Volume 4, Number 47 - February 17, 2005
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Jonah impacts examined
There is an estimated 10,500 billion cubic feet of natural gas in the Jonah Field east of Marbleton and natural gas operators are hoping to gain approval from the Bureau of Land Management to recover between 3,400 and 8,200 BCF of that amount as part of a infill development project within the existing field. Those are the numbers that are being contemplated in the Jonah infill draft environmental impact statement, released for public review last week. The BLM's preferred alternative, one of 10 examined in the voluminous document, calls for 3,100 new wells in the Jonah Field.
Considerable natural gas development has already occurred within the Jonah Field as approved in past BLM planning documents and impacts from this past development would continue for approximately 63 years without any further development authorizations. Therefore, most impacts associated with the infill project would involve increases in the magnitude and/or duration of impacts already described in past BLM documents.
The EIS noted: "For most resources, the quicker the project is implemented, the shorter the duration of impacts; therefore, pace of development may have the greatest effect on area resources. For example, the faster the gas is recovered, the sooner the area can be reclaimed."
But the BLM reports that preliminary research and monitoring results indicate significant adverse impacts to many area resources have already occurred with existing development and mitigation requirements in place.
For example, yearly inventories of raptor nests have revealed declines in the number of active ferruginous hawk nests in and adjacent to the Jonah area over the last eight years.
In addition, surveys of the Jonah Field conducted over the last few years indicate that while the area is still used for nesting and summer and winter foraging, use of the area by greater sage-grouse continues to decline. This decline is likely due in part to the increased loss of habitat resulting from oil and gas development, according to the EIS.
Since significant adverse impacts have already occurred, BLM is now proposing to increase on-site mitigation efforts, while recommending initiation of a "compensatory mitigation" program. All compensatory mitigation efforts would be voluntarily developed and proposed by the operator, and following approval and authorization by BLM, would become commitments of the operator.
• Air pollution: Some increase in air pollutant emissions would occur as a result of the proposed action and alternatives. Near-field impacts from these emissions are predicted to be below applicable significance thresholds. However, there is a potential for direct and cumulative visibility impacts to exceed visibility levels of concern within PSD Class I Bridger Wilderness Area and deposition thresholds within Bridger Wilderness Area, Popo Agie Wilderness Area, and Wind River Roadless Area.
• Transportation: Approximately 353 miles of resource roads, 8 miles of new collector/local roads, and 12 miles of Burma Road improvement would be required for field development. A total of approximately 8,744,600 round trips or approximately 499 round trips per day is anticipated under the BLM's preferred action for the life of the project. This is an increase of 162 new miles of road and 7,680,100 round trips.
• Visual resources: A significant impact to the visual resources on non-federal lands and minerals is defined as an apparent change, to the casual observer, from a natural landscape to an "industrialized appearing" landscape in areas visible from U.S. Highway 191, residential areas and the town of Pinedale. Due to the presence of natural gas development as a dominant visual feature throughout the Jonah area, as well as project effects such as haze, nighttime lighting, increased traffic, and short-term visible smoke plume events, significant visual resource impacts are anticipated.
The EIS noted: "The expansion of gas development facilities, and various development effects (e.g., haze, smoke plumes, nighttime lighting effects on regional star-gazing) and associated roads would be an unavoidable adverse impact to visual resources," both within and outside the Jonah Field.
• Hazardous materials: Under the BLM's preferred alternative, there would be an approximate six-fold increase in the potential for material spills, pipeline ruptures, and/or exposure to hazardous materials above current approved levels (from 533 wells currently to 3,100 new wells).
The BLM is authorized to require mitigation measures to prevent unnecessary or undue degradation of the public lands and protect surface resources in the approval of surface use plans. According to the federal government, mitigation may include: Avoiding the impact altogether by not taking a certain action or parts of an action; Minimizing impacts by limiting the degree or magnitude of the action and its implementation; Rectifying the impact by repairing, rehabilitating, or restoring the affected environment; Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action; and Compensating for the impact by replacing, or providing substitute resources or environments.
The BLM's view is that while on-site mitigation is the first priority when mitigating significant impacts, compensatory mitigation is an available tool for enhancing mitigation when impacts to BLM resources cannot be adequately mitigated on the site where the impacts are occurring.
The EIS includes a list of these mitigation ideas, including:
• Purchase of a conservation easement on an irrigated hay meadow adjacent to existing greater sage grouse habitat that is as close to the Jonah Field as possible, that is not encumbered by fluid mineral leases, and restore that meadow to sagebrush vegetation similar to the adjacent sagebrush community;
• Purchase a large block of sagebrush ecosystem land that is unencumbered by fluid mineral leases and is adjacent to existing greater sage-grouse habitat, and enhance sagebrush habitat function on that land;
• Purchase development rights on grasslands in the area that are unencumbered by fluid mineral leases, and enhance forage production; and
• Purchase conservation easement and establish and maintain three ferruginous hawk or bald eagle or burrowing owl nesting sites as close as possible to the Jonah Field and facilitate continued occupation of those nests.
In addition, the natural gas operators have committed to funding an off-site "Cumulative Impacts Mitigation Fund" to offset impacts of their proposed Jonah Infill development. While details are emerging, one form of financing the fund could be to deposit a particular dollar amount for every acre of new initial surface disturbance in the Jonah Field above a certain acreage threshold. For example, the operators have suggested a hypothetical amount of $850 for every acre of new initial surface disturbance authorized above a threshold of 11,000 acres. The fund would be used to fund project such as pronghorn migration corridor protection; grouse habitat preservation, protection, and enhancement projects; raptor protection; recreational resource augmentation; conservation easement development; air quality projects; on-the-ground reclamation research with an emphasis on sagebrush; and cultural resource projects. The mitigation fund would be established as a trust or similar instrument administered by a non-profit organization.
Many of the 158 items listed as operator-committed practices are environmental protection measures that would be included as conditions of approval in the BLM's record of decision for the project.
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