Comments on the Little Snake Draft RMP

I reviewed the alternatives for the Little Snake Draft RMP, and I urge the adoption of Alternative D. Alternative B is completely unacceptable in that it completely disregards citizen-proposed wilderness areas that have been in place for many years, and imposes virtually no restrictions on destructive cross-country OHV use. Alternative C (BLM’s preferred alternative) goes a long way towards recognizing the citizen-proposed wilderness areas, but falls short in the key area of Vermillion Basin. In 2001 the BLM determined that Vermillion Basin possessed significant wilderness character, and the Colorado Environmental Coalition has designated Vermillion Basin as a Citizen-Proposed Wilderness Area. Only Alternative D would completely preserve the wilderness character of Vermillion Basin. All other alternatives allow for at least some oil/gas drilling within the basin, which would at the very least impair the wilderness character and at worst completely destroy it. Any drilling within the basin would be accompanied by roads, which would increase erosion on already fragile areas, provide openings for invasive weeds and permanently prevent wilderness designation for Vermillion Basin. I urge the BLM to stand by its 2001 decision to manage Vermillion Basin for its wilderness character, and to close it to oil/gas drilling. Only Alternative D accomplishes this, and so that is the only alternative I hope to see BLM adopt.

Recognizing the economic incentive and national directives that exert pressure to allow increased oil/gas drilling, I see a compromise that could allow both full wilderness preservation and full mineral extraction in Vermillion Basin. Wikipedia lists a directional drilling operation in England that extracts oil 6 horizontal miles from the drill pad. There is no area inside Vermillion Basin that is more than 6 miles from private property or areas which allow drilling, even under Alternative D. Why not keep a directional-drilling option open? Directional drilling technology improves every year, and costs continue to go down. While the limit is 6 miles or less this year, it may be 10 miles next year, and 20 miles the year after that. There are numerous geologic factors influencing local directional drilling potential, but due to economic incentives, people are finding solutions to these limitations all the time. It’s a fact that directional drilling is more expensive than vertical drilling, but it’s also a fact that the oil companies made record profits in 2006. I don’t think it’s too much to ask that some of that profit goes into making sure the land isn’t destroyed by roads and drill pads. Federal land is rightfully the property of all Americans, and it should not be despoiled for the short-sighted profit of a select few. Therefore, if Vermillion Basin were designated as a No Surface Occupancy (NSU) area, no surface drilling operations would be allowed inside the basin, but the option to extract oil/gas via directional drilling from adjacent areas would remain open. This seems like a reasonable compromise to me, and perhaps it could be worked into Alternative D.

Sam Cox