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Pundarika Foundation

315 Palomino Way

P.O. Box 58

Crestone, Colorado, 81131

Attention: Mike Blenden, Project Leader, USFWS

RE: Comments on the Draft EA for the Proposed Gas and Oil Exploration, Baca National Wildlife Refuge

Dear Mr. Blenden,

I am writing on behalf of Pundarika Foundation, a non-profit foundation based in Crestone Colorado (see www.pundarika.org). We have been following the developments in the San Luis Valley regarding Lexam’s potential exploratory gas and oil drilling and the possibility of swift movement into production if they have a viable find. If the exploration and development of an oil or gas field were to happen, especially based on this inadequate Draft Environmental Assessment, there would be significant impact to the activities of our foundation as well as all of the contemplative and spiritual retreat Centers in the Baca and therefore on the well-being of the community itself, since our Centers are the basis of economic stability in the Crestone/Baca community. The Draft EA completely bypasses the real, substantial and potentially irreversible impact on humans and the human environment.

According to the Council of Environmental Quality/Executive Office of the President, Citizen’s Guide to NEPA, “Environmental Assessments”, it states that “[The EA]… should focus on the context and intensity of effects that may significantly affect the quality of the human environment…” Many issues, proposed actions, and cumulative impacts do not fulfill the requirement to determine if the action is significant. Furthermore, the CEQ regulations are concerned primarily with those "major federal actions significantly affecting the quality of the human environment" (42 U.S.C. 4332): “Accordingly, agency procedures, resources, and efforts should focus on determining whether the proposed federal action is a major federal action significantly affecting the quality of the human environment”.

However, this Draft EA was incorrectly limited to a very small area of the Refuge and the accessing of the mineral estate. What was completely eliminated from the Draft EA is the human context and, perhaps one might say, the context of the “spiritual estate” that dominates the life of Crestone. Because of this, we are asking that the USFWS recognize the inadequacies of the Draft EA and proceed directly to the conduct of a full Environmental Impact Statement before making a decision about when, how and if any drilling should and may occur on the refuge.

As to our particular situation, Pundarika Foundation sponsors retreats in the Buddhist traditions taught by Ven. Tsoknyi Rinpoche in Crestone each year. The uniquely spacious and silent atmosphere of Crestone is essential for our retreats. Tsoknyi Rinpoche chose Crestone as his Seat in the Western Hemisphere because of these attributes. About 300 students from around the world come to Crestone to attend the retreats and “audiences” which Tsoknyi Rinpoche conducts each August. Since we do not have a residential center, our retreats bring much economic benefit to the community. We rent the retreat space and the housing for the students; cater from within the community the meals for the retreatants, Rinpoche’s household and for his guests; the shops, restaurants and cafes are frequented before and after the retreats. Additionally, many students have purchased homes here once they experience how the pristine beauty and silence of Crestone enhances their contemplative and meditative practices. Nearly all citizens who re-locate to this area do so for aesthetic or spiritual reasons that in turn formulates a unique environment. This cultural “uniqueness” with its spiritual heritage, attractiveness, and visitors has been completely overlooked and/or avoided in this EA. The potential significant impact to this cultural resource is great and must be fully assessed. This discussion of “cultural uniqueness” may very well apply to the EA’s section on “Socio-economic impact” as well.

If Lexam were permitted to proceed according to the Draft EA proposed by the USFWS, the noise level, traffic, night light, dust and haze would have significant negative impact on us all, including the Pundarika Foundation retreats as well as the meditative activities of our individual practitioners who live here, and consequently on the economy of Crestone. We would no longer be able to speak to our students of the pristine practice environment that so many Tibetan Masters, including Tsoknyi Rinpoche, found in Crestone. We could not assume that meditation practitioners would want to visit here, let alone spend a period of retreat in a place compromised by gas and oil drilling.

Additionally, Pundarika Foundation has 60 acres of prime land on which we have built the Stupa of Enlightenment and a shrine to Yudronma. These are sacred places to our community and draw visitors to the Baca from far and wide. We also have a Master Plan to further develop our land by building a residence for Tsoknyi Rinpoche, a long-term retreat building and numerous retreat cabins for students. Needless to say, we would be in no position to proceed with these plans, which not only would negatively impact our ability to function as a spiritual center, but would have significant long-term negative impact on the economic foundation of Crestone. By mistakenly ignoring the existence of the spiritual Centers and their importance on Crestone’s economy, the Draft EA mistakenly ignores the NEPA mandate to consider the complete context of the proposed actions.

If drilling were permitted without a complete Environmental Impact Statement, our unique environment, so perfect for spiritual practice, could well be permanently destroyed and it is unlikely that visitors, students, and meditators would be interested in coming here. This would be an undeniable instance of negative, significant impact on the economy and the unique spiritual offerings of Crestone. There is no other community in this country which has, as its heart, 20+ spiritual and contemplative centers that function in a fully harmonious atmosphere. We are just one of these centers, but the negative impact would affect so many people, so much wildlife - so much that is unique and beneficial about this precious place on earth. Therefore we urge the USFWS to commence with a full EIS to determine the full significance of the impacts as a result of the exploratory drilling in the Baca National Wildlife Refuge.

Thank you for considering our comments,

The Pundarika Foundation, Tsoknyi Rinpoche, President

Esteban Hollander, Executive Administrative Director