources. Lease
Stipulations and Notices are created to mitigate impacts of oil and gas development
on other resources.
Executive Order 13112 requires Federal Agencies to promote activities in a manner

which avoids introduction of spread of invasive species. Invasive species introduced to
Utah affect plant and animal communities. Surface disturbing activities have the
potential to introduce/spread invasive species/noxious weeds. The BLM “Partners
Against Weeds, An Action Plan for the Bureau of Land Management” provides
strategies to prevent and control spread of noxious weeds Noxious weeds are invasive
exotic plants designated by the State of Utah as being hazardous to public health, the
environment or the economy (Utah Code Title 4, Chapter 17).
Invasive Impacts by invasive species / noxious weeds due to the proposed action are contained
Species/Noxiou in the analysis for the Monticello 2008 RMP. This proposed sale and issuance of an oil N. Noyes
NI
s Weeds (EO and gas leases would not authorize any ground disturbances which could encourage 04/11/19
13112) spread of invasive species/noxious weeds. Leasing is an administrative action that does
not result in any surface disturbance. Site-specific effects cannot be analyzed until an
exploration or development application is received, after leasing has occurred. The
applied lease stipulations and notices will notify buyers during sale of leases and allow
for the opportunity to make adjustments at the site specific level when an APD is
received and will ensure impacts are addressed. Future development proposals on the
leases would be subject to the standard lease terms, and all applicable laws, regulations
and onshore orders in existence at the time of lease issuance. Additional detailed
analysis in this EA is not necessary.
Impacts to lands/Access from leasing are contained in the analysis for the Monticello
Norbert Norton
NI Lands/Access RMP. Actions and impacts are not changed from those disclosed in these NEPA
04/15/19
documents.
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July 2019
The lessee/operator would submit an APD when oil and gas exploration and
development activities are proposed, which may entail surface disturbing activities.
The APD would be subject to site specific NEPA analysis. Potential impacts to
livestock grazing, if any, would be addressed during this APD analysis and approval
Livestock process. N. Noyes
NI
Grazing 04/11/19
Potential impacts to livestock grazing from oil and gas leasing are adequately
2008 RMP. Actions and impacts are not changed from those disclosed in the existing
NEPA documents.
Migratory birds including raptors are protected under the Migratory Bird Treaty Act
(Executive Order 13186). An MOU between the BLM and United States Fish and
Wildlife Service (USFWS) provides BLM further direction for project-level NEPA
guidance for meeting MBTA conservation and compliance (BLM MOU WO-230-
2010-04). The effects of leasing, development and the application of the BMPS for
raptors were analyzed in the Section 4.2.7 and 4.2.8 of the EIS supporting the Price
Field Office RMP. The application of buffers and timing restrictions identified in the
RMP have been effective in mitigating impacts to raptors. The impacts of oil and gas
development and the application of these lease notices applied for Migratory
Birds/Raptors and their habitats were fully analyzed in the 2008 Monticello RMP.
Actions and impacts are not changed from those disclosed in these NEPA documents.
See Wildlife and Botany Resources Leasing Assessment for detailed species and
habitat information and Appendix A for the applicable lease notices and stipulations
developed in the 2008 Monticello RMP.
Migratory Migratory birds and raptors may be present within all of the proposed parcels. The Melissa Wardle
NI
Birds/Raptors following lease notices will be applied, as noted to all parcels: 4/15/2019
• UT-LN-43: (Raptors)
• UT-LN-45: (Migratory Bird)
Leasing would not, by itself, authorize any ground disturbances which could affect
these resources. This proposed action, the sale and issuance of an oil and gas leases, is
an administrative action that does not result in any surface disturbance. Site-specific
effects cannot be analyzed until an exploration or development application is received,
after leasing has occurred. Development proposals on the leases would be subject to
the standard lease terms, and all applicable laws, regulations and onshore orders in
existence at the time of lease issuance. The applied lease notices will ensure impacts to
raptors are minimized, and adequately mitigate potential lease development impacts to
those species. Implementing applicable lease notices at the development stage will
ensure leasing of identified parcels will not impact listed or proposed plant species to
the degree that will require additional detailed analysis in this EA.
BLM Manual Section 6840, requires consideration of sensitive species lists in
planning and environmental documents. Instructional Memorandum No. UT IM-
2019-005 provides the plant and wildlife Species lists for BLM-administered public
lands in Utah. The impacts of oil and gas development and the application of these
lease notices and stipulations applied on Utah BLM Sensitive Species and their
habitats were fully analyzed in the 2008 Monticello RMP. See Wildlife and Botany
Utah BLM Resources Leasing Assessment for detailed species and habitat information and
Melissa Wardle
NI Sensitive Appendix A for the applicable lease notices and stipulations developed in the 2008
4/15/2019
Species Monticello RMP.
Potential for occurrence of Utah BLM Sensitive Species exists in all parcels, and the
following lease notice will apply to all parcels:
• LN-49: (Utah Sensitive Species)
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July 2019
Leasing would not, by itself, authorize any ground disturbances which could affect
these resources. This proposed action, the sale and issuance of an oil and gas leases,
is an administrative action that does not result in any surface disturbance. Site-
specific effects cannot be analyzed until an exploration or development application is
received, after leasing has occurred. Development proposals on the leases would be
subject to the standard lease terms, and all applicable laws, regulations and onshore
orders in existence at the time of lease issuance. The applied lease notices will ensure
impacts to BLM Sensitive Species are minimized, and adequately mitigate potential
lease development impacts to those species. Implementing applicable lease notices at
the development stage will ensure leasing of identified parcels will not sensitive
species to the degree that will require additional detailed analysis in this EA.
The sale and issuance of an oil and gas lease is an administrative action that does not
directly result in any surface disturbance. However, the issuance of a lease is
considered to be an irretrievable commitment of resources because the BLM
generally cannot deny all surface use of a lease unless the lease is issued with a no
surface occupancy stipulation.
development activities are proposed. The APD would be subject to site specific
NEPA analysis and relevant cultural resource avoidance or mitigation measures if
Native warranted. John Chmelir
American
NI Government to Government consultations with Native American Tribes were initiated, 4/15/2019
Religious
Concerns by certified letter, on November 6, 2018.
Responses have been received from several tribes, by letter and by phone.
Consultation with Native American tribes is ongoing.
Native American Religious Concerns Stipulations and Lease Notices to all parcels;
UT-S-170:CSU; Cultural
LN-67; Historical And Cultural Resource Values
LN-68: Notification & Consultation Regarding Cultural Resources
Impacts to the paleontological resources from leasing are contained in the analysis
for the Monticello RMP.
NEPA analysis.
All lease parcels contain areas of high potential for paleontological resources. The
Monticello RMP contains management decisions to protect paleontological Angela Bulla
NI Paleontology
resources. Lease notice UT-LN-72: High Potential Paleontological Resources will be 4/11/2019
attached to all parcels as specified by the Monticello RMP
Attachment of this lease notice will adequately mitigate impacts to paleontological

resources.
Potential impacts to paleontology from leasing are adequately analyzed and

documented in the environmental analysis prepared for the Monticello RMP. Actions
and impacts are not changed from those disclosed in these NEPA documents.
development activities are proposed, which may entail surface disturbing activities.
The APD would be subject to site specific NEPA analysis. An approved APD is
Rangeland subject to standard operating procedures (SOP) required by regulation, stipulations
N. Noyes
NI Health attached to the lease, best management practices (BMP) included in the APD
04/11/19
Standards submission, and conditions of approval (COA) developed during the NEPA analysis
and documentation process. These SOPs, BMPs, and COAs mitigate impacts to other
resources, such as to Rangeland Health Standards, from oil and gas exploration and
development activities.
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July 2019
Potential impacts to rangeland health standards from oil and gas leasing are
adequately analyzed and documented in the environmental analysis prepared for the
Monticello 2008 RMP. Actions and impacts are not changed from those disclosed in
these NEPA documents.
Impacts to recreation from leasing are contained in the analysis for the Monticello
RMP. Actions and impacts are not changed from those disclosed in these NEPA
Jason Byrd
NI Recreation documents. No leases are adjacent to developed recreation sites or other recreation
4/15/2019
areas that would require additional stipulations or notices. These sites are not highly
used recreation areas.
Potential impacts to socio economics from oil and gas leasing are adequately
Socio- analyzed and documented in the environmental analysis prepared for the Monticello CGiffen
NI
Economics RMP. Actions and impacts are not changed from those disclosed in these NEPA 4/10/2019
documents.
NEPA analysis. An approved APD is subject to standard operating procedures (SOP)
required by regulation, stipulations attached to the lease, best management practices
(BMP) included in the APD submission, and conditions of approval (COA)
developed during the NEPA analysis and documentation process. These SOPs,
BMPs, and COAs, mitigate impacts to other resources and users from oil and gas
exploration and development activities.
The Monticello RMP contains management decisions and stipulations to protect

fragile soils on steep slopes and reduce erosion. Stipulations UT-S-98:NSO—Fragile
Soils/Slopes Greater than 40 Percent will be attached to parcels 409, 410, 414, 415, CGiffen
416, 417, 418, 421, 423, 424 and UT-S-106 CSU—Fragile Soils/Slopes 21-40 4/10/2019
NI Soils
Percent and will be attached to all parcels. Ken Bradshaw
4/18/2019
When an applicant submits an APD, the location would be reviewed by a BLM
resource specialist for conformance with the slope stipulations. A well location,
access road, or other surfacing disturbing activity located on slopes inconsistent with
these stipulations would require modification of the location or denial of the APD.
These lease stipulations, SOPs BMPs and COAs, including erosion control and
reclamation standards, would adequately mitigate impacts to the soil resource.
Potential impacts to soils from oil and gas leasing are adequately analyzed and
documented in the environmental analysis prepared for the Monticello RMP. Actions
and impacts are not changed from those disclosed in these NEPA documents.
The Endangered Species Act (ESA) requires federal agencies, in consultation with the
USFWS, to ensure that actions they authorize, fund or carry out are not likely to
jeopardize the continued existence of federally listed endangered or threatened species,
or result in destruction or adverse modification of their designated critical habitat (16
U.S.C. §1531 et seq. (1973)). Through formal consultation with the FWS during the
development of the 2008 Monticello RMP, lease stipulations and notices where
developed to ensure listed species and habitats would receive needed protective
Threatened, measures to ensure impacts from development activities are minimized. See Wildlife Melissa Wardle
Endangered or and Botany Resources Leasing Assessment for detailed species and habitat 4/15/2019
NI
Candidate Plant information and Appendix A for the applicable lease notices and stipulations Karen Cathey
Species developed in the 2008 Monticello RMP. No habitat for the Navajo sedge or Jones’ 05/06/2019
cycladenia occurs on the proposed parcels. The following lease notices will be applied:
• Handbook H-3120-1: (Endangered Species Act) – All parcels
This proposed action, the sale and issuance of an oil and gas leases, is an
administrative action that does not result in any surface disturbance. Site-specific
after leasing has occurred. The BLM will consult with the USFWS as appropriate on
106
July 2019
possible effects to federally listed species from this lease sale and during review of
future development plans. The applied lease notices and future consultation as
appropriate will ensure compliance with the ESA and adequately mitigate potential
lease development impacts to federally listed or proposed species/habitat.
Implementing applicable lease notices at the development stage will ensure leasing of
identified parcels will not impact listed or proposed species to the degree that will
require additional detailed analysis in this EA.
The Endangered Species Act (ESA) requires federal agencies, in consultation with
the USFWS, to ensure that actions they authorize, fund or carry out are not likely to
jeopardize the continued existence of federally listed endangered or threatened
species, or result in destruction or adverse modification of their designated critical
habitat (16 U.S.C. §1531 et seq. (1973)). Through formal consultation with the FWS
during the development of the 2008 Monticello RMP, lease stipulations and notices
where developed to ensure listed species and habitats would receive needed
protective measures to ensure impacts from development activities are minimized.
See Wildlife and Botany Resources Leasing Assessment for detailed species and
habitat information and Appendix A for the applicable lease notices and stipulations
developed in the 2008 Monticello RMP. Potential habitat for the California condor,
Mexican spotted owl, southwestern willow flycatcher, yellow-billed cuckoo may
occur. In addition, due to potential water depletion through development, the
Bonytail chub, Colorado pikeminnow, humpback chub, and razorback sucker may be
indirectly affected, as indicated by application of the following lease stipulations:
• Handbook H-3120-1: (Endangered Species Act) – All parcels

Threatened, • UT-S-182: NSO-Colorado Endangered Fish – All parcels Melissa Wardle
Endangered or • UT-S-275: (CSU/TL – Bald Eagles) – Parcel 414 4/15/2019
NI
Candidate Karen Cathey
• UT-S-288: (CSU/TL – Mexican spotted owl) – Parcels 406, 407, 408, 409,
Animal Species 05/06/2019
410, 411, 412, , 414, 416, 417, 418, 419, 420, 421, 422, 423, 424
• UT-S-290: (CSU/TL – Southwestern Willow Flycatcher) – Parcels 406, 407,
408, 409, 414, 415, 418, 419, 423
• UT-S-297: (CSU/TL – Yellow-billed Cuckoo) – Parcels 406, 407, 408, 409,
414, 415, 418, 419, 423
• T&E-11: (California Condor) – All parcels
This proposed action, the sale and issuance of an oil and gas leases, is an
administrative action that does not result in any surface disturbance. Site-specific
after leasing has occurred. The BLM will consult with the USFWS as appropriate on
possible effects to federally listed species from this lease sale and during review of
future development plans. The applied lease notices and future consultation as
appropriate will ensure compliance with the ESA and adequately mitigate potential
lease development impacts to federally listed or proposed species/habitat.
Implementing applicable lease notices at the development stage will ensure leasing of
identified parcels will not impact listed or proposed species to the degree that will
require additional detailed analysis in this EA.
Wastes Potential impacts to Wastes from oil and gas leasing are adequately analyzed and
N. Noyes
NI (hazardous or documented in the environmental analysis prepared for the Monticello 2008 RMP.
04/11/19
solid) Actions and impacts are not changed from those disclosed in these NEPA documents.
groundwater resources. The decision to lease is connected to these impacts; however it Melissa Wardle
does not affect groundwater resources to a degree that detailed analysis is required. If 4/15/2019
Groundwater an APD is filed, SOPs required by regulation and design features would be sufficient
NI Resources/Qual to isolate and protect all usable ground or surface water sources before drilling or
Ken Bradshaw
ity exploration begin. The SOPs include the requirements for disposal of produced water 4/19/2019
contained in Onshore Oil and Gas Order (O.O.) No. 7 and the requirements for drilling
operations contained in O.O No. 2. Potential fresh water aquifers zones would be
protected by the requirement of casing and cementing the drill hole to total depth. The
107
July 2019
casing would be pressure tested to ensure integrity prior to drilling out the surface
casing shoe plug.
Potential impacts would be addressed and a design feature would be included utilizing
UT IM 2010-055 (Protection of Ground Water Associated with Oil and Gas Leasing,
Exploration and Development) prior to APD approval. Standard protocols and best
management practices would minimize possibility of releases. BMPs, SOPs and site
specific mitigation may be applied at the APD stage as COAs.
There is consensus among BLM hydrologists and related resource specialties that
these required design criteria would minimize the potential for impacts to water
resources if/when development occurs. If leasing was proposed in an unusually
sensitive area, if foreseeable development was expected to be of high intensity, or if
water resource concerns unknown to BLM were brought forward then there may be a
need for detailed analysis in an EA. None of these conditions apply for this lease sale
and therefore detailed analysis is not required for this lease level EA. It may be
necessary to undertake detailed analysis of impacts to water resources when specific
plans for development are proposed, but the decision whether to complete NEPA
analysis will be made at that time based on scoping, issue sensitivity, and other
considerations.
Parcels 407 and 419 contain Public Water Reserves and Stipulation UT-S-128
NSO—Floodplains, Riparian Areas, Springs, and Public Water Reserves will be
attached to those parcels. There are also water rights within and/or adjacent to all
parcels.
Leasing the proposed parcels would not, by itself, authorize any disturbances or
impact water rights. Site-specific effects cannot be analyzed until an exploration or
development application is received, after leasing has occurred. However, any
development proposal on the lease parcels would be subject to the standard lease
terms, the protective lease notices and stipulations identified in Appendix A, and all
applicable laws, regulations and onshore orders in existence at the time of lease
issuance. Site- specific analysis would be required prior to the approval of any
ground disturbance proposal on the lease parcels. In addition water rights are
protected under State Law, and a junior water right holder is liable for damages
caused when senior water right holders are impacted by their water use.
Impacts to groundwater resources and water rights/Public Water Reserves would be

mitigated through SOPs, BMPs, State of Utah Water Rights Law, and other mitigation
measures discussed above, therefore, are not anticipated to occur as a result of leasing
the proposed parcels.
Hydraulic fracturing is a technique developed in the 1940’s. Around 2000, the

technique was combined with directional drilling to dramatically increase production
from deposits previously considered uneconomical (EPA 2016 p. 3-4).
The hydraulic fracturing water cycle describes the use of water in hydraulic fracturing,
from water withdrawals to make hydraulic fracturing fluids, through the mixing and
injection of hydraulic fracturing fluids in oil and gas production wells, to the collection
and disposal or reuse of produced water. These activities can impact drinking water
resources under some circumstances. Impacts can range in frequency and severity,
depending on the combination of hydraulic fracturing water cycle activities and local-
or regional-scale factors. The following combinations of activities and factors are more
likely than others to result in more frequent or more severe impacts (EPA, 2016 p. ES-
3):
• Water withdrawals for hydraulic fracturing in times or areas of low water
availability, particularly in areas with limited or declining groundwater
resources;
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July 2019
• Spills during the management of hydraulic fracturing fluids and chemicals or

produced water that result in large volumes or high concentrations of chemicals
reaching groundwater resources;
• Injection of hydraulic fracturing fluids into wells with inadequate mechanical
integrity, allowing gases or liquids to move to groundwater resources;
• Injection of hydraulic fracturing fluids directly into groundwater resources;
• Discharge of inadequately treated hydraulic fracturing wastewater to surface
water resources; and,
• Disposal or storage of hydraulic fracturing wastewater in unlined pits, resulting
in contamination of groundwater resources.
"The above conclusions are based on cases of identified impacts and other data,
information, and analyses presented in the report. Cases of impacts were identified for
all stages of the hydraulic fracturing water cycle. Identified impacts generally occurred
near hydraulically fractured oil and gas production wells and ranged in severity, from
temporary changes in water quality to contamination that made private drinking water
wells unusable” (EPA 2016 p. ES-3-4).
If fracking should occur in an area where there is no vertical separation between the
hydraulically fractured rock formation and the bottom of the potential underground
drinking water source, fracking fluid may be introduced into the source. However, the
occurrence of fracking within a potential drinking water source is low, concentrated in
a few fields in Wyoming and Montana (EPA 2016 p. ES-8).
Produced water can contain many constituents depending on the composition of the
injected hydraulic fracturing fluid and the type of rock being fractured. Produced water
has been found to contain salts, metals, benzene, toluene, ethylbenzene, and xylenes
(BTEX), oil and grease, radioactive materials, and hydraulic fracturing chemicals and
their chemical transformation products. (EPA 2016 p. ES-33). Overall, the severity of
impacts on water quality from produced water spills depends on the identity and
amount of water spilled, the toxicity of constituents in the water, and the characteristic
of the receiving groundwater or surface water; and spill prevention and response can
prevent and/or minimize contamination of water resources (EPA 2016 p. ES-37).
The measures required (spill containment systems, casing integrity testing, pit lining),
etc. for all wells drilled in Utah, fracked or not, are adequate to prevent fracking fluids
as well as hydrocarbons and produced water from the wells to prevent ground/surface
water contamination. The UDOGM has promulgated rules to prevent environmental
impacts from fracking (Utah Administrative Code R649-3-39). Further
analysis/mitigation of impacts is not warranted.
Oil and Gas development that may occur as a result of this lease sale may affect water
resources. The decision to lease is connected to these impacts; however it does not
affect water resources to a degree that detailed analysis is required. If an APD is filed,
SOPs required by regulation and design features would be sufficient to isolate and
protect all usable ground or surface water sources before drilling or exploration begin.
The SOPs include the requirements for disposal of produced water contained in Melissa Wardle
Surface Water Onshore Oil and Gas Order (O.O.) No. 7 and the requirements for drilling operations 4/15/2019
NI Resources/Qual contained in O.O No. 2. Potential fresh water aquifers zones would be protected by the
ity requirement of casing and cementing the drill hole to total depth. The casing would be Ken Bradshaw
pressure tested to ensure integrity prior to drilling out the surface casing shoe plug. 4/19/2019
Requirements under O.O. 2 and O.O. 7, along with stipulation UT-S-128 NSO—
Floodplains, Riparian Areas, Springs, and Public Water Reserves will be attached to
parcels 406, 407, 408, 409, 410, 411, 412, 414, 415, 419, 422, 423, and 424.
109
July 2019
In addition to requirements under O.O. 2 and O.O. 7 to protect surface water, BMPs
and mitigation measures that limit surface disturbances in or adjacent to intermittent
and perennial streams, wetlands, floodplains, and/or riparian areas maintain the health
and function of those areas. In addition, BMPs and mitigation measures that reduce
surface disturbances on soils help to reduce the potential for soil compaction, rutting,
and erosion, and lessen impacts to surface water quality.
Given the Stipulations, Lease Notices and mitigation measures (e.g., BMPs and SOPs)
discussed above, impacts to surface water quality would be mitigated and detailed
analysis is not required in this EA.
wetland/riparian resources. The decision to lease is connected to these impacts;
however it does not affect water resources to a degree that detailed analysis is
required. If an APD is filed, SOPs required by regulation and design features would be
sufficient to isolate and protect all usable ground or surface water sources before
drilling or exploration begin. The SOPs include the requirements for disposal of
produced water contained in Onshore Oil and Gas Order (O.O.) No. 7 and the
requirements for drilling operations contained in O.O No. 2. Potential fresh water
aquifers zones would be protected by the requirement of casing and cementing the drill
hole to total depth. The casing would be pressure tested to ensure integrity prior to
drilling out the surface casing shoe plug.
Executive Order 11990 directs federal agencies to avoid short and long term impacts
to wetlands to the extent possible; Executive Order 11988 directs federal agencies to
Jed Carling
avoid similar impacts through modification of floodplains, and to restore and 4/11/19
preserve the natural and beneficial values served by floodplains. The BLM Manual
Wetlands/Ripar 1737 – Riparian-Wetland Area Management, Riparian-Wetland Initiative provides
NI Ken Bradshaw
ian Zones direction for planning and management actions related to riparian areas, and
4/19/2019
Instructional Memorandum No UT 2005-091 provides specific guidance to Utah Karen Cathey
BLM riparian lands while supporting all BLM national guidance directives. 05/06/2019
Local knowledge, review of corporate GIS data, and review of the National Wetlands
Inventory identified the presence of springs, and other in the following parcels: 406,
407, 408, 409, 410, 411, 412, 414, 415, 416, 417, 418, 419, 421, 422, 423, and 424.
The following stipulations to be applied, as noted:
• UT-S-128: (NSO – Floodplains, Riparian Areas, Springs, and Public Water

Reserves) – Parcels 406, 407, 408, 409, 410, 411, 412, 414, 415, 416, 417,
418, 419, 421, 422, 423, and 424
Given the executive directives, Stipulations, and mitigation measures (e.g., BMPs and
SOPs) discussed above, impacts to riparian resources, wetlands, and floodplains would
be mitigated and detailed analysis is not required in this EA.
.
There are no parcels within river segment corridors identified as suitable for
Wild and Silas Sparks
NP designation into the National Wild and Scenic River System (NW&SR). There are no
Scenic Rivers 4/12/19
designated NW&SR system river segments in the Monticello Field Office.
Wilderness/WS Misti Haines
NP There are no parcels within Wilderness or Wilderness Study Areas
A 4/15/2019
Potential impacts to woodlands and forestry from oil and gas leasing are adequately
analyzed and documented in the environmental analysis prepared for the Monticello Melissa Wardle
Woodland /
NI RMP. Actions and impacts are not changed from those disclosed in these NEPA 4/15/2019
Forestry
documents. Additional site specific review will occur at the development stage.
110
July 2019
Vegetation Potential impacts to Vegetation Excluding USFWS Designated Species from oil and N. Noyes
Excluding gas leasing are adequately analyzed and documented in the environmental analysis 4/11/19
NI USFWS prepared for the Monticello 2008 RMP. Actions and impacts are not changed from Karen Cathey
Designated those disclosed in these NEPA documents, and further detailed analysis here is not 05/06/2019
Species necessary.
Potential impacts to visual resources from oil and gas leasing are adequately analyzed
and documented in the environmental analysis prepared for the Monticello RMP,
which assigned visual resource management classes to these areas. Actions and
impacts are not changed from those disclosed in these NEPA documents
Parcel 408 and a portion of Parcel 407 are in VRM Class III. The goals of this
management class are partially retain the existing character of the landscape. Change
allowed may be moderate and activities may attract attention but should not dominate
the view. The remaining parcels are in VRM Class IV. This management class allows
Visual for a high degree of change and activities that require major modification of the S. Sparks
NI
Resources existing character of the landscape. 4/15/19
Potential future development of these parcels could be visible from key observation
points and could potentially impact Visual Resources through modifications to the
landscape that would attract the attention of the casual observer. However, such
impacts would be mitigated and/or prevented at the development stage through the
use of best management practices such as strategic siting, color camouflaging, and
vegetative screening of facilities. The leasing and potential future development of all
parcels included in the proposed action would conform to all applicable Visual
Resource Management objectives established in the Monticello RMP.
• The Monticello RMP, 2008 decision WC-1 (page 85) identified which of
these lands would be managed to “Protect, maintain and preserve wilderness
characteristics.” These inventories identified the following lands adjacent to
the Squaw and Papoose Canyons WSA as possessing wilderness
characteristics:
Squaw and Papoose Canyons Unit
• 041 956
• 042 592
• 043 272
• 045 26
Total 1,846
On October 21, 2014, the Southern Utah Wilderness Alliance (SUWA) submitted
information suggesting the presence of wilderness characteristics in the Tin Cup
Mesa and Monument Canyon units. BLM conducted an analysis and lands within
these units were found to possess wilderness character (WC) as determined by
Documentation of BLM Wilderness Characteristics Inventory Findings. Misti Haines
Lands with
NI Wilderness The parcels and acreage of LWC are: 4/15/2019
Characteristics
Monument Canyon Unit
• 409 1,482
• 410 1,726
• 411 893
• 421 484
Total Acreage 4,585
Tin Cup Mesa Unit

• 412 229 acres
• 415 960 acres
• 416 1,562 acres
• 417 459 acres
• 418 853 acres
• 422 613 acres
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July 2019
• 423 994 acres

