From the pages of
Sublette Examiner
Volume 8, Number 26 - September 18, 2008
brought to you online by Pinedale Online

BLM Releases Antivline ROD

by Joy Ufford

The Bureau of Land Management touted the release last Friday of the long-coming Pinedale Anticline Project Area (Anticline) Record of Decision (ROD) as “a prime example of the successful partnership between BLMand the State of Wyoming,” particularly the Game and Fish and Department of Environmental Quality agencies.

“Our agencies worked to find ways to minimize impacts to wildlife habitat and other resources in and adjacent to the Pinedale Anticline area while harnessing important energy resources for our nation,” said C. Steven Allred, Department of the Interior assistant secretary for Lands and Minerals Managements, on Friday.

Gov. Dave Freudenthal, present at the ceremonial release, was more circumspect but positive after the ROD presentation.

“This 2008 (ROD) for the Pinedale Anticline is an improvement over the 2000 document,” he said, adding, “It’s important to note, however, that this is not the end of the work we have to do but the beginning.”

The Anticline ROD is an adapted version the BLM’s Alternative D, its preferred option, which provides “the best balance of multiple uses ... and will sustain the long-term yield of resources while promoting the stability of local and regional economies, environmental integrity and conservation of resources for future generations,” the summary.

“Alternative D, as modified, will provide for the management of the PAPA in a manner that allows for natural gas exploration and developmentwhile providing for mitigation of impacts on key resources, including air quality and wildlife.”


In response to the ROD, “concerned citizens in the Anticline decision” aired their grievances against the new 88 page document.

“The Pinedale Anticline (ROD) would allow natural gas drillers to more than quadruple the numbers of wells in a gas field where 1,000 existing wells have had severe impacts on air quality, visibility in the nearby Wind River Range, groundwater and potentially human health,” their statement reads.

“The BLM has failed to provide us any assurance that this plan will protect them from ozone pollution, groundwater pollution or other threats to our health,” said longtime county resident Rod Rozier.

The “proponents” – Shell, Ultra and Questar – stated Friday they are “currently reviewing” the ROD and “remain committed to developing the Pinedale Anticline in a responsible manner that benefits the environment, wildlife and the community.”

Key elements

• The year-round access sought by operators is allowed under the new ROD and 4,399 natural gas wells will be allowed on 600, instead of 700, well pads. “This ROD allows for year-round development and delineation activity within big game (pronghorn and mule deer) and greater sage-grouse seasonal use areas by granting exceptions to the big game and greater sagegrouse seasonal restrictions,” it says. “The extent, location and duration of relief from seasonal habitat restrictions will be determined at ... annual planning meeting (s). No surface occupancy (NSO) restrictions for all species will remain in effect.”

• Construction of new well pads, expansion of existing well pads and construction of new roads and pipelines will occur to take place through 2023; well drilling is expected through 2025 and wells are expected to have a 40-year production life through 2065.

• The Core Area includes 45,415 acres or 23 percent of the PAPA with five Development Areas (DA-1 through DA-5). Cumulatively, DAs 1 through 5 exactly equal the Core Area. Relief from seasonal restrictions for pronghorn and mule deer and greater sage-grouse will be granted in the Core Area as provided for below in Core Area Development and Core Area Delineation. Relief from other seasonal restrictions will be allowed on a site-specific basis where it is consistent with regulations for systematic Anticline development.

• The Potential Development Area (PDA), adjacent to the Core Area, is available for year-round development and is made of 24,875 acres or 12 percent of the Anticline. Buffers vary for each DA.

• The DEQ-AQD will conduct “an air toxics health assessment for Sublette County residents” and monitoring of ozone and “airborne chemicals” will begin in November. An “interim risk assessment will be available in December with a draft report for public review around August 2009. Ambient air monitors will be assessed, added and relocated as needed.

“BLM acknowledges that project work will result in ozone formation. However, BLM is committed to assuring that any mitigation necessary to reduce the project’s contribution to ozone concentrations will be implemented and that project emissions of ozone precursors will be below applicable regulatory standards, to the extent consistent with BLM’s role as land manager and mineral lessor,” the ROD says. Also, “the final goal for air quality mitigation for visibility (is to) ensure zero days of impaired visibility over 1 deciview” at the Bridger Wilderness.

• The ROD sets short- and long-term “milestones” for operators to reduce visibility impacts in the wilderness area to reach the above goal within 78 months. It also outlines specific emissions reductions including use of advanced technologies, liquids gathering systems (required by Shell, Ultra and Questar within two years of the ROD signing) and winter ozone contingency plans.

