Gaia Ki
"in balance with the life force of this living Earth"
Earth is not ours to 'own'
we are here but in passing
a dance in a dream...
Earth belongs to
Nature's myriad life
& future generations
yet to be born...
Asante Riverwind
Conservation & Arts Director
541.390.2957
asanteriverwind@gmail.com
Gaia Ki
P. O. Box 5534
Bend, Oregon 97708
Founded July 22, 2010
Helping bring meaningful
change & environmental
protection through community
education, inspired arts,
wildlands adventures, and
legal aikido advocacy ~
reconnecting human societies
as part of the wondrous nature
of this living Earth.
P.O. Box 5534
Bend, Oregon 97708
asanteriverwind@gmail.com
November 18, 2010
Newberry Geothermal Project,
Bureau of Land Management,
Deborah Henderson-Norton, District Manager,
Linda Christian,
Prineville District Office,
3050 NE 3rd St.
Prineville, OR 97754
OR_Newberry_EGS_Project@blm.gov
Deschutes National Forest
Shane Jeffries, District Ranger, Bend-Ft. Rock Ranger District
Molly Chaudet,
comments-pacificnorthwest-deschutes-bend-ftrock@fs.fed.us
comments-pacificnorthwest-deschutes@fs.fed.us
Newberry Geothermal EGS Project Scoping Comments
Our organizations have reviewed the BLM public notice for
the proposed DOI-BLM-OR-POOO-2011-0004-EA responding to the
"Notice of Intent to Conduct Geothermal Resource Exploration
Operations" submitted by Davenport Newberry Holdings LLC and
AltaRock Energy Inc. proposal "to develop and test an enhanced
geothermal system (EGS) reservoir on the western flank of Newberry
Volcano." Jointly these comments are submitted by the League Of
Wilderness Defenders - Blue Mountains Biodiversity Project,
Cascadia Wildlands, Gaia Ki, and the Juniper Group Sierra Club.
Our organizations members and supporters regularly use the greater
Newberry Project area, including the adjoining Newberry Volcanic
National Monument for natural recreation, ecological study, wildlife
watching, scenic vistas, and conservation efforts. The proposed and
ongoing geothermal exploration, seismic testing, leasehold activities,
EGS development, and inextricably related potential for an industrial
scale geothermal energy production facility individually, directly and
cumulatively adversely affect our four organizations including our
considerable members and supporters throughout this region, and
throughout this nation.
We include the accompanying DVD exhibits as part of these
joint comments on the proposed EA. We herein incorporate by
reference all previous comments, appeals, and communication on
proposed geothermal exploration, testing, development, and leasing
related to this proposed project. As the BLM letter concerning this
projects notes its incorporation by reference of related geothermal
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analysis both for various phases of Newberry area projects, as well as the national Programmatic EIS and
ROD for geothermal leasing (BLM-WO-GI-09-003-1800), we also herein incorporate by reference the
public record for all of these related geothermal analysis projects and decisions, including prior
comments, appeals, and exhibits in their entirety submitted on behalf various conservation organizations
and the Sierra Club.

NEPA Analysis Issues and Recommendations

Analysis Segmentation Fails to Comply with the NEPA
The current proposal to conduct yet another piecemeal environmental analysis represents a
continuing pattern of improperly segmented, narrowly developed myopic Environmental Assessments for
each sequential phase of inextricably connected subprojects motivated by and focused on the eventual
private commercial development of industrial-scale geothermal energy production in the Newberry area.
Previous segmented phases include:
 BLM issued an October 26, 2007 decision on the "Newberry Geothermal Exploration Project
EA";
 BLM issued an April 29, 2010 decision on the "Drilling, Testing, and Monitoring of Temperature
Gradient/Passive Seismic Geothermal Exploration Wells EA";
 the Deschutes National Forest has begun analysis on the "Geothermal Consent to Lease Project
EA," initiating a public scoping comment period culminating in July 2010 (with analysis
apparently ongoing, awaiting the forthcoming EA's public review and comment prior to another
segmented decision directly affecting the Newberry Project);
 and the Dept. of Energy (DOE) issued a July 19, 2010 public notice soliciting comments on their
"Supplement to the Cumulative Impacts Analysis of: Drilling, Testing, and Monitoring of
Temperature Gradient/Passive Seismic Geothermal Exploration Wells."
 Meanwhile, the DOE has also disclosed that they are in the process of awarding $5 million in
federal renewable energy development funds to Newberry Geothermal/Davenport Power for the
temperature gradient/passive seismic exploration wells, and are also awarding an additional $20
million to Newberry partner company AltaRock for experimental hot dry rock Enhanced
Geothermal System (EGS) production development. The Department of Energy's award of energy
stimulus funds of $5 million to Davenport/Newberry and $20 million to AltaRock has begun
absent a legally credible publicly meaningful environmental analysis process, representing a
significant breach of federal environmental policy laws and public trust.