• 424 1,246 acres
Total Acreage 6,916
Total Acreage of LWC within all parcels = 13,347
Leasing of these parcels may result in the loss of WC in these areas. While these
areas were found to possess wilderness characteristics as determined subsequent to
the RMP, only those areas designated in RMP decision WC-1 will be managed to
“Protect, maintain and preserve wilderness characteristics …”
Leasing of these parcels is consistent with the management decisions in the

Monticello RMP. Potential impacts to LWC from oil and gas leasing are adequately
RMP and the March 2018 EA. Actions and impacts are not substantially changed
from those disclosed in these NEPA documents.
None of the parcels are in the vicinity of the Old Spanish Trail.
During the previous consideration of the parcels, comments were received from
multiple commenters regarding impacts from oil and gas leasing and development to
National units of the National Park System.
Historic Trails/
To mitigate impacts the following Lease Notice will be attached to all parcels:: CGiffen
NP/NI Units of the
4/10/2019
National Park LN-125; Light And Sound - Sensitive Resources
Service
Further rationale for eliminating the concern for detailed analysis can be found in
Table 2. Issues not included in Further Detail in the Environmental Assessment in
the EA.
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July 2019
Appendix E – References
APCD. 2017. "Colorado Air Pollution Control Division, Department of Public Health and
Environment. PS Memo 05-01." State of Colorado.
https://www.colorado.gov/pacific/sites/default/files/AP_Memo-05-01-Oil-and-Gas-
Condensate-Tank-Batteries-Guidance.pdf.
BLM. 2019. "2018 BLM Utah Air Monitoring Report." https://go.usa.gov/xmDkx.
—. 2015. "Air Resource Management Program Strategy 2015-2020 ." Bureau of Land
Management. February. Accessed August 17, 2018.
https://www.blm.gov/sites/blm.gov/files/AirResourceProgramStrategy.pdf.
BLM. 2008. "Biological Opinion for BLM Monticello Field Office RMP." West Valley City,
UT. https://eplanning.blm.gov/epl-front-
office/projects/lup/68097/85495/102695/Monticello_Biological_Opinion.pdf.
—. 2008. BLM Monticello Field Office Record of Decision and Approved RMP (UT-090-2007-
40). Monticello, Utah. https://eplanning.blm.gov/epl-front-
office/projects/lup/68097/85493/102694/Monticello_Final_Plan.pdf.
BLM. 2009. "Canyons of the Ancients National Monument Proposed Resource Management
Plan and Final Environmental Impact Statement."
BLM. 2007. Final Vegetation Treatments Using Herbicides Programmatic Environmental
Impact Statement and Record of Decision. Washingtion, D.C., September.
https://eplanning.blm.gov/epl-front-
office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentP
ageId=103592.
BLM. 2018. March 2018 Canyon Country District Competitive Oil and Gas Lease Sale. Moab.
doi:https://eplanning.blm.gov/epl-front-
ageId=122746.
BLM. 2019. "March 2019 Lease Sale Cultural Resources Report (Utah SHPO Case No. 19-
0235)." Salt Lake City, UT.
—. 2016. "Moab Master Leasing Plan and Proposed Resource Management Plan
Amendments/Final Enviornmental Impact Statement." July.
office/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite&
projectId=68430&dctmId=0b0003e880d9ffc7.
—. 2016. Moab Master Leasing Plan and Proposed RMP Amendments/FEIS for Moab and
Monticello Field Offices (DOI-BLM-UT-Y010-2012-0107-EIS). Moab, Utah.
ageId=99718.
—. 2008. Monticello Field Office Proposed RMP and FEIS. Monticello: Monticello Field Office.
https://eplanning.blm.gov/epl-front-office/projects/lup/68097/85623/102818/RMP.pdf.
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—. 2005. Monticello Reasonable Foreseeable Development Scenario (RFD) For Oil and Gas.
Monticello, Utah. https://eplanning.blm.gov/epl-front-
office/projects/lup/68097/85828/103015/RFD.pdf.
BLM. 2017. Monticello RMP Land Use Amendment/Maintence Change No. 102. Monticello,
July 24. https://eplanning.blm.gov/epl-front-
office/projects/lup/68097/144192/177756/Monticello_RMP_Maintenance_102.pdf.
—. 2012. Reasonably Foreseeable Development Scenario for Oil and Gas in the Moab MLP
Area, Canyon Country District. Moab, Utah: Bureau of Land Management.
office/projects/lup/68430/88315/105655/MLP_OG_RFD_final_091012_508_web.pdf.
—. 2016. Record of Decision and Moab MLP Approved RMP Amendments for Moab and
Monticello Field Offices (DOI-BLM-UT-y010-2012-0107-EIS). Moab, Utah: Bureau of
Land Management. https://eplanning.blm.gov/epl-front-
ageId=99718.
BLM. 2019. "Specialist Report on GHG Analysis for BLM Utah Oil and Gas Leasing."
—. 2007. "Surface Operating Standards and Guideline for Oil and Gas Exploration and
Development. The Gold Book, Fourth Edition." Denver, Colorado: BLM/WO/ST-
06/021+3071/REV 07. Bureau of Land Management. 84pp.
https://www.blm.gov/sites/blm.gov/files/uploads/The%20Gold%20Book%20-
%204th%20Ed%20-%20Revised%202007.pdf.
—. 2018. "Telephone Call Record. Hydraulic Fracking and Seismic Activity in Utah." March.
—. 2018. "Utah Air Resource Management Strategy (ARMS)." Bureau of Land Management.
Accessed April 23, 2019. https://go.usa.gov/xmDkx.
BLM. 2014. Utah Air Resource Management Strategy Modeling Project Impact Assessment
Report. Modeling Project, Fort Collins: AECOM. Accessed August 2018.
https://www.blm.gov/sites/blm.gov/files/program_natural%20resources_soil%20air%20
water_airut_quick%20links_ImpactsRpt.pdf.
Bryce, S.A., J.R. Strittholt, B.C. Ward, and D.M. Bachelet. 2012. "Colorado Plateau Rapid
Ecoregional Assessment Report. Prepared for the U.S. DOI."
https://landscape.blm.gov/REA_General_Docs/COP_Final_Report_Body.pdf.
Carbon. 2019. Carbon Offset Projects. 5 2.
https://www.carbonfootprint.com/carbonoffsetprojects.html.
Council, National Research. 2010. "Informing an Effective Response to Climate Change."
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Davis, William E. 1989. "The Lime Ridge Clovis Site." Utah Archaeology 66-76.
Duniway et. al. 2019. "Wind Errosion and dust from US drylands: a review of causes,
consequences, and solutions in a changing world." Ecosphere 28.
EPA. 2019. 2014 National Air Toxics Assessment. Accessed 5 23, 2019.
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—. 1995. "AP-42: Compilation of Air Emissions Factors." United States Environmental

Protection Agency. https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-
compilation-air-emissions-factors#5thed.
—. 2018. Facility Level Information on GreenHouse Gases Tool (FLIGHT).
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—. 2019. Greenhouse Gases Equivalencies Calculator - Calculations and References.
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references.
—. 2019. "Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2017." 5 6.
https://www.epa.gov/sites/production/files/2019-04/documents/us-ghg-inventory-2019-
main-text.pdf.
—. 2019. Natural Gas STAR Program Accomplishments. https://www.epa.gov/natural-gas-star-
program/natural-gas-star-program-accomplishments.
—. 2018. Overview of Greenhouse Gases. Accessed August 16, 2018.
https://www.epa.gov/ghgemissions/overview-greenhouse-gases.
Golder. 2010. Cane Creek Air Quality Impact Assessment (letter submitted to the BLM and
NPS). Fort Collins, CO: Golder Associates Inc.
Hurst, Winston B., and Hugh L. Robinson. 2014. The Comb Wash Campground Survey: An
Archaeological Surface Inventory of 2,200 Acres in San Juan County, UT. Bureau of
Land Management, Monticello Field Office: Monticello Field Office.
Janssens-Maenhout, G., M. Crippa, D. Guizzardi, M. Muntean, E. Schaaf, J.G.J Olivier, J.A.H.W
Peters, and K.M. Schure. 2017. Fossil CO2 and GHG Emissions of All World Countries.
Luxembourg: Publications Office of the European Union. doi:10.2760/709792.
Matson, R. G. 2014. "Cedar Mesa Basketmaker II: The Story Continues." Archaeology
Southwest 3 and 4 (28): 24-29.
McPherson, Robert S. 1995. "A History of San Juan County: In the Palm of Time." Utah
Centennial County History Series.
Robins, Michael R. 1997. "Modeling the San Juan Basketmaker Socio-Economic Organization:
A Preliminary Study in Rock Art and Social Dynamics." Early Farmers in the Nothern
Southwest: Papers on Chronometry, social Dynamics, and Ecology.
Rubinstein, Justin and Alireaza Babaie Mahani. 2015. Myths and Facts on Waste Water
Injection, Hydraulic Fracturing, Enhanced Oil Recovery, and Induced Seismicity. Vols.
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State of Utah. 2018. State of Utah Resource Managment Plan. Salt Lake City, Utah: State of
Utah. Accessed August 2018. http://publiclands.utah.gov/current-projects/rmp/.
Strategies, Center for Climate. 2007. "Utah Greenhouse Gas Inventory and Reference Case
Projections, 1990-220." http://www.climatestrategies.us/policy_tracker/policy/index/45.
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UDAQ. 2018. "2014 Statewide Emissions Inventories."

https://deq.utah.gov/legacy/programs/air-quality/emissions-inventories/inventories/2014-
state-list.htm.
UDOGM. 2018. Utah Oil and Gas Monthly Production Reports by County.
https://oilgas.ogm.utah.gov/oilgasweb/publications/monthly-rpts-by-
cnty.xhtml?rptType=CNTY.
United States Department of the Interior and United States Department of Agriculture. 2007.
Surface Operating Standards and Guidelines for Oil and Gas Exploration and
Development. BLM/WO/ST-06/021+307/REV 07. . Denver, Colorado: Bureau of Land
Management.
USDI and USDA. 2007. "The Gold Book." Vers. Fourth Edition - Revised 2007. Bureau of Land
Management. Accessed August 29, 2018. https://www.blm.gov/programs/energy-and-
minerals/oil-and-gas/operations-and-production/the-gold-book.
USGCRP. 2018. "Impacts, Risks, and Adaptation in the United States: Fourth National Climate
[Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K."
Washington, DS, USA: U.S. Global Change Research Program.
USGS. 2018. "Federal lands greenhouse emissions and sequestration in the United States—
Estimates for 2005–14: Merrill, M.D., Sleeter, B.M., Freeman, P.A., Liu, J., Warwick,
P.D., and Reed, B.C."
WRAP. 2013. "West-wide Jumpstart Air Quality Modeling Studay, Final Project Report and
Modeling Results." Accessed 05 24, 2019.
https://www.wrapair2.org/pdf/WestJumpAQMS_Model_Results_UT_April16_2014.pdf.
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Appendix F – Acronyms/Abbreviations
AO Authorized Officer NESHAP National Emission Standards For
APD Application for Permit to Drill NHPA National Historic Preservation Act
ARMPA Approved Resource Management NRHP National Register of Historic Places
Plan Amendments
BCR Bird Conservation Region NSO No Surface Occupancy
BLM Bureau of Land Management O.O. Onshore Oil and Gas Order
BMP Best Management Practice PLPCO Public Lands Policy Coordinating Office
CAA Clean Air Act PARFDS GRSG Population Area Reasonably
Foreseeable Development Scenario
CFR Code of Federal Regulations RFDS Reasonably Foreseeable Development
Scenario
CIAA Cumulative Impact Analysis Area RMP Resource Management Plan
COA Condition of Approval ROD Record of Decision
CWCS Comprehensive Wildlife ROW Right of Way
Conservation Strategy
DR Decision Record S Stipulation
EA Environmental Assessment SHPO State Historic Preservation Office
EAR Environmental Analysis Record SITLA State Institutional Trust Lands
Administration
EIS Environmental Impact Statement
EOI Expression of Interest UDAQ Utah Division of Air Quality
EPA Environmental Protection Agency UDWR Utah Division of Wildlife Resources
ESA Endangered Species Act USFS United States Forest Service
FFO Fillmore Field Office USFWS United States Fish & Wildlife Service
FLPMA Federal Land Policy and UT Utah
Management Act
FONSI Finding of No Significant Impact UTSO Utah State Office
GIS Geographical information System
GWP Global Warming Potential WO Washington Office
H Handbook
IDPRT Interdisciplinary Parcel Review
Team
IM Instruction Memorandum
LN Lease Notice
MBTA Migratory Bird Treaty Act
Mcf One Million Cubic Feet
MLA Mineral Leasing Act
MOU Memorandum of Understanding
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AO Authorized Officer NESHAP National Emission Standards For

NAAQS National Ambient Air Quality
Standards
NCLS Notice of Competitive Lease Sale
NEPA National Environmental Policy Act
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Appendix G – Reasonable Foreseeable Development of Leases Scenario

Development of the parcels under the Proposed Action can be conceived of in three phases and their
associated activities: Implementation phase (pad construction, drilling of the well using a conventional pit
system or closed-loop system, hydraulically fracturing the well, development of any needed access roads,
or expansion of existing roads, installation of pipeline), production phase (vehicle traffic, engines to pump
oil if necessary, compressor engines to move gas through a pipeline, venting from storage tanks, hauling
produced fluids, regularly monitoring the well, and completing work-over tasks throughout the life of the
well if and when necessary), plug and reclamation phase (plugging the well, reclaiming the well pad and
other associated disturbances to include access roads and pipelines).
Standard terms, conditions, and stipulations listed would apply as appropriate to each lease. In addition,
site specific mitigation measures and best management practices (BMPs) would be attached as Conditions
of Approval (COAs) for each proposed exploration and development activity authorized on a lease.
Additional site-specific impacts would be addressed in a subsequent NEPA document at the Application
for Permit to Drill (APD) stage. Drilling of wells on a lease would not be permitted until the lease owner
or operator secures approval of a drilling permit and a surface use plan of operations as specified under
Onshore Oil and Gas Orders (43 CFR 3162), nor until site-specific NEPA analysis is conducted.
Oil and gas leases are issued for a 10-year period and continue for as long thereafter as oil or gas is
produced in paying quantities. However, it should be noted that if a leaseholder fails to produce oil and
gas, does not make annual rental payments, does not comply with the terms and conditions of the lease, or
relinquishes the lease, the lease defaults back to the Federal Government and the lease can be re-offered
in another lease sale.
Well Pad and Road Construction

Where the surface is not federally owned, the operator is required to obtain a Surface Access Agreement.
Surface Access Agreement is addressed in Onshore Oil and Gas Order No. 1 (O.O. #1.III.D.4).
Equipment for well pad construction could consist of dozers, scrapers, excavators and graders.
Disturbance for each well pad could range from 1.0 acre up to 6.8 acres depending on numerous factors
such as depth and type of well (vertical, directional, horizontal). All available topsoil from each well pad
would be stripped and stockpiled around the edge of the pad for future reclamation. When needed, topsoil
would be spread over interim reclamation areas, seeded, left in place for the life of the well, and the
remaining topsoil would be used during the final reclamation process. All well pads would be reclaimed.
During interim and/or final reclamation, disturbed land would be seeded with a mixture (certified weed
free) and rate as required by the BLM.
Depending on the locations of the proposed wells, some new or upgraded access roads are anticipated to
be required to access well pads and maintain production facilities. Any new roads constructed for the
purposes of oil and gas development would be utilized year-round for maintenance of the proposed wells
and other facilities, and for the transportation of fluids and/or equipment, and would remain open to other
land users. Construction of new roads or upgrades to existing roads would require a 30-foot construction
width and would be constructed of native material. After completion of road construction activities, the
30-foot construction width would be reclaimed to an 18-foot wide crowned running surface as well as
drainage ditches. The location of the wells would not be known until the APD stage.
5.1.1 Well Drilling and Completion Operations
A drilling rig would be transported to the well pad (along with other necessary equipment). Drilling
would commence with well spud. Typical drilling operations would include: adding joints of drill pipe at
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the surface as the hole deepens; circulating drilling fluids to cool the drill bit and remove the drill
cuttings; pulling the drill pipe from the hole to replace worn drill bits; and setting strings of casing and
cementing them in place. Air and/or water-based drilling fluid may be used to drill the hole. Prior to
setting the production casing, open-hole well logs may be run to identify potentially productive horizons.
If the evaluation concludes that sufficient natural gas and/or oil are present and recoverable, steel
production casing would be installed and cemented in place. Drilling activities on a well would typically
occur 24 hours per day, seven days per week, and would require approximately 20 workers. Depending
on the depth and complexity of the well, drilling could last from a few days to one week.
Once a well has been drilled and evaluated to have sufficient oil and/or natural gas, completion operations
would begin. Well completion involves perforating the production casing in target zones, followed by
hydraulic fracturing (also known as, fracking) of the formation (see below for more information on
hydraulic fracturing). The next phase of completion would be to flow and test the well to determine rates
of production.
Typical equipment and vehicles used during completion activities might include carbon dioxide tanker
trucks; sand transport trucks; water trucks; oil service trucks used to transport pumps and equipment for
fracking; flat beds and gin trucks to move water tanks, rigs, tubing, and fracking chemicals; logging
trucks (cased hole wireline trucks); pickup trucks to haul personnel and miscellaneous small materials;
and workover rigs.
Completion activities on individual wells may occur 24 hours per day, seven days per week, and would
require approximately 20 to 40 workers. Completion of an individual well could take from 7 to 30 days,
depending on the number of completion zones.
Hydraulic Fracturing
Hydraulic fracturing (also known as fracking) is a well stimulation technique used to increase oil and gas
production from underground rock formations. Fracking would also be evaluated at the APD stage should
the lease parcel be sold/issued and a development proposal submitted. The following paragraphs provide
a general discussion of the fracking process that could potentially be implemented if development were to
occur, including well construction information and general conditions encountered.
Fracking involves the injection of fluids through a wellbore under pressures great enough to fracture the
oil and gas producing formations. The fluid is generally comprised of a liquid such as oil, carbon-dioxide
or nitrogen, and proppant (commonly sand or ceramic beads), and a minor percentage of chemicals to
give the fluid desirable flow characteristics, corrosion inhibition, etc. The proppant holds open the newly
created fractures after the injection pressure is released. Oil and gas flow through the fractures and up the
production well to the surface.
Fracking has been used by oil and natural gas producers since the late 1940s and for the first 50 years was
mostly used in vertical wells in conventional formations. Fracking is still used in these settings, but the
process has evolved. Technological developments (including horizontal drilling) have led to the use of
fracking in unconventional hydrocarbon formations that could not otherwise be profitably produced.
The use of horizontal drilling through unconventional reservoirs combined with high-volume water based
multi-stage fracking activities has led to an increase in oil and gas activity in several areas of the country
which has, in turn, resulted in a dramatic increase in domestic oil and gas production nationally. However,
along with the production increase, fracking activities are suspected of causing contamination of fresh
water by creating fluid communication between oil and gas reservoirs and aquifers. The Environmental
Protection Agency (EPA) recently conducted an assessment of fracking on drinking water resources
(https://www.epa.gov/hfstudy) [EPA 2016]. Presently, there are no unconventional reservoirs that are
being exploited using high-volume water based hydraulic fracturing techniques.
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5.1.2 Production Operations

If wells were to go into production, facilities would be located at the well pad and typically include a well
head, two storage tanks, a truck load-out, separator, and dehydrator. Construction of the production
facility would be located on the well pad and not result in any additional surface disturbance.
All permanent surface structures would be painted a flat, non-reflective color (e.g., covert green) specified
by the BLM in order to blend with the colors of the surrounding natural environment. Facilities that are
required to comply with the Occupational Safety and Health Act (OSHA) would be excluded from
painting color requirements. All surface facilities would be painted immediately after installation and
under the direction and approval of the BLM.
If oil is produced, the oil would be stored on location in tanks and transported by truck to a refinery. The
volume of tanker truck traffic for oil production would be dependent upon production of the wells.
If natural gas is produced, construction of a gas sales pipeline would be necessary to transport the gas. An
additional Sundry Notice, right of way (ROW) and NEPA analysis would be completed, as needed, for
any pipelines and/or other production facilities proposed across public lands. BLM Best Management
Practices (BMPs), such as burying the pipeline and/or installing the pipeline within the road, would be
considered at the time of the proposal.
All operations would be conducted following the “Gold Book”, Surface Operating Standards for Oil and
Gas Exploration and Development (United States Department of the Interior and United States
Department of Agriculture 2007). The Gold Book was developed to assist operators by providing
information on the requirements for conducting environmentally responsible oil and gas operations on
federal lands. The Gold Book provides operators with a combination of guidance and standards for
ensuring compliance with agency policies and operating requirements, such as those found at 43 CFR
3000 and 36 CFR 228 Subpart E; Onshore Oil and Gas Orders (Onshore Orders); and Notices to Lessees.
The Gold Book includes environmental BMPs designed to provide for safe and efficient operations while
minimizing undesirable impacts to the environment.
Exploration and development on split-estate lands are also addressed in the Gold Book, along with IM
2003-131, Permitting Oil and Gas on Split-Estate Lands and Guidance for Onshore Oil and Gas Order
No. 1, and IM 2007-165, Split-Estate Report to Congress – Implementation of Fluid Mineral Leasing and
Land Use Planning Recommendations. Proper planning and consultation, along with the proactive
incorporation of these BMPs into the APD Surface Use Plan of Operations by the operator, would
typically result in a more efficient APD and environmental review process, increased operating
efficiency, reduced long-term operating costs, reduced final reclamation needs, and less impact to the
environment.
5.1.3 Produced Water Handling
Water is often associated with either produced oil or natural gas. Water is separated out of the production
stream and can be temporarily stored in the reserve pit for 90 days. Permanent disposal options include
discharge to evaporation pits or underground injection for enhanced recovery. Handling of produced
water is addressed in Onshore Oil and Gas Order No. 7.
Most injection wells do not cause earthquakes. In the United States, there is approximately 35,000 active
waste-water disposal wells, 80,000 active enhanced oil-recovery wells, and tens of thousands of wells,
and tens of thousands of wells are hydraulically fractured every year in the United States. The earthquake
rate increased in Oklahoma, southern Kansas, central Arkansas, and multiple parts of Texas (Rubinstein
2015). In Utah, the volumes are lower than those states experiencing induced seismicity. Also, the
geology is different than those states experiencing induced seismicity. The injection zones are
stratigraphically thousands of feet above the basement rock that may contain large unknown faults.
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Therefore, at this time it appears that induced seismicity from water injection is not a problem in the oil
fields of Utah (BLM 2018).
5.1.4 Maintenance Operations
Traffic volumes during production would be dependent upon whether the wells produced natural gas
and/or oil, and for the latter, the volume of oil produced. Well maintenance operations may include
periodic use of work-over rigs and heavy trucks for hauling equipment to the producing well, and would
include inspections of the well by a pumper on a regular basis or by remote sensing. The road and the
well pad would be maintained for reasonable access and working conditions. Portions of the well pad not
needed for production of the proposed well, including the reserve pit, would be re-contoured and
reclaimed, as an interim reclamation of the site.
5.1.5 Plugging and Abandonment
If the wells do not produce economic quantities of oil or gas, or when it is no longer commercially
productive, the well would be plugged and abandoned. The wells would be plugged and abandoned
following procedures approved by a BLM Petroleum Engineer, which would include requiring cement
plugs at strategic positions in the well bore. All fluids in the reserve pit would be allowed to dry prior to
reclamation work. After fluids have evaporated from the reserve pit, sub-soil would be backfilled and
compacted within 90 days. If the fluids within the reserve pit have not evaporated within 90 days (weather
permitting or within one evaporation cycle, i.e. one summer), the fluid would be pumped from the pit and
disposed of in accordance with applicable regulations. The well pad would be re-contoured, and topsoil
would be replaced, scarified, and seeded within 180 days of the plugging the well.
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Appendix H – Comments and Responses

As defined in the NEPA Handbook (page 40), “an ‘issue’ is a point of disagreement, debate, or dispute with a proposed action based on some anticipated environmental effect. An issue is more than just a position statement, such as disagreement
with grazing on public lands. An issue:
• Has a cause and effect relationship with the proposed action or alternatives;
• Is within the scope of the analysis;
• Has not been decided by law, regulation, or previous decision; and
• Is amenable to scientific analysis rather than conjecture.”
Comments that express a professional disagreement with the conclusions of the analysis or assert that the analysis is inadequate may or may not lead to changes in the EA. Substantive comments and non-substantive comments are defined in the
NEPA Handbook, H-1790-1, section 6.9.2. The BLM National Environmental Handbook (H-1790-1) states that substantive comments do one or more of the following:
• Question, with reasonable basis the accuracy of information in the EIA or EA
• Question, with reasonable basis, the adequacy of methodology for, or assumptions used for the environmental analysis
• Present new information relevant to the analysis
• Present reasonable alternatives other than those analyzed in the EIS or EA
• Cause changes or revisions in one or more of the alternatives.
Comments that are not substantive or comments received after the close of the public comment period may not receive a response.
All comments received are posted on ePlanning. Please note, paragraph numbering was added to comments.
BLM responded to ACHP’s review of the March 2019 Lease Sale Cultural Resource Report formally through the Section 106 consultation process. This letter is available to the public at: http://go.usa.gov/xPfnq
Commenter Comment Response

