Blackleaf Project EIS Team Lead
Bureau of Land Management, Lewistown Field Office
P.O. Box 1160
Lewistown, MT 59457

RE: My comments on Rocky Mountain Front

Dear EIS team,

Americans have long known the natural and biological values of the Rocky Mountain Front and have supported its protection. I join the millions of Americans who want the Front protected from oil and gas drilling. It is absolutely critical that you include in the EIS a legitimate "No Action" alternative. That alternative must quantify, among other things, the costs the federal government might incur to trade or buy out all the leases in the Blackleaf unit. Anything short of that analysis will be a paper exercise designed only to justify a foregone drilling decision.

Because of the Blackleaf area's proximity to the Bob Marshall Wilderness Area, Montana's largest and a designated Class I airshed, air quality concerns are extremely important. You must detail all air quality impacts from particulates due to construction work, pollution from vehicles and generators, hydrogen sulfide releases in natural gas and damage to agriculture from particulates and pollution.

Drilling activity undermines the unique sense of place and wilderness values of this area. It can adversely impact the viewshed for a much larger area than simply the project sites. Please ensure that the EIS assesses those values and likely impacts. When it wrote a similar document in 1997, the U.S. Forest Service found that "sense of place" is an important value for the Front, one that drilling would affect in ways that cannot be mitigated. The BLM must also analyze the impact of drilling on this value.

The wildlife values of the Front are matchless. It is essential that the EIS detail the habitat fragmentation that will follow road and well-pad construction and what such fragmentation will mean to sensitive species. The document must also keep in the forefront of its analysis the fact that all the proposed drilling would occur in occupied grizzly habitat.

The initial exploration proposal could easily lead to major, full-field development. The EIS must fully assess the cumulative impacts of development on that scale. These include noise and light pollution, associated impacts from pipelines and a sweetening plant, and fragmentation and other impacts that could extend well beyond the actual disturbed area of proposed drill-pads and roads. It would be disingenuous and misleading to ignore these impacts in the EIS.

Finally, the EIS needs to fully disclose the economic damage that could result from a loss of hunting, fishing and wildlife-viewing opportunities, diminished outfitter business and a general decline in area tourism on which many counties and communities in the area are dependent.

Thank you for considering my comments.