1. On non-federal lands in conservation areas that are already or will be leased for traditional oil
and gas, the two species need a baseline amount of protection (maximum threshold of
disturbance) to ensure their conservation. We recommend limiting surface disturbance to 5%
per unit (4-6 well pads per section), planning development at least 300 feet from plant locations
and consolidating development locations to prevent fragmentation. This will still allow for
access to subsurface oil and gas.
2. For oil shale development areas on non-federal lands within within conservation areas species
conservation will require a commitment to maintain a certain percent of lands intact with no
surface disturbance, for reference sites and for the resiliency of the species. We recommend
30% of these lands be protected for the term of the agreement with no surface disturbance. .
3. From Jonathan’s Dec 18, 2013 e-mail clarifying disturbances in conservation areas, “hence, the
reason for removing any oil shale activities within Conservation Areas and essentially making
those areas off-limits (of course, again subject to valid existing rights). The individual
units/polygons may end up being tighter than the original version, but they would have stronger
and more-clear protections associated with them.” So do you agree with our designated
conservation area locations and polygons? Sounds as if you would like to change the polygons. If
so, can you please send us those changes?
4. From Jonathan’s Dec 18, 2013 e-mail clarifying disturbances in conservation areas, “On nonfederal land conservation areas as relating to oil shale development, surface disturbance would
be limited to de minimus activities (e.g. core drilling, temporary roads, etc.) subject to valid
existing rights in consultation with the Conservation Team, under the avoid/minimize/mitigate
process.” So what about the lands that are already leased and/ or owned specifically for oil
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shale development within conversation areas? Are you proposing de minimus disturbance on
those lands within conservation areas?
On federal lands within conservation areas, we request incorporating a disturbance threshold of
5% per unit to ensure access for leases and provide protection for the species. .. .
If disturbance levels exceed protective thresholds there needs to be a commitment to
mitigation, such as incorporation of new occurrences into a conservation area.
On federal lands outside of conservation areas we suggest incorporation of Appendix 1 of the
previous CA (except for the gravel requirement for roads in 4c). Where these measures cannot
be followed, BLM would mitigate the impacts. A mitigation program will be developed by the
conservation team.
Where grazing occurs in conservation areas we need BLM to monitor the species and take
action when impacts reach a management trigger level. The trigger level will be developed in a
monitoring plan developed by BLM and USFWS within one year of the signing of the agreement.
The BLM needs to describe in detail how the conservation measures of the CCA will be included
in permitting and management decisions so that they are fully incorporated into the BLM land
management process and will last for the term of the agreement. Can BLM develop a habitat
management plan for the species within 2 years of the agreement?
BLM will commit to incorporate the CCA’s conservation measures into the next RMP renewal.