The BLM notice requesting public scoping comments by Nov. 22nd on the Newberry Geothermal
EGS Project represents the 5th myopically segmented NEPA analysis for the same related geothermal
energy development project. The initial 2007 Newberry EA Decision has now generated a series of
sequential and simultaneously overlapping analysis projects, agency management actions, and
implementation activities - for the same essential Newberry Geothermal Energy Development Project -
that have yet to be publicly analyzed in one requisite legally compliant comprehensive NEPA analysis
process.
BLM and USFS officials previously have stated that each of these segmented analysis projects
instead represent wholly contained projects, not dependent upon or unduly influencing subsequent
Newberry geothermal plans and related analysis. However, such claims fail to match reality. For example,
at a recent public presentation involving representatives of DOE, BLM, USFS, Newberry
Geothermal/Davenport, and AltaRock, the issue of continuing costly geothermal exploration, EGS
demonstration, and future development at the current well site 29 was discussed. Exploration activities at
this well site have degraded scenic qualities from Newberry National Volcanic Monument's Paulina Peaks
and Rim trail viewpoints. If an industrial scale geothermal energy facility were constructed at this site, its

2
location would irreparably damage the natural quality of the forest adjoining the monument, and
permanently degrade scenic qualities. Yet there are other existent but largely undeveloped leases
throughout much of the adjoining public lands on all sides of the Monument, some of which may be better
suited to protecting scenic views, forest ecosystem integrity, and wildlife habitat qualities. However,
consideration of moving geothermal development activities to other lease sites where degradation of
natural resource qualities are of less priority concern was dismissed as infeasible by both industry and
federal agency officials, due to the substantial economic and resource investments already made at well
site 29. Such sequential but inadequately addressed impact consequences, that preclude future resource
options and chart a piecemeal course for the irretrievable commitment of public resources, are exactly
'why' NEPA forbids the segmentation of connected projects and actions.
We herein remind federal agencies and private enterprises that we have previously addressed the
consequences of their failure to first conduct a proper comprehensive NEPA EIS analysis for all of these
connected Newberry geothermal energy projects. We previously cautioned against implementing this
project piecemeal, absent comprehensive foundational analysis and meaningful community involvement.
We have warned the companies involved that investing financial resources and considerable time
exploring geothermal potential in locations that ultimately may prove environmentally unsuitable for
industrial geothermal production could result in significant economic loss. We again remind the federal
agencies responsible for charting the course of this analysis of their responsibilities under federal law,
including the APA, NEPA, NFMA, ESA, CWA, FLPMA, Oregon State laws, and treaties. We sincerely
caution against further continuation of any and all parts of this geothermal energy development project
before completing the requisite NEPA analysis on all of its related phases.
First and foremost, the EIS must establish a legally credible environmental impacts analysis basis
for the Newberry area geothermal leases, many of which were issued absent proper public NEPA
analysis, well-before the actual impacts of industrial scale geothermal energy development were
sufficiently known and understood. Second, before re-authorizing geothermal leases in this area, the EIS
must publicly assess and reasonably determine if industrial geothermal development is compatible with
the public's best interest for natural resources in close proximity to Newberry Volcanic National
Monument (NVNM). To accomplish this foundational step, the EIS must fully disclose and address the
known and foreseeable direct and cumulative impacts of industrial scale geothermal energy development
and production in this vicinity. Third, upon this factual impacts basis, the EIS must address the potential
withdrawal of some or even all of the current geothermal leases dependent upon analysis findings. If some
lease locations are considered compatible with natural resource and Monument qualities, the EIS must
determine which of these are more suitable for geothermal development, and prioritize these for the
various phases of exploration, testing, demonstration projects, and potential energy development. The EIS
must similarly consider precluding geothermal development in lease locations - such as site 29 - where
development impacts irreparably degrade highly valued natural, scenic, and recreational qualities both
