Table of Contents

A. The DSEIS is part of a fundamentally-flawed 2007 Forest Plan that never considered oil and gas drilling a significant issue

The DSEIS grew out of the development of the 2007 Forest Plan. Unfortunately, when the 2007 Forest Plan was developed, the Forest Service refused to consider OGD a significant issue. The DSEIS is now attempting to "fix" that mistake by addressing many of the issues that should have been addressed during the forest plan revision process. However, unless and until the Forest Service revisits the entire planning process and comprehensively analyzes the direct, indirect and cumulative effects of OGD in relation to all other aspects of forest management, such as recreation and tourism, clean air and water and protection of wildlife habitat, this DSEIS process will not satisfy the requirements of NEPA or the National Forest Management Act (NFMA).

Preparing this SEIS to “fix” a few parts of a fatally flawed Forest Plan is simply not enough, particularly in light of what the legal opinion written by Ronald Mulach on May 24, 2007 says about the Forest Service’s adherence to the NEPA, NFMA, the Multiple-Use and Sustained-Yield Act (MUSYA) and the Endangered Species Act (ESA).