From the pages of
Sublette Examiner
Volume 7, Number 41 - January 3, 2008
brought to you online by Pinedale Online

Revised anticline DSEIS out for study
Air-quality study added; NOx emissions exceed ROD levels
by Joy Ufford

Last Friday, the Bureau of Land Management (BLM) issued a notice of availability for the new “Revised Draft Supplemental Environmental Impact Statement (RDSEIS) with five alternatives for development in the Pinedale Anticline Project Area (PAPA).

The public comment period closes Monday, Feb. 11.

The two additional alternatives were developed after public comments including “voluntary commitments” made by the industry (according to Questar spokeswoman Emily Fisher) were received on the previous DEIS during the past year, with the BLM’s Preferred Alternative D also holding a full hand of industry trade beads such as mega-funds to provide wildlife habitat away fromthe core areas.

At the heart of the matter is a proposal by Questar, Shell and Ultra to conduct year-round drilling of exploratory and productionwells on their leases within the Anticline’s existing natural gas fields. The three, also called the “Proponents” in the document, have requested drilling another 4,399 wells from another 250 well pads over 60 years with relaxed seasonal restrictions.

Many of the concentrated areas of development are heavily used by big game for migration routes, winter range and birthing grounds and are very close to known in-use sage-grouse leks, maps show.

The document points out that through November 2006, wells, pads, facilities and pipeline and access road miles have not yet met or exceeded the limitations set forth in the 2000 PAPA Record of Decision (ROD).

Those limitations would be preserved in the BLM’s “no-action” Alternative A, which in effect maintains the status quo of the ROD with 900 initial well pads, 700 producing wells or well pads, 276 miles of access roads, 280 miles of gas-gathering pipeline and 121.5 miles of sale pipeline. However, the air-quality standard as set down in the ROD has been exceeded, with three compressors generating more NOx emissions than allowed for the entire gas field.

NOx-ious levels

Current cumulative NOx emissions exceed the thresholds set in the 2000 PAPA ROD, thus the DRSEIS also includes “an additional cumulative air quality environmental review.”

While the PAP ROD allows for up to 376.59 ton per year (TPY) of NOx from compression and a total from all sources in the field of 693.5 tpy, current analyses show that from compression alone, the NOx output is 472.2 tpy.

“...The total estimated NOx emission of 472.2 tpy is over the 376.59 tpy NOx analysis threshold specified in the PAPA ROD,” says the RDSEIS (Ch. 1, p. 4; Ch. 2, p. 5-6, 10). “This document provides the additional air quality impact analysis that is required by the PAPROD... mostly due to the increased number of drilling rigs.”

The RDSEIS analyzes the five alternatives’ impacts to ground and water resources, air quality, wildlife and habitats, grazing, reclamation, noxious weed control, transportation, cultural and paleontological resources, visual quality, wetlands and riparian lands, and socioeconomic resources, according to each of the alternatives.

“Each alternative contains variations on the amount and level of mitigation that would be required,” the executive summary states. “In addition to mitigation measure typically required by the BLM, mitigation measures are also provided within the Alternative itself. Further, additional mitigation opportunities that could be applied to all Alternatives have been identified and included in Chapter 4.

“All Alternatives that contemplate yearround development contain an offer by the Proponents to provide off-site compensatory mitigation.” There are numerous charts, tables and appendices attached to the RDSEIS alternatives, interested parties can get copies of the RDSEIS at the BLM’s Pinedale Field Office, 1625 West Pine St., Pinedale. The RDSEIS and PAPA ROD are also available online at http://www.blm.wy/st/en/info/NEPA/pfodocs/anticline.html.

Alternative A (No Action)

“In many instances, the No Action Alternative means ‘no project’ when a new project is proposed. The No Action Alternative can also mean ‘no change,’ in this case, from BLM’s current management in the PAPA,” the document states.

“In this (RDSEIS) the No Action Alternative has elements of both meanings; the Operators’ (Proponents’) Proposed action would not occur and BLM would continue to manage natural gas development in the PAPA, based on all provisions of the PAPA ROD and subsequent Decision Records. ... Mitigation under the No Action Alternative would be the measures set forth in the PAPA ROD.”

Development beyond limits and analysis thresholds as set forth in the PAPA ROD would “require additional environmental review,” it says, although “the PAPA ROD did not specify the type or extent of the additional environmental review required.”

The development period runs through 2011 and the production-only period ends in 2051.

Alternative B (Proponents’)

This includes a long-term development plan with exceptions granted in the core area only for seasonal restrictions for mule deer, pronghorn and greater sagegrouse. It encloses 22 percent (68.1 square miles) of the PAPA and has thee “concentrated development areas (CDAs) that would move as pads are drilled out.” The core area includes 43,624 acres with an initial disturbance area of 12,885.6 acres and lifetime-of-project area disturbance of 4,102.5 acres.

