Environmental United States Department of Assessment Agriculture
Forest True Oil LLC - Lander Peak Area Service Exploratory Proposal
March Bridger-Teton National Forest 2017
Sublette County, Wyoming
Township 32 North, Range 115 West, Sections 15, 16, 22, & 27
For further information contact:
Don Kranendonk, District Ranger Big Piney Ranger District P. O. Box 218 Big Piney, Wyoming 83113 307-736-5500
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, gender, religion. age, disability, political beliefs, sexual orientation, or marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an equal opportunity provider and employer.
Lander Peak Area Exploratory Proposal Environmental Assessment
TABLE OF CONTENTS
CHAPTER 1 - INTRODUCTION ...... 1 1.1 Introduction ...... 1 1.2 Document Structure ...... 1 1.3 Project Background and Location ...... 3 1.3.1 Regulatory Background ...... 3 1.3.2 Project Location ...... 4 1.3.3 National Environmental Policy Act Documents ...... 4 1.4 Purpose and Need ...... 6 1.5 Conformance with Existing Plans ...... 7 1.6 Decision Framework ...... 11 1.7 Agency and Tribal Consultation ...... 11 1.8 Public Involvement ...... 12 1.9 Key Issues ...... 12 CHAPTER 2 - PROPOSED ACTION AND ALTERNATIVES ...... 15 2.1 Introduction ...... 15 2.2 Project History and ExistinG Disturbance in the Lander Peak Area ...... 15 2.3 Alternatives Analyzed in Detail ...... 17 2.3.1 No Action Alternative ...... 17 2.3.2 Proposed Action ...... 17 2.3.3 Mitigation Alternative ...... 43 2.4 Comparison of Alternatives and Impacts ...... 53 2.5 Alternatives Considered but not Analyzed in Detail ...... 65 CHAPTER 3 - AFFECTED ENVIRONMENT AND EFFECTS ...... 67 3.1 Introduction ...... 67 3.2 Air Quality and Climate ...... 68 3.2.1 Current Conditions ...... 68 3.2.2 Environmental Consequences ...... 86 3.3 Environmental Justice ...... 90 3.3.1 Current Conditions ...... 90 3.3.2 Environmental Consequences ...... 91 3.4 Fire and Fuels ...... 91 3.4.1 Current Conditions ...... 91 3.4.2 Environmental Consequences ...... 92 3.5 Geologic Resources ...... 94 3.5.1 Current Conditions ...... 94 3.5.2 Environmental Consequences ...... 102 3.6 Invasive, Non-native Species and Noxious weeds ...... 104 3.6.1 Current Conditions ...... 104 3.6.2 Environmental Consequences ...... 107 3.7 Land Tenure, Rights of Way and Other Uses ...... 108 3.7.1 Current Conditions ...... 108 3.7.2 Environmental Consequences ...... 110 3.8 Migratory Birds ...... 110 3.8.1 Current Conditions ...... 110 3.8.2 Environmental Consequences ...... 113 3.9 Mineral Resources ...... 115 3.9.1 Current Conditions ...... 115 3.9.2 Environmental Consequences ...... 117 3.10 Paleontological Resources ...... 118 3.10.1 Current Conditions ...... 118 3.10.2 Environmental Consequences ...... 119 3.11 Range Management ...... 119 3.11.1 Current Conditions ...... 119
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3.11.2 Environmental Consequences ...... 120 3.12 Recreation ...... 122 3.12.1 Current Conditions ...... 122 3.12.2 Environmental Consequences ...... 123 3.13 Socioeconomics ...... 124 3.13.1 Current Conditions ...... 124 3.13.2 Environmental Consequences ...... 126 3.14 Soils ...... 127 3.14.1 Current Conditions ...... 127 3.14.2 Environmental Consequences ...... 127 3.15 Special Areas and Designations ...... 132 3.15.1 Current Conditions ...... 132 3.15.2 Environmental Consequences ...... 134 3.16 Threatened, Endangered, Proposed, Candidate, and Sensitive Animal Species ...... 135 3.16.1 Current Conditions ...... 135 3.16.2 Environmental Consequences ...... 158 3.17 Threatened, Endangered, Candidate and Sensitive Plant Species ...... 166 3.17.1 Current Conditions ...... 166 3.17.2 Environmental Consequences ...... 168 3.18 Transportation/Access ...... 169 3.18.1 Current Conditions ...... 169 3.18.2 Environmental Consequences ...... 169 3.19 Vegetation ...... 170 3.19.1 Current Conditions ...... 170 3.19.2 Environmental Consequences ...... 176 3.20 Visual Resources ...... 177 3.20.1 Current Conditions ...... 177 3.20.2 Environmental Consequences ...... 178 3.21 Wastes, Hazardous or Solid ...... 179 3.21.1 Current Conditions ...... 179 3.21.2 Environmental Consequences ...... 179 3.22 Water Resources ...... 180 3.22.1 Current Conditions – Surface Water ...... 180 3.22.2 Environmental Consequences – Surface Water ...... 189 3.22.3 Current Conditions – Groundwater Quantity and Quality ...... 191 3.22.4 Environmental Consequences – Groundwater Quantity and Quality ...... 194 3.22.5 Current Conditions – Water Use and Water Rights ...... 197 3.22.6 Environmental Consequences – Water Use and Rights ...... 202 3.23 Wetlands and Riparian Zones ...... 202 3.23.1 Current Conditions ...... 202 3.23.2 Environmental Consequences ...... 203 3.24 Wildlife ...... 204 3.24.1 Current Conditions ...... 204 3.24.2 Environmental Consequences ...... 209 CHAPTER 4 - CUMULATIVE EFFECTS ...... 212 4.1 Introduction ...... 212 4.2 Cumulative Effects Analysis Areas ...... 212 4.3 Past, Present, Reasonably Foreseeable Actions ...... 215 4.4 Cumulative Effects to individual resources ...... 215 4.4.1 Air Quality and Climate ...... 215 4.4.2 Cultural ...... 221 4.4.3 Environmental Justice ...... 221 4.4.4 Fire and Fuels...... 221 4.4.5 Geologic Resources ...... 221 4.4.6 Invasive, Non-native Species ...... 221 4.4.7 Land Tenure, Rights-of-Way and Other Uses ...... 222
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4.4.8 Migratory Birds ...... 222 4.4.9 Mineral Resources ...... 222 4.4.10 Paleontological Resources ...... 222 4.4.11 Range Management ...... 222 4.4.12 Recreation ...... 222 4.4.13 Socioeconomics ...... 222 4.4.14 Soils ...... 222 4.4.15 Special Areas and Designations ...... 223 4.4.16 Threatened, Endangered, Proposed, Candidate, and Sensitive Animal Species ...... 223 4.4.17 Threatened, Endangered, Proposed, Candidate, and Sensitive Plant Species ...... 223 4.4.18 Transportation/Access ...... 223 4.4.19 Tribal and Native American Religious Concerns ...... 223 4.4.20 Vegetation ...... 223 4.4.21 Visual Resources ...... 223 4.4.22 Wastes, Hazardous or Solid ...... 224 4.4.23 Water Resources...... 224 4.4.24 Wetlands and Riparian Zones ...... 224 4.4.25 Wildlife ...... 224 CHAPTER 5 - CONSULTATION AND COORDINATION ...... 225 5.1 AGENCY PARTICIPATION ...... 225 5.2 Preparers and Reviewers ...... 225 CHAPTER 6 – REFERENCES ...... 226
List of Figures
Figure 2.3-1 Well Pad 23-15 Stormwater BMPs for Initial Disturbance ...... 26 Figure 2.3-2 Well Pad 23-15 Stormwater BMPs for Long-Term Disturbance ...... 27 Figure 2.3-3 Well Pad 42-27 Stormwater BMPs for Initial Disturbance ...... 28 Figure 2.3-4 Well Pad 42-27 Stormwater BMPs for Long-Term Disturbance ...... 29 Figure 3.2-1 Snyder Basin, Wyoming Meteorological Data Wind Rose ...... 70 Figure 3.2-2 Annual Nitrogen Deposition (kg/ha-yr) at Pinedale, PND165 (1990–2013) ...... 85 Figure 3.2-3 Annual sulfur deposition (kg/ha-yr) at Pinedale, PND165 (1990–2013) ...... 85 Figure 3.5-1 Geologic Cross Sections ...... 96 Figure 3.16-1 Average Peak Counts of Greater Sage-Grouse Males at Active Leks within 5.3 miles of Access Roads from U.S. Highway 189 into the Project Area from 2006 through 2015 ...... 155 Figure 3.22-1 Available Surface Water Flow Data from South Cottonwood Creek – Gaging #9191300 (WSEO, 2016) ...... 186 Figure 3.22-2 Geologic Cross-Section in the Vicinity of the Lander Peak Unit ...... 194
List of Maps
Map 1.1-1 General Location ...... 2 Map 1.3-1 Project Area Access ...... 5 Map 1.5-1 Desired Future Conditions ...... 8 Map 2.2-1 Existing Development ...... 16 Map 2.3-1 Proposed Action ...... 18 Map 2.3-2 Well Pad 23-15 Proposed Disturbance Limits ...... 23 Map 2.3-3 Well Pad 42-27 Proposed Disturbance Limits ...... 24 Map 2.3-4 Mitigation Alternative – Monitoring Locations ...... 49 Map 2.5-1 Alternatives ...... 66 Map 3.4-1 Fire Management Units ...... 93 Map 3.5-1 Geology ...... 95
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Map 3.5-2 Landslides ...... 101 Map 3.9-1 Oil and Gas Units ...... 116 Map 3.11-1 Allotments ...... 121 Map 3.14-1 Soil Mapping Units ...... 128 Map 3.15-1 Roadless Areas ...... 133 Map 3.16-1 Greater Sage-Grouse Habitat ...... 153 Map 3.16-2 Greater Sage-Grouse Habitat and 5.3-Mile Lek Buffers ...... 154 Map 3.16-3 Greater Sage-Grouse DDCT Evaluation Area - Detail ...... 164 Map 3.19-1 Vegetation Cover Types ...... 171 Map 3.22-1 Subwatersheds ...... 181 Map 3.22-2 Surface Water Features and Photo Locations ...... 182 Map 3.24-1 Big Game Ranges ...... 205 Map 3.24-2 Big Game Migration Routes ...... 206 Map 4.2-1 CD-C Project 4/12 km Domain ...... 213 Map 4.2-2 Cumulative Effects Analysis Areas ...... 214
List of Tables
Table 1.5-1 Forest Plan Desired Future Conditions and Resource Prescriptions, Standards, and Guidelines ...... 9 Table 2.2-1 Wells Drilled in the Lander Peak Area ...... 15 Table 2.2-2 Estimate of Existing Surface Disturbance and Reclaimed Areas in the Project Area ..... 17 Table 2.3-1 Modifications to True Oil’s Proposal ...... 19 Table 2.3-2 Applicable Lease Stipulations by BLM Lease Number ...... 20 Table 2.3-3 Surface Locations of Proposed Wells in the Lander Peak Area ...... 21 Table 2.3-4 Existing and Proposed Initial and Long-Term Surface Disturbance Associated with the Proposed Action ...... 22 Table 2.3-5 Constituents of Typical Hydraulic Fracturing Operation ...... 32 Table 2.3-6 Water Requirements during the Construction Phase ...... 34 Table 2.3-7 Construction Workforce ...... 36 Table 2.3-8 Estimated Peak Traffic Requirements during the Construction Phase ...... 37 Table 2.3-9 Workforce during the Operations Phase ...... 39 Table 2.3-10 Estimated Traffic Requirements during the Operations Phase ...... 39 Table 2.3-11 Recommended Spatial and Seasonal Buffers for Breeding Raptors ...... 46 Table 2.3-12 Water Quality Sampling Parameters ...... 51 Table 2.4-1 Comparison of Protective Measures and Mitigation for Alternatives ...... 54 Table 2.4-2 Comparison of Impacts ...... 61 Table 3.1-1 Potentially Impacted Resources ...... 67 Table 3.2-1 Mean Monthly Temperature Ranges and Total Precipitation Amounts ...... 69 Table 3.2-2 Wind speed distribution, Snyder Basin, Wyoming, 2011–2015 ...... 71 Table 3.2-3 Wind Direction Frequency Distribution, Snyder Basin, Wyoming, 2011–2015 ...... 71 Table 3.2-4 Ambient Air Quality Standards ...... 73 Table 3.2-5 Acute RELs (1-hour exposure) ...... 74 Table 3.2-6 Non-Carcinogenic HAP RfCs (annual average) ...... 75 Table 3.2-7 PSD increments (µg/m3) ...... 75 Table 3.2-8 Background ambient air quality concentrations (µg/m3) ...... 84 Table 3.2-9 Emissions (tpy) for Well Pad 23-15 ...... 87 Table 3.2-10 Maximum Well Production Emissions (tpy) ...... 87 Table 3.2-11 Lander Peak Area GHG (CO2e) Emissions (metric tons per year) ...... 88 Table 3.5-1 Stratigraphy of the Lander Creek Unit ...... 98 Table 3.6-1 Noxious Weed Species that Could Occur within the Project Area ...... 105 Table 3.7-1 Existing Rights-of-Ways within the Project Area and Along the Access Route ...... 109 Table 3.8-1 Birds of Conservation Concern within Bird Conservation Region 10 (Northern Rockies) that Occur or May Occur in the Project Area ...... 111
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Table 3.14-1 Limiting Soil Characteristics for Soils Affected ...... 129 Table 3.14-2 Soil Mapping Units Affected by the Proposed Action ...... 130 Table 3.14-3 Proposed Surface Disturbance in Sensitive Soils ...... 131 Table 3.16-1 Threatened and Endangered Species Listed under the ESA that Could Potentially Occur in the Project Area ...... 135 Table 3.16-2 Areas of Suitable Lynx Habitat for Five Forest Cover Types within in the Project Area...... 137 Table 3.16-3 Forest Service Sensitive Animal Species and Wyoming Species of Greatest Conservation Need Not Listed Under the Endangered Species Act that Could Potentially Occur in the Vicinity of the Project Area ...... 147 Table 3.16-4 Results of Fish Counted During Snorkel Surveys Conducted on Three Streams within the Project Area During August and September, 2011 ...... 157 Table 3.17-1 Forest Service Plant Sensitive Species Not Listed Under the Endangered Species Act ...... 167 Table 3.19-1 Vegetation Cover Types, Areas, and General Locations within the Project Area ...... 172 Table 3.19-2 Current Aspen Structural Stage Distribution in the Forest and in the Project Area Compared to Desired Conditions ...... 173 Table 3.19-3 Current Whitebark Pine Structural Stage Distribution in the Forest and in the Project Area Compared to Desired Conditions ...... 173 Table 3.19-4 Current Spruce/Fir Structural Stage Distribution in the Forest and in the Project Area Compared to Desired Conditions ...... 175 Table 3.19-5 Current Lodgepole Pine Structural Stage Distribution in the Forest and in the Project Area Compared to Desired Conditions ...... 175 Table 3.19-6 Estimated Disturbance by Vegetation Type ...... 176 Table 3.22-1 Mean Monthly Creek Streamflow Measurements, (cfs), 1983 – 1990 Monitoring Station 091913 - South Cottonwood Creek Near Big Piney, Wyoming (Drainage Area = 21.4 square miles) ...... 185 Table 3.22-2 Streamflow Measurements - September 2011 ...... 187 Table 3.22-3 WDEQ Use Based Surface Water Classifications – Classes 2AB and 3B ...... 189 Table 3.22-4 General Hydrologic Properties of the Geologic Strata in the Lander Peak Unit ...... 193 Table 3.22-5 Surface Water Rights ...... 197 Table 3.22-6 Groundwater Rights ...... 199 Table 4.2-1 Cumulative Effects Analysis Areas ...... 212 Table 4.3-1 Past, Present and Reasonably Foreseeable Activities/Projects ...... 216 Table 4.4-1 RFD Emissions within the CD-C Project Study Area ...... 218
List of Appendices
Attachment A Project Design Features and Conditions of Approval Attachment B Water Supply Well Permit from Wyoming State Engineer’s Office Attachment C Potential Fossil Yield Classification Attachment D Biological Evaluation for Sensitive Species and Management Indicator Species Report Attachment E Final Technical Report – TBSM/WEPP Modeling
List of Abbreviations and Acronyms
µeq/L microequivalents per liter µg/m3 micrograms per cubic meter AADT average annual daily traffic amsl above mean sea level ANC acid neutralizing capacity APD Application for Permit to Drill AR5 IPCC Fifth Assessment Report
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AQD Air Quality Division AQRVs Air Quality Related Values AQTSD Air Quality Technical Support Document BACT Best Available Control Technology BBS Breeding Bird Survey BCC Birds of Conservation Concern BEA Bureau of Economic Analysis BGEPA Bald and Golden Eagle Protection Act BLM Bureau of Land Management BLS Bureau of Labor Statistics BMPs Best Management Practices BOPE Blowout Preventer Equipment BTEX benzene, toluene, ethylbenzene, and xylene CAMx Comprehensive Air quality Model with Extensions) CASTNET Clean Air Status and Trends Network CD-C Continental Divide-Creston CEAA cumulative effects analysis area CEQ Council on Environmental Quality CFR Code of Federal Regulations cfs cubic feet per second CO carbon monoxide COAs Conditions of Approval CO2e carbon dioxide equivalents DATs deposition analysis thresholds dBA decibels dbh diameter at breast height DDCT Density and Disturbance Calculation Tool DFC Desired Future Condition DPS Distinct Population Segment dv deciview DVC base year or current year EA Environmental Assessment EIS Environmental Impact Statement EO Executive Order EPA U.S. Environmental Protection Agency oF degrees Fahrenheit fbs feet below surface FDOP first date of production FEM Fugitive Emissions Modeling FIP Federal Implementation Plan FLAG Federal Land Managers’ Air Quality Related Values Work Group FLMs Federal Land Managers FML federal mineral lease FMU Fire Management Unit Forest Bridger-Teton National Forest Forest Service United States Forest Service FR Federal Register FWS U.S. Fish and Wildlife Service GHGs greenhouse gases GHMA General Habitat Management Area GIS Geographic Information System gpm gallons per minute GWP Global Warming Potential GWPC Ground Water Protection Council GYE Greater Yellowstone Ecosystem GYWPMWG Greater Yellowstone Whitebark Pine Monitoring Working Group
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HAPs hazardous air pollutants Hayden-Wing Hayden-Wing Associates, LLC HMA Herd Management Area ICE internal combustion engine IDHL Immediately Dangerous to Life or Health IMPROVE Interagency Monitoring of Protected Visual Environments INCs Incidents of Non-Compliance IPPC Intergovernmental on Climate Change IRA Inventoried Roadless Area JIDP Jonah Infill Drilling Project Area kg/ha-yr kilograms per hectare per year LAU Lynx Analysis Units m3 cubic meters MATS Modeled Attainment Test Software MBTA Migratory Bird Treaty Act MDP Master Development Plan MIS Management Indicator Species MMT million metric tons MOU Memorandum of Understanding N nitrogen N2O nitrous oxide NAAQS National Ambient Air Quality Standards NADP National Acid Deposition Program NASA National Aeronautics and Space Administration NCA National Climate Assessment NEPA National Environmental Policy Act NESHAPS National Emission Standards for Hazardous Air Pollutants NFMA National Forest Management Act NFSR National Forest System Road NOx nitrogen oxides NO2 nitrogen dioxide NOAA National Oceanic and Atmospheric Administration NPS National Park Service NRCS National Resources Conservation Service NSPS New Source Performance Standards NSR New Source Review NTN National Trends Network NWI National Wetland Inventory PCA Primary Conservation Area PCEs Primary Constituent Elements PGM photochemical grid model PHMA Priority Habitat Management Area PM particulate matter PM2.5 particulate matter less than 2.5 microns in diameter PM10 particulate matter less than 10 microns in diameter ppb parts per billion ppm parts per million PRISM Parameter-elevation Regressions on Independent Slopes Model PSD Prevention of Significant Deterioration PVC polyvinyl chloride RARE II Roadless Area Review and Evaluation RAWS Remote Automatic Weather Station RCRA Resource Conservation and Recovery Act REA Rapid Ecoregional Assessment RELs Reference Exposure Levels RfCs Reference Concentrations for Chronic Inhalation
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RFD reasonably foreseeable development RIPRAP Recovery Implementation Program Recovery Action Plan ROS Recreation Opportunity Spectrum S sulfur SDS Scientific Data Sheet SGCN Species of Greatest Conservation Need SI spark ignition SIP State Implementation Plan SO2 sulfur dioxide SPCC Spill Prevention Control & Countermeasure SUPO Surface Use Plan of Operations SWAP State Wildlife Action Plan SWPPP Storm Water Pollution Prevention Plan TBSM Tahoe Basin Sediment Model TIP Tribal Implementation Plan tpy tons per year True Oil True Oil, LLC UGRB Upper Green River Basin USEIA U.S. Energy Information Administration USGS U.S. Geological Survey VIEWS Visibility Information Exchange Web System VOC volatile organic compound VQO Visual Quality Objective WAAQS Wyoming Ambient Air Quality Standards WAQSR Wyoming Air Quality Standards and Regulations WDAI Wyoming Department of Administration and Information WDEQ Wyoming Department of Environmental Quality WEPP Water Erosion Prediction Project WGFD Wyoming Game and Fish Department WOGCC Wyoming Oil and Gas Conservation Commission WSDOT Washington State Department of Transportation WYDOT Wyoming Department of Transportation WYNDD Wyoming Natural Diversity Database WYPDES Wyoming Pollutant Discharge Elimination System YGZRB Yellowstone Grizzly Bear Recovery Zone YRD Year-Round Development
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1.0 CHAPTER 1 - INTRODUCTION
1.1 INTRODUCTION
The United States Forest Service (Forest Service) and the Bureau of Land Management (BLM) have received a proposal from True Oil LLC (True Oil) to drill two exploratory natural gas wells (Klaenhammer Federal 23-15H and Klaenhammer Federal 42-27H) on existing federal leases on National Forest System (NFS) lands, as well as to drill a water supply well on an existing well pad with a temporary surface water line to the two well pads with the proposed exploratory wells (Project or Proposed Action). True has also submitted Applications for Permit to Drill (APDs) to the BLM. The Forest Service and the BLM share responsibilities in managing oil and gas activities on NFS lands according to a Memorandum of Understanding (MOU) BLM MOU WO300-2006-07 (BLM and Forest Service, 2006). The Forest Service serves as the lead agency for this environmental analysis and is responsible for approving the Surface Use Plan of Operations. The BLM serves a co-lead for the environmental analysis, manages the federal mineral estate, and provides final APD approval with enforceable Conditions of Approval (COAs). A list of Project Design Features and COAs are provided in Attachment A. The Forest Service and BLM will cooperate with each other on the signing and release of decision documents.
Map 1.1-1 provides the general location of the Proposed Action. An environmental analysis under the National Environmental Policy Act (NEPA), which includes public participation, is required for all proposed operations and is provided in this Environmental Assessment (EA).
1.2 DOCUMENT STRUCTURE
This EA has been prepared in compliance with NEPA and other relevant federal and state laws and regulations. It describes and discloses the direct, indirect, and cumulative environmental effects of the No Action Alternative, the Proposed Action, and the Mitigation Alternative for True Oil’s proposal to complete two exploratory natural gas wells within the Bridger-Teton National Forest (Forest). This EA is not a decision document. The decision to lease this area for oil and gas exploration/development has already been made and leases were issued in 1969. The pending decision is how and where the drilling and production would occur. If it is determined that there are no significant impacts, a draft decision would be described and explained in a draft Decision Notice and Finding of No Significant Impact and an opportunity to object would be provided to those eligible. Upon completion of the objection process a final decision would be made. If significant impacts are expected to occur, an Environmental Impact Statement would be prepared. This EA is organized as follows:
Chapter 1.0 Introduction - describes the purpose of and need for the Proposed Action and discusses how the Project relates to the 1990 Bridger-Teton National Forest Land and Resource Management Plan as amended in 2015 (Forest Plan – Forest Service 2015a). This chapter details how the Forest Service informed the public of the Proposed Action, describes how the public responded, and identifies the issues driving the analysis.
Chapter 2.0 Proposed Action and Alternatives - describes the Proposed Action and alternatives. The No Action Alternative, Proposed Action, and the Mitigation Alternative are considered in detail. Alternatives to the Proposed Action that were considered but not analyzed in detail are presented along with the rationale for not analyzing them in detail.
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Map 1.1-1 General Location
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Chapter 3.0 Affected Environment and Environmental Consequences - describes the physical, biological, and human environments potentially affected by the Proposed Action and alternatives and describes the potential effects of the Proposed Action and alternatives.
Chapter 4.0 Cumulative Effects – described the potential cumulative effects of the Proposed Action and alternatives.
Chapter 5.0 Consultation and Coordination - contains information on consultation and coordination that occurred as part of the Project and provides a list of preparers.
Chapter 6.0 – References – a listing of literature cited in the document.
Appendices - provide supplementary information for Chapters 1.0 through 3.0.
The interdisciplinary team used a systematic approach for analyzing the Proposed Action and alternatives and preparing this EA. The process complies with NEPA and the Council on Environmental Quality (CEQ) regulations and Forest Service Handbook (FSH) 1909.15 (Forest Service, 2012). Project planning was coordinated with appropriate federal, state, and local agencies and federally-recognized Native American tribes of interest.
The EA may be downloaded from the project webpage at http://www.fs.usda.gov/project/?project=31165 or a compact disc may be requested from the Big Piney Ranger District office in Big Piney, Wyoming.
1.3 PROJECT BACKGROUND AND LOCATION
1.3.1 Regulatory Background The BLM manages the federal mineral estate (including under NFS lands) and offers, sells, and issues federal oil and gas leases. Federal oil and gas leases are legally binding contracts that grant the exclusive right to drill for, mine, extract, remove, and dispose of all the oil and gas (except helium) in the lands included in the lease, together with the right to build and maintain necessary improvements. The BLM considers the use of public lands and underlying mineral resources that it administers as a temporary use and not necessarily exclusive of other beneficial public uses. The oil and gas minerals within the Lander Peak Project Area were leased to True Oil in 1969.
