Eastern Sandoval Citizens Association

Comments for Pipeline Project Extended to Weds., December 5

The Farmington BLM Field Office has extended to December 5 the period for public comments regarding their preparation of an EA (Environmental Assessment) on a proposed project for an interstate natural gas liquids pipeline, which would use existing pipelines running through Placitas, including the Placitas Open Space.  Comments can be submitted by mail to:

Lorraine Salas

BLM National Project Manager

1800 Marquess St.

Las Cruces, NM 88005

or by email to: lsalas@blm.gov

We must correct an error that appeared in a previous LPA announcement about this project.  We wrote there that the pipeline would carry “liquified natural gas”.  Instead the pipeline is proposed to carry “natural gas liquids”, which are substances like butane and propane.

Further information on this project can be found on the LPA website here.  Please check the site for updates as we learn more.  The BLM website page discussing this project is here.

Las Placitas Association (LPA) and ES-CA have just posted their joint comments on the Bureau of Land Management Draft Resource Management Plan (BLM DRMP) for the Rio Puerco area, including Placitas.  Please feel free to use all or parts of these comments for your submission to the BLM.  Comments must be submitted to the BLM no later than November 26.

The comments can be found on the LPA website here: http://lasplacitas.org/rio_puerco/comments.php.  These comments may be revised over the coming days, so please check this web page occasionally for revisions.

There are 2 different comments documents posted: 1) The full 18 page joint LPA/ES-CA Comment document, including detailed comments on all the major topics, 2) A shorter 3 page document consisting of abstracts/summaries from the full document.  Both of these can be useful in submitting your own comments.

A Workshop will be held this coming Saturday, November 17, at 2 PM at the Placitas Community Center on how to best submit comments to the BLM.  All are invited.  The  San Felipe and Santa Ana pueblos are also invited to give short presentations on their proposals to acquire Placitas Area BLM parcels for wildlife corridors.  Materials will be handed out at the Workshop to help in submitting comments.

The full DRMP text and maps can be found here: http://lasplacitas.org/rio_puerco/index.php.

Information on how to submit comments to the BLM can be found here: http://www.blm.gov/nm/st/en/fo/Rio_Puerco_Field_Office/rpfo_planning/rpfo_draft_rmp.html

BLM RMP Comment Deadline Extended through November 26th

by Sandy Johnson/President/Las Placitas Association

On October 9, 2012 board members from Las Placitas Association and Eastern Sandoval Citizens Association met with Jesse Juen, the State Director of the BLM and his assistant Aden Seidlitz in Santa Fe and secured a 45 day extension to the comment period for the BLM Resource Management Plan.  The purpose of the meeting was to convince the BLM that the Draft Environmental Impact Study (DEIS) in their Resource Management Plan (RMP) for the parcels in Placitas contained enough text and mapping flaws that Placitans could not accurately provide comments.

Maps presented in the plan have been superseded more than once due to errors found by LPA members studying it.  Boundaries for proposed new gravel mines were not always defined in the alternatives, and text in the plan did not match maps in the plan.  One alternative proposed by the BLM didn’t even have a description of the land use included at all, and page numbers between hard and electronic media differed.

With those kinds of errors, LPA and ES-CA was concerned that comments made by the citizens of Placitas could end up being ignored, or worse, members of the community could make little sense of the text and maps and not provide comments at all.

LPA and ES-CA continue to work on creating substantive comments to the BLM by the new comment period due date.  Using the correct maps on the LPA web site you can see where BLM proposed mining sites are, and if you’d like to hike out there you will find that the two pieces of the 800 acres proposed for mining are now staked and marked.

Another accomplishment at this meeting was to get both LPA and ES-CA on the list of officials and agencies to be contacted when specific BLM projects are planned in the Placitas area, prior to their environmental assessments so we can effectively participate in the process.  We are now going to be notified with the quarterly “Expression of Interest” letter assembled by the BLM that lists proposed mining operations for the area. Both organizations will post information as it is received about upcoming BLM activities in Placitas and if you wish to be notified you may register on the LPA and/or ES-CA to receive that information.

