fre United States Department of the Interi
ee
a NATIONAL PARK SERVICE
i ‘Zion National Park
a spre
L7619(1590)
VIA ELECTRONIC MAIL AND HARD COPY TO FOLLOW
March 72017
Memorandum
To: ‘Brian Tritle, Manager, St. George Feld Office, Bureau of Land Management
From: Superintendent, Zion National Park
Subject: Comments hy Zon National Park an Environmental Assessment for June 2017 Oi and
Gas Lease Sale (DOL-BLM-UT-C030.2017-0010-EA)
Zion National Park has reviewed the Environmental Assessment (EA) for the June 2017 lease sale for
three tracts totaling 4,730.14 eres on lands managed bythe St. George Feld Office in Washington
County, Utah. Too ofthe parcels, UT-0517-042 and UT-0517-083, spa the Kulub Terme Rua hice
is the primary means of acces othe central portions ofthe park. These parcels are 15 miles distant
from the park boundary a ther closest approach and 5 mils distant at thir wes boundary.
ion National Pack was established over 100 years ago. Then, 35 now, it provides vistors withthe
‘opportunity to experience nture by viewing magnificent scenery, seeking slide, viewing wildlife, and
by partaking in emarkable recreational atvities. Resources within Zion National Park ae protected
under the NPS Organic Act of 1916. The Organic Act established the fundamental purpose of units ofthe
‘ational Pak System, which is “..to conserve the scenery and the natural and historic object and the
wild ife therein and to provide forthe enjoyment of the same n such manner ad by such mes as will
leave them unimpaired forthe enjoyment of fature generations." (34 USC § 100101(a)
We appreciate the opportunity to provide input otis process, We commented on these tracts during the
scoping period in September 2016 wien they were included onthe BLM Utah preliminary ol and gas
lease sale list. We concur with the planning assumptions in the EA thatthe potential for il and gas
development on these parcels is relatively low, However we continue to have concerns regarding the
Teasing andthe potential for subsequent exploration and development of ol or gas operations n these
parcels in regard to protection of park resoures and visitor experience
rir to leasing in these areas, we would ike to evaluate and discuss with BLM whether the 1999
Resource Management Plan (RMP) decisions (eg areas open o leasing) and associated mitgations are
still adequate in 2017. Our objective isto collaboratively ensure thatthe oil and gas decisions inthe 1999
RMP are sf relevant and adequate to protect park resources and values should development occu, and
iftnot, ow any shortcomings may'be remedied pio to decisions whether leasing is appropiate in areas
near the park. We comment further on these RMP concerns and multi-agency collaboration atthe
conclusion ofthis memorandum,Mitigatons that willbe included as stipulations to th proposed leases (EA, Appendix A), were identi’
inthe 1999 RMP. We understand that addtional mitigatons may also be implemented pos-easng as
‘Best Management Practices, Design Feature or Conditions of Approval (COAS) through this leasing EA,
‘orany subsequent application fra permit to dill (APD), However our experience i that additonal
mitigation canbe difficult apply once a lease is issued, Potential impacts to NPS resources ad values
‘of most concem includ:
‘Impacts to scenery and scenic resources to nearby areas ofthe park along the Kolob Terrace
ond;
‘+ Impacts to Aie Quality and Air Quality Related Values (AQRVS) in Zion National Park, a