Wyoming Outdoor Council Alert
February 4, 2003BLM Plans To Give 66,000 Natural Gas Wells A Home On The Range In Wyoming And Montana. Protests Due February 18th!
The Powder River Basin of Wyoming and Montana is a vast region of rolling plains nestled near the Rockies that is home to large herds of wildlife, and to farmers and ranchers who have made it their home for generations. This 13 million acre area is the quintessential wide-open West. The U.S. Bureau of Land Management (BLM), however, is seeking to turn this quiet rural landscape into a national sacrifice area for the benefit of the oil and gas industry. BLM's Final Environmental Impact Statements for the Powder River Basin in Wyoming and Montana together call for 66,000 new wells to be drilled in this magnificent area. This would be the largest natural gas field ever approved by BLM! Most of these wells would extract "coalbed methane" (CBM), which is natural gas extracted from coal seams that involves a process which causes extreme environmental impacts, particularly water pollution problems. Last spring we alerted you to BLM's plans when the draft studies were released. And your comments at that time made a difference- because of overwhelming public concern BLM acknowledged many scientific errors and unacceptable impacts to surface waters and improved its analysis of impacts to our clean air and water and wildlife resources. But the final studies remain unacceptable in many ways. For example, no new alternatives were developed to lessen the impacts of the 66,000 new CBM wells, and BLM still adopts industry's maximum production scenario with no new serious solutions offered to meaningfully reduce impacts.
It is critical that you speak out again! Don't delay! Protests must be postmarked by February 18 or e-mailed by close of business that day. You can send the enclosed suggested letter to BLM, or better yet, send a personalized letter. Thanks!
Detailed Statement Of The Problem
The Powder River Basin is located in northeast Wyoming and south-central/southeastern Montana. It is a land of sweeping short-grass prairies that once was home to vast herds of bison and is still home to huge herds of deer, elk, and pronghorn antelope, as well as other wildlife such as golden eagles, sage grouse, and prairie dogs. The Basin is ringed by the Rockies in many places, giving meaning to the line 'purple mountains majesty above the fruited plain' in America the Beautiful. It is ranching country where many farmers and ranchers have worked hard to earn livings for generations. This vast area of approximately 13 million acres is dissected by rivers with names that evoke the wide-open spaces of the west: the Yellowstone, Tongue, Belle Fourche, and Powder River itself.
The Powder River Basin is also underlain with seams of coal. Coal mining operations already exist in the area. Coal, however, also produces methane-natural gas-and the oil and gas industry is bent on exploiting this resource for its profit. Much of the coal in the Powder River Basin is owned by the Federal government, which means it must give its approval before much of the "coalbed methane" (CBM) can be extracted. But the Administration has made no secret of its desire to dramatically expand oil and gas drilling on the public lands, so the Federal government is actively assisting industry to expand drilling in the Powder River Basin. The Powder River Basin plans are a poster-child for the on-the-ground reality of the Administration's energy policy, demonstrating almost total emphasis on increasing production with little effort to mitigate impacts to our wildlife and clean air and water. The Federal agency taking the lead in making the Administration's energy policy reality is the U.S. Bureau of Land Management (BLM), which is in charge of leasing, and managing the development of, onshore Federal oil and gas resources.
Unfortunately, the BLM is seeking to turn the quiet rural landscape of the Powder River Basin into an industrial sacrifice zone for the benefit of the oil and gas industry, instead of a home for ranchers and wildlife. BLM has released its Final Environmental Impact Statements (EISs) for the Powder River Basin in Wyoming and Montana. Together, the EISs call for 66,000 new wells to be drilled in this magnificent area. This would be the largest natural gas field ever approved by BLM! Most of these wells would extract CBM. There are already 14,000 CBM wells in the Powder River Basin.
CBM extraction creates environmental impacts that are far more severe than "conventional" oil and gas development. For example, the density of wells is often far greater in CBM fields, which means there are far more roads, power lines, and other infrastructure, which destroys wide-open spaces and wildlife habitat. BLM's EISs do not comprehensively plan for, or reduce the impacts of, the 26,000 miles of new roads, 52,000 miles of new pipelines, powerlines, and utility corridors, 1.6 million acres of disturbed land, 3,000-plus newly excavated infiltration pits, and thousands of discharge points for the nearly 2 trillion gallons of produced water that will result from the 66,000 wells BLM plans to approve. Impacts on this scale will destroy the natural environment of the Powder River Basin, its wildlife, and the social fabric of the area.