1. Southern Utah [Due to the length, the BLM has summarized the comments. The document in its entirety Due to the length, the BLM has summarized the comments to the headers. The document in its entirety is published on the ePlanning website.
Wilderness is published on the ePlanning website] SUWA also submitted exhibits which were not timely and was not submitted through ePlanning.
Alliance
[1] SUWA Incorporates Its Protests of the March and December 2018 and [1] Incorporation of a prior comment or protest requires a summary of the points of the comment or protest as it applies to the current action. On page two
March 2019 Monticello Field Office Lease Sale. of the comment, the commenter provided a bulleted list of points, however only one was not repeated in the current comment: “BLM must first complete
the San Juan Master Leasing Plan (San Juan MLP prior to offering new oil and gas leases for development in this region.” This is out of scope for a
comment on the EA.
[2] BLM Failed to take a Hard Look at the Direct, Indirect, and Cumulative [2] An EA must take a hard look at the direct, indirect, and cumulative impacts of a proposed action. 40 C.F.R. § 1508.9(b); NEPA Handbook H-1790, p.
Impacts of Its Leasing Decision… 55, 81. The Tenth Circuit has held that the “hard look” test under NEPA is satisfied if “the BLM considers generally the potential environmental effects of
its actions before issuing a lease and reserves a more detailed environmental analysis until a [site-specific] drilling proposal is made.
[2a]BLM Failed to Analyze Site-Specific Impacts of the Lease Sale…
[2a]The commenter contends that the BLM must “analyze all direct, indirect and cumulative impacts of its leasing decision.” It bases this contention on
the principle that lease issuance is an “irretrievable commitment of resources” and “BLM regulations, the courts and [Interior Board of Land Appeals
("Board")] precedent proceed under the notion that the issuance of a lease without an NSO stipulation conveys to the lessee an interest and a right so
secure that full NEPA review must be conducted prior to the decision to lease.” S. Utah Wilderness Alliance, 159 IBLA 220,241 (2003 ) However, 43
CFR §3101.1-2 States:
A lessee shall have the right to use so much of the leased lands as is necessary to explore for, drill for, mine, extract, remove and dispose of all the
leased resources in a leasehold subject to: Stipulations attached to the lease; restrictions deriving from specific nondiscretionary statures: and such
reasonable measures as may be required by the authorized officer to minimize adverse impacts to other resource values, land uses or users not
addressed in the lease stipulations at the time lease operations are proposed (emphasis added).
In other words, the lessee’s right to use the surface does not include a right to violate laws to protect certain resources. Such laws include
a) The Clean Air Act

b) The Clean Water Act
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c) The Threatened and Endangered Species Act
d) The National Historic Preservation Act
e) The Migratory Bird Treaty Act
f) The Bald and Golden Eagle Protection Act
g) The Paleontological Resources Preservation Act
Also note that the IBLA decision quoted above does not state that BLM must “analyze all direct, indirect and cumulative impacts of its leasing decision.”
It states that: “full NEPA review must be conducted prior to the decision to lease.” (emphasis added) The BLM conducts a site specific review of all these
protected resources prior to offering a parcel for lease to determine if there is potential that lease development will violate any of these Acts, and attaches
Lease Stipulations and Notices to inform the lessee that development of the parcel will be constrained, if necessary (substantially constrained, if
necessary), to ensure compliance with the law. These Lease Stipulations and Notices are derived from existing analyses that are incorporated by reference
in the analysis. As such, existing analysis, particularly the EIS prepared to disclose the impacts from a proposed Land Use Plan is often sufficient
disclosure at the leasing stage to make an informed decision. If the BLM resource specialist determines additional analysis is necessary to supplement
existing analysis, that analysis is included in an EA or EIS, as appropriate.
The BLM also conducts site specific review of other issues and concerns that are not protected by law. If, after all existing analyses with derived
stipulations and notices are reviewed and applied, the resource specialist determines that additional analysis is needed to disclose potentially unacceptable
impacts, the analysis is included in the EA or EIS. Frequently new lease notices are derived that will allow the BLM to add Conditions of Approval when
issuing the development permits. Many of these analyses have been conducted in past NEPA documents, making it unnecessary to conduct new analyses
when attaching the lease notices.
Thus the statement that the BLM must “analyze all direct, indirect and cumulative impacts of its leasing decision” is substantially correct, but it is
incorrect that new site specific analysis must be prepared for each decision. Site specific review is conducted, and rationale provided if the resource
specialist determines new analysis is not warranted.
The commenter has specifically called out a perceived lack of existing analysis on Bears Ears (BENM) or Canyons of the Ancients National Monuments.
In regards to BENM, the commenter asserts that the “western bloc of parcels are located less than four miles” away. The commenter is referring to the
historic boundary of the BENM, however the current boundary is about 9.5 miles from the nearest parcel. The commenter has provided no specific
conflicts the parcels may have with BENM resources.
In respect to the Canyon of the Ancients National Monument (CANM), the commenter’s assertion that impacts from oil and gas development have never
been analyzed is incorrect. When established, 80% of the lands with the CANM were under lease. The EIS prepared for the CANM RMP extensively
discussed impacts from oil and gas development including, in the cumulative impact section, development outside the CANM. This EIS has been added to
the list of documents in Section 1.7 of the EA, and the list of references.
In respect to the commenter’s assertion that neither the March 2018 EA nor the 2008 MtFO RMP EIS analyze the direct, indirect or cumulative impacts to
the Squaw and Papoose Canyon lands with wilderness characteristics, again, the analysis of impacts to wilderness characteristics does not need to be
started “from scratch” for every decision. Appendix D provides the acreage leased within each of these units, and Table 2 of the EA provides additional
rationale why further detailed analysis is not required for cumulative impacts to lands with wilderness characteristics within the MtFO.
[2b] The comment points to the recent 10th Circuit Court of Appeals Decision that, upon preparation of a Reasonably Foreseeable Development Scenario
[2b]BLM Failed to Analyze All Reasonably Foreseeable Cumulative Impacts (RFDS), the BLM must consider the number of wells projected in the RFDS as reasonably foreseeable in a cumulative impact analysis. However, the
Court Decision involved an RFDS prepared for a particular geologic formation, not a Field Office, and the Court did not state that the number of wells in
an RFDS must be used in the cumulative impact analysis for a resource with a Cumulative Impact Analysis Area (CIAA) that is smaller than the area
considered in the RFDS. However, BLM agrees that the 2005 MtFO RMP RFDS is a reasonable foreseeable action is regards to cumulative impact
analysis of Air Quality and Greenhouse Gases, and has revised the EA accordingly. The commenter’s assertion that a cumulative impact analysis of a
CIAA much smaller than that used to derive an RFDS must be conducted as though all development projected in that RFDS will occur in that CIAA has
no merit. In addition, the MtFO RMP EIS did use the 2005 RFDS in preparing its cumulative impact analysis.
[3] SUWA summarized the comments in 4 through 4f and are addressed below. Comments by Ms. Williams were not submitted through the ePlanning
[3] SUWA Incorporates the Comments Prepared by Ms. Megan Williams system, nor submitted timely.
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[4] BLM Must Analyze the Impacts of its Actions on Climate Change under [4] and [4a] Background – no response required.
NEPA
[4b] As stated on page 3 of the GHG specialist report (BLM 2019), BLM Utah uses GWP from the IPCC Fifth Assessment Report and the 100-year time
[4a] Climate Change Impacts are Already Occurring and Must Be Analyzed horizon. Specifically the value used for CH4 is 28, and 265 for N2O. The reference to the IPCC Fifth Assessment Report was inadvertently left out of the
and Disclosed GHG specialist report, but has been added. The 100-year time horizon is used to allow for a direct comparison with state and national emissions that are
also reported using the 100 year GWP.
[4b] BLM Failed to Disclose the True Magnitude of Methane Pollution
For the construction and operation emissions the BLM listed the mass emitted of each GHG (CO2, CH4, and N2O) so that the public has the information
to calculate other GWP using different time horizons (20 year or 500 year) if they choose. The mass for each gas is not provided for combustion
emissions since the combustion process converts methane into carbon dioxide as shown in the following chemical formula, CH4 + 2O2 → CO2 + 2H20
(http://www.classzone.com/vpg_ebooks/ml_sci_gr8/accessibility/ml_sci_gr8/page_284.pdf), and combustion emissions will not be meaningfully different
between different GWP time scales. Additionally the calculation for combustion emissions follow IPCC guidance. Reporting the 20 year GWP will not
provide any additional information for the decision maker beyond what is already included in the EA. However, for public disclosure purpose the EA has
been updated to show the 20-year GWP time horizon for construction and operation emissions using values from the IPCC Fifth Assessment Report.
[4c] BLM Failed to Adequately Analyze and Disclose the Direct and Indirect
[4c] Since the act of leasing is an administrative action there are no direct GHG emissions, and similarly no direct climate impacts. As stated in the EA,
Impacts of its Actions on Climate
section 3.3.2.2, indirect emissions that may result from the lease sale could come from well construction, well operations, and combustion of produced oil
and gas. As no development plans are available the BLM is unable to reasonably estimate mid-stream emissions (i.e. compressor stations, distribution
pipelines, refining processes, etc.) that may occur. Although, most mid-stream emission sources are required to report GHG emissions, so emissions from
these activities are included in the cumulative analysis with the reported state and U.S. emissions.
Additional information is added to the EA to clarify how the single well emissions were estimated from the Moab Master Lease Plan FEIS (BLM 2008)
emissions inventory. An appendix has been added to the GHG specialist report to provide more detail on the GHG emissions that come from each phase
of development. In reviewing the emission calculations from the Moab MLP it was discovered that an earlier version of emission inventory was used.
GHG emission estimates have been updated to use the final emissions inventory that was used in the Moab MLP FEIS air analysis. Changes between the
early and final version include improved estimates for heavy equipment exhaust emissions during construction, and the addition of re-completion,
blowdown, and workover emissions during operations.
Providing an estimate of every possible end-use is outside the scope of this analysis. Emissions from other end-uses are not included because it does not
provide additional information about environmental impacts that are not already disclosed through reporting combustion emissions. The BLM has no
authority to direct what the end-use of produced oil or gas should be, and does not have any information at this time related end-use. In the EA, the BLM
assumes 100% of produced oil and gas will be used in combustion for domestic energy and heating purposes. This assumption provides a sufficient
estimate of end-use emissions to inform the decision maker of the environmental impacts, and estimating other end-use emissions is unnecessary.
That statement about combustion emissions being conservative was clarified from the GHG specialist report. This statement was intended to show that the
calculations accounted for no product loss between the wellhead and point of combustion, but could be interpreted that calculated end-use emissions are
conservative.
Additional information related to GHG mitigation was added to the EA.
[4d] BLM has provided a best estimate of the cumulative GHG emissions at the time the draft EA was written. In summary, the commenter states that
[4d] BLM Failed to Analyze and Disclose the Cumulative Impacts of its Actions BLM failed to include foreseeable development from Utah School and Institutional Trust Lands leases, the March 2019 lease sale, the March and
on Climate December 2018 lease sales, or from notice of intents for future lease sales. We have coordinated with STILA. We have taken into account the non-federal
and federal APDs into our cumulative analysis which is the best available information we have. STILA did not provided any RFDs for their past and
future lease sale. Section 3.2 has been updated. BLM has included emissions from foreseeable development from the December 2018, March 2019, June
2019, September 2019, and December 2019 BLM lease sales. Only these lease sales were considered to avoid double counting of emissions from prior
lease sales and from foreseeable development associated with the APDs that were included in the cumulative. Total annual emissions estimates in this EA
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have been updated with better estimates of foreseeable development for the December 2019 lease sale, and to include non-federal APDs. The EA has also
been updated to include emissions associated with the planning area reasonably foreseeable development scenarios contained in the Monticello RMP, and
Moab MLP. This provides an estimate of emissions from all leasable acres in the planning area which includes all past, present, and foreseeable lease
sales.
In addition to the cumulative emission analysis for the field office, the EA reports total annual statewide emissions which includes BLM lease sales from
other field offices. Federal fossil fuel related emissions across the Rocky Mountain region and nationally are not included because they occur outside the
CIAA and lease sales outside the state of Utah are not connected actions (section 6.8.3.2 in NEPA Handbook H-1790-1). However, the BLM does
disclose federal fossil fuel emissions from Utah, surrounding states, and nationally as it is reported in the USGS report (USGS 2018).
[4e] Climate impacts are a result of global emissions as a whole and at present there are no informative methods for expressing the climate impacts from a
[4e] BLM Failed to Analyze and Disclose the Significance of its Actions on
single projects GHG emissions. In the EA, direct and indirect GHG emissions are used as a proxy for climate impacts, compared to state and national
Climate…Social Cost of Carbon…Social Cost of Methane…Global Carbon
emissions, and expressed in terms of the equivalent amount of vehicles and home energy use to make the impacts from emissions relatable to public life.
Budgeting
The commenter references CEQ guidance for not comparing project emissions with national and global emissions. However, this guidance has been
rescinded and the recent WEG vs Zinke court ruling instructs the BLM to include a comparison to state and national emissions. While section 3.3.2.2
doesn’t include a discussion of climate impacts, they are included in the cumulative analysis section 3.3.2.4. Section 3.3.2.2 has been updated to direct
readers to the climate impact discussion in Section 3.3.2.4.
Additionally, the commenter provides no better alternative for expressing the direct and indirect GHG emissions impact on the climate. The commenter
states that GHG emissions could be monetized, but monetization is not an environmental impact. Additionally, reporting only the cost of GHG emissions
without a full cost benefit analysis would misinform the decision maker and public. NEPA does not require a cost benefit analysis.
BLM chose not use social cost of carbon estimates for several reasons. First, social cost of carbon estimates are an economic metric meant to monetize the
net effects associated with an increase in carbon dioxide emissions. As such, social cost of carbon estimates are developed through an economic cost-
benefit analysis. NEPA does not require an economic cost-benefit analysis (40 C.F.R. § 1502.23). Without a complete monetary cost-benefit analysis,
which would include the social benefits of energy production to society as a whole and other potential positive effects, inclusion of a global social cost of
carbon analysis would be unbalanced, potentially inaccurate, and not useful. Additionally, CEQ’s draft NEPA Guidance on Consideration of GHG
Emissions states “an agency need not weigh the effects of the various alternatives in NEPA in a monetary cost-benefit analysis using any monetized
Social Cost of Carbon (SCC) estimates and related documents (collectively referred to as “SCC estimates”),or other similar cost metrics.”
(https://ceq.doe.gov/guidance/ceq_guidance_nepa-ghg.html)
The commenter states that the SCC is a “digestible figure for the public” by providing an example that a lease sale could have $100 million in climate
impacts. While this sounds simple, there is multiple carbon costs to choose from and no consensus on which value is best to use. In some cases there can
be a 1000% difference between low and high SCC estimates. With such a large difference, the use of SCC would only confuse the decision maker and
public on the climate impacts.
Furthermore, social cost of carbon estimates are just one approach that an agency can take to examine climate consequences from GHG emissions
associated with the proposed leasing action. The fact that climate impacts associated with GHG emissions were not quantified in terms of monetary costs
does not mean that climate impacts were ignored in this EA. This EA quantifies greenhouse gas emissions as the common metric and then qualitatively
discusses potential climate impacts. Climate change and potential climate impacts, in and of themselves, are often not well understood by the general
public (Etkin and Ho 2007, National Research Council 2009). This is in part due to the challenges associated with communicating about climate change
and climate impacts, stemming in part from the fact that most causes are invisible factors (such as greenhouse gases) and there is a long lag time and
geographic scale between causes and effects (National Research Council 2010). Research indicates that for difficult environmental issues such as climate
change, most people more readily understand if the issue is brought to a scale that is relatable to their everyday life (Dietz 2013); when the science and
technical aspects are presented in an engaging way such as narratives about the potential implications of the climate impacts (Corner,Lewandowsky,
Phillips, and Roberts 2015); use examples and make information relevant to the audience while also linking the local and global scales (National Research
Council 2010). In order to more effectively convey the potential climate impacts the BLM quantified greenhouse gas emissions as a common metric,
presented emissions in an equivalent related to everyday life, and discussed narratively climate impacts. This approach presents the data and information
in a manner that follows many of the guidelines for effective climate change communication developed by the National Academy of Sciences (National
Research Council 2010) by making the information more readily understood and relatable to the decision-maker and the general public. The approach
taken by the BLM for this EA to discuss climate change provides impacts at several scales whereas the social cost of carbon metric only provides an
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impact metric at the global scale. This limits the usefulness for the decision-maker given the lack of information on more localized impacts. The BLM
approach in the EA meets the “hard look” requirement by presenting the environmental impacts of the proposal and the alternatives in comparative form
(quantified greenhouse gas emissions), and discusses cumulative climate impacts, providing for the definition of issues and environmental consequences
ensuring that an informed decision can be made.
• Corner, A., Lewandowsky, S., Phillips, M. and Roberts, O. (2015). The uncertainty handbook-A practical guide for climate change
communicators. Bristol: University of Bristol.
• Dietz, T. (2013). Bringing values and deliberation to science communication. Proceedings of the National Academy of Sciences (PNAS)
110(3):14081-14087.
• Etkin, D. and Ho, E. (2007). Climate change: Perceptions and discourses of risk. Journal of Risk Research 10(5): 623-641.
• National Research Council. (2009). Informing decisions in a changing climate: Washington D.C.., The National Academies Press.
• National Research Council. (2010). Informing an effective response to climate change: Washington D.C.., The National Academies Press.
The commenters reasoning for using the Social Cost of Methane in the greenhouse gas analysis is essentially the same the reasoning for using the Social
Cost of Carbon. Similar to what was mentioned about the Social Cost of Carbon, there are several cost estimates that can be used for methane. The
commenter provides an estimated cost range of $540 to $3,200 for each ton of methane emitted. These values represent a nearly 600% difference, and
would similarly lead to confusion for the decision maker and public.
Carbon budgeting is a simplified approach for identifying how much additional CO2 emissions the atmosphere can accept in order to limit global warming
to a certain temperature above pre-industrial levels (2.0C for Paris Agreement, 1.5C for IPCC 2018 Special Report). The carbon budget was developed as
a tool to assist policy makers in reducing GHG emissions on national and global scales. There is no requirement or mechanism to apply a worldwide
carbon budget to a site specific project such as the proposed action. Carbon budgets do not currently exist at the national or state level, and creating such a
budget is beyond the scope of this EA. While a carbon budget sounds like a simple tool there is a lot of complexity and uncertainty to it that make it
confusing to the decision maker and public. There are multiple carbon budgets to choose from, each representing a different amount of global warming.
Even for a carbon budget that limits warming to 1.5C, scientists have struggled to agree on the size of the budget. According to the Intergovernmental
Panel on Climate Change (IPCC) 2018 Special Report (SR), “uncertainties in the size of these estimated remaining carbon budgets are substantial.” The
IPCC SR estimates the budget for a 50/50 chance of exceeding 1.5C at 580 gigatonnes of CO2 (GtCO2), with an uncertainty of ± 400GtCO2. This
uncertainty is nearly 70% of the budget. The uncertainty results from what the precise meaning of the 1.5C target is, definition of what "surface
temperature" means, definition of the "pre-industrial" period, what observational temperature dataset to use, uncertainty in non-CO2 factors that influence
warming, and if earth-system feedbacks should be taken into account. With the large uncertainty in the remaining carbon budgets, it is not a useful tool for
assigning a GHG emissions significance level at this time. Additionally, carbon budgets are inherently reduced with any GHG emissions. Based on the
disclosed GHG emissions in the EA and the substantial uncertainties in the size of carbon budgets, inclusion of carbon budgets would not provide
additional useful information to the decision maker or public.
Furthermore, the IPCC SR further states that policy actions across sectors and spatial scales are needed to reduce emissions and limit warming.
Evaluations of such policy actions are beyond the scope of this EA.
• IPCC, 2018: Global warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and
related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable
development, and efforts to eradicate poverty [V. Masson-Delmotte, P. Zhai, H. O. Pörtner, D. Roberts, J. Skea, P.R. Shukla, A. Pirani, W.
Moufouma-Okia, C. Péan, R. Pidcock, S. Connors, J. B. R. Matthews, Y. Chen, X. Zhou, M. I. Gomis, E. Lonnoy, T. Maycock, M. Tignor, T.
Waterfield (eds.)]. World Meteorological Organization, Geneva, Switzerland, 32 pp.
[4f] BLM must analyze and disclose to the public the climate impacts at the [4f]Reasonably foreseeable climate impacts resulting from GHG emissions is included in the EA, see section3.3.2.2. This EA incorporates by reference
leasing stage the climate analysis from the Colorado Plateau Rapid Eco-regional Assessment (Bryce 2012), which identifies the potential for climate change within the
Colorado Plateau. Potential for climate change across the Plateau varies from low to very high. Additional information was added to the EA to point out
the potential for climate change where lease parcels are located.
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[5] The first part of the commenter’s comment in regards to the requests of other entities is out of scope since the requests are not specific to the 2019 EA.
[5] BLM failed to Take a Hard Look at Impacts to Protected Lands including Dark Skies The second and third parts, involving impacts to Hovenweep National Monument were addressed in the EA. The EA incorporates by reference the Night
at Hovenweep National Monument and Hovenweep National Monument Resource Skies and soundscape analyses in the Moab MLP, and attaches the Lease Notice derived from that analysis:
Protection
LIGHT AND SOUND - SENSITIVE RESOURCES
The lessee/operator may be required to utilize best management practices and the best available technology in order to minimize/mitigate noise and
light pollution impacts. In accordance with section 6 of the lease terms and 43 CFR 3101.1-2, modifications to Surface Use Plan of Operations may
be required to minimize the impacts to the values of silence and night skies to visitors of parks, monuments, river corridors and other destinations
where light and/or sound impacts would mar the visitor experience. For example, the lessee/operator may be required to install multi-cylinder pumps,
hospital sound reducing mufflers, and/or place exhaust systems in manner that directs noise away from or reduces noise at the area. Additionally, the
lessee/operator may be required to utilize such methods such as limiting the height of light poles, limiting wattage intensity, constructing light shields
and/or adhering to prescribed restrictions on the timing for conducting artificially illuminated operations in order to minimize/mitigate light pollution
impacts. However, the above described requirements will not be applicable when their implementation would adversely affect human health and
safety.
As far as air quality impacts on the Monument, the EA has conducted a reasonable analysis on the EA on air quality which is applicable to the Monument.
[6, 6a and 6b] These are comments on the NHPA process which has a separate comment period. The commenter made NHPA comments on these parcels
[6] BLM’s Treatment of Cultural Resources Violated the National Historic Preservation when they were previously considered to be offered for lease in the March 2019 Lease Sale. The responses to those comments can be found here:
Act and NEPA https://eplanning.blm.gov/epl-front-office/projects/nepa/117403/169516/206123/2018-02-13_March2019_OG_SUWA_comments.pdf
[6a]BLM Failed to Make a Reasonable and Good Faith Effort to Identify Historic
Properties
[6b]BLM’s No Adverse Effect Determination is Unsupported and Arbitrary
[6c] The BLM Failed to Take a Hard Look at Impacts to Cultural Resources Pursuant to [6c] BLM has prepared a Cultural Resources Report and is consulting with the SHPO for this lease sale (sections 4.2, 4.2.2, and Appendix D), in addition
NEPA to sending the Cultural Resources Report to consulting parties. The act of leasing does not authorize any development or use of the surface of lease lands
without further application by the operator and approval by the BLM. A lessee must submit an Application for Permit to Drill (APD) (Form 3160-3) to the
BLM for approval and must possess an approved APD prior to any surface disturbance in preparation for drilling. The EA analyzes all impacts that are
reasonably foreseeable at the lease sale stage. Any stipulations and/or notices attached to the standard lease form must be complied with before an APD
may be approved. If APDs are received, the BLM would conduct additional site-specific NEPA analysis before deciding whether to approve the APD and
what additional conditions of approval (COA) would be applied.
[7] BLM utilized the Cane Creek visibility modeling to assess impacts to the closest Class I areas (Canyonlands and Arches National Parks) to the lease
[7] BLM’s Reliance on the Cane Creek Project and Moab MLP is Arbitrary parcels. Class I areas are provided additional protections for air quality related values (i.e., visibility, deposition) by the Clean Air Act that are not
provided to all other area (including Bear Ears, Hovenweep, or Canyons of the Ancient National Monuments). Since the Cane Creek Project is located
much closer to the Class I areas than the parcels being offered for lease, the visibility impacts to the Class I areas are likely to be much less than what was
analyzed for the Cane Creek Project.
While the commenter correctly states that lease parcels are no located in the Moab MLP modeling analysis, this was identified in the introductory
paragraph of section 3.3.1.4. However, the Moab MLP modeling area does overlap with the CIAA (i.e. San Juan County, Utah) and provides some insight
into the cumulative impacts that are predicted to occur in portions of the CIAA. In addition to the Moab MLP, cumulative impact information was
incorporated from the Utah Air Resource Management Strategy (ARMS) modeling study. The ARMS modeling domain covered the entire CIAA, and
shows that pollutants of concern (Ozone and PM2.5) are predicted to be below but near the NAAQS. The EA identifies that additional analysis may be
warranted based on site specific details that are available when a lessee submits a plan of development.
The commenter recommends use of the air quality modeling analysis prepared for the BLM Colorado Tres Rios, Uncompahgre, and Grand Junction field
offices. Information provided by the commenter about the BLM Colorado modeling analysis (https://www.co.blm.gov/nepa/airreports/AR2015.html) is
specific to the field offices in Colorado, and information is not accessible from that report for the CIAA or BLM Utah Monticello field office.
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In addition to the modeling information, this EA contains a qualitative discussion about the air quality impacts for oil and gas development. As identified
in section 3.3.1.1 and incorporated from the BLM Air Monitoring Report (BLM 2019), air quality in the Monticello Field office is generally good. The
area is in attainment or unclassifiable for all NAAQS pollutants. Air Quality Index information shows that San Juan County, Utah, had less had one
percent of days with unhealthy air between 2008 and 2017. The low level of development projected from this lease sale will have a negligible increase in
in pollutant emissions compared to existing emissions reported in the 2014 Nation Emission Inventory (BLM 2019). As a result, it is unlikely that the
small increase in emissions from developing the lease parcels would substantially degrade air quality in the area.
The modeling information presented in this EA, along with the qualitative discussion sufficiently informs the decision maker of potential air quality
impacts if parcels are developed.
[8] The Interior Board of Land Appeals (IBLA) has held that subsumed in a no action alternative is consideration of a no leasing alternative like the ones
[8] BLM Violated the NEPA Alternative Mandate; Legal Framework – NEPA the commenter proposed in its comments on the EA. See Biodiversity Conservation Alliance et al., 183 IBLA 97, 124 (2013) (finding that an alternative
Alternatives Analysis…BLM Analyzed Only the Extreme Lease-Nothing or Lease- that would have deferred leasing in certain sage grouse habitat was “clearly considered” by the BLM “in the course of considering the no action
Everything Alternatives – and SUWA’s Recommended Alternatives alternative, under which all of the public lands proposed for leasing would not be leased, and thus would not be developed for oil and gas purposes.
Subsumed under the no action alternative was not leasing all of the parcels within the Core Areas, including the parcels now at issue..”). Thus, the BLM’s
No Action alternative would eliminate any potential impact to the areas that would be analyzed in the commenter’s suggested “leasing outside wilderness
caliber lands” and “cultural resource preservation” alternatives.
The commenter’s “phased development-leasing” alternative would require a stipulation that is currently not authorized by the MtFO RMP, so such an
alternative would not be in compliance with the RMP. As stated in the Memorandum Decision and Order Denying Plaintiff’s Motion for Review of
Agency Action and Dismissing Certain Claims as Moot in the United States District Court for the District of Utah Case No. 2:15-cv-00194-JNP-EJF,
SUWA et. al. vs. BLM et. al. “FLPMA prohibits…BLM from taking actions inconsistent with the provisions of RMPs.” (Memorandum, page. 6). On
January 31, 2018, BLM released WO IM 2018-034, which states that “It is BLM policy that existing land use plan decisions remain in effect until an
amendment or revision is complete or approved.” This would also prevent the BLM from implementing the commenter’s “mitigation leasing” alternative,
which may require new controlled surface use and no surface occupancy stipulations. Best Management Practices are not attached to leases, but are
required by regulation and through Conditions of Approval attached to development authorizations.
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2.) Pueblo of [9] The Pueblo of Acoma (" Pueblo" or "Acoma") has directed the Chestnut Law Offices, P.A., as its legal counsel , to submit these [9-14]. These are comments on the NHPA process which has a separate comment period. The commenter
Acoma comments on its behalf. Acoma appreciates the opportunity to submit scoping comments to the Bureau of Land Management ' s (BLM) made NHPA comments on these parcels when they were previously considered to be offered for lease in the
Monticello Field Office's (MtFO) September 2019 competitive oil and gas lease sale (# DO I BLM-UT-0000-2019-0003-EA). The Pueblo March 2019 Lease Sale. The responses to those comments can be found here: https://eplanning.blm.gov/epl-
of Acoma demands that the BLM defer the September 20 19 Lease Sa le for the reasons stated belo w front-office/projects/nepa/117403/169516/206123/2018-02-13_March2019_OG_SUWA_comments.pdf
The Commenter made a request for government to government consultation. There are no comments specific
[10]Background to the EA to respond to. The letter has been passed on to the appropriate manager to handle the request for
government to government consultation. UT BLM responded to ACHP’s review of the March 2019 Lease Sale
Cultural Resource Report formally through the Section 106 consultation process. This letter is available to the
[10a] BLM has proposed for lease nineteen parcels, previously deferred from the BLM MtFO's March 2019 Lease Sale {#DOI-BLM-
public at: http://go.usa.gov/xPfnq
UT-Y020-2019-004-DNA) The stated reason for the March 2019 Lease Sale’s deferral was for additional environmental analysis.
Primarily, the need for additional e environmental analysis was due to the need for additional cultural resource evaluation, a subject that
was ultimately appealed to the Advisory Council on Historic Preservation (" AC HP”). The ACHP highlight h ted the BLM's erroneous
assert ion that lea sing would have no ad verse effect, and its conclusion that " it is possible to site a single oil and gas well within
each parcel without causing direct or indirect effects to known historic properties, and that ground C lass III surveys and
consultation will be conducted prior to approval of any ground disturbing activities." In stark disagreement , the ACHP could not
agree with the BLM' s ultimate finding of "no adverse effect," citing the BLM's failure to document how it would consider specific
direct, indirect , and cumulative effects, or how the BLM would avoid adverse effects to subsequently identified eligible districts
or landscapes. The ACHP noted the BLM' s failure to commit itself to a No Surface Occupancy stipulation for the lease parcels ,
which the ACHP concluded: " it logically follows that there is the potential for direct adverse effects of this reasonable fo rese ea
ble eve nt. Further mo re, we would argue that there is a re asonable probability for the lease to result in adverse effects on historic
properties... from related activities resulting from well pad deve lopment, such as in creased traffic and no is e."
[10b] The ACHP correctly notes the area of the proposed parcels in southeastern Utah to contain "world-class resources." For the Pueblo
of Acoma, they represent something greater. The location of these nineteen parcels is in an area dense with cultural resources important
to the Pueblo of Acoma as part of its ancestral cultural land scape. Acoma believes there to be increased pressure on its cultural
resources from potential oil and gas development in this region of Southeastern Utah. This increase in interest for oil and gas
development is alarming due to the Pueblo's concerns about the adequacy of identifications, analysis is, and protections for Pueblo
cultural resources and historic properties. Although actual development has been limited in comparison to other oil and gas development
regions like in New Mexico, the BLM still has its obligations under federal law to ensure the adequate identification, analysis, and
protection of eligible historic properties and our cultural properties upon the initiation of any .federal undertaking. More so, the BLM
has the opportunity to conduct informed and efficient land management at this stage, by working with the Pueblo, and other tribes, to
identify critical area s of concern, Pueblo cultural resources, and historic properties prior to oil and gas leasing. In fact, the ACHP
recommended the BLM develop a programmatic agreement to address its Section I 06 obligations prior to the lease sale. Such a
programmatic agreement must be developed consultation with the Pueblo of Acoma and other tribes, and must be done so immediately.
Until then, BLM must again, defer new lease s until it has completed a comprehensive analysis identifying Acoma cultural resource s as
part of the BLM's Section I 06 duties. That analysis is necessary to strike a more appropriate balance between the conservation of our
nation’s heritage and oil and gas drilling. A hurried sale, risks causing cumulative harm to one of America’s most treasured landscapes
and to the Pueblo’s irreplaceable cultural resources. Importantly, since the March 2019 Lease Sale's deferral, no additional substantive
work or consultation, consistent with fulfilling the obligation of Section 106, has occurred with the Pueblo of Acoma. No programmatic
agreement, as recommended by the ACHP has been developed as part of this undertaking.
[10c] BLM has a duty to identify Acoma’s historic properties and traditional cultural properties in compliance with Section I 06 of the National
Historic Preservation Act. Any reliance on a Class I analysis, a literature review, is de facto insufficient as prior analysis (even existing Class
III pedestrian surveys) have not used qualified experts who are able to identify Acoma cultural resources that may be eligible for the National
Register of Historic Places. Evaluation of identified archaeological resources may not be complete as they do not incorporate Pueblo of Acoma
ethnographic information. Incorporation and analysis of Acoma ethnographic information may cause them to be eligible historic properties
under the National Register of Historic Places ' four criteria. The region of the leases lies due east of the Bears Ears National Monument as
formally designated by President Barack Obama. This original monument was established in recognition of the area's importance as a cultural
landscape, containing cultural resources, historic properties, and traditional cultural properties important to the five tribal coalition, in addition
to other Pueblos such as Acoma. However, as the Pueblo of Zuni, a member of the coalition, has consistently stated -- this region is important
not just to the Pueblo of Zuni , but other Pueblos as well. The monument's reduction by President Trump, does not reduce the cultural landscape
which the redrawn monument now sits upon. Nor is the cultural landscape in southeastern Utah, marked by Ancestral Puebloan archaeological
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and cultural features, limited to the Bears Ears National Monument. The proposed leases li e northwest of the Hovenweep National Monument,
an important archaeological and cultural resource too many Pueblos. The proposed leases sit directly between two major cultural landscapes of
great importance to the Pueblo of Acoma. It can reasonably be deduced that lying between the two National Monuments is a rich Puebloan
cultural landscape, filled with cultural resources, traditional cultural properties, and archaeologic al sites. This has been made apparent by the
BLM as it acknowledges, "in the vast majority of the Monticello FO parcels, there is a high probability of the presence of cultural resources."
This area of southeastern Utah, part of the Four Comers region, is important to the Pueblo of Acoma. The Pueblo of Acoma considers
nearby regions such as Hovenweep, Mesa Verde, Crow Canyon, the Canyons of the Ancients, and Aztec as part of its ancestral homeland.
The area of the "Four Comers Region" is a critical part of the Pueblo's cultural landscape, and where the Pueblo's cultural resources,
traditional cultural properties, sacred sites, and historic properties are maintained. While these regions may lie within different states, Acoma
understands them to be connected and part of the Pueblo's history as Acoma's ancestors journeyed through these areas and far beyond in their
journey to their present home at Acoma. The Pueblo of Acoma has worked extensively with federal agencies and nongovernmental organizations
on projects in these regions. The Pueblo of Acoma has connections to cultural resources within the Bears Ears National Monument. In addition,
the Pueblo of Acoma visited the region of the proposed September 2019 lease parcels as part of the BLM MtFO's December 2018 Oil and Gas
Lease sale. There, Pueblo of Acoma representatives observed several Ancestral Puebloan archaeological sites and nearby areas with a high
likelihood of the presence of other Acoma cultural resources. Therefore, the BLM should be well aware that the location of September 2019
leases lies on an important cultural landscape to the Pueblo of Acoma with a high likelihood of undocumented or unanalyzed Pueblo of Acoma
cultural resources that may be eligible historic properties. The BLM's duties under Section I 06 require you to first identify these historic
properties prior to committing yourself to this action. The BLM cannot in good faith move forward, knowing full well that it does not have the
requisite data or expertise to identify Acoma's cultural resources, traditional cultural properties, and historic properties. Unless the BLM has
identified the Pueblo of Acoma's historic properties including the Pueblo's traditional cultural properties, which may include, but not be limited
to, specific sites, a cultural landscape, shrines, blessing places, springs, buttes, or any other number of Acoma cultural resources, then the BLM
has not complied with its legal obligations.
[11] Updated land use planning is necessary to avoid impacts to cultural resources.
Acoma urges the BLM to defer lease sales pending an update to the Monticello Field Office's 2008 Resource Management Plan ("RMP") and
the development of cultural resource management plans for the region of the September 2019 lease sale. BLM MtFO continuously discovers
new information about cultural resources and new archaeological sites yearly in one of the densest archaeological regions of Utah. Because of
the cultural resources management situation, the BLM MtFO developed stringent management actions under its ("RMP").Pursuant to the MtFO's
Cultural Resource Management Actions under the RMP, it is the goal of the MtFO to "[i]dentify, preserve, and protect important cultural
resources... [.]"12 Under BLM's management actions it shall "[prioritize] geographic areas for new field inventory pursuant to Section 110
of the [NHPA] and Section 14 of the Archaeological Resources Protection Act (ARPA) [to] be identified based upon a probability for
unrecorded important resources. These inventories will be conducted as funding is available and as opportunities arise. However, as of
2015, it is unclear as to whether adequate cultural resource management planning has occurred within the MtFO, let alone for the
geographic region of the September 2019 Lease parcels. The BLM MtFO admits in its 2015 Land Use Plan Evaluation Report that
"completion of a cultural resource management plan would improve [the BLM's] ability to plan for access to cultural sites.... [and] [a]s a
result the RMP does not fully protect significant cultural and paleontological resources through special designations. If such a cultural
resource management plan were to be completed, the plans "will also include but not be limited to ... identifying areas for cultural inventory
where federal undertakings are expected to occur. This region of the MtFO is under increasing pressure from oil and gas development
with the completion of the March 2018 and December 2018 Oil and Gas Lease Sales. The proposed September 2019 lease sale only
compounds this pressure with no foreseeable halting of future oil and gas leasing in sight. Adding to the threat of harm to cultural resources
no indication that the MtFO has identified or is actively pursuing a cultural resources management plan as mandated by the RMP for this
region of the MtFO. The Pueblo of Acoma has previously stated, and continues to urge the BLM, that there are likely Acoma cultural
resources and eligible historic properties that have not yet been identified. BLM must factor the increasing degree of industry interest in
the region, and its status in following through with its cultural resources management actions. Coupled with the Pueblo of Acoma's
concerns that this region where the most recent lease sales have occurred contains a dense cultural landscape; it demands reconsideration
of the assumptions on which the existing RMP relies and deferral of the Lease Sale until updated land management planning occurs.
[12] BLM must comply with its duties under Section 106 of the NHPA.
"Section 106" requires federal agencies to evaluate "undertakings" that may affect historic properties in accordance with a mandatory
consultation process. 54 U.S.C. § 306108; 36
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C.F.R. Part 800. Federal undertakings" include the issuance of oil and gas leases. Mont. Wilderness Ass 'n v. Fry, 310 F. Supp. 2d 1127,
1152 (D. Mont. 2004). The statute explicitly requires that BLM must complete this process "prior to" issuing or otherwise irretrievably
committing to the issuance of any proposed leases. 54 U.S.C. § 306108; 36 C.F.R. § 800.1(c). BLM must determine whether the
leasing of parcels will affect the Bears Ears and Hovenweep National Monuments, and any other historic properties including
traditional cultural properties. This evaluation must account for any indirect and cumulative effects, including impacts to the context
and setting of these resources. Waiting to complete this step of the NHPA until after leases have been sold, and real property interests
created, is not compliant with the directives of the NHPA.
[12a] BLM must complete its review under Section 106 "prior to" approving the undertaking, as required by the statute.
BLM continues to take the unwarranted position that it can wait to initiate the Section 106 process until the latter stages of the oil and gas
leasing process, primarily during the "APO" phase (application for permit to drill). Under the NHPA, BLM must initiate the Section 106
process "early in the undertaking's planning, so that a broad range of alternatives may be considered during the planning process for the
undertaking." 36 C.F.R. § 800. l(c). "This directive makes it pellucid that agencies are not expected to delay NHPA review until all details
of the proposal are set in cement." Safeguarding the Historic Hanscom Area's Irreplaceable Res., Inc. v. Federal Aviation Admin., 651
F.3d 202, 215 (1st Cir. 2011). The Section 106 regulations direct BLM to "consider [its] section 106 responsibilities as early as possible
in the NEPA process, and plan [its] public participation, analysis, and review in such a way that they can meet the purposes and
requirements of both statutes in a timely and efficient manner." 36C.F.R. § 800.8(a)(l). This "early coordination" requirement of Section
106 is designed to ensure that BLM fully engages consulting parties in the decision-making process, "when the purpose of and need for
the proposed action as well as the widest possible range of alternatives are under consideration." Id. § 800.8(a)(2). BLM must complete
the Section 106 process "prior to" committing itself to a course of action that may affect historic properties. 54 U.S.C. § 306108. Here, as
soon as possible, BLM must identify and invite interested parties, as well as interested tribes, to participate in Section 106 consultation.
The BLM should not forego its duties to invite the Pueblo of Acoma, or other tribes, to consult with the BLM to identify potential historic
properties and other cultural resources prior to the lease sale.
[12b] BLM must make a "reasonable and good faith effort" to identify Traditional Cultural Properties (TCPs) and other historic
properties.
BLM must make a "reasonable and good faith effort" to identify TCPs and other historic properties within the area potentially 1•
affected
by the protested leases. Under Section 106, BLM must make "a reasonable and good faith effort" to identify historic properties located
within an undertaking's area of potential effects ("APE"). 36 C.F.R. § 800.4(b)(l). To satisfy this requirement, BLM must, "at a
minimum, [conduct] a review of existing information on historic properties that are located or may be located within the APE...."1
Existing information is not limited to tomes in the agency office, but includes commonly known facts, or others that have become known
to the agency, such as the Acoma's, and other Pueblos', enduring and substantial cultural connection to sites throughout the Monticello
Field Office area. Additional identification efforts, including "consultation, oral history interviews, sample field investigation, and field
survey", are also required, in particular when tribes have "indicated the existence of traditional cultural properties ..." Pueblo of Sandia v. U.S.
Forest Serv., 50 F.3d 856, 860 (10th Cir. 1995). BLM must account for the identification of TCPs associated with Acoma within the cultural
landscapes surrounding the Bears Ears and Hovenweep National Monuments. This is especially the case for cultural resources that may be
identified on or near the lease parcels closest to the Hovenweep National Monument. At Hovenweep, the US Department of the Interior has
recognized the cultural affiliation of 18 of 20 Pueblos to Hovenweep National Monument on its registration of Hovenweep to the National
Register of Historic Places. The affiliation listing includes the Pueblo of Acoma. BLM should therefore be on notice of the likely existence of
Acoma TCPs surrounding Hovenweep that may possibly be affected by future oil and gas development. Under Section 106, TCPs are a type of
historic property that BLM must identify and evaluate.19 According to National Register Bulletin 38.
[a]n early step in any effort to identify historic properties is to consult with groups and individuals who have special knowledge
about and interest in the history and culture of the area to be studied. In the case of traditional cultural properties, this means those
individuals and groups who may ascribe traditional cultural significance to locations within the study area, and those who may have
knowledge of such individuals and groups. Ideally, early planning will have identified these individuals and groups, and established
how to consult with them.
As previously discussed in Section 1 of this comment, supra, the BLM has insufficient information to be able to fully identify Acoma
TCPs. However, it is not enough to merely ask the Pueblo of Acoma to identify its TCPs on a map, or expect the Pueblo to be readily able
to provide exact pinpoint locations of such cultural resources. Such a request is not enough under the NHPA:"[a] mere request for
information is not necessarily sufficient to constitute the 'reasonable effort' section 106 requires." Pueblo of Sandia, 50 F.3d at 860. BLM
has limited its TCP identification effort here to "mere requests for information," or cursory review of the limited information available to
the Monticello Field Office, and not yet completed any field inspections by qualified experts able to identify Acoma cultural resources.
Therefore, BLM has not fully engaged in the Section 106 Process or the independent duty of federal agencies to consult with Acoma
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concerning federal actions that can affect sacred sites and other places of importance BLM must heed the lessons of Pueblo of Sandia.
There, the U.S. Forest Service knew in advance of initiating consultation that the pueblo had identified a specific location as "an area of
great religious and traditional importance...." Pueblo of Sandia, 50 F.3d at 860 (internal quotations omitted). BLM now finds itself in a
similar position as it is aware this area if of importance to the Pueblo of Acoma, and likely other tribes and Pueblos. Prior to this leasing
proposal, in the field identification of Acoma TCPs and eligible historic properties is necessary. BLM must engage with the Acoma in
good faith consultation concerning the identification and evaluation of TCPs in the cultural landscape that underlies the area of the
September 2019 lease sale.
[12c] BLM must account for a cultural landscape encompassing the Bears Ears National Monument, Hovenweep National Monument,
and related cultural resources.
BLM must account not only for the Bears Ears National Monument and the Hovenweep National Monument, but also of Ancestral Puebloan
archaeological features and other cultural resources that may emanate and connect these locations. BLM should not view the archaeological
resources in a vacuum but analyze the cumulative effect to a cultural landscape (or multiple landscapes) connecting the Bears Ears National
Monument and Hovenweep National Monument. There is a high likelihood that emanating from and connecting the Bears Ears and Hovenweep
National Monuments are shrines, blessing places, pilgrimage trails, other non-archaeological cultural sites, earthworks, dry farming areas, and
other road-related features that could be harmed by the leasing and subsequent development of parcels. Some of these cultural resources may be
natural resources (with archaeological traces) that may be unrecognizable by archaeologists not trained to identify Acoma cultural resources or
historic properties. Further evaluation by Acoma cultural experts may identify and evaluate cultural resources to be active cultural resources to
the Pueblo of Acoma. Further evaluation may determine a cultural landscape encompassing the Bears Ears National monument and the
Hovenweep National Monuments due to their proximity and relation to one another.
[12d] BLM must fully assess the potential for adverse effects.
BLM must fully assess the potential for adverse effects on the Bears Ears and Hovenweep National Monuments, and other significant cultural
resources in the landscape surrounding and connecting the two. Under Section 106, BLM must "apply the criteria of adverse effect to historic
properties within the area of potential effects." 36 C.F.R. § 800.S(a). Those criteria include ''cumulative" effects, as well as effects on "the
property's setting that contribute to its historic significance" and ''visual, atmospheric or audible" effects "that diminish the integrity of the
property's significant historic features...."Id. § 800.S(a)(l ), (a)(2)(iv), (v). BLM has failed to correctly apply these criteria to the proposed
lease sale.
[12dI]BLM must fully assess the potential for visual and auditory effects.
BLM must fully evaluate the potential for visual and auditory effects on the Bears Ears National Monument, the Hovenweep National
Monument, and other significant cultural resources in the landscape surrounding and connecting the two. These effects are not speculative as
the visual and audio effect of oil and gas development can severely affect Acoma archaeological and cultural resources. 21 Because
many important cultural resources associated with the Bears Ears National Monument and the Hovenweep National Monument were
intentionally located to achieve maximum visibility, they are highly susceptible to the visual and auditory impacts of oil and gas
development. Consequently, BLM must recognize and fully evaluate the potential for these impacts on these two National Monuments,
and associated traditional cultural properties that may exist on or near the propose BLM parcels.
[12dII] BLM must fully evaluate cumulative effects on Bears Ears National Monument, Hovenweep National Monument, the Alkali
Ridge ACEC, and other significant cultural resources in the surrounding landscape. BLM must also evaluate the cumulative effects of
the proposed leases in conjunction with past, present and reasonably foreseeable future activities. Under Section 106, BLM must identify
"reasonably foreseeable effects caused by the undertaking that may occur later in time, be farther removed in distance or be cumulative."
36 C.F.R. § 800.S(a)(l). This includes analyzing the effect of existing oil and gas wells, tanks, roads, pipelines, other infrastructure, and
undeveloped oil and gas leases upon in the landscape surrounding the Bears Ears National Monument, the Hovenweep National
Monument, the Alkali Ridge ACEC, and the immediate region.
[13] BLM has failed to comply with its obligations under the 2008 RMP to inventory lands under Section 110 of the NHPA.
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"Section 110" of the NHPA places the responsibility of the BLM for the preservation of historic properties within their ownership or
control. 54 U.S.C. § 306101. The agency is further obligated to have a program that includes the "identification, evaluation and
nomination" of historic properties to the National Register. 54 U.S.C. § 306102. Here, the BLM has not met its responsibility to
proactively survey the area in the years since the RMP was developed. This is concerning given BLM's elevated awareness of the
significance of the lands in the leased areas to the tribes which have ancestral ties to the region. The Hopi Tribe expressed major
concerns in the March 2018 lease sale, for instance, that tribal cultural resources had not been adequately considered. The Pueblo of
Acoma reiterated similar concerns during the December2018 Lease Sale and the most recent March 2019 Lease Sale which proposed
these same parcels here.
The Record of Decision approving the 2008 Monticello Resource Management Plan instructs BLM to "conduct proactive cultural
inventories under Section 110 of the National Historic Preservation Act"• However, in a review of the RMP in 2015 BLM staff noted that:
the RMP does not fully protect significant cultural and paleontological resources through special designations. Likewise, route
and travel designations in the RMP fail to address cultural and paleontological needs and protection. Nomination of the most
significant sites to the National Register of Historic Places and additional road inventories in the field office would help
remedy these shortfalls. An updated Class I survey for the Monticello Field Office is in progress.25
Despite these suggestions, BLM has failed to comprehensively undertake National Register evaluations. Even worse, it denies
the responsibility for doing so. In BLM's response to the National Trust and Friends of Cedar Mesa's protest of the March 2018
lease sale BLM stated in frank terms:
[T]he BLM is not required to consider a request from the public to make districts, landmarks, or other special designations when
analyzing impacts from an undertaking.
The result is that unless the BLM proactively inventories the cultural resources in its control, the BLM will continue to suffer from a lack
of information and potentially cause destruction of unidentified historic properties. The Pueblo of Acoma's visit to the region of the
December 2018 lease sale confirmed to the Pueblo, the richness of the cultural landscape and likelihood of additional unidentified Acoma
cultural resources for this area. BLM should pause to adequately inventory the region of the September 2019 Lease Sale in compliance
with its duties under Section 110 of the NHPA.
[14] Conclusion & Request for Consultation