“Each of the three individual CDAs would not exceed eight square miles; however, they would be tightly grouped and the combined area of the three would not exceed 19 square miles. The CDAs and their movement would leave large, contiguous blocks of land and corridors available for wildlife without active natural gas development activities.”

The proponents would try to fully develop each multi-well pad to the “approved bottom-hole spacing before moving drilling rigs off of well pads” at the average rate of moving rigs to a new pad about once a year.

“Pad reclamation would proceed as soon as practical when the last well on the pad is completed. ... Interim reclamation would occur on well pads not scheduled for development activity within two years.”

Delineation wells are proposed for the first five years to “assess production capabilities.” “Where possible, the delineation wells would be drilled in accordance with all seasonal restrictions for big game and greater sage-grouse,” the document states. “There may be some instances in the first (five) years where delineation wells must be drilled outside the CDAs and outside of the Alternative B Core Area during the seasonally restricted periods.”

System would “result in better protection for big-game and greater sagegrouse populations than what is currently afforded by the seasonal restrictions set forth in the PAPA ROD by lowering the amount and frequency of human presence year-round and throughout the production phase.” Computer-assisted operations on multi-well pads would be expanded to reduce daily personnel visits.

Proponents “plan to implement Tier 2 equivalent emissions technology” on all new drilling rig engines within two years after the ROD is issued on this RDSEIS. Some existing engines would keep Tier 1 and Tier 0 engines and be phased out after 2010. By 2025 at the end of development, the Proponents’ alternative would have an estimated 4,399 wells on 250 new well pads (making a total of 590 pads) with all surface disturbance completed by 2023. Gas gathering pipelines and liquids gathering systems would decrease traffic and pollution from trucks that currently haul the products. In this alternative, production-only will run to 2065, as it does in Alternatives C and D.

This alternative has a Proponent sponsored wildlife and habitat mitigation plan but does not include its wildlife monitoring and mitigation matrix developed with Wyoming Game and Fish (only in Alternative D); mitigation would be funded offsite, if necessary.

Under this option, Proponents’ emissions will undergo Tier-2-equivalent reductions on selected rigs and according to the BLM’s 2004 decision of record.

Alternative C

“Although Alternative C is similar to Alternative B in that it includes the same project components, geographically it is different,” the RDSEIS states. “That is, rather than only specifying certain areas where year-round development could occur, Alternative C specifies areas where year-round development would not occur.”

Its core area of 39,678 acres, while smaller than that of Alternative B, completely encircles the Pinedale Anticline axis and includes or neighbors five development areas (DAs) ranging from “very high” to “low” potential for oil and gas production, with the core consisting of the “high” and “very high” potential DAs. Year-round development would be allowed in four of the five fixed-location development areas with exception for seasonal restrictions for big game and sage-grouse seasonal habitats, during the seasonally restricted periods.

“For year-round development, in all DAs except for DA-5, Operators would be required to fully develop each existing and/or new well pad in one continuous time span for as long as necessary to drill and complete all wells on one pad,” it says. “Once an Operator has determined that a well pad has been fully developed, they would not be allowed to reinitiate development on the well pad.”

“Full-site restoration and reclamation” would begin when the ground thaws and completed “before the onset of winter” based on the alternative’s specific reclamation plan. DA5 is the southern most area and while it is within two miles of the Yellow Point Lek Complex, it is the only DA that is not described as being on or near big game crucial winter ranges or within one quarter mile of the Lander Trail. Operators would be required to expand existing well pads before building new ones in all areas of the PAPA.

Development activities would be allowed in all DAs and outside the core area at any time with adherence to seasonal restrictions.

“Outside of the seasonally restricted periods, Operators would not be required to completely develop pads and could return to the pad in the future.”

This alternative has a Proponents sponsored wildlife and habitat mitigation plan but does not ascribe to follow its wildlife monitoring and mitigation matrix developed with Wyoming Game and Fish; mitigation would be funded offsite, if necessary. Proponents state emission will be reduced to 2005 NOx levels with a further 80 percent within five years.

Alternative D (Preferred)

Although the Proponents’ proposal of choice is indicated as Alternative B, the same operators appear as a strong cast of characters in this BLM-preferred Alternative D. The BLM developed this option “based upon public comments received on the Draft SEIS ... (and) in part by comments from the Proponents (Ultra, Shell, Questar, BP, Stone/Newfield, Yates and Anschutz) the (Wyoming Game and Fish Department) and (Wyoming Department of Environmental Quality) Air Quality Division.” Alternative D has a core area of 45,415 acres (23 percent of the PAPA) and is expanded to include leases currently held by Anschutz “all within mule deer crucial winter range,” the RDSEIS states.

