Gingery opposes drilling in Wyoming Range
Greg Clark, District Ranger
Big Piney Ranger District
P.O. Box 218
Big Piney, WY 83113
re: Scoping Comments for the Eagle Prospect and Noble Basin Master Development Plan EIS
Dear Mr. Clark:
Please accept the following scoping comments on my behalf, as the State Representative for House
District 23, regarding the Eagle Prospect and Noble Basin Master Development Plan. I urge the U.S.
Forest Service to recognize the degree of concern with which the public regards this project. Not only
will full field development forever change the character of this forest, but I agree with Governor
Freudenthal that this project may be the “first domino” that ushers in development of tens of thousands of
leased acres in the Wyoming Range.
I do not dispute that Plains holds valid leases. However, Plains (and previous speculators holding these
same leases) has far exceeded the statutory ten year lease term through their numerous extensions and
suspensions. I urge the U.S. Forest Service to suspend the EIS process in order to ensure that proper
baseline analyses are prepared and landscape scale availability decisions are made. By suspending the
EIS process, would allow for Wyoming’s congressional delegation to work on a buy out of the leases.
Plains (and their predecessors in interest) have been granted more time, the public should receive the
same benefit of more time.
I also do not believe that mitigation will be successful in regards to compliance with the Clean Air Act,
Clean Water Act, and the Endangered Species Act. The U.S. Forest Service has the statutory authority
and the duty to outright deny the development for violating the above stated non-discretionary statutes.
If you decide to not suspend the EIS process, I would urge the U.S. Forest Service to at least make the
public comment period longer between the scoping deadline and the draft EIS. I believe it is important
for there t be public field trips into the area during the Summer months. It is nearly impossible for the
public to access the area in the middle of Winter. The draft EIS deadline should be moved into the Fall to
allow for the public to view the area throughout the Summer months.
Taking a more deliberate and careful approach would be beneficial for everyone involved. It would allow
the opportunity to more effectively analyze the impacts from the proposed development, but it would also
provide time for all stakeholders to pursue other, non-development alternatives outside the U.S. Forest
Service’s direct authority. This includes the option of voluntary retirement of leases in the Wyoming
Range through purchase or trade.
If you do decide to proceed without suspending the EIS process or extending the deadline for the Draft
EIS to the Fall of 2008, I urge the U.S. Forest Service to consider as the preferred alternative the buy
out/trade alternative. This is a win – win option for both the developer and the people of Wyoming. This
is not only an environmental concern, but also a concern to the financial stability of the State of
Wyoming. Presently there is not enough pipeline capacity in this part of Wyoming to add anymore
natural gas production. By bringing this field on line, will drive the price of natural gas down further,
causing a ripple effect in the Wyoming economy.
I am also concerned that once this development is approved that the next area will be the leases that sit
between Hoback Junction and Game Creek in Teton County. It is my understanding that this area is
believed to have a greater potential than the Jonah Field.
For the reasons stated above, I respectfully request that the U.S. Forest Service suspend the Eagle
Prospect and Noble Basin Master Development Plan EIS. A suspension will allow time for the U.S.
Forest Service to complete numerous studies required for a project of this severity and allow time for
interested stakeholders to find creative solutions that could occur outside the EIS process. If the Forest
Service instead decides to move forward with preparation of a draft EIS, I would respectfully request that
you extend the deadline from May 2008 to the Fall of 2008 in order to allow the public an opportunity for
public field trips during the Summer months to look at the site. I would also urge that the buy out/trade
alternative be your preferred alternative.
Sincerely,
State Representative Keith Gingery – Jackson Hole
Wyoming House of Representatives