Please plan on submitting your comments by November 26 on the proposed use of the Placitas BLM.  Participation matters.  Both LPA and ES-CA will have sample comments on their respective web sites to help with the formulation of yours.  You can submit your comments via email to: NM_RPFO_Comments@blm.gov.  

The official BLM website is: www.blm.gov/nm/st/en/fo/Rio_Puerco_Field_Office/rpfo_planning/rpfo_draft_rmp.html

Visit the LPA Web Site for up to date information on the RMP: http://www.lasplacitas.org/rio_puerco/index.php

LPA and ES-CA were greatly aided in convincing the BLM to extend the comment period by our state and federal legislators. On the state level, State Senator John Sapien, State Representative Jim Smith and State Representative David Doyle have worked in concert with LPA and ES-CA.  Senator Sapien worked with Director Juen to achieve the initial extension.  State Representative David Doyle arranged the October 9 meeting, which included the Governor’s Deputy Chief of Staff Ryan Cangiolosi and State Energy and Minerals Secretary John Bemis.  Patricia Dominguez from Representative Martin Heinrich’s staff also provided help on the federal level.  We greatly appreciate the effort they all made on behalf of Placitas.

Oct. Letter to BLM Requesting Extension

The attached letter was sent by FedEx, on October 4, 2012, to Mike Pool, National BLM Director, and is from the Las Placitas Association (LPA) and the Eastern Sandoval Citizens Association (ES-CA). To date, the BLM has stonewalled on the previous 45 day request regardless of the numerous inconsistencies discovered in the current RPM draft.

LPA and ES-CA are working together to draft substantive comments; however, as of Wednesday October 3, it was still unclear what prescriptive uses were actually included in the Rio Puerco Regional Management Plan’s (RPM) four options for lands in Placitas. As of Sunday, October 7, for the lands within the Placitas Area, there is still not an accurate definition of potential uses available to the public. Publicly available maps and text do not agree, and it may be that Parcel A, the 3, 000 acre “Buffalo” shaped land at the north end of Placitas, may in fact be without a BLM recommended prescriptive use. This makes substantive comments all the more difficult and basically has created an “anything goes” scenario with only the BLM able to interpret final use. This could be a disadvantage to Placitas if comments are wildly varying and considered by the BLM not substantive.

With an accurate draft RMP, and adequate time for the public to understand potential uses, the lack of definition could actually be an advantage if Placitans can achieve some consensus on potential uses or non-uses. The uncertainties within the RMP draft document and BLM’s unwillingness to grant more time to protect the public process has made some of us suspicious of BLM’s intent.

The Bureau of Land Management (BLM) held a public meeting Monday, Sept. 17, regarding their draft Resource Management Plan (DRMP) for the Rio Puerco region.  Well over a hundred people from Placitas and elsewhere were in attendance.  The meeting was initially structured such that there would be a presentation by BLM personnel, primarily Tom Gow, Rio Puerco Field Office Manager, and Angel Martinez, Planning and Environmental Specialist, followed by a brief Question & Answer period, following which the attendees would talk individually to BLM “experts” in a “workshop” session.  But at the beginning of the Q&A period it became evident that the attendees wished the BLM to address specific concerns to everyone, so a lengthy interaction between the audience and BLM took place.  During the BLM presentation Martinez emphasized that to be effective submitted comments must be “substantive”.  They should either point out errors in the data that BLM used to arrive at their recommendations, or expose the omission of relevant data.

Over a month ago Las Placitas Association (LPA) had formerly requested a 45 day extension to the public comment period, scheduled to end on October 11.  This date was set due to the original EPA notice for the DRMP being published in the Federal Register on July 13, with October 11 being 90 days from then.  However the DRMP was dated August 1, and it seems reasonable to suppose that the 90 days be counted from then.  To further complicate this matter, the BLM Federal Register notice was published two weeks after the EPA notice.  But LPA only asked for a 45 day extension from October 11.  It is standard governmental procedure for reasonable requests like this to be granted.

