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The Wasatch-Cache National Forest finally released the Table Top Exploratory Oil Well Draft Supplemental Environmental Impact Statement (DSEIS). What makes it supplement? The 1994 EIS and decision to drill for oil in the heart of the Main Fork just north of the High Uintas Wilderness (see HUPC Newsletter and LYNX, 1/97, 4/98, 6/01, 4/04, 6/04, and 8/04 for background).

The history is complex and tells two distinct stories: 1) the utter absurdity of oil and gas leasing rules on public lands, and 2) the complete support of the Wasatch-Cache National Forest for drilling the heart of this roadless area. It is a long story we have told many times over, so we will summarize:


The Table Top oil and gas unit consists of the thousands of acres from the West Fork Blacks Fork west to the Main Fork, much of it within roadless country and most of it leased for many decades. (In theory, a lease has a life span of ten years, but, in a decidedly biased twist of fate, leases often "last" for decades and decades without any activity or drilling!) This particular proposed well site was the second proposed for the Main Fork. The first was in the late '80s. When our delightful predecessor group, the Utah Wilderness Association, appealed it, the company (AMOCO) withdrew the proposal.


In the early '90s Chevron proposed the existing well site. The EIS was completed in '94. The Utah Wilderness Association appealed but this time lost. Another company took over the drilling rights from Chevron (another common practice.) However, the clock on the lease was ticking and BLM (the Department of Interior controls the actual leasing; the Forest Service decides whether to lease or not) informed them there would be no suspension. Chevron had to work around various EIS restrictions to beat the clock. This offered us some hope as the company noted there was not adequate time.


The company appealed to the Interior Board of Land Appeals (IBLA) and was given a suspension on the lease after finishing some initial road work.


And as it does so often on leasing issues, time stopped. A new drilling company stepped in with a new demand upon the Forest Service either lease the few remaining unleased lands around the drilling site (about 700 acres or so), or drilling can't/won't proceed!


Over our comments and those of dozens of others, the forest plan offered the lands for lease without hesitation.


HUPC and others appealed the forest plan and that particular decision in June 2003. Although the Forest Service has had but not answered our appeal(s) for 18 months, in November the land was offered for lease, purchased, and the SDEIS released without a scoping comment period (also legal, but not mandated).

And here we are today. The Table Top Unit runs from the West Fork Blacks Fork to the Main Fork, most of it under lease for many decades and much of it within roadless country. Notably, most of this unit and all of the Main Fork is within the North Flank Fault which the US Geological Survey notes has a very low potential for oil discovery. To this date, none has been discovered! Yet on we proceed with the Forest Service foaming at the mouth to lease and allow drilling.

While we do appreciate the process of preparing a SDEIS (it was released without formal public scoping), we all know that is superficial and disingenuous. The history is clear: the applicant was unwilling to go forward until an oil and gas leasing decision was made in the revised forest plan, assuming the few remaining unleased lands in the drilling vicinity would be offered for lease. While the Wasatch-Cache had the clear opportunity not to offer the lands for leasing and recognize other resource values (roadlessness, potential wilderness, wildlife, backcountry recreation, etc.) in the revised forest plan and in spite of numerous public comments, the Wasatch chose to offer those lands for lease.

It is intellectually dishonest to suggest the Wasatch-Cache has not aided, supported and cemented the decision to continue the Table Top leasing and drilling proposal, given the specific history and decisions made by the forest to ease both the leasing and drilling proposal and to assure the action takes place. Thus we have a hard time believing the sincerity and honesty of the Forest Service in the context of this DSEIS.

The revised forest plan was prepared not to objectively look and analyze resource values on the Main Fork, but to assure the decade-old, stalled drilling proposal continued when it became convenient for the drilling proponents. So much for public interest and professional forest planning!

Problems with the SDEIS are many, deep and rendered meaningless by the history of the decision-making process. It is indeed a credibility-stretching document. The DSEIS minimizes impacts to roadless areas by suggesting roadlessness surrounds the drilling site and access road and does not directly impact roadlessness (except for small acreage at the alternative drilling site), yet only tangentially notes that this is because the action has already bisected a continuous roadless unit. The DSEIS continues with the depleted logic that the impacts to the roadless landscape are minimal because the drilling site and road impact only a small percentage of the roadless acres.

Pine Marten By Margaret PettisThe value of roadlessness is not simply a function of acres; it is one of the continuity, size, and scope of those acres. In this case, a large roadless landscape has been bisected and will now host a major industrial development whose impacts reverberate throughout the roadless landscape.

Dick Carter

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