within the Monument, along nearby Paulina Creek, and within adjoining forest habitats. Fourth, once the
community, through a comprehensive public EIS process has been meaningfully involved in such
determinations, the EIS must address the permissible environmental parameters within which current
lease holders may operate, establishing standards of oversight and responsibility that effectively protect
the natural environment, the NVNM, and affected area communities (including aquifers, residences, and
popular recreational areas). Only once such responsible comprehensive analysis steps have been
completed, would a legally founded geothermal plan of exploration and possible development be
permissible.
Instead of acknowledging such legal responsibilities, BLM, DOE, and USFS plans to date
represent a legally non-complaint series of short-sighted improperly segmented assessments, with
contrived predetermined conclusions and decisions tailored to match the criteria of private commercial
enterprise gain. Piecemeal geothermal analysis to date fails to uphold these agencies legal and ethical
responsibilities to protect the public interest and the natural environment.
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Segmentation
The Newberry Geothermal project is being improperly segmented piecemeal from its inextricably
connected driving objectives and incremental actions. Myopically segmented piecemeal analysis violates
the requirements of the NEPA:
 The failure to comprehensively address significant connected irretrievably resource
impacts;
 The failure to address cumulative impacts issues of connected reasonably foreseeable
actions;
 The current proposal for additional Newberry geothermal EGS development is clearly a
connected action with overall motivating objectives to locate and develop resources that
will enable the development of a commercial industrial-scale geothermal electrical energy
production plant within Deschutes National Forest public lands adjoining Newberry
National Monument;
 The agency may not segment connected analysis processes piecemeal, separating each
connected phase and myopically addressing only the incremental impacts of each separate
action. Segmented analysis fails to disclose and address the full environmental impacts of
these connected and reasonably foreseeable actions, including the impacts of an industrial
energy production plant in affected site locations. By incrementally segmenting the
Newberry geothermal project analysis, the requisite foundational information will not be
available for inclusion in assessing the overarching irretrievable resource commitments and
cumulative impacts. NEPA requires that connected and cumulative impacts of past,
present, and reasonably foreseeable actions be disclosed and assessed in an Environmental
Impact Statement analysis, before federal agencies may arrive at an environmentally and
legally acceptable decision.

Quite clearly, the current Newberry geothermal EGS proposal, the recently completed exploration
project (which set the location for this subsequent connected EGS proposal - and if successful, for an
industrial plant without ever addressing these direct cumulative impacts), and the associated passive
seismic and temperature gradient well testing - by the connected private ventures in the same overall
location, with the same objective of eventual commercial geothermal production (shared as well by other
lease holding ventures surrounding Newberry Monument) - are connected actions. These overarching and
foundation environmental impacts issues must be responsibly addressed in an EIS analysis for this
proposed EGS project.
Connected actions, the impacts of which must be considered in the same EIS, fall within one of
three categories: Actions that “(i) Automatically trigger other actions which may require environmental
impact statements; (ii) Cannot or will not proceed unless other actions are taken previously or
simultaneously; or (iii) Are interdependent parts of a larger action and depend on larger action for their
justification.” 40 C.F.R. § 1508.25(a)(1). Plainly the Newberry geothermal exploration projects are
incremental connected parts of the underlying objective to locate and commercially develop geothermal
energy production resources in the project area. As stated by one court: “Quite simply, „( s)egmentation of
a large or cumulative project into smaller components in order to avoid designating the project a major
federal action has been held to be unlawful.‟ Clearly, by the geothermal venture‟s own public
announcements, the proposed EGS project is a connected action to related geothermal development plans,
stemming from previously segmented exploration and well-testing phases. The existence of a
comprehensive program with cumulative environmental effects cannot be escaped by disingenuously
describing it as only an amalgamation of unrelated smaller projects. National Wildlife federation v.
Appalachian Regional Commission, 677 F.2d 883, 890 (D.C. Cir. 1981) (citation omitted).