The Pueblo of Acoma requests immediate government-to-government consultation with the BLM regarding this undertaking (#DOI-
BLM-UT-0000-2019-0003-EA) as mandated upon the BLM by federal law and executive order. The Pueblo requests the BLM to
present information related to this undertaking at the Pueblo of Acoma. In addition, the BLM should be well aware that government-to-
government consultation is not a one-time meeting, but a continuing dialogue. The Pueblo of Acoma appreciates the opportunity to
provide scoping comments, and Acoma looks forward to participating throughout the NEPA and NHPA processes to assist the BLM's
consideration of the proposed leasing and for you coming to the Pueblo of Acoma to present further information. If you have any
questions, please feel free to contact the Pueblo of Acoma.
3.)Richard W [15] My wife and I are the owners of 320 acres in San Juan County which are now part of Parcel UT0319-421, one of 19 parcels to be [15] If any activity were to occur on split estate parcels, the lessee and/or operator would be responsible for
Kollenkark included in the September 2019 oil & gas lease sale. We purchased the property in 1996 and, since then, have constructed a facility known as adhering to BLM requirements as well as formulating and reaching an agreement with the private surface
Peacewhisper Spiritual Retreat Center, which was formally dedicated in June of 2007. Peacewhisper is a 501(c3) nonprofit that is board- landowners regarding access, surface disturbance, and reclamation (O.O.#1). Parcel 421 will have NSO
governed and averages over 100 retreatant nights annually. The attractions of Peacewhisper are many, most valued being the quiet and portions. Stipulations UT-S-98 (NSO – Fragile Soils/Slopes Greater than 40 Percent), UT-S-128 (NSO –
peaceful enviroment. Being surrounded by trees that are older than our own USA or seeing a pottery sherd for the first time just lying in the Floodplains, Riparian Areas, Springs, and Public Water Reserves), and UT-S-182 (NSO – Critical Habitat of
dirt, are a few of the other reasons people continue to return. This acreage was one of the last homesteads given by the federal government in the Endangered Colorado River Fishes) are attached to this parcel. At this time, the acreage is unknown. Please
the lower 48 states. That was in 1967. A short time later the property was fenced and that has made it the 'island' that it is now. By 'island' I refer to Appendix A and section 2.5.3.
mean that it has retained most of its wilderness characteristics and many of the surface cultural artifacts remain. The property is bordered on
the north by Lake Canyon which is over 500 feet below and steepness into the canyon forms a natural barrier, no fence required. The
southern-most 80 acres of this property is still unfenced and is noticeably different different, most likely because of the seasonal cattle
grazing and, more recently, the human traffic from the nearby youth camp, Open Sky. There is also an old well pad on it that prodeced a 'dry
hole' in the 1960s. This well was scheduled to be reentered about 10 years ago, but never happened. What did happen was an agreement to
give the drilling company access to that well, along with other wells to the west, across this portion of the property from County Road #347
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using an old roadway. This is the shortest route to these wells, so the drilling company, D.J. Simmons, had the old road re-engineered and
surveyed for equipment and pipeline installatiobn as well as having a full archaelogical study completed. This route would still be the most
efficient way to access the parcels that are to the west and south, which seems to be the general direction of the development as shown on the
map, page 113. Also, on this map is Parcel 410 which is immediately west of 421 and has the identical stipulations and notices. Parcel 410 is
also the only one of the 19 that lists Major Constraints, in the form of 383.31 NSO acres, some of which are surely contiguous to those in
421. Parcel 421 is specifically mentioned several times in the Appendix D checklist as having unique qualitites and the already mentioned
fenced acres have been especially protected. Aside from the real estate itself is Peacewhisper the Retreat Center, a separate entity that has
had positive effects on the lives of hundreds over the past twelve years and is publicly supported by even more. Over the years, amenities to
the retreat facility have been added, such as the 1/4 mile Stations of the Cross Walk. There is a 7-circuit labyrinth and a 500' Rosary Walk,
both visible on Google Earth. The stone Hermitage is found at the end of a mile-long path through old growth Juniper and Pinyon. My point
is that this portion of Parcel 421 has already been developed into a proven reputable spiritual haven, as well as a residence and farm and
sharing it for purely speculative reasons would not be an improvement. The concern is that any oil and gas activity at all on this property
would negatively impact the work put into Peacewhisper over the past 20 years so as to make it unsustainable. Development is slow to non-
existent in remote country like this, but there is something here now and this EA does not address that fact. The intent of this letter is to
update the information on our status in order to provide a more accurate picture of what happens on this parcel. Our request would be to have
all the acreage inside our fence line to be designated as NSO. This would allow full enjoyment of the property as the owner as well as that of
Peacewhisper retreatants. Our unfenced 80 acres mentioned above would remain within the original Parcel 421 and we would work with any
successful lessee to resolve a surface use agreement for them.
4.) National [16] The Natural History Museum of Los Angeles County (NHMLA) is respectfully submitting the following comments to the Bureau [16] Background information. Additional response is not warranted.
History of Land Management (BLM) Monticello Field Office regarding the NHMLA Excavations in Southeastern Utah. The NHMLA has a
Museum of Los long tenure of conducting paleontological research and excavations on BLM lands, both in Utah as well as other states such as
Angeles County California, Montana, and Wyoming. Most recently, the NHMLA has spent the past 10 years working on BLM lands under the
jurisdiction of the Monticello Field Office. The NHMLA has successfully collected a wide range of significant fossils from multiple
quarries and sites during this time. Research on these specimens is ongoing, however some studies have already been published in the
scientific literature (for example, see Milan and Chiappe, 2009; Milan et al., 2015) or presented at scientific conferences (for example,
see Bell et al., 2018, 2019; Martin et al., 2011; Mocho and Chiappe, 2019, 2018).
Active NHMLA Quarry
The NHMLA has an active quarry site on Parcel 408 in San Juan County, Utah (Fig. 1). This quarry was discovered during a prospecting trip in
2007 under a survey and surface collection permit from the Monticello Field Office. Starting in 2008 excavations began under excavation
permits, with work occurring in 2008, 2009, and 2012-2018. In this period, the NHMLA has collected over 600 bones from the quarry (Fig. 2).
Most of these bones have been identified as belonging to sauropod dinosaurs, but Allosaurus, ankylosaur, stegosaur, and ornithopod have also
been identified so far. In addition to scientific contributions to the paleontological record, the quarry is central to many of the NHMLA’s
outreach and education initiatives. The NHMLA has hosted numerous high school, undergraduate, and graduate students at the quarry, many of
whom belong to demographics historically underrepresented in the sciences. Locally, the NHMLA has worked with the BLM and other groups
such as the Bears Ears Education Center in Bluff, UT to host community members for tours of the quarry. Efforts such as these, along with the
scientific value of the specimens found in the quarry, are central to the broad significance of the quarry.
The Morrison Formation
The NHMLA quarry on Parcel 408, as well as many other NHMLA sites discovered during earlier field work, are located in the Upper Jurassic
Morrison Formation. The Morrison Formation is the classic dinosaur lagerstätten (e.g., Selden and Nudds, 2005). Extending from the Colorado
Plateau to the Uinta Mountains and northern New Mexico and Arizona, the red and green weathering mudstones and resistant sandstone ledges
of the Morrison are a landmark on the western landscape (Dodson et al., 1980; Turner and Peterson, 2004). The Morrison has long been known
to represent deposition in a continental setting under arid to semi-arid conditions. However, work in the past 15 years on sedimentology and
stratigraphy as well as the non-dinosaurian faunas and floras of the Morrison has demonstrated critical episodes of wet conditions (Demko et
al., 2004; Turner and Peterson, 2004; Owen et al., 2015). This climate change resulted in more defined fluvial features that shift through the
stratigraphy of the formation.
In southeast Utah, the Morrison can be divided into five members (Hintze, 1988; Peterson and Turner- Peterson, 1989). The lowermost Bluff
Sandstone Member overlies the Wanakah Formation (Middle Jurassic) along a major, regional uncomformity (the J5 unconformity; Pipiringos
and O’Sullivan, 1978). The Bluff Sandstone is predominantly fluvial deposits with small amounts of floodplain and lacustrine deposits and is
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more or less correlative with the primarily mudstone Tidwell Member elsewhere. The overlying Salt Wash Member is distinguished by small
cliffs of lenticular cross-bedded sandstone and conglomerate interbedded with red and green weathering mudstone. Regionally, two members
are recognized above the Salt Wash Member: the Recapture Member and the Westwater Canyon Member. The uppermost member is the
Brushy Basin Member, recognized throughout the entire Morrison basin, and the setting for the NHMLA quarry on Parcel 408.
Dinosaur and other vertebrate fossils, such as crocodiles, lizards, sphenodonts, mammals, and frogs are found throughout the Morrison but
tend to be concentrated in discrete beds (Gregson and Chure, 2000; Santucci, 2000; Foster and McMullen, 2017). The major quarries, such as
the Douglass Quarry at Dinosaur National Monument and the Cleveland-Lloyd Quarry in the San Rafael Swell, are found in the Salt Wash or
Brushy Basin members. The Tidwell or Bluff Sandstone members contain rare but valuable early Jurassic sauropods (e.g., Gillette, 1993;
Bernier and Chan, 2000) in southeastern Utah. Throughout the Morrison, significant bone beds are mostly concentrated in basal channels of
conglomerate or sandstone (Dodson et al., 1980; Jeffery et al., 2011; Bertog, 2013) although material is also found weathering out of the
mudstones (Figure 2). The Morrison also has a strong history of preserving ichnofossils, with footprints from a variety of trackmakers
(Gierlinski and Sabath, 2008; Lockley et al., 1998; Platt et al., 2006) as well as large mammal burrows (Martin et al., 2011) and a variety of
other ichnofossils present (Hasiostis, 2004; Hasiotis et al., 1998). A variety of the types of fossil preservation known from the Morrison
Formation are shown in Figure 3. Bonebed preservation similar to that of the NHMLA’s quarry in Parcel 408 is common in the Morrison. In
addition to the famous quarries at Dinosaur National Monument and the Cleveland-Lloyd Quarry mentioned above, numerous other quarries
are known from the Morrison Formation, including the Hanksville-Burpee Quarry in Utah; Garden Park, Dry Mesa Quarry, and the Fruita
Paleontological Resource Area in Colorado; and Bone Cabin Quarry, Como Bluff, and the Wyoming Dinosaur Center in Wyoming (Eberth et
al., 2010). All of these sites preserve significant paleontological resources providing invaluable scientific data as well as important outreach
and education opportunities to the public. [17] Background information. Additional response is not warranted.
[17] Deficiencies of the Environmental Assessment DOI-BLM-UT-000-2019-0003- OTHER_NEPA_MtFO-EA

