Comments on oil and gas lease auction, Parcel No. 188, New Fork River, Sublette County


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,

Section 8.

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.

wyo.gov/projects/projects-funded, almost

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

purposes.

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

dollars.

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

conserved.

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.

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