Colorado Trout Unlimited has released their comments to the BLM on the Christo “Over the River” project and have determined there are many areas of the plan that need further analysis and improvements before the project can proceed.

The comments are broadly broken down into three areas: environmental impacts and risks of the project; inadequacies in the analysis within the EIS; and consistency with BLM management plans and special area designations.

Environmental Impacts of the Project

Of most concern to CTU is the (1) disturbance of land and vegetation along the river – and the associated increase in sedimentation in the river; (2) risk of fuel/chemical spills; (3) risks from catastrophic failure; and (4) the need for a “leave no trace” approach. Point number four, leave no trace, is the strongest request made by CTU. Essentially we are asking that “what goes in the ground must come out” I love that line. It’s a great rally cry for the opposition to the project.

Inadequacies in the EIS Analysis

The main argument here is that the EIS fails to take into account the cumulative effect of the 9100 bore holes of the project. CTU argues that although the single impact of one bore hole may be insignificant the EIS fails to take into account the impacts of all holes combined.

CTU also argues that there is little to no analysis on the impact to guides and fisherman in the area. The comments point to specific studies that show anglers prefer scenic beauty and poor fishing to excellent fishing in poor scenic areas. The later would be the case during construction of the project.

Consistency with Management Plans and Special Designations

This section of the comments calls into question whether this project meets the directive established by the Arkansas Canyonlands ACEC. There are several major environmental impacts that will occur within the project that seem to fly in the face of the BLM regulations. These include:

“The DEIS states that Over the River would have “moderate to significant” impacts on bighorn sheep, including long-term impacts (DEIS 4-3).  Raptors would face moderate to significant impacts as well (DEIS 4-19, 4-20).  Peregrine falcon specifically would also face moderate to significant impacts (DEIS 4-55).”

Overall the comments from CTU ask BLM to address several improtant issues with the “Over the River” before the project is approved. Read the full version of the comments and let CTU know what you think.