4
Cumulative Impacts
BLM and the Forest Service are required to discuss and fully analyze the cumulative impacts of a
project. 40 C.F.R. 1508.8. “„Cumulative impact‟ is the impact on the environment which results from the
incremental impact of the action when added to other past, present, and reasonably foreseeable future
actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions.
Cumulative impacts can result from individually minor but collectively significant actions taking place
over a period of time.” 40 C.F.R. 1508.7. Recently, the Ninth Circuit has held, "[a] proper consideration
of the cumulative impacts of a project requires some quantified or detailed information; . . . [g]eneral
statements about possible effects and some risk do not constitute a hard look absent a justification
regarding why more definitive information could not be provided." Klamath-Siskiyou Wildlands Center
v. Bureau of Land Management, 387 F.3d 989, 993 (9th Cir. 2004) quoting Neighbors of Cuddy
Mountain v. United States Forest Service, 137 F.3d 1372, 1379 (9th Cir. 1998) (internal quotations
omitted).
Federal agency analysis must discuss the environmental consequences from the activities. Lands
Council v. Powell, See 379 F.3d 738, 745 (9th Cir. 2004).
The Ninth Circuit has recently held that cumulative impacts analysis must enumerate
environmental effects of related projects and consider the interaction of multiple activities. Cumulative
effects analysis must also include actions that are “reasonably foreseeable. Oregon Natural Resources
Council Fund v. Timber Products, No. 05-35063 (9th Cir 2007).

The Need for an EIS

NEPA requires the Federal agency‟s to prepare a detailed Environmental Impact Statement (EIS)
for all “major Federal actions significantly affecting the quality of the human environment.” 1 NEPA
“ensures that the agency . . . will carefully consider detailed information concerning significant
environmental impacts.” 42 U.S.C. § 4332(2)(c); 20 C.F.R. § 1502.3. To succeed in showing that the
agency has violated NEPA by not preparing an EIS, Appellants need not prove that there will be
significant effects from the project. Idaho Sporting Congress v. Thomas, 137 F.3d 1146, 1149 (9th 1998).
Rather, the Ninth Circuit held in Thomas that an EIS must be prepared if “substantial questions are raised
as to whether a project… may cause significant degradation” to the environment. Id. Further, Blue Mtns.
Biodiversity Project v. Blackwood, 161 F.3d 1208, 1212 (9th Cir 1998), held that the agency must provide
a “convincing statement of reasons” why a project will not have significant effects.
An EIS is clearly required for a proposed action of this scale of environmental significance, the
consequences of which are likely to irretrievably and cumulatively affect the natural environmental
quality of the Newberry National Volcanic Monument and surrounding public and private lands for
decades to come. The EIS public NEPA analysis must:
 Reasonably inform and meaningfully involve the public affected by the proposed action, including
recreationists, greater area residents (La Pine, Sunriver, South Bend/Deschutes River Woods,
Bend and outlying rural areas), and people whose occupations are located in the affected vicinity.
We again recommend adequate public notice be posted throughout the Monument for a
reasonable period of time (throughout the 2011 peak recreational season) to inform affected
recreational visitors and resort employees; that a notice be mailed to all residents of the greater
area; that comprehensive accurate information on this proposal and related actions, and the actual
impacts of industrial geothermal energy development and production be objectively published in
news media in the region, presented in an EIS analysis, and distributed in public notices; that
these include information on how to participate in the public process; and that reasonable

