New plan for drilling approved

by Stephen Crane

The Department of the Interior approved the long-awaited Record of Decision (ROD) on Friday, detailing the new policies that will regulate energy development on the Pinedale Anticline Project Area (PAPA) for years to come.

Assistant secretary for Land and Minerals Management for the Department of the Interior, Stephen Allred, and Governor Dave Freudenthal signed the ROD in Cheyenne on Friday.

“The completion of this Record of Decision is a prime example of the successful partnership between the BLM (Bureau of Land Management) and the State of Wyoming,” said Allred in a press release. “Our agencies worked to find ways to minimize the impacts to wildlife habitat and other resources in and adjacent to the Pinedale Anticline area while harnessing important energy resources for our nation.”

Until now, the PAPA, which is composed of 198,037 acres of federal, state, and private lands, has been under the regulatory policies outlined in the ROD from July 2000. But the desire to increase development by energy companies, as well as the environmental impact from development in recent years, led the BLM to prepare a Supplemental Environmental Impact Statement (SEIS) that was meant to address these new concerns.

After receiving public commentary on the SEIS, the BLM issued a Revised Draft SEIS, and again opened the door for more public commentary, ultimately publishing its Final SEIS, which came out in June of this year.

This FSEIS detailed five alternatives for the upcoming ROD, labeled A through E. The BLM decided that its preferred alternative was D, which would, among other things, open the PAPA to winter drilling, a practice that was only allowed in a very limited capacity up to now so that winter migration corridors could be maintained.

According the decision in the ROD, “The decision to implement Alternative D, as modified, provides the best balance of multiple uses within the PAPA, and will sustain the long-term yield of resources while promoting

stability of local and regional economies, environmental integrity, and conservation of resources for future generations.”

The new ROD sanctions the recovery of 25 trillion cubic feet of natural gas on the PAPA, which is expected to produce $16 billion dollars in royalties, half of which will go to the state of Wyoming.

This natural gas will be recovered through the drilling of 4,399 new wells on 600 new well pads.

But the ROD also places more stringent environmental standards on the energy companies, not only for the new wells being developed, but also for existing wells on the PAPA.

“From my experience in other parts of the country, (this ROD) is going to set the standard for other EISs,” said Belinda Salinas, manager of environmental, safety and regulatory affairs for Ultra Resources. “It is a lot more regulated, and of course, that is due a lot to where we’re located.”

These new regulations consist of a number of actions intended to minimize the environmental impact of the development, including the “footprint” of the actual surface area, the emissions, the visibility, as well as the air and water quality.

“This ROD allows for more production of the area’s natural gas reserves but requires industry to use cleaner technology to reduce impacts to Wyoming’s air quality, to protect wildlife by not developing in the areas adjacent to the Anticline, and to use clustered development and offsite migitation,” said

Freudenthal in a press release. “It represents a positive change in considering the needs of wildlife that use this area for winter range and migration.”

Among the specific regulations included in the ROD is the requirement that Shell, Ultra, and Questar “install a liquids gathering system to reduce the amount of truck traffic associated with production.” This 471-mile system of pipelines will cut truck trips on the PAPA by 165,000 annually, thereby reducing emissions as well.

The ROD also implements a Concentrated Development (CD) area, which will limit drilling to the innermost core of the PAPA. The CD area will comprise about one-third of the total surface area of the PAPA, running parallel to the outer boundary.

The energy companies will also suspend all drilling activities outside this CD area for the next five years, though the Anschutz company may be allowed to drill outside the CD, though not during the winter months. This suspended drilling activity equals 49,903 acres of land inside the PAPA. And only after reclaiming land in the CD will the companies be allowed to begin development in other areas of the PAPA.

The ROD also establishes a monitoring and mitigation fund, which the energy companies will finance, annually paying $7,500 for each well. “Annual contributions are anticipated to be $1.8 million per year with an initial contribution of at least $4.2 million,” according to the ROD.

The fund will be used to finance additional air quality monitoring, wildlife research, and both on and off-site mitigation efforts.

In order to organize and process the information gathered from monitoring and mitigation efforts, the ROD also establishes a Pinedale Anticline Project Office, which will coordinate with the Pinedale Anticline Working Group (PAWG) and the Jonah Interagency Mitigation and Reclamation Office.

The ROD also creates three air quality timelines for energy development that will “ensure that emissions from the PAPA result in zero days of visibility impairment over one deciview at the Bridger Wilderness Area.”

After 12 months, the ROD wants no more than 40 days of visibility impairment. After 42 months, there should be no more than 10. By 78 months, there should be none. And according to the ROD, “BLM may reduce the pace of development to achieve this goal.”

In order to further reduce ozone emissions, the ROD requires that “individual contingency plans will be developed by the Operators with WDEQ and BLM to address avoidance of wintertime ozone exceedances.” The companies will have 90 days to present these plans.

Not all in the community are reassured by these new environmental efforts however, and some are skeptical of the new ROD, which allows 4,399 new wells to be drilled.

“The BLM has failed to provide us any assurance that this plan will protect us from more ozone pollution, groundwater pollution or other threats to our health,” said 30-year Sublette County resident Rod Rozier in a press release. “We are breathing unhealthy air under the current level of development due to industry pollution. If BLM can’t ensure healthy air today, how can we rationalize and support additional development?”

Operational and On-site Mitigation Measures for Shell, Ultra, and Questar

— Use directional drilling

— Use consolidated pad construction and development

— Implement consolidated completion activity

— Install rig engine NOx (nitrogen oxide) emissions controls

— Follow existing air monitoring agreements with the Wyoming Department of Environmental Quality

— Incur expenses to reduce emissions from any project related source

— Participate and fund visibility and ozone modeling required by the ROD

— Fund necessary groundwater characterization and monitoring

— Install a liquid gathering system

— Assure completion of current mule deer, pronghorn, and greater sage-grouse research

— Complete block cultural and paleontological inven tories and evaluations

— Conduct current habitat and vegetation inventory

Possible Mitigation Requirements by the BLM and WDEQ for Emission Reduction

— Replace diesel drilling rig engines with natural gas engines

— Use fuel additives

— Use gas turbines rather than internal combustion engines for compressors

— Reduce the number of drilling rigs

— Require Tier 2 equivalent (or better) emissions on drilling rig engines

— Install selective catalytic reduction on drilling rig engines

— Use electric drill rigs

— Implement electric compression

— Require centralization of production facilities to reduce truck traffic

— Adopt cleaner technologies on completion activities

— Implement advancements in drilling technology

— Reduce the pace of development