A.Federal Regulations
Paleontological resources are limited, nonrenewable resources of scientific, cultural, and educational value and are afforded protection
under federal and state laws and regulations. Federal regulations that provide protections for paleontological resources include the
Paleontological Resources Preservation Act and the National Environmental Policy Act, as discussed below:
Paleontological Resources Preservation, Omnibus Public Lands Act, Public Law 111-011, Title VI, Subtitle D (PRPA), 2009.
This legislation directs the Secretaries of the U.S. Department of the Interior (USDI) and U.S. Department of Agriculture (USDA) to
manage and protect paleontological resources on federal land using “scientific principles and expertise.” To formulate a consistent
paleontological resources management framework, the Paleontological Resources Preservation Act (PRPA) incorporates most of the
recommendations from the report of the Secretary of the Interior titled “Assessment of Fossil Management on Federal and Indian
Lands” (USDI, 2000). In passing the PRPA, Congress officially recognized the scientific importance of paleontological resources on
some federal lands by declaring that fossils from these lands are federal property that must be preserved and protected. The PRPA
codifies existing policies of the Bureau of Land Management (BLM), National Park Service (NPS), U.S. Forest Service (USFS),
Bureau of Reclamation, and U.S. Fish and Wildlife Service (USFWS), and provides the following:
• uniform criminal and civil penalties for illegal sale and transport, and theft and vandalism of fossils from federal lands;
• uniform minimum requirements for paleontological resource-use permit issuance (terms, conditions, and qualifications of
applicants);
• uniform definitions for “paleontological resources” and “casual collecting;” and
• uniform requirements for curation of federal fossils in approved repositories.
The National Environmental Policy Act (NEPA) of 1969. NEPA (Public Law [PL] 91-190, 42 USC 4321-4347, January 1, 1970), as
amended (PL 94-52, July 3, 1975; PL 94-83, August 9, 1975; and PL 97-258 § 4(b), Sept. 13, 1982) recognizes the continuing
responsibility of the federal government to “preserve important historic, cultural, and natural aspects of our national heritage…” (Sec.
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101 [42 USC § 4321]: #382). With the passage of the PRPA, paleontological resources are considered a significant resource and it is
therefore now standard practice to include paleontological resources in NEPA studies in all instances where there is a possible impact.
B.BLM Guidelines
The BLM has developed a series of documents providing guidance for the protection of paleontological resources on BLM lands, in
fulfillment of the PRPA and NEPA, as discussed below: Potential Fossil Yield Classification System (2008, 2016). The BLM’s PFYC
system was developed to provide baseline guidance for assessing paleontological resources and allow BLM employees to make initial
assessments of paleontological resources. The presence of paleontological resources is correlated with mapped geologic units. The system
assigns a class value to each geological unit, representing the potential abundance and significance of paleontological resources that occur in
that geological unit. A complete discussion of the background and context for the PFYC system is provided in the BLM IM2016-124 (2016)
document. The BLM PFYC system ranges from Class 1 (very low) to Class 5 (very high). PFYC Class 5 (very high) is defined as follows:
Highly fossiliferous geologic units that consistently and predictably produce significant paleontological resources. Units
assigned to Class 5 have some or all of the following characteristics:
•Significant paleontological resources have been documented and occur consistently.
•Paleontological resources are highly susceptible to adverse impacts from surface disturbing activities.
•Unit is frequently the focus of illegal collecting activities.
(1) Management concerns for paleontological resources in Class 5 areas are high to very high.
(2) A field survey by a qualified paleontologist is almost always needed. Paleontological mitigation may be necessary before or
during surface disturbing activities.
The probability for impacting significant paleontological resources is high. The area should be assessed prior to land tenure adjustments. Pre-
work surveys are usually needed and on-site monitoring may be necessary during land use activities. Avoidance or resource preservation
through controlled access, designation of areas of avoidance, or special management designations should be considered. (BLM, 2016). Within
this framework, it is clear that the Morrison Formation should be assigned PFYC Class 5, very high. The abundance of paleontological
resources known from the Morrison Formation, as documented above, include body fossils of dinosaurs, mammals, and other animals, trace
fossils such as footprints and burrows, invertebrate, and plant fossils. These fossils are found as isolated specimens as well as accumulated into
large bone beds, such as the famous quarries at Dinosaur National Monument and the Cleveland-Lloyd Quarry, as well as numerous other
lesser-known quarries.
Guidelines for Assessment and Mitigation of Potential Impacts to Paleontological Resources (BLM Instructional Memorandum 2009-
011). This document establishes procedures to follow at all stages of project development in order to assess and mitigate potential impacts to
paleontological resources, and is based around best practices for each of the PFYC levels as defined in BLM IM2016-124 (2016), discussed
above. BLM policy for projects on PFYC Class 5 (very high) geologic units, such as the Morrison Formation, indicates that for projects that
may disturb paleontological resources a number of steps must be taken to minimize those impacts. These include field surveys prior to project
commencement, avoidance through changes to project location or scope, mitigation through monitoring, etc. (BLM, 2009).
In particular relevance to the NHMLA quarry on Parcel 408, this document states that: “In the case where it is known that significant
paleontological resources will be adversely impacted, the preferred course of action is avoidance of the impact by moving or rerouting the site
of construction, or eliminating or reducing the need for surface disturbance.” [BLM, 2009:1- 4] Monticello Field Office Approved Resource
Management Plan (RMP). The Monticello RMP (2015) addresses paleontological resources through the identification of ten Plan Decisions
(PAL-1 – PAL-10). Of particular relevance to the September 2019 sale is PAL-10:
PAL-10. Conduct on-site evaluation of surface-disturbing activities for all Class 5 areas and minimize impacts to paleontological
resources to the degree practicable. Evaluation will consider the type of surface disturbance proposed and mitigation will be developed [18 and 19] The 2008 RMP/FEIS did assign the Brushy Basin Member of the Morrison Formation as PFYC
based on site-specific information (BLM, 2015). Class 5 (Refer to page 4-293, Table 4.100 in the RMP) The Westwater Canyon, Salt Wash and Recapture
Members of the Morrison Formation are classified as PFYC Class 4/5.
[18] Therefore, all proposed projects that may impact the Morrison Formation, as PFYC Class 5, should be the subject of a paleontological
evaluation to assess the impacts of the proect and develop mitigation measures for those impacts.
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[19] Impacts to Paleontological Resources. Oil and gas exploration and resource development may impose a variety of impacts to
paleontological resources, both at the NHMLA quarry on Parcel 408 as well as to any area where PFYC Class 5 geologic units would be
impacted. Impacts to the NHMLA Quarry on Parcel 5. A variety of impacts from oil and gas development could occur at the active quarry.
Drilling or other ground disturbance at the quarry would both destroy the paleontological resources known to occur there, as well as impede the
NHMLA crew from their scientific, educational, and outreach work. Furthermore, the development of roads or other infrastructure to the area
also has the risk of damaging the quarry or disrupting NHMLA access to the site. Increased traffic by oil and gas personnel in the vicinity of the
quarry increases the risk of fossil theft. The NHMLA is careful to bury the quarry at the end of each season, but during the winter it is largely
unmonitored; the more people who are aware of the exact location, the higher the risk of vandalism or theft.
[20] Impacts to Paleontological Resources within the Morrison Formation. As discussed above, the Morrison Formation is PFYC Class 5 [20 and 21] The 2008 RMP/FEIS analyzed the impacts of development on paleontological resources (Refer to
(very high) in regards to the potential to encounter paleontological resources. This means that any surficial or ground disturbing activities that 4-295 to 4-317). Surface-disturbing actions such as road construction could damage or destroy surface fossils
occur in rocks mapped as the Morrison Formation are at high risk for encountering fossils. Activities such as grading, drilling, and trenching or in paleontologically sensitive areas/geologic units (Class 3, 4/5, and 5). In these areas, paleontological resource
other excavations are at high risk of damaging or destroying fossil resources. impacts mitigation would reduce potential direct, adverse impacts to below the level of significance. Surface
fossils would he collected by a qualified and BLM-permitted paleontologist prior to surface disturbance, and
[21] Recommendations: As currently drafted, the Environmental Assessment (EA) for the September 2019 Competitive Oil and Gas Lease paleontological monitoring of construction-related excavations would allow the salvage and recovery of
Sale (DOI-BLM-UT-000-2019-0003-OTHER_NEPA_MtFO-EA) fails to provide adequate protections for both known and potential important sub-surface paleontological resources. Stipulations UT-S-176 and UT-S-177 were derived from the
paleontological resources within the parcels offered. The NHMLA recommends the following additions to the EA in order to adequately protect 2008 Price Field Office RMP, and cannot be applied to parcels in Monticello Field Office. Lease Notice UT-
paleontological resources, as provided for by the PRPA and NEPA, and in accordance with existing BLM guidelines (2009, 2016). LN-72 has been applied to all parcels. BLM regulations at 43 CFR 3101.1-2 allow for the relocation of
A. Removal of the NHMLA Quarry in Parcel 408. proposed oil and gas leasing operations up to 200 meters and/or timing limitations up to 60 days to provide
additional protection to ensure that proposed operations minimize adverse impacts to resources, uses, and
Because the active quarry in Parcel 408 constitutes a known paleontological resource, in conjunction with the guidelines provided by the users. Lease Notices, Stipulations, standard operating procedures, and best management practices would be
BLM (2009: 1-4), the NHMLA recommends that the parcel be redrawn, with the quarry site and a buffer zone of at least 100 meters incorporated as conditions of approval (COA). The COA’s would be attached to permits for oil and gas lease
withdrawn from leasing. Alternatively, the entire Parcel 408 could be withdrawn from leasing, should the BLM determine this to be most operations to address site-specific concerns or new information. Lease Notice UT-LN-72, 43 CFR 3101.1-2,
and Paleontological Resources Preservation Act will protect the paleontological resources. See response 2a and
effective.
section 2.5.3...
B. Stipulations
Due to the high sensitivity of the Morrison Formation as PFYC Class 5, the NHMLA recommends that all parcels currently listed in the
September 2019 competitive lease sale which contain outcrops of the Morrison Formation have two stipulations attached to them (see
below). While the current EA does list Notice UT-LN-721 for these parcels, the stipulations suggested below are far more rigorous, as is
necessary for avoiding impacts to paleontological resources in areas assessed as having PFYC Class 5, particularly in the inability for the
waiver of the requirements.
1. UT-S-176 CONTROLLED SURFACE USE – FOSSIL RESOURCES
(PRECONSTRUCTION SURVEYS). Preconstruction paleontological surveys will be required prior to any surface disturbing
activity in the Morrison, Cedar Mountain, Blackhawk, North Horn, or Chinle Formations. Exception: The authorized officer may
grant an exception if the area has previously been inventoried within the last three (3) years. Modification: None Waiver: None
2. UT-S-177 CONTROLLED SURFACE USE – FOSSIL RESOURCES. A BLM permitted paleontologist will be required
to be onsite during disturbance in any Potential Fossil Yield Classification (PFYC) 4 or 5 areas. Exceptions: None Modification:
None Waiver: None
[22] Summary information. Additional response is not warranted.
[22] Conclusions. In conclusion, the NHMLA respectfully recommends that in order to comply with the PRPA and NEPA, the active quarry
site in Parcel 408 be withdrawn from leasing, through either redrawing the parcel boundaries or removing the entire parcel, and that two
stipulations to mandate the survey and monitoring of projects occurring in PFYC Class 5 geologic units. These measures meet BLM guidelines
for paleontological resources while still enabling shared land use between the paleontological community and the oil and gas industry.
5.) Mary Moran [23] I am concerned about the proposed additional oil and gas leasing near Hovenweep National Monument. I am familiar with the area,
[23]. See section 1.3 and the response to Comments 2 and 5. The Mineral Leasing Act of 1920 (MLA), as
especially the monument itself. I know that near the Square Tower (main) unit of Hovenweep there is a "land farm" of leftover fracking
amended [30 U.S.C. 181 et seq.], and the Federal Onshore Oil and Gas Leasing Reform Act of 1987
sludge upslope topographically and geologically from small springs critical to the canyon ecosystem within the monument. These springs
(FOOGLRA), require the BLM to conduct quarterly, competitive lease sales to offer available oil and gas lease
were the reason for the Ancestral Puebloan decision to settle there, leaving the structures that the monument is known for. I know that,
parcels in Utah if nominated parcels are received from the public. The public nominated the parcels as
decades ago, an oil spill drained on the ground surface into the Cajon Unit of Hovenweep. I know that I, and many others, value the quiet
Expressions of Interest (EOI). The BLM did not nominate parcels for the September 2019 Lease sale. From
and night sky darkness of the monument. Indeed, the monument procured a telescope and the small staff hold night-sky viewing events these EOIs, the BLM prepares the parcels and determines whether or not the existing analyses in the LUPs, as
for visitors to experience the unusually dark night skies. I love hearing the owl calls at night, from the unusualy high number of owl amended, provide basis for leasing oil and gas resources within these parcels or if additional NEPA analysis is
species that nest in the monument's canyons. I also know that the BLM is legally obligated to examine cumulative impacts. I don't believe
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they've done that. There have already been two BLM oil and gas leases in the area in the last 16 months. It's time to pause and examine needed before making a leasing decision.
cumulative impacts.
6.)Grand [24] I am writing on behalf of the Grand Canyon Trust (“Trust”) to urge the Bureau of Land Management to reconsider its proposal [24] Summary information. Response is not warranted.
Canyon Trust to include in its September 2019 oil and gas lease sale 19 parcels near Hovenweep and Canyons of the Ancients national monuments.
We believe the environmental assessment analyzing this proposal is deficient under the National Environmental Policy Act for three
reasons. First, the EA inadequately considered, or wholly failed to consider, the impacts that the lease will have on lands with
wilderness characteristics, water, climate change, fish and wildlife, and cultural resources. Second, BLM improperly deferred
elements of its analysis to the drilling stage of the leasing process. Third, leasing the proposed parcels will potentially have a
significant impact on the environment, triggering BLM’s obligation to prepare an environmental impact statement.
[25] The BLM is working through the NHPA process. This is not a valid comment for the EA, as it primarily
[25] In addition, BLM did not meet its consultation obligations under the National Historic Preservation Act because BLM did not applies to the NHPA process, not the NEPA process. The NHPA process is on-going.
reinitiate consultation for the September lease sale and did not make meaningful efforts to consult with Tribal Historic Preservation
Officers.
[26] BACKGROUND: The Grand Canyon Trust is a 501(c) (3) regional non-profit conservation organization whose mission is to [26] Background information. Response is not warranted
safeguard the wonders of the Grand Canyon and the Colorado Plateau, while supporting the rights of its Native peoples. We envision a
Colorado Plateau where wildness, a diversity of native plants and animals, clean air, and flowing rivers abound; where sovereign Tribal
nations thrive; where a livable climate endures; and where people passionately work to protect the region they love for future generations.
The 19 parcels on which we are commenting are located in one of the most significant cultural landscapes in the United States. Located
between Mesa Verde National Park, Canyons of the Ancients, Hovenweep, and Bears Ears national monuments, the parcels offered
represent areas containing high densities of cultural sites holding among the best preserved human history found anywhere in America.
Largely free from human habitation today, the area once teemed with human life, and the traces left by the ancestors of regional Native
American tribes still offer so much to learn about our shared history. Cultural connections exist here between the internationally-
recognized wonders of Bears Ears, Mesa Verde, and Chaco Canyon. Here, rock art and human-placed natural materials function as
calendars, ancient trade routes connect seemingly disparate individual sites, and regional styles merge and blend together creating unique
and irreplaceable sites. Still largely undocumented by western science, the area affected by this and recent lease sales has far more public
value in the preservation of its irreplaceable cultural resources than in whatever marginal oil and gas resource may be extracted here.
Should this sale proceed, and should these and other recent leases be fully developed for oil and gas, future generations will condemn the
short-sighted and irreversible decisions made now. The area is best suited to permanent and stringent protections for its exceptional
cultural sites, not one- time development of non-renewable fossil fuels.
COMMENTS
[27] BLM’s analysis of the proposed lease sale does not comply with NEPA. To take the “hard look” mandated by NEPA, BLM is required [27] See the response to Comment 2.
to analyze a proposed action’s ecological, aesthetic, historic, cultural, economic, social, and health impacts. 40 C.F.R. § 1508.8. These impacts
must be analyzed “whether direct, indirect, or cumulative.” Id. Put differently, BLM must consider the direct, indirect, and cumulative impacts
of a proposed action, as well as of past, present, and reasonably foreseeable future actions prior to making any irreversible and irretrievable
commitment of resources. Issuing an oil and gas lease without a no-surface-occupancy (NSO) stipulation constitutes an irretrievable
commitment of an agency’s resources. See S. Utah Wilderness Alliance, 159 IBLA 220, 241 (2003) (explaining that courts have reasoned that a
“‘non-NSO’ lease ‘does not reserve to the government the absolute right to prevent all surface disturbing activities’ and thus its issuance
constitutes ‘an irretrievable commitment of resources’ under section 102 of NEPA” (quoting Friends of Southeast’s Future Morrison, 153 F.3d
1059, 1063 (9th Cir. 1998))). For these parcels, BLM has not reserved the absolute right to prevent all surface disturbing activities. In this
instance, BLM failed to adequately analyze the impacts of the proposed lease on lands with wilderness characteristics, water, climate change,
fish and wildlife, and cultural resources. Each is addressed below.
[28] BLM inadequately analyzed how the proposed lease will impact lands with wilderness characteristics. In the September 2019
EA, BLM failed to analyze in detail the impacts that the proposed lease may have on two wilderness-characteristic “units”: the Tin Cup [28] See the response to Comment 2
Mesa and Monument Canyon units. To defend that decision, BLM asserted that the effects of leasing on lands with wilderness
characteristics were already analyzed in the Monticello Field Office Resource Management Plan (“Monticello RMP”) and an EA for the
March 2018 competitive oil and gas lease sale. The Monticello RMP only analyzes impacts on wilderness-characteristic lands generally,
not at the site-specific level required for leasing. The March 2018 EA is insufficient because it only analyzed impacts to a portion of the
lands with wilderness characteristics that are available for leasing under the September 2019 EA.BLM states that the land with wilderness
characteristics found within the Tin Cup Mesa and Monument Canyon units are not entitled to protection because they were identified after
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the Monticello RMP was adopted and are therefore not subject to the RMP’s protections. Even if the units are not subject to the RMP’s
protections that does not excuse BLM from analyzing the impacts of the proposed leases on the Tin Cup Mesa and Monument Canyon
units. If anything, the post-RMP designation of these units only highlights the importance of analyzing leasing impacts on these units now
since BLM completed no such analysis for the RMP. Moreover, both of these units are proposed for wilderness designation in the
America’s Red Rock Wilderness Act. Unlike the RMP, the March 2018 EA analyzed how leasing would affect wilderness- characteristic
lands in the Tin Cup Mesa and Monument Canyon units, but that analysis is insufficient for the lease parcels proposed under the September
2019 EA. The Tin Cup Mesa unit has 9,743 acres of wilderness-characteristic lands and the Monument Canyon unit has 17,200 acres. The
March 2018 EA only analyzed the impacts of leasing on the units assuming that, cumulatively, 32% of the Monument Canyon Unit (5,504
acres) and 29% of the Tin Cup Mesa Unit (2,825 acres) would be leased. Yet if the proposed September 2019 parcels are leased, 80% of the
Monument Canyon Unit and 100% of the Tin Cup Unit will be leased.1 As a result, the acreage leased in the Monument Canyon Unit will
increase from 5,504 acres analyzed under the March 2018 EA to 13,760 acres under the September 2019 EA (an increase of 8,256 acres).
For the Tin Cup Mesa Unit, the acreage leased will increase from the 2,825 acres under the March 2018 EA to 9,743 acres under the
September 2019 EA (an increase of 6,918 acres). The upshot is that BLM is proposing to lease 15,174 more acres of wilderness-
characteristic lands in the September 2019 sale as compared to the March 2018 sale without any analysis of the effect on those lands.
Tiering to the March 2018 EA in this manner breaches NEPA’s hard-look requirements. One of the reasons that BLM decided in March
2018 to issue leases in these wilderness-characteristic units was that the units would retain significant areas with wilderness characteristics
even at the then-proposed full level of development. But that reasoning does not apply to the proposed September 2019 sale, because the
sale could cause both units to wholly lose their wilderness characteristics. This flaw renders BLM’s analysis of wilderness-characteristic
lands inadequate under NEPA. See 40 C.F.R. § 1502.1 (noting that NEPA analysis must provide a full and fair disclosure of impacts); 40
C.F.R. § 1502.20 (clarifying that teiring is appropriate when the tiered document has a broader analysis of the impacts).
[29] BLM inadequately analyzed the direct and indirect impacts, and failed to analyze the cumulative impacts, of the lease sale on [29a]The parcels up for lease in the September 2019 Lease Sale, from the Monticello Field Office, are the
cultural resources. exact same parcels that were analyzed in the March 2019 Lease Sale Cultural Resources Report (March 2019
[29a]The September 2019 EA does not evaluate the impacts that the lease sale may have on cultural resources present in the parcels. Instead, LSCRR), and then deferred from the March 2019 Lease Sale for air quality concerns. Because the nature of the
the September 2019 EA tiers to the March 2018 EA and a cultural resource report prepared for the March 2019 competitive oil and gas lease action has not changed, UT BLM has determined, an additional Section 106 review of the parcels in
Monticello is not warranted. Furthermore, the assertion “…the March 2019 Cultural Resource Report (sic)
sale. The March 2018 EA’s cultural resource analysis is inapplicable to the September 2019 EA because the parcels offered for sale at that
indicates that, due to the chronic lack of surveying across the parcels, BLM should have done a much more
time are different than the upcoming September parcels. And the March 2019 Cultural Resource Report indicates that, due to the chronic lack
thorough inventory of cultural resources.”, is the opinion of Grand Canyon Trust, and not a statement made by
of surveying across the parcels, BLM should have done a much more thorough inventory of cultural resources. BLM’s decision to tier to the the March 2019 LSCRR
March 2018 EA’s analysis of impacts to cultural resources cannot be justified because the March 2018 EA analyzed entirely different lease The lease sale EA does not tier to the March 2018 lease sale EA. It incorporates the analysis by reference.
parcels than the September 2019 EA. None of the parcels are the same in the EAs. As a result, none of the analysis in the March 2018 EA is BLM resource specialists determined that the impacts disclosed to cultural resources in the March 2018 Lease
relevant. Sale EA would be essentially the same for the parcels considered for the September 2019 lease sale.
[29b]The cultural resource report from March 2019 does not suffer from this flaw, but it too is deficient, because it reveals that far too little is
known about the cultural resources present in the parcels to satisfy BLM’s hard-look obligations under NEPA. The report analyzed the 19
parcels proposed for leasing in September 2019. It recognized that the lease sale is in an area with many potentially sensitive sites and notes [29b] See the response to Comment 25
that the coverage of previous cultural resource inventories varies widely across the parcels, ranging from 4% to 34% for the 19 Monticello
Field Office parcels. In fact, the 19 parcels set to be leased have an average survey coverage of 14%, and only one parcel has surveys covering
more than one third of the parcel. The means the vast majority of the area of potential effects, defined as the entire lease parcel area plus a half
mile buffer in each direction, is currently unsurveyed for cultural resources. According to BLM Manual 8110 – Identifying and Evaluating
Cultural Resources, a Class III intensive survey is generally required in previously unsurveyed areas of potential effect when the proposed
action would disturb the land surface, affect the integrity of historic properties, or alter the use of cultural resources. Oil and gas leasing and
development will do all of the above. Because exploration and drilling rights are acquired by the lessee at the leasing stage, it is inevitable that
the lease sale will result in significant surface disturbance where exploration has predicted production. And, due to the significantly high
cultural resource density of the area combined with inadequate knowledge of what sites may exist in the unexplored portions of the area,
cultural resource and historic properties are bound to be adversely, and perhaps irreparably, affected. This point is explained in more detail
below. For these reasons, BLM should have conducted intensive, Class III surveys in accordance with its internal manual. Instead of
completing intensive surveys, BLM conducted a Class I literature review of currently known sites within the lease parcels. Yet because only a
small fraction of the parcels have been surveyed, currently known sites are only a small fraction of those that exist within the lease parcels and
the area of potential effects. In fact, the limited surveys conducted in the parcels and area of potential effects uncovered over 1,600 sites, a
significant number of which are eligible to be listed on the National Register of Historic Places. By extrapolation, there are likely thousands
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of unknown cultural resources and sites within the lease parcels and the APE. Those sites could be discovered, and adequate protections
instituted, if BLM undertook intensive, on- the-ground surveys in the unsurveyed areas of the parcels and area of potential effects.
Furthermore, the March 2019 report does not disclose the impacts that the lease sale, when combined with other past, present, and reasonably
foreseeable actions, will have on cultural resources. The report reaches broad conclusions without offering support for how its determinations
were reached or what analysis was done. For all parcels, the report concludes that, based on observed site density and protections afforded by
lease stipulations, development can occur within the lease parcels without causing adverse effects. But the report provides no insight into how
BLM made that determination. And indeed, it is impossible to defensibly reach that conclusion without having completed additional surveys
of the lease parcels. Because of these flaws, the September 2019 EA inadequately analyzed the direct and indirect impacts to cultural
resources and it also failed to analyze cumulative impacts. Therefore, BLM has violated NEPA, and its determination that there will be no
adverse effects to cultural resources is arbitrary and capricious.
[30] See the response to Comment 2, and Appendix D. Appendix D was updated to attach UT-S-128 on
[30] BLM failed to consider the direct, indirect, and cumulative impacts that the proposed lease and subsequent parcels 413 and 420. There should be no impact to groundwater from abandoned wells. If these parcels are
development would have on water sources. BLM failed to analyze the direct, indirect, and cumulative impacts that the proposed acquired and an APD is submitted, the well is subject to the casing, cementing and plugging requirements of
lease may have on water sources. BLM’s reason for not considering impacts to water sources was that those sources are already Onshore Oil and Gas Order No.2. (O.O.#2) All APDs are subject to review by a BLM petroleum engineer,
protected by law and lease stipulations that operators must obey. This rationale is flawed for two reasons. First, BLM cannot avoid geologist, and hydrologist. Compliance with O.O. #2 will ensure protection of useable ground water aquifers
analyzing the impacts of its actions due to the protections afforded by other laws. NEPA demands that the impacts of a proposed from drilling, completion and production operations. The RFDs do not assumes that all wells drilled on the
action be analyzed even if there are other laws that may protect the resources in question. In other words, a statute that protects nominated parcels will produce sufficient to prevent abandonment. Instead, the RFDs are a planning tool to
water does not obviate NEPA’s requirement to analyze water impacts. Second, lease stipulations are not guaranteed to fully provide a reasonable estimate of what oil and gas exploration and development activities might be proposed,
insulate a lease from adverse impacts. For the September lease parcels, there is only one proposed lease stipulation that purports to should a decision be made to lease the area and the surface development of a well (regardless if it is a dry
protect water sources, and it leaves those sources vulnerable to degradation. That stipulation, UT-S-128, is attached to all the lease hole). The MtFO has classified lands within the district boundary. The parcels are located in San Juan County,
and are classified as high potential for occurrence of oil and gas but with a lower level of certainty of
parcels except for 413 and 420. It prohibits surface-disturbing activities within active floodplains, public water reserves, or 100
production. It is estimated that 59 percent of the wells drilled in MtFO will be capable of production and 41
meters of riparian areas along perennial streams and springs. But it allows for exceptions when: (a) there are no practical
percent is estimated to be a dry hole.
alternatives, (b) impacts could be fully mitigated, or (c) the action is designed to enhance the riparian resource values. These
exceptions leave water sources susceptible to negative impacts from the leases and their future development. The proposed lease
sale will impact water resources despite these stipulations and legal protections, and NEPA requires BLM to analyze those impacts.
For example, BLM did not analyze how much water it would take to drill wells on the lease parcels and other nearby areas that
have been or may be leased for oil and gas development. Oil and gas operations require significant amounts of water to stimulate
production from formations. They also bring to the surface billions of gallons of water that naturally exists in subsurface
formations. This “produced water” is typically the largest by-product of oil and gas operations, and is often managed as an
unreclaimable waste. To properly analyze the effect of these uses of water, BLM must make a reasonable forecast of how much
water will be used and produced on the lease parcels. If the agency is unable to make that quantitative forecast, it is obligated to
explain why the impacts cannot be quantified and discuss the impacts qualitatively. BLM has done neither here BLM likewise
should have analyzed the impacts that abandoned wells may have on groundwater sources. The September 2019 EA assumes that
all the wells that will be drilled on the nominated parcels will produce sufficiently to prevent abandonment. But it is inevitable that
some wells will not produce and will be abandoned. Additionally, many wells that are productive in the beginning, will eventually
cease production and be abandoned. According to the Reasonably Foreseeable Development Scenario, there have been 3,267 wells
drilled in the Monticello planning area, 2,132 of which have been abandoned. This amounts to over 65% of all wells being plugged
and abandoned. Moreover, within the specific lease parcels at issue and the area of potential effects, there are 126 abandoned wells.
And it is established that abandoned wells sometimes cause significant contamination of groundwater, even when they are properly
plugged. Yet the September 2019 EA addresses abandoned wells only by describing why wells are abandoned and the process for
plugging them. Because BLM has not properly analyzed the direct, indirect, and cumulative impacts of the proposed leases on
water sources, its conclusion that the leases will not “significantly affect the quality of the human environment” is unsound.
[31] BLM inadequately analyzed the direct, indirect, and cumulative impacts on climate change as a result of greenhouse gas [31] See Response to Comment 4 [a-f] and Comment 61
emissions generated from the lease sale and subsequent development. BLM’s analysis of the impacts that greenhouse gas
emissions will have on climate change is inadequate. Although the September 2019 EA quantified the greenhouse gas emissions
expected to occur from the proposed lease sale, development of the leases, and future use of the oil and gas obtained, the EA made no
attempt to analyze the impacts that these emissions will have on climate change.
As part of its required NEPA analysis, BLM must analyze what impact expected greenhouse gas emissions will have on the
environment. A component of this analysis is what impact such emissions will have on climate change and its effects. A major area of
concern that BLM failed to analyze is how the greenhouse gas emissions will contribute to the warming effect of climate change,
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commonly referred to as global warming. For much of its greenhouse gas emissions analysis, the EA incorporates by reference and
defers to a report analyzing greenhouse gas emissions from BLM’s oil and gas leasing in Utah. This report, like the EA, does not
attempt to analyze the impacts caused by greenhouse gas emissions, but it does provide some insight into the data sources and
methods used to analyze such impacts. One of those methods is to apply the global warming potential of the greenhouse gases
expected to be emitted and predict the temperature increase that may result due to the emissions. These global warming potentials
have been developed for several greenhouse gases and can be applied over different time spans (i.e. 20 years, 100 years, etc.). BLM
has all of the information necessary to apply global warming potentials to each greenhouse gas it expects to be emitted in the quantity
that is expected. Despite this, BLM did not apply global warming potentials and did not analyze what impacts the lease sale and
subsequent development would have on global and regional warming beyond noting that average annual temperatures on the Colorado
Plateau are expected to increase in the future. If the global warming potentials were applied to the greenhouse gas emissions set forth
in the EA, BLM would be able to better inform the public of the significance of future temperature increases, time spans within which
predicted temperature increases will occur, and the more specific, regional effects of the temperature increases on other resources such
as water evaporation and decreased precipitation. Because BLM only quantified greenhouse gas emissions and failed to take the next
essential step of analyzing whether the emissions would have a significant impact on the environment as required by NEPA, the EA’s
decision that greenhouse gas emission will not have a significant impact is arbitrary and capricious.
[32] BLM failed to analyze the direct, indirect, and cumulative impacts that proposed lease would have on fish and wildlife. [32] See the responses to Comments 2 and 29
The September 2019 EA does not analyze the lease’s impacts to fish and wildlife. Instead, the EA determines that, although fish and
wildlife are present in the area of potential effects, they are not affected to a degree that detailed analysis is required. Part of BLM’s
rationale for this determination is that impacts to fish and wildlife were fully analyzed in the Monticello RMP and the March 2018 EA.
Yet, tiering to these documents again falls short of NEPA’s requirements. As stated above, the Monticello RMP is a broad guidance
document that was not intended to, and does not, analyze the site-specific effects of project-level actions. Instead, it is intended that
there be site-specific analysis undertaken before implementing any decisions or actions allowed by the RMP. The time to perform site-
specific analysis is at the leasing stage. The analysis in the March 2018 EA is likewise inadequate for two reasons. First, the current
analysis considers completely different parcels. Second, it has no analysis of leasing’s impacts on wildlife other than discussing
impacts to migratory birds and raptors. There are a host of other wildlife species that may be impacted beyond migratory birds and
raptors. These include bighorn sheep, pronghorn, deer, elk, and others. Additionally, part of the analysis must include impacts to
lambing and rutting areas, fawning areas, habitats, migration corridors, and the like. Neither the March 2018 EA nor the September
2019 EA discussed or analyzed these issues. As a result, it was improper for BLM to tier to the analysis in the March 2018 EA. BLM
must conduct a separate analysis specific to the September sale. In order to comply with NEPA’s mandates, the EA must discuss and
analyze how the lease could impact wildlife and their habitats. Because the EA does not do so, BLM has not complied with NEPA.
[33a] BLM improperly deferred analysis from the leasing stage to the drilling stage. BLM chose not to consider some impacts of leasing in [33a]See the response to Comment 2. Cultural resources, known or unknown, are not at risk because lease
the September EA on the grounds that these impacts can be adequately analyzed, and avoided or mitigated, at the Application to Drill (“APD”) rights are subordinate to non-discretionary statue.
stage. But by deferring its analysis, BLM is narrowing the range of protective measures at its disposal. Once a non-NSO lease is issued, a lessee
acquires a right to disturb the surface of that lease parcel. Therefore, adequate analysis needs to be completed before the leasing decision. After
the parcel is leased, the lessee has acquired exploration and drilling rights that make protecting resources more difficult, if not impossible, for
BLM. The September 2019 EA consistently defers analysis to the Application to Drill (“APD”) stage, including with cultural resources. This
contravenes the management decisions in the Monticello RMP. The RMP obligates BLM to conduct proactive cultural resource inventories.
Yet instead of being proactive, BLM has, for the September lease sale, deferred doing any Class III cultural resource surveys until the APD
stage, citing uncertainties of development at the leasing stage. These uncertainties, however, do not release BLM from its duties to analyze the
impacts of the lease sale. And analyzing such impacts is impossible to do if BLM is not aware of what may be impacted. Given the current
survey coverage of the parcels proposed for lease, BLM cannot comprehend what types of cultural resources are at risk and what the potential
impacts are.
[33b]. Between the internationally-recognized cultural landscapes of Bears Ears and Canyons of the Ancients, the proposed lease sale would [33b] There is no proposal at this stage to allow full scale oil and gas development. Should such development
allow for oil- and- gas development in one of the most culturally rich and distinctive areas in the world. Site densities in the region are among be proposed, it will be evaluated and constrained to comply with discretionary statutes. On-the-ground impacts
the highest in the United States, and the resources here are little documented, poorly researched, and not well understood. The value of these would potentially occur when a lessee applies for and receives approval to explore, occupy and/or drill on
sites, as well as how they function together with landscape features and with regional transportation and trade routes exceeds the marginal lease
prospect of oil and gas development here. The question of whether to allow that full scale oil and gas development cannot be answered without
fully analyzing the irreplaceable cultural heritage at stake. Deferring that such analysis to the APD stage, after leases have been let and lease
holders have rights to damage such sites is thus indefensible.
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[34] BLM should have prepared an EIS. The September lease sale has the potential to significantly affect the human environment, especially [34] In accordance with BLM Manual Part 516, Chapter 11, the action currently before BLM is not one that
when taken collectively with past, present, and future lease sales. NEPA requires federal agencies to prepare an environmental impact statement normally requires the preparation of an EIS (approval of an RMP, WSR/NS&HT, coal lease sale, energy
(“EIS”) when they take “major federal actions” that may significantly affect the quality of the human environment. 42 U.S.C. § 4332(2) (c). facilities, major ROWs, radioactive operations, or mining operations). New circumstances do not automatically
The current lease sale, when combined with the March 2018 and December 2018 lease sales, will result in over 60 leases covering hundreds of require the revision or amendment to a land use plan nor the preparation of an EIS, regardless of the age of the
thousands of acres being issued in the culturally rich Four Corners region. The significant harm to the environment is mounting as BLM planning decisions. If warranted, an environmental assessment is prepared to analyze the impacts of new
incrementally leases away virtually the entire area between Canyons of the Ancients National Monument, Hovenweep National Monument, and circumstances. Section 1.2 outlines BLM’s steps it would take if a FONSI cannot be reached. As outlined in
Bears Ears National Monument. Among the factors to be considered when determining whether an EIS is necessary, several are applicable to Utah BLM’s NEPA Guidebook, “the CEQ Guidelines [40 CFR 1501.4 (e)] require that an agency make
the leases at issue, including “[u]nique characteristics of the geographic area such as proximity to historic or cultural resources, park lands,” available a FONSI to the public for review in certain limited circumstances. Therefore, an unsigned FONSI
“[t]he degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the should be released with an EA when the EA is made available for public comment. The unsigned FONSI is
National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources” and the typically a simple statement accompanying the EA. It allows the public to comment on the significance of the
controversial nature of the leases due to their location and uncertainty of effects. BLM must prepare an EIS for this lease sale because the impacts analyzed in the EA.” A detailed FONSI (covering context and intensity) has been prepared and
parcels considered have a high density of cultural sites; the parcels are located in close proximity to Nation Register-listed and eligible sites and released with the revised EA at the protest period associated with the NCLS. There are a variety of
national monuments; recent and future lease sales may cause loss or destruction of significant scientific, cultural, or historical resources; and the stipulations, notices, and mitigation measures that are included in the impact analysis, which ensure that
sales are controversial. Put differently, leasing these parcels will result in a significant effect on the environment. For these reasons, BLM must significant impacts will not occur from the proposed action.
prepare an EIS for the September lease sale.
[35] BLM’s consultation efforts fell short of NHPA’s requirements. BLM chose not to reinitiate Section 106 consultation under the National [35] See the response to Comment 25
Historic Preservation Act (“NHPA”) for the September 2019 lease sale. Instead, BLM relied on its consultation efforts for the March 2019 sale
and states that consultation may continue (i.e. be reinitiated) at the request of any tribe. BLM should have reinitiated a new consultation period
because new, relevant information had been acquired since the March 2019 sale consultation and Tribal Historic Preservation Officers were not
consulted during the March 2019 sale. BLM has acquired more relevant information on the lease parcels than it had during the March 2019
consultation. The parcels proposed for lease in the September sale were all deferred from the March 2019 sale. For that reason, BLM did not
restart consultation, but instead relied on its efforts to consult on the March sale. This does not meet the NHPA’s requirements. The lease
parcels in the March 2019 lease sale were deferred because additional environmental analysis was needed. Tribes, just like the general public,
would benefit in their feedback during consultation from the updated environmental analysis that BLM completed for the September sale.
Furthermore, because consultation was not reinitiated, tribes have not received the final March 2019 Cultural Resource Report. According to
the consultation schedule in the September 2019 EA, consultation efforts ended on February 25, 2019. On that day, BLM provided the Pueblo
of Pojoaque with a copy of the draft cultural resource report. The final cultural resource report was not published until March 27, 2019 and, to
our knowledge, tribes have not been provided the final report. Similarly, the tribal consultation efforts were conducted before two key
documents were created. The first is a protest letter submitted by Friends of Cedar Mesa and the National Trust for Historic Preservation on
February 28, 2019, and the second is an April 26, 2019 review by the Advisory Council on Historic Preservation of BLM’s no-adverse-effect
finding. The February letter informed BLM of a significant number of cultural sites and resources within the lease parcels. Because many of the
sites were previously unknown by BLM, tribal consultation should have been reinitiated for those sites. The Advisory Council’s review did not
agree with BLM’s finding of no adverse effect. Instead, it urged BLM to undertake more effort to identify sites and consider impacts before
leasing, and it recommended that BLM “[c]ontinue to invite and engage in Section 106 consultation on lease parcels deferred to future sales.”
Instead of heeding the Advisory Council’s recommendations and advice, BLM has undertaken no further consultation efforts since February
2019. As a result, tribal consultation has been legally inadequate. To satisfy the NHPA’s requirements, BLM must pursue informed tribal
consultation by providing tribes with all relevant documents and information. It is inappropriate for leasing to proceed when tribal consultation
was not fully informed. How can BLM possibly conclude that there will be no adverse effects to cultural sites and resources if the tribal
consultation efforts did not provide the tribes with all of the relevant information? Because the tribal consultation process is not complete,
BLM’s determination of no adverse effect is, for all practical purposes, a predetermined finding. Similarly, even though the lease parcels are
not within tribal reservations, BLM should have made meaningful efforts to consult with Tribal Historic Preservation Officers (“THPOs”). All
of the lease parcels have high potential areas for cultural site density and are on the ancestral lands of several tribes. Because of this, THPOs are
a knowledgeable resource for forecasting the kind of cultural sites that may exist in the area. There is no indication in the September 2019 EA
that attempts were made to contact and consult with THPOs outside of contacting tribes themselves. The ACHP advises federal agencies to
contact both the tribal governmental leaders and the THPO before formally initiating Section 106 consultation to determine the appropriate
points of contact. BLM did not do this, and for this reason too, its consultation under the NHPA was inadequate.
[36] Summary information. BLM response is not warranted
[36] BLM manages about 700 million acres of federal subsurface mineral rights across the country. Being the gatekeeper to that much
land and resources, it is imperative that BLM carefully scrutinize what lands should be available for mineral leasing and development
and which lands should not. This area between Bears Ears and Canyons of the Ancients national monuments should not be available
for any leasing or development. The area is one of our country’s most culturally significant and scientifically valuable landscapes, yet
it is also an area in dire need of protection. The ancestral places of southeast Utah, including the leasing area, was placed on the
national Trust for Historic Preservation’s 2019 “America’s 11 Most Endangered Historic Places” list. For these reasons, we request
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that BLM make the reasoned decision to cancel the leases proposed in this area. If BLM will not cancel the leases, we request that the
leases be postponed until all the shortcomings identified in these comments are remedied. Thank you for your consideration of these
comments and your attention to this important matter.
7.) Friends of [Due to the length, the BLM has summarized the comments. The document contains highly sensitive cultural site information. The redacted
Cedar Mesa document is published on the ePlanning website]
Parcels Commented On: 406, 407, 408, 409, 410, 411, 412,414, 415,416, 417, 418, 419, 420, 421, 422, 423, and 424
Comments [37] through [40] - These are comments on the NHPA process which has a separate
[37] Improper postponement of compliance with Section 106 of the NHPA
comment.period. The commenter made NHPA comments on these parcels when they were previously
[38] Disagreement with No Adverse Effect Determination considered to be offered for lease in the March 2019 Lease Sale. The responses to those comments can be
[39] Lack of Consideration of ACHP’s Comments found here. https://eplanning.blm.gov/epl-front-office/projects/nepa/117403/169522/206129/2019-03-
[40] National Historic Preservation Act Concerns That Apply To All Parcels…Arbitrary and Capricious Area of Potential Effects…Failure to 20_March2019_OG_FCM_comments_response.pdf
Make a Reasonable and Good Faith Identification Effort to Identify Historic Properties…Failure to Make National Register of Historic Places See the response to Comment 25
Eligibility Determinations…Arbitrary and Capricious No Adverse Effect Determination,,,Predetermination of Finding of No Adverse Effects See Response to Comment 9-14 for discussion of March 2019 ACHP Letter.
and Failure to Initiate Early and Meaningful Section 106 Consultation…NHPA Consultation Has Been Effectively Foreclosed for the March .
2019 Sale…Report Lacks Any Analysis of Cumulative Effects…Inappropriately Deferring Analysis Until APD Phase…Critique of Parcel-By-
Parcel Analysis [41] and [41a] See the Response to Comment 8.
[41] NEPA Concerns
[41a]Failure to Consider a Reasonable Range of Alternatives [41b] See the response to Comment 34.
[41b] NEPA Requires the Preparation of An EIS for All “Major Federal Actions Significantly Affecting the Quality of Human Environment”
[41c, 41d, 41e and 41f]These comments reference the DNA for the March 2019 Lease Sale and are out of
[41c] BLM’s FONSI and Its Decision to Forego Preparation of an EIS Before Approving the September 2019 Monticello Lease Sale Is
scope for comment on the EA.
Arbitrary
[41d] Failure to Take Hard Look
[41e] Relevance of DNA and Previous Analysis
[41f] BLM’s Reliance on a DNA Contradicts NHPA Analysis [41g] See the response to Comment 2. Cumulative effects were analyzed in the MtFO RMP FEIS (Chapter 4).
[41g] Failure to Analyze Increasing Cumulative Effects
[42] The BLM as a Federal agency authorizing this lease sale, continues to consult where appropriate with the
[42]ESA Concerns: Failure to Prepare Biological Assessment and to Initiate and Reinitiate ESA Consultation Over Impacts to Listed Species USFWS with regard to potential impacts to species listed, proposed to be listed or candidates for listing under
the Endangered Species Act. Prior to authorization of a lease, the BLM will ensure development of the lease is
not likely to harm a listed species.
[43] Lands With Wilderness Characteristics

[43]See the Response to Comment 8.
[44]Parcel-Specific Comment…Recapture/Mustang District parcels…Montezuma Canyon and Tributaries District… [44] Comment noted. This is not a valid comment for the EA. BLM response is not warranted.
[45] The BLM provided a 30-day public comment period and will provide a 30-day protest period. The BLM
[45] REQUEST FOR POSTPONEMENT UNTIL FULL EA IS COMPLETED In response to this shortened comment and protest period
did not shorten the public comment period. Refer to section 1.10.
and reissuance of the lease sale tiered to the March 2018 Canyon Country Oil and Gas Lease NEPA/NHPA analysis, we request that the BLM
postpone the March 25, 2019, sale until a full EA has been completed. REQUEST FOR DEFERRAL OF EIGHTEEN PARCELS IN
LEASE SALE We formally request that the March 2019 Monticello Oil and Gas Lease be postponed until a full EA and revised RMP have
been completed. Additionally, we request that parcels 406, 407, 408, 409, 410, 411, 412, 414, 415, 416, 417, 418, 419, 420, 421, 422, 423, and
424 be deferred from leasing until further survey of cultural resources on the ground has been completed and a practical plan can be put in place
to facilitate responsible development while protecting intact cultural landscapes and districts.
CONCLUSION
[46a]The site quantities and characteristics of the March 2019 sale are quite similar to the December 2015 deferred parcels and the March 2018
parcels. We believe it is arbitrary and capricious of the BLM to determine that parcels with similar site counts, similar site densities, and in [46a] This is out of scope of the EA.
some cases overlapping or adjacent boundaries with parcels deferred in the 2015 sale, can and should be offered again for lease when nothing
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has changed on the ground in the meantime. We do, however, know of more resources and have even better data (the MtFO’s recent predictive
model) that suggest high probabilities of sites in these areas that would support, not reject, reasons for deferral. We argue once again that the
Montezuma Canyon/Alkali Ridge region of the MtFO requires landscape-level planning and district analysis to balance multiple, conflicting
land uses.
FCM requests that the BLM:
1.BLM re-initiate Section 106 consultation for the March 2019 sale and initiate Section 106 consultation for the September 2019
sale to address the deficiencies raised in this letter and in the ACHP’s letter.
2.BLM develop a Programmatic Agreement to guide leasing in this cultural landscape; this approach is also recommended
by the ACHP. [46b]See the Response to Comment 8.
[46b]
3.BLM should revise the action alternative to include a stipulation that lessees complete a cultural resource survey of the
entire APE for the project, not just the project boundaries plus a buffer, before the Application for Permit to Drill is
approved.
4. FCM recommends that BLM consider a Cultural Resources Protection Alternative that would apply an NSO stipulation to
parcels with sensitive cultural resources. This may take the form of an NSO stipulation that is subject to waiver or
modification if the Section 106 process reveals that the proposed ground disturbance would have no adverse effect on
cultural resources in the entire APE.
8.) Business [47] On behalf of nineteen businesses in Bluff, Utah, the Business Owners of Bluff would like to thank the Bureau of Land [47]See the response to comments 5 and 62. The Business Owners of Bluff does not provide information or
Owners of Management (BLM) for the opportunity to comment on the September 2019 Oil and Gas Competitive Lease Sale in southeast reasoning as to why the notice UT-LN-125 applied to those parcels do not resolve its concerns (refer to section
Bluff Utah near Hovenweep National Monument. The Business Owners of Bluff (BOB) is an organization of hospitality, service-based, 1.9 in the EA). The NPS was consulted and they have not provided sky brightness measurements for
and nonprofit businesses that are heavily dependent on tourism and outdoor recreation. We are proud of our world-renowned Hovenweep National Monument. With the trend toward increased recreation within MtFO, user conflicts are
backyard of public lands and benefit directly from the careful management of their multiple uses. Our businesses rely and thrive likely to remain an issue between user groups (motorized, non-motorized, non-mechanized, river floating and
on high-quality visitor experiences, economic diversity, and protection of our pristine night skies. Just an hour's travel from Bluff, specialized recreation). The 2008 RMP/FEIS analyzed impacts on social economic conditions (section
Hovenweep National Monument is an International Dark Sky Park of the gold-tier and an economic driver for the Town of Bluff 4.3.12.2.6 in the FEIS, Appendix D in this EA). Comment Noted. Additional response is not warranted.
and San Juan County. In 2018, Hovenweep received 34,143 visitors and many of those visitors spent tourism dollars in Bluff
during their trip to enjoy the park. [figures about Bluff visitation numbers?] As a gateway community to both Hovenweep and
Bears Ears National Monuments, we are concerned about the alarming rate at which BLM lands near those monuments are being
leased for oil and gas development. The scale and rushed nature of the leasing leaves us questioning the impacts to our local
economy and the level of analysis undertaken by the BLM. Specifically, BOB is concerned that the draft Environmental Analysis
for the September Lease Sale elects to not analyze dark skies, despite concerns expressed by the National Park Service. Instead,
the BLM will rely on non-binding stipulations during future drilling to protect one of southeast Utah' s most valuable resource.
Dark skies are a tourism driver for Bluff and help extend the length of our visitor season, which leads to economic prosperity for
our businesses and Town. This latest lease sale could allow for leasing as close as 4 miles to Hovenweep, which would place oil
and gas operations directly in the park's viewshed. This could most certainly impact visitor experiences and the enjoyment of dark
skies, since industrial light pollution can be seen from up to 35 miles away and the sounds and smells of energy development can
be a nuisance. BOB opposes this lease sale and strongly encourages the BLM to reconsider leasing the nineteen parcels in the
Monticello Field Office until the agency can conduct a thorough analysis of its socio-economic impacts to dark sky tourism and
local economies. Additionally, sky brightness measurements have not been taken at Hovenweep National Monument since its
International Dark Sky Park designation in 2014 and we feel this missing data is critical to the analysis needed. We urge the BLM
to proceed with caution and care for the landscape and resources upon which our tourism-based economy depends.
9.) Teri Mader [48] I would like to comment on the proposal to sell oil and gas leases on BLM lands in southern Utah. As a resident of Grand County, [48] Comment Noted. Please refer Appendix D.
UT, I have very strong feelings regarding the possible destruction of the multitudes of cultural resources that are found in this area. I “ The majority of flow back water from hydraulic fracturing in Utah is recycled and used in future hydraulic
have spent many an hour on the trails, in the canyons, and contemplating our history - simply because I have chosen to live close to such fracturing completions. Therefore, the underground injection of hydraulic fracturing flow back in Utah is very
a rich cultural area. These are priceless sites that, once compromised, will never be the same. We seem to be doing our best to destroy limited and presents little potential for inducing seismic activity. In fact, there has been no reported induced
much of our heritage for the very dubious desire for more fuel drilling and destruction of the natural habitat. The short term effect of seismicity in Utah that was from water injected into Class II wells. Oil and gas wells produce a great amount
these leases CANNOT outweigh the long term destruction of the irreplaceable artifacts and natural beauty of the area. The piecemeal of wastewater. The majority this water has high salt brine content and must be disposed of in an
approach to these leases seems to be picking away bit by bit at the very things we should be more carefully protecting. The overall long environmentally safe manner. In Utah, a majority (95%) of this produced water is pumped into Class II
term impact must be considered before the damage is done and cannot be repaired. One final point: there are other consequences of injection wells. In certain parts of the country, water injection /waste water disposal has caused some induced
allowing these leases to proceed. Many of us choose to live near this area specifically because of the unmatched dark skies. There are seismicity in the form of small earthquakes. Two major factors play a role in induced seismicity from water
also always water consequences that develop due to the drill sites. The probability of fracking, which may lead to more and more
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earthquake activity is also a consideration. In summary, please do not allow these lease sales to proceed. There is too much at stake here. injection. First, the amount of water being injected. Secondly, the local geology of the water injection site. In
Utah, the volumes are lower than those states experiencing induced seismicity. Also, the geology is different
than those states experiencing induced seismicity. The injection zones are stratigraphically thousands of feet
above the basement rock that may contain large unknown faults. Therefore, at this time it appears that induced
seismicity from water injection is not a problem in the oil fields of Utah. (Personal communication from John
Rogers, Utah Division of Oil, Gas and Mining (UDOGM) to Angela Wadman, March 27, 2018 (BLM
2018)).”Additional response is not warranted.
10.)National [49] The National Trust for Historic Preservation appreciates the opportunity to submit comments on the Environmental Assessment for the [49] Scoping is one form of public involvement in the NEPA process. (H-1760-1, section 6.3). The BLM
Trust for Monticello Field Office’s September 2019 competitive oil and gas lease sale. Correspondingly, we intend that these comments be considered conducted internal scoping and external scoping. Refer to Appendix D and section 4.2. The BLM is providing
Historic in connection with Section 106 of the National Historic Preservation Act. BLM proposes to lease nineteen parcels in the September sale public involvement as defined in section 8.2.
Preservation covering approximately 32,000 acres of public land. These are the same parcels deferred from the March 2019 sale. BLM has not provided
an opportunity for scoping on the EA and has indicated – to the objection of consulting parties - that it considers Section 106 consultation to
have been completed. We have significant concerns that BLM’s environmental review is incomplete and that the EA does not contain enough
information or analysis to reasonably conclude that no direct, indirect or cumulative effects to cultural resources will occur as a result of the
lease sale. More than 40,000 acres of the lands located between Canyons of the Ancients National Monument and Route 191 were leased in
2018, and this lease sale alone would increase that amount by 80%. Accordingly, we urge BLM to halt further leasing in the region pending
completion of a Resource Management Plan (RMP) update and Programmatic Agreement (PA).
[50] Interests of the National Trust for Historic Preservation The National Trust for Historic Preservation is a private, nonprofit [50] Background information. No Response is warranted.
organization chartered by Congress in 1949 to facilitate public participation in the preservation of our nation's heritage, and to further the
historic preservation policy of the United States. See 54 U.S.C. § 312102(a). Congress intended the National Trust “to mobilize and coordinate
public interest, participation and resources in the preservation and interpretation of sites and buildings.” S. Rep. No. 1110, 81st Cong., 1st Sess.
4 (1949). With headquarters in Washington, D.C., 27 historic sites, more than one million members and supporters, and a national network of
partners in states, territories, and the District of Columbia, the National Trust works to save America’s historic places and advocates for historic
preservation as a fundamental value in programs and policies at all levels of government. In addition, the National Trust has been designated by
Congress as a member of the Advisory Council on Historic Preservation, which is responsible for working with federal agencies to implement
compliance with Section 106 of the National Historic Preservation Act. 54 U.S.C. §§ 304101(8), 304108(a). The National Trust has been
advocating for the protection of historic properties on public lands in San Juan County for over a decade. This includes submitting comments
on oil and gas lease sales that have the potential to cause direct and indirect effects to cultural resources. As described in BLM’s 2008 RMP the
Monticello field office possesses “one of the highest archaeological site densities and North America” (RMP at 4-9). The breadth of leasing
activity that has occurred over the course of the past year and a half in this region led the National Trust to profile the “Ancestral Places of
Southeast Utah” in its 2019 list of America’s 11 Most Endangered Historic Places.
[51]. The existing stipulations for oil and gas leasing were developed as part of a thorough and public land use
[51] The Existing Resource Management Plan does not provide sufficient protections for cultural resources proposed to be leased in planning process for the MtFO RMP (2008) Historical data shows that only 1/3 of all leased parcels receive
the upcoming sale. While BLM argues to the contrary, oil and gas leasing has the potential to cause significant impacts to historic properties. some form of surface disturbance. Looting as an indirect result of oil and gas development would only result in
The photo below is one evidentiary example. An oil and gas well active along Montezuma Creek in the viewshed of the Nancy Patterson response to the addition of new roads into previously road-less areas. Typically, initial development of a
Village site. Across the road in the foreground of the picture is a looted site, including a damaged and exposed kiva. The relationship between wildcat well relies on use of existing routes with the minimal addition of new road mileages. Additionally,
increased industrial activity and illegal looting is a primary concern of the consulting parties under Section 106. Exploratory activities and research conducted in Grand Staircase-Escalante National Monument has indicated that looting of
road building provide easier access to sensitive cultural resources on a landscape that has already seen damage from looters. No surface archaeological sites has actually decreased over the past 20 years.
occupancy (NSO) stipulations can be an effective safeguard from new road building, which can have both direct and indirect adverse effects
on cultural resources. Yet, even though directional drilling is becoming more technologically feasible, only 383.31 acres – or about 1% of the Additional analysis of indirect effects associated with the opening of previously road-less areas as a result of
current lease sale -- would be subject to NSO stipulations (EA at 20). This is largely due to the RMP, which failed to provide protections for oil and gas development will be further considered in the NEPA and NHPA analysis related to any
some of the most significant cultural resources in the planning area. An update of the RMP is long overdue. As recognized by the BLM State applications for development on a leased parcel.
Director in 2015, significant new information about the historic resources within the Monticello planning area has been recognized since the Developing new NSO or CSU stipulations would require a RMP amendment and is outside the scope of this
existing RMP was completed in 2008. The Monticello Field Office has ample information on which to establish a new guiding framework for project.
future development in the area.
[52a] The EA inappropriately omits any discussion of impacts to cultural resources, limiting its analysis only to the effects of leasing on [52a] A Cultural Resources Review was prepared to document the BLM’s reasonable and good faith effort to
air quality and greenhouse gas/climate change. At Section 1.9 the EA states four reasons as BLM’s rationale for “not further discussing” identify effects this undertaking may have on historic properties. To comply with NEPA, the BLM describes
cultural resources in detail in the EA. In sum, it concludes further analysis unnecessary because BLM: affected cultural resources and potential impacts of the proposed action in the IDPRT checklist, Section 1.9,
and Appendix D. Refer to comment 2.
• Has completed a literature search of existing site information;
• Intends to apply Stipulation H 3120-1 to consult under Section 106 at the APD stage;
• Maintains the right to modify development proposals prior to granting APDs; and
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• Completed a cultural resource analysis in March 2018 prior to the deferral of those parcels to the September 2019
sale.
We object to each point as outlined below. Broadly, we find BLM’s reluctance to consider the impacts to cultural resources deeply
problematic, and at odds with NEPA’s fundamental purpose to have federal agencies “study, develop, and describe appropriate alternatives
to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources”
and to consider alternatives to the proposed action. 42 U.S.C. §§ 4332(E), 4332(C)(iii). BLM is well aware of the deep- seated concern
among tribes and the general public that unfettered oil and gas development is not appropriate in many parts of this region. It contains some
of the most significant and longstanding settlements associated with ancestral Puebloan communities, including the Nancy Patterson Village
site, and Coal Bed Village site, as well as in the vicinity of significant rock art (see below image
Further, insufficient funding for the stewardship of archaeological sites has led to large knowledge gaps. In good faith efforts, Friends of
Cedar Mesa and others have assisted BLM in filling the gaps, providing research and funding for more complete documentation efforts.
Yet, despite receiving significant new information about cultural resources in the project area since the RMP was last updated more than a
decade ago, BLM has dramatically increased its leasing activity without a management strategy that takes account of this information.
Following are our comments on why BLM’s decision to omit a cultural resources analysis in the EA is misplaced, and unlawful.
Identification efforts have been inadequate. BLM has not acted reasonably and in good faith in relying solely on a literature review to
justify its determination that oil and gas leasing will not harm cultural resources for the following reasons.
i. Most of the existing survey data BLM relies on has generally been done to survey specific sites for prior
industrial development. In our experience working with archaeologists who are knowledgeable about the region,
many significant sites remain unidentified, leaving them vulnerable to harm from exploratory activities.
ii. BLM’s lease sale stipulations do not require Class III surveys at the APD stage, nor do its lease stipulations
preserve BLM’s ability to implement the “no drilling” alternative.
iii. BLM has been reluctant to acknowledge that prehistoric sites can be eligible for the National Register under
broader criteria of significance than just criterion d (significance based on the information the site is likely to
yield). For instance, in many prehistoric villages sightlines and dark skies were critical making its setting and
viewshed a core component of its significance. Consultation with tribes and more complete survey and analysis
is critical to understanding and recognizing how these places connect across the landscape.
The below image, for instance, demonstrates how viewshed can be a core component of a site’s significance. It
shows evidence of prehistoric occupation at the head of a canyon (known as Pedro Point) located on the western
boundary of Canyons of the Ancients National Monument at the Colorado state line. The site affords significant
views into BLM land in the State of Utah, which are not part of the Monument, but deserve to be afforded
special protection as an integral component of its significance. [52b] This is not a valid comment for the EA, as it primarily applies to the NHPA process, not the NEPA
process. The NHPA process is on-going. Lease stipulations do not cover the NHPA process. See Response to
[52b] Lease stipulations are insufficient to ensure consultation at the APD stage Comment 9-14 for discussion of March 2019 ACHP Letter.
Based on past practice, we are not convinced that BLM’s stated commitment to consultation at the APD stage will satisfy the
reasonable and good faith standard. This is largely because the manner in which BLM Utah has conducted Section 106 review with
respect to oil and gas leasing in the Monticello Field Office has consistently been inadequate in light of the significant resources at
stake.
The National Trust is particularly concerned that BLM failed to provide notice to consulting parties with an express interest in leasing
in the Monticello Field Office in the March 2019 sale. Despite having participated as a consulting party on both the March and
December 2018 lease sales, the National Trust was not informed of the specific process BLM created for consulting party requests in
the March 2019 lease sale (BLM states in the EA that it “posted data and instructions on ePlanning,” EA at 43).
On April 1, 2019 the National Trust submitted a letter to BLM’s lead oil and gas archaeologist with a request for consulting party
status on the September 2019 lease sale (Attachment A). We were then informed by BLM via email that this letter was not acceptably
conveyed as a consulting party request, for which BLM required it be mailed (per instructions on the ePlanning website) and that,
regardless, the parcels we identified as of concern “were already subject to a Section 106 analysis during the March 2019 Lease Sale.”
The email stated BLM has “no plans to re-analyze the Monticello parcels under Section 2016 in the September 2019 Lease Sale”
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(Attachment B).
BLM’s position that consultation is complete seems to be firm despite an Advisory Council on Historic Preservation dispute
resolution letter indicating disagreement with the agency’s finding of no adverse effect (stating that “ACHP does not agree that, in all
circumstances and regardless of location, leasing will not have an adverse effect on historic properties”(Attachment C)(emphasis in
original)). The ACHP faulted BLM for failing to cite any documentation for how direct, indirect, or cumulative effects will be
considered, and failing to provide information on how potentially eligible districts would be avoided in later phases. While the ACHP
recommended the development of a Programmatic Agreement (PA) to address these issues, BLM has taken no such action in
response as of the time of this writing.
We urge BLM to reinitiate Section 106 consultation and accept our request to participate as a consulting party, our request having
been made in good faith.
[52c] BLM fails to retain adequate authority to modify projects prior to drilling [52c] See Response to Comment 2
While BLM states in the EA that it maintains the authority to modify projects in the event of unanticipated adverse effects to cultural
resources, BLM provides no support for this claim. The stipulations themselves do not confirm that BLM has the discretion to prohibit
development on parcels, even where impacts to cultural resources cannot be mitigated. Further, the stipulation language does not
require BLM to conduct a Class III survey at the APD phase.
While current BLM policy may enable denial of an APD application for impacts to cultural resources or Class III survey, the public
has no assurance that this policy will remain in place after the parcels are leased. For instance, BLM has already been forced to
balance its responsibility to consult reasonably and in good faith with a new departmental policy to hurry through the compliance
process with a strict 6-month period to complete NEPA and NHPA review (see IM 2018-034). Therefore, legally binding language in [52d] These are comments on the NHPA process which has a separate comment period. Although the
stipulations is the only measure that can effectively assure the public of these protections. commenter apparently didn’t participate as a consulting party for the March 2019 Lease Sale, Friends of Cedar
Mesa did. The responses to their comments can be found here: https://eplanning.blm.gov/epl-front-
[52d] BLM’s prior cultural resources analysis is insufficient office/projects/nepa/117403/169522/206129/2019-03-20_March2019_OG_FCM_comments_response.pdf
See Response to Comment 9-14 for discussion of March 2019 ACHP Letter.
We hereby incorporate our March 2019 lease sale protest dated February 28, 2019, which was cited in ACHP’s dispute resolution
letter. The protest – jointly submitted with Friends of Cedar Mesa - objected to many of the assumptions contained within the draft
Cultural Resources Report including, among others, concern with
• BLM’s assumed half-mile Area of Potential Effects (APE), regardless of the site and its setting;
• The lack of a good faith identification effort;
• BLM’s unwillingness to consider National Register eligibility determinations for archaeological districts in eastern
San Juan County; and
• The basis of BLM’s “No Adverse Effect” determination, which appears to be predetermined regardless of the
extent of survey on any given parcel.
The cultural resources review must be updated to effectively incorporate the ACHP’s concerns about the process. In order to do so
BLM has an obligation to re-initiate consultation.
[53] The BLM did not rely on the DNA.
[53] BLM’s decision to omit a discussion of impacts to cultural resources and rely on a Determination of NEPA Adequacy is
inconsistent with past practice. In two lease sales in 2018 BLM initiated scoping and prepared EAs acknowledging impacts to
cultural resources as a significant issue. Even though we disagreed with BLM’s ultimate conclusion that no harm would occur to
cultural resources, those documents at least provided some analysis of the issue. In the September 2019 EA BLM completely omits
any discussion of cultural resources whatsoever (resting on its previous Determination of NEPA Adequacy which was likewise not
sufficient).
[54] BLM has failed to account for cumulative effects to historic resources due to recent leasing activity in the project area. One [54] Cumulative Impacts to leasing and developing were considered in the 2008 MtFO RMP EIS.
of the most pernicious aspects of failing to carry forward cultural resources as an issue in the EA is the concern that BLM is altogether
avoiding analysis of the relationship of this sale to the March and December 2018 competitive sales. In calendar year 2018 BLM Utah
leased over 40,000 acres of land in the Monticello Field Office planning area, much of it in the culturally rich canyons feeding
Montezuma and Recapture Creeks. The National Trust strenuously objected to both sales as a consulting party under Section 106 of
the National Historic Preservation Act.
[55] This is not a valid comment for the EA. This is outside the scope.
[55] A Programmatic Agreement is necessary to address systemic inadequacies and problems associated with cultural
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resource identification in the Monticello Field Office.
The Record of Decision approving the 2008 RMP commits BLM to “conduct proactive cultural inventories under Section 110 of the
National Historic Preservation Act” (ROD at 15). However, in a review of the RMP in 2015 BLM staff noted that
cultural resources have not yet been assigned to appropriate use categories, and that completion of a cultural resource management
plan would improve their ability to plan for access to cultural sites, particularly with regard to special recreation permits. As a
result, the RMP does not fully protect significant cultural and paleontological resources through special designations. Likewise,
route and travel designations in the RMP fail to address cultural and paleontological needs and protection. Nomination of the most
significant sites to the National Register of Historic Places and additional road inventories in the field office would help remedy
these shortfalls.
(Monticello RMP Five-Year Evaluation at 5). Consistent with these significant concerns, BLM must make proactive identification
efforts outside the oil and gas context to fulfill its legal responsibilities to steward the exceptional resources under its care.
A PA, combined with an RMP update, can also help resolve conflicts by establishing a path for the identification of the cultural
resources in the planning area where setting, feeling and association is a defining aspect of their significance. The footprints of
seismic lines, well pads, pipelines, and associated access roads and ancillary facilities may be relocated to avoid direct harm to
specific sites, but the auditory and visual harm to landscape level resources, districts, and traditional cultural places is often
impossible to avoid in the context of oil and gas development, particularly where heavy site densities occur within specific parcels.
Where high priority sites are known new ACECs should be established to ensure that surface occupancy will not occur within an
appropriate boundary.
[56] Conclusion. We maintain significant concerns that the EA inadequately evaluates potential harm from the lease sale on cultural resources.
[56] Comment noted.
11.)National [58] Thank you for the opportunity to provide comments for the September 2019 Competitive Oil and Gas Lease Sale Environmental [58] Background information was provided. Deferral of the parcels in the proposed action would be
Park Service- Assessment (EA), Monticello Field Office, DOI-BLM-UT-000-2019-0003- OTHER NEPA -MtFO-EA. The 19 parcels located inconsistent with the RMP and contrary to current BLM policy as stated in WO IM 2018-034. Additional
Hovenweep northwest from Hovenweep National Monument (Hovenweep) are generally between 4.5 and 21 miles from the separate units of the response is not warranted.
monument. Despite the distance from Hovenweep, we believe that oil and gas exploration and development on these parcels will be
detrimental to the visitor experience in the monument and surrounding lands, and will negatively affect resources important to
Hovenweep. Therefore, we respectfully request the Bureau of Land Management withdraw the subject parcels from the September 2019
lease sale. [59] The RFD Scenario the NPS is referring to is the broad RFDs created for the MLP. Just below the broad
discussion of the RFDS created for the land use plans, the EA breaks it down for the 19 parcels covering
[59] Reasonably Foreseeable Development Scenario 32,067.42 acres. Please refer to section 2.2.1.
It is not clear how BLM arrived at an anticipated 195 well pads in 15 years and 115 producing wells. It is also not clear how many of “For the analysis of the 19 nominated parcels encompassing 32,067.42 acres, the MtFO estimated a maximum
those well pads and producing wells would result from this planned lease sale. We recommend the EA include sufficient detail that a of 4 wells would be drilled, and the maximum new disturbance will be 4 wells totaling 38.40 acres (one well
pad and access road disturbance at 9.6 acres). This scenario would occur rarely, if at all. Over the last three
reader can understand the basis of the calculations, and specifically how the current lease sale is expected to contribute to the total number
years (2015-2018), six wells have been drilled in San Juan County. Out of those six wells, only 1 well was
of well pads and production wells.
capable of production. Statistically, it is more probable that three wells would be drilled for the nominated
MtFO parcels.”
The comment is noted and the BLM clarified the method and calculations in Section 2.2.1 for the nominated
parcels. For information regarding the broad analysis used for the MLP and the RFD, please go to the
ePlanning. The links are also included in the Appendix E.
[60] The Air Resource Technical Advisor Group (AiRTAG), including the National Park Service, was
[60] Air Quality consulted for the Moab Master Leasing Plan (MLP) air quality analysis. Due to the estimated limited level of
Oil and gas exploration and production activities that may result from leasing the subject parcels have the potential to cause direct, oil and gas development activity predicted by the Appendix G, section 2.2.1 not being substantially different
indirect, and cumulative effects on air quality and air quality related values (particulate deposition and visibility) that have implications than what was analyzed for the MLP and the absence of any amount of definitive development, BLM
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for resource conditions in Hovenweep, and surrounding areas. Because ozone concentrations in the region are approaching National determined that additional consultations with the NPS Air Resources and the Utah BLM's AiRTAG would not
Ambient Air Quality Standards, effects of oil and gas activities on ozone formation are of particular concern. Consistent with the 2011 be appropriate at this time. This consultation would be more appropriate at the lease development stage when a
Interagency Memorandum of Understanding concerning air quality analyses and mitigation for federal oil and gas decisions, we ask that proposal would be subject to site-specific NEPA analysis.”
BLM consult with the NPS Air Resources Division and other members of the Utah air resources technical advisory group in determining Additionally the air quality modeling analysis presented in the EA were performed in consultation with NPS
the most appropriate type of air quality analyses to conduct if these parcels are leased and subsequently developed. Dust emissions from Air Specialists and the AiRTAG. These model analysis include the Cane Creek project, the Moab MLP, and
pads and roads associated with exploration and production activities, including increased bare ground and increased vehicle traffic, have the Air Resource Management Strategy ARMS. These models evaluated direct, indirect and cumulative
impacts on air quality and air quality related values from oil and gas development.
the potential to increase regional haze and reduce visibility. This is a key concern related to the visitor experience.
While Ozone is a regional concern, the NPS own monitoring data from the Canyonlands National Park
IMPROVE site shows the 5 year average ozone concentrations has been decreasing since 2007. The data also
shows there has only been one year out of the last ten where the fourth highest 8-hr average ozone
concentration exceeded the NAAQS.
(http://views.cira.colostate.edu/fed/AvgExplorer/Default.aspx?wcfid=ADE_High4_5YA&nyears=5&ey=2016)
In addition the Moab MLP air analysis which is incorporated by reference identified that high ozone
concentrations near Canyonlands NP and Arches NP is primarily a result of pollution sources outside of the
region and that oil and gas development in the planning area has little contribution to the overall concentration.
In section 3.3.1.4 ozone was identified as being a potential concern in the future, and that if monitored
concentration levels increase then additional air quality analysis may be necessary, as identified in UT-LN-
102.
[61] Climate Change [61] Comment noted. BLM considered many of the suggested improvements to the climate change analysis
We applaud the inclusion of a climate change discussion in the EA and offer the following comments to improve the discussion and also to (including the USGS National Climate Change Viewer and CMIP5 tools) and will consider these
improve BLM’s ability to communicate climate change issues to stakeholders. recommendations for future lease sales. For this lease sale, BLM chose to incorporate the climate analysis
from the Colorado Plateau Rapid Eco-regional Assessment (REA) (Bryce 2012). While the USGS National
• In Table 10, we recommend BLM provide future projections of temperature and precipitation. Projections are widely available Climate Change Viewer provides a county level look projected climate change it tends to only focus on
in the literature (see for example; Cook, B. I., T. R. Ault, and J.E. Smerdon. 2015. Unprecedented 21st century drought risk in atmospheric variables such as temperature and precipitation and excludes other parts of the earth climate
the American Southwest and Central Plains. Sci. Adv. 1, e1400082). The USGS National Climate Change Viewer system. In addition to evaluating the atmospheric changes to climate, the Colorado Plateau REA also includes
(https://www2.usgs.gov/landresources/lcs/nccv/viewer.asp) is an excellent source for climate change projections based on potential impacts to the hydrosphere (water, lakes, rivers, etc.) and biosphere (living organism, plants and
animals). This information is compiled into a simple map Figure 3 showing the potential (low to very high) of
ensemble forecasts from global circulation climate models
climate change at local levels. While NPS disagrees with the findings of the Colorado Plateau REA, that
• The last paragraph on page 35 states that methane has an average atmospheric lifetime of 12 years compared to 50 to 200 years approximately 70% of the plateau will experience moderate or lower potential for change, the method
for carbon dioxide. We recommend the paragraph also state that methane is a much more potent greenhouse gas (GHG), suggested by them of inferring that since there will be substantial worldwide impacts from global warming of
approximately 28 to 36 times more potent than carbon dioxide (https://www.epa.gov/ghgemissions/understanding-global- 2℃ there will also be substantial impacts within the cumulative impact area is not based on sound science.
warming- potentials). There is inherent difficulties in downscaling a global impact to a site specific impact. As stated earlier the
• In Table 11, we recommend BLM state the time frame for the tabulated emissions: is the time frame one average year, one alternative provided by the USGS National Climate Change Viewer only considers the atmospheric component
particular year, or cumulative over a time frame of several years? of the of the earth climate system, and doesn’t include the hydrosphere, biosphere, or other climate systems
• In Table 12, we recommend BLM clearly indicate if the Operations values shown in the table are for the first year of operation, like the REA. However, as the REA potential for climate change across the entire Colorado Plateau, additional
statements are added to the EA to identify the potential for climate change where lease parcels are located.
or if they representative of each and every year of operation.
• In the paragraph immediately following Table 12, BLM states that the annual GHG emissions for the reasonably foreseeable
development scenario are 15,603 MT CO2e/yr, based on 4 wells. However, this calculation would seem to be valid only for the To clarify the tabulated emissions, the construction emissions will occur only in the first year of development,
the operation emissions are representative annually over the entire life of the well, and combustion emissions
first year of operation when construction emissions would be included. The sum of 3,900.8 MT CO2e/yr per well does not are an average annual amount. Additional information has been added to the EA to show the estimated total
match the data provided in Table 13. life of well emissions. Updates are also made to clarify how the emissions are calculated in the paragraph
• In Table 13, we recommend BLM provide an estimate (low, average, and high) of the emissions over the lifetime of a immediately after Table 12.
producing oil well and the lifetime of a producing gas well, based on average production well lifespan. An alternative would be
to estimate lifetime emissions based on an equation of the curve of typical well production over time. No changes will be made to the document to identify methane capture technology or to require operators to use
• In Section 3.3.2.3, we recommend BLM include an item stating that methane capture technology will be used at wellheads, or such technology. The BLM is not a regulatory authority for air pollutant emissions. The permit by rule
that technologies to prevent methane leakage from a wellhead will be required. requirements recently established by the Utah Division of Air Quality (R307-511) requiring “Associated gas
We disagree with BLM’s statement in the first full paragraph of page 40 that the potential for climate- related change on the Colorado from a completed well shall either be routed to a process unit for combustion, routed to a sales pipeline, or
Plateau is predicted to be “mostly moderate or lower.” Our opinion is based on the scientific literature (one example cited above) and on routed to an operating VOC control device except for emergency release situations,” sufficiently addresses this
comment.
ensemble model predictions from the Coupled Model Intercomparison Project phase 5 (CMIP5). We recommend BLM rewrite this
section, based on the overwhelming scientific literature related to effects of climate change on the Colorado Plateau and the CMIP5
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model results summarized in Table 1 and available at the following USGS website
(https://www2.usgs.gov/landresources/lcs/nccv/viewer.asp).
The scientific consensus (IPCC, 2014: Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and III to the Fifth
Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, R.K. Pachauri and L.A. Meyer (eds.)].
IPCC, Geneva, Switzerland, 151 pp.) is that temperature increases of 2°C or greater compared to the pre-industrial baseline will lead to
substantial worldwide negative effects on the human environment. Table 1 indicates that San Juan County, Utah is like to exceed the 2°C
increase in temperature within the next 5 to 30 years. Therefore, it is not credible to suggest in the EA that climate change effects on the
Colorado Plateau will be moderate or lower.
[62]See Response to comment 5. The noise propagation modeling conducted by the NPS for the Moab MLP
[62] Naturally Dark Night Skies and Soundscapes states that “In Utah’s Lease Notices, VRM classes are used as the basis for determining where alternative
We recommend that BLM discuss more fully the effect of oil and gas exploration and development on naturally dark night skies and mineral lease stipulations would apply for purposes of protecting viewsheds, soundscapes and night skies.”
quiet soundscapes, and the increase in night sky viewing opportunities in Hovenweep and on adjacent public lands. In our opinion, the This is incorrect. VRM classes are not meant to mitigate any of those issues.
inclusion of Utah Lease Notice UT-LN-125, Light and Sound- Sensitive Resources provides insufficient guidance and requirements for
protection of dark night skies. Hovenweep is certified as an International Dark Sky Park. Naturally dark night skies are becoming ever The Report went on to say: “Required setbacks to mitigate sound and light impacts are limited to a maximum
more popular with park visitors and we are concerned that lights from exploration and development actions on the leased parcels will of 200 meters. When viewed alongside the results presented in this report, setbacks of 200 meters are clearly
affect Hovenweep’s dark night skies. We are also concerned about potential impacts of oil and gas exploration and drilling activities on unlikely to prevent significant impact to restful sleep, wilderness solitude, and recreational experiences, for
natural soundscape conditions experienced in Hovenweep. Parcels 417, 418, 419, and 424 are located about five miles away from example.”
Hovenweep. Noise propagation modeling conducted in support of the Moab Master Leasing Plan indicated that noise generated by
drilling operations can be heard more than six miles away from the source under some conditions. Misunderstandings of the BLM’s use of stipulations and lease notices appears to be the basis for the Park
Service’s concerns for this and previous lease sales. The Lease Notice serves to alert potential lessees of a
resource conflict that may result in Conditions of Approval that would require measures to prevent impairment
[63] Groundwater Quality and Quantity
of night skies and soundscapes in the area of concern. This not achieved through setbacks, but through use of
We also are concerned about potential impacts of exploration and development activities on groundwater resources. The Monument infrastructure to quiet motors and deflect light.
depends on groundwater from the Navajo Sandstone for all administrative and visitor uses, and development of groundwater for oil and
gas extraction in the area has the potential to affect the quantity and quality of Hovenweep’s groundwater source. Additional use of [63] Comment noted. BLM will continue to work and coordinate will all stakeholders including the Division
groundwater has the potential to diminish groundwater resources over a wide area because of hydraulic continuity between aquifers and of Water Quality, Division of Water Rights, Utah Geological Survey and the U.S. Geological Survey. Please
extremely slow rates of recharge. Therefore, we request BLM work with leaseholders to use sources of water that will have the least refer to Appendix D (IDPR) and section 4.2 through 4.3. If these parcels are acquired and an APD is
possible future impact on Hovenweep. Hydraulic fracturing associated with oil and gas production has the potential to introduce submitted, the well is subject to the casing and cementing requirement of Onshore Oil and Gas Order No.2.
contaminants into groundwater systems. Therefore, we request that BLM consult with the US Geological Survey or the Utah Geological (O.O. #2). All APDs are subject to review by a BLM petroleum engineer, geologist, and hydrologist.
Survey regarding the effects of hydraulic fracturing on water quality in the area. In addition to the groundwater quality and quantity Compliance with O.O. #2 will ensure protection of useable ground water aquifers from drilling, completion
issues, we are concerned about the potential for earthquakes that could result from lubrication of faults, bedding planes, formation and production operations. Additional response is not warranted
contacts, and other subsurface geologic structures by injection of fluids during hydraulic fracturing or injection of produced water. We
recommend BLM evaluate effects of fluid injection on the geologic formations into which fluids are likely to be introduced and the
susceptibility of those formations to earthquakes caused by fluid injection. Prehistoric cultural structures at Hovenweep could be very
susceptible to earthquakes initiated by fluid injection.
12.) Thomas [64] The BLM is legally required to analyze "cumulative impacts," not only of this immediate lease sale but of this lease sale combined [64] Cumulative impacts have been analyzed in this EA. Refer to section 3.2, 3.3.1.4, and 3.3.2.4.Currently the
Messenger with other potential development in the area. The BLM fails to do this in the environmental analysis (EA). This is the third time in 18 MtFO has 243,736 authorized leased acres (Table 3). The Monticello Field Office RMP, as amended by the
months that the BLM has offered or sold leases in this area and each time limited the analysis to the potential impacts of developing the GRSG ARMPA (BLM 2015 and 2019) designates 432,296 acres in the planning area as open to leasing with
area offered in each particular sale. The BLM must analyze the big picture, cumulative impacts of the developing whole 150+ square standard stipulations where approximately 23% (99,051 acres) have been leased. An additional 586,736 acres
miles. The proposed lease blocks are located in one of the most culturally and archaeologically rich public land areas in the U.S. that are open to leasing with moderate stipulations (CSU/TL) where approximately 16% (92,143 acres) have been
includes cliff dwellings, pueblos, kivas, petroglyph and pictograph panels. The area has not been adequately inventoried and impacts to leased. Major stipulations, such as No Surface Occupancy (NSO), has been designated across 82,216 acres and
cultural resources have not been adequately assessed. The lands proposed for the September 2019 lease sale blocks include lands approximately 18% (14,553 acres) of these acres have been leased. The September 2019 lease sale would
determined by the BLM to have wilderness character and which are also proposed for wilderness designation in America's Red Rock make approximately an additional 6% (27,896 acres) acres with standard stipulations, < 1% (2,005 acres) acres
Wilderness Act's Monument Canyon and Tin Cup Mesa units. The EA fails to adequately assess impacts to wilderness values. with moderate stipulations, and no acres with major stipulations available for leasing. Currently there are
243,736 leased acres within the MtFO boundary and the lease sale would make an additional 32,067 acres
available for lease. If all parcels are sold in the lease sale then total leased acres for the MtFO would
cumulatively increase to 275,803 acres or 25% leased acres. This would be a cumulative increase of 3%
compared to current leased acres (Table 3).
None of the parcels are within Wilderness or Wilderness Study Areas (Appendix D).
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13.) John Gould [65] My reading the law indicates that the BLM is required to assess the total impacts of the entire project. It sure appears as though you [65] Refer to comment 34.
folks have broken this single-area development into three phases in order to come to a conclusion of No Significant Impact. In addition, it
is my understanding that assessing the total impacts includes assessing the impacts of the use of the extracted materials. However, you
state in Section 3.3.2.2 the following: "Indirect Impacts from Combustion of Produced Oil or Gas If lease parcels are developed and if the
resulting well produces oil or gas it is foreseeable that indirect GHG emissions will result from the end-use of the fossil fuel. Estimates of
downstream emissions are assumed to come from the combustion of oil or gas for domestic heating or energy production. However, May
2019 Monticello Field Office DOI-BLM-UT-000-2019-0003-EA 37 the BLM has no authority to direct or regulate the end-use of the
produced products and an actual end-use may differ from the assumption used for calculating downstream GHG emissions. Calculations
of indirect emissions from downstream combustion can be made by multiplying the produced number of barrels (bbl) of oil and thousand
cubic feet (mcf) of gas with GHG emission factors ".What does "...the BLM has no authority to direct or regulate the end-use of the
produced products..." have to do with it? You are not required to direct or regulate the use of these materials, only to assess their impacts
on the environment, and "directing" and "regulating": are not necessary for assessing the impacts of burning fossil fuels. Kindly go back,
assess the environmental impacts of the leasing of ALL the parcels in ALL the lease sales in the area, and in addition, please assess ALL
the factors required by law. In the meantime, I support only the No Action Alternative.
14.)Utah Rock [66] We have reviewed the Environmental Assessment (EA) for the Monticello Field Office September 2019 Competitive Oil and Gas [66] Background information. BLM response is not warranted.
Art Research Lease Sale and respectfully submit the following comments on the EA and on the Finding of No Significant Impact (FONSI). Who We
Association Are: URARA is the leading organization in the state of Utah advocating for the preservation, documentation, and study of pre-historic
and historic petroglyphs and pictographs (rock art). Our membership includes rock art enthusiasts, professional archeologists,
anthropologists, geologists and others. We are engaged with land managers on federal, state, county, and city lands, assisting with and
consulting on land use activities that may impact rock art. We are a resource for government agencies, municipalities, communities, and
private landowners, to aide them in identifying, preserving, and protecting these cultural resources within their boundaries and/or
jurisdictions. Statement of Concern: The Utah Rock Art Research Association understands that the proposed September 2019 oil and gas
lease sale has designated nineteen parcels totaling approximately 32,067.42 acres located in the Monticello Field Office (MtFO) area.
While URARA does not have any knowledge of rock art sites within these parcels, the BLM’s own analysis in Attachment C –
Interdisciplinary Team Checklist to the March 2019 Competitive Oil and Gas Lease Sale DNA recognizes the cultural importance of this
area when it states the “preliminary analysis using the cultural resources planning model (Beck et. Al., 2017) indicates that, in the vast
majority of the Monticello FO parcels, there is a high probability of the presence of cultural resources.” URARA’s primary concern, as
stated in our original comments to the March 2019 DNA, is the location of the scattered lease parcels in the greater Montezuma Creek,
Alkali Ridge, and Recapture Creek areas. The high cultural value of the Montezuma Creek, Alkali Ridge, and Recapture Creek areas has
been recognized for nearly a century. These areas have a long habitation history including occupation by Basketmaker II, Basketmaker
III, Pueblo I, Pueblo II and Pueblo III cultures. The largest Pueblo villages in Utah are located in the Montezuma Creek system. A
prehistoric road, stretching from the San Juan River to as far north as Lowry Pueblo, has been documented adjacent to ruins in aerial
photographs. Tributaries from this road extend to many ancient village sites. We are aware of previous oil and gas exploration and
development in the area as evidenced by drill pads and exposed pipes throughout the drainages and believe that any new oil and gas
development threatens to further degrade these unique cultural resources. URARA believes the high concentration of archeological and
rock art sites in the Montezuma Creek, Alkali Ridge, and Recapture Creek areas are a significant national and state resource whose value
far outweighs the value of the oil and gas leases proposed in this sale. We understand that the current lease parcels are removed from the
Montezuma Creek, Alkali Ridge, and Recapture Creek areas, we still believe that the BLM’s current assumptions do not adequately
predict the potential for adverse effect in culturally rich areas. The criterion does not weigh the cumulative impact of exploration, seismic
testing, well drilling, pipe construction, and transportation corridors on cultural resources both inside and outside the lease parcel. In
particular Montezuma Creek and its tributary canyons contain a very high density of rock art and other cultural sites. Montezuma Creek
is, and has been for thousands of years, the main travel corridor into and out of this area, which is why so much rock art and other
cultural sites are located here, and we believe that it will be impossible to access the proposed lease parcels without adversely impacting
cultural sites. In Nine Mile Canyon, a similar transportation corridor to oil and gas parcels on Tavaputs Plateau, adverse effect to rock art
adjacent to the road from a combination of dust, vibration, and increased visitor use was not considered sufficiently in environmental
assessments.
[67] The September 2019 lease sale presents a similar situation in Montezuma Creek where the road is adjacent to cliffs with a high [67] The Cultural Resource Stipulation (H 3120-1) states: This lease may be found to contain historic
concentration of rock art and nearby archeological habitation sites. We believe that the impact on cultural resources from the properties and/or resources protected under the National Historic Preservation Act (NHPA), American Indian
development of access roads and pipelines to the lease parcels has not been sufficiently considered in the determination of the Finding of Religious Freedom Act, Native American Graves Protection and Repatriation Act, E.O. 13007, or other
152
July 2019