The Forest Service has the authority and responsibility to identify lands available for leasing and to identify terms (stipulations) to be included in oil and gas leases on NFS lands. Leases do not authorize ground disturbance. Operations (including roads) proposed pursuant to leases must go through a separate permitting process. Once operations are proposed, the Forest Service and the BLM work closely with the lessees/operators in planning and designing operations to minimize impacts, to the extent allowed by the lease terms. The Forest Service has the authority to regulate all surface-disturbing activities conducted pursuant to federal oil and gas leases on NFS lands. Operators are required to conduct operations on leaseholds on NFS lands in a manner that minimizes effects to surface resources, prevents unnecessary or unreasonable surface resource disturbance, and is in compliance with other applicable requirements. The Forest Service is responsible for approving Surface Use Plan of Operations (SUPOs) that describes how the federal mineral estate would be developed.
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The BLM makes the final decision on activities pursuant to oil and gas leases subject to Forest Service approval of the SUPO, which is part of the APD. Permitting requirements for oil and gas wells and facilities located on federal lands are detailed in Federal Onshore Oil and Gas Order No. 1. The BLM may not approve an APD until the Forest Service has approved the SUPO. The Forest Service also approves surface disturbing aspects of related and subsequent operations. The Forest Service, the BLM, and lessee/operator must adhere to all statutory requirements and timelines for processing and approving an APD. COAs which are constraints on operations are incorporated in permits, and operations are overseen by the Forest Service and the BLM for compliance with the COAs. The COAs are made enforceable with inspections and if necessary, enforcement actions might be in the form of Written Orders and Incidents on Non-Compliance (INCs). Operations out of compliance with permit conditions may be halted until compliance is reached.
1.3.2 Project Location The Project Area is located approximately 24 miles southwest of Daniel in Sublette County, Wyoming. The Lander Peak Project Area is defined by the Lander Peak federal unit which contains 4,736 acres, all of which are NFS lands (see Map 1.3-1). A federal unit provides for the exploration and development of an entire geologic structure or area by a single operator so that drilling and production may proceed in the most efficient and economic manner.
This area is not included in the public land in the Wyoming Range withdrawn from future mineral leasing (Wyoming Range Legacy Act). Valid existing lease rights are not affected by the Act. The legal location for the Lander Peak Unit and Project Area is as follows:
6th Principal Meridian, Sublette County, Wyoming T. 32 N., R. 115 W. Sec. 9, S½, NW¼, S½, NE¼ Sec. 15, S½, NW¼ Sec. 16, 21, 22, 23, 27, 28, all
The Proposed Action would occur within Sections 15, 16, 22, and 27.
1.3.3 National Environmental Policy Act Documents Previous documents prepared under NEPA for this area are:
• True Oil Company Soda Unit Federal 33-22 Exploratory Gas Well Environmental Assessment and Decision Document (Forest Service and BLM, 1985a and 1985b); • True Oil Company, Soda Unit Federal 42-27 Exploratory Gas Well Environmental Assessment (WY-049-EA6-16) and Decision Document (BLM and Forest Service 1986a and 1986b); and • Soda Unit Federal Natural Gas Field Development Project Environmental Assessment (WY-041-EA87-037) and Decision Notice and Finding of No Significant Impact (Forest Service and BLM, 1988 and 1989).
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Map 1.3-1 Project Area Access
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1.4 PURPOSE AND NEED
The Forest Plan (Forest Service, 2015a) provides direction in goal 1.1 and objective 1.1(d) such that the Forest is to support community prosperity and to provide leasable, locatable, and salable mineral exploration and development opportunities (Forest Service, 2015a - p. 140). In addition, the Forest Plan goal 4.4 directs that other resources are protected during exploration and development of subsurface resources (Forest Service, 2015a - p. 149). Specifically objectives 4.4(a, b and c) directs the Forest Service to: a) require that surface occupancy of lands takes place only on lands available for mineral exploration and development; b) prevent surface occupancy where potential effects on other resources, including wildlife, threatened and endangered species, recreation, soils, air, visual resources, and water are unacceptable; and c) apply performance standards or stipulations in mineral plans, permits, and leases for the protection of other resource values.
Therefore, the purpose of this proposed federal action is to allow True Oil to exercise the rights granted under the federal leases within the Project Area in a manner that adequately protects other resource values. The need is for the Forest Service to comply with the respective legal and regulatory requirements, including but not limited to the Mineral Leasing Act, the Federal Land Policy and Management Act, 36 Code of Federal Regulations - CFR § 228.107, and 43 CFR § 3162.3-1. There is also a need to comply with relevant decisions in the Forest Plan (Forest Service, 2015a) concerning the review and approval of proposals to conduct activities on federal oil and gas leases.
If True Oil determines there is economic potential for the Lander Peak Area, they would be required to submit a Master Development Plan prior to full-field development. A Master Development Plan facilitates better planning of oil and gas infrastructure by considering development as a whole. A Master Development Plan includes a master drilling plan and a master SUPO. A Master Development Plan also identifies the geographic boundaries of the plan and lists all proposed facilities associated with the Proposed Action including well pads, roads, staging areas, production facilities, pipelines, utility corridors, gas compression facilities, and water facilities. Additional analysis under NEPA would be required before approval of a Master Development Plan.
All onshore oil and gas operations authorized by the BLM, such as APDs and Master Development Plans, are required to be conducted in a manner which protects other natural resources, environmental quality, life, property, and results in the maximum ultimate recovery of oil and gas with minimum waste and with minimum adverse effect on the ultimate recovery of other mineral resources (43 CFR § 3161.2). This EA analyzes the effects of the proposed Project on the physical, biological, and human elements of the environment, and requires, where necessary, operating conditions that ensure oil and gas lease operations associated with the APDs are conducted in the manner prescribed above.
The Forest Service has previously approved surface operating requirements in the form of lease stipulations. The BLM has incorporated these provisions within oil and gas leases which authorize the exploration for federal oil and gas resources in this area. The purpose and need for federal action is to determine whether and how (with what COAs) to approve the exploration proposed by True Oil for their existing lease operations on Forest. The Forest Service is responsible for the approval of surface plans, while the BLM is responsible for the review and approval of the oil and gas operator’s proposal and APDs.
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1.5 CONFORMANCE WITH EXISTING PLANS
The Forest Plan (Forest Service, 2015a) includes the following:
• goals and objectives for managing a variety of national forest resources (see Forest Plan, pages 112-121), • standards and guidelines, which are forest wide management prescriptions that apply to all areas on the national forest and are intended to accomplish the goals and objectives (see Forest Plan, pages 121-145) • desired future conditions (DFC), which are descriptions of future land or resource conditions that achieve a set of compatible multi-resource goals and objectives, and • management areas, which are descriptions and maps of desired future condition areas, summaries of associated output schedules, and management area-specific standards and guidelines.
The Project is consistent with Goal 1.1(d) under Communities continue or gain greater prosperity, which states “Provide leasable, locatable, and salable mineral exploration and development opportunities.”
The Project is consistent Goal 4.4 which directs that other resources are protected during exploration and development of subsurface resources. Specifically objectives 4.4(a, b and c) directs the Forest Service to: a) require that surface occupancy of lands takes place only on lands available for mineral exploration and development; b) prevent surface occupancy where potential effects on other resources, including wildlife, threatened and endangered species, recreation, soils, air, visual resources, and water are unacceptable; and c) apply performance standards or stipulations in mineral plans, permits, and leases for the protection of other resource values.
The Project Area is located in Management Area 25 – Cottonwood Creek. Management Area 25 includes 48,500 acres (1.4 percent of the Forest) that are managed for timber harvest, oil and gas, livestock production, and other commercial activities. Management Area 25 is characterized by a mixed conifer forest type that ranges from sapling-sized trees in burned and harvested areas to large pole/small saw log-sized trees in areas that have not been harvested during the last 50 years. Old growth timber is rare in the area. In addition to resource development, Management Area 25 is managed to provide wildlife habitat, watershed protection, dispersed recreation, and visual resources.
Map 1.5-1 shows the DFCs coinciding with the Project Area including DFC 1B, DFC 10, and DFC 12. DFC 1B is Substantial Commodity Resource Development with Moderate Accommodation of Other Resources, DFC 10 is Simultaneous Development of Resources, Opportunities for Human Experiences and Support for Big Game and a Wide Variety of Wildlife Species, and DFC 12 is Backcountry Big Game Hunting, Dispersed Recreation, and Wildlife Security Areas. Nearly all (98 percent) of the DFCs coinciding with the Project Area are managed for resource development. DFCs that coincide with the Project Area are listed in Table 1.5-1 along with resource prescriptions and standards and guidelines that would apply to the Project.
The Project is consistent with the Big Game Habitat Guideline for DFCs 1B and 10 which state “sufficient habitat should be provided to maintain desired populations and distribution of big- game species.” The Project would affect 5.50 acres of habitat and is not expected to alter desired populations and distribution of big-game species.
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Map 1.5-1 Desired Future Conditions
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Table 1.5-1 Forest Plan Desired Future Conditions and Resource Prescriptions, Standards, and Guidelines Desired Future Condition, Theme, and Management Emphasis Summary of Key Resource Prescriptions, Standards and Guidelines DFC 1B: Substantial Commodity Resource Recreation Prescription – Recreation is managed to provide Roaded Natural appearing Development with Moderate Accommodation of opportunities in roaded areas, and Semi-Primitive opportunities in other areas. Roaded Other Resources recreation opportunities are compatible with timber, livestock grazing, and minerals development. Recreation activities suitable for this area include dispersed, road-oriented Theme: An area managed for timber harvest, oil and uses such as firewood gathering, roadside camping and day use, off-highway vehicle (OHV) gas, and other commercial activities with many roads use on open routes, hunting, and winter sports. Use of closed roads for semi-primitive forms and moderate to occasionally substantial emphases of recreation such as horseback riding and hiking is suitable. on other resources Visual Quality Prescription – The Visual Quality Objective is generally Partial Retention or Modification. In sensitive foreground area, the Visual Quality Objective is retention. Management Emphasis: Management emphasis is Fisheries and Wildlife Prescription – Habitat is provided for existing populations of game on scheduled wood-fiber production and use, on and fish, but hunter-success and recreation-day objectives identified by the Wyoming Game livestock production, and other commodity outputs and Fish Department may decrease. A use-attainability study may be needed for a specific stream segment to determine if fishery-beneficial use is being protected to an adequate level. Big-Game Habitat Guideline – Sufficient habitat should be provided to maintain desired populations and distribution of big game species. Vegetation: Range Prescription – Range is managed to maintain and enhance range and watershed condition while providing forage for livestock and wildlife. Minerals Prescription – Minerals or energy exploration and development is encouraged. Lease stipulations emphasize mineral commodity production, while meeting some other resource objectives. Access: Roads Prescription – Management of the area requires an extensive road system with some seasonal and long-term road closures. Most vehicle access is limited to arterial and collector roads. Seasonally, local roads may be accessible. Some roads remain open to vehicles, and the main roads are maintained for passage of all vehicles. DFC 10: Simultaneous Development of Resources, Recreation Prescription – Existing roaded recreation opportunities continue where they do Opportunities for Human Experiences, and Support not interfere with the objectives for this area. Areas of both Semi-primitive Motorized and for Big-Game and a Wide Variety of Wildlife Species Semi-primitive Non-motorized are provided. Visual Quality Prescription – The Visual Quality Objectives are Retention, Partial Theme: An area managed to allow for some Retention, and Modification. resource development and roads while having no Fisheries and Wildlife Prescription – Groups of species are emphasized, such as early-or adverse and some beneficial effects on wildlife late-succession-dependent species, in order to increase species richness or diversity. Habitat is managed to achieve the game and fish populations, harvest levels, success, and Management Emphasis: Management emphasis is recreation-day objectives identified by the Wyoming Game and Fish Department and agreed to provide long-term and short-term habitat to meet to by the Forest Service. the needs of wildlife managed in balance with timber Big-Game Habitat Guideline – Sufficient habitat should be provided to maintain desired harvest, grazing, and minerals development. All populations and distribution of big-game species.
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Desired Future Condition, Theme, and Management Emphasis Summary of Key Resource Prescriptions, Standards and Guidelines surface-disturbing activities are designed to have no Vegetation: Range Prescription – Range is managed to maintain and enhance range and affect or beneficial effects on wildlife. If any portion of watershed condition while providing forage for livestock and wildlife. this area contains grizzly bear habitat, no surface- Minerals Prescription – The area is available for minerals location, sale or energy leasing, disturbing activities can occur there until the grizzly exploration, and development. New leases are issued with the appropriate stipulations to bear cumulative effects model can be run to help require compatibility with other resource objectives. determine potential effects on the grizzly bears Access: Roads Prescription – Management of the area requires a moderate road system to provide commodity and public access. Most travel is limited to arterial and collector roads with seasonal or long-term closure of many local roads for wildlife security. DFC 12: Backcountry Big-Game Hunting, Dispersed Recreation Prescription – Recreation and other human activities are managed to meet Recreation, and Wildlife Security Areas needs of the big-game species. Visual Quality Prescription – The Visual Quality Objectives are Retention and Partial Theme: An area managed for high-quality wildlife Retention. habitat and escape cover, big-game hunting Fisheries and Wildlife Prescription – Habitat will be managed to help meet the game opportunities, and dispersed recreation activities populations, harvest levels, success, and recreation-day objectives, and to fully achieve the fish populations, harvest levels, success, and recreation-day objectives identified by the Management Emphasis: Management emphasis is Wyoming Game and Fish Department and agreed to by the Forest Service. on providing such important habitat for big-game as Big Game Habitat Guideline – Sufficient habitat should be provided to maintain desired winter ranges, feedgrounds, calving areas, and populations and distribution of big-game species. security areas. Management provides for habitat Minerals Prescription – Minerals or energy exploration and development of existing leases capability and escape cover, and maintained Semi- is allowed. Energy development areas must meet habitat capability and escape cover. primitive Non-motorized opportunities that emphasize Although some energy development projects do not meet Semi-primitive opportunity big-game hunting activities. If any portion of this area classification, every effort is made to make them compatible. Exploration and development contain grizzly bear habitat, no surface-disturbing methods and practices that minimize road building, noise, and other game disturbance will activities can occur there until the grizzly bear be encouraged. cumulative effects model can be run to help Access; Roads Prescription – Management of the area requires a limited amount of open determine potential effects on the bear. roads for public access and some commodity removal. Most travel is limited to arterial and collector roads with long-term closure of most local roads for wildlife security.
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The Project is also consistent with Guidelines 21 and 22 of the Greater Sage-grouse Record of Decision (Forest Service, 2015b) which state:
Guideline 21 – In priority core habitat management areas and sagebrush focal areas, limit the density of activities related to oil and gas development or mining activities to no more than an average of one pad or mining operation per 640 acres, using the current Density Disturbance Calculation Tool process or its replacement.
Guideline 22 – In priority habitat management areas and sagebrush focal areas, do not authorize surface disturbing activities unless all existing discrete anthropogenic disturbances cover less than 5% of the suitable habitat in the surrounding areas using the current Density Disturbance Calculation Tool process or its replacement and the new use will not cause exceedance of the 5% cap.
1.6 DECISION FRAMEWORK
Given the purpose and need, the deciding official (the Big Piney District Ranger) reviews the Proposed Action and the other alternatives in order to make the following determinations:
The natural gas exploration proposal complies with applicable standards and guidelines found in the Forest Plan and all laws governing Forest Service actions.
Sufficient site-specific environmental analysis has been completed.
The proposed Project benefits the public and is in their best interest.
With these assurances the deciding official (the Big Piney District Ranger) must decide:
Whether or not to accept the Proposed Action or one of the alternatives which includes the No Action Alternative.
What, if any, additional actions should be required to better manage natural resources and recreational opportunities in the Project Area.
1.7 AGENCY AND TRIBAL CONSULTATION
Native American Tribes: The Project was discussed with the tribal representative for the Eastern Shoshone in May of 2015 in a face-to-face meeting. Because the Proposed Action would take place on areas previously surveyed and no sites were identified, the tribal representative had no concerns with the Project (Schoen, 2016).
U.S. Fish and Wildlife Service: The Forest Service has prepared a Biological Assessment addressing potential impacts to species listed under the Endangered Species Act (ESA). On February 16, 2017 the Forest Service requested concurrence from the U.S. Fish and Wildlife Service (FWS).
Wyoming State Historic Preservation Office: Previous cultural resource surveys and consultation for existing well pads was adequate and provided coverage for new proposed disturbance. There were no historic or prehistoric sites in the area and no historic properties would be affected. Therefore, there is no need for additional survey or consultation for the Project (Schoen, 2011).
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1.8 PUBLIC INVOLVEMENT
As part of the NEPA process, public scoping was conducted in 2012 in response to True Oil’s 2012 proposal and again in 2015 when True Oil revised their proposal. Scoping conducted in 2015 provided the public a second opportunity to comment on the proposed Project. The Project is now subject to the pre-decisional objection process (36 CFR § 218.7 parts A and B), and is no longer subject to the appeal process (36 CFR § 215) as noted in the 2012 scoping letter. The new regulations provide an opportunity for individuals, organizations, and tribal entities to file an objection to a project before the final decision is signed. This differs from the previous process when the appeals review began subsequent to the decisions. This allows those interested parties to express concerns regarding the draft decision before the final decision is made. Individuals, agencies, businesses and environmental groups who submitted comments during either the 2012 or 2015 scoping process are eligible to participate in the objection process.
The 2012 proposal, a news release, a letter to the public, and a map were posted to the Forest Service website at http://www.fs.usda.gov/project/?project=31165 on March 15, 2012. Additionally, letters were mailed to interested parties soliciting comments on the proposal. The Forest Service invited the public to provide comments on the proposal for 30 days beginning March 15, 2012 through April 16, 2012. In response to requests from the public, the comment period was extended for an additional 30 days to May 15, 2012. No public meetings were held. A second scoping letter to the public was posted on the Forest Service website on October 23, 2015 and the 2015 proposal was posted to the website on October 28, 2015. The public was invited to provide comments on the proposal for 30 days beginning November 1, 2015 through December 1, 2015.
The public comments were reviewed and have been considered in the analysis, where appropriate.
1.9 KEY ISSUES
During the 2012 comment period, 24 comment letters/emails were received and during the 2015 comment period, 21 comment letters/emails were received. A summary of identified issues from both 2012 and 2015 scoping is provided below.
Alternatives. One comment suggested that the Forest Service analyze a reasonable range of alternatives and not narrowly constrict the purpose and need statement.
Air Quality. The air quality comments centered on gathering baseline ambient air quality data prior to development, (which would involve adding an air monitoring station in the vicinity of the Project); providing estimates of emissions during construction and operations; demonstrating compliance with Wyoming and National ambient air quality standards (WAAQS and NAAQS), PSD (Prevention of Significant Deterioration) increments; evaluating impacts to air quality related values (visibility and atmospheric deposition); addressing Upper Green River Basin nonattainment area issues for the ozone NAAQS; and addressing the effects of proposed greenhouse gases on climate change.
Cumulative Impacts. Commenters suggested considering the cumulative impacts related to the Legacy Act, and all direct and indirect impacts to fish and wildlife from any ongoing and proposed oil and gas development on the Forest.
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General. A few general comments expressed frustration that the leases fall outside the Legacy Act boundaries; others expressed either general opposition or general support for the Project; Comments raised concerns about prior upkeep of the well sites and associated equipment and the lack of monitoring and oversight by the Forest Service.
Geology and Soils. Comments included concern regarding earthquake prone areas and hydraulic fracturing operations.
Grazing. Cottonwood Ranches expressed concern about oil and gas development adversely affecting their current and future use of the South Cottonwood Allotment for grazing.
Hazardous Materials and Waste. Commenters asked about trash and waste handling, monitoring and detection of spills and leaks, and expressed concern about the use of hydraulic fracturing chemicals.
Health and Safety. Concerns were expressed related to water, soil, and air contamination, traffic management, storage of chemicals, and requested full disclosure of chemicals used for drilling and hydraulic fracturing.
Land Use. The Lincoln County Board of Commissioners requested that a map of all private and public lands and current leases be provided in the document.
Monitoring and Mitigation. Commenters asked that short- and long-term monitoring plans be developed for water sampling prior to, during, and after exploration. Commenters expressed concern regarding Forest Service oversight and monitoring of operations in 2006.
Noise. Commenters asked that the noise be addressed – specifically how it would impact recreation in the area. One comment recommended noise baseline studies at various locations on the road and at residences and adopting procedures to limit traffic if noise guidelines are exceeded.
Invasive Non-Native Species and Noxious Weeds. Comments recommended equipment decontamination procedures and reclamation plans and standards that would prevent the spread of noxious weeds.
Process/Policy. Several commenters asked about the plans to expand the field if exploration proves successful and questioned why the larger development plan was not mentioned in the scoping process. It was recommended that full-field development be disclosed and considered in any environmental analysis. Some commenters suggested preparing an Environmental Impact Statement (EIS) rather than an EA due to the potential impacts from future full-field development.
Proposed Action. The Wyoming Game and Fish Department (WGFD) expressed concern about the man-made reservoir included in the 2012 proposal on the existing well pad and suggested drilling freshwater wells or installing a gathering pipeline between wells for the shipping and disposal of water to reduce truck traffic. WGFD also suggested that the Forest Service consider alternative pad locations that consider setbacks from riparian areas, existing disturbance, and popular recreation areas.
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Reclamation. The WGFD recommended that True Oil outline reclamation plans and standards in the Surface Use Plan of Operations to include both ground cover and species composition requirements for both interim and permanent reclamation. One comment suggested that the Forest Service require True Oil to promptly restore all disturbed areas to predisturbance conditions and to conduct interim reclamation concurrently with other operations. Another comment suggested that the EA include provisions to clean up any residual surface and subsurface problems in the current producing well sites and storage sites, should they exist.
Recreation. Several commenters discussed the recreation use of the area and asked that impacts to recreation – specifically, fishing, hunting, and camping – be fully analyzed.
Socioeconomics. Comments expressed concern regarding the socioeconomic impacts and mitigation measures related to travel and tourism, recreation, and county services.
Special Status Species. The WGFD and other commenters expressed concern and requested that the Forest Service provide adequate resource protections for Species of Greatest Conservation Need, specifically the Colorado River cutthroat trout. Other species mentioned include the greater sage-grouse and the Canada lynx.
Transportation and Access. Several comments discussed increased truck traffic and impacts to access routes during construction and operations. Suggestions included speed control measures, road designs that would eliminate erosion, analysis and management of wildlife populations along access routes, and limiting access and activity during critical big game seasons. One commenter addressed the transportation corridor that affects the Ryegrass Area.
Vegetation. The WGFD recommended avoiding impacts to vegetation, including no surface occupancy within riparian corridors and a 500-foot buffer; avoiding any loss or impacts to aspen, willow, and sedge communities; and avoiding using riparian areas as staging and refueling areas. One comment recommended a baseline study of flora and fauna to assess changes as a result of development.
Visual and Lighting. Commenters expressed concern about visual impacts and light pollution and recommended measuring and establishing a baseline and addressing light pollution as it pertains to recreation in the forest. Mitigation could include light deflectors and time limitations during drilling and using vegetation and topographic features to conceal well pads.
Wetlands. Comments suggested surveying and mapping wetlands and riparian zones in the Project Area and recommended setbacks and buffer protections.
Water Resources. Numerous comments requested analysis of potential impacts to surface water and groundwater quantity and quality, the availability of baseline data and the need for monitoring plans. Specific concerns included the extent of surface and groundwater connection and the potential impacts of hydraulic fracturing.
Wildlife. Comments addressed the disruption/removal/fragmentation of habitat. Concern was expressed about big game migration routes and seasonal habitats; increased sediment loads in streams; decreased riparian vegetation; and impacts to fish, macroinvertebrates, and amphibians. Recommendations included incorporating the most current big game data and seasonal range designation maps in the analysis as well as restrictive buffers, baseline surveys, and limiting disturbance during critical big game seasons.
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2.0 CHAPTER 2 - PROPOSED ACTION AND ALTERNATIVES
2.1 INTRODUCTION
The purpose of this chapter is to describe alternatives, both those analyzed in detail and those considered but not analyzed in detail. Alternatives analyzed in detail include the No Action Alternative, the Proposed Action, and the Mitigation Alternative.
2.2 PROJECT HISTORY AND EXISTING DISTURBANCE IN THE LANDER PEAK AREA
Project History. In 1978 True Oil drilled an exploratory well in the Lander Peak Area, which was subsequently plugged and abandoned. True Oil formed the federal Soda Unit in August 1981 which encompassed approximately 22,527 acres on NFS lands. The Soda Unit was terminated in 1995. Between 1981 and 1987, True Oil drilled four exploratory wells on four well pads, three of which are currently producing when weather conditions allow and one which has been plugged and abandoned (see Table 2.2-1). In August 2001, True Oil drilled the Klaenhammer Federal 32-22 well, which is currently producing.
Table 2.2-1 Wells Drilled in the Lander Peak Area Well Pad Depth Section Name Well Name Spud (feet) Status Lease No. P&A1 16 13-16 Bare Creek Unit 13-16 10/12/1980 4,582 11/25/80 WYW16419 (NWSW) 13-16a Soda Unit 13-16A 10/16/1983 14,298 Producing 15 P&A 23-15 Soda Unit 23-15 10/07/1981 11,847 WYW16419 (NESW) 8/31/95 22 32-22 Klaenhammer Fed 32-22 8/22/2001 12,175 Producing WYW16420-A (SWNE) 22 33-22 Soda Unit 33-22 7/24/1985 11,994 Producing WYW16420-A (NWSE) 27 42-27 Soda Unit 42-27 7/17/1987 11,573 Producing WYW16420 (SENE) 1 P&A=plugged and abandoned.
The Soda Unit was approved in 1981 to target the Frontier Formation but was terminated in 1995. In 2013, the Lander Peak Unit was approved to target the Hilliard Shale. The boundary of the Lander Peak Unit coincides with the Project Area.
Existing Disturbance. Existing disturbance within the Project Area totals approximately 25.4 acres (5.4 acres for well pads and 20 acres for roads) with an additional 16.8 acres of reclaimed lands (5.8 acres for well pads and 11 acres for gathering lines). Table 2.2-2 provides approximate acreages for the various types of existing disturbance. Existing disturbance was estimated by digitizing disturbance from satellite imagery (see Map 2.2-1). There are currently four producing wells (on four well pads) which produce from the Frontier Formation, generally during the summer months from July through September (see Table 2.2-2).