However at the Sept. 17 meeting Tom Gow announced that there would only be a 15 day extension granted, to October 26.  Interestingly, the previous week at a similar BLM public meeting in Albuquerque Gow told the attendees that the 45 day extension would very probably be granted.  When he was challenged on the too brief 15 day extension at the Sept. 17 meeting, Gow said he would resubmit the request for the 45 day extension.

At the public meeting held by LPA and ES-CA (Eastern Sandoval Citizens Association) at the Placitas Elementary School on August 26, a promise was made that recommendations and guidelines for comments would be posted to the LPA website soon.  That this has not yet been done is due to LPA uncovering a number of major discrepancies in the DRMP, which make it difficult to know exactly what to comment on.  These mainly involve the “preferred alternative” in the DRMP regarding gravel mining on the “Buffalo Parcel”, which is our name for the approximately 3200 acre BLM parcel to the north of Placitas.

The main discrepancy is that the text for this “preferred alternative”, which appears on page 2-50 of the electronic version of the DRMP and page 2-51 of the print version – see below for more on this mysterious difference between the two versions – states that mineral extraction, including gravel, would be restricted to “Section 13, Township 13 North, Range 4 East and Section 18, Township 13 North, Range 5 East”, which indicates two sections on the north edge of the Buffalo Parcel bordering the San Felipe Pueblo lands.  Yet the maps in the DRMP indicate that such mineral extraction would be allowed throughout the Buffalo Parcel, also on the 200 acre BLM parcel bordering Overlook, Cedar Creek and Ranchos de Placitas subdivisions, and on the Placitas Open Space managed by the Albuquerque Open Space.  This discrepancy was pointed out in a meeting between LPA directors and Mr. Martinez from BLM about 4 weeks prior to the Sept. 17 meeting, but at that meeting BLM still did not have an answer regarding which was right: the text or the map.

On Wednesday, Sept. 19, Martinez informed two LPA directors that the text is right and the maps are wrong, and that this correction would appear the next day on the BLM web site.  But as of this evening no such correction has appeared.  Also Martinez verbally informed LPA that only an extension to October 26 would be given.  However even that has not appeared on the BLM web site, where it still lists the last date for submission as October 11.  At present all we have is verbal promises from BLM officials regarding any of this.

But as we have discovered, things are even worse regarding the Buffalo Parcel.  Though the text indicates the two sections that would be open for gravel mining, BLM has provided no GIS data that would allow citizens to precisely locate the boundaries of those sections, walk them and inspect them.  This lack of location data is perhaps why this was not specified on the DRMP maps.  For this reason alone it is unreasonable to expect citizens to submit “substantive” comments at this time regarding BLM’s mining intentions.  If the agency itself is so confused about their “preferred alternative”, how are we citizens to respond at all effectively?

Then there is the recently discovered difference between the electronic and print versions of the DRMP.  What appears on 2-50 of one version appears on 2-51 of the other.  This leads to the question: Just how different are the two versions, and are the differences trivial or substantial?  Citizens should not be expected to play “Where’s Waldo”, that is, to be BLM’s proofreaders.  This raises concerns about whether the DRMP, though 4 years in the works, was rushed out the door prematurely.

LPA has also found upon discussion with BLM personnel that they did not take into adequate consideration the effect on property values and other social/economic factors of mining activities so close to residential properties.  Nor have they given due consideration to the environmental effect this would have on wildlife populations that use that area for habitat and migration.

What has made discussion of the Buffalo Parcel all the more interesting in recent weeks is that both the Santa Ana and San Felipe Pueblos have expressed strong interest in acquisition of that BLM parcel, largely to protect these wildlife habitats and migration paths.  This would predictably put the Buffalo Parcel to far different uses than if BLM were to continue to manage it.  So an important question that arises regarding public responses to the DRMP is what to comment as regards these possible acquisitions, which are not mentioned in the DRMP “preferred alternative”.