[Fwd: TAKE ACTION THIS WEEK: Sheldon National Refuge threatened by proposed Ruby gas pipeline]

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Jane Feldman

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Aug 2, 2009, 11:28:03 PM8/2/09
to best-conser...@googlegroups.com, Rose Strickland
Hi, all -
    Could you make some comments on a project that will impact us significantly here at home in Nevada?
    There's information for a letter below, as well as the address to send it to the Federal Energy Regulatory Commission (FERC). If you have any specific questions, you can address them to Rose, the Sierra Club volunteer who has researched this and worked with this project for a while now.
    Thank you.
    Jane

-------- Original Message --------
Subject: TAKE ACTION THIS WEEK: Sheldon Refuge threatened by Ruby gas pipeline
Date: Sun, 2 Aug 2009 19:11:35 -0700
From: Rose Strickland <rose...@SBCGLOBAL.NET>
Reply-To: Rose Strickland <rose...@SBCGLOBAL.NET>
To: TOIYAB...@LISTS.SIERRACLUB.ORG
References: <c6580f830907311656g22f...@mail.gmail.com>


chapter leaders, 

the Sheldon could use some friends to urge the FERC to protect the Refuge from impacts from the gas pipeline, especially the preferred route which is just south of the Refuge boundary.  Ruby Pipeline LLC plans to use the Refuge roads to access the pipeline construction site which is in a 2-3 mile corridor between Sheldon, the Summit Lake Reservation and several wilderness areas - a totally unacceptable place for industrial uses.  

An alternative route goes directly through the Refuge along Hwy. 140 into Oregon.  You can read why the USFWS opposes the alternative route below.  You can send comments to FERC at the address below.  Comment deadline is August 10, next Monday.

Our review of the dEIS does not show any need for the natural gas in Nevada and alternative sources of gas already exist for No. California. The proposed route and many of the alternative routes have significant adverse impacts on sage brush wildlands all across No. Nevada, but impacts could be worse as many required studies have not been completed yet.  

Please urge the FERC to select the No Action alternative, or IF there is an actual need, to permit a pipeline route only along already disturbed utility or road corridors in NV and other states.

David and Jane, please send this alert to your conservation activist lists.  If anyone knows how to get the alert on California or national conservation activist lists, please do so.

Many thanks.

Rose
 
Ruby Pipeline Threatens Sheldon National Wildlife Refuge

 

Sheldon National Wildlife Refuge (Refuge) was created in 1931 to conserve pronghorn antelope and other native wildlife of the sagebrush steppe ecosystem.  The 575,000 acre Refuge protects the best remaining sagebrush habitats in the United States, which is one of the most endangered ecosystems.  The refuge has populations of sagegrouse, pygmy rabbits, and pika, all of which are under review for listing under the Endangered Species Act.  It host good populations of migratory birds dependant on sagebrush communities, like sage thrasher, brewers sparrow, prairie falcon, Western meadowlark, grasshopper sparrow, and loggerhead shrike – all have shown marked declines across their range.  More than 1,200 species of plants and animals have been found at the Refuge, making it a critical reserve for biodiversity. National Wildlife Refuges are strongest commitment of the U.S. public to conserve wildlife.

 

Ruby Pipeline has proposed the construction and operation of a 678-mile, 42-inch natural gas pipeline from Opal, Wyoming to Malin, Oregon.  According to documents developed by Ruby Pipeline and/or the Federal Energy Regulatory Commission (FERC), the Pipeline’s Proposed Route would cross northwest Nevada immediately south of Sheldon NWR, except at the southwest corner of the Refuge, where it would cross a narrow arm of the Refuge which extends south approximately 1-mile beyond the primary east-west boundary.  Under the Proposed Pipeline Route, Ruby Pipeline would also access the Pipeline for construction, mitigation, operation, maintenance, repair, and/or termination through Sheldon NWR using 7-8 roads, including 5-6 two-tracks (undeveloped paths for off-highway vehicles).