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Map 2.2-1 Existing Development
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Table 2.2-2 Estimate of Existing Surface Disturbance and Reclaimed Areas in the Project Area Total Project Component (acres)1 Existing Disturbance Well Pads 5.4 Roads 20 Subtotal 25.4 Reclaimed Areas Well Pads 5.8 Gathering Lines and Pipelines2 11 Subtotal 16.8 Total 42.2 1 Acres were calculated from digitized disturbance based on 2015 satellite imagery. 2 Gathering lines and pipelines are generally co-located with roads.
2.3 ALTERNATIVES ANALYZED IN DETAIL
2.3.1 No Action Alternative NEPA and CEQ regulations require that a No Action Alternative be presented in all EAs to serve as a “baseline” or “benchmark” from which to compare all proposed “action” alternatives. All action alternatives involve federal subsurface minerals encumbered with federal oil and gas leases that grant the lessee a right to explore and develop the leases. Although the Forest Service and BLM cannot deny the right to drill and develop the leasehold, individual APDs can be denied to prevent unnecessary and undue degradation. The No Action Alternative constitutes denial of the APDs associated with the Proposed Action. Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. However, Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These include activities associated with oil and gas development, pipelines, access roads, habitat management, commercial timber harvest, recreation, and grazing (see Table 2.2-2).
2.3.2 Proposed Action Under the Proposed Action, True Oil would conduct an exploratory drilling program in the Project Area to evaluate production potential of the Hilliard Shale. The True Lander Peak Project Area is defined by the Lander Peak federal unit and consists of approximately 4,736 acres. The Construction Phase of the Project includes reconstruction of reclaimed Well Pad 23- 15 and expansion of existing Well Pad 42-27. One well would be drilled on each well pad over a 2 to 3 year period (see Map 2.3-1). A water supply well would be drilled on existing Well Pad 13- 16a and a temporary surface water line would be installed between well pads 13-16a and 42-27, passing through Well Pad 23-15. The temporary water line would be installed during drilling of the two exploratory wells and would follow the existing reclaimed gas gathering line disturbance. Existing resource roads in the Project Area would provide access to the well pads and any additional natural gas gathering lines would be installed within the disturbance for the well pads. The natural gas gathering lines transport natural gas to an existing gas sales pipeline. All surface disturbance would occur during the Construction Phase which includes drilling and completion. The Construction Phase is described in detail below.
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Map 2.3-1 Proposed Action
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If drilling results in an unproductive well during the Construction Phase, the well would be plugged and abandoned in compliance with the Federal Onshore Oil and Gas Orders and the State of Wyoming regulations within 90 days of well completion, weather permitting. If a well produces economic quantities of natural gas, True Oil would produce (operate) the well for an estimated 20 years in the Operations Phase also known as long-term production. Production would occur generally between July 1 and September 30 of each year when project area is accessible. The two phases can occur simultaneously (i.e., some wells would be producing while a well might be in the process of drilling and/or completion). No additional surface disturbance would occur during the Operations Phase. Details regarding the Operations Phase are provided below.
All phases of the Proposed Action would be in accordance with the Project Design Features and Best Management Practices (BMPs) provided in True Oil’s SUPO, as revised by applicable COAs and well pad design revisions discussed below.
Based on discussions throughout the NEPA process and a site visit with the Forest Service in September of 2016, True Oil has made minor modifications to the Proposed Action which would reduce potential impacts to resources. The minor modifications to the Proposed Action area listed in Table 2.3-1.
Table 2.3-1 Modifications to True Oil’s Proposal Project Component 2015 Exploratory Proposal Proposed Action Units Lander Peak Unit- Proposed Lander Peak Unit – approved 2013 No new or upgraded roads – The last 300 feet of access to Well Pad 23-15, New/Reconstructed 200 feet of new road while present as a well-worn two track Road on the ground, is not a NFSR (not even one as closed). All gathering lines installed within well New Gathering Lines 200 feet of gathering line pad disturbances Initial disturbance approximately 3.32 Initial Disturbance approximately Well Pad 23-15 Initial acres – including stormwater BMPs – 2.89 acres – not accounting for and Long-Term long-term disturbance 1.43 acres after BMPs – long-term disturbance 2.5 Disturbance interim reclamation and including acres after interim reclamation stormwater BMPs Initial Disturbance approximately 2.18 Initial Disturbance approximately Well Pad 42-27 Initial acres – including stormwater BMPs – 1.21 acres – not accounting for and Long-Term long-term disturbance 1.31 acres after BMPs – long-term disturbance 2.5 Disturbance interim reclamation and including acres after interim reclamation stormwater BMPs Well Pad 23-15 reoriented to parallel Well Pad Orientation Standard existing road, Well Pad 42-27 reoriented to be further from creek. Addition of diversion ditches and Stormwater BMPs Minimal BMPs sediment traps Anticipate some trees may be Tree Removal No tree removal removed New water supply well on existing Municipal water would supplement Water Supply well pad 13-16a water from new well Secondary containment Earthen dikes Corrugated steel berms with liners Winter Access Winter access may be required No winter access
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The Proposed Action would comply with all applicable Federal Onshore Oil and Gas Orders and all other applicable permits and approvals. True Oil would be required to adhere to stipulations protecting sensitive resources that are included on federal leases (Table 2.3-1), unless an exception is granted, as well as any stipulations/requirements in the Forest Plan (Forest Service, 2015a), and COAs included in APD approvals. Where a stipulation is not adhered to, an exception to the stipulation would be required. Under the Proposed Action, Well Pad 42-27 proposed expansion is within 500 feet of South Fork Bare Creek and National Forest System Road (NFSR) 10046 which would require a stipulation exception for expansion of Well Pad 42- 27 within 500 feet of a road and the high waterline. True Oil would be required to obtain a variance from the Wyoming Oil and Gas Conservation Commission (WOGCC) groundwater sampling requirements because there are no existing water wells within 0.5 mile of the proposed natural gas wells, as defined by WOGCC (WOGCC Rules and Regulations, Chapter 1, Section 2(kkk) and Chapter 3, Section 46(d)).
Under the Proposed Action, True Oil would exercise the right to develop oil and gas resources under their existing federal leases. Table 2.3-2 lists the pertinent leases and provides a summary of the stipulations on each lease.
Table 2.3-2 Applicable Lease Stipulations by BLM Lease Number Location Stipulation BLM Lease Effective Well applies within Number Lease Date Pad T. 32 N., R. 115 W. Special Stipulation No occupancy of a strip of land 200 feet on each side of the centerline of the South WYW16419 01/01/1969 23-15H Sec. 15, S½NW¼ Cottonwood Road (important aesthetic values for public benefit). No surface disturbance until lessee or surface management Sec. 27 agency has conducted an archeological, paleontological, and historical inventory No Surface Occupancy within 500 feet of roads and highways, 200 feet of trails, 500 feet of high waterline, 400 feet of springs, 400 feet of any improvements either Sec. 27 owned, permitted, leased or WYW16420 01/01/1969 42-27 otherwise authorized. (Note: An exception from this stipulation would be obtained under the Proposed Action and Mitigation Alternative). No drilling, construction of roads or pipelines or other activities requiring removal of vegetation Sec. 27 until a plan of construction and development has been approved by the Forest Service representative.
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Location Stipulation BLM Lease Effective Well applies within Number Lease Date Pad T. 32 N., R. 115 W. Special Stipulation No occupancy of the surface of a strip of land 200 feet on each side Sec. 27, NE¼, W of the North Piney Creek Road W½SE¼ (important aesthetic values for public benefit). Wildlife Habitat Stipulation – Elk. Prior to entry onto the leasehold, the Operator will jointly discuss the proposed activities with the Area Oil and Gas Supervisor or his (their) representative, the Sec. 27 Forest Supervisor or his representative, and the Game and Fish Department. Additional measures may be required to protect elk calving, forage and migration. Unstable Soils Stipulation – Lands within the leasehold contain unstable/highly erodible soils. Therefore, prior to entry onto the lands, the lessee (operator) will discuss the proposed activities Sec. 27 jointly with the Area Oil and Gas Supervisor or his (their) representative, the Forest Supervisor or his (their) representative. Additional measures for the protection of soils may be required. 2.3.2.1 Construction Phase The Construction Phase includes well pad construction, drilling a water supply well, drilling and completing two natural gas production wells, and installing additional gathering lines within the well pad disturbance over a 2 to 3 year period. Table 2.3-3 provides a list of the two proposed wells, their federal lease numbers, and location within the Lander Peak Project Area.
Table 2.3-3 Surface Locations of Proposed Wells in the Lander Peak Area Surface Location Proposed Well Well Pad Lease T R Q S Klaenhammer 23-15H 23-15 WYW16419 32N 115W NESW 15 Klaenhammer 42-27H 42-27 WYW16420 32N 115W SENE 27
Surface Disturbance by Project Component Table 2.3-4 provides the acres of existing surface disturbance and proposed short-term and long-term disturbance associated with the Proposed Action.
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Table 2.3-4 Existing and Proposed Initial and Long-Term Surface Disturbance Associated with the Proposed Action Proposed Initial Total Pad Existing Pad Disturbance Disturbance Long-Term Well Pad Disturbance (acres) (acres) Disturbance 23-15 0.00 3.321 3.32 1.43 42-27 1.04 2.182 3.222 1.31 13-16a 1.74 0.00 1.74 0.00 Total 2.78 5.503 6.54 2.74 1 Approximately 2.08 acres have been previously disturbed and reclaimed. 2 Approximately 1.90 acres has been previously disturbed and reclaimed. 3 No additional disturbance is required for gathering line installation – gathering line disturbance would be within the proposed well pad disturbance.
Well Pads. Well Pad 23-15 would be reconstructed at the reclaimed Soda Unit 23-15 well pad. Total disturbance for this well pad would be 3.32 acres (see Table 2.3-4 and Map 2.3-2) of which 2.08 acres would be re-disturbance of the reclaimed Soda Unit 23-15 well pad. The existing Soda Unit 42-27 well pad would be expanded by 2.18 acres (see Table 2.3-4 and Map 2.3-3) of which 1.90 acres would be re-disturbance of the area reclaimed during interim reclamation of the Soda Unit 42-27 well pad.
Well pads would be reconstructed and expanded from the native soil and rock materials present in the Project Area using a bulldozer, grader, front-end loader, and/or backhoe. Vegetation would be cleared and stripped, and all available topsoil would be stockpiled. The well pads would be leveled using cut-and-fill techniques. The tops of cut banks and pad corners may be rounded to improve their appearance. Berms would be built around the well pads to prevent erosion and sediment transport.
Diversion ditches would be built around the well pads. The berms would be designed and constructed to channel surface water flow to one or more sediment collection traps and flows from the trap would discharge to a detention basin that would dissipate the flow of energy and prevent erosion (see Figures 2.3-1 through 2.3-4).
On September 14, 2016, the Forest Service and True Oil attended an on-site meeting to review the current status of the well pads and to review the proposed expansion of Well Pad 42-27 and reconstruction of Well Pad 23-15. The following revisions would be incorporated into each well pad design:
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Map 2.3-2 Well Pad 23-15 Proposed Disturbance Limits
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Map 2.3-3 Well Pad 42-27 Proposed Disturbance Limits
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Well Pad 23-15
• Reconstruction of Well Pad 23-15 would be designed to minimize disturbance but safely allow for drilling and completion. Interim reclamation would be designed to minimize the production well pad. The well pad would be rotated in a counterclockwise direction to be parallel with the existing road requiring 3.32 acres of new disturbance. After interim reclamation, approximately 1.43 acres would remain for long-term production of the well pad (see Map 2.3-2 and Figures 2.3-1 and 2.3-2).
• The production pad working area would be bermed so that there is no runoff toward South Cottonwood Creek. An outfall would be located to the south.
• The wellhead would have a protective structure around it.
• The area would be sprayed for weeds before construction begins (Canada Thistle observed on-site).
• Facilities would be painted dark green which is BLM “Beetle” or “Yuma” green from the Standard Environmental Colors Chart (whichever better matches the conifer background).
Well Pad 42-27
• Expansion of the well pad would be designed to minimize disturbance but safely allow for drilling and completion. Interim reclamation would be designed to minimize the size of the production well pad. The well pad would be rotated in a counterclockwise direction requiring 2.18 acres of new disturbance. After interim reclamation, approximately 1.31 acres would remain for long-term production of the well pad (see Map 2.3-3 and Figures 2.3-3 and 2.3-4).
• Two existing tanks currently located on the east side of the well pad towards South Fork Bare Creek would be relocated away from the creek and on the south side of the well pad. New tanks would also be placed in this location.
• Berms around the water and condensate tanks and methanol storage would be reworked with corrugated steel berms with liners.
• The production pad working area would be graded and bermed so that there is no runoff toward South Fork Bare Creek. An outfall would be located to the northwest along the pad access.
• The well pad expansion would not remove the vegetated hill on the south and southwest margins of the existing well pad to help protect South Fork Bare Creek.
• Wellheads would have protective structures around them.
• Facilities would be painted dark green which is BLM “Beetle” or “Yuma” green from the Standard Environmental Colors Chart (whichever better matches the conifer background).
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Figure 2.3-1 Well Pad 23-15 Stormwater BMPs for Initial Disturbance
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Figure 2.3-2 Well Pad 23-15 Stormwater BMPs for Long-Term Disturbance
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Figure 2.3-3 Well Pad 42-27 Stormwater BMPs for Initial Disturbance
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Figure 2.3-4 Well Pad 42-27 Stormwater BMPs for Long-Term Disturbance
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Roads and Gathering Lines. True Oil would use existing highways and county roads to access the Project Area. The Proposed Action does not require new access roads. Approximately 3.6 miles of the existing 13 miles of roads in the Project Area would be used for the Proposed Action. The existing roads would be maintained in conditions equal to conditions that existed prior to commencement of the exploration. Erosion controls on the existing roads would be maintained. True Oil does not plan to widen, compact, or crown any of the existing roads. All equipment and vehicles would be confined to existing roads. Water obtained from either the water supply well or from municipal sources would be used for dust suppression as necessary. Note that the last approximately 300 feet of access road to Well Pad 23-15 are beyond the mapped end of NFSR 10351. However, the road exists on the ground and no new construction would take place.
Maintenance of the access roads would continue until abandonment and reclamation of the well pads are completed. Access roads would be maintained to prevent erosion and sedimentation. All road work would comply with the Gold Book Standards for roads (BLM and Forest Service, 2007) as well as FP-03 Standard Specifications for Roads and Bridges (Federal Highway Administration, 2016). Heavily used road surfaces would be graveled and graded and borrow ditches would be sized to accommodate stormwater runoff according to Gold Book Standards. Erosion control measures (wattles, filter bags, or straw bales) would be placed in the ditches to dissipate runoff water velocity. Light duty roads would have water bars installed to prevent channeling and erosion.
The capacity of True Oil’s existing natural gas gathering system which delivers gas to the existing sales pipeline is sufficient to transport anticipated gas volumes from the two proposed wells to the sales pipeline (see Map 2.2-1). It would be necessary to construct additional gathering lines within the well pad disturbances. New gathering line connections would be pressure tested with fresh water. Water would be obtained from the water supply well drilled on Well Pad 13-16a and pumped to the well pads via a polyvinyl chloride (PVC) surface pipe. Hydrostatic testing of the gathering lines is expected to require a minimal amount of water due to the short distances of new gathering line. After testing, the water would be trucked off-site to R360 Environmental Solutions located at 1427 Calpet Road in LaBarge, Wyoming for disposal.
Well Drilling and Completion
Well construction includes several activities, starting with well drilling, casing, and testing (evaluation of drill cuttings, geophysical logging, and/or drill stem testing). If economic resources are identified, the wells would be completed by additional testing to ensure casing strength, casing perforation, and well stimulation (hydraulic fracturing). Drilling and completion would be conducted in compliance with all Federal Oil and Gas Onshore Orders, as well as all applicable rules and regulations.
Drilling. Drilling would target the gas producing zones in the Hilliard Shale Formation at approximate 7,400 feet true vertical depth. It is anticipated each well would contain a horizontal leg within the Hilliard Shale. The horizontal leg would extend northwest from the vertical leg and is anticipated to be 4,700 feet long in the Klaenhammer 23-15H well and 12,500 feet long in the Klaenhammer 42-27H well (see Map 2.3-1). Any usable water zones encountered during drilling would be adequately protected in accordance with the Federal Onshore Oil and Gas Orders and the 43 CFR § 3100 regulations by installing surface or intermediate casing as approved by the BLM Authorized Officer and reported. In addition, WOGCC rules require the surface casing to reach a depth below all known or reasonably estimated utilizable groundwater. All usable water
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zones, potentially productive hydrocarbon zones, and valuable mineral zones would be isolated by cementing the open space between the casing and the bedrock.
True Oil would use a closed-loop drilling system which eliminates the requirement for reserve pits. In a closed-loop system, the pit is replaced with a series of on-site storage tanks that separate liquids and solids. This equipment minimizes the amount of drilling waste muds and cuttings that require disposal and maximizes the amount of drilling fluids that are recycled and reused in the drilling process.
Drilling would be performed with circulation of an inert bentonite water-based mud, with various viscosity and density-adjusters such as polymers and barite. Density is adjusted to lift cuttings and suppress formation fluid pressure. Other additives may be used to stabilize borehole wall expansive clays. Drilling mud lubricates and cools the bit and flushes cuttings to settling tanks at the surface. Drilling mud would be displaced from the well bore in each separate casing setting and cementing event (surface, intermediate, and production casings).
Solids would be separated from the drilling fluid returns from the well, and the entire liquid volume would be re-used in the circulating system. Because the drill cuttings (the solids) would be dried after separation, no water or liquid phase would be discarded on location. Cuttings would be tested, in accordance with the requirements of the APD approvals, and buried on-site if testing results are within the specified criteria. The dried drill cuttings could be piled with spoil dirt, mixed with the spoil dirt during final reclamation, and covered with topsoil. The other option would be to place the dried drill cuttings in an approved cuttings pit on location and bury it when the drilling operations are completed. The pits (one on each well pad) would be approximately 30x30x10 feet and the cuttings would be hauled to the pit(s) using a loader. If buried on-site, it is not anticipated that soil would be imported to cover the cuttings. If testing shows the cuttings cannot be buried on-site, they would be disposed off-site at R360 Environmental Solutions located at 1427 Calpet Road in LaBarge, Wyoming.
Each well would be drilled, cased, cemented, and tested in stages. The BLM would be notified in advance of all testings. A 24-inch vertical hole would be drilled from the surface to about 60 feet below surface (fbs) to accommodate a 16-inch conductor casing. A 12-1/4-inch vertical hole would be drilled to accommodate the 9-5/8-inch surface casing, which would extend from the surface to a minimum depth of 10 percent of true vertical depth and/or 50 feet below freshwater aquifers within one mile. The surface casing would be cemented in place to isolate upper aquifers. Blowout Preventer Equipment (BOPE) would be welded to the top of the surface casing to contain unexpected fluid blowouts.
Once the surface casing is set, an 8-3/4 inch, directionally controlled pilot hole would be drilled from the base of surface casing to top of the Hilliard Shale core point, about 7,400 fbs. Directionally controlled means the location of the drill bit would be tracked and “steered” to the location wanted. The tools used to do this measure inclination, azimuth, and distance from a known starting spot (surveyed well collar). The shale would be cored from about 7,400 fbs to about 7,600 fbs to provide information for hydraulic fracturing. The pilot hole would be plugged back to about 6,800 fbs. An 8-3/4-inch, directionally drilled hole would be extended from about 6,800 to 7,700 fbs, and 7-inch intermediate casing would be set to protect usable quality water zones and any oil, gas, or prospectively valuable minerals deposits that may be encountered and to provide protection against abnormal pressure zones and lost circulation zones.
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A 6-1/8-inch, essentially horizontal, hole would be drilled to the designated end point of the well. The hole would be logged while drilling to determine if adequate hydrocarbon reserves are recoverable. If production is considered possible, a 4-1/2-inch liner would be set from about 200 feet within the 7" casing to the end point of the well. The liner would be constructed to allow for hydraulic fracturing.
Rig wash and other miscellaneous water used on location during drilling would be collected and re-directed into the water storage tank for re-use in the drilling fluid. At the end of the drilling operation, the remaining volume of water at the surface would be trucked off-site for disposal at R360 Environmental Solutions located at 1427 Calpet Road in LaBarge, Wyoming.
Well Completion. After production casing has been cemented in place and the drilling rig has been moved off the location, the location would be bladed flat and graveled as necessary. Anchors would be set. Well completion would consist of running a cement bond log to evaluate cement integrity and correlate the cased hole logs to the open hole logs. The casing would then be perforated across the hydrocarbon producing zones and the formation would be stimulated to enhance the production of oil and gas. The typical method used for stimulation consists of a hydraulic fracture treatment in which sand and non-toxic fluids are pumped into the producing formation with sufficient pressure to fracture the rock formation (see Table 2.3-5 for list of typical constituents used in hydraulic fracturing). The final material list would not be decided until the contract for the hydraulic fracturing is finalized. At that time, the list would be made available to the WOGCC (Chapter 3, Section 45(d) and subsequently to the public, with the exception of any material determined to be proprietary per Chapter 3 Section 45(f) and associated Guidelines). Sand serves as a proppant to keep the created fracture open, thereby allowing reservoir fluids to move more efficiently into the well bore. Water for use in hydraulic fracturing treatments would be pumped from the water well on Well Pad 13-16a and also delivered by truck. The water would be stored in a Poseidon tank on the well pad and in the hydraulic fracture tanks on the well pad.
Table 2.3-5 Constituents of Typical Hydraulic Fracturing Operation 1 Common Use of Additive Type Typical Example % by volume Function Example Compound Dissolves mineral Swimming pool Acid Hydrochloric acid 0.123 cement in rocks and chemical and cleaner initiates cracks Eliminates bacteria in Disinfectant; sterilizer the water that produce Biocide Glutaraldehyde 0.001 for medical and dental corrosive or poisonous equipment by-products Used in hair dye, as a Ammonium Allows delayed disinfectant, and Breaker 0.010 persulfate breakdown of the gel manufacture of household plastics Creates a brine carrier Used in low-sodium Potassium fluid that prohibits fluid table salt substitutes, Clay stabilizer 0.060 chloride interaction with medicines, and IV formation clays fluids Used as preservative Corrosion Prevents corrosion of in livestock feed; used Formic acid 0.002 inhibitor the well casing as lime remover in toilet bowl cleaners Crosslinker Borate salts 0.007 Maintains fluid viscosity Used in laundry
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Common Use of Additive Type Typical Example % by volume Function Example Compound as temperature detergents, hand increases soaps, and cosmetics Used as a flocculent in Friction “Slicks” the water to Polyacrylamide 0.088 water treatment and reducer minimize friction manufacture of paper Thickens water to help Used as a thickener, Gelling agent Guar gum 0.056 suspend the sand binder, or stabilizer in propping agent foods Used as flavoring Prevents precipitation of Iron control Citric acid 0.004 agent or preservative metal oxides in foods Used in soaps, Increases the viscosity Surfactant Lauryl sulfate 0.085 shampoos, detergents, of the fluid and as foaming agents Sodium hydroxide Adjusts pH of fluid to used in soaps, drain Sodium pH adjusting maintain the cleaners; acetic acid hydroxide, acetic 0.011 agent effectiveness of other used as chemical acid components reagent, main ingredient of vinegar Used in dishwashing Sodium Prevents scale deposits Scale inhibitor 0.043 liquids and other polycarboxylate in the pipe cleaners Ethanol, Added as necessary as Various cosmetic, Winterizing isopropyl alcohol, -- stabilizer, drier, and anti- medicinal, and agent methanol freezing agent industrial uses Total Additives 0.049 % Total Water 99.51 % and Sand 1 Source: Forest Service, 2016a.
Hydraulic fracturing would be scheduled no sooner than 2 weeks after the liner is run to allow enough time for the swell packers to swell and seal. A crew would move in and rig up on the well. A multi-stage hydraulic fracturing treatment utilizing up to 65,000 barrels of water, 480,000 pounds 100 mesh sand, 2,080,000 pounds 30/50 mesh sand, and 320,000 pounds 20/40 resin coated sand would be pumped into the lateral section in the Hilliard Shale. Completion fluids are custom-engineered to accomplish various objectives, including:
• Pressuring the formation through perforations in the production casing to fracture the rock, and propagate those fractures some distance into the formation; • Carrying proppant particulates, sand, ceramic or plastic (to prop fractures open when the pressure is released), and small rubber balls to block perforations and hold injected fluids outside the casing for a short time; and • Carrying other chemicals to “break” the gel suspending the proppant, disinfect the hydraulically fractured zone and retard microbial growth which can sour the well, and flush general residual chemicals.
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Most constituents are either consumed in the treatment (acid, pH buffers), inert (sand), or biodegradable. Biocide retards microbes that would otherwise grow rapidly in the guar starch, until such time as the fluid can be produced in flowback water or displaced and plugged in a well that is abandoned. Similar to the drilling fluids, all hydraulic fracturing fluids are fully contained in the closed-loop system (pitless).
The well would be flowed back into tanks to allow the well to unload hydraulic fracturing load fluid. Once the well is completed, the well would be opened up to flow through a test separator while recording the amount of load water recovered as well as any oil, gas, and formation water. All wells would be completed using “green completions” which means the natural gas at the wellhead would be captured immediately after well completion rather than being flared or released to the atmosphere. The volume of load water recovered after the hydraulic fracturing treatment would not be known in advance. Typically, for this type of formation, up to 30 percent of the hydraulic fracturing water may be recovered. The water would be trucked off-site for disposal at R360 Environmental Solutions located at 1427 Calpet Road in LaBarge, Wyoming. The pumping equipment would be installed if needed and the production equipment and flow lines would be installed. The well would then be placed in production.
Once the pumping operation is completed, the hydraulic fracturing equipment would be rigged down and moved off location. Subsequent to drilling and completion of each well, the well would be shut in under pressure, and that pressure would be monitored to assess formation pressures and the possibility of leaks, prior to final development. Completion of a single well is expected to take approximately 20 days. Hydraulic fracturing is part of the completion process and is expected to take between 3 and 5 days of the 20 days.
