Environmental Groups Seek Better Protections for One of the Largest U.S. Natural Gas Developments Ever Proposed

The Bureau of Land Management at the end of 2012 released its draft analysis of one of the largest onshore natural gas developments ever proposed in the United States — on March 5th, in official comments, several groups are urging the agency to make significant improvements. The Wyoming Outdoor Council, Environmental Defense Fund, Natural Resources Defense Council, and others submitted joint recommendations to the agency, identifying several shortcomings in the draft analysis and recommending a wide range of improvements.

The Continental Divide-Creston proposal, an enormous development project for the Wamsutter area of south-central Wyoming, includes drilling nearly 9,000 new natural gas wells across 1,672 square miles (or 1.1 million acres) of public and private lands — an area a bit larger than the state of Rhode Island. Its massive scale makes it one of the biggest natural gas development projects put forth in the United States. The well-known Jonah Field in western Wyoming, by comparison, covers about 21,000 acres and includes about 3,500 wells.

In their comments to the BLM, the environmental groups articulated serious concerns about potential air pollution, which, if managed improperly, could be dangerous for local residents and workers. They also urged enhanced protection for lands in the area, including important wildlife habitats for pronghorn and sage-grouse.

Wyoming’s Upper Green River Basin area near Pinedale has been plagued by dangerous smog in recent winters as a direct result of pollution from the nearby Jonah and Pinedale Anticline gas field developments. The groups say it is imperative to guard against this kind of pollution in this new development.

“With a project this large, and this close to an existing area of unhealthy air pollution, it is imperative that the BLM gets this right,” said Jon Goldstein, EDF’s senior energy policy manager. “The BLM must ensure that it takes every measure it can to protect air quality, including doing some commonsense things like detecting and controlling pollution leaks from equipment.”

The comments were put together by the groups’ team of legal and scientific experts with guidance from Megan Williams, an independent air quality expert. Williams’ assessment found that the BLM’s draft analysis of the project underestimates emissions from project sources, does not consider the likely negative contributions to ozone pollution levels in the nearby Upper Green River Basin nonattainment area, and fails to ensure compliance via adequate emissions monitoring and self-certification requirements, among other things.

The environmental groups also criticized the BLM’s failure to provide adequate mitigation measures to control fugitive pollution from leaky equipment, vented emissions from well maintenance activities including liquids unloading activities, as well as methane and volatile organic compound emissions.

“I believe we have to do a much better job of protecting local residents and the people who are going to be living and working in and around this development,” said Bruce Pendery with the Wyoming Outdoor Council. “Wyoming citizens have learned some important lessons in recent years from the problems that have arisen in the Pinedale area and elsewhere, including many unanticipated impacts related to these mega field developments.”

“Today, we, and the BLM, know better. So let’s apply the lessons learned to this project so we protect air, water, land, and wildlife,” Pendery said.

Since this is largely an infill project in an area with a history of oil and gas development and surface disturbance in the “railroad checkerboard” along Interstate 80, the groups are not opposing development in all of this area outright. However, they do point out the need for better projections to mitigate potential environmental impacts and the need for stronger environmental controls and they are urging that some currently undeveloped areas should remain undisturbed for the sake of wildlife and wildlife habitat.

The BLM’s draft analysis of this proposed project considers five alternative development options but it does not specify a “preferred alternative.” The BLM will adopt a preferred alternative when it releases its final environmental analysis, which is expected within the coming year or two.

Based on the options presented in the draft and corresponding analysis, the groups are recommending that the BLM’s final decision should include the following elements:

  • Enhanced resource protections for vegetative communities, habitat, and wildlife;
  • Surface disturbance limits on active well pads within the project area, using unitization of leases or lease suspensions to accomplish this;
  • Emphasis on directional drilling, with estimated reaches in excess of 2,500 feet so that even fewer well pads are needed;
  • Maintenance of continuous blocks of undeveloped land, and preventing development on the 400 currently undeveloped sections in the project area;
  • Other best management practices for well integrity, emissions controls, water and wastewater handling, and noise, light and visual mitigation measures. 

Megan Williams’ independent air quality analysis, which has been submitted to the BLM, is available here.

The groups’ full joint comments to the BLM are available here.

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