Read the US Fish and Wildlife Service's full comments in the related story.
The U.S. Fish and Wildlife Service objected to the issuance of a permit for H&C Oil Operating Inc., to drill for oil in the Cheyenne Bottoms wetlands during the public comment period provided by the United States Army Corps of Engineers. It further recommended an environmental impact statement be prepared, and the permit be held in abeyance pending the completion of the EIS.
“We believe that the cumulative impacts of multiple oil well drilling and productions sites along with related activities will result in substantial and unacceptable impacts to an aquatic resource of national importance,” said Field Supervisor Heather Whitlaw in a letter to Luke Cory, Regulatory Team Leader with the USACE.
“We also believe that this exceptional resource, the Cheyenne Bottoms complex, is critical to the welfare and survival of migratory birds including the whooping crane, least tern, and piping plover.” All three species are on the federal endangered species list. The Corps has requested a formal consultation for the whooping crane and informal consultations for the least tern and piping plover.
The 10 page letter identified several potential environmental impacts, from changes n water quantity and quality, pollutants resulting from energy sector activities, disruption of sediment and sheet flow from infrastructure, habitat fragmentation. Concerns included impacts on wildlife from collision or electrocution, habitat fragmentation, and air and water quality issues arising from the fumes from sulfur or nitrogen compounds which are common in the area of drilling sites.
Other concerns include the possibility that groundwater and subsurface water could mix, night time lighting will disturb wildlife, and some wildlife could die from contact with pits during the drilling process.
USFWS also requested additional information about the height of the oil well pad, the source of fill material for the pad, the construction of any ditches to divert water flow around oil wells, how the oil will be stored until collected from the site, and the length of time pits will be in existence. This information was not included in the public notice.
“Compensatory mitigation should be required for the impacts of construction a pit pond and scraping the soil,” Whitlaw wrote.
In the public notice issued by the USACE in June, a proposal to provide mitigation was mentioned to compensate for a 30 ft. by 30 ft. area which would include the oil well and equipment is mentioned. The USFWS recommends that mitigation only be allowed in the Cheyenne Bottoms area, at a ratio of 10:1, or for preservation activities, no less than 20:1.
According to a statement issued by Cory, the Corps is currently reviewing all other comments received over the 30-day period. It is currently reviewing the requests that were received for a public hearing and will make a decision if holding a hearing is warranted.
“The Corps takes their permit responsibilities very seriously and therefore invests time and research in making permit decisions,” Cory said.
The Corps issued public notice of the permit request June 13. The original comment period was scheduled to end July 4, but the Environmental Protection Agency requested an additional 10-day extension. There is a similar request for a permit to drill within the Cheyenne Bottoms Wildlife Preserve by LD Drilling of Great Bend.