Major Changes Proposed and Major Values at Stake:

The Bureau of Land Management (BLM) recently released its revised plan for expanded drilling on the Pinedale Anticline. The proposal calls for 4,400 more wells, almost nine times the number currently in place, likely drilled at a rate of up to 232 wells per year, and substantially expanding the impacts beyond those that were authorized in the original plan issued in 2000. In addition, in a precedent setting move the operators propose to drill year-round and no longer be subject to well-established, seasonal drilling protections for big game and sage grouse.

Unless strong and enforceable mitigation measures are included, this ramped-up drilling in the Pinedale Anticline will harm northwest Wyoming's quality of life, exceptional vistas, and extraordinary wildlife - all the things that make the Upper Green a great place to live and visit.

Finding an approach that won't sacrifice the Upper Green River Valley for energy:

Although the new plan contains several components proposed by industrial operators that would actually work to reduce habitat fragmentation and wildlife disturbance, it still allows development to proceed too fast, and does not provide enough protections.

The BLM has the tools for a good plan but so far has failed to combine them into a sensible conservation alternative. BLM needs to revise its proposals so that the final decision incorporates both the positive operator-proposed components found in alternative D and the special area protections and timing stipulations found in alternative E (the alternative E provisions continue important and long-established special area protections found in the 2000 Pinedale Anticline EIS). In addition, specific changes must be made to strengthen and/or clarify several air and wildlife provisions, as described in the section below.

If the BLM and cooperating agencies make these changes, the final SEIS would then allow for the operators' proposed 4,400 new wells but at a slower pace, with stronger mitigation measures, and with clearer language governing implementation. Doing less than this will mean significant erosion of the world-class wildlife populations and air quality found in this part of the Greater Yellowstone Ecosystem, as well as escalation of the stresses on roads, infrastructure, businesses, social services, and housing that the current drilling boom is already causing.

Key Changes, Clarifications, or Additions Needed to the SEIS Preferred Alternative:

• Incorporate the special management area provisions in alternative E into the currently preferred alternative (alternative D) so that development is guided by a staged, coordinated drilling approach limited to the Anticline crest via multi-well pads, liquid gathering system, and long-term flank protections, as well as seasonal timing restrictions and special management area prescriptions. No more than 250 additional well pads should be constructed.
• Strengthen the new provision in the preferred alternative suspending some flank area leases (or imposing No Surface Occupancy requirements) in order to preserve wildlife migration and limit big game winter range disturbance. The length of the lease suspensions (currently only certain for 5 years) should at a minimum equal the length of the drilling phase for the Anticline crest, which is until at least 2023. Suspensions for only 5 years cannot guarantee protection of the important wildlife habitats on the flanks.
• Remove Alternative D's Potential Development Area or "PDA." There is no need for this half-mile wide expansion beyond the core area where year-round drilling could be allowed. Pinedale operators are already capable of directionally drilling a half mile (and technological advances will soon make greater reach distances feasible). Alternative D's core area was already expanded 23 percent beyond the original Draft SEIS proposal, which ensures that all the high gas potential areas are included in this core area (see SEIS map 2.4-4). Also, previous BLM analysis has concluded that the Mesa Breaks and New Fork River area provide exceptional refuge for winter wildlife, but the proposed PDA includes some of these areas. To access gas beyond the core area, operators should access it directionally from existing pads.
• In order to protect the exceptional fisheries in the New Fork and Green watersheds, stronger measures to control sediment run-off should be added so that "substantial watershed impacts" do not occur, as allowed and acknowledged in the current SEIS.
• Instead of limiting actions to "practicable means," the final SEIS must clearly require "any and all available means" (as specified in the original draft SEIS) be used to protect visibility in Class I airsheds of Grand Teton Park and all Wind River Wilderness Areas.
• Strengthen the Wildlife Monitoring and Mitigation Plan and Matrix (Appendices 9 and 10) so that revision of drilling operations and pace of development (option 4 in the matrix) is stipulated as a primary response to any wildlife threshold exceedance. At best, Alternative D now provides for this as a last resort, after other voluntary options are first tried and years of monitoring show continued exceedance. Also, so that the public has certainty that the thresholds will provide some protection and so that they compel operators to proactively take action, the monitoring and mitigation program details must be provided in the SEIS and not left up to just operators, BLM, and WYGFD to develop after SEIS approval.
• Include more direction in the SEIS regarding off-site mitigation and for all monies in the Operators Monitoring and Mitigation Fund, and soon after SEIS approval. As now proposed, the operators will develop a comprehensive off-site mitigation plan within one year of SEIS approval and initially contribute only $4.2 million of the total $36 million committed. The rest of the monies are tied to industry getting to pursue the pace of development it wants. Given that Anticline operators expect to spend $3-8 million per well and will likely gross $ 175 billion (assuming $7/mcf gas price - Cheyenne Hub price on 1/14/08 - and given the SEIS estimate of 25 TCF total field production), providing just $36 million up front is a very financially modest requirement.
• Add a provision to the SEIS specifying that all currently unleased lands in the PAPA (now totaling 37,067 acres), as well as any areas in the PAPA with upcoming lease expirations, be withdrawn from leasing availability for the life of the SEIS. In addition, the SEIS should identify areas adjacent to the PAPA for lease withdrawal (the Pinedale Resource Management Plan should reinforce these lease withdrawals). Such a withdrawal provision would serve to help provide both secure wildlife habitat areas off the Anticline core and provide larger blocks of habitat where off site mitigation projects could be effectively conducted without risk of development undermining such investments.

More information on this plan can be found here: http://www.blm.gov/wy/st/en/info/NEPA/pfodocs/anticline/seis.html

To submit your own comments:

Caleb Hiner
Project Manager
Bureau of Land Management
Pinedale Field Office
1625 West Pine Street
P.O. Box 768
e-mail: WYMail_PAPA_YRA@blm.gov