Expert James R. Kuipers P.E. Final EIS Comments

James R. Kuipers P.E.

1.0 Executive Summary
The Final Environmental Impact Statement and Proposed Plan Amendment for the Powder River Basin Oil and Gas Project (FEIS) has identified impacts to soils and lands, and water resources that will occur due to extensive Coal Bed Methane (CBM) development. The Bureau of Land Management (BLM) has attempted to identify and evaluate mitigation measures to address water resource protection and reclamation of disturbed lands, but the present effort falls far short of ensuring that impacts will not occur that cause violations of state and federal water quality regulations, which will result in significant taxpayer liability for environmental cleanup.

The FEIS clearly acknowledges that impacts to soils and lands and water resources will occur. However, the environmental impacts from coal bed methane, while well known, have not been extensively described or studied. Based on my best professional judgment and expert opinions the following recommendations are made to the FEIS.