No Significant Impact. statutes and executive orders. The BLM will not approve any ground disturbing activities that may affect any
such properties or resources until it completes its obligations under applicable requirements of the NHPA and
other authorities. The BLM may require modification to exploration or development proposals to protect such
properties, or disapprove any activity that is likely to result in adverse effects that cannot be successfully
avoided, minimized or mitigated. Additional Section 106 analysis and tribal consultation will occur for any
proposed development activities associated with the sale of these leases. Potential adverse impacts tied to
development activities will be evaluated and projects will be modified or redesigned to avoid impacts. If there
is an irreconcilable adverse impact, the BLM will either deny the proposed action or work to develop a
mitigation strategy and an associated MOA as provided for in the Section 106 regulations.
Through the Cultural Resource Protection Stipulation attached to all leases, BLM has the authority to require
modification of, or disapprove; parcel development plans if cultural resource conflicts cannot be satisfactorily
resolved. This gives BLM the authority to control future development to avoid adverse effects, including, but
not limited to, those caused by a degradation of setting and other indirect effects.
Offering federal mineral estate parcels for lease and subsequently issuing oil and gas leases are strictly
administrative actions, which, in and of themselves, do not cause or directly result in any surface disturbance.
Issuance of an oil and gas lease does convey to the lessee the exclusive right to use as much of the leased land
as is reasonably necessary to explore for and extract oil and gas resources from the lease area, subject to the
terms of the lease, including stipulations (43 CFR 3101.1-2 and 3101.1-3), regulations pertaining to oil and gas
leasing, Onshore Orders, and with prior approval of the Authorized Officer. However, depending on lease
stipulations, post leasing activities may or may not result in impacts to surface resources. As part of the lease
issuance process, nominated parcels are reviewed against the appropriate land use plan, and stipulations are
attached to mitigate any known environmental or resource conflicts that may occur on a given lease parcel. As
[68] We support EA Alternative B – No Action, and we strongly recommend that any future undertakings related to parcels that are stated above, on-the-ground impacts would potentially occur when a lessee applies for and receives approval to
leased will not be approved by the BLM until its obligations to consider cultural resources under NEPA, NHPA and other authorities explore, occupy and/or drill. The BLM cannot determine at the leasing stage whether or not a lease would
specific to those future undertakings have been completed. Consideration of impacts to rock art and other cultural resources, and adverse actually be explored or developed.
effects to historic properties must be taken into account during the approval stage of site specific development plans. URARA requests
consulting party status for these reviews.
[68]-Summary information. BLM response is not warranted.
15.) Town [69] RESOLUTION NO. 24 [69] Comment Noted. Response is not warranted
Council of
Bluff A RESOLUTION OPPOSING AND URGING CAUTION REGARDING OIL AND GAS LEASING ON BUREAU OF LAND
MANAGEMENT ADMINISTERED LANDS NEAR HOVENWEEP NATIONAL MONUMENT
WHEREAS the Bureau of Land Management is currently accepting comments on the draft Environmental Assessment (EA) that
considers offering 19 parcels near Hovenweep National Monument for oil and gas leasing in September 2019; and, WHEREAS
Hovenweep National Monument is an internationally recognized showpiece for San Juan County and for Utah; and, WHEREAS
Hovenweep National Monument is designated an International Dark Sky Park of the Gold-Tier; and, WHEREAS the cultural landscape
of the area surrounding Hovenweep National Monument contributes to the beauty, economy, cultural heritage preservation , and
recreation values of San Juan County; and, WHEREAS allowing oil and gas development near Hovenweep National Monument may
not balance multiple uses and may lead to the degradation of visitor experience, cultural heritage preservation, dark skies, air quality,
and water quality in that area; and WHEREAS one proposed lease parcel would allow for oil and gas extraction as close as 4 miles
from Hovenweep National Monument; and, WHEREAS the US Bureau of Land Management is accepting comments on the draft EA
until July 1, 2019; and, WHEREAS it is in the best interest of the residents of San Juan County for the US Bureau of Land
Management to make a well-informed and cautious decision regarding multiple uses of the land; and, WHEREAS the Town of Bluff is
a gateway community to Hovenweep National Monument. NOW, THEREFORE, BE IT RESOLVED BY THE TOWN OF BLUFF
OF SAN JUAN
COUNTY, UTAH that the Town of Bluff expresses reservation on oil and gas extraction near Hovenweep National Monument. BE IT
FURTHER RESOLVED that the Town of Bluff for opposes and calls on the US Bureau of Land Management to exercise caution and
ensure that any oil and gas leases on land near Hovenweep National Monument be conducted in a way that will not negatively impact
tourism, cultural heritage preservation, dark skies, traffic flow, air quality, and water resources in the area. BE IT THEREFORE
RESOLVED that the Town Council is authorized to file an official comment with the US Bureau of Land Management in accordance
153
July 2019

