Thanks to Rita Beving for providing the information below about the oil and gas lease sale near Lake Lewisville. Everything you need to know to write your own letter of protest.
From Rita: Below is this “Sample Letter” for writing the BLM as a citizen. There are some things that really need to be in here to make it count and it’s all included on the sample letter:
1) Addressed to Ms. Leuders at BLM
2) Parcel # and docket
3) State that you are “protesting” the sale of the lease
4) State how you are personally affected or how you are an affected party
– Lake Lewisville provides me/my family water
– I recreate at Lake Lewisville (boat, hike, picnic, run, etc.)
– I own property near the Lake
– I am worried about the emissions and how this could affect my asthma due to poor air quality.
5) State that the parcel should be pulled – and that the Environmental Assessment does not meet the requirements of the National Environmental Protection Act.
(The last paragraph in the sample letter has very important language.)
6) You must include your name, your address, and I suggest your phone number and email.
People might want to raise other issues, but it is very important they say how they are personally impacted – and their family.
ISSUES OF CONCERN for WRITING THE BLM:
Often when you write a letter to protest a state or federal permit re: an issue such as this, you need to include certain elements in your letter for it to legally “count” for that agency’s consideration. If all the elements are not included, then they can dismiss your letter.
Though a letter has already been sent in asking for a delay of the sale, it is important that the public send in a letter of “protest” regarding the proposed lease.
If you have a copy of the Environmental Assessment (EA), turn to page 7-8 and you will see a list of questions and issues listed in the EA doc below to address:
The pdf is called: April 2016 OB Lease Sale EA_30 day public comment.pdf
The following issues are listed on page 6-7 of the Environmental Assessment (EA). The issues listed by the BLM as those they charged to examined and addressed as required by the National Environmental Protection Act. The BLM lists these issues of review including the question “What effects will the proposed action have on…the following:
- Air Pollution/contaminants
- Watershed and Water quality
- Soil loss and contamination
- Artifacts/Cultural Resources
- Spread of Non-Native animal or plant species
- Threatened/Endangered species
- Migratory birds
- Contamination of proposed lease parcel
- Climate Change
- Visual quality of the area
- Recreation area/Recreation Impacts
- State/local economies
- Minorities/Low Income Populations
Areas the BLM claim they addressed and dismissed were:
- Public Health and Safety
- Areas of Critical Environmental concern
- And others (see page 7 of the Environmental Assessment)
Bureau of Land Management
New Mexico State Office
P.O. Box 27115
Santa Fe, NM 87502-0115
February 11, 2016
Re: Protest of April 20, 2016 Lease Sale
Dear Ms. Lueders:
I am filing this Protest of the Bureau of Land Management’s (BLM) planned April 20, 2016 oil and gas lease sale and Environmental Assessment DOI-BLM-NM-040-2015-61-EA, pursuant to 43 C.F.R. § 3120.1-3.
I formally protest the inclusion of the following parcel, NM- 201603-43, covering a total of 258.9 acres. The proposed parcel is on/adjacent to Lewisville Lake.
I am filing this protest on behalf of [myself, my family, my business] . My [name] is and I live at [address/zip] and I can be reached at [phone]. My email is [email].
[there needs to be a statement here as to the person’s interests—e.g., I live near the Lake, I am a property owner here, I visit the Lake on the weekends, I live in Highland Village (or Denton) and my water comes from the Lake…etc.]
The reason I feel I am an affected party by the auction of the 10-year mineral lease on the property is due to the following [concerns]:
1) Highland Village obtains its drinking water supply from Lake Lewisville and public water wells near the lake. I am worried about the contamination of our drinking water through possible drilling runoff from the site. The possible migration of contaminants through our aquifers could also impair our public water wells.
2) I am also concerned about the potential for increased seismicity from added drilling in and around Lake Lewisville. The Lewisville dam is currently under repair after a 161-foot long, 23-foot wide slide on an earthen embankment this past spring. Additional drilling or the migration of drilling fluids along existing fault areas below the lake could negatively impact the integrity of the dam’s infrastructure.
The Environmental Assessment for this proposed lease sale is substantially and procedurally flawed. There was no analysis of how drilling, fracking, or wastewater injection could impact the Woodbine, Trinity or Paluxy aquifers in relation to this parcel. The EA does not address the soils or the geology regarding this Lake Lewisville parcel along with other important issues. Therefore, BLM’s offer of this parcel is unlawful as it fails to sufficiently address the above issues as required by the National Environmental Protection Act (NEPA). Please pull this parcel from the April 20 auction. Do not put my family’s water, health, and well-being at risk.
[Name – Include Complete Address/Phone/Email]
OTHER ISSUES TO RAISE IN YOU LETTER
AIR POLLUTION – Denton county is is designated as “serious” as part of a 10-county nonattainment area for not having healthy air under the federal Clean Air Act. In early 2015, the EPA took public comments regarding elevating the 10-county DFW area to “severe.” Any drilling air emissions will only add to our unhealthy air quality.
In DFW during summer months, the wind primarily blows from southeast to northwest any pollution could impact the Denton airport monitor, which has the worst air pollution readings consistently in our region.
If you have someone in your family whose health may be impacted ie. asthma by oil and gas operations on this parcel, feel free to address that.
LOCAL ECONOMICS – If your business or the city’s local economy may be impacted should this parcel be contaminated, etc. feel free to mention that.
WATER POLLUTION – A 2015 peer-reviewed study by Dr. Zachariah Hildenbrand and others, “A Comprehensive Analysis of Groundwater Quality in the Barnett Shale” gives indications that fracking compounds have been detected in water samples near wells sites in an analysis of more than 500 samples in the Barnett shale. Some of this sampling was done in Denton county.
SOIL/DAM IMPACTS– A 2013 presentation by Anita Branch of the Army Corps of Engineers identified new issues of concern in the relationship to dams and drilling. These issues include induced seismicity (earthquakes), the transmission of fracking fluids outside the target zone via natural faults underground, and the disposal of flowback water raising the potential for ground and surface water contamination.
The presentation by the Corps further added that “[e]rosion of the embankment along existing faults located in the foundation, abutments or outlet works [that] could lead to project failure… [and] an uncontrolled loss of pool or flood storage.” In other words, a breach in a dam.
RECREATION IMPACTS – If you recreate, run, or boat at Lewisville Lake, feel free to discuss how the impacts that drilling on this parcel could negatively impact you and your family’s ability to recreate.
WILDLIFE/MIGRATORY BIRDS – The whooping crane and the least interior tern are on the endangered species list and have been seen on Lewisville Lake (see DFW Urban Wildlife website)
CLIMATE CHANGE – The lifecycle of natural gas drilling heightens the effects of climate change. From the clearing of the well pad to drilling, fracking, storage and combustion, we do not need to add to this problem.
Methane is 86 times more potent than carbon dioxide. It is a trigger for the creation of ozone- and is hazardous to human health.
A July 2015 study, “Come Heat and High Water: Climate Risk in the Southeastern U.S.” found that Texas will be one of the states most negatively impacted by climate change by mid-century absent any changes. The study forecasted more hot days, heat-related deaths, sea rise along Texas shoreline, and an annual storm damage increases of at least $650 million due to increased storm related loss and damage along the Texas coast.
COPY CONGRESSMAN MICHAEL BURGESS
You may want to copy Congressman Michael Burgess on this letter and ask him to send a letter of protest or ask the BLM to pull this parcel by copying his staff on your letter:
His staff contacts include:
Kelle Strickland – DC Chief of Staff
Erik With – Local District Chief of Staff
Melanie Torres- Director of Constituent Services