O&G Threat to National forests

Public comment is being accepted until Nov. 2, 2020 regarding a proposed policy change that would expedite the process of granting drilling permits in our National Forests. This is important because it will potentially affect federally managed forests across the nation, including many in our own state, and yet a preliminary comment period, which took place a year ago, garnered only 91 comments. Below is a sample letter followed by instructions for how to access the government website that will give you more information about the proposed policy change and allow you to submit your own comment.

I live in Fort Collins, Colorado.  For more than a month, the air quality here has swayed back and forth between poor and dangerous.  My husband made a trip to the ER because of shortness of breath.  My daughter and son-in-law check air quality reports before taking their infant son out for a walk.  We are stuck inside our homes because we are stuck between two major sources of air pollution:  wildfires in forests to the west and ozone producing fracking operations to the east.  The proposed rule is likely to exacerbate both of these threats to the “public interest.”

The proposal states:

It is in the national interest to promote clean and safe development of our Nation’s vast energy resources while preserving the surface resources of national forests and grasslands.

This statement, if applied to oil and gas extraction, is an oxymoron.  Living in a region that has been intensively exploited by hydraulic fracturing, I am acutely aware of the fact that it is a process that is never “clean” and that is frequently dangerous and destructive.  Spills, leaks, unexpected releases of toxic emissions, fires and explosions are frequent occurrences even while industry representatives assure the public that they are applying extreme caution and best practices in all their operations.

A policy that attempts to subsume permits for drilling in National Forests under the more generalized process for BLM lands ignores the distinctive nature of forests.  In addition to providing recreation and habitat for wildlife, forests absorb carbon, regulate climate, and are critical for maintaining water resources.

We have wildfires to the west of us and to the north of us.  As of September 25th there were 1,500 wildfires currently active across the western united states.  There is a connection between these fires and oil and gas extraction—climate change.  The consequences of excessive reliance on fossil fuels are negatively impacting our lives today.  Continued dependence on oil and gas does not line up with increased “national security.” What we need are policies that protect our National Forests from the private exploitation that is robbing the general population of our most important national resources: clean air and clean water.

Once the fires are extinguished and air quality improves, we will then have to worry about our water supply.  The mountains, where many of these fires have been burning, is our watershed.  Denuded hillsides are susceptible to erosion.  The water never has a chance to sink into aquifers; it races away and leaves land that is already stressed by drought without the water we need to drink, to grow crops, to survive.

According to the proposed rule:

Section 2 of E.O. 13783 directs agencies to review existing regulations that potentially burden the development or use of domestically produced energy resources and appropriately suspend, revise, or rescind those that unduly burden the development of domestic energy resources beyond the degree necessary to protect the public interest or otherwise comply with the law.

The production and use of domestic energy resources has not been “unduly burdened.”  Quite the contrary.  This is an industry that has been coddled and that burdens the public by refusing to assume responsibility for the negative externalities it has imposed on society and the economy.  It is an industry that has burdened tax-payers with subsidies.  It has burdened the public with negative health impacts, with the pollution of our air and water, with abandoned infrastructure that will impose risks well into the future as pipes corrode and cement deteriorates, and above all it has burdened us all by tenaciously pushing forward its own private-profit-focused agenda even while knowing that this would lead to global climate change. 

Responsible governance for today and for the future will require renewed commitment to protecting  forests and other public lands.  There is little advantage to “streamlining” a process that leads to destruction and degradation of the land, air and water that sustain us all.  We are rapidly finding other ways of meeting the energy needs of the country, but clean air and water are non-negotiable and irreplaceable. 

I strongly urge that the proposed rule change be denied.


Electronically: Via the Federal eRulemaking Portal: http://www.regulations.gov. In the Search box, enter 0596-AD33, which is the RIN for this proposed rulemaking. Then, in the Search panel on the left side of the screen, under the Document Type heading, click on the Proposed Rule link to locate this document. You may submit a comment by clicking on “Comment Now!”

Mail: Send written comments to USDA-Forest Service. Attn: Director-MGM Staff, 1617 Cole Boulevard, Building 17, Lakewood, CO 80401.

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