with the positions outlined in this resolution. This resolution shall become effective immediately upon approval and adoption by the
Bluff Town Council.
16.)Mollie [70] I am writing to oppose the September 2019 Competitive Oil and Gas Lease Sale in southern Utah. The areas in which these sales are [70] Comment Noted. Response is not warranted
Podmore proposed are home to tremendous archeological resources, environmental treasures, and diverse cultures. Leaving these areas as they are
will allow Utahns and visitors alike to continue to benefit from the historical, natural, and cultural assets for generations to come. Drilling
for oil and gas here would undoubtedly cause irreversible harm to both the landscape and the citizens of Utah and the nation as a whole.
Please do not open the September 2019 lease sale, and instead allow the broad range of resources in southern Utah to continue to flourish
as they have for centuries.
17.)Sue deVall [71] I have hiked and camped in the area in and near the new Bears Ears National Monument. This land is valuable for its Antiquities and [71] Comment Noted. Response is not warranted
its Wilderness characteristics. I do not believe that it should be wasted by extractive industries for short time profit. I urge you to move
away from climate changing fossil fuels and toward renewables.
18.)Augustus [72] I am writing to oppose the new lease on southeastern Utah public lands for the purpose of drilling oil and gas. Long enough have [72] Comment Noted. Response is not warranted
Griffin we sold public lands for nearly nothing to already wealthy companies. I have yet to see the tangible benefit of these leases for me or my
community members. I have however seen the degredation of cultural, environmental, and recreational landscapes. Not only within a
small radius of the drill sites which experience the largest effect but hundreds of miles. Light and air polution are not contained. How
will the people who are experiencing these degredations be repaid? The lease is giving away our land to a texas based firm that does not
benefit our local economy but takes our resources leaving behind damaged landsapes and a wealthy buisnessman in another state is
benefiting. I do not see the pros of this deal and I hope that it does not go through. Thank you for you time.
19.)Tory Hill [73] Please don't allow any mineral leasing in this very sensitive area. It has been proven that fracking causes earthquakes and this [73] Comment Noted. Response is not warranted Refer to Appendix D which states:.

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U.S.

Department of the Interior

September 2019 Competitive Oil and Gas Lease Sale

Monticello Field Office

3.3.2.1 Affected Environment ..................................................................................................... 34

Chapter 1 Purpose & Need

1.1 Project Location and Legal Description

1.6 Plan Conformance Review

• Bald and Golden Eagle Protection Act of 1962 (BGEPA)

State of Utah Plans/Rules

BLM Activity Plans/Strategies/Practices

BLM Land Use Plans

Monticello RMP, October 2008, as amended

Moab Master Leasing Plan and RMP, December 2016, as maintained

1.7 Relationship to Statutes, Regulations, Policies or Other Plans

Issue Issue Statement Impact Indicator

Table 2. Issues not included in Further Detail in the Environmental Assessment

1.10 Public Comment Period

Chapter 2 Description of Alternatives

anticipated to take place as described in Appendix G – Reasonable Foreseeable Development of

2.3 Alternative A – Proposed Action

Chapter 3 Affected Environment

3.2 General Setting

Table 3. Leasing Category Acreages for Monticello Field Office.

432,296 99,051 23% 27,896 6%

586,736 92,143 16% 2,005 < 1%

82,216 14,553 18% 0 0%

1,101,2483 243,736 22% 32,067 3%

Number Standard Moderate Major Acreage Private Federal

411 1,280.00 - - 1,280.00 - 1,280.00

3.3 Resources/Issues Brought Forward for Analysis

# of Days When AQI was… % of Days Rated …

O3 San Juan County 8-hour 0.064 ppm 0.070 ppm

PM2.5 Mesa County, CO Annual 6.1 µg/m3 12.0 µg/m3

PM2.5 Mesa County, CO 24-hour 19 µg/m3 35 µg/m3

Area Sources 384.42 649.79 4,252.57 524.24 2.72 218.46

Area Sources Oil and

Non-Road Mobile 1,718.66 103.03 21.12 19.67 0.42 535.85

On-Road Mobile 1,551.00 747.70 239.52 78.86 2.89 153.20

Point Sources 240.37 357.52 234.93 88.63 505.93 60.30

Biogenics 15,795.81 0.00 0.00 0.00 0.00 72,896.61

Wildfires 1.35 0.04 0.16 0.15 0.00 0.23

County Total 19,987.7 2,057.37 4,750.69 713.93 512.89 85,704.70

HAPS (tpy) San Juan

PM10 NOX CO VOC

terminated with no development or production emissions occurring. If production is not established

Air Quality Related Values

Utah US Energy United Global

3.3.2.2 Environmental Consequences

Single Well Emissions Metric Tons per year

Emissions from Combustion of Produced Oil or Gas

3.3.2.3 Required Design Features/Mitigation Measures

3.3.2.4 Cumulative Impacts

Moab MLP 128 349,823 228,918 115,663

Monticello 189 532,934 348,742 612,253

BLM Utah 9,687 6,975,421 4,449,851 39,583,936

Moab MLP 125 341,624 223,553 112,952