As president of the Upper Green River
Chapter of Trout Unlimited, I wanted to
submit our comments and concerns regarding
the proposed oil and gas lease auction
of land adjacent to and underlying the New
Fork River in Sublette County, specifically
Parcel #188, Township 32N, Range 108W,
The mission of the Upper Green River
Chapter of Trout Unlimited is to conserve,
protect and restore cold water fisheries,
habitat and watersheds in Sublette County,
including the Upper Green River Basin. The
New Fork River flows south from New Fork
Lake until it reaches its confluence with the
Green River south of Highway 351. The
New Fork River is one of the more productive
trout streams in Wyoming and sees
heavy usage during prime angling season.
It has a prominent statewide reputation, as
evidenced by drift boat trailer tags from outlying
counties and states.
The New Fork River winds its way
through this area in numerous active oxbows.
The wide sandy shoulders and ancient
oxbows are evidence of ongoing river movement.
According to the Sublette County GIS
map, this section of the New Fork River is
designated as wetland on the National Wetlands
Inventory and floodplain per the designated
Federal Emergency Management
Agency floodplain map. The Sublette GIS
map further notes that this low lying area is
within zero to 50 feet of groundwater. Obviously,
any disturbance of this loose composite,
graveled river course will affect the
hyporheic zone hydraulics with its potential
for riverine water quality corruption as well
as potable well water contamination.
The Upper Green River Chapter of Trout
Unlimited has participated in multiple New
Fork River riparian repair projects, contributing
more than $85,000 in funding for bank
stabilization and stream habitat projects. But
UGR-TU is not the only organization that
recognizes the worth of this blue ribbon trout
habitat. Three other groups, the Natural Resources
Conservation Service (145 acres),
Jackson Hole Land Trust (352 acres) and
Wyoming Stock Growers (470 acres) hold
conservation easements along the New Fork
River in the stretch just above the airport
to the rivers confluence with the East Fork
River. The easement purchase cost of these
parcels is unknown to UGR-TU, but is likely
substantial, reflecting the conservation value
of this area.
The State of Wyoming has also recognized
the significance of this water resource.
According to the Wyoming Wildlife & Natural
Resource Trust website, https://wwnrt.
half a million dollars have been expended
for projects on the New Fork River and tributaries
to protect the wetlands, floodplains,
banks and fish habitat. It’s confounding that
the State of Wyoming’s left hand (working
to conserve fragile areas) and right hand
(striving to develop fragile areas) are at cross
In February 2019, I attended a coordination
meeting of fisheries experts from the
Wyoming Game & Fish Department, U.S.
Bureau of Land Management, U.S. Forest
Service and U.S. Fish and Wildlife Service
Agency. One topic of discussion was ongoing
fish and wildlife habitat improvement
projects on the New Fork River, including
one scheduled for completion in 2019. In
keeping with UGR-TU chapter priorities,
we offered our volunteer service on this riverbank
restoration and stabilization project.
In conclusion, the Upper Green River
Chapter of Trout Unlimited respectfully
requests that parcel No. 188 be withdrawn
from the upcoming auction. First, the potential
impact of land disturbance on groundwater
and surface water quality and habitat
is problematic. Second, the Wyoming Office
of State Lands and Investments must act as
a good steward and not negate prior publicly
funded projects that would waste taxpayer
If the OSLI decides to go forward with
selling development opportunities within a
hydrologically sensitive area, UGR-TU requests
the following be included to protect
coldwater resources and fish habitat:
1. A minimum 900-meter stream buffer
from bank-full or high-water stage. As evidenced
by shifting oxbows, the New Fork
River is an active waterway and areas currently
considered “dry” could become inundated
in future years.
2. At the time of application of APD, any
location must be approved by a WGFD biologist
or appropriate biologist to provide
specific protective stipulations for both onsite
and off-site impacts.
3. Ensure interim reclamation, as well as
final reclamation, is attached to leases in an
initial lease agreement. Swift, effective interim
reclamation is a UGR-TU priority for
promptly restoring all areas to pre-disturbance
conditions and by conducting reclamation
concurrently with other operations.
4. OSLI should require industry to use
gold book standards for reclamation and
maintenance of native vegetation.
5. No surface occupancy on areas that are
in perennial, coldwater streams, springs and
other water sources.
6. OSLI would work closely with Trout
Unlimited and the Wyoming Game & Fish
Department to develop stipulations to ensure
existing habitat improvements projects are
not compromised, community fisheries are
enhanced and destination sport fisheries are
Thank you for your time and consideration
of our comments. We look forward
to continued dialogue to adequately protect
sport fisheries and areas with a coldwater
nexus in Sublette County and the Upper
Green River Basin.