Letter Asking for Intervening Aid on Behalf of Migrating Elk Herd
Colorado Oil and Gas Conservation Commission
For distribution to COGCC Commissioners / hard copies are forthcoming
October 04, 2007
I am writing to ask the state of Colorado, Department of Wildlife and all intervening jurisdictions to reconsider the permitting of nine natural gas wells at the site of the well believed responsible by the state of Colorado for the Divide Creek Seep. Re: [Schwartz] 2-14D (O2E); 2-11A (J2E); 2-10A (J2E); 2-10D (J2E); 2-11D (J2E); 11-3B (O2E); 11-2A (O2E); 2-14A (O2E); 2-15A (O2E)
Aside from impacts to residents, which will be noted in a separate letter, I believe this activity will tremendously impact a historically migrating herd of elk which utilizes and depends upon this area for important primary winter range and calving grounds.
The elk utilize this area beginning in late October / early November through mid-late March / early April. Of course this pattern fluctuates according to the severity of the winter season.
In years past, EnCana pushed forward with the installation of a pipeline through this region which bisected and occupied these particular grounds. The results were disastrous. The elk panicked and, rather than flee the area, smashed into and over one another and through fences. I donít know what effect this impact had on that seasonís calving rate, since, to my knowledge, no follow-up observations were conducted.
EnCana and the state were made aware of the condition of the herd at the time of this pipeline installation. Installation went forward without disruption. Subsequent to the installation, some months later, EnCana solicited from me a map delineating this herdís areas of high usage relative to the entire region. I provided a map and noted where usage occurred, when it occurred, and how intense it tended to be. I was told that EnCana desired this map so as to better understand and therefore work around such use, minimizing its operational impacts to these elk in future work.
As I noted in brief for the COGCC commission at the hearing in Grand Junction on October 03, 2007, the elk, as members of this herd and which I have had the privilege of observing, are extremely habitual animals and do not tolerate forced, accelerated adaptation, under continued adverse conditions.
Given EnCanaís extensive holdings elsewhere, the reallocation of resources should not hinder production, but could certainly relieve the pressure which will be brought upon this historic herd. Such intense pressure, at such a critical time, could contribute to or cause irreversible loss and degradation to this deeply integrated element of this regionís ecology.
The development of nine wells is far more intensive, extensive and intrusive than the installation of a pipeline.
If the intervening authority in this situation feels that it is in the best interest of these animals to pursue the proposed drilling activity during this critical time, then perhaps the DOW could at least institute a feeding plan in an attempt to lure these animals into other, less impacted, nearby areas, with plans to closely observe and act to mitigate any noted detrimental effects.
In fact, this large satellite herd (of hundreds) utilizes most of the available area along either side of 6500 road (a road which extends approximately 1.5 +/- miles from the county road -- straight measurement -- to the area in question.)
However, the specific area in question (which is the subject of this letter) should be given special consideration, since it is relied upon especially heavily for calving purposes due to its special combination of certain attributes, which are: relative isolation, unique access to forage and water, and dense cover. In fact, the area adjacent to this land is invested in a preservation easement to encourage and protect this known activity.
I ask once again that you please reconsider your decision and place due emphasis on the well being of these animals. If I may be of any assistance in providing additional information, please contact me. Thank you for your thoughtful considerations of this important matter.
Regards, Lisa Bracken
Department of Natural Resources Ė Director, Harris
Note: On 11-14-07 I sent the Bureau of Land Management (BLM) a copy of this letter.
The BLM has a great deal of authority in allowing disruption to elk herds
within a federal unit. [for more information on a federal unit, please see
Citizen Resource Guide and
Federal Unit visual aid]. In other areas
of this region, the BLM has restricted drilling activities during sensitive
times of the year for elk populations. I hope they will act to protect this
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