“After this two-year period, all producing wells must be connected to the liquids gathering system prior to production unless waived by the BLM AO. Within one year of the signing of this ROD or at such time as production occurs, all other PAPA operators will be required to demonstrate, and within a subsequent one-year period implement, a reduction in VOCs comparable to that obtained by the liquids gathering system as approved by the BLM AO. Installation of a liquids gathering system will meet this requirement. Operators not installing a liquids gathering system must demonstrate a comparable reduction in VOCs.

• “Within 90 days of the signing of this ROD, and on an annual basis thereafter, until such time as BLM and WDEQ deem it is no longer necessary, individual contingency plans will be developed by the Operators with WDEQ-AQD and BLM to address avoidance of winter time ozone exceedances.

Failure to comply by any individual company will result in BLM withholding approvals for that company and/or reducing the pace of development and/or production.”

• The ROD acknowledges groundwater protection – “especially sources of current and future drinking water” – is a major issue and that hydrocarbon detection in wells “is a concern.”

Within three months of the ROD’s signing, the BLM, industry, DEQ Water Quality Division and the Environmental protection Agency will develop an “Interim Groundwater/Aquifer Pollution Prevention, Mitigation and Monitoring Plan” to begin groundwater characterization and fund existing monitoring programs if needed.

“BLM will continue to work with the regulatory agencies and the Operators to identify and mitigate causes of contamination,” the ROD says. “This ROD includes increased monitoring and mitigation to further protect groundwater resources.”

Within six months of the ROD’s signing, operators must either show proof that locked backflow-prevention devices are installed on all water supply wells.

Also, “no BLM rights-of-way or other approvals for new industrial water supply wells will be allowed...until the Groundwater Characterization is completed and the causes of the hydrocarbon detections have been determined and effectively mitigated.”

• A Wildlife Monitoring and Mitigation Matrix will set “specific triggers for specific wildlife management responses.” Mule deer, antelope and sage-grouse species and habitat “(are afforded) equal or greater protection” than in the current development by maximizing well-pad drilling to minimize disturbance, allowing orderly systematic development and reducing human presence.

• The $36 million Monitoring and Mitigation Fund will be used to implement appropriate projects such as habitat improvements and to pay for WDEQ-Air Quality Division staff, ambient air monitoring, analysis and reports.

• Limited flank development, the ROD says, is due to “the unprecedented voluntary level of cooperation that the Operators have provided for this development plan.

“Ultra, Shell, Anschutz, BP, Stone, Newfield, and Yates have offered to conduct no additional activity on certain leases in the Flanks of the PAPA for at least five years, which creates collectively 49,903 acres inside the PAPA, of which 16,954 acres are within big game crucial winter range and 37,019 acres are within two miles of a greater sage-grouse lek.”

•The ROD also states it provides gas-field workers a chance for permanent residence by allowing year-round development, “reducing the number of transient workers needed for seasonal jobs.

“Strain on infrastructure, housing and lodging, transportation systems, fire protection services, law enforcement and medical services were anticipated under all alternatives especially the full-field development alternatives, the ROD states. “These issues are a major concern to local communities and governmental agencies. The Operators will provide 10-year rolling forecasts of field development at the annual planning meetings. These forecasts will be made available to local government agencies to assist in planning efforts.”

• To preserve the Lander Trail’s integrity and viewshed, a quarter-mile buffer of No Surface Occupancy is designated along both sides and outer development impeding the historic trail’s viewshed will be minimized “to the greatest extent practicable.”

• The character of the Mesa Breaks’ crucial deer winter habitat and landscape will be maintained as is best practical with a quartermile buffer, three-mile viewshed, avoidance of steep slope disturbances and recognition of paleontological resources.

• The ROD establishes the Pinedale Anticline Project Office to handle the required monitoring, collecting, storing and distributing of information and reports. This office will coordinate with the Pinedale Anticline Working Group and the Jonah Interagency Mitigation and Reclamation Office.

• Performance-based and adaptive management practices will be used for implementing, evaluating, recommending and sharing mitigation projections and results. “The Operators’ annual and 10-year projections will be provided to the PAWG and the PAWG task groups to foster communication with the public,” the RODstates. “The PAWG will ... continue to be amechanism for sharing information with the public and interested stakeholders, including modeling and monitoring results.”

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