Wild Earth Guardians have submitted a powerful petition calling on BLM to do a programmatic Environmental Impact Statement assessing climate and non-climate impacts (costs and benefits) of its oil and gas leasing program. Great work! Check it out for important legal arguments on cumulative climate- and non-climate impacts of o&g leasing, which must be considered but cannot be considered at the Unit or parcel levels. The FS must do a Forest-wide EIS to assess such impacts on SE Ohio and the Wayne! 1-16
Please send comments to the Wayne National Forest (WNF) and Bureau of Land Management (BLM) to oppose leasing any Wayne land for fracking. Comments on plans for the Marietta Unit were due 1-22-16. But, although that comment period is technically closed, we have been told that late comments will be accepted, and since the comment period was for the Marietta Unit and the other units have not had formal comment periods, feel free to keep those comments coming in!
Write: firstname.lastname@example.org. Please cc Tony Scardina, National Forest Supervisor, email@example.com (Wayne NF 13700 US Highway 33, Nelsonville OH 45764). Include RE: DOI-BLM-Eastern States-0030-2016-0002-EA. Note that comments will be public. A few key issues:
- The Marietta Unit must not be a sacrifice zone! Please object to the Wayne illegally opening up our Forest to fracking, with its vast consumption of water and production of toxic, radioactive waste, air pollution, industrialization of our region, and significant exacerbation of climate change.
- The BLM and WNF have no business considering fracking the Wayne until the Wayne evaluates potential impacts at the forest-wide level. Doing this legally obligatory research will make it abundantly clear that fracking will have significant negative impacts on our community’s air, water, and local economies as well as on the climate and therefore must be rejected. District-wide or site-by-site assessments cannot evaluate these cumulative impacts, which under the National Environmental Policy Act (NEPA) must be evaluated in a Forest-wide Environmental Impact Statement (EIS) due to their significance, scale, and intensity.
- In order for the BLM to consider leasing mineral rights under the Wayne, federal law requires that the Forest Service (FS) first consent. We demand that the FS withhold consent because the FS can take action on proposals with significant potential impacts (on the Forest and human community surrounding the Forest) only if the action is in accord with the Forest’s Plan. Fracking was not evaluated in the most recent Wayne Forest Plan, done in 2006.
- The Wayne’s inadequate 2012 Supplemental Information Report (SIR), undertaken after community opposition got the 2011 lease sale canceled, is not a NEPA-based evaluation and cannot legally substitute for one. The FS must undertake a full NEPA-based environmental review of fracking on our forest, our community, its economy, and the climate before considering consent. This review must consider all the new information from peer-reviewed studies, the EPA fracking study (not the misleading statements about its conclusions), NY’s evaluation that led to its statewide ban, and incident reports of explosions, fires, and toxic radioactive releases that have occurred at frack sites and frackwaste operations in Ohio and elsewhere, contaminating air and water and threatening drinking water supplies. (Note especially the weeklong fire of chemicals and waste at a Monroe County frack pad and the Kleese injection well release that killed an entire pond ecosystem in Vienna Ohio.)
No Wayne District is okay to frack. No compromise, no sacrifice zones, no Consent! More extensive talking points here and sample comments here. And another here: Groff BLM Public Comment Letter re Wayne, complete with relevant photos.
And note Washington Post on the SOTU:
In the coming days, the White House is expected to announce a proposed regulation to limit emissions of greenhouse gases from oil and gas operations on federal land.
Obama suggested that the world had moved beyond the debate over climate change, despite a large caucus of skeptics in Congress.
“Look, if anybody still wants to dispute the science around climate change, have at it,” he said. “You’ll be pretty lonely, because you’ll be debating our military, most of America’s business leaders, the majority of the American people, almost the entire scientific community, and 200 nations around the world who agree it’s a problem and intend to solve it.”