Water Requirements and Water Supply
During the Construction Phase, water would be required for drilling, completion, and dust control (see Table 2.3-6). A small amount of water may be required for hydrostatic testing of new gathering lines installed within the well pad disturbances but the amount is negligible compared to water requirements for other activities.
Table 2.3-6 Water Requirements during the Construction Phase1 Water Volume Water Volume Water Volume Activity (gallons) (barrels) (acre-feet) Drilling – Water Supply Well 2,100 50 0.01 Drilling – Natural Gas Well 109,200 2,600 0.34 Completion 2,730,000 65,000 8.38 Dust Control2 4,737,600 112,800 14.54 Total 7,578,900 180,450 23.27 1 Estimates based on construction for the first year for a single well. Second year estimates would not include drilling a water supply well. 2 Based on the expectation that 80 barrels of water per mile would be applied to approximately 30 miles of unpaved roads every other day (for 47 days out of the 94- day construction period).
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Approximately 50 barrels (2,100 gallons) of water would be required to drill the water supply well, depending on drilling method and quantity of groundwater encountered during drilling. For example, if the well were drilled with air, much less water would be needed. The initial drilling fluid system requirement for a single well natural gas well is estimated to be approximately 1,600 barrels, increasing to 2,600 barrels as the well is drilled. Use of the closed-loop drilling fluid system would eliminate the need for a reserve pit which would minimize the volume of water required for drilling. Water for well completion (including hydraulic fracturing) of a single well is estimated to be 65,000 barrels (2.73 million gallons).
Water for dust control may be necessary on unpaved surfaces without gravel. It would be implemented on an as-needed basis. The volume of water required for dust control would depend on annual weather fluctuations, but could include up to 112,800 barrels (4.7 million gallons) per year during the Construction Phase.
It is anticipated that the proposed water supply well on existing Well Pad 13-16a could supply up to 16,666 barrels (700,000 gallons) of water on an annual basis; however, water requirements on an annual basis during the Construction Phase could be up to 180,400 barrels (7.6 million gallons) depending on water requirements for dust control. Additional water would be obtained from municipal sources. If any existing water wells in the municipal sources are used as part of the water supply, a temporary water use agreement would also be filed with the Wyoming State Engineers Office (WSEO).
The water supply well has been permitted by the WSEO for a depth of 200 feet, with a production interval from 30 to 200 feet below surface. The location is on the existing Well Pad 13-16a, as shown on Map 2.3-1, and a copy of the WSEO permit is included in Attachment B. The well would be drilled with a truck-mounted rig, and is anticipated to take about 1 week to drill and complete. Drilling would be done using a closed-loop drilling system and cuttings would be hauled off-site for disposal. The well would be cased with either steel or PVC and gravel packed through the production interval. The upper portion of the hole would be cemented to prevent leakage of surface water along the casing, and access to the well would be restricted. In accordance with the WSEO permit, the well would be equipped with a flow meter and backflow preventer.
From the water well on Well Pad 13-16a, water would be pumped to locations through a 3.48- mile temporary PVC pipe that would be laid on the surface, in the borrow ditches of existing roads or within reclaimed disturbances for gathering lines (see Map 2.3-1). The temporary water line would be inspected visually for leaks on a daily basis. Water would be stored on the well pad in tanks. Water from municipal sources would be delivered to the location in 80-barrel transport trucks to supplement water from the water supply well. All water would be stored on the well pad in temporary holding tanks.
Workforce
The Proposed Action is expected to have a construction workforce of approximately 107 workers as well pads and gathering lines are constructed and wells are drilled and completed. Table 2.3-7 shows the peak number of workers estimated for each construction activity. Major construction activities occur sequentially and the entire construction workforce would not be present in the Project Area at the same time. The number of workers present in the Project Area at any given time would peak at 73 workers during well completion (56 completion workers, 16 water truck drivers, and 1 dust control truck driver). True Oil expects that all construction workers would come from Sublette and Sweetwater counties.
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Table 2.3-7 Construction Workforce Number of Workforce Category Days Workers Well Pad Construction 3 - 51 42 Road/Gathering Line Construction 1 - 21 73 Well Drilling 544 215 Well Completion 204 566 Water Supply Truck Drivers - Completions 204 167 Interim Reclamation 2 – 31 21 Dust Control 80 – 84 1 Total 80 – 84 107 Assumptions: 1 Estimate based on industry averages. 2 Assumes that one 3 to 4 man crew would work 3 to 5 days expanding Well Pad 42-27 and 3 to 5 days reconstructing reclaimed Well Pad 23-15. 3 Assumes that one two-man crew would construct gathering lines within the well pad disturbances. 4 True Oil, 2015. 5 Estimated drilling workforce for one drill rig includes drilling contractor (2 7-man crews with 1 supervisor and six workers), 1 wellside consultant, 1 mudlogger, 1 mud engineer, 1 solids control, 1 directional driller, 1 mwd, 1 active system aeration. Drilling crews would work 24 hours/day. 6 Estimated completion workforce includes one completion crew with a peak of 50 workers during hydraulic fracturing (working during daylight hours), and 6 drivers hauling recovered completion water to an off-site disposal facility. 7 Based on estimated water requirements for well completions.
Traffic
Peak Project-related traffic would occur during the Construction Phase as well pads are constructed, drill rigs are mobilized and demobilized, and wells are drilled and completed. Table 2.3-8 shows the peak number of vehicles estimated during the Construction Phase. Well pad reconstruction and expansion, rig mobilization, drilling, rig demobilization, well completion, and interim reclamation would occur sequentially, and the number of vehicles required for these activities would not overlap with one another. Rig mobilization/demobilization and well completions are expected to have the highest vehicle requirements. Traffic during approximately 5 days of drill rig mobilization and 5 days of rig demobilization would include up to 42 vehicles per day. Traffic during drilling would include approximately 11 vehicles per day for 54 days. Traffic during well completions is estimated to include up to 12 light vehicle round trips and 48 heavy vehicle round trips per day for 20 days. These peak vehicle estimates assume that drilling and completion workers carpool and that dust suppression and daily deliveries are being conducted.
The estimated duration of construction traffic shown in Table 2.3-8 exceeds the estimated construction workforce schedule shown in Table 2.3-7 by 10 days. This is due to the 10 days of traffic associated with rig mobilization and demobilization.
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Table 2.3-8 Estimated Peak Traffic Requirements during the Construction Phase1 Light-Vehicle Heavy-Vehicle Total Vehicle Round Round Round Activity Days Trips/Day Trips/Day Trips/Day Well Pad Construction 3 – 52 22 12 3 Road/Gathering Line Construction 1 - 22 22 22 4 Rig Mobilization 52 102 302 40 Well Drilling 54 63 32 9 Rig Demobilization 52 102 302 40 Well Completion 20 113 34 14 Water Disposal – Completion 20 0 125 12 Water Delivery – Completion 20 0 326 32 Interim Reclamation 2 – 3 0 12 1 Deliveries 90 – 94 12 0 1 Dust Control 90 – 94 0 12 1 Assumptions: 1 Numbers provided are for the first year of construction and assumes one production well is drilled and completed. Major construction activities occur sequentially rather than concurrently, and vehicle estimates for most construction activities are not additive. Well completions and water deliveries would occur concurrently. Deliveries and dust control would be conducted during other construction activities. 2 Assumption based on industry averages. 3 Assumes that drilling and completion workers carpool with four workers per light vehicle. 4 Estimated heavy vehicles include three miscellaneous trucks per day transporting two completion workers per vehicle. 5 Estimates six water disposal trucks making two round-trips per day. Approximately 65,000 barrels of water would be required per completion (True Oil, 2015). Estimated water disposal trucks are based on 30 percent of completion water being recovered (flowback) and hauled for off-site disposal (65,000 barrels of water @ 30 percent recovery rate = 19,500 barrels/80 barrel trucks = 244 total truck trips/ 20 completion days = 12 flowback water disposal truck trips per day). 6 Estimates 16 water supply trucks making two round-trips per day. Assumes 50,934 barrels are delivered over 20 days in 80 barrel trucks. 2.3.2.2 Operations Phase The Operations Phase includes long-term production and maintenance of producing wells. Surface facilities at each well pad would consist of wellheads, production units, heater/treaters, meters, dehydration units. Volumes of oil (or condensate) and water produced with the natural gas are unknown. Produced water and condensate would be stored in aboveground storage tanks. It is estimated that each pad would have up to four 400-barrel tanks. Existing Well Pad 42-27 currently has two 400-barrel production tanks which would be moved to the south side of the well pad. Production equipment would be shared to the greatest extent possible, reducing wellhead fugitive emissions.
A pumper in a pickup truck would visit the well pads on a daily basis during the summer months and early fall. When the roads can no longer be accessed due to weather, the producing wells would be shut-in until the next season. Access roads would be maintained in accordance with Gold Book Standards for roads (BLM and Forest Service, 2007) as well as FP-03 Standard Specifications for Roads and Bridges (Federal Highway Administration, 2016) to prevent soil erosion.
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Tank batteries would be placed within secondary containment to prevent off-site migration of accidentally spilled produced water and condensate. Secondary containment would be designed to hold 110 percent of the volume of the single largest tank in the contained area with sufficient free board to contain anticipated precipitation. Heater/treaters would be located within a metal building that is surrounded by secondary containment and glycol storage tanks would also have adequate secondary containment. Secondary containment would consist of corrugated steel berms with liners to prevent movement of fluids. All loading lines would be placed inside the containment liner. True Oil would continue to follow the Spill Prevention Control and Countermeasure (SPCC) Plans that have been prepared for each well pad.
Periodically, the workover or recompletion of a well may be required to ensure that efficient production is maintained. Workovers can include repairs to the well bore equipment (casing, tubing, rods, or pump), the wellhead, or the production facilities. These repairs would usually be completed during daylight hours.
Water Requirements and Water Supply
During the Operations Phase, dust suppression could be necessary on unpaved roads without a gravel surface but is unlikely due to the low traffic volume. Dust suppression would be implemented on an as-needed basis.
Natural Gas and Condensate Production
Natural gas and some condensate (oil) would be produced and separated at the wellhead on individual well pads. Natural gas would be directed to the gathering system which feeds directly to the existing gas sales pipeline. Condensate would be stored in on-site tanks located on the production well pad. Condensate would be picked up in tanker trucks and hauled off-site to markets. Existing wells in the Lander Peak Unit produce very little condensate and it is usually picked up by truck only once in early fall as the production facilities are winterized. Existing production is from the Frontier Formation. The amount of condensate production from the Hilliard Shale Formation is not known at this time and could be either less or greater than that from the Frontier Formation.
Produced Water Disposal
Water would be produced with the natural gas and condensate and would be stored on-site in steel tanks on the production well location. Produced water would be trucked to R360 Environmental Solutions located at 1427 Calpet Road in LaBarge, Wyoming. Water production is also very low from the existing Frontier Formation wells. Water production from the Hilliard Shale Formation is not known at this time and could be either less or greater than that from the Frontier Formation.
Workforce
Once both wells are drilled and completed, the operations workforce would include approximately four workers, including a pumper, maintenance worker, and two truck drivers (see Table 2.3-9). True Oil expects that all long-term production workers would come from Sublette and Sweetwater counties.
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Table 2.3-9 Workforce during the Operations Phase Number of Workforce Category Days Workers Pumper Daily 1 Maintenance 5 days/year 1 Truck Drivers 15 days/year 21 Total 4 Assumptions: 1 Includes one driver to haul condensate from storage tanks to sales and one driver to haul produced water to R360 Environmental Solutions, an approved off-site disposal facility in LaBarge, Wyoming.
Traffic
Traffic during the Operations Phase would include one pumper truck, one maintenance truck, one truck hauling produced water to an approved disposal facility, and another truck transporting condensate to markets (see Table 2.3-10). Pumper traffic would occur daily and maintenance traffic would occur 5 days per year per well. Based on anticipated levels of condensate and water production, condensate and produced water truck traffic would occur approximately 1 day per month. As practical, oil condensate and produced water transport would be scheduled for different days of the week.
Table 2.3-10 Estimated Traffic Requirements during the Operations Phase1 Light-Vehicle Heavy-Vehicle Total Activity Round Trips/Day Round Trips/Day Round Trips/Day Pumper 1 0 1 Maintenance1 1 0 1 Produced Water Truck2 0 1 1 Condensate Truck3 0 1 1 Total 2 2 4 Assumptions: 1 Maintenance traffic would occur for approximately 5 days per year per well. 2 A truck would visit each producing well 1 day per month to haul produced water to R360 Environmental Solutions in LaBarge, Wyoming. 3 A truck would visit each producing well 1 day per month to haul condensate off-site for sale. 2.3.2.3 Site-Specific Resource Surveys Land surveys were conducted by Uintah Engineering and Land Surveying for the reconstruction of Well Pad 23-15 and the expansion of Well Pad 42-27. The Proposed Action is within areas that have been previously surveyed for cultural resources. Hayden-Wing Associates, LLC (Hayden-Wing) conducted surveys for the Project Area in August and September, 2011, which included: northern goshawk surveys, raptor nest surveys, three-toed woodpecker surveys, Canada lynx foraging habitat surveys, amphibian surveys, an R1/R4 Fish and Fish Habitat Assessment, special status plant and invasive weed surveys, beaver dam locations, and wetland surveys. These biological surveys were planned in coordination with Forest Service representatives.
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2.3.2.4 Abandonment and Reclamation Interim Reclamation. After well completion for the two wells, True Oil would reduce the size of the well pads (23-15 and 42-27) to approximately 1.43 acres and 1.31 acres, respectively. Any areas unnecessary for operations would be reshaped to blend with natural topography to the extent possible. Interim reclamation would be accomplished by grading, leveling, spreading topsoil, and seeding, as recommended by the Forest Service. Interim reclamation would reduce the disturbed area to a size that would allow production operations to continue in a safe environment. If interim re-vegetation is unsuccessful, additional preparation and reseeding would be completed annually until standards are met. Requirements for reseeding of unsuccessful temporary seeding would be considered on a case-by-case basis.
Interim reclamation work would include: • Removing all debris, materials, and trash unnecessary to production operations. • Removing the temporary surface water line. • Reshaping of all areas unnecessary to operation to blend with natural topography to the extent possible. • Reseeding with seed mixes and techniques specified by the Forest Service.
Well Plugging and Abandonment. Dry/non-producing wells would be plugged and abandoned. A Sundry Notice would be submitted to the BLM that describes the engineering, technical, and/or environmental aspects of final plugging and abandonment.
The Sundry Notice would describe final reclamation procedures and any mitigation measures associated with the final reclamation. The pads would be reclaimed (regraded and reseeded) to pre-exploratory construction contours as quickly as possible, leaving the well pad equipment and disturbance in place that was present prior to exploration.
BLM and WOGCC standards for plugging would be followed. A configuration diagram, a summary of plugging procedures, and a job summary with techniques used to plug the wellbore (e.g., cementation) would be included in the Sundry Notice.
If not transferred to the Forest Service or other entity for continued use, the water supply well would be plugged and abandoned in accordance with the WSEO permit requirements.
Final Reclamation. When the last well on an existing well pad is abandoned, reclamation is considered to be final. Final reclamation work would include:
• All equipment, facilities, and trash would be removed from the location. • Each borehole would be plugged, capped, and its related surface equipment removed. • Subsurface lines would be purged and capped at specific intervals.
After the well is plugged and abandoned, the site would be reclaimed as soon as possible. Earthwork and seeding would be completed within one year from the date of plugging and abandonment, weather permitting. 2.3.2.5 Schedule It is estimated that the Construction Phase would begin once approvals are obtain and would begin after July 1 and continue through approximately September 30. The two exploratory wells would be drilled and completed over a 2- to 3-year period with one drilling rig. The construction period (including drilling and completion) for each well is expected to last between 80 and 84
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days (see Table 2.3-7). An additional 10 days would be required for drill rig mobilization (set-up for 5 days) and demobilization (take-down for 5 days). Operations (long-term production) would occur in the summer months once the Project Area can be accessed and would continue into fall when the wells are shut-in due to limited or no access to the Project Area. The wells are expected to be in production for approximately 20 years. 2.3.2.6 Project Design Features (Applicant-Committed Measures to Protect Resources) The following Project Design Features are applicant-committed measures included in True Oil’s SUPO for the Lander Peak Exploratory Project or otherwise agreed to. They are specifically intended to reduce potential damage to existing infrastructure and the natural environment.
Air Quality
• Tier 2 compliant drilling rig engines would be used to minimize emissions. The Tier 2 engines have a 68 percent reduction in nitrogen dioxide (NOx) emissions over Tier 0 engines.
• Drilling and completion crews would carpool to reduce traffic and vehicle emissions.
• Production equipment would be shared to the greatest extent possible, reducing wellhead fugitive emissions.
• Water would be used for dust suppression on well pads and roads as necessary to reduce fugitive dust emissions.
• All wells would be completed using “green completions” which means the natural gas at the wellhead would be captured immediately after well completion rather than being flared or released to the atmosphere.
Stormwater Control
• True Oil has applied for coverage under the Wyoming Pollutant Discharge Elimination System (WYPDES) Authorization to Discharge Storm Water Associated with Small Construction Activity under the National Pollutant Discharge Elimination System. The general WYPDES permit WYR10-A000 became effective July 8, 2013. True Oil has prepared a Storm Water Pollution Prevention Plan (SWPPP) in compliance with the terms of this permit. BMPs, as required by the permit and the SWPPP, would be in place before, during, and after construction until the location has reached final stabilization. All other requirements of the permit would be followed such as inspection and reporting requirements.
• All disturbed areas would be revegetated as soon as possible after disturbance.
• Diversion ditches would be built around the well pads to prevent sediment loss. The berms would be designed and constructed to channel surface water flow to one or more sediment collection traps and flows from the trap would discharge to a detention basin that would dissipate the flow of energy and prevent erosion.
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Weed Control
• Straw, wattles, or anything vegetative used to slow water or used to protect the soil would be certified weed-free. Any seeds used for planting and erosion control would be from a certified weed-free native seed mix approved by the Forest Service. Wattles would be made of aspen.
Access and Traffic
• All equipment and vehicles would be confined to existing roads.
• All road work would comply with the Gold Book Standards for roads (BLM and Forest Service, 2007) as well as FP-03 Standard Specifications for Roads and Bridges (Federal Highway Administration, 2016).
Drilling and Completion
• True Oil would use a closed-loop drilling system which eliminates the requirement for reserve pits.
• All usable water zones, potentially productive hydrocarbon zones, and valuable mineral zones would be isolated by cementing the open space between the casing and the bedrock.
• Blowout Preventer Equipment would be welded to the top of the surface casing to contain unexpected fluid blowouts.
Production
• Tank batteries would be placed within secondary containment to prevent off-site migration of accidentally spilled produced water and condensate. Secondary containment would hold 110 percent of the volume of the single largest tank in the contained area with sufficient free board to contain anticipated precipitation. Heater/treaters would be located within a metal building that is surrounded by secondary containment and glycol storage tanks (used for three phase separation) would also have adequate secondary containment. All secondary containment would consist of corrugated steel berms with liners to prevent movement of fluids. All loading lines would be placed inside the secondary containment.
Reclamation
• Interim reclamation of the well pads (23-15 and 42-27) would reduce the size of the well pad to approximately 1.43 acres and 1.31 acres, respectively. Interim reclamation would occur immediately after well completion, if weather allows, or during the following growing season.
• After the last well on a well pad is plugged and abandoned, final reclamation earthwork and seeding would be completed within one year from the date of plugging and abandonment, weather permitting. Reclamation would be confirmed to be effective before True Oil would be released from their obligations.
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Spill Control
• True Oil would continue to follow the SPCC Plans that have been prepared for each well pad.
Safety
• True Oil would submit both the Drilling Contractor’s safety plan as well as True Oil’s safety plan to the Forest Service for approval. The safety plans would be implemented to protect employees, contractors, and the public during construction, production, maintenance, and reclamation.
Visual
• Facilities would be painted dark green which is BLM “Beetle” or “Yuma” green from the Standard Environmental Colors Chart (whichever better matches the conifer background).
• Night-lighting during drilling would be Forest Service-approved. 2.3.2.7 Monitoring True Oil would implement the following monitoring during construction and operations.
• Erosion and channel formation would be monitored during construction and after large rainfall or snowmelt runoff events during operations.
2.3.3 Mitigation Alternative This alternative was developed in response to public and agency inputs collected during the scoping process and in response to updated site-specific information in order to potentially reduce the environmental impacts of the Project. This alternative is similar to the Proposed Action; however, additional protective (mitigation) measures would be implemented to reduce the potential environmental consequences of the Proposed Action. Under this alternative, the water supply well would not be drilled and the temporary water line would not be installed. This Mitigation Alternative also includes requirements for monitoring. 2.3.3.1 Protection Measures The following are additional measures that would be implemented under the Mitigation Alternative in addition to the Project Design Features included in True Oil’s proposal:
Geology
To ensure that hydrologic fracturing does not result in unanticipated changes in the subsurface, the following measures are included in this alternative:
• An evaluation of the orientation of the proposed drill holes relative to the Prospect Thrust Fault and the potential for fluid movement along the fault would be conducted and submitted to the BLM prior to well construction.
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• An appropriate tracer would be used during hydraulic fracturing to affirm casing integrity and identify any unanticipated fracture paths.
• True Oil would participate in FracFocus, which is a national hydraulic fracturing chemical registry managed by the Ground Water Protection Council and Interstate Oil and Gas Compact Commission; two organizations concerned with conservation and environmental protection. The primary purpose of the registry is to provide information concerning hydraulic fracturing and groundwater protection (FracFocus, 2014).
Water Resources
• All chemicals, solvents, and fuels (at least 5 gallons) would be kept at least 150 feet away from streams and riparian areas, and on impermeable surfaces.
• All refueling would occur at least 150 feet away from streams and riparian areas.
• True Oil would update their SPCC Plan to be consistent with the redesign of the proposed well pads based on the September 2016 onsite visit.
Stormwater Control
• True Oil would update their SWPPP to be consistent with the redesign of the proposed well pads based on the September 2016 onsite visit.
Invasive, Non-Native Species
• True Oil would educate all Project personnel regarding environmental concerns and requirements, including weed identification, prevention, and control methods.
• All vehicles and equipment that would be utilized during construction and/or reclamation and abandonment would be cleaned prior to entering and upon departure from the Project Area to prevent the spread of seeds and propagules (cleaning location determined by Forest Service and True Oil).
• If weeds are located prior to disturbance, they would be treated prior to ground disturbance.
• All gravel, road base, or other delivered soil products would be certified weed-free.
• True Oil would implement the Forest Service (2004) weed management plan, which includes pre-disturbance surveys, methods for prevention and control, monitoring, reclamation, and treatment.
• Straw or wattles or anything vegetative used to slow water or used to protect the soil would be “certified weed-free” and “certified cheatgrass-free”. Any seeds used for planting and erosion control would be from a “certified weed-free” and “certified cheatgrass-free” native seed mix.
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• Upon completion of drilling described in this EA and as a function of interim reclamation and upon final reclamation, areas designated to be reclaimed would be fenced with fencing sufficient to preclude cattle grazing and recreational use by the public to ensure substantial and sustainable reclamation and prevention of invasive plant infestation and proliferation. Fencing would be maintained by True Oil until such time as deemed unnecessary by the Authorized Officer and then True Oil would removing fencing. All fencing would comply with appropriate wildlife protection features as defined by the designated Authorized Officer.
Wildlife and Migratory Birds
• Trash and garbage would be placed in appropriate caged containers and the container and contents transported to an approved disposal facility. All containers would be equipped with bear-resistant openings.
• If vegetation clearing occurs between May 15 and July 15, a survey would be required to minimize disruptions to migratory birds during the nesting season, unless deemed unnecessary by the Authorized Officer.
• A policy stating that no guns, dogs, drugs, or alcohol would be in place for all employees and subcontractors to minimize potential conflicts with wildlife.
• Environmental awareness training would be provided describing the consequences of poaching and information on Wyoming wildlife laws, licensing, and residency requirements.
• Raptor surveys would be conducted if surface disturbance is planned prior to August 15 to determine nesting activity, unless deemed unnecessary by the Authorized Officer. If future surveys indicate nests, then appropriate protections would be applied (see Table 2.3-11).
Fire and Fuels
• A fire management plan would be prepared and implemented which addresses employee fire safety education to assist personnel in preventing and containing Project- related accidental ignitions.
Transportation
• Speed limits would be enforced from the beginning of construction throughout the life of the Project to minimize collisions with wildlife. Posted speed limits would be followed. Where there is no posted speed limit, speeds on unpaved accessed roads and disturbed areas would not exceed levels considered safe for the conditions and would be slow enough to prevent collisions with wildlife and livestock.
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Table 2.3-11 Recommended Spatial and Seasonal Buffers for Breeding Raptors 1 Common Name Spatial buffer Scientific Name (miles) Seasonal buffer Golden Eagle 0.5 January 15 - July 31 Aquila chrysaetos Ferruginous Hawk 1.0 March 15 - July 31 Buteo regalis Swainson's Hawk 0.25 April 1 - August 31 Buteo swainsonii Bald Eagle 0.5 January 1 - August 15 Haliaeetus leucocephalus Prairie Falcon 0.5 March 1 - August 15 Falco mexicanus Peregrine Falcon 0.5 March 1 - August 15 Falco peregrinus Short-eared Owl 0.25 March15- August 1 Asio flammeus Burrowing Owl 0.25 April 1 – September 15 Athene cunicularia Northern Goshawk 0.5 April 1 - August 15 Accipiter gentilis Osprey 0.25 April 1 - August 31 Pandion haliaetus Cooper's Hawk 0.25 March 15 – August 31 Accipiter cooperii Sharp-shinned Hawk 0.25 March 15 – August 31 Accipiter striatus Red-tailed Hawk 0.25 February 1 – August 15 Buteo jamaicensis Northern Harrier 0.25 April 1 - August 15 Circus cyaneus Merlin 0.5 April 1 - August 15 Falco columbarius American Kestrel 0.125 April 1 – August 15 Falco sparverius Common Barn Owl 0.125 February 1 – September 15 Tyto alba Northern Saw-whet Owl 0.25 March 1 - August 31 Aegolius acadicus Boreal Owl 0.25 February 1 – July 31 Aegolius funereus Long-eared Owl 0.25 February 1 – August 15 Asio otus Great Horned Owl 0.125 December 1 – September 31 Bubo virginianus Northern Pygmy-Owl 0.25 April 1 – August 1 Glaucidium gnoma Eastern Screech-owl 0.125 March 1 – August 15 Megascops asio Western Screech-owl 0.125 March 1 – August 15 Megascops kennicottii Great Gray Owl 0.25 March 15 – August 31 Strix nebulosi 1 Source: FWS, 2016a.