5
 advance public notification be followed by a public hearing addressing all phases of proposed
geothermal development in the vicinity of the Newberry National Monument.
 The EIS must disclose the original analysis process and the environmental impacts and issues
addressed therein for existent Newberry area geothermal leases, including all current leases
proposed for geothermal related activities. A federal appeals court decision on the Pit River
Tribes vs. USFS case in California in Nov. 2006 addressed the need for existent and proposed
leases to be based on sound NEPA analysis. Where such analysis was lacking during the original
lease determinations, and/or where additional environmental and research considerations have
since become evident, new NEPA analysis must be conducted before leases may be legally
established and geothermal activities may commence.
 New NEPA analysis for existent and proposed leases must be conducted, bringing consideration
of leases in the vicinity of Newberry Monument current with additional scientific research and
experience regarding the known and potential impacts of geothermal energy exploration,
development, and production. The EIS analysis must objectively disclose and incorporate
relevant scientific research, and abide by federal environmental policies and judicial case law
concerning leaseholds.
 Dependent on the NEPA adequacy of the original lease analysis for all leases throughout the
Deschutes and adjoining public lands, it may be necessary to conduct a forest-wide/public
landscape interagency EIS bringing all existent leases into compliance with environmental policy
laws - or terminating some or all of such leases should analysis and public process prove such
would be in the best public interest.
 In particular, the EIS must address the direct and cumulative impacts arising from this and
additional phases of the project from site 29 and other leases within close proximity of Paulina
Creek, the Monument's caldera Rim Trial, and/or within or adjoining inventoried and/or
uninventoried roadless areas.
 The EIS must address issues of open road access and public safety. Previous geothermal
exploration by Davenport/Newberry Geothermal disrupted public access along FS road 9735,
closing this road for an extended period of time, and closing additional FS roads for many
months. The analysis must accurately disclose what roads and public lands areas may be closed
or restricted to public access and use, and for how long a period of time these may be affected.
 The EIS must disclose and address the full range of relevant scientific research and known impacts
of geothermal energy exploration, testing, EGS development, and industrial scale energy
production development and operation.
 The EIS must disclose impacts resulting elsewhere from geothermal exploration, testing,
development, and operation activities. For example:
o Geothermal development in Basal Switzerland, in 2006 and 2007 had a earthquake of 3.4
followed by 60 smaller after-shocks and another earthquake of 2.5 magnitude one week
later. The project was shutdown, legal charges were filed, and claims for approximately $9
million in damages were filed.
o Geothermal development in Landau in der Pfalz, Germany shook the city with a 2.7 quake,
which resulted as well in a sonic boom.
o AltaRock Energy, one of the partners in proposed Newberry Geothermal exploration and
testing, planned to employ similar EGS technology as used in Germany and Switzerland in
a project in Geysers California. A mix of seismic activity and economic concerns
reportedly resulted in the preventive shutdown of the project in December, 2009.
o In Wiesbaden Germany on Nov. 6, 2009 a project that drilled for geothermal energy
instead flooded the Finance Ministry and a hotel, reportedly resulting in an approximate
6,000 liters of water flooding out per minute.
6
 o In addition to the above relatively recent examples, the comment and appeal exhibits
previously provided to both the BLM and USFS staff and decision-makers involved in the
previous segmented analysis phases of geothermal exploration and testing in the project
area note a number of other serious environmental impacts and human health harms from
geothermal exploration, development and/or production. In particular, we again direct
agency planners and decision makers to the report "Tapping Earth's Geothermal Energy;
Green Panacea or Pandora's Box; and to our previous NEPA comments, appeals, and
exhibits on the Newberry Exploration, Geothermal Wells, and Geothermal Lease projects
in the Newberry vicinity.
 The EIS NEPA analysis must comprehensively address inextricably related phases of geothermal
leasing, exploration, testing, development, and industrial energy production. The analysis for this
