The undersigned organizations write to provide comments on the proposed Environmental Assessment (“EA”) for Burnett Oil Company’s 3-D Seismic Survey proposal within Big Cypress National Preserve (“Preserve” or “Big Cypress”). The Burnett Oil Company, Inc. (“Burnett”) has proposed to conduct geophysical exploration activities over 110 square miles (70,454 acres) within the Preserve (hereinafter, “proposed action”).
We urge the National Park Service (“NPS”) to reject Burnett’s proposed plan of operations (“POP”). If NPS nonetheless decides to allow the proposed action to go forward, the agency must prepare a full Environmental Impact Statement (“EIS”) for all phases of exploration because the proposed action constitutes a major federal action under the National Environmental Policy Act (“NEPA”). NPS has the broad legal authority to protect the Preserve’s resources and cultural and recreational values from the adverse effects of oil and gas development. NPS fails to provide this much-needed protection because the EA: (1) improperly segments Burnett’s larger four-phase exploration proposal; (2) fails to evaluate all of the direct, indirect, and cumulative impacts of the proposed action, subsequent exploration phases, and adjacent exploration activities on Preserve resources and values; (3) fails to fully evaluate impacts to endangered and threatened species and critical habitat for these species; (4) fails to analyze the effectiveness of the proposed mitigation measures; and (5) fails to evaluate a reasonable range of alternatives to the proposed action.