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Visual
• Lighting during construction would follow “dark-sky” lighting practices. Such practices are designed to reduce the effects of artificial light on the natural environment, including sky glow, glare, light trespass, light clutter, and decreased visibility at night (International Dark-Sky Association – IDA, 2014). “Dark-sky” lighting practices implemented in the Project Area would include, but not be limited to the following:
o using low glare lighting equipment; o shielding security lighting so that the majority of light hits the target and does not cause glare; o targeting lower lighting levels and better uniformity for safety and security lighting; o to the extent practical, aiming lighting on facilities from the top down, and away from adjacent areas; and
• Upon completion of drilling activities and as a function of interim reclamation, a vegetative visual screening or buffer would be planted between the adjacent primary roads and well pads 13-16a and 42-27. Tree sizes would be evenly distributed between the sizes of 2 foot to 8 foot. Trees would be transplanted from nearby areas as designated by the forest timber program. Trees would be acquired via the Forest Service commercial tree purchase process so as to plant trees most acclimated to the area. Trees would be transplanted according to industry best planting practices which includes season of transplant and method of transplanting. Number of trees should range between twenty and fifty trees per well pad based on input from the Forest Visual Resource Specialist and as decided by the Authorized Officer.
Range Management
• Damage to existing range improvements would be avoided and if damage occurs, it would be repaired immediately.
Cultural and Paleontological Resources
• If cultural or paleontological materials are uncovered during construction, the operator will immediately stop any work which would affect such materials and contact the Authorized Officer. The Authorized Officer will determine what mitigation may be necessary before construction continues. 2.3.3.2 Monitoring Geology
To ensure that the hydrologic fracturing does not result in unanticipated changes in the subsurface, monitoring would be conducted as follows:
• A seismic/microseismic monitoring program would be implemented before, during, and after hydraulic fracturing. Monitoring locations would be selected to coincide with existing disturbances. The monitoring program would be reviewed and approved by the BLM and results would be submitted to the BLM once construction of the well is complete.
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• During hydraulic fracturing, pressure monitoring would be used to detect potential anomalies, and the monitoring results recorded. The plan for detection of anomalies (e.g., unanticipated high or low pressures) and the response(s) to detection of anomalies would be submitted to the BLM prior to well construction.
Water Resources
True Oil would prepare and implement a Sampling and Analysis Plan which sets forth surface water and groundwater sampling locations and sampling frequencies. It would also set forth reporting requirements and format; measures to be taken in response to unanticipated changes in the monitoring results, and procedures for updating the plan as additional data is obtained. Elements of sampling and analysis are described below.
Surface Water. To ensure the environmental consequences to surface water resources are within modeled magnitudes and do not degrade existing conditions and to ensure additional mitigation or remedial action is not needed, the Mitigation Alternative would include the collection of streamflow measurements and water quality sampling designed to provide site- specific information on surface water resources. Sampling locations are shown on Map 2.3-4 and would include:
• Three locations along South Cottonwood Creek, including one upstream, one within, and one downstream of the Project Area. The downstream location would also be downstream of the Prospect Thrust Fault;
• Two locations on the South Fork of Bare Creek, including one upstream of the Project Area and one above the confluence with South Cottonwood Creek;
• A location on the largest of the Soda Lakes; and
• The spring for which the Forest Service has a water right in the drainage of the South Fork of Bare Creek.
Samples would be collected prior to drilling, during drilling, upon completion, and at a reduced frequency during production. Data from the surface water monitoring locations would be used to:
• Establish baseline conditions;
• Compare with the data from the shallow and deep monitoring wells to help determine the recharge/discharge relationship along the creek. This relationship helps determine the extent, if any, of impacts of water use; and
• In the event of a spill, leak, or other unanticipated condition, provide data on the extent of the fluid movement from the spill, leak, or other unanticipated condition.
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Map 2.3-4 Mitigation Alternative – Monitoring Locations
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Depending on site accessibility, it is anticipated that surface water sampling would be conducted once per month from May through October prior to drilling and once per month when drilling and completion are conducted. If production begins, the sampling frequency could be reduced, depending on the baseline information, and would be determined in accordance with the Sampling and Analysis Plan. Sampling frequency and locations would also be supplemented in the event of a spill, leak, or other unanticipated condition impacting surface water resources. Because the surface water data would be compared with the groundwater data, the sampling parameters would be the same as those for groundwater (Table 2.3-12), and the specifications for the surface water locations, flow estimates, and sampling parameters and protocols would be submitted to the WOGCC with the specifications for the proposed wells (see below). The specifications would also describe the process and format for reporting sampling results and addressing unanticipated sampling results.
Groundwater. In 2014, the WOGCC approved a rule requiring groundwater monitoring in accordance with a plan submitted to the WOGCC (2016a). The rule is based on the assumption that wells would be available for sampling within one-half mile of a proposed oil or gas well, and a variance may be applied for if no water sources, as defined by WOGCC, are available within one-half mile (WOGCC, 2016b). There are no water sources in the Project Area, other than the proposed water supply well within one-half mile of the proposed oil and gas wells. However, to help ensure the anticipated lack of environmental consequences to the groundwater resources, this Mitigation Alternative includes installation and monitoring of groundwater wells specifically designed to provide site-specific information on the groundwater resources. The sampling parameters required by the WOGCC are listed in Table 2.3-12. The specifications for the monitoring well design, testing, and sampling would be in compliance with WOGCC requirements and submitted to the WOGCC for review and approval. The Sampling and Analysis Plan would describe the process and format for reporting sampling results and addressing unanticipated sampling results.
The proposed sampling locations are shown on Map 2.3-4. As discussed below, the proposed well locations and depths are designed to provide information on: existing (baseline) groundwater levels and quality: existing or potential interaction among surface water, shallow groundwater, and deep groundwater; and the impact of the Prospect Thrust Fault on groundwater occurrence and movement. Once potential well locations were identified based on hydrogeologic considerations, locations were selected from the potential locations to minimize potential impacts to the setting (e.g., adjacent to existing roads where possible. The wells would be drilled with a truck-mounted rig, using a closed-loop drilling system, and the cuttings would be removed from the drill site. Each shallow well is anticipated to take about 2 days to drill and complete, and each deeper well is anticipated to take about 1 week to drill and complete.
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Table 2.3-12 Water Quality Sampling Parameters1 Field Parameters Temperature pH Conductivity Odor Color Sediment Bubble/Effervescence General Parameters Temperature pH Oxidation-Reduction Potential Specific Conductance Turbidity Dissolved Oxygen Alkalinity (Total Bicarbonate and Carbonate as CaCO3 Ammonia Nitrate Major Anions and Cations Bromide Chloride Fluoride Sulfate Nitrate and Nitrite as N Phosphorus Calcium Iron Magnesium Manganese Potassium Sodium Other Elements Barium Boron Selenium Strontium Bacteria (presence of) Iron related Sulfate reducing Slime forming Organic Compounds Dissolved Gases (methane, ethane, propane) Total Petroleum Hydrocarbons BTEX compounds (benzene, toluene, ethylbenzene, and xylenes) Napthalene Tracer Specific to the selected tracer. 1 Source: WOGCC, 2016.
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Mitigation of Potential Consequences to Shallow Groundwater. Under this alternative, installation and monitoring of three shallow monitoring wells would be initiated prior to well construction. The wells are expected to be about 40 feet deep and completed in the alluvium and glacial till along the South Cottonwood Creek drainage. The well locations would be adjacent to surface water sampling locations to the extent possible (see above). Monitoring of the water supply well would also be initiated prior to well construction. Data from the shallow ‘alluvial’ wells and the water supply well would be used to:
• Establish baseline conditions; • Compare the water levels in the shallow wells with the streamflow measurements and the water levels in the deeper wells to help determine the recharge/discharge relationship along the creek. This relationship helps determine the extent, if any, of impacts of water use; • Compare the shallow groundwater quality with the surface water quality (see above) and water quality from deeper wells to help determine the recharge/discharge relationship along the creek. This relationship helps determine the extent of water quality impacts, if any; and • In the event of a spill or leak, provide data on the extent of the fluid movement from the spill or leak.
The water levels and quality of the permitted water supply well would also be established prior to use of the well for supply. A totalizing flow meter and backflow preventer would be placed on the well. Water levels would also be measured at an interval specified in the Sampling and Analysis Plan while the well is in use, and would include measurement of the static and pumping water levels.
Mitigation of Potential Consequences to Deeper Groundwater. Under this alternative, three deeper monitoring wells would be installed prior to drilling and completion of the exploratory wells. Two of the wells would be completed in the formation(s) on the bottom of the Prospect Thrust Sheet which are considered the most likely to function as aquifers (e.g., the Nugget Sandstone), in a less geologically restricted setting (Table 3.22-4, below). The other well would be completed in the Wasatch Formation in the Green River Basin, i.e., on the opposite side of the fault. The most efficient well locations would be in the vicinity of the fault to the east of the Project Area but still on the Forest (Map 2.3-4). Installation of monitor wells in the formation(s) on the bottom of the Prospect Thrust Sheet directly over the horizontal sections of the proposed exploration wells is not considered efficient for two reasons. First, because of the formation depths in the vicinity of the exploration wells, a much larger rig would be needed, with the associated increase in time required to drill the wells, much larger quantities of drill cuttings would be generated, and similar increases in other drilling aspects. Second, although not anticipated, any vertical impacts from the proposed exploration wells, in particular the hydraulic fracturing, would probably not be evidenced directly vertically but would follow the Prospect Thrust Fault.
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Data from the deeper ‘bedrock’ wells would be used to:
• Establish baseline conditions. Existing conditions are not anticipated to have been impacted by previous human activity, such as drilling and production from the various oil and gas units in the vicinity (Section 3.9), but monitoring before additional drilling would help verify this assessment; • Compare the water levels in the deeper wells with the streamflow measurements and the water levels in the shallow wells to help determine the recharge/discharge relationship along the creek. This relationship helps determine the extent, if any, of effects of water withdrawal from the water supply well; • Compare the deeper groundwater quality with the surface water quality (see above) and water quality from shallow wells to help determine the recharge/discharge relationship along the creek. This relationship helps determine the extent of water quality impacts, if any; • Compare water levels and water quality across the Prospect Thrust Fault to help determine groundwater movement, if any across the fault, and whether recharge from the Overthrust Belt to the Green River Basin is primarily along surface water channels or due to cross-fault movement, or both; • Potentially provide additional monitoring locations for seismicity monitoring during hydraulic fracturing; and • In the event of a spill or leak, provide data on the extent of the fluid movement from the spill or leak.
Invasive, Non-native Species
• Monitoring of noxious weeds would occur on all well pads during construction and operations. Noxious weed would be inventoried and documented at each site prior to disturbance and on an annual basis following initial disturbance. • True Oil would monitor for invasive species along reclaimed areas for 3 to 5 years after interim reclamation and throughout the Operations Phase; where necessary, invasive species would be treated with methods and herbicides approved by the Forest Service.
2.4 COMPARISON OF ALTERNATIVES AND IMPACTS
Table 2.4-1 provides a comparison of the elements of each of the action alternatives; the Proposed Action, the Mitigation Alternative, and the No Action Alternative. Table 2.4-2 provides a comparison of impacts for the Proposed Action, Mitigation Alternative, and No Action Alternative.
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Table 2.4-1 Comparison of Protective Measures and Mitigation for Alternatives Item Proposed Action Mitigation Alternative No Action Expand Existing Well Pad 42-27 Reconstruct Well Pad 23-15 Project Similar to Proposed Action, but water supply well would not be Drill two exploratory natural gas wells (one on each None Components drilled. well pad) Drill Water Supply Well on Existing Well Pad 13-16a 5.50 acres including 1.52 acres of new disturbance and 3.98 acres of previously disturbed and reclaimed Well Pad – Initial areas. Well Pad 23-15 would require 3.32 acres of Same as Proposed Action None Disturbance new disturbance. Well Pad 42-27 would require 2.18 acres of new disturbance. After interim reclamation, approximately 1.43 acres would remain for long-term production of Well Pad 23- Existing disturbance of 1.04 Well Pad – Long- 15. After interim reclamation, approximately 1.31 acres Same as Proposed Action acres associated with Well Pad Term Disturbance would remain for long-term production of Well Pad 42- 42-27 would remain. 27. Roads and No additional disturbance. No new roads necessary Gathering Lines - and gathering line disturbance would be within the well Same as Proposed Action None Disturbance pad disturbance. Reconstruction of Well Pad 23-15 would be designed to minimize disturbance but safely allow for drilling and completion. Interim reclamation would be designed to minimize the production well pad. Under this alternative, the well pad would be rotated in a counterclockwise direction to be parallel with the Well Pad Design – existing road. Same as Proposed Action None Well Pad 23-15 The production pad working area would be bermed so that there is no runoff toward South Cottonwood Creek. An outfall would be located to the south.
The wellhead would have a protective structure around it. Expansion of the well pad would be designed to minimize disturbance but safely allow for drilling and Well Pad 42-27 would not be completion. Interim reclamation would be designed to redesigned to minimize impacts minimize the size of the production well pad. The well to South Fork Bare Creek. Well Pad Design – pad would be rotated in a counterclockwise direction. Additional and improved Same as Proposed Action Well Pad 42-27 stormwater control measures Two existing tanks currently located on the east side of described under the Proposed the well pad towards South Fork Bare Creek would be Action would not be relocated away from the creek and on the south side implemented. of the well pad. New tanks would also be placed in this
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Item Proposed Action Mitigation Alternative No Action location.
Berms around the water and condensate tanks and methanol storage would be reworked with corrugated steel berms with liners.
The production pad working area would be graded and bermed so that there is no runoff toward South Fork Bare Creek. An outfall would be located to the northwest along the pad access.
The well pad expansion would not remove the vegetated hill on the south and southwest margins of the existing well pad to help protect South Fork Bare Creek.
Wellheads would have protective structures around them. Same as Proposed Action – and,
All Project personnel would be educated regarding environmental concerns and requirements, including weed identification, prevention, and control methods.
All vehicles and equipment that would be utilized during construction and/or reclamation and abandonment would be Straw, wattles, or anything vegetative used to slow cleaned prior to entering and upon departure from Project Area to water or used to protect the soil would be certified prevent the spread of seeds and propagules (cleaning location weed-free. Any seeds used for planting and erosion determined by Forest Service and True Oil). control would be from a certified weed-free native seed mix approved by the Forest Service. Wattles would be If weeds are located prior to disturbance, they would be treated Weed Control None made of aspen. prior to ground disturbance.
The area around Well Pad 23-15 would be sprayed for All gravel, road base, or other delivered soil products would be weeds before construction begins (Canada Thistle certified weed-free. observed during on-site visit). True Oil would implement the Forest Service (2004) weed management plan, which includes pre-disturbance surveys, methods for prevention and control, monitoring, reclamation, and treatment.
Straw or wattles or anything vegetative used to slow water or used to protect the soil would be “certified weed-free” and “certified cheatgrass-free”. Any seeds used for planting and erosion control
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Item Proposed Action Mitigation Alternative No Action would be from a “certified weed-free” and “certified cheatgrass- free” native seed mix.
Upon completion of drilling described in this EA and as a function of interim reclamation and upon final reclamation, areas designated to be reclaimed would be fenced with fencing sufficient to preclude cattle grazing and recreational use by the public to ensure substantial and sustainable reclamation and prevention of invasive plant infestation and proliferation. Fencing would be maintained by True Oil until such time as deemed unnecessary by the Authorized Officer and then True Oil would remove the fencing. All fencing would comply with appropriate wildlife protection features as defined by the designated Authorized Officer. True Oil has applied for coverage under the Wyoming Pollutant Discharge Elimination System (WYPDES) Authorization to Discharge Storm Water Associated with Small Construction Activity under the National Pollutant Discharge Elimination System. The general WYPDES permit WYR10-A000 became effective July 8, 2013. True Oil has prepared a Storm Water Pollution Prevention Plan (SWPPP) in compliance with the terms of this permit. BMPs, as required by the permit and the SWPPP, would be in place before, during, and after construction until the location has Same as Proposed Action, and Well Pad 42-27 would not be reached final stabilization. All other requirements of redesigned with improved Stormwater Control the permit would be followed such as inspection and True Oil would update their SWPPP to be consistent with the stormwater control BMPs. True reporting requirements. redesign of the proposed well pads based on the September 2016 Oil’s existing SWPPP would be onsite visit. implemented. All disturbed areas would be revegetated as soon as possible after disturbance.
Diversion ditches would be built around the well pads to prevent sediment loss. The berms would be designed and constructed to channel surface water flow to one or more sediment collection traps and flows from the trap would discharge to a detention basin that would dissipate the flow of energy and prevent erosion. Water would be used for dust suppression on well Dust Control pads and roads as necessary to reduce fugitive dust Same as Proposed Action. None emissions. Same as Proposed Action, and True Oil would continue to follow the SPCC Plans that Existing SPCC Plan would Spill Control have been prepared for each well pad. continue to be implemented. All chemicals, solvents, and fuels (at least 5 gallons) would be kept
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Item Proposed Action Mitigation Alternative No Action at least 150 feet away from streams and riparian areas, and on impermeable surfaces.
All refueling would occur at least 150 feet away from streams and riparian areas.
True Oil would update their SPCC Plan to be consistent with the redesign of the proposed well pads based on the September 2016 onsite visit. All equipment and vehicles would be confined to Same as Proposed Action – and existing roads.
Speed limits would be enforced from the beginning of construction All road work would comply with the Gold Book throughout the life of the Project to minimize collisions with wildlife. Standards for roads (BLM and Forest Service, 2007) Existing speed limits would be Access and Traffic Posted speed limits would be followed. Where there is no posted as well as FP-03 Standard Specifications for Roads enforced. speed limit, speeds on unpaved accessed roads and disturbed and Bridges (Federal Highway Administration, 2016). areas would not exceed levels considered safe for the conditions
and would be slow enough to prevent collisions with wildlife and Drilling and completion crews would carpool to reduce livestock. traffic and vehicle emissions. Tier 2 compliant drilling rig engines would be used to minimize emissions. The Tier 2 engines have a 68 percent reduction in nitrogen dioxide (NOx) emissions over Tier 0 engines.
True Oil would use a closed-loop drilling system which eliminates the requirement for reserve pits.
All usable water zones, potentially productive hydrocarbon zones, and valuable mineral zones would be isolated by cementing the open space between the Drilling casing and the bedrock. Same as Proposed Action None
Blowout Preventer Equipment would be welded to the top of the surface casing to contain unexpected fluid blowouts.
True Oil would submit both the Drilling Contractor’s safety plan as well as True Oil’s safety plan to the Forest Service for approval. The safety plans would be implemented to protect employees, contractors, and the public during construction, production, maintenance, and reclamation. All wells would be completed using “green Same as Proposed Action - and Completion None completions” which means the natural gas at the
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Item Proposed Action Mitigation Alternative No Action wellhead would be captured immediately after well An evaluation of the orientation of the proposed drill holes relative completion rather than being flared or released to the to the Prospect Thrust Fault and the potential for fluid movement atmosphere. along the Fault would be conducted and submitted to the BLM prior to well construction.
An appropriate tracer would be used during hydraulic fracturing to affirm casing integrity and identify any unanticipated fracture paths.
True Oil would participate in FracFocus, which is a national hydraulic fracturing chemical registry managed by the Ground Water Protection Council and Interstate Oil and Gas Compact Commission; two organizations concerned with conservation and environmental protection. The primary purpose of the registry is to provide information concerning hydraulic fracturing and groundwater protection Production equipment would be shared to the greatest extent possible, reducing wellhead fugitive emissions.
Tank batteries would be placed within secondary containment to prevent off-site migration of accidentally spilled produced water and condensate. Secondary containment would hold 110 percent of the volume of the single largest tank in the contained area Existing production equipment Production with sufficient free board to contain anticipated Same as Proposed Action and containment would not be precipitation. Heater/treaters would be located within a improved for Well Pad 42-27. metal building that is surrounded by secondary containment and glycol storage tanks (used for three phase separation) would also have adequate secondary containment. All secondary containment would consist of corrugated steel berms with liners to prevent movement of fluids. All loading lines would be placed inside the secondary containment. Same as Proposed Action, and
Trash and garbage would be placed in appropriate caged containers and the container and contents transported to an approved disposal facility. All containers would be equipped with Construction and Operation would occur outside of bear-resistant openings. Wildlife sensitive wildlife periods for big game and greater None
sage-grouse (lek attendance, nesting, and wintering). If vegetation clearing occurs between May 15 and July 15, a survey would be required to minimize disruptions to migratory birds during the nesting season, unless deemed unnecessary by the Authorized Officer.
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Item Proposed Action Mitigation Alternative No Action A policy stating that no guns, dogs, drugs, or alcohol would be in place for all employees and subcontractors to minimize potential conflicts with wildlife.
Environmental awareness training would be provided describing the consequences of poaching and information on Wyoming wildlife laws, licensing, and residency requirements.
Raptor surveys would be conducted if surface disturbance is planned prior to August 15 to determine nesting activity, unless deemed unnecessary by the Authorized Officer. If future surveys indicate nests, then appropriate protections would be applied. Damage to existing range improvements would be avoided and if Grazing No protective measures None damage occurs, it would be repaired immediately. A fire management plan would be prepared and implemented which addresses employee fire safety education to assist Fire and Fuels No protective measures None personnel in preventing and containing Project-related accidental ignitions. Same as Proposed Action – and
Lighting during construction would follow “dark-sky” lighting practices. Such practices are designed to reduce the effects of artificial light on the natural environment, including sky glow, glare, light trespass, light clutter, and decreased visibility at night (International Dark-Sky Association – IDA, 2014). “Dark-sky” lighting practices implemented in the Project Area would include, but not be limited to the following:
Facilities would be painted dark green which is BLM o using low glare lighting equipment; “Beetle” or “Yuma” green from the Standard o shielding security lighting so that the majority of light hits the Environmental Colors Chart (whichever better matches target and does not cause glare; Visual the conifer background). None o targeting lower lighting levels and better uniformity for safety
and security lighting; and Night-lighting during drilling would be Forest Service- o to the extent practical, aiming lighting on facilities from the approved. top down, and away from adjacent areas.
Upon completion of drilling activities and as a function of interim reclamation, a vegetative visual screening or buffer would be planted between the adjacent primary roads and well pads 13-16a and 42-27. Tree sizes would be evenly distributed between the sizes of 2 foot to 8 foot. Trees would be transplanted from nearby areas as designated by the forest timber program. Trees would be acquired via the Forest Service commercial tree purchase process so as to plant trees most acclimated to the area. Trees would be
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Item Proposed Action Mitigation Alternative No Action transplanted according to industry best planting practices which includes season of transplant and method of transplanting. Number of trees should range between twenty and fifty trees per well pad based on input from the Forest Visual Resource Specialist and as decided by the Authorized Officer. After the last well on a well pad is plugged and abandoned, final reclamation earthwork and seeding would be completed within one year from the date of Reclamation Same as Proposed Action None plugging and abandonment, weather permitting. Reclamation would be confirmed to be effective before True Oil would be released from their obligations. Same as Proposed Action – and
Monitoring of noxious weeds would occur on all well pads during construction and operations. Noxious weed would be inventoried and documented at each site prior to disturbance and on an annual basis following initial disturbance.
True Oil would monitor for invasive species along reclaimed areas for 3 to 5 years after interim reclamation and throughout the Operations Phase; where necessary, invasive species would be treated with methods and herbicides approved by the Forest Service.
A seismic/microseismic monitoring program would be implemented before, during, and after hydraulic fracturing. Monitoring locations Erosion and channel formation would be monitored would be selected to coincide with existing disturbances. The Monitoring during construction and after large rainfall or snowmelt monitoring program would be reviewed and approved by the BLM None runoff events during operations. and results would be submitted to the BLM once construction of the well is complete.
During hydraulic fracturing, pressure monitoring would be used to detect potential anomalies, and the monitoring results recorded. The plan for detection of anomalies (e.g., unanticipated high or low pressures) and the response(s) to detection of anomalies would be submitted to the BLM prior to well construction.
Streamflow measurements would be collected and surface water quality sampling would be designed to provide site-specific information on surface water resources.
Installation and monitoring of groundwater wells specifically designed to provide site-specific information on the groundwater resources.