proposed action may not segment the various phases in separate environmental analysis processes,
addressing piecemeal the incremental irreparable impacts and irretrievable commitment of
resources lease designation and consequent industrial exploration and development entails.
 Geothermal exploration and development consists of industrial activities that irretrievably alter
affected areas, and as such are not compatible with traditional public use of the natural
environment as established by the Multiple Use Sustained Yield Act (MUSYA) and by the
National Forest Management Act (NFMA). Lease consideration must establish that designated
lease locations are within the public's best interest. Areas of traditional public recreation and
natural resource use must not be adversely degraded by lease activities, directly or cumulatively.
Private financially vested enterprises must not be permitted usurpation of public rights or allowed
to irreparably degrade public natural resources. Appropriate areas for lease consideration should
be located well distant from high value natural recreation areas, such as Newberry National
Volcanic Monument and Paulina Creek, and away from important wildlife habitat, waterways, and
connective natural landscapes. Lease activity areas for geothermal resources should be located
near existent transmission routes, in already degraded landscapes, nearer to similar industrial use
locations. While the greater area immediately adjoining Newberry Monument has been adversely
impacted by prior logging and road construction, this affected area is beginning to recover from
past management harms. Due to considerations of wildlife habitat, ecological integrity, scenic
vistas, and public recreational qualities; there should be no industrial conversion of public lands at
a minimum within 2 miles or more extant of the Monument's boundary, or within two or more
miles of Paulina Creek and popular recreational sites. Additionally, analysis must address lease
location impacts upon the forest landscape, including: wildlife habitat connectivity, disruption of
wildlife movement and territory patterns, introduction of invasive exotic plants, alterations of the
local natural environment, the proximity of significant local ecological or geological features, the
affects of transmission facilities and connective routes, the location of water resources and
pipeline routes, both long and short-term water usage and affects on area aquifers, and the impacts
of industrial geothermal development on forest access roads and adjoining highways.
 The EIS must disclose the extent of existent geothermal leases throughout the greater Newberry
Monument area public lands. Existent cumulative impacts resulting from past, current, and
foreseeable future geothermal activities must be disclosed and addressed. For example, there are a
number of geothermal exploration sites where past and recent impact harms to the natural
environment have yet to be restored. Some sites have been clear cut, industrially compacted, and
left dormant - put into suspension - for over 15 years, despite provisions in their previous NEPA
project analysis that sites would be reclaimed. Previous NEPA analysis failed to responsibly
disclose the length of time such sites would be left degraded upon the natural forest landscape.
During recent field trips, both federal agency and geothermal company representatives stated that
reclamation efforts have since begun at some of the old Cal Energy sites. Agency personnel also
mentioned that some of the old sump ponds and other unnatural industrial impacts are being
7
 retained on the landscape. The EIS must disclose current and planned reclamation efforts, and the
timeline for their accomplishment. The EIS must disclose the full extent of reclamation needs and
leasehold conditions. The analysis must address the rationale for retaining rather than restoring
industrial features and impacts in the forest landscape.
 The EIS must address the cumulative impacts of potential widespread geothermal lease activities
upon the natural forest environment.
 The analysis must objectively and accurately address whether and how exploration sites that have
been clear cut, industrially leveled, and severely compacted by extensive heavy machinery use
may ever be sufficiently reclaimed and restored to function as natural forest, or whether such sites
are more likely to remain in a permanently degraded unnatural state for many decades to centuries.
 The NEPA analysis must develop provisions that effectively protect the integrity of the Newberry
Volcanic National Monument in its entirety, and protect Paulina Creek and popular recreational
areas as well as ecologically important native species habitat and overall forest environment
quality and connectivity.

