Date: July 8, 2011


Attn: Bald Hill Federal Unit,

3028 E. Main St.,

Canon City, CO 81212 or

faxed to 719-269-8599

FROM: Doris and Larry LeDue, Members of The South Park Coalition, Inc.

PO Box 221, Como, CO 80432. Tel 719-836-4804


REFERENCE: Draft Environmental Assessment for Park County November 2011 Mineral Lease Sale

Dear RGFO,

Please find several comments regarding the EA. We believe that the aggregation of these issues are more than sufficient to warrant a comprehensive Environmental Impact Statement. The Environmental Assessment on each individual parcel is not adequate.

The current EIS for this area is extremely outdated. I believe it is a Resource Management Plan / EIS from 1994.

BLM's bonding requirements are minimal and need to be updated to reflect current values.

Air Quality. What are the controls in place to prohibit venting and flaring of methane into the environment? This practice contributes highly to green house gases. Also burning it is wasting it and the royalties that it could pay!


What are the controls in place to prohibit open pits?

What controls are in place for the fluid recovery and recycling of it?

How many acres are underlain by the Niobrara? Could it be as many as 300,000? The potential for industrial scale development and its impacts are unknown and need to be evaluated. The Federal Bald Hill Unit, being the first unitized area, serves as a vehicle for initials studies before damage occurs. I believe it is the BLM’s responsibility to look at the big picture.

Quantity of water. What is the water requirement of this sort of mineral development?


Quality of Water.

What are the underlying formations and how do they flow to Antero, Spinney and Eleven Mile Reservoirs?

What about the connection to the Middle Fork and the South Fork of the South Platte River?

What are the similarities with other areas that have been heavily developed? Have the deep water aquifers been contaminated?

This area sits on one of the oldest, non-contaminated aquifers in Colorado.

What about the Radioactivity? A factor that should be extensively studied is that Uranium is highly present and due to the fractured nature of the formations it will more than likely to migrate to the streams, fens, reservoirs, etc. The process of hydraulic fracturing produces such high volumes of fluid under such high pressure that it is only logical that migration will occur.

Geologic Formations.

Isn’t this area highly faulted naturally? Further research into the Elk Horn Fault and the structure of the Niobrara are needed.

What about the potential for seismic activity? 


We have heard over and over again that there is no damage as a result of Hydraulic Fracturing and we are very strong believers that there has been and that the BLM has the obligation to study this issue further and obtain the evidence required to expose the truth

A re view of the royalties that are paid needs to occur.No further leasing should occur until the potential is established. In this way the Public can obtain the highest value for its natural resource.

South Park has some of the most important fisheries in Colorado. The impact of full scale Oil and Gas Development could be devastating. Perhaps an EIS would find that the loss would be unacceptable? We cannot know for sure unless a full EIS is performed.

The cumulative negative impacts to wildlife, wildlife habitat and the unique qualities of the JMJSWA need to be addressed a part of the Environmental Impact Statement. The Division of Wildlife has gained experience from other impacted areas of the state.


Sale of these lease and full scale development will impact Denver and Aurora water supply.  They are also located near the South Platte River seven miles upstream of Aurora’s Spinney Mountain Reservoir.  Denver’s Eleven Mile Canyon, Chessman, Waterton Canyon/Strontia Springs, and Chatfield Reservoirs are also downstream, as are South Metro’s South Platte and Reuter-Hess Reservoirs

Lease Stipulations should require the use of Green Fracking Fluids.

Lease Stipulations should require base line water testing and that if damages were to occur they will be covered by the Industry. That is, remove the loophole where they are able to buy the silence of a victim

In Conclusion:

The way of life in South Park is heavily steeped in Ranching, Tourism, Historical Preservation, Pre-historic Archeological finds, Vistas, Hunting, Fishing, Camping, 2nd Homes not to mention residents and ranchers whose way of life is dependent on clean water and air.

Please use the rules and regulations of your agency for the protection of the South Park Heritage Area. It is truly a place that is worth protecting for everyone’s enjoyment. Colorado law may favor the development of oil and gas, but his does not mean that the BLM can turn a blind eye to insuring responsible safeguards.

At the BLM National Public Hearing in Golden on April 25th, one of your officials from DC stated that it is the policy of the BLM to be “Smart before we Start”. Please see that South Park, Colorado becomes your model for this slogan!

Thank you.

Doris and Larry LeDue

PO Box 221

Como, CO 80432

Members South Park Coalition