Jackson Chamber speaks out against Hoback drilling
Letter to the Forest Service about the DEIS for the Eagle Prospect Exploratory wells
May 1, 2007
Editor’s Note: The Jackson Hole Chamber of Commerce sent a letter to Bridger-Teton National Forest Big Piney District Ranger Greg Clark for their public comment on the Draft Environmental Impact Statement for the Eagle Prospect Exploratory wells.
In their letter, they said the "DEIS process and documentation must include a comprehensive analysis of the short- and long-term, direct and indirect, individual and cumulative socioeconomic impacts that would be created by the proposed project."
They include analysis of the “Impacts of proposed project upon the marketing investments made by the affected businesses and economies” as well as “Impacts of the proposed project upon the real estate values…”, among other socioeconomic impacts.
The entire text of their letter is below:
April 30, 2007
Greg Clark, District Ranger
Bridger-Teton National Forest
PO Box 218
Big Piney, WY 83113
Dear Mr. Clark,
The Jackson Hole Chamber of Commerce has reviewed the Draft Environmental Impact Statement (DEIS) for the Eagle Prospect Exploratory Wells. The purpose of this letter is to provide comments on this DEIS, specifically for those aspects of the DEIS that relate to socioeconomic considerations and impacts.
Statements in the DEIS indicate that the Forest Service recognizes that “Scenic resources are important to the expectations and experiences of both visitors and local residents”, that “Scenery and related aesthetic values have long been recognized in the Greater Yellowstone Area as an important resource to protect”, and that “Beyond state, federal, and county recognition, local groups, organizations, and individuals emphasize, and even market, the incredible scenic resources of this area” (section 3.4.5). According to statistics provided by Wyoming Travel & Tourism, the top five reasons that people visit Wyoming are for our mountains, wilderness areas, wildlife, lakes and rivers, and natural environment. These statistics indicate that for Teton County in 2005, recreation and tourism account for 6,190 jobs (25% of total jobs), $163.4 million in total business earnings (16.2% of total business earnings), and $15.1 million in state sales tax distributions (44.4% of total state sales tax distributions). Recreation and tourism for Sublette County and Lincoln County account for a combined 1,200 jobs, $25 million in total business earnings, and $1.8 million in state sales tax distributions.
Given this comprehensive recognition of the interdependency and interconnectedness of the environment, economy, and community, the DEIS process and documentation must include a comprehensive analysis of the short- and long-term, direct and indirect, individual and cumulative socioeconomic impacts that would be created by the proposed project. As stated in the National Environmental Policy Act (NEPA), “When . . . economic or social and natural or physical environmental effects are interrelated, then the environmental impact statement will discuss all of these effects on the human environment . . .” (40 CFR 1508.14). Such an analysis and documentation should include but not be limited to the following:
(1) Impacts of proposed project upon the marketing investments made by the affected businesses and economies. Local, state, regional, and national tourism and recreation businesses, organizations, and agencies invest considerable annual marketing and public relations resources (in the millions of dollars) to promote the pristine scenic, abundant wildlife, and related aesthetic qualities and unique individual and cumulative tourism and recreational opportunities and experiences our area provides. These individual and cumulative qualities differentiate our area from other tourism and recreation destinations and provide a distinct marketing advantage and socioeconomic benefits. An analysis of the short- and long-term, direct and indirect, individual and cumulative impacts of the proposed project upon the loss of the corresponding socioeconomic benefits due to a negative change in public perception, visitor and resident expectations and experiences, and marketing advantage must be provided. This analysis must account for the impacts of the proposed project upon (1) the financial investments/expenditures being made in marketing and public relations performed by all affected local, state, regional, and national tourism and recreation businesses, organizations, and agencies; and (2) tourism and recreation jobs, earnings, and sales tax distributions within the affected area.
(2) Impacts of the proposed project upon local socioeconomic trends, resources, and infrastructure. These include but are not limited to increased rates of crime and substance abuse and corresponding impacts upon county and town law enforcement and social services; and upon housing and lodging shortages. Additional and significant resources, infrastructure, and values include traffic and roads, schools, health and medical services, emergency and fire services, wildlife, air and water quality, employees (competition for qualified employees), wages and other compensation, diversity of the economy, and community culture and character.
(3) Cumulative impacts and timing of the proposed project with other existing and proposed energy development projects upon town and county resources, infrastructure, and values including but not limited to traffic and roads, housing, schools, law enforcement, health and medical services, social services, emergency and fire services, wildlife, air and water quality, employees, wages and other compensation, diversity of the economy, and community character.
(4) Impacts of the proposed project upon the real estate values of the properties owned in the affected area due to impacts from project transportation, development, and proximity, as well as potential impacts upon air and water quality.
(5) Impacts of the proposed project upon the loss of economic benefits to all hunting, outfitting, and recreation businesses operating within or adjacent to the project area.
A review of the Eagle Prospect Exploratory Wells DEIS indicates that little or no socioeconomic analysis of the short- and long-term, direct and indirect, individual and cumulative impacts of the proposed project upon the communities in the affected areas has been performed and/or documented. Some statements indicate that an analysis may have been performed to demonstrate the positive economic benefits to the affected area (section 4.5.6, page 4-75, last paragraph), however, no analysis is evident that addresses the negative impacts of the proposed project.
Conclusive statements such as “Socioeconomic impacts of the proposed project would be largely positive” (section 4.5.6, p. 4-74, 2nd paragraph), “Under Alternative B, there would be no permanent displacement of any recreational or commercial activity, and any economic impact would be short-term and would not be measurable” (section 4.5.6, p. 4-75, 1st paragraph), and “There would be no measurable loss of revenues to the local economy from travel- and recreation-related spending during project implementation and operation” (section 4.5.6, p. 4-78, last paragraph) are made in the DEIS without analytical, objective substantiation. While the citation of statistical information such as in section 3.4.6 demonstrates an attempt to describe the economic and demographic characteristics of the communities in the affected area, and Table 2-4 displays a comparison of environmental effects between alternatives, this information is not evidence of an analysis of the impacts of the proposed project.
In addition, there is no indication that such an analysis was performed and used as a basis for defining the significant issues used in the formulation of alternatives (section 1.9, pp. 1-15 and 1-16). This latter apparent shortcoming in the DEIS calls into question the validity and rigor of the development and analysis of the alternatives to the Proposed Action.
The affected area identified by the DEIS includes Sublette and Teton counties and associated towns, but does not include Lincoln County and associated towns. As shown in statistics provided by Wyoming Travel & Tourism, Lincoln County also derives economic benefits from the unique tourism and recreational characteristics and opportunities of the area.
A review of the DEIS also indicates that there was no apparent review, consultation, and authorization with agencies on socioeconomic resources and impacts such as with Wyoming Travel & Tourism and other concerned agencies (section 1.10). A complete process of review, consultation, and authorization must include such relevant agencies.
Thank you for the opportunity to provide comments for the Eagle Prospect Exploratory Wells DEIS. We look forward to seeing a complete analysis of the socioeconomic impacts of this proposed project.
Jackson Hole Chamber of Commerce