Questions to be Disclosed and Addressed in the NEPA Analysis:

1. What are the range of impacts from EGS elsewhere?
2. What comprises the content of drilling muds, fluids, and lubricants?
3. What chemicals, compounds, minerals, and other ingredients exist in current and previous
Newberry geothermal sump sites, and may be found in planned sump sites?
4. What are the types, methods, and impacts of the planned hydro-fracking or hydro-shearing?
5. What additives to pressurized water may be used - such as chemicals, hydro-fracking/shearing
enhancing compounds, sands, silica, ceramic beads, plastic or other beads?
6. What are the chemical and element ingredients in the "biodegradable" plastic beads planned for
use in the Newberry EGS project?
7. How may waters, fluids, plastic beads, and other substances utilized combine with existent
naturally occurring environmental toxins, heavy metals, gases, and other subsurface compounds
found within geothermal brines?
8. How will known and potentially hazardous substances, ingredients, and affected waters used
and/or generated by the planned EGS activities be addressed?
9. What direct and cumulative impacts may the project have upon area aquifers?
10. What are the range of potential direct and cumulative affects to the Paulina Creek water system,
water source aquifers, community wells, and affected area soil hydrology?
11. What total quantities of water will the project require, including the range of potential depletion
rates, replenishment, and additional water needs over time?
12. What will be the duration of various periods of atmospheric venting, including the venting of
potentially toxic geothermal steams (such as the duration of venting periods during initial EGS
and/or other well development and testing, and during possible plant development, maintenance,
and expansion over time)?
13. What chemicals and toxins are found in geothermal steams in other existent locations, and what
may be found in geothermal steams in the Newberry location?
14. What is the prevailing wind direction from the proposed geothermal site with regards to the
National Monument, human residences, and recreational areas?
15. Will federal agency's require the use of pollution abatement scrubbers to capture emissions rather
than allowing open atmospheric venting?
16. What are the compositions of fluids and gases found in current and previously drilled geothermal
test wells in the greater Newberry area?
17. What are the types, depths, and ranges of geologic strata found in the current and previously
drilled Newberry vicinity geothermal test wells?
8
 18. What are the known and potential geologic faults existent in the Newberry project vicinity?
19. What regional faults exist in the greater area, and what may be the interconnections of general and
localized Newberry faults and fractures with these?
20. What regional seismic and volcanic activities have occurred during recorded history? What
seismic events have occurred within a 100 (or more) mile radius of the Newberry project area
during this century?
21. What is the volcanic and geologic event history of the greater Newberry region?
22. What are the ranges of induced seismic activities, other related events, and impacts that have
occurred from geothermal exploration, development, and/or production elsewhere (such as those
noted herein above)?
23. What are the induced seismic activity threshold levels above which proposed activities will be
halted? What protocol will be employed in addressing seismic activity issues?
24. What are the range of risks to recreational hikers and visitors to Newberry Monument and Paulina
Creek from seismic generated rock and/or debris falls and/or landslides in trail, off-trail, road, and
campground locations?
25. How will the proposed project address issues of site visibility from the National Monument's
Paulina Peaks scenic viewpoint, and from other areas within the Monument (such as the Caldera
Rim Trail)?
26. What are the ranges and duration of noise and disturbance generated by the project and its
concurrent and likely future connected actions?
27. How many acres of lineal clearcuts will be needed for overhead power lines to reach the current
proposed activity site if it becomes a power plant? Would power transmission lines from this
location connect with existing lines?
28. What would be the range of potential transmission capacity needed, what would be the range of
corresponding EMF levels and impacts, and the range of corresponding transmission line ROW
maintenance activities needed?
29. What are the premised electrical power needs for this project? What are the projected power costs
comparative to existent power sources? What are the projected power generation capacities in
comparative ratio to exploration investment and development costs and impacts?
30. What % of projected power would be supplied to what locations in California, to meet what power
needs? What % of generated power would be utilized elsewhere for what primary purposes?
31. Comparatively, how would the implementation of effective energy efficient conservation
measures reduce current and projected energy use needs? How would economic investment
comparable to that required to develop and implement Newberry, utilized instead to develop
energy conservation and efficiency, affect current and projected energy use needs and patterns?
32. In comparative ratio, how does reducing energy use affect the measurable levels of societal
carbon/climate change impacts compared to contributing to current and projected regional energy
use levels by developing and operating a new geothermal power plant in the Newberry area
(taking into account the full range of resource uses involved in developing a new power plant
comparative to the full range of conservation potential that can be achieved)?

