Dear Mr. Chavez:
This is to register strong opposition to the "preferred
alternative" forest management plan proposal being
considered in the above-referenced draft environmental
impact statement (DEIS) that would severely curtail natural
gas leasing, exploration, development and production in
the Jicarilla Ranger District of the Carson National Forest.
The proposal and the seriously flawed supporting DEIS
should be withdrawn.
As a national association representing 24 of the largest
independent natural gas and oil exploration and production
companies, the Domestic Petroleum Council is concerned
about the Jicarilla Ranger District proposal and DEIS
for several specific reasons that have national implications.
First, DPC members would have their operations significantly
reduced by the proposed Forest Service actions outlined
in the DEIS. The result would be a significant reduction
in the amount of natural gas that they would otherwise
supply to consumers in a wide area from California to
points east of New Mexico.
Second, and more broadly, the proposal being considered
appears to be starkly contrary to the energy needs of
the nation, and the National Energy Policy of the Administration,
with no discussion of why that is acceptable, especially
when each natural gas well permitted under current rules
and regulations must meet specific environmental analysis
and mitigation requirements.
Third, the DEIS process has caused us to not only evaluate
the specific proposal being considered and the lack of
DEIS support for it, but also to hear from our members
serious concerns about the already slow pace of processing
applications for permits to drill (APDs) in the Jicarilla
Ranger District. This is despite its being a known producing
area with much environmental study having been done as
part of the San Juan Basin EIS completed this year and
on individual well locations. As a result, by copy of
this letter we are asking the Chief of the Forest Service
and the White House Task Force on Energy Project Streamlining
to initiate a review, similar to those underway by the
Interior Department's Bureau of Land Management (BLM),
as to how the permit consideration processes and timelines
of the Forest Service ranger districts compare with one
another and with BLM field offices, and how there may
be a sharing of improvement ideas.
Against this background, and in recognition of the detailed
comments of the exploration and production companies operating
in the Jicarilla Ranger District that will lay out the
specific natural gas supply, economic impact and legal
reasons that the Forest Service needs to withdraw its
proposal and DEIS, we again urge that the Forest Service
do so as soon as possible - noting that the Governor of
New Mexico, Bill Richardson, has also made the same withdrawal
request.
Finally, we hope and expect that the APD consideration
processes of the Jicarilla Ranger District, the Carson
National Forest and the National Forest System will be
examined and improved as quickly as possible so that they
might best help meet the energy needs of the region and
the nation. At the same time we expect that our members
and other energy producers will work constructively with
you and your staff to ensure the environmental compatibility
of energy operations.
Thank you for considering our views, and please do not
hesitate to let me know if the DPC may be of assistance
in the future.
Sincerely,
William F. Whitsitt
President
cc: Dale Bosworth
Chief
U.S. Forest Service
14th & Independence Avenue, SW
PO Box 96090
Washington, DC 20090
Robert W. Middleton, Ph.D.
Director
White House Task Force on Energy Project Streamlining
US Department of Energy
1000 Independence Ave., SW, WH-1, Room 8E044
Washington, D.C. 20585
Domestic Petroleum Council contact: Bill Whitsitt, 202
544 7100