Most important, however, are the impacts of CBM development on the priceless water resources and rivers in this arid land. CBM production generates huge volumes of water. This "produced" water can be of low quality, with salinity problems that can destroy crops and affect aquatic ecosystems. Water tables can drop drastically, which severely impacts culinary, agricultural and livestock water sources, and can lead to the release of methane that finds its way into people's homes (creating explosion hazards) and kills vegetation. Produced water should be reinjected into the ground to avoid these and other problems. But BLM's chosen water handling method is to construct huge CBM "infiltration pits" on people's property, where impurities can become even more concentrated and cause even greater problems as the water finds its way into streams and aquifers. Furthermore, BLM's analysis of the impacts of all of this water is almost pure speculation because actual disposal methods will almost certainly differ from those assumed in the EISs. Again, nearly 2 trillion gallons of produced water would be generated.
Last spring we alerted you to the problems of CBM development in the Powder River Basin, and you responded in overwhelming numbers. Thank you, and your comments on last year's draft studies did make a difference. Because of overwhelming public concern, BLM acknowledged many scientific errors and unacceptable impacts to surface waters and improved its analysis of impacts to our clean air and water and wildlife resources. But, the final EISs remains unacceptable for the reasons described above, as well as for many other reasons. For example, no new alternatives were developed to lessen the impacts of the 66,000 new CBM wells, and BLM still adopts industry's maximum production scenario with no new serious solutions offered to meaningfully reduce impacts.
Therefore, it is critical that you speak out again! Don't delay! The deadline for protests to be received is February 18. You can send the enclosed suggested letter, or better yet, send a personalized letter. Thanks!
Contact Information
Protests must be postmarked by February 18 or e-mailed by close of business on that date. Time is short so don't delay sending them!
Your letter must include your name, address, and telephone number, even if you submit your protest by e-mail. If possible, state your interest, concern and involvement in this issue and refer to any prior comments you submitted.
Protests should be sent to:
Kathleen Clarke, Director
U.S. Bureau of Land Management
5655 MIB
1849 C Street NW
Washington, D.C. 20240E-mail: Kathleen_Clarke@blm.gov
The "Final Environmental Impact Statement and Proposed Plan for the Powder River Basin Oil and Gas Project" in Wyoming can be viewed at http://www.prb-eis.org/prb-feis.htm
The "Final Statewide Oil and Gas Environmental Impact Statement and Proposed Amendment of the Powder River and Billings Resource Management Plans" in Montana can be viewed at http://bogc.dnrc.state.mt.us/Final%20CBM%20EIS.htm
Please put the words "Powder River Basin FEIS protest" in the subject line if you send an e-mail to Director Clarke at: Kathleen_Clarke@blm.gov
Suggested Letter
Dear Ms. Clarke:
I want to protest the "Final Environmental Impact Statement and Proposed Plan for the Powder River Basin Oil and Gas Project" in Wyoming and the "Final Statewide Oil and Gas Environmental Impact Statement and Proposed Amendment of the Powder River and Billings Resource Management Plans" in Montana. As an American citizen I am directly and personally interested in, and affected by, the unprecedented oil and gas development activities that would occur as a result of the Bureau of Land Management's (BLM) plans presented in these environmental impact statements (EIS), which will have profound impacts on public lands and resources. My specific concerns include the following:
1. BLM failed to take the legally required "Hard Look" at the impacts of drilling thousands of new coalbed methane (CBM) wells.
2. BLM significantly altered the draft EIS by changing the primary means of water handling, reversing major scientific assumptions and providing volumes of new technical information, yet it did not provide for public and scientific review of this new material in a supplemental study.
3. BLM failed to fully analyze the impacts to surface waters due to the discharge of trillions of gallons of water over the life of the projects into ephemeral drainages and into infiltration reservoirs. BLM failed to look at other economically viable alternatives for the development of CBM that would reduce these impacts.
4. BLM failed to fully disclose the impacts to landowners who will bear the brunt of the impacts from drilling, road building, pipeline and power line construction, and water discharges.
5. BLM's chosen water handling method, constructing huge CBM "infiltration pits" on people's property is inadequately researched, will take large tracts of land out of production, and has not been demonstrated to accomplish the claimed results of preventing both ground and surface water contamination. Furthermore, BLM's analysis of the impacts of this water is speculative because actual disposal methods will almost certainly differ from those assumed in the EISs.
6. BLM's assessment of impacts to soils, vegetation, and wildlife resources is qualitative in nature and fails to comprehensively analyze impacts to these resources, and then avoid or mitigate those impacts.
7. BLM has done nothing to try and plan comprehensively at this stage to carefully and thoughtfully stage or phase development to lessen the impacts from the thousands of miles of new roads, pipelines, and power lines; the vast areas of bare soil created by drilling pads and roads; and the thousands of water disposal pits that will be constructed.
Thank you for considering these comments.Sincerely,
Thank you for your help with this important issue!
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The Wyoming Outdoor Council represents Wyoming citizens who are concerned
about our quality of life, our communities and our environment.We invite you to learn more about Wyoming Outdoor Council and the environmental issues in Wyoming. Visit our web site: www.wyomingoutdoorcouncil.org