January 29, 2001
Subject: Coalbed
Methane Development Plan
Mary Bloom, Project Leader
Bureau of Land Management
111 Garryowen Road
Miles City, MT 59301
Dear Ms. Bloom:
The Montana Chapter of the American Fisheries Society is
very concerned about coalbed methane development in eastern Montana and would
like to see several important issues addressed in the planning process and any
development proposals. Our 150+
membership includes fish biologists, limnologists, fisheries managers, stream
ecologists and anglers, some of who work in the Tongue and Powder River basins.
First and foremost is our concern about the impacts on fish
and aquatic life of groundwater discharged into streams or other surface waters.
These direct discharges have been found to be highly saline and may
contain a variety of toxic substances, not to mention the significant depletion
of underground aquifers which support late season streamflows in this semi-arid
region. In some locations, the discharges themselves can cause
erosion, siltation and stream channel damage by disrupting natural water flows.
All of these effects need to be adequately addressed in the development
plan.
At minimum, wastewater treatment methods need to be fully
discussed in order to ensure that discharged water does not threaten aquatic
organisms. The option of
reinjecting groundwater into wells should be fully explored as a way to minimize
adverse effects on all resources. And
finally, the plan should address the potential for cumulative effects of
multiple wells being developed in one river basin.
Thank you for the opportunity to comment on this important
planning action. Please keep us
informed of the progress of this development plan.
Sincerely,
Michael Enk
President, Montana Chapter AFS
PO Box 1408
Great Falls, MT 59403