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Table 2.4-2 Comparison of Impacts Resource Proposed Action Mitigation Alternative No Action Approximately 5.50 acres would be disturbed including 1.52 acres of new disturbance and 3.98 No new disturbance and stormwater BMPs on Amount of Disturbed acres of previously disturbed and reclaimed areas. Same disturbance as the Proposed Action. existing Well Pad 42-27 would not be Lands No additional disturbance above existing improved. disturbance on Well Pad 42-27 after interim reclamation (including improved stormwater BMPs). Air pollutant concentrations resulting from construction and operations would be in compliance with the National Ambient Air Quality Standards (NAAQS) and Wyoming Ambient Air Quality Standards (WAAQS). Impacts from operations would be below PSD Class II increments. Impacts would be the same as the Proposed Impacts would be less than the Proposed Climate and Air Quality Impacts would not exceed the NAAQS, WAAQS, or the applicable PSD Class I/Class II increments at Action. Action. any of the nearby Class I and sensitive Class II areas. In addition, impacts to air quality related values (AQRVs) (i.e., visibility, atmospheric deposition of nitrogen and sulfur, sensitive lakes) at the nearby Class I and sensitive Class II areas would be below applicable threshold values. Environmental Justice No impact. No impact. No impact. Possibly less impact. True Oil would prepare and Most impact. Potential for fire during summer implement a site-specific fire management plan; Least impact. Potential for fire from existing Fire and Fuels months workers and ignition threats from heavy however, water from the water supply well would operations would continue. equipment during construction. not be available to support fire crews. Most impact. Low potential for subsurface impacts Similar to Proposed Action; but reduced due to due to hydraulic fracturing such as creation of large- surface and subsurface monitoring, and Geologic Resources scale fractures connecting oil and gas producing No additional impact. identified response options to detection of formations with formations that contain better water anomalies. quality. Least impact. True Oil would implement the Invasive, Non-Native Most impact. The Proposed Action would have the Forest Service (2004) weed management plan, Less impact. True Oil would not implement the Species and Noxious potential to allow establishment of invasive, non- which includes pre-disturbance surveys, Forest Service (2004) weed management Weeds native species and noxious weeds. methods for prevention and control, monitoring, plan. reclamation, and treatment. Land Tenure, Rights-of- No impact. No impact. No impact. Way and Other Uses Most impact. Project-related activities would overlap Less than the Proposed Action. No vegetation the period when raptors could be nesting and when clearing would occur between May 15 and July Migratory Birds No additional impacts. nestlings and newly fledged juveniles would be 15 unless surveys were conducted within at least present and depend on adults for food. 2 weeks, unless deemed unnecessary by the
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Resource Proposed Action Mitigation Alternative No Action Authorized Officer. Ground disturbance during peak nesting (May 15 to July 15) could result in nest abandonment, Raptor surveys would be conducted prior to displacement of birds, and possible mortality of project activities, unless deemed unnecessary by nestlings. Spatial and temporal limitations would the Authorized Officer. If raptors are lessen possibility of nest abandonment due to noise documented, activity may be delayed. and human presence. Most impact. Natural gas production would contribute to the draining of hydrocarbon-bearing Mineral Resources reservoirs in the Hilliard Formation. No effects on Same as the Proposed Action. No additional impacts. current or future developments of oil and gas, coal, phosphorus, bentonite, or sand and gravel. Same as Proposed Action. Also, potential for Paleontological Most impact. It is unlikely that fossils would be occurrence of fossil resources would be revisited No additional impacts. Resources affected. Monitoring is not recommended. once the locations for monitoring wells are determined. Less impact. Posted speed limits would be Most impact. Increased vehicle traffic increases the followed and speeds would not exceed levels potential for collisions with livestock, if the allotment considered safe for the conditions and would be is stocked. slow enough to prevent collisions with wildlife Range Management and livestock where there is no posted speed No additional impacts. Invasive weeds could be introduced into the Project limit. Area which would reduce the yield and quality of forage. True oil would implement the Forest Service (2004) weed management plan. Most impact. Night lighting may affect recreational Less impact. True Oil would implement dark-sky Recreation users during construction and would be short-term No additional impacts. lighting. and temporary. Most impact. Demand for short-term house would No additional impact; however economic Socioeconomics increase temporarily. Economic benefits to federal, Same as Proposed Action. benefits to federal, state, and Sublette County state, and Sublette County would be realized. would not be realized. Most impact. Disturbance of 5.50 acres across two soil mapping units including 1.52 acres of new disturbance and re-use of 3.98 acres. Mixing of Soils topsoil and subsoil could occur as well as Same as the Proposed Action. No additional impact. compaction resulting in direct impacts. Indirect impacts to soils could occur from wind and water erosion. Special Areas and No impact. No impact. No impact. Designations In a Biological Assessment, the Forest Service Threatened, Endangered, determined the Project would “may affect, likely to Candidate, and Sensitive Same as Proposed Action. No impact. adversely affect” the endangered bonytail (Gila Animal Species elegans), Colorado pikeminnow (Ptychocheilus
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Resource Proposed Action Mitigation Alternative No Action Lucius), humpback chub (Gila cypha) and razorback sucker (Xyrauchen texanus). The Project would have an average annual water depletion of 23.3 acre-feet. Because the average annual depletion would be less than 100 acre-feet, no payment to the recovery program is required.
Also in the Biological Assessment, the Forest Service determine there would be a “may affect, not likely to adversely affect” Canada lynx (Lynx canadensis) and its designated critical habitat, grizzly bear (Ursus arctos horribilus), and yellow- billed cuckoo (Coccyzus americanus) and its designated critical habitat. In addition, the Project is “not expected to jeopardize the continued existence of the species” for the gray wolf (Canis lupus) and wolverine (Gulo gulo).
Although project disturbance would occur within designated Priority Habitat Management Area, the Project is consistent with Guideline 21 and 22 of the Greater Sage-grouse Record of Decision. Less impact. True Oil would implement the Forest Service (2004) weed management plan. Threatened, Endangered, Most impact. Payson’s milkvetch and Payson’s Speed limits would be enforced and would not Candidate, and Sensitive bladderpod could be impacted by fugitive dust, if exceed levels considered safe for the conditions No additional impact. Plant Species present. where there is no posted speed limit and would be slow enough to prevent collisions with wildlife and livestock. Most impact. Compared to 2013 traffic levels, Project traffic during well completion could increase daily traffic volumes between 2 and 9 percent on affected segments of U.S. Highway 189, less than 3 percent on affected segments of U.S. Highway 191, and approximately 6 percent on Wyoming State Similar to Proposed Action; additional roads may Transportation/Access No additional impact. Highway 351. Project construction would result in be required to install monitoring wells. noticeable traffic increases on CR 23-117 and CR 23-129. During well completions, traffic on CR 23- 117 could be twice as high and traffic on CR 23-129 could be three times as high traffic volumes recorded in June 2015 Most impact. Dust from project-related traffic could Less impact. True Oil would implement the Vegetation affect Payson’s milkvetch and Payson’s bladderpod, Forest Service (2004) weed management plan. No additional impact. if present. Speed limits would be enforced and would not
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Resource Proposed Action Mitigation Alternative No Action exceed levels considered safe for the conditions where there is no posted speed limit and would be slow enough to prevent collisions with wildlife and livestock. Least impact. Similar to Proposed Action; Most impact. Existing tanks and production Less impact. No disturbance to Well Pad 23- however, lighting on the well pads during Visual Resources equipment on Well Pad 42-27 would be moved so it 15 area. Tanks on Well Pad 42-27 would not construction would follow “dark sky” lighting is less visible from the road. be relocated. practices. Wastes, Hazardous or Most impact. Generated wastes would be removed Same as Proposed Action. No additional impact. Solid from project area and disposed at approved facility. Similar to Proposed Action but Less impact. All chemicals, solvents, and fuels would be kept at Most impact. Potential for erosion and least 150 feet from streams and riparian areas Existing impact would continue. Well Pad 42- Water Resources – sedimentation from disturbed areas and and all refueling would occur at least 150 feet 27 would not be reconstructed with improved Surface Water contamination by spills and leaks; however, use of from stream and riparian areas. Monitoring of BMPs to reduce potential effects to water BMPs would reduce impact. surface water quality would be conducted in quality. accordance with the Sampling and Analysis Plan. Similar to Proposed Action but reduced potential for impact. All chemicals, solvents, and fuels Most impact. Potential for impact to groundwater would be kept at least 150 feet from streams and Existing impact would continue. Well Pad 42- Water Resources - quality from leaks and spills and low potential for riparian areas and all refueling would occur at 27 would not be reconstructed with improved Groundwater impact from hydraulic fracturing due to large scale least 150 feet from stream and riparian areas. BMPs to reduce potential effects to water fractures. Monitoring of groundwater quality would be quality. conducted in accordance with the Sampling and Analysis Plan. Water Resources - Water Minimal impact. Same as Proposed Action No additional impact. Use and Rights Most impact. Little or no measureable effects to Least impact. The water supply well would not Wetlands and Riparian wetlands. Water supply line would cross riparian be drilled and the temporary water line would not No additional impact. Zones areas but would be temporary. be installed. Less impact. Similar to Proposed Action; however, speed limits would be enforced and where not posted on unpaved access roads, would not exceed levels considered safe for the Most impact. Terrestrial species could be affected conditions and would be slow enough to prevent by removal of habitat, lighting, traffic, noise, and Wildlife collisions with wildlife and livestock. Dark sky No additional impact. human presence during construction, drilling, and lighting practices would be implemented and the completion. Forest Service weed management plan would be implemented. True Oil would provide environmental awareness training to address consequences of poaching.
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2.5 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL
If an alternative is considered during the environmental analysis process, but the agency decides not to analyze the alternative in detail, the agency must identify those alternatives and briefly explain why they were eliminated from detailed analysis (40 CFR § 1502.14).
The Forest Service put forth two alternatives that were considered but were not analyzed in detail. The reasons for not considering these alternatives are described below.
Forest Service Alternative 1. Forest Service Alternative 1 is similar to the Proposed Action described above; however, under this alternative, Well Pad 42-27 would not be expanded in its current location and production of the existing Soda Unit 42-27 well would continue. The current condition of Well Pad 42-27 would remain unchanged. The proposed stormwater BMPs designed to reduce sediment transport and erosion from existing Well Pad 42-27 to South Fork Bare Creek would not be implemented. Existing tanks on Well Pad 42-27 would not be moved to further away from South Fork Bare Creek. A new well pad (42-27A) would be constructed on the opposite side of NFSR 10046 from Well Pad 42-27 (see Map 2.5-1). The new well pad would be outside of the 500 ft stream buffer (South Fork Bare Creek) but would be within the 500 ft road buffer of NFSR 10046. Approximately 2.82 acres would be required for this new well pad. No new access road would be required because the well pad would be located along NFSR 10046 and any additional natural gas gathering line would be constructed within the well pad disturbance.
This alternative was not carried forward for analysis because of the visual impacts that would occur by constructing a new well pad across from the existing Well Pad 42-27. It would also require an additional 2.82 acres of surface disturbance.
Forest Service Alternative 2. Under this alternative, Well Pad 42-27 would not be expanded in its current location; however, production of the existing Soda Unit 42-27 well would continue. The proposed stormwater BMPs designed to reduce sediment transport and erosion from existing Well Pad 42-27 to South Fork Bare Creek would not be implemented. Existing tanks on Well Pad 42-27 would not be moved to further away from South Fork Bare Creek. The current condition of Well Pad 42-27 would remain unchanged. A new well pad (42-27B) would be constructed outside of the 500 ft stream buffer (South Fork Bare Creek) and outside of the 500 ft road buffer of NFSR 10046 (see Map 2.5-1). The well pad would require 2.67 acres of disturbance and the 570 foot access road would require approximately 0.55 acre of disturbance. The well pad would be located within wetland habitats. A portion of the access road would be located within the 500 ft road buffer. A gathering line would be installed within the disturbance for the access road.
Constructing this well pad in the immediate vicinity of the existing Well Pad 42-27 would cause additional visual impact, wetland vegetation would be disturbed, and an additional 3.22 acres of disturbance would occur. For these reasons, this alternative was not carried forward for analysis.
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Map 2.5-1 Alternatives
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3.0 CHAPTER 3 - AFFECTED ENVIRONMENT AND EFFECTS
3.1 INTRODUCTION
This section provides a description of the human and natural environmental resources that could be affected by the Proposed Action and presents comparative analyses of the direct and indirect effects on the affected environment stemming from the implementation of the actions under the Proposed Action and other alternatives analyzed. This EA draws upon information compiled in the Forest Plan (Forest Service, 2015a).
Table 3.1-1 lists the various resources and shows whether the resource would be affected by the Proposed Action. If a resource is not present or would not be impacted, it is not analyzed in this EA.
Table 3.1-1 Potentially Impacted Resources Forest Not Service Present On No Potentially Mitigation Evaluator Resources Location Impact Impacted necessary Initial & Date Air and Climate Cultural Resources Environmental Justice Fire and Fuels Geologic Resources Invasive, Non-native Species and Noxious
Weeds Land Tenure, Rights of Way and other
Uses Migratory Birds Mineral Resources Paleontological Resources Prime or Unique Farmlands Range Management Recreation Socioeconomic Soils Special Areas and Designations Threatened, Endangered, Proposed,
Candidate and Sensitive Animal Species Transportation/ Access Tribal and Native American Religious
Concerns Vegetation Visual Resources Wastes, Hazardous or Solid Water Resources Wetlands and Riparian Zones Wild and Scenic Rivers Wild Horse and Burros Wildlife
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For those resources identified in Table 3.1-1 that are either not present or would not be impacted by the alternatives, clarifying information is provided below.
Cultural Resources. The areas proposed for disturbance were surveyed previously and no cultural sites of concern, historic or prehistoric, were located. The Wyoming State Historic Preservation Office concurred with the findings of the survey results. If the Project is approved and cultural materials are uncovered during construction, the operator will immediately stop any work which would affect such materials and contact the Authorized Officer. The Authorized Officer will determine what mitigation may be necessary before construction continues.
Prime or Unique Farmlands. According to the Natural Resources Conservation Service (NRCS) Web Soil Survey spatial and tabular data of Sublette County, Bridger National Forest Wyoming, Western Part WY663, (NRCS, 2015), 16 soil mapping units occur in the Project Area (see Section 3.14). None of the identified soil mapping units are determined to be prime farmland.
Tribal and Native American Religious Concerns. Because the Proposed Action would occur within previously disturbed areas and based on the results of the previous cultural surveys, the Eastern Shoshone had no concerns with the Project during discussions with the Forest Service in May 2015. The Forest Service would continue to update the Tribe as the NEPA process continues and would inform the Tribe immediately if the Project is approved and activities associated with the Proposed Action unexpectedly encountered items of cultural concern.
Wild and Scenic Rivers. Passage of the Craig Thomas Snake Headwaters Legacy Act in 2009 added all or segments of 13 rivers and streams in the Snake River Headwaters to the National Wild and Scenic Rivers System. The purpose of this designation is to protect the free-flowing condition, water quality, and ‘outstandingly remarkable’ values of the Headwaters for the benefit and enjoyment of present and future generations (Forest Service, 2014). The Snake River headwaters are the closest designated wild and scenic rivers to the Project Area and are over 25 miles to the north. Therefore, environmental impacts to wild and scenic rivers from any of the alternatives will not be analyzed.
Wild Horse and Burros. The BLM maintains and manages 16 wild horse herd management areas (HMA) in Wyoming. Wyoming has no wild burros. No wild horse HMAs coincide with the Project Area. The nearest wild horse HMA is the Little Colorado HMA, which is located approximately 50 miles south of the Project Area, near Fontenelle Reservoir. Therefore, environmental impacts to wild horse and burros from any of the alternatives will not be analyzed.
3.2 AIR QUALITY AND CLIMATE
3.2.1 Current Conditions Regional air quality is influenced by a combination of factors including climate, meteorology, the magnitude and spatial distribution of local and regional air pollution sources, and the chemical properties of emitted pollutants. Within the lower atmosphere, regional and local scale air masses interact with regional topography to influence atmospheric dispersion and transport of pollutants. The following sections summarize the climatic conditions and existing air quality within the Project Area and surrounding region.
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3.2.1.1 Regional Climate The Project Area is located in mountainous terrain on the eastern side of the Wyoming Range. Terrain elevations within the Project Area range from approximately 8,300 feet to 10,600 feet above mean sea level (amsl). The Project Area is subject to strong and gusty winds, reflecting channeling and mountain valley flows due to complex terrain. During winter months, strong winds are often accompanied by snow, producing blizzard conditions. Given that representative precipitation and temperature measurements are not available within the Project Area, data to describe the conditions in the Project Area were obtained from the Parameter-elevation Regressions on Independent Slopes Model (PRISM, 2016) climate mapping system database, based on the 30 year normal dataset for long-term average precipitation and temperature over the 1981 to 2010 time period.
Average annual precipitation data for the Project Area is estimated as 34.1 inches with the greatest occurring from late fall through the spring months. Most precipitation during these months falls as snow. The region has cool temperatures, with an average monthly range (in degrees Fahrenheit - ˚F) between 6.9˚F and 25.8˚F in December to between 39.9˚F and 71.8˚F in July. The frost-free period generally occurs from June to September. Table 3.2-1 shows the mean monthly temperature ranges and total precipitation amounts.
Table 3.2-1 Mean Monthly Temperature Ranges and Total Precipitation Amounts1 Average Temperature Range Total Precipitation Month (˚F) (inches) January 7.1 – 27.1 4.26 February 6.1 – 30.3 3.61 March 12.2 – 37.5 3.54 April 19.5 – 45.4 3.19 May 27.2 – 53.0 3.32 June 33.9 – 62.0 2.08 July 39.9 – 71.8 1.28 August 38.8 – 70.2 1.42 September 32.2 – 60.2 1.53 October 25.1 – 47.9 2.12 November 13.6 – 33.3 3.83 December 6.9 – 25.8 3.95 ANNUAL 34.5 (mean) 34.1 (mean) 1 Source: PRISM, 2016.
Comprehensive wind measurements are collected at the Remote Automatic Weather Station (RAWS, 2016) Snyder Basin site located approximately 15 miles south of the Project Area. To describe the wind flow pattern for the region, a wind rose for the site, for available years 2011 through 2015, is presented in Figure 3.2-1.
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Figure 3.2-1 Snyder Basin, Wyoming Meteorological Data Wind Rose
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Tables 3.2-2 and 3.2-3 provide the wind speed and wind direction distributions in tabular format. From this information, it is evident that the winds originate from the south through the west 53 percent of the time.
Table 3.2-2 Wind speed distribution, Snyder Basin, Wyoming, 2011–20151 Wind Speed (mph) Frequency (%) 0 – 4.0 41.6 4.0 – 8.0 22.0 8.0 – 13.0 22.3 13.0 – 19.0 11.1 19.0 – 25.0 2.2 Greater than 25.0 0.7 1 Source: RAWS, 2016.
Table 3.2-3 Wind Direction Frequency Distribution, Snyder Basin, Wyoming, 2011–20151 Wind Direction Frequency (%) N 0.9 NNE 1.0 NE 3.1 ENE 1.9 E 1.1 ESE 0.9 SE 0.9 SSE 1.9 S 8.4 SSW 9.2 SW 11.2 WSW 14.5 W 9.8 WNW 2.7 NW 1.3 NNW 1.1 1 Source: RAWS, 2016.
3.2.1.2 Overview of Regulatory Environment The Wyoming Department of Environmental Quality – Air Quality Division (WDEQ-AQD) is the primary air quality regulatory agency responsible for estimating impacts once detailed industrial development plans have been made. Those development plans are subject to applicable air quality laws, regulations, standards, control measures, and management practices. Unlike the conceptual ‘reasonable, but conservative’ engineering designs used in NEPA analyses, any WDEQ-AQD air quality preconstruction permitting demonstrations required would be based on very site-specific, detailed engineering values, which would be assessed in the permit application review. Any proposed facility which meets the requirements set forth under Wyoming Air Quality Standards and Regulations (WAQSR) Chapter 6 (WDEQ, 2015a) is subject to the WDEQ-AQD permitting and compliance processes.
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Federal air quality regulations adopted and enforced by WDEQ-AQD limit incremental emission increases to specific levels defined by the classification of air quality in an area. The Prevention of Significant Deterioration (PSD) Program is designed to limit the incremental increase of specific air pollutant concentrations above a legally defined baseline level. Incremental increases in PSD Class I areas are strictly limited, while increases allowed in Class II areas are less strict. Under the PSD program, Class I areas are protected by Federal Land Managers (FLMs) through management of air quality related values (AQRVs) such as visibility, aquatic ecosystems, flora, fauna, and others. Areas throughout the region not designated as PSD Class I are classified as Class II. FLMs can designate specific Class II areas that they manage as “sensitive” Class II areas, based on their own criteria, and request that PSD Class I level air quality analyses are included for these areas.
The 1977 Clean Air Act amendments established visibility as an AQRV for Federal Land Managers to consider. The 1990 Clean Air Act amendments contain a goal of improving visibility within PSD Class I areas. The Regional Haze Rule, finalized in 1999, requires states, in coordination with federal agencies and other interested parties, to develop and implement air quality protection plans to reduce the pollution that causes visibility impairment.
Regulations and standards which limit permissible levels of air pollutant concentrations and air emissions and which are relevant to the Lander Peak Area Project air impact analysis include:
• National Ambient Air Quality Standards (NAAQS) (40 CFR Part 50) and Wyoming Ambient Air Quality Standards (WAAQS) (WAQSR Chapter 2). • Ozone nonattainment designation of the Upper Green River Basin (UGRB) in 2012; • Conformity Analysis (Clean Air Act Section 176(c) and WAQSR Chapter 8); • Prevention of Significant Deterioration (40 CFR Part 51.166); • New Source Performance Standards (NSPS) (40 CFR Part 60); • Non-Road Engine Tier Standards (40 CFR Part 89); • Wyoming Oil and Gas Permitting Guidance (supplement to WAQSR Chapter 6, Section 2); and • National Emission Standards for Hazardous Air Pollutants (NESHAPS) (40 CFR Part 63). Each of these regulations is further described in the following sections. 3.2.1.2.1 Ambient Air Quality Standards The Clean Air Act requires the U.S. Environmental Protection Agency (EPA) to set NAAQS for pollutants considered to endanger public health and the environment. The EPA has developed NAAQS for six criteria pollutants: nitrogen dioxide, carbon monoxide, sulfur dioxide, particulate matter, ozone, and lead. Lead emissions from Project sources are negligible and therefore the lead NAAQS is not addressed in this analysis. There are two types of NAAQS; primary standards that prescribe limits on ambient levels of these pollutants in order to protect public health, including the health of sensitive groups, and secondary standards that provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings. States typically adopt the NAAQS but may also develop state- specific ambient air quality standards for certain pollutants. The NAAQS and the state ambient air quality standards for Wyoming (WAAQS) are summarized in Table 3.2-4. The ambient air quality standards are shown in units of parts per million (ppm), parts per billion (ppb), and micrograms per cubic meter (µg/m3) for purposes of providing the standards as written in the corresponding regulation, and for comparison with ambient pollutant concentrations.
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Table 3.2-4 Ambient Air Quality Standards NAAQS WAAQS Pollutant Averaging Time 3 3 (ppm) (ppb) (µg/m ) (ppm) (ppb) (µg/m ) 1-hour1 35 35,000 40,000 35 35,000 40 (mg/m3) Carbon monoxide 8-hour1 9 9,000 10,000 9 9,000 10 (mg/m3) 1-hour2 0.1 100 188 0.1 100 188 Nitrogen dioxide Annual3 0.053 53 100 0.053 53 100 Ozone 8-hour4 0.0705 70 137 0.0756 75 147 24-hour1 NA NA 150 NA NA 150 PM 10 Annual3 NA NA --7 NA NA 50 24-hour8 NA NA 35 NA NA 35 PM 2.5 Annual3 NA NA 12 NA NA 15 1-hour9 0.075 75 196 0.075 75 196 Sulfur dioxide 3-hour1 0.5 500 1,300 0.5 500 1,300 Note: Bold indicates the standard as written in the corresponding regulation. Other values are conversions. 1 Not to be exceeded more than once per year. 2 An area is in compliance with the standard if the 98th percentile of daily maximum 1-hour nitrogen dioxide concentrations in a year, averaged over 3 years, is less than or equal to the level of the standard. 3 Annual arithmetic mean. 4 An area is in compliance with the standard if the fourth-highest daily maximum 8-hour ozone concentrations in a year, averaged over 3 years, is less than or equal to the level of the standard. 5 Revised ozone NAAQS was published October 26, 2015 (EPA, 2015a). 6 Revised ozone NAAQS not yet updated in Wyoming Air Quality Standards and Regulations. 7 The NAAQS for this averaging time for this pollutant has been revoked by EPA. 8 An area is in compliance with the standard if the highest 24-hour PM2.5 concentrations in a year, averaged over 3 years, is less than or equal to the level of the standard. 9 An area is in compliance with the standard if the 99th percentile of daily maximum 1-hour sulfur dioxide concentrations in a year, averaged over 3 years, is less than or equal to the level of the standard.
An area that is shown to exceed the NAAQS for a given pollutant may be designated as a nonattainment area for that pollutant. In May 2012, Sublette County and parts of Lincoln and Sweetwater counties were designated by the EPA as “marginal” non-attainment areas under the 2008 ozone standard given there were monitored ozone concentrations above the 75 ppb ozone NAAQS. The effective date of the non-attainment designation was July 20, 2012 (WDEQ, 2015b). The EPA has recently proposed to determine that these areas have already attained the 2008 NAAQS by the applicable attainment date of July 20, 2015, based on complete, quality-assured and certified ozone monitoring data for 2012 to 2014 (EPA, 2015a).
On October 1, 2015, the EPA lowered the primary ozone NAAQS from 75 ppb to a more stringent value of 70 ppb (EPA, 2015b). The EPA expects to issue detailed guidance on the designation process in 2016, but has indicated that attainment designations for the 2015 NAAQS will be based on 2014-2016 data. State recommendations for designations of attainment and nonattainment areas are due to EPA by October 1, 2016 and EPA will finalize designations by October 1, 2017.
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The Project Area is located in western Sublette County, and within the UGRB non-attainment area. Consequently, under Section 176(c) of the Clean Air Act and WAQSR Chapter 8, a conformity analysis must be completed to determine conformity to any applicable state, Tribal or federal implementation plans (SIP, TIP or FIP) for attaining and maintaining the NAAQS. Where actions are not specifically exempted, the Forest Service must complete a conformity determination before authorizing any action in a nonattainment area. Activities permitted under New Source Review (NSR) are exempt from conformity review. WAQSR Chapter 8 Section 3 establishes thresholds under which a project is presumed to conform. 3.2.1.2.2 Hazardous Air Pollutants Toxic air pollutants, also known as hazardous air pollutants (HAPs), are those pollutants that are known or suspected to cause cancer or other serious health effects, such as reproductive effects or birth defects, or adverse environmental effects. No ambient air quality standards exist for HAPs; instead, emissions of these pollutants are controlled by a variety of regulations that target the specific source class and industrial sectors for stationary, mobile, and product use/formulations. Sources of HAPs from Project operations consist of well-site production emissions (benzene, toluene, ethyl benzene, xylene, n-hexane, and formaldehyde).
Short-term (1-hour) HAP concentrations are compared to acute Reference Exposure Levels (RELs) (EPA, 2014a) shown in Table 3.2-5. RELs are defined as concentrations at or below which no adverse health effects are expected. No RELs are available for ethyl benzene and n- hexane; instead, the available “Immediately Dangerous to Life or Health” (IDLH) values divided by 10 (IDLH/10) are used. These IDLH values were determined by the National Institute for Occupational Safety and Health and were obtained from EPA’s Air Toxics Database (EPA, 2014a). These values are approximately comparable to mild effects levels for 1-hour exposures.
Table 3.2-5 Acute RELs (1-hour exposure) HAP REL (µg/m3) Benzene 1,3001 Toluene 37,0001 Ethyl Benzene 350,0002 Xylene 22,0001 n-Hexane 390,0002 Formaldehyde 551 1 EPA Air Toxics Database, Table 2 (EPA, 2014a). 2 No REL available for these HAPs. Values shown are IDLH (IDLH/10), EPA Air Toxics Database, Table 2 (EPA, 2014a).
Long-term exposure to HAPs is compared to Reference Concentrations for Chronic Inhalation (RfCs). An RfC is defined by the EPA as the daily inhalation concentration at which no long-term adverse health effects are expected. RfCs exist for both non-carcinogenic and carcinogenic effects on human health (EPA, 2014b). Annual modeled HAP concentrations are compared directly to the non-carcinogenic RfCs shown in Table 3.2-6. Long-term exposures to emissions of suspected carcinogens (benzene, ethyl benzene and formaldehyde) are also evaluated based on estimates of the increased latent cancer risk over a 70-year lifetime.
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Table 3.2-6 Non-Carcinogenic HAP RfCs (annual average)1 HAP Non-CarcinogenicRfC1 (µg/m3) Benzene 30 Toluene 5,000 Ethyl Benzene 1,000 Xylenes 100 n-Hexane 700 Formaldehyde 9.8 1 EPA Air Toxics Database, Table 1 (EPA, 2014b). 3.2.1.2.3 Prevention of Significant Deterioration The PSD Program is designed to limit the incremental increase of specific air pollutant concentrations above a legally defined baseline level. All areas of the country are assigned a classification which describes the degree of degradation to the existing air quality that is allowed to occur within the area under the PSD permitting rules. PSD Class I areas are areas of special national or regional natural, scenic, recreational, or historic value, and very little degradation in air quality is allowed by strictly limiting industrial growth. PSD Class II areas allow for reasonable industrial/economic expansion. Areas such as national parks, natural wilderness areas, and national monuments are designated as PSD Class I areas, and air quality in these areas is protected by allowing only slight incremental increases in pollutant concentrations. The PSD Class I area nearest to the Project Area is the Bridger Wilderness Area. In a PSD increment analysis, impacts from proposed emissions sources are compared with the allowable limits on increases in pollutant concentrations, which are called Class I PSD increments; these increments are shown in Table 3.2-7. The Project Area is classified as PSD Class II, where less stringent limits on increases in pollutant concentrations apply.
Table 3.2-7 PSD increments (µg/m3) PSD Class I PSD Class II Pollutant Averaging Time Increment Increment 1-hour None None Nitrogen dioxide Annual 2.5 25 24-hour 8 30 PM 10 Annual 4 17 24-hour 2 9 PM 2.5 Annual 1 4 1-hour None None 3-hour 25 512 Sulfur dioxide 24-hour 5 91 Annual 2 20 Note: The PSD demonstrations serve information purposes only and do not constitute a regulatory PSD increment consumption analysis.
Comparisons of Project impacts to the PSD Class I and II increments are for informational purposes only and are intended to evaluate a threshold of concern. They do not represent a regulatory PSD Increment Consumption Analysis, which would be completed as necessary during the New Source Review permitting process by the State of Wyoming.
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In addition to the PSD increments, Class I areas are protected by FLMs through management of AQRVs such as visibility, aquatic ecosystems, flora, and fauna. Evaluations of impacts to AQRVs would also be performed during the New Source Review permitting process under the direction of the WDEQ-AQD in consultation with the FLMs.
AQRVs of concern in the region include visibility and atmospheric deposition. A discussion of the analysis thresholds and applicable background data is provided below.
Visibility Thresholds. Change in atmospheric light extinction relative to background conditions is used to measure regional haze. Analysis thresholds for atmospheric light extinction are set forth in The Federal Land Managers’ Air Quality Related Values Work Group (FLAG) Report (FLAG, 2010), with the results reported in percent change in light extinction and change in deciviews (dv). A 5-percent change in light extinction (approximately equal to 0.5 dv) is the threshold recommended in FLAG (2010) and is considered to contribute to regional haze visibility impairment. A 10-percent change in light extinction (approximately equal to 1.0 dv) is considered to represent a noticeable change in visibility when compared to background conditions.
Atmospheric Deposition. The effects of atmospheric deposition of nitrogen and sulfur compounds on terrestrial and aquatic ecosystems are well-documented and have shown to cause leaching of nutrients from soils, acidification of surface waters, injury to high-elevation vegetation, and changes in nutrient cycling and species composition. FLAG (2010) recommends that applicable sources assess impacts of nitrogen and sulfur deposition in Class I areas.
This guidance recognizes the importance of establishing critical deposition loading values (“critical loads”) for each specific Class I area as these critical loads are completely dependent on local atmospheric, aquatic, and terrestrial conditions and chemistry. Critical load thresholds are essentially a level of atmospheric pollutant deposition below which negative ecosystem effects are not likely to occur. FLAG (2010) does not include any critical load levels for specific Class I areas and refers to site-specific critical load information on FLM websites for each area of concern. This guidance does, however, recommend the use of deposition analysis thresholds (DATs) developed by the National Park Service (NPS) and the FWS. The DATs represent screening level values for nitrogen and sulfur deposition from Project-alone emission sources below which estimated impacts are considered negligible. The DAT established for both nitrogen and sulfur in western Class I areas is 0.005 kilograms per hectare per year (kg/ha-yr).
In addition to the Project-specific analysis, critical load thresholds established for the Rocky Mountain region may also determine total deposition impacts. The NPS has provided recent information on nitrogen critical load values applicable for Wyoming Class I areas (NPS, 2014). For Class I areas in Wyoming, a critical load value of 2.2 kg/ha-yr for nitrogen deposition (estimated from a wet deposition critical load value of 1.4 kg N/ha-yr) is applicable, based on research conducted by Saros et. al. (2010) in the eastern Sierra Nevada and Greater Yellowstone ecosystems. This is a critical load value that is protective of high elevation surface waters.
For sulfur deposition current critical load values have not been established for the Rocky Mountain region. For this Project the critical load threshold published by Fox et al. (1989) for total sulfur of 5 kg/ha-yr, for the Bob Marshall Wilderness Area in Montana and Bridger Wilderness Area in Wyoming, is used as the critical load threshold for cumulative source impacts at Class I areas. This value is likely an overestimate of a current representative critical load value for the region.
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3.2.1.2.4 New Source Performance Standards Under Section 111 of the Clean Air Act, the EPA has promulgated technology-based emissions standards which apply to specific categories of stationary sources. These standards are referred to as New Source Performance Standards (NSPS; 40 CFR Part 60). The NSPS potentially applicable to the Project include the following subparts of 40 CFR Part 60:
• Subpart A – General Provisions; • Subpart Kb – Standards of Performance for Volatile Organic Storage Vessels; • Subpart JJJJ – Standards of Performance for Stationary Spark-Ignition Internal Combustion Engines; • Subpart OOOO – Standards for Crude Oil and Natural Gas Production Sources; and • Proposed Subpart OOOOa – Standards for Crude Oil and Natural Gas Production Sources. Subpart A – General Provisions. Provisions of Subpart A apply to the owner or operator of any stationary source which contains an affected facility. The provisions apply to facilities that commenced construction or modification after the date of publication of any proposed standard. Provisions of Subpart A apply to proposed Project sources that are affected by NSPS.
Subpart Kb – Volatile Organic Liquid Storage Vessels. Subpart Kb applies to storage vessels with a capacity greater than or equal to 75 cubic meters (m3) that are used to store volatile organic liquids for which construction, reconstruction, or modification is commenced after July 23, 1984. This subpart is applicable to storage tanks for natural gas liquids.
Subpart JJJ – Spark Ignition Internal Combustion Engines. Subpart JJJJ establishes emission standards and compliance schedules for the control of emissions from spark ignition (SI) internal combustion engines (ICE). The rule requires new engines of various horsepower classes to meet increasingly stringent nitrogen oxides and volatile organic compound (VOC) emission standards over the phase-in period of the regulation. Owners and operators of stationary SI ICE that commenced construction, modification, or reconstruction after June 12, 2006 are subject to this rule; standards will depend on the engine horsepower and manufacture date. This regulation applies to central compressor engines, wellhead and lateral compressor engines, and artificial lift engines as well as any other miscellaneous engines that are stationary, spark-ignited natural gas-powered engines. Therefore, provisions of Subpart JJJJ apply to proposed SI ICE sources in the Project Area.
Subpart OOOO – Crude Oil and Natural Gas Production Sources. Effective October 15, 2012 with related amendments through July 31, 2015, the NSPS Subpart OOOO regulates VOC emissions from common sources in oil and gas upstream and midstream facilities that include well sites and natural gas processing plants. It also regulates sulfur dioxide emissions from sweetening units at onshore natural gas processing plants. The emission sources affected by Subpart OOOO include well completions, pneumatic controllers, equipment leaks from natural gas processing plants, sweetening units at natural gas processing plants, reciprocating compressors, centrifugal compressors and storage vessels at facilities which are constructed, modified or reconstructed after August 23, 2011. Well completions subject to Subpart OOOO are limited to hydraulic fracturing or re-fracturing completion operations at natural gas wells.
Subpart OOOOa – Crude Oil and Natural Gas Production Sources. Effective August 2, 2016, NSPS Subpart OOOOa (EPA, 2016) regulates VOC and methane emissions from oil and gas upstream and midstream facilities constructed, modified, or reconstructed. Newly regulated
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emission sources includes 1) fugitive emissions from well sites and compressor stations, 2) hydraulically fractured or re-fractured oil well completions, 3) pneumatic pumps, and 4) compressors and pneumatic controllers at natural gas transmission compressor stations and gas storage facilities. 3.2.1.2.5 Non-Road Engine Tier Standards The EPA sets emissions standards for non-road diesel engines for hydrocarbons, nitrogen dioxide, carbon monoxide, and particulate matter. The emissions standards are implemented in tiers by year, with different standards and start years for various engine power ratings. The new standards do not apply to existing non-road equipment. Only equipment built after the start date for an engine category (1999-2006, depending on the category) is affected by the rule. Over the life of the Project, the fleet of non-road equipment would turn over and higher-emitting engines would be replaced with lower-emitting engines. 3.2.1.2.6 Wyoming Oil and Gas Permitting Guidance The Project Area lies entirely within western Sublette County in Wyoming; this area is part of the State of Wyoming-defined UGRB and is therefore subject to permitting guidance and restrictions of emissions set forth in the WDEQ-AQD’s May 2016 Oil and Gas Production Facilities Chapter 6, Section 2 Permitting Guidance (WDEQ, 2016). The Guidance states, “Presumptive BACT (Best Available Control Technology) permitting requirements…apply to facilities with associated wells with the first date of production (FDOP) on/after July 1, 2016 and to facilities with a modification occurring on/after July 1, 2016. Startup or modification of a facility may occur prior to obtaining an Air Quality Permit or Waiver only when the Presumptive BACT permitting requirements under this Guidance are met. Otherwise, an Air Quality Permit or Waiver shall be obtained prior to start up or modification of a facility.”
The Guidance establishes presumptive BACT requirements for emissions from the following source categories:
• Tank Flashing. VOC and HAP flashing emissions shall be controlled by at least 98%. Tanks for emergency or upset condition use are not subject to these requirements, and control devices may be removed with approval after one year if VOC flashing emissions will be less than 4 tons per year (tpy). • Dehydration Units. All VOC and HAP emissions from dehydration unit process vents must be controlled by at least 98%. Controls may not be removed. • Pneumatic Pumps. VOC and HAP emissions from discharge streams of all natural gas- operated pneumatic pumps shall be controlled by at least 98% or the pump discharge streams shall be routed into a closed loop system. For removable combustion units, the control method for pump emissions will be evaluated upon request for approval to remove the combustion unit. • Pneumatic Controllers. New or modified facilities must be equipped with low- or no-bleed controllers, or controller discharge stream shall be routed to a closed loop system. • Produced Water Tanks. VOC and HAP emissions from all active produced water tanks must be controlled by at least 98%. • Fugitives. New and modified facilities where fugitive emissions are greater than or equal to 4 tpy of VOCs shall submit a Fugitive Emissions Monitoring (FEM) Protocol that must be approved by the Division.
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• Well Drilling/Completions. WDEQ-AQD will issue one air quality permit to each company that drills and completes wells. • Blowdown/Venting. BMPs and information gathering requirements will be incorporated into permits for new and modified facilities. • Emission Sources without Presumptive BACT requirements. For uncontrolled sources emitting greater than or equal to 4 tpy VOC that do not have Presumptive BACT requirements, a BACT analysis shall be filed with the permit application for the associated facility. 3.2.1.2.7 National Emission Standards for Hazardous Air Pollutants Under Section 112 of the Clean Air Act, the EPA has promulgated emissions standards for HAPs which apply to specific source categories. These standards are referred to as National Emission Standards for Hazardous Air Pollutants (NESHAPS) and are codified in 40 CFR Part 63. Applicable to this Project is 40 CFR Part 63 Subpart HH, National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities. Subpart HH sets standards for benzene, ethylbenzene, toluene, and xylene (BTEX) at gas well facilities and natural gas processing plants. Sources regulated include existing and new, small and large glycol dehydrators at major and area sources, certain storage vessels at major sources, and compressors and ancillary equipment in VOC/HAP service at major sources. 3.2.1.2.8 Greenhouse Gases and Climate Change Climate change is a statistically-significant and long-term change in climate patterns. The terms climate change and “global warming” are often used interchangeably, although they are not the same thing. Climate change is any deviation from the average climate, whether warming or cooling, and can result from both natural and human (anthropogenic) sources. Natural contributors to climate change include fluctuations in solar radiation, volcanic eruptions, and plate tectonics. Global warming refers to the apparent warming of climate observed since the early 20th century and is primarily attributed to human activities such as fossil fuel combustion, industrial processes, and land use changes.
The natural greenhouse effect is critical to the discussion of climate change. The greenhouse effect refers to the process by which greenhouse gases (GHGs) in the atmosphere absorb heat energy radiated by Earth’s surface and re-radiate some of that heat back toward Earth, causing temperatures in the lower atmosphere and on the surface of Earth to be higher than they would be without atmospheric GHGs. These GHGs trap heat that would otherwise be radiated into space, causing Earth’s atmosphere to warm and making temperatures suitable for life on Earth. Without the natural greenhouse effect, the average surface temperature of Earth would be about 0˚F. Higher concentrations of GHGs amplify the heat-trapping effect resulting in higher surface temperatures. Water vapor is the most abundant GHG, followed by carbon dioxide, methane, nitrous oxide, and several trace gases. Water vapor, which occurs naturally in the atmosphere, is often excluded from the discussion of GHGs and climate change because its atmospheric concentration is largely dependent upon temperature rather than being emitted by specific sources. Other GHGs, such as carbon dioxide and methane, occur naturally in the atmosphere and are also emitted into the atmosphere by human activities.
Atmospheric concentrations of naturally-emitted GHGs have varied for millennia and Earth’s climate has fluctuated accordingly. However, since the beginning of the industrial revolution around 1750, human activities have significantly increased GHG concentrations and introduced man-made compounds that act as GHGs in the atmosphere. The atmospheric concentrations of carbon dioxide, methane, and nitrous oxide have increased to levels unprecedented in at least
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the last 800,000 years. From pre-industrial times until today, the global average concentrations of carbon dioxide, methane, and nitrous oxide in the atmosphere have increased by around 40 percent, 150 percent, and 20 percent, respectively (Intergovernmental Panel on Climate Change – IPCC, 2013).
Human activities emit billions of tons of carbon dioxide every year. Carbon dioxide is primarily emitted from fossil fuel combustion, but has a variety of other industrial sources. Methane is emitted from oil and natural gas systems, landfills, mining, agricultural activities, and waste and other industrial processes. Nitrous oxide is emitted from anthropogenic activities in the agricultural, energy-related, waste, and industrial sectors. The manufacture of refrigerants and semiconductors, electrical transmission, and metal production emit a variety of trace GHGs including hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. These trace gases have no natural sources and come entirely from human activities. Carbon dioxide, methane, nitrous oxide, and the trace gases are considered well-mixed and long-lived GHGs.
Several gases have no direct effect on climate change, but indirectly affect the absorption of radiation by impacting the formation or destruction of GHGs. These gases include carbon monoxide, oxides of nitrogen, and non-methane volatile organic compounds. Fossil fuel combustion and industrial processes account for the majority of emissions of these indirect GHGs. Unlike other GHGs, which have atmospheric lifetimes on the order of decades, these gases are short-lived in the atmosphere.
Atmospheric aerosols, or particulate matter (PM), also contribute to climate change. Aerosols directly affect climate by scattering and absorbing radiation (aerosol-radiation interactions) and indirectly affect climate by altering cloud properties (aerosol-cloud interactions). Particles less than 10 micrometers in diameter (PM10) typically originate from natural sources and settle out of the atmosphere in hours or days. Particles smaller than 2.5 micrometers in diameter (PM2.5) often originate from human activities such as fossil fuel combustion. These so-called “fine” particles can exist in the atmosphere for several weeks and have local, short-term impacts on climate. Aerosols can also act as cloud condensation nuclei, the particles upon which cloud droplets form. Light-colored particles, such as sulfate aerosols, reflect and scatter incoming solar radiation, having a mild cooling effect, while dark-colored particles (often referred to as “soot” or “black carbon”) absorb radiation and have a warming effect. There is also the potential for black carbon to deposit on snow and ice, altering the surface albedo (or reflectivity), and enhancing melting. There is high confidence that aerosol effects are partially offsetting the warming effects of GHGs, but the magnitude of their effects contributes the largest uncertainly to the understanding of climate change (IPCC, 2013).
Current understanding of the climate system comes from the cumulative results of observations, experimental research, theoretical studies, and model simulations. The IPCC Fifth Assessment Report (AR5) (IPCC, 2013) uses terms to indicate the assessed likelihood of an outcome ranging from exceptionally unlikely (0 to 1 percent probability) to virtually certain (99 to 100 percent probability) and level of confidence ranging from very low to very high. The findings presented in AR5 indicate that warming of the climate system is unequivocal and many of the observed changes are unprecedented over decades to millennia. It is certain that Global Mean Surface Temperature has increased since the late 19th century and virtually certain (99 to 100 percent probability) that maximum and minimum temperatures over land have increased on a global scale since 1950. The globally averaged combined land and ocean surface temperature data show a warming of 1.5°F. Human influence has been detected in warming of the atmosphere and the ocean, in changes in the global water cycle, in reductions in snow and ice,
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in global mean sea-level rise, and in changes in some climate extremes. It is extremely likely (95 to 100 percent probability) that human influence has been the dominant cause of the observed warming since the mid-20th century (IPCC, 2013). Findings from AR5 and reported by other organizations, such as the National Aeronautics and Space Administration (NASA) Goddard Institute for Space Studies (National Oceanic and Atmospheric Administration - NOAA, 2013), also indicate that changes in the climate system are not uniform and regional differences are apparent.
National Assessment of Climate Change. The U.S. Global Change Research Program released the third U.S. National Climate Assessment in May 2014. The Assessment summarizes the current state of knowledge on climate change and its impacts throughout the U.S. It was written by climate scientists and draws from a large body of peer-reviewed scientific research, technical reports, and other publicly available sources. The Assessment documents climate change impacts that are currently occurring and those that are anticipated to occur throughout this century. It also provides region-specific impact assessments for key sectors such as energy, water, and human health.
The Assessment summarizes their conclusions in a number of Key Messages (National Climate Assessment - NCA, 2014a), several of which are excerpted here:
• Global climate is changing and this change is apparent across a wide range of observations. The global warming of the past 50 years is primarily due to human activities. • Global climate is projected to continue to change over this century and beyond. The magnitude of climate change beyond the next few decades depends primarily on the amount of heat-trapping gases emitted globally, and how sensitive the Earth’s climate is to those emissions. • U.S. average temperature has increased by 1.3°F to 1.9°F since record keeping began in 1895; most of this increase has occurred since about 1970. The most recent decade was the nation’s warmest on record. Temperatures in the United States are expected to continue to rise. Because human-induced warming is superimposed on a naturally varying climate, the temperature rise has not been, and will not be, uniform or smooth across the country or over time. • Average U.S. precipitation has increased since 1900, but some areas have had increases greater than the national average, and some areas have had decreases. More winter and spring precipitation is projected for the northern United States, and less for the Southwest, over this century. • Global sea level has risen by about 8 inches since reliable record keeping began in 1880. It is projected to rise another 1 to 4 feet by 2100. • The oceans are currently absorbing about a quarter of the carbon dioxide emitted to the atmosphere annually and are becoming more acidic as a result, leading to concerns about intensifying impacts on marine ecosystems. The Assessment provided analysis of projected climate change by region, and the Project is part of the Great Plains region. The Key Messages for this region (NCA, 2014b) are as follows:
• Rising temperatures are leading to increased demand for water and energy. In parts of the region, this will constrain development, stress natural resources, and increase competition for water among communities, agriculture, energy production, and ecological needs.
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• Changes to crop growth cycles due to warming winters and alterations in the timing and magnitude of rainfall events have already been observed; as these trends continue, they will require new agriculture and livestock management practices. • Landscape fragmentation is increasing, for example, in the context of energy development activities in the northern Great Plains. A highly fragmented landscape will hinder adaptation of species when climate change alters habitat composition and timing of plant development cycles. • Communities that are already the most vulnerable to weather and climate extremes will be stressed even further by more frequent extreme events occurring within an already highly variable climate system. • The magnitude of expected changes will exceed those experienced in the last century. Existing adaptation and planning efforts are inadequate to respond to these projected impacts. Project Greenhouse Gas Emissions and Climate Change. GHGs projected to be emitted by Project sources are carbon dioxide, methane, and nitrous oxide. In 2007, the U.S. Supreme Court ruled in Massachusetts v. EPA that the EPA has the authority to regulate GHGs such as methane and carbon dioxide as air pollutants under the Clean Air Act. The ruling did not, however, require the EPA to create any emission control standards or ambient air quality standards for GHGs. At present there are no ambient air quality standards for GHGs. However, EPA New Source Performance Standards for oil and gas emission sources (EPA, 2016) will limit methane emissions and these methane emission limits would apply to the sources developed under the Project. In addition there are applicable reporting requirements under the EPA’s Greenhouse Gas Reporting Program. These GHG emission reporting requirements, finalized in 2010 under 40 CFR Part 98, will require Operators to develop and report annual methane and carbon dioxide emissions from equipment leaks and venting, and emissions of carbon dioxide, methane, and nitrous oxide from flaring, onshore production stationary and portable combustion emissions, and combustion emissions from stationary equipment.
CEQ recently released final guidance for federal agencies on consideration of GHGs and the effects of climate change in NEPA documents (CEQ, 2016). While the guidance provides federal agencies with significant discretion on how to consider the effects of GHG emissions and climate change in their evaluation of proposals for federal actions, it also provides an expectation of what should be considered and disclosed. Agencies are directed to consider two separate issues when addressing climate change: (1) the potential effects of a proposed action on climate change as indicated by its GHG emissions; and (2) the effects of climate change on a proposed action and its environmental impacts. Agencies should consider the climate change effects of a proposal by comparing the GHG emissions of the proposed action and the reasonable alternatives. The effects of climate change on the proposed action and alternatives should be considered during the analysis of the affected environment. Land managers should consult the CEQ guidance for information on direct, indirect, and cumulative impact analyses, among other topics.
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Renewable and nonrenewable resource management actions have the potential to impact climate change due to GHG emissions and other anthropogenic effects. However, the assessment of GHG emissions and climate change is extremely complex because of the inherent interrelationships among its sources, causation, mechanisms of action, and impacts. Emitted GHGs become well-mixed throughout the atmosphere and contribute to the global atmospheric burden of GHGs. Given the global and complex nature of climate change, it is not possible to attribute a particular climate impact in any given region to GHG emissions from a particular source. The uncertainty in applying results from Global Climate Models to the regional or local scale (a process known as downscaling) limits our ability to quantify potential future impacts from GHGs emissions at this scale. When further information on the impacts of local emissions to climate change is known, such information would be incorporated into Forest Service planning and NEPA documents as appropriate.
The environmental impacts of GHG emissions from oil and gas refining and from consumption, such as from vehicle operations, are not effects of Forest Service actions related to oil and gas development as defined by the CEQ because they do not occur at the same time and place as the action. Thus, GHG emissions from refining and consumption of oil and gas do not constitute a direct effect that is analyzed under NEPA. Nor are refining and consumption an indirect effect of oil and gas production because production is not a proximate cause of GHG emissions resulting from refining and consumption. 3.2.1.3 Monitored Air Pollutant Concentrations Monitoring of air pollutant concentrations has been conducted in the Project Area region. These monitoring sites are part of several monitoring networks overseen by state and federal agencies, including: WDEQ (State of Wyoming), Clean Air Status and Trends Network (CASTNET), Interagency Monitoring of Protected Visual Environments (IMPROVE), and the National Acid Deposition Program (NADP) National Trends Network (NTN).
Air pollutants monitored at these sites include carbon monoxide, nitrogen dioxide, ozone, PM10, PM2.5, and sulfur dioxide. Background concentrations of these pollutants define ambient air concentrations in the region and establish existing compliance with ambient air quality standards. The most representative monitored regional background concentrations available for criteria pollutants as identified by WDEQ (2015c) are shown in Table 3.2-8.
3.2.1.4 Monitored Visibility Visibility conditions can be measured as standard visual range, the farthest distance at which an observer can just see a black object viewed against the horizon sky; the larger the standard visual range, the cleaner the air. Visibility for the region is considered to be very good. Continuous visibility-related optical background data have been collected in the PSD Class I Bridger Wilderness Area (the closest Class I area to the Project Area), as part of the IMPROVE program. The average standard visual range at Bridger Wilderness Areas is over 200 kilometers (Visibility Information Exchange Web System – VIEWS, 2016).
