WHOA’s Preliminary Comments to Placitas BLM Lands Draft Environmental Impact Statement

PLACITAS BLM LANDS
DRAFT ENVIRONMENTAL IMPACT STATEMENT
Rio Puerco Resource Management Plan Update
Preliminary Comments
8/24/12

Summary; The Resource Management Plan Update for the Placitas BLM lands is now in its second step visible to the public.  The first step was the scoping process in 2008, the BLM accepted public comments on what folks thought were the issues and concerns. The second step is their recently published Draft Environmental Impact Statement (DEIS) which gives four alternatives, none of which seem to include the public’s thousands of inputs.

It does contain some BIG SCARES regarding gas, oil, and fracking which appear to be empty threats as there have been no test wells here. The real threats to Placitas BLM lands are still:

• Mining and its associated water usage
• I-40 Bypass Loop Rd Highway
• Development and associated loss of wildlife, wild life habitat, and open spaces.

WHOA’s Preliminary Comments

1. Out of Scope Horses: During the Scoping process the I-40 Bypass (Loop Road), wild horses and Land Tenure Adjustment for a Wild Horse Park were all out of scope of the Scoping Process.  The scoping process is over and the BLM has now put these issues in scope.
   1. If the BLM is now putting the horses in scope, the Scoping Process needs to be re-opened.
   2. The issue of the horses being legally wild, or not, is being addressed outside of this public process for a number of reasons including the round-up attempt by BLM in May of 2011.
2. The Highway (I-40 Bypass or Loop Rd) through the BLM has not been addressed. During the scoping process, BLM representatives stated that they had not received the Right of Way Request (ROW) from Sandoval County which WHOA had produced. The BLM representatives also stated that inputs by Sandoval County were confidential.  However, WHOA has obtained both the ROW request to the BLM and the document the BLM received, and stamped as received, from Sandoval County. This is a ROW request by Sandoval County and it was part of the scoping process and is listed as comment ML 189 Michael Springfield 1 (See Attached). It is not addressed in the DEIS.  WHOA’s many requests including that in green below was also not addressed.  WHOA requested: We ask that Right of Ways (ROWs) be excluded from the Unit #5 BLM area in Placitas. We specifically ask also that roads and transmission lines be excluded from the Unit #5 BLM area in Placitas.
3. Cattle Grazing: Cattle Grazing, Grazing permits, and the mis-use of grazing science were discussed in public comment and beyond and has also not been addressed.

Below is a copy of Sandoval County’s Comment into the BLM Scoping Process, Requesting a Right of Way: