The Houston Regional Group and Lone Star Chapter of the Sierra Club (Sierra Club) provided scoping comments to the U.S. Forest Service (FS) on October 21, 2020, about a proposed special use permit (SUP) for the Raven Forest Operating LLC Complex (RFOLLCC) in Sam Houston National Forest (SHNF). The RFOLLCC includes:
1. An existing natural gas well pad A with three drilled wells and with one additional well to be drilled (4 wells).
2. Adding 5 wells to pad A (a total of 9 wells) and expanding well pad A from 2.35 acres to 5.74 acres.
3. Use of the existing pad A right-of-way (ROW) and construction of an 8” natural gas pipeline to add to the existing 4” natural gas pipeline.
4. Construction of an 8” or less natural gas pipeline to connect well pad A to pad B in a 15-foot-wide ROW.
5. Possible construction of future utilities (fiber optic, electrical, water, oil, etc.).
6. Stored topsoil stockpiles, installed erosion control measures, and construction of diversion ditches.
7. Construction of a natural gas pipeline in an existing 4.83-mile-long multi-use ROW.
8. Construction of a 9.38 acre well pad B to allow drilling of 8 wells.
9. Construction of a new 202-foot road (20 feet-wide), connected to existing 2,120-foot road with a natural gas pipeline that extends 7,673 feet and merges with a larger pipeline on FM 149.
10. Boring pipelines under Red-cockaded Woodpecker (RCW) clusters, starting 50 feet away from each cluster boundary, and under low-lying areas.
11. No tree removal within 200-feet of RCW cavity trees; no equipment use within 50-feet of RCW cavity trees; and no storage of construction equipment and material within 200-feet of RCW cavity trees.
Some Sierra Club comments about significant issues include:
1. An environmental impact statement (EIS) is required to completely analyze this oil/gas proposal.
2. Climate change impacts must be fully revealed and analyzed with a climate change ecological resilience and resistance plan (CCERRP) prepared and implemented.
3. A mitigation plan is required for the RCW, forest fragmentation, Lone Star Hiking Trail (LSHT), riparian ecosystems, prairies, noise pollution, light pollution, illegal off-road vehicle use, roads, solitude, climate change, and non-native invasive plant species (NNIPS).
4. All impacts due to drilling, fracking, production, operation, transportation, etc., must be revealed including direct, indirect, secondary, connected, and cumulative impacts, and require a public comment period.
The Sierra Club will continue to track this proposal and work to reduce its climate change and environmental impacts. If you have any questions contact Brandt Mannchen at: brandt_mannchen@comcast.net or 281-570-7212.
Author: Brandt Mannchen
Note: The image is from the Texas Railroad Commission GIS public image viewer at https://www.rrc.state.tx.us/about-us/resource-center/research/gis-viewers/ and the existing well (in red), plus the proposed wells and pipelines (black circles and lines) are visible.