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Patrick and Sandra Hammond
1134 Badger Road
P.O. Box 907
Crestone , Colorado, 81131
February 25, 2008
Attention: Mike Blenden, Project Leader
RE: Comments on the Draft EA for the Proposed Gas and Oil Exploration, Baca National Wildlife Refuge
Dear Sir,
We have lived in the Baca since 2005 and, like many others, were regular visitors here before that, attending retreats with our spiritual teacher every August for many years. We are extremely concerned about the destructiveness of the proposed drilling and have carefully read the Draft EA. In the Draft EA there are many under- and un-addressed issues concerning the potential significant impact of drilling in the Refuge on the actual water and air quality, the actual environment impact, the actual welfare of wildlife, the actual effects on our health and the preservation of under-ground archeological artifacts. However, in this letter we will limit our comments to the significant impacts on the residents of the Baca and Crestone, the spiritual Centers and economic base this represents. This is a completely unique community in an equally unique environment. Adequately protecting this unique human environment and irreplaceable landscape MUST be addressed in order to be in compliance with NEPA.
The NEPA process requires, as part of informed decision-making, that you to look at the intensity and severity of “significant” impacts, including the context of the proposed drilling. The context is not just within the 14 acres of the Refuge or within the context of a de facto decision to allow Lexam to drill. To have focused exclusively on the physical Refuge per se (and only of a limited area of that) has yielded an exceedingly narrow scope of information and shows complete disregard for significant impact on the Refuge’s nearby human residents in Crestone/Baca. To have said nothing about real, significant impacts on the human environment, let alone the natural environment (there is not even a management plan in place) is a glaring omission. Pages 3-39 through 3-43 and pages 4-18 through 4-21of the Draft EA comprise the entire assessment of direct human impact and it is significantly inadequate in content, documentation and context in terms of the intensity and severity of impact, especially on our community. As such, it does not address the real purpose of NEPA to inform decision makers through the provision of documented scientific and socio-economic data and to give voice to the public’s concerns and lives. Indeed, the Draft EA’s picture makes our community completely invisible by sweepingly eliminating all human factors in the immediate vicinity of the Refuge, even though the Refuge is next to the town of Crestone and in view of the Baca. It is not just one of the “several small communities …nearby” (in 3.10); the Refuge is in our front yard. Indeed, it is our front yard.
On the whole, it can be said that we who live in this remote location have chosen to do so because of the completely unique environment. It is not an easy place to live, but over one thousand of us have made it our home, our community and our life. Additionally, many people come as visitors to study and spend extended periods of time in retreat at the spiritual Centers. Many of us eventually buy homes here, contributing to the economic well being of our community. This environment supports the contemplative and spiritual practice of many individuals and numerous spiritual Centers based on qualities of environment which are unparalleled on this earth, such as the profound quiet and vast, pristine views which are the basis for many of the spiritual practices done here. The peaceful and beneficial relationship among the 20+ groups of practitioners in Crestone/Baca is extraordinary in the world today. The drilling could easily destroy this harmony, destroy the irreplaceable environment and destroy the fragile economy the spiritual activity supports.
One might have expected to find reference to our community’s pervasive contemplative and spiritual activity and the spiritual Centers as the most viable economic activity of our community, bringing business to our few stores, filling our few restaurants and adding residents to our community who value life in this remote area. The Draft EA says Alamosa would be Lexam’s base of operations for their employees, presumably including food, housing, entertainment, shopping and offices. So even Lexam’s presence in the Valley will have little positive impact on Crestone/Baca’s economic future. Tourism and related hospitality services, and the many retreats offered at over 20 spiritual Centers form the basis of our local economy. There is not now, nor for the foreseeable future, will there be “industry” here, with the possible exception of solar energy technologies (the development of which would be adversely effected by oil and gas development due to the degradation of the air shed). There is no other long-term, viable economic base. But even in section 3.10.2, Economic Overview, the spiritual Centers are never mentioned. There is no assessment of the economic impact on our community, yet it is not unreasonable to argue that the drilling will almost certainly force numerous residents whose lives revolve around those spiritual practices which depend on this pristine environment to move away. Additionally, the drilling could literally be the demise of the spiritual Centers which are the economic base of our community. Despite the fact that Crestone is world known as a spiritual epicenter, it is highly doubtful that people would want to make the difficult trip here to practice in the 24/7 noise, haze, contaminated air, and bright night lights which even the Lexam and the EA promise will accompany the drilling. Therefore it is clear that, as a result of the drilling, there will be a negative cumulative impact to our economy and it would swiftly occur. The potential demise of the spiritual Centers is certainly an intense and severe impact to be considered.
One might have expected to find more extensive, accurate and scientific consideration of the impact on the physical setting (3.11.1.2), on the noise/ambient soundscape (3.11.2.1) and Aesthetics (4.11) as it affects Crestone/Baca. But this was not the case with the Draft EA. The assessments presented and the data to back up these assessments are totally inadequate from our viewpoint. For example, the visual impact was not even studied from the Crestone/Baca perspective and as to noise levels, we are not an agricultural community with farming noise as was suggested in the Draft EA and our baseline noise levels are much lower than those stated. The negative impact on our lives of insidiously present background noise, degenerated air quality and constant night light will have intensely significant impact not only on our spiritual lives, but our mental and physical health as well. No consideration was given to these realities vis a vis the residents of and visitors to Crestone/Baca.
On might have expected the Draft EA in sections 3.10.6, 3.10.7and 4.10.1.2 to consider the extreme limitations and dangers to our community if there were an emergency caused by Lexam’s activity which blocked, damaged or otherwise made Road T unusable. It is the only road into and out of Crestone/Baca and that makes us very vulnerable. But the Draft EA did not even mention this. Additionally, it speaks about our population as if the “town of Crestone (population 73 in 2000)” is the sum total of people who live here and the only notable activity concerns the three USFS trailheads. There are over a thousand residents and many visitors staying at the spiritual Centers for extended periods of time in addition to the mountain climbers and visitors accessing the Great Sand Dunes National Park from the north. Any problem with Road T would absolutely impact more the 73 people and no contingency plan was offered if this road were rendered impassable if, for example, there was a wildlands fire or a toxic chemical spill from Lexam itself.
Because of these (among many other gross oversights) we are asking that the USFWS recognize the inadequacies of this Draft EA and proceed directly to the conduct of a full EIS before making a decision about when, how and if any drilling should and may occur on the refuge. The Protective Measures and Standards proposed in the Draft EA do not address our vital concerns and the damage to our community and our lives could be irreparable. It is clear that, according to NEPA, the purview of an EA is not limited the exploratory aspect of the drilling only. This ignores cumulative long-range impacts and seeks to minimize the understanding of those. The requested EIS should not only address exploration but also address production. Without addressing this, granting permission for exploratory drilling alone will set a clear and erroneous precedence.
After careful reading and discussion of the Draft EA we have concluded that this EA is very flawed and blatantly wrong. We feel that drilling in the refuge is not an appropriate use of this wildlife resource at all. Allowing production to proceed directly from exploration (as Lexam’s state issued permits do) on the basis of this wholly inadequate EA would be a travesty of NEPA and common sense. Only by doing a through and excellent EIS can we be assured this will not happen.
Thank you for your attention and consideration,
Sandra and Patrick Hammond
1134 Badger Road, P.O.B. 907, Crestone, CO 81131
719 – 256 - 4181