Dear Superintendent Whittington,
We, the undersigned organizations, write to provide comments on the proposed Plan of Operations (“POP”) for the Nobles Grade 3-D seismic survey (project no: 13BOC2197). The revised POP, proposed by the Burnett Oil Company (“Burnett” or “applicant”) for the Big Cypress National Preserve (“BNCP”) and the Big Cypress National Preserve Addition (“BCNPA” or “Addition”) (collectively, “the Preserve” or “Big Cypress”) would affect more than 110 square miles of the Preserve.
As drafted, the proposed POP would cause significant adverse impacts to the Preserve, contravene the Big Cypress National Preserve General Management Plan and Minerals Management Plan (“GMP/MMP”) and the agreement governing the exercise of oil and gas rights in the Addition. The operations would be likely to adversely affect federally-listed threatened and endangered species. The proposed POP may not be approved unless it is modified to comply with applicable laws, management plans, and agreements. The National Park Service (“NPS”) must prepare an Environmental Impact Statement (“EIS”), pursuant to the National Environmental Policy Act, (“NEPA”) that fully evaluates the impacts of the POP and considers reasonable alternatives to minimize impacts on the Preserve. Further, the NPS should not approve any POP until it updates the 1991 Minerals Management Plan for the Preserve and finalizes revisions to 36 C.F.R. Part 9, Subpart B (“9B Rules”) to ensure that standards governing oil and gas exploration and development take account of current information about modern-day technologies and practices, the resulting impacts, and best practices for environmental protection and mitigation.