Societal Imperatives
Contemporary industrial society remains apparently entrapped on an exponentially progressive
course of unsustainable growth and consumption, irreparably altering interwoven regional and global
ecosystems, diminishing the natural biodiversity and abundance of life on Earth. Scientific research
emphatically emphasizes the need to reduce societal impacts, protecting existent natural areas from
further development incursions. Recent research demonstrates the importance of our region's forest
ecosystems in offsetting climate change, through forest and soil community carbon sequestration, while
helping maintaining core areas of abundant biodiversity and imperiled species habitat.
9
 The greater Newberry area, including the National Monument and adjoining forestlands, is an
ecologically rich territory, critically important in maintaining the ecological integrity of our region.
Plans to develop the Newberry Geothermal Project would expand industrial societal impacts into
currently more remote forest locations. The corporate industrial tentacles reaching to develop Newberry
span from distant locations, supporting the profiteering venture of Connecticut-based Davenport Power,
and the unsustainable energy consumption of California industries and urban conglomerates. Regionally,
within the greater Newberry vicinity, there exists no actual need for additional electrical power. Yet there
does exist an imperative need to restore available waters to degraded salmonid watersystems, and to
provide for the protection of forest habitat and the recovery of the area's over 200 species of concern.
Contemporary society has yet to effectively begin addressing energy use levels and environmental
impacts. Implementing energy efficiency and conservation measures remains largely to be accomplished,
with only minimal inconsistent voluntary efforts yet begun. It is doubtful that the impacts of the Newberry
Project are justified, in light of the ecological significance of the Newberry Monument area and the latent
but as yet unrealized imperative potential of reducing energy use needs across the nation (including the
California use-area for projected Newberry power). While the development of geothermal energy may
play a significant role in replacing some current environmentally harmful power sources, such as coal and
nuclear, it is important that pioneering geothermal proposals not result in compounding one set of
ecological harms with additional new harms.
Federal agencies have yet to responsibly assess which locations on public lands (or private lands)
are best suitable to additional resource development, including geothermal energy - and which locations
have environmental qualities warranting protection from the impacts of such development. In the greater
region, there are many possible locations where geothermal development could be far more suitable than
the currently proposed Newberry location. Additionally, as power needs are located far distant in
California, it is more environmentally appropriate to first consider locations in closer proximity to
resource needs. To date, responsible federal agencies have failed to represent the public's best interest by
conducting such analysis - as a prerequisite to considerations of where and how geothermal or other
energy resources may be developed on public lands. Despite the expenditure of private and public funds
and resources, the Newberry Project remains unfounded, premised on private enterprise profit objectives
rather than natural resource suitability and public interest.
Geothermal energy has a range of known and potential harmful impacts that vary on scale in par
with the level of industrial energy production development planned. Small scale localized use of direct
geothermal heat (such as exists at Klamath Falls and Breitenbush) generally has little significant impact
harms. In the Newberry area, geothermal heat sources could potentially be developed on such a small
scale level, providing heat as well as sauna facilities at resort and campground locations. Hot springs in
the area are popular public recreational locations already. These would be largely unaffected by limited
small scale direct use development in resort locations. Such limited development may not result in
appreciable environmental impacts, yet public agencies fail to address this consideration, and fail to
acknowledge the diminishment of such future opportunities that may result from commercial industrial
geothermal development instead. Hot springs and other naturally occurring geothermal resources, for
example, have been shown to be depleted by industrial scale geothermal development
Exploration and development for large-scale industrial energy production is accompanied by an
inseparable litany of environmental and human health harms and concerns. These concerns and impacts
must be fully disclosed and addressed in the analysis for this proposed action. An interagency EIS is
requisite for this project, not another piecemeal repetition of improperly segmented myopically focused
"analysis" that already has a foregone conclusion. We herein refer project planners to the accompanying
DVD of our comment exhibits, which include the appeals of the BLM Newberry and Geothermal Wells
projects, our previous comments on these projects, and supporting research, reports, articles, legal rulings,
and other relevant documentation. We request that these comments and our full exhibits be meaningfully

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disclosed and addressed in the NEPA analysis for this proposed action. Please contact us directly if you've
any questions or clarifications, thank you.

For Life in Balance with Nature,

Asante Riverwind,
Conservation & Arts Director,
Gaia Ki
P.O. Box 5534
Bend, OR 97708
asanteriverwind@gmail.com
http://gaiaki.wordpress.com/
541.390.2957

Karen Coulter, Director,

League Of Wilderness Defenders – Blue Mountains Biodiversity Project
27803 Williams Lane
Fossil, Oregon 97830
(541) 468-2028 office or 385-9167 voice mail

Josh Laughlin
Campaign Director
Cascadia Wildlands - we like it wild.
www.CascWild.org -
PO Box 10455
Eugene, OR 97440
(541) 434-1463

Marilyn Miller
Conservation Chair
Juniper Group Sierra Club
P.O. Box 6376
Bend, Oregon 97708
(541) 389-9115

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