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Written Advocacy

Public Lands 

Comments on Rock Springs RMP revision (April 4, 2011)
Comments on BLM’s proposed regulations for oil and gas hydraulic fracturing on federal and Indian lands (Aug. 12, 2013)
Letter to the Office of Governor Matt Mead and the Wyoming Oil and Gas Conservation Commission on orphan oil and gas wells (Jan. 15, 2014)
Comments on BLM’s proposed amendment to the Pinedale RMP (Oct. 9, 2017)
Letter re: comments on Converse County oil and gas project DEIS (March 12, 2018)

True Oil’s proposed drilling in the Wyoming Range —
Scoping comments regarding True Oil, LLC’s proposed Lander Peak Exploration Project on the Bridger-Teton National Forest (May 27, 2012)
Additional scoping comments regarding True Oil, LLC’s proposed Lander Peak Exploration Project on the Bridger-Teton National Forest (Dec. 1, 2015)
Objection to True Oil’s Lander Peak Area Exploration Proposal (May 22, 2017)
Response to Forest Service’s offers of resolution to the Outdoor Council’s objection to True Oil, LLC’s proposed Lander Peak Area Exploration Project (Nov. 9, 2017) 

Contested Oil and Gas Leases in the Wyoming Range —
Letter re: leasing EIS for 44,720 acres on the Big Piney Ranger District (Feb. 14, 2008)
Letter re: supplemental EIS regarding oil and gas leasing of 44,720 acres on the Big Piney Ranger District (April 10, 2008)
Letter re: supplemental EIS regarding oil and gas leasing of 44,720 acres on the Big Piney Ranger District (April 16, 2008)
Scoping comments for the supplemental EIS regarding oil and gas leasing of 44,720 acres on the Big Piney Ranger District (April 25, 2008)
Comments on the draft supplemental EIS regarding oil and gas leasing in the Wyoming Range (March 17, 2010)
Analysis and critique of Stanley Energy’s comments on the DSEIS for oil and gas leasing in the Wyoming Range (May 4, 2010)
Record of Decision regarding 35 lease parcels located within the Wyoming Range (Jan. 25, 2011)
Memorandum to Citizens for the Wyoming Range re: disposition of 44,720 contested oil and gas lease acres in the Bridger-Teton National Forest (Jan. 7, 2013)
Letter to Intermountain Regional Forester Nora Rasure (Jan. 21, 2015)
Comments on the draft supplemental EIS regarding oil and gas leasing in portions of the Wyoming Range (May 17, 2016) 

Mineral Leasing Act Lawsuit on behalf of the BLM —
Dismissal of ‘energy companies’ appeal request in mineral leasing act lawsuit (March 12, 2013)
Response brief of Wyoming Outdoor Council in mineral leasing act lawsuit (June 3, 2011)
Memorandum decision and order (June 29, 2011)
Complaint from ‘energy companies’ in mineral leasing act lawsuit (Oct. 15, 2010) 

136-Well Drilling Proposal in the Upper Hoback —
Comments on DEIS for Eagle Prospect Exploratory Wells Project on the Bridger-Teton National Forest (April 30, 2007)
Scoping comments for Eagle Prospect and Noble Basin Master Development Plan EIS (Feb. 6, 2008)
Letter to Bridger-Teton National Forest Supervisor Jacqueline Buchanan (Dec. 21, 2010)
Comments on DEIS for Eagle Prospect and Noble Basin Master Development Plan Project (March 10, 2011)
Letter to Bridger-Teton National Forest Supervisor Jacqueline Buchanan (Dec. 22, 2011)
Letter to Bridger-Teton Mineral Management Specialist Shane Walker (July 6, 2012)
Letter re: RMP amendment for 5,120 acres of split-estate land in Upper Hoback (Oct. 9, 2017) 

Wyoming Range Oil and Gas Lease Protests and Appeals —
Protest of parcel to be offered at BLM’s December 6, 2005 competitive oil and gas lease sale (Nov. 17, 2005)
Protest of parcels to be offered at BLM’s April 4, 2006 competitive oil and gas lease sale (March 17, 2006)
Petition for Stay Pending Appeal of Dec. 6, 2005 lease sale (May 8, 2006)
Protest of parcels to be offered at BLM’s June 6, 2006 competitive oil and gas lease sale (May 19, 2006)
Petition for Stay Pending Appeal of April 4, 2006 lease sale (June 2006)
Protest of parcels to be offered at BLM’s Aug. 1, 2006 competitive oil and gas lease sale (July 13, 2006)
Appellants’ Statement of Reasons for Petition for Stay Pending Appeal (July 2006)
Appellants’ reply to Appeal of the Dismissal of Protest of the sale of oil and gas lease parcels in April 4, 2006 lease sale (Sept. 5, 2006)
Appellants’ reply to Appeal of the Dismissal of Protest of the sale of oil and gas lease parcel in Dec. 6, 2005 lease sale (Sept. 8, 2006)
Petition for Stay Granted (Sept. 21, 2006)
Appellants’ request for clarification and objection to BLM’s request for remand (Jan. 19, 2007) 

Scott Well and Federal Well #26-2 in the Shoshone National Forest Comments, Appeals, and Letters —
Scoping comments on Windsor Energy Group’s proposed federal well #26-2 (Oct. 29, 2008)
Scoping comments on Scott Well #2 (Jan. 27, 2010)
Comments on pre-decisional EA for Scott Well #2 Project (Oct. 8, 2010)
Appeal of SUPO authorization for Scott Well #2 Project (June 9, 2011)
Request for State Director Review of the Decision Record (DR) and Finding of No Significant Impact (FONSI) for the Scott Well #2 Project (Feb. 17, 2012)
Issuance of a Stay of the approval of Scott Well #2 Project (June 29, 2012)
Letter from BLM State Deputy Director in response to Request for State Director Review (May 29, 2013) 

Shoshone Forest Plan Revision Letters and Comments —
Letter to Fremont County Commission (May 7, 2008)
Comments on Shoshone Forest Plan Revision (June 19, 2009)
Letter to Shoshone National Forest Supervisor Joe Alexander (May 10, 2011)
Comments on Shoshone Forest Plan Revision (Feb. 2, 2012)
Letter to Regional Forester Daniel Jiron (June 21, 2013)
Letter to Commissioners and Conservation District Representatives (July 30, 2013)
Letter to Governor Matt Mead (Feb. 21, 2014)
Letter of Objection to Shoshone Forest Plan Revision (March 20, 2014)
Letter to USFS Associate Deputy Chief James Pena (July 30, 2014)

Water 

Letter to Wyoming Oil and Gas Conservation Commission on a statewide groundwater testing rule (July 11, 2013)
Letter to Wyoming Oil and Gas Conservation Commission on a statewide groundwater testing rule (Oct. 11, 2013)
Comments on DEQ/WQD’s Categorical Use Attainability Analysis for Recreation and Final Determination Regarding the Categorical Redesignation of Streams in the State from Primary Contact to Secondary Contact Recreation (Sept. 16, 2015)
Letter to DEQ/WQD regarding granting of variances under the Clean Water Act (March 27, 2017)
Letter to EQC on Water Quality Variances (Feb. 20, 2018)
Letter re: True Oil, LLC – Lander Peak Area Exploratory Proposal – BLM Must Address Potential Downhole Impacts to Usable Water in Compliance with Onshore Order No. 2 (March 15, 2018)
Letter re: Error in DEQ Categorical Use Attainability Analysis for Recreation—Townsend Creek, Lander, Wyoming
(June 12, 2018)
Letter re: Response to Townsend Creek Petition (July 18, 2018)
Letter re: Triennial Review of Water Quality Standards (Oct. 12, 2018)
Comments on Draft EIS for the Lost Creek Uranium Mine Modification-Expansion (Oct. 15, 2018)

Moneta Divide Gas Field Discharge Permit Comments and Memorandums —
Analysis of, and comments on, proposed WDEQ Wastewater Discharge Permit for Aethon Energy Operating, LLC (June 27, 2019)
Review of ERM Water-Quality Modeling Study of Boysen Reservoir
 (July 1, 2019)
Comments on Moneta Divide Gas Field Discharge Permit (July 3, 2019) 
Complaint and Request for Investigation of the Moneta Divide Oil and Natural Gas Field (Aug. 15, 2019)

Air 

Comments on DEQ, Air Quality Division, Upper Green River Basin Ozone Strategy (March 2013)
Comments on DEQ/AQD Proposed Requirements for existing oil and gas production facilities/sources in the Upper Green River Basin (July 11, 2014)
Comments on Oct. 2014 Proposed Revisions to DEQ, Air Quality Division, requirements for existing oil and gas production facilities or sources in Upper Green River Basin (Dec. 1, 2014)
Comments on EPA’s Proposed Revisions to 8-Hour National Ambient Air Quality Standard (NAAQS) for Ozone (March 17, 2015)
Comments on Feb. 2015 Proposed Revisions to DEQ, Air Quality Division, Requirements for existing oil and gas production facilities or sources in Upper Green River Basin (April 13, 2015)
Memorandum regarding cost effectiveness of conducting quarterly LDAR (Aug. 25, 2015)
Comments on DEQ, Air Quality Division, update to oil and gas production facilities (Oct. 26, 2015)  

Wildlife

Comments on Wyoming BLM second quarter competitive oil and natural gas lease sale EA (March 27, 2018)
Comments on Wyoming Greater sage-grouse Draft RMP amendment and EIS (Aug. 2, 2018)
Letter re: protest of Wyoming BLM September 2018 competitive oil and natural gas lease sale (Aug. 11, 2018)
Letter re: request for lease deferrals in the Sublette mule deer migration corridor and in mule deer crucial winter range (Aug. 21, 2018)
Letter re: supplemental comments on Wyoming BLM fourth quarter competitive oil and natural gas lease sale EA (Nov. 9, 2018)
Letter re: ensuring functionality of wildlife corridors by using the best available science to implement secretarial order 3362 (Dec. 3, 2018)
Comments on US Forest Service’s proposed land management plan amendments and DEIS (Dec. 10, 2018)
Comments on Wyoming BLM first quarter competitive oil and natural gas lease sale EA (Dec. 13, 2018)
Letter re: protest of Wyoming BLM February 25 to March 1, 2019 competitive oil and natural gas lease sale (Jan. 19, 2019)
Protest of Wyoming Greater sage-grouse proposed RMP amendment/final EIS (Jan. 28, 2019)
Letter re: protest of Wyoming BLM March 2019 competitive oil and natural gas lease sale (Feb. 25, 2019) 
Comments on the Supplemental Draft Environmental Impact Statement for Converse County Oil and Gas Project (July 25, 2019)
Protest of the Wyoming BLM’s fourth quarter competitive oil and gas lease sale (Nov. 6, 2019)
2018-2019 BLM Oil & Gas Leased Acreage within the Baggs Mule Deer Migration Corridor
2018-2019 BLM Oil & Gas Leased Acreage within the Sublette Mule Deer Migration Corridor
2018-2019 BLM Oil & Gas Leased Acreage within the Platte Valley Mule Deer Migration Corridor