Its core area of 45,015 acres has five DAs and a surrounding “potential development area” (PDA) of 24,875 acres “which would be potentially open for year-round development,” according to the RDSEIS. “...Year round development would not initially be allowed in the PDA. The need for year-round development within the PDA would be determined by the success of delineation drilling. ... For the purpose of the analyses contained in Chapter 4, it is assumed that yearround development would occur in the PDA.”

The DAs would see year-round development with exception to seasonal restrictions for big game and greater sage-grouse seasonal habitats would be allowed with specific limitations, it states.

Delineation drilling in DA-1, which includes the Stewart Point area, would take place the first two years with seasonal restrictions for wildlife observed. After the first two years, delineation requiring new pads or roads would take place either one mile or 18 months ahead of the six square-mile area of development. No additional pads would be allowed for delineation unless recommended and approved at an annual planning meeting by the BLM.

The remaining DAs and PDAs have very specific desires and offered mitigations; however, exception is given in most for big game or greater sage-grouse seasonal habitats. However, development would not occur within a quarter-mile buffer of occupied sage grouse leks (a standard buffer applying to all occupied leks).

In return, Shell, Anschutz, Ultra, Shell, BP, Stone/Newfield and Yates have “offered to conduct no additional activity on certain leases in the Flanks ... for at least five years.” The area concerned totals 49,903 acres. “To accomplish this, leases without current production would be suspended,” the draft says. “Leases that are producing cannot be suspended but would not have additional activity because of the Proponents’ commitment to do no additional development in these term NSO leases for five years.” After that time, federal suspended and term NSO leases would go up for review during the annual planning meeting.

In addition, Ultra, Shell and Questar “have voluntarily proposed the creation of the Pinedale Anticline Mitigation and Monitoring Fund to mitigate potential impacts identified in the Draft SEIS.”

The $36 million compensatory fund would be in addition to the on-site mitigation the Proponents would implement under their proposal, including but not limited to directional drilling, consolidated pad construction and development, rig engine NOx emission controls, existing air monitoring agreements with WDEQ, liquids gathering system, current big game and sage grouse research and current vegetation and habitat inventory.

Proponents state they will reduce emissions to 20 05 NOx levels within one year and a further 80 percent within 42 months.

Alternative E

“Alternative E was created by the ID Team in response to comments concerning the pace of development,” the draft states.

“Alternative E slows the pace of development by approximately 10 years with construction through 2015, drilling through 2033 and production through 2073.”

It is similar to Alternatives B, C, and D in that it has all project components (with the exception of the proposed liquids gathering system), the same development procedures for wellfield activities and pipeline procedures, calls for a total of 4,399 more wells and has an air quality impact analyses based on a peak of 48 drilling rigs in PAPA.

It contains the existing management areas’ 1 through 9 (MAs) objectives and limitations in a core of 45,415 acres with a buffer (24,875 acres) and flanks.

Current seasonal restrictions would be observed for delineation well drilling, concentrated development, drilling rig movement and in restricted areas except for those where activities are allowed for Questar through 2013-2014 per the BLM 2004 Decision Record.

There is no Proponent-sponsored wildlife and habitat mitigation plan or matrix included, nor industry compensatory mitigation or emissions reductions.

These would be provided for by the “BLM’s incorporation of environmental BestManagement Practices by the operator under all alternatives” ... (and) Proponent committed mitigation varies by alternative.”

Money makes the world go ’round

In announcing the release of the RDSEIS on Dec. 28, BLM project Leader Caleb Hiner counted the economic benefits to be enjoyed by local and state entities.

“The project area, 198,034 acres of federal, private and state land generally located south of Pinedale, contains an estimated 21 trillion cubic feet of natural gas reserves,” stated Hiner.

“The production of natural gas could generate approximately $16 billion in federal royalties, $8 billion of which would go to the state of Wyoming. In addition, year-round access may provide opportunities for a year-round workforce instead of the seasonal boom-and-bust cycle.” However, the RDSEIS Executive Summary states, “Increasing revenues would help local governments meet these demands (for housing and services)” but also that “communities are likely to continue to experience growth-related problems.”

Recreational use of off-highway vehicles is expected to decrease, as would big game and game bird populations and hunting opportunities, would-be visitors due to lack of lodging and preservation of fossils, or cultural and historic resources.

Also negatively impacted will be the visual landscape, existing vegetation and habitats, eroding soils, endangered or threatened species, grazing resources, surface water, groundwater, and wildlife and aquatic resources, according to the summary.

Public Comments

A public meeting is set for noon to 9 p.m. Jan. 17 at the Pinedale Library. Written comments can be sent through Feb. 11 to the BLM, Pinedale Field Office, PAPA RDSEIS Project Manager, 1625 West Pine, Pinedale, WY 82941. Emails also can be sent to: WYMail_PAPA_YRA@ through Feb. 11. For more information, contact Project Leader Caleb Hiner at 307-367-5352 or by email:

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