 

FERC’s draft environmental impact statement (EIS) for the Project also discuss an alternative route for the Pipeline (the Sheldon Route Alternative) that would generally lie within and follow the Nevada State Highway 140 rights-of-way (ROWs) through the heart of the Refuge.  This Pipeline alternative would traverse the Refuge for a total of approximately 34.5 miles, except in a handful of locations where it would cross the Highway or deviate from the ROWs (for a total of 4.5 miles).  Additionally, according to the EIS, the Sheldon Route Alternative would cross approximately 1.5 miles of the Gooch Table Wilderness Study Area (WSA).

 

1. The Sheldon Route Alternative should be removed from further analysis – it contradicts the refuge purpose and mission of the Refuge System.  Listed below are a number of factors that describe why 34.5 miles of pipeline through a Refuge is not compatible:
  • Loss and fragmentation of critical wintering habitat for pronghorn antelope.
  • Fragment and disrupt sensitive sagebrush communities and ecosystem processes.
  • Disrupt sagegrouse lek areas and winter habitat.
  • Cross sensitive high desert streams and wetland habitat.
  • Above-ground sections of pipeline are a barrier to movement of pronghorn, mule deer, and bighorn sheep.
  • Cross as many as four Refuge Wilderness Study Areas for miles.
  • Disturb sensitive cultural resources, including prehistoric rock shelters, petroglyphs, quarries, and lithic scatters.
  • Disturb protected paleontological resources, including Pleistocene mammal deposits.
  • Create noise, dust, other air pollution, and visual scars that detract from the natural aesthetics of Sheldon’s wide open spaces and scenic vistas
2. Sagebrush communities take 30-200 years to reach maturity once disturbed, and in some cases cause permanent loss.  Soil disturbance and traffic causes the spread of invasive species.  All precautions possible should be taken to minimize disturbance and prevent the spread of invasive plants like cheatgrass, whitetop, halogeton, and Russian thistle.

 

3. FERC indicates that the pipeline can be constructed within the ROW of Rt. 140. FWS has the responsibility to authorize the pipeline in or out of the ROW in the Refuge, not FERC or Nevada Department of Transportation.  The ROW contains valuable habitat and it is physically impossible to keep the construction within the highway ROW.

 

4. Building the pipeline through the Refuge will draw additional developments that degrade the habitat for wildlife and quality of recreation for the public.

 

5. Steep grades at McGee Mountain and Doughty Slide pose significant construction obstacles.

 

6. The points above do even address the significant impacts to endangered species, wildlife habitat, cultural resources, proposed Wilderness, and wetlands on BLM administered lands along the Sheldon Route Alternative.

 

7. The draft EIS did not include comparable survey information for the Sheldon Route Alternative as the proposed and Black Rock Routes.  Conclusions were made without adequate information.

 

8. Access through the Refuge for the Proposed route (south of the Refuge) should be limited to roads that are already developed (Routes 8a and Summit Lake Road). No additional roads should be developed within the Refuge.  All information necessary to conduct the Compatibility Determination must be included in the EIS process for public comment.

 

9. Use of developed roads in the Refuge is required to be regulated under a Special Use Permit after completing a Compatibility Determination (meeting requirements for public safety and protecting of wildlife and cultural resources).  All information necessary to conduct the Compatibility Determination must be included in the EIS process for public comment.

 

10. The sagebrush ecosystem is a dwindling legacy of the West. The entire route of the Ruby Pipeline cuts through the best remaining habitat.  Construction activities should avoid and minimize impacts, and mitigate damage so there is no net loss of habitat for sensitive species like sagegrouse, pygmy rabbit, Lahontan cutthroat trout and migratory birds.

 

11. FERC’s accelerated NEPA process has prevented adequate environmental analysis and public comment.  The comment period should be extended at least another 30 days.

 

Send comments by August 10, 2009 to:

 

Secretary of FERC
  File comment by online (QuickComment):       https://ferconline.ferc.gov/QuickComment.aspx
  Mail original and two copies of comments to:
            Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE; Room 1A
Washington, DC 20426

 

Secretary of Interior
  Send comments online:
  Mail comments to:
            Ken Salazar, Secretary
Department of the Interior
1849 C Street, N.W.
Washington DC 20240

 

Background information on the Ruby Pipeline
Information from Ruby Pipeline, LL:C

 

FERC’s Draft Environmental Impact Statement:

 


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