On May 2, 1982, oil companies in western Colorado shut down the Colony Oil Shale Project and left 2,200 residents unemployed overnight. That day went down in Colorado infamy as "Black Sunday" and was a fateful lesson of the technical and cost difficulties surrounding large-scale development of unconventional energy resources.

Now the Bureau of Land Management (BLM) has issued a Draft Programmatic Environmental Impact Statement (PEIS) for commercial oil shale and tar sands development on our public lands in Colorado, Utah, and Wyoming. Oil shale is rock that yields oil when heated to extreme temperatures, and tar sands contain extremely heavy oil mixed with sand and clay. While tar sands are present only in Utah, oil shale is present in all three states.

Although the PEIS is itself not a leasing document, it establishes where future leasing will occur on BLM lands. Industry wants to lease public land now to develop these dirty fuels, even though there are still years of research and development before we will have a more complete knowledge about what the environmental impacts will be.

There is no good reason for BLM to be preparing for commercial oil shale and tar sands leasing. Oil shale developers admit they are not ready to produce on a commercial scale now, and won't be for many years. Technologies are still in the research and development phase, and industry leaders believe commercial development is more than a decade away. BLM should monitor companies' research and development to see whether it is technically and economically viable before taking steps towards commercial leasing. Furthermore, we know from preliminary research, as well as lessons learned from tar sands development in Canada, that the environmental impacts of tar sands leasing will likely be enormous, but the BLM's Draft PEIS doesn't provide sufficient detail on foreseeable cumulative impacts. The public must be able to judge for themselves whether the technology results in unacceptable impacts on the environment or communities.

There are many potentially negative impacts of commercial-scale oil shale and tar sands development. These include:

Water impacts
Oil shale development is projected to have a dramatic effect on the West's water supplies and potentially its water quality. There is simply not enough water in Colorado to support this industry. Surface mining and retorting of oil shale could use up to five barrels of water for each barrel of oil produced. In 1996, the BLM found that oil shale development would result in a reduction in the annual flow of the White River of up to 8.2 percent. These low flows could concentrate dissolved solids, increase salinity, and devastate fisheries. In the same 1996 study, the BLM warned that a large-scale shale oil industry "would result in the permanent loss or severe degradation of nearly 50% of BLM stream fisheries" and that surface disturbance, base flow reductions, and long-term aquifer disruption would result in the loss of 35% of Colorado River cutthroat trout fisheries.

Oil shale development also poses a potentially serious threat to water quality. The process of transforming the kerogen in shale into oil leaves behind salts and numerous toxic, water-soluble chemicals that could leach into the groundwater that is the source of much of the region's surface water during the critical time when flow is lowest. The technical feasibility of isolating and treating contaminated groundwater has not yet been demonstrated.

Furthermore, predicted changes in climate in the upper Colorado River Basin were not accounted for in the BLM's analysis. Although the Draft PEIS acknowledges the potential for future changes, the analysis estimates water availability based on historical averages that do not account for expected effects climate change will have on the region's snowpack runoff. As Secretary Kempthorne explained in a July 2007 speech, "Here in the West, for example, runoff in five of the seven Colorado River basin states is projected to decline by more than 15 percent during the 21st century. If the basin warms and evaporation increases, we could face a situation in which the amount of precipitation we are receiving today produces significantly less runoff in the future."

Air impacts
The proposed surface and underground production technologies now being developed by Shell, Chevron, and EGL Resources will create major new demands on the energy grid. Our existing power plants are nearing their full production rates. To meet this demand, oil shale and tar sands development will require the construction of new power plants capable of producing electricity all day, every day. The most readily available fuels for new plants are coal and natural gas. The relatively low cost of coal makes this dirtiest of fossil fuels the more economically attractive choice for powering oil shale and tar sands development.

To support the million barrel-per-day industry forecast in the Draft PEIS, ten giant new power plants and five giant new coal mines will be required. These could emit 105 million tons of carbon dioxide every year—but you won't find that in the document. That's 80% more than was released by all existing electric utility generating units in Colorado, Utah, and Wyoming in 2005. Sulfur dioxide and nitrogen dioxide emissions, the major culprits in acid rain, could increase by over 35,000 tons per year each. This will greatly impair air quality in a region that's already seeing spikes in air pollution from the natural gas boom.

Impacts to wildlife and landscapes
The Draft PEIS states, "There is a potential for commercial oil shale development projects to adversely affect most of the threatened, endangered, and sensitive species that occur in the counties where development could occur." BLM has estimated that large-scale oil shale development would result in the permanent loss of 35% of Colorado River cutthroat trout fisheries. Oil shale would also adversely impact Colorado's largest elk herd by severing migration corridors and destroying the winter range of all big game species.

Other likely impacts the BLM identifies:
1. Habitat loss, alteration, fragmentation, and resulting changes in habitat use
2. Disbursement and displacement – habitat modification, noise, fire, lights, etc.
3. Mortality – collisions with structures and vehicles, changes in predator populations
4. Toxicity from herbicides, hydrocarbons, or other contaminants
5. Increased accessibility – human infiltration of previously remote habitat

According to the Draft PEIS, impacts of commercial oil shale development to our landscape will include: industrial noise across the landscape, visual transformation of the landscape, increased traffic, new roads, increased access to currently remote areas, industrialization of agricultural and undeveloped landscapes, sprawl, loss of available land for other new industries, decreased property values for adjacent landowners, and degradation or loss of cultural sites.

Tar Sands
The environmental impacts of commercial tar sands mining are devastating. Tar sands mining usually utilizes strip mining or open pit techniques, completely ruining the environment during production, and possibly permanently destroying the wildlife and landscapes that are impacted. The BLM admits that a commercial tar sands industry would have substantial social and economic effects for Utah's communities, as quality of life and property values will decrease significantly. Tar sands mining produces three times as much global warming pollution as conventional oil, greatly threatening air quality in the places it is developed.

Tar sands mining in Alberta, Canada, provides an example of the devastation wrought by this unconventional energy source—yet the Draft PEIS does not refer to the Canadian experience with tar sands development. The development of Canada's tar sands requires clear-cutting thousands of square miles of some of the most important habitat on Earth—boreal forest. Left behind are toxic landscapes that may never be capable of reclamation; not one acre has so far been fully rehabilitated, despite attempts by the responsible companies. If that were not enough, tar sands production in Canada is rapidly increasing the country's greenhouse gas emissions and air pollution, sucking dry the water sources that local communities depend on, and producing large amounts of toxic waste that poses serious health concerns.

Bottom Line
BLM should not commit our public lands to commercial oil shale and tar sands leasing until industry can prove that development of these unconventional energies can be done without causing unacceptable harm to our air, water, landscapes, wildlife, and health. Until then, let's tell BLM to SLOW DOWN! and wait for companies to come forward with specific technologies that allow for an oil shale and tar sands program to be fully evaluated.

Please act now. To submit your own comments, click here.

For more information, see http://ostseis.anl.gov/index.cfm.