From the pages of
Sublette Examiner
Volume 8, Number 15 - July 3, 2008
brought to you online by Pinedale Online

BLM Releases Anticline ‘Final SEIS’
Industry influences ‘preferred’ option
by Joy Ufford

The Bureau of Land Management’s “preferred” Alternative D outlined in its just published Final Supplemental Environmental Impact Statement (FSEIS) to guide Pinedale Anticline natural gas development holds an expanded core area of 45,415 acres for year round drilling.

It also has an additional “potential development area” (PDA) of 24,875 acres for possible year-round drilling, bringing the BLM’s option for total potential acreage for year-round drilling to 70,290 acres.

Industry’s “proposed action” Alternative B consists of three “core development areas” (CDAs) of year-round drilling on 43,624 acres “within certain areas ... that coincide with big game (mule deer, pronghorn, and moose) crucial winter habitats and greater sage-grouse seasonal habitats.”

The revised and redrafted NEPA document examines the “Proponents” proposal for increased and concentrated year-round drilling and production in the Pinedale Anticline Project Area (PAPA), to include wells, associated access roads, pipelines and production facilities. “The BLM has determined that the Proponents’ proposal could cause significant impacts to the human and natural environments,” the summary states.

While Alternative B proposes drilling on less acreage than the BLM prefers, there are numerous similarities between industry and the agency’s alternatives.

The June 27 FSEIS cover letter states this “preferred” alternative was shaped as “the result of comments received on the Draft SEIS (12/2006) and the revised Draft SEIS (12/2007).”

Many of those comments helping shape the BLM’s alternative, as it is further explained in FSEIS Chapter 2, came from – industry.

“Based upon public comments received on the Draft SEIS (BLM, 2006a), the BLM has developed Alternative D,” it says. “Alternative D was created, in part, by comments from the Proponents (Ultra, Shell, Questar, BP, Stone/Newfield, Yates, and Anschutz), the (Wyoming Game and Fish Department) WGFD, and the (Wyoming Department of Environmental Quality) WDEQ – Air Quality Division...”

The Anticline FSEIS was published in the Federal Register June 27, kicking off a 30-day appeal period.

BLM Pinedale Field Office Director Chuck Otto, DEQ-AQD Administrator Dave Finley or U.S. Environmental Portection Agency Air Quality Larry Svoboda could not be reached before press time.

On the table, A to E

The FSEIS offers analyses of five alternatives including Alternative A, the “no action” option, which would leave the 2000 Anticline Record of Decision (PAPA ROD) intact and deny the Proponents’ proposal.

“Alternative A does not provide for full oil and gas resource recovery,” the FSEIS notes.

Development as set forth in the PAPA ROD has not reached its full potential; it allows development to 2011 and production-only to 2051, with 1,139 additional wells and 249 new well pads for a proposed total of 534 pads on an initial disturbance area of just over 4,000 acres and life-of-project disturbance of 1,622 acres. It also provides for 10.5 miles of liquids gathering pipelines (LGS) and 99.6 miles of new roads. Year-round development would only be allowed according to the BLM’s 2004 ROD on Questar’s leaseholds through 2013-2014.

Alternative B, the “proposed action alternative,” calls for up to 4,399 new wells and 12,885 acres of new surface disturbance, with development concentrated on the Anticline Crest within three CDAs “at any one time,” it says.

The three CDAs could be up to eight miles square, each not to exceed 19 square miles total, encompassing 43,624 acres. The CDAs would not follow current big game or sage-grouse seasonal restrictions but would maintain a quarter-mile buffer across the Anticline. Shell and Ultra would develop LGS in central and southern parts of the PAPA.

Compensatory mitigation would be provided at three to one offsite “if necessary.” Tier 2-equivalent reductions for nitrous oxides would take place “on selected rigs and according to BLM’s 2004 (ROD).”

Alternative C has the same project components as B, and calls for development through 2025 with production-only to 2065, but has a different core area boundary, encompassing 39,678 acres in five “development areas” (DAs) with year-round development allowed within four of the five DAs. Seasonal restrictions for greater sage-grouse and big game would not be followed but the sage grouse quarter-mile buffer remains intact. It contains the same offsite mitigations and calls for a reduction to 2005 NOx levels within one year and an additional 80 percent within five years.

“The overall objective of Alternative C is to control spatial disturbance over time, maximizing development in some areas while minimizing development in other areas, especially in portions of big game crucial winter ranges,” the FSEIS says. “(It) includes additional air mitigation to further reduce impacts to nearby sensitive areas and performance-based objectives to further reduce impacts to other resources.”

Alternative D has “an expanded core area” divided into five DAs and a PDA surrounding most of the core.

“Similar to Alternative C, this... presents a spatially phased development approach while adding operator committed measures, including suspended and no-surface occupancy leases outside of the Core Area and the PDA, an adaptive management approach and an operator funded compensatory mitigation fund,” the FSEIS says.

Alternative E is “also the result of public comment on the Draft SEIS” and maintains seasonal wildlife timing restrictions while “fully analyzing the number of wells and other impacts necessary to effectively recover the energy resource.”

The development period is extended to 2033 with production-only to 2073, eight years longer than Alternatives B, C and D. It is divided into nine management areas (MAs) in a core of 45,415 acres with a buffer of 24,875 acres and the “flanks.” This alternative contains neither compensatory mitigation from Proponents nor emission reductions by operators.

More than 120,000 total public “substantive comments” from industry, agencies, groups and individuals were collected before the FSEIS was issued, according to the Executive Summary. More than 63,000 comments were taken after the Draft SEIS was released in February 2007; the revised draft brought more than 68,000 comments after its December 2007 release.

The FSEIS is available at the Pinedale Field Office and at http//

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