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Table 3.2-8 Background ambient air quality concentrations (µg/m3) Measured Background Pollutant Averaging Period Concentration
1 1-hour 572 Carbon monoxide 8-hour 343
2 1-hour 20.7 Nitrogen dioxide Annual 1.4 Ozone3 8-hour 125.6
4 24-hour 31 PM10 Annual 7.9
5 24-hour 17.2 PM2.5 Annual 5.9 1-hour 15.7 6 3-hour 11.4 Sulfur dioxide 24-hour 2.9 Annual 0.8 1 Data collected during 2014 at North Cheyenne Soccer complex (Ncore), Cheyenne Wyoming; concentrations are maximum values. 2 Data collected at Juel Spring, Wyoming: 1-hour concentration is the three year average (2012-2014) of daily maximum 98th percentile 1-hour concentrations, annual value is for 2014. 3 Data collected at Juel Spring, Wyoming: 8-hour concentration is the three year average (2012-2014) of the fourth-highest daily maximum 8-hour concentrations. 4 Data collected at Boulder, Wyoming during 2014, 24-hour value is maximum concentration. 5 Data collected at Pinedale, Wyoming: 24-hour value is the three year average (2012- 2014) of daily maximum 98th percentile 24-hour concentrations, annual value is three year average of annual means (2012-2014). 6 Data collected at Ncore, Cheyenne Wyoming; 1-hour value is the three year average (2012-2014) of daily maximum 98th percentile 1-hour concentrations, 3-hour, 24-hour and annual concentrations were collected during 2014, 3-hour and 24-hour data are second-highest maximum values. 3.2.1.5 Monitored Atmospheric Deposition Atmospheric deposition refers to the processes by which air pollutants are removed from the atmosphere and deposited on terrestrial and aquatic ecosystems, and it is reported as the mass of material deposited on an area per year (kg/ha-yr). Air pollutants are deposited by wet deposition (precipitation) and dry deposition (gravitational settling of pollutants). The chemical components of wet deposition include sulfate, nitrate, and ammonium; the chemical components of dry deposition include sulfate, sulfur dioxide, nitrate, ammonium, and nitric acid.
The NADP and the NTN station monitors wet atmospheric deposition and the CASTNET station monitors dry atmospheric deposition at a site near Pinedale (station PND165). The total annual nitrogen and sulfur deposition (wet and dry) derived from CASTNET and NADP/NTN measurements for the monitoring period of record (1990 through 2013) are shown in Figure 3.2- 2 and 3.2-3.
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Source: Views 2016. Figure 3.2-2 Annual Nitrogen Deposition (kg/ha-yr) at Pinedale, PND165 (1990–2013)
Source: Views, 2016. Figure 3.2-3 Annual sulfur deposition (kg/ha-yr) at Pinedale, PND165 (1990–2013)
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3.2.2 Environmental Consequences 3.2.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. Therefore, the types and amounts of Project-related emissions and impacts to air quality described below for the Proposed Action and other alternatives would not occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue, including those associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.2.2.2 Proposed Action Air emissions inventories were developed for the Lander Peak Area Project to quantify emissions resulting from Project construction and production. Air quality modeling performed for the Jonah Year-Round Development Project (BLM, 2016a) provided an estimate of air quality impacts which would occur locally from construction and operation of the Project. Air pollutant impacts and AQRV impacts (impacts on visibility, atmospheric deposition and potential increases in acidification to acid-sensitive lakes) at nearby Class I and sensitive Class II areas were evaluated and compared to applicable air quality modeling assessment results that were prepared in support of the Pinedale Anticline Oil and Gas Exploration and Development (PAP) Final Supplemental EIS (BLM, 2008). 3.2.2.2.1 Impact Significance Criteria Air quality impacts from pollutant emissions are limited by regulations, standards, and implementation plans established under the federal Clean Air Act, as administered by the WDEQ-AQD under authorization of the EPA. Under the National Forest Management Act (NFMA) and the Clean Air Act, the Forest Service cannot conduct or authorize any activity which does not conform to all applicable local, state, tribal, or federal air quality laws, statutes, regulations, standards or implementation plans. As such, significant impacts to air quality from the proposed Project-related activities would result if it is demonstrated that:
• NAAQS or WAAQS would be exceeded; or • Class I or Class II PSD Increments would be exceeded; or • AQRVs would be impacted beyond acceptable levels.
All NEPA analysis comparisons to the PSD Class I and II increments are intended to evaluate a threshold of concern, and do not represent a regulatory PSD Increment Consumption Analysis. The determination of PSD increment consumption is an air quality regulatory agency responsibility. Such an analysis would be conducted to determine minor source increment consumption or, for major sources, as part of the NSR process. The NSR process would also include an evaluation of potential impacts to AQRVs such as visibility, aquatic ecosystems, flora, fauna, etc. performed under the direction of FLMs. 3.2.2.2.2 Emissions Inventory Development Maximum annual field-wide criteria pollutant (carbon monoxide, nitrous oxides, sulfur dioxide, PM10 and PM2.5), VOC, and HAP (benzene, toluene, ethyl benzene, xylene, n-hexane, and formaldehyde) emissions were calculated for the maximum annual period of construction and development. The maximum field-wide construction emissions are expected to occur from construction of Well Pad 23-15, which has a proposed land disturbance area of 3.32 acres,
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compared to Well Pad 42-27 (2.18 acre disturbance from expansion). The criteria pollutant and total HAP emissions for well development activities from Well Pad 23-15 are shown in Table 3.2-9. The HAP emissions include benzene, toluene, ethyl benzene, xylene, n-hexane, and formaldehyde emissions, which are; 0.007, 0.003, <0.001, 0.002, 0.001, and 4.61 tpy, respectively, for the construction phase.
Table 3.2-9 Emissions (tpy) for Well Pad 23-15 Activity PM10 PM2.5 NOx CO SO2 VOC HAPs Well Pad Construction 0.32 0.04 0.14 0.27 0.01 0.01 <0.001 Gathering Line Construction 0.05 0.01 0.05 0.04 0.001 0.01 <0.001 Drilling 5.02 0.87 10.83 7.40 0.40 0.55 0.01 Completion 6.14 0.70 1.93 1.77 0.03 0.21 4.60 Total Development 11.53 1.62 12.95 9.48 0.44 0.78 4.61
Well pad construction PM10 and PM2.5 emissions would be approximately 20 percent less for Well Pad 42-27 than those shown above for Well Pad 23-15 due to the reduced disturbance area size.
The maximum field-wide production emissions would occur when both wells are in production. The criteria pollutant and total HAP emissions for production activities are shown in Table 3.2- 10. The HAP emissions include benzene, toluene, ethyl benzene, xylene, n-hexane, and formaldehyde emissions, which are; 0.15, 0.36, 0.02, 0.32, 0.04, and 0.006 tpy, respectively for the production phase.
Table 3.2-10 Maximum Well Production Emissions (tpy) Activity PM10 PM2.5 NOx CO SO2 VOC HAPs Workover Rig Engines 0.02 0.02 0.54 0.34 0.02 0.02 <0.001 Production Traffic 4.17 0.47 0.52 0.39 <0.01 0.05 <0.001 Separator Heaters <0.01 <0.01 0.01 0.01 <0.01 <0.01 0.001 Tank Heaters <0.01 <0.01 0.04 0.02 <0.01 0.01 0.002 Dehy Reboiler Heaters 0.01 0.01 0.09 0.07 <0.01 <0.01 0.002 Dehy Flash Tank Heaters <0.01 <0.01 0.01 0.01 <0.01 <0.01 <0.001 Dehy Flashing 0.07 0.07 1.42 3.75 <0.01 8.26 0.830 Production Fugitives <0.01 <0.01 <0.00 <0.01 <0.01 0.08 0.0001 Water Transfer Pumps 0.02 0.02 0.74 0.15 <0.01 0.05 0.006 Condensate Tank Storage 0.02 0.02 0.47 1.25 <0.01 2.23 0.062 Condensate Loading <0.01 >0.01 <0.01 <0.01 <0.01 <0.01 <0.001 Condensate Transport 0.06 0.01 0.01 0.01 <0.01 <0.01 <0.001 Total Production 4.37 0.62 3.85 6.00 0.02 10.72 0.904
Greenhouse Gases. As part of the development of the Project emission inventory, an inventory of carbon dioxide, methane, and nitrous oxide emissions from field construction and production was prepared. The GHG inventory is presented here for informational purposes and is compared to other U.S. GHG emission inventories in order to provide context for the Project GHG emissions.
Emissions of the greenhouse gases carbon dioxide, methane, and nitrous oxide are quantified in terms of CO2 equivalents (CO2e). Measuring emissions in terms of CO2e allows for the comparison of emissions from different greenhouse gases based on their Global Warming Potential (GWP). GWP is defined as the cumulative radiative forcing of a gas over a specified
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time horizon relative to a reference gas resulting from the emission of a unit mass of gas. The reference gas is taken to be CO2. The CO2e emissions for a greenhouse gas are derived by multiplying the emissions of the gas by the associated GWP. The GWPs for the inventoried greenhouse gases are carbon dioxide:1, methane:25, nitrous oxide:298 (EPA, 2014c). Greenhouse gas emissions for construction and production activities are shown in Table 3.2-11.
Table 3.2-11 Lander Peak Area GHG (CO2e) Emissions (metric tons per year) Construction Production Lander Peak Area Project 1,530.8 1,778.2 3.2.2.2.3 Conformity Analysis Because the Lander Peak Project is located within a federal air quality nonattainment area and the Forest Service must approve development of the Project, a conformity evaluation is required in accordance with the Clean Air Act Section 176(c) and WAQSR Chapter 8 Section 3. Air emissions from the Project have been evaluated to determine if they conform to the State Implementation Plan for the Upper Green River Basin Ozone Nonattainment Designation Area.
WAQSR Chapter 8 Section 3(c) establishes project air emission thresholds below which a proposed project would be presumed to conform to nonattainment area requirements and would not be required to prepare a formal conformity determination. For the Upper Green River Basin Ozone Nonattainment Designation Area, the conformity de minimis thresholds are 100 tons per year of nitrogen oxides or VOCs.
An applicability analysis was performed to evaluate total Project emissions for comparison to the de minimis thresholds. An air emissions inventory was developed which calculated emissions from construction (including drilling and completion), and well production for the Project. Emission sources permitted under New Source Review are excluded from the evaluation as specified in WAQSR Chapter 8 Section 3(c)(iv)(A). Maximum annual emissions from the Project subject to conformity were calculated to be 26.7 tons per year nitrogen oxides and 1.6 tons per year VOC.
All totals are less than the de minimis threshold of 100 tons per year; therefore, the Project is presumed to conform to nonattainment requirements and no conformity determination is required. 3.2.2.2.4 Near-Field Impacts The Lander Peak Area is located approximately 40 miles (northwest) from the Jonah Gas Field and both are located in the Upper Green River Basin ozone nonattainment area. A NEPA air quality analysis was prepared for the Jonah Gas Field in 2016 as part of a review of the Jonah Year-Round Development (YRD) Environmental Assessment (BLM, 2016a). As part of that analysis, a near-field ambient air quality impact assessment was performed to evaluate maximum air pollutant impacts from YRD Project Area resulting from proposed Project-related construction and production emissions. The YRD Project analyzed the construction and operation of 245 wells. Near-field modeling assessed impacts of both criteria pollutants (carbon monoxide, nitrogen dioxide, sulfur dioxide, PM10, and PM2.5) and HAPs.
Air quality modeling for Jonah YRD field construction sources predicted that project construction activities would be in compliance with the NAAQS and WAAQS for all pollutants. Impacts from Jonah YRD well production sources were shown to be below the NAAQS and WAAQS, and did not exceed the PSD Class II increments. HAP emissions resulting from Jonah YRD well
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construction and production were found to produce impacts that were below the HAP threshold exposure levels, and cancer risk levels would fall below the one-in-one-million cancer risk level approximately 0.25 miles from a well pad.
Because air emission sources which would be present during construction and operation of the Lander Peak Area Project and the Jonah YRD would be similar, and because the Lander Peak Area Project includes two single wells, compared to 245 wells on multi-well pads analyzed for the Jonah YRD, impacts assessed in the Jonah YRD EA were considered to be a conservative estimate of maximum impacts from the Lander Peak Area sources. Consequently, the Lander Peak Area Project would be expected to demonstrate compliance with NAAQS, WAAQS, and HAP thresholds throughout the construction and production phases of the Project. 3.2.2.2.5 Far-Field Impacts Far-field pollutant impacts were assessed at PSD Class I areas (Bridger, Fitzpatrick, Teton, and Washakie Wilderness Areas and Grand Teton and Yellowstone National Parks), and at the sensitive Class II Popo Agie Wilderness and Wind River Roadless areas in support of the PAP Final Supplemental EIS (BLM, 2008) using the CALPUFF model. The analyses included impact assessments to ambient air concentrations, and AQRVs (visibility, acid deposition, and lake acidity - at sensitive lakes within the Wilderness Areas) from air pollutant emissions of NOx, SO2, PM10 and PM2.5 expected to result from the PAP. The modeling results are applicable for evaluating the potential impacts from the Lander Peak Area Project.
PSD Increment Comparison. The maximum direct modeled concentrations of nitrogen dioxide (NO2), SO2, PM10, and PM2.5 at Class I and sensitive Class II areas resulting from the Lander Peak Area Project emissions would be less than the concentrations analyzed for the PAP Final Supplemental EIS (BLM, 2008) for the Alternative C “Phase 2 – 80 percent control on drill rig emissions reduction” scenario and would be below the applicable PSD Class I and Class II increments.
Visibility Impacts. Visibility impacts, at the nearby PSD Class I and sensitive Class II areas, resulting from the Lander Peak Area Project emissions would be less than impacts analyzed for the PAP Final Supplemental EIS (BLM, 2008) for the Alternative C - “Phase 2 - 80 percent control on drill rig emissions reduction” scenario.
Deposition Impacts. Potential direct atmospheric nitrogen and sulfur deposition impacts within Class I and sensitive Class II areas would be less than impacts analyzed for the PAP Final Supplemental EIS (BLM, 2008) for the Alternative C “Phase 2 – 80 percent control on drill rig emissions reduction” scenario. Impacts at sensitive lakes (Black Joe, Deep, Hobbs, Lazy Boy, and Upper Frozen lakes within the Bridger Wilderness Area, Ross Lake in the Fitzpatrick Wilderness Area, and Lower Saddlebag Lake in the Popo Agie Wilderness Area) would be below threshold values. 3.2.2.2.6 Regional Ozone Formation Potential ozone impacts resulting from the Project and other regional emissions have been predicted as part of the Continental Divide-Creston (CD-C) EIS (BLM, 2016b) and are discussed further in Section 4.4.1, below. 3.2.2.2.7 Greenhouse Gas Emissions and Climate Change The current scientific consensus is that the global climate is warming due to the influence of anthropogenic emissions of greenhouse gases. Current projections of future climate indicate that this warming trend is likely to continue and that there will be widespread impacts (NCA,
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2014a). Specific regional effects of climate change are uncertain but, in general, for the Great Plains region and Wyoming, “Rising temperatures are leading to increased demand for water and energy. In parts of the region, this will constrain development, stress natural resources, and increase competition for water among communities, agriculture, energy production, and ecological needs” (NCA, 2014b). It is not possible to attribute emissions of GHGs from any particular source to a specific climate impact, globally or regionally, due to the longevity of GHGs in the atmosphere. GHG emissions from all sources contribute to increased incremental concentrations in the Earth’s atmosphere and to the global climate response. It is currently not feasible to predict with certainty the net impacts from an individual project on global or regional climate. That is, while Forest Service actions may contribute to climate change, the specific effects of those actions on global or regional climate are not quantifiable. Therefore, the Forest Service does not have the ability to associate an action’s contribution in a localized area to impacts on global climate change. As climate models improve in their sensitivity and predictive capacity, the Forest Service will incorporate those tools into NEPA analysis at that time.
The total Project GHG emissions are presented for informational purposes and are compared to other U.S. GHG emission inventories in order to provide context for the Project GHG emissions. The maximum greenhouse gas emissions resulting from Project GHG emissions are estimated at 0.005 million metric tons (MMT) per year of CO2e emissions, resulting from production activities. To place the Project’s GHG emissions in context, the GHG emissions, during year 2014, from the top five emitting coal-fired power plants in Wyoming range from 3 to 14 MMT of CO2e (EPA, 2015c). 3.2.2.3 Mitigation Alternative Air quality impacts resulting from the Mitigation Alternative would be the same as those which would occur under the Proposed Action. Maximum potential near-field impacts and far-field impacts to air quality and AQRVs would be comparable to the impacts discussed for the Proposed Action and would be below the applicable air quality standards and thresholds. In addition there would be impacts to air quality and AQRVs during the year when groundwater monitoring wells are drilled and completed, however the impacts would be minor (less than impacts from natural gas exploration well drilling and production) and would only occur during days when monitoring well drilling occurs. Under the Mitigation Alternative, the Project would conform to nonattainment requirements and would not be subject to a conformity determination because, as under the Proposed Action, total emissions subject to conformity are below the 100 ton per year threshold.
3.3 ENVIRONMENTAL JUSTICE
3.3.1 Current Conditions Executive Order 12898 requires federal agencies to identify and address disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority and low-income populations. The U.S. Census Bureau estimated that racial minorities, which include persons of African American/Black, American Indian, Alaska Native, Asian, Native Hawaiian, other Pacific Islander, or multi-racial descent, comprised 5.2 percent of the population in Sublette County and 7.3 percent of the population in Wyoming in 2014. In that year, the Census Bureau estimated that persons of Hispanic origin, who may be of any race, comprised 8.1 percent of Sublette County’s population and 9.8 percent of Wyoming’s population (U.S. Census Bureau, 2015a).
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Household incomes in Sublette County tend to be higher than the state as a whole. In 2013, the median household income in Sublette County was $74,951, compared to a median household income of $58,424 in Wyoming. In 2013, low income populations, defined as individuals whose income during the previous 12 months fell below the poverty level, comprised 6.3 percent of Sublette County’s population and 10.9 percent of the statewide population (U.S. Census Bureau, 2015b).
3.3.2 Environmental Consequences 3.3.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to environmental justice from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.3.2.2 Proposed Action Because Sublette County has a lower portion of racial minority, Hispanic and low income populations than the state as a whole, the Project would not result in disproportionately high and adverse human health or environmental impacts on minority or low-income populations. 3.3.2.3 Mitigation Alternative Potential effects to environmental justice under the Mitigation Alternative would be the same as those described for the Proposed Action.
3.4 FIRE AND FUELS
3.4.1 Current Conditions The 2015 Bridger-Teton National Forest Fire Management Plan (Forest Service, 2015c) implements the standards and guidelines of the Forest Plan (Forest Service, 2015a) and helps achieve Forest resource management objectives. It is a decision support tool to help fire personnel and decision makers determine the management response to unplanned ignitions and provides specific details of the fire program.
The Forest is divided into five Fire Management Units (FMUs) which are differentiated by land management objectives, access, political boundaries and values to be protected. The FMUs are described below:
• FMU 1 – Wilderness: includes the Gros Ventre, Bridger, and Teton Wilderness Areas, plus the Shoal Creek Wilderness Study Area in the Gros Ventre range.
• FMU 2 – Front Country/Roaded Access: Encompasses those Forest lands that are adjacent to the valleys, which include other land ownerships and areas with access by motorized vehicles on forest road systems. These areas include developed recreation sites, special use permit area, timber base areas and dispersed development of private lands, lodges, and ranches.
• FMU 3 – Backcountry: Composed of mostly roadless areas and those areas with limited motorized vehicle access through gated or pen roads. Includes dispersed recreation,
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grazing allotments, timber base areas outside of DFC 1A & AB (DFC 10 and 12) wildlife habitat, and other resource management activities.
• FMU 4 – Palisades Wilderness Study Area: This area consists of mostly Targhee National Forest lands administered by the Forest along the western boundary of the forest, north of the Snake River and south of Teton Pass.
• FMU 5 – Protection: Includes Forest lands where there are increased risks to higher resource values, other land ownerships and complicating factors that require a suppression oriented response. These areas may involve urban interface, high value developed sites, or are managed for human use.
Lands within the Project Area are designated as FMU 2, 3, and 5 as shown on Map 3.4-1. In FMU 2, Front Country/Roaded Access, suppression activities should be only those necessary to control the fire and rehabilitation done under BAER guidance. In FMU 3, Backcountry, the response to wildland fire will consider positive and negative benefits from those actions to the key characteristics of each DFC such as developed and dispersed recreation, higher public use (due to road systems) and other resource values. In FMU 5, Protection, wildfires may be managed for benefits in relationship to fuels management treatments. General risk category is high in FMUs 2 and 5 and moderate in FMU 3.
Vegetation communities in the Project Area have been directly and indirectly affected by fire over the past 100 years; highest fire risks in the Project Area are the overstocked mixed conifer stands with saplings as ladder fuels. The possibility of ignition in mixed conifer and sagebrush/grass fuel types ranges from low to extreme, depending on weather conditions and patterns, current fire risk rating, moisture conditions, and fuel loadings. Most fires on the Forest occur between July and September, although in the last 20 years, fires have been reported as early as April and as late as October. In the June 1 through October 10 fire season, during the time period of 1988 to 2010, 67 percent of fires were lightning caused and 7 percent of those fires were > 10 acres. Campfires accounted for 23 percent of the fires during this time period (Forest Service, 2015c).
Two recent wildfires proximate to or including the Project Area are the 520-acre Triple fire in 2005 and the 65,220-acre Fontenelle fire in 2012 which were both human-caused (Teton Interagency Fire, 2015). Wildfire within the Project Area has been limited to 106 acres of the Triple Fire plus small fires ranging from 0.1 to 8 acres each, that burned in 1961, 1976, 1977, 1985, 1988 and 1993 (Forest Service, 2013a). In 2014 and 2015, there were 59 wildland fires reported on the Forest of which 27 were human caused (non-prescribed fires), 8 during 2014 and 19 during 2015 (Teton Interagency Fire, 2015).
3.4.2 Environmental Consequences 3.4.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related effects to fire and fuels from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing.
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Map 3.4-1 Fire Management Units
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3.4.2.2 Proposed Action Potential direct effects from the construction and operation of the Proposed Action include the possibility of Project-related fire. During initial surface disturbance, drilling, and subsequent production, ignition threats from heavy equipment and workers would pose the greatest risk to increasing the number of fires on the Forest, especially during dry summer months. Potential indirect effects include increased human access and presence in the area which increases the possibility of human-related wildfire. Water from the water supply well on Well Pad 13-16a would be available to support fire crews in the event of a fire. 3.4.2.3 Mitigation Alternative Potential effects from fire and fuels under the Mitigation Alternative are similar to those described above for the Proposed Action; however, under this alternative, True Oil would prepare and implement a site-specific fire management plan. The fire management plan would provide employee fire safety education to assist personnel in preventing and containing Project- related accidental ignitions.
3.5 GEOLOGIC RESOURCES
3.5.1 Current Conditions General Geology. The Lander Peak Unit is located in the mountainous Overthrust Belt of western Wyoming, along the western margin of the plains of the Green River Basin (Map 3.5-1). The Overthrust Belt is a major structural feature which extends from British Columbia, through Montana, Idaho, and Wyoming, and southeast into Utah. In general within the Overthrust Belt, geologic formations ranging in age from younger Mesozoic formations (including Triassic, Jurassic, and Cretaceous formations) to older Paleozoic formations were pushed eastward in a series of low-angle, westward-dipping, overlapping thrust faults. Stratigraphic displacements were up to 40,000 feet, and lateral movement was up to 45 miles. Folding and faulting also occurred within the formations. However, major fault breccia or gouge zones or evidence of metamorphosis of the formations are generally not present. The Green River Basin is an intermontane basin in western Wyoming filled with several thousand feet of generally flat-lying geologic strata ranging in age from younger Tertiary formations to older and Cretaceous formations. Along the western edge of the Basin, these formations were overridden by the thrust faults (Ahern et al., 1981).
The Overthrust Belt in the vicinity of the Lander Peak Unit is comprised of two thrust faults of major horizontal and stratigraphic displacement. From west to east, these are the Darby and Prospect faults. The surface area of the Lander Peak Unit is located on the Prospect Thrust Sheet, about 3 miles east of the surface expression of the Darby Thrust Fault and about 3 miles west of the surface expression of the Prospect Thrust Fault (Map 3.5-1). The thrust sheet is wedge-shaped, with the thinner portion of the sheet occurring to the east. Based on geologic cross-sections (Rubey, 1973a), the thickness of the thrust sheet underlying the Project Area ranges from about 5,000 feet on the eastern side of the Project Area to over 8,000 feet on the western side of the Project Area. As expected, the structural geology within the thrust sheet includes complex folding of sedimentary geologic formations and numerous faults of relatively minor displacement within the sheet. Beneath the thrust sheet, the structure is less complex, and the sedimentary geologic formations are relatively flat-lying. A geologic map of the area is included on Map 3.5-1, and two geologic cross-sections are included on Figure 3.5-1.
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Map 3.5-1 Geology
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Figure 3.5-1 Geologic Cross Sections
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Table 3.5-1 lists the stratigraphic units beneath the Project Area based on data from the existing wells and anticipated conditions in the proposed wells. The stratigraphy beneath the Project Area includes a relatively thin veneer of Quaternary alluvium and glacial till at the surface. These deposits overlie a series of geologic formations in the Prospect Thrust Sheet ranging in age from younger Upper Cretaceous formations down to older Triassic formations with descending depth. The Prospect thrust fault is about 6,000 feet below surface at the proposed drilling locations. The fault brings the older formations in the thrust sheet over younger formations of Tertiary age in the Green River Basin. These Tertiary formations are underlain by the same Upper Cretaceous and older formations found in the thrust sheet (Figure 3.5-1).
Essentially all of the geologic formations of interest are composed of sedimentary rocks and represent a range of depositional environments. There are considerable interbedding and transitional zones between some of the formations, and variations in stratigraphic nomenclature are noted in Table 3.5-1. The thickest of the formations in the Prospect Thrust Sheet are the Hilliard Shale and Frontier Formation (which are also described as the Blind Bull Formation), with combined thicknesses up to 2,000 feet. The thicknesses of the lower formations in the thrust sheet are generally much thinner (1,000 feet or less). Beneath the thrust fault, the Hilliard Shale and Frontier Formation are again the primary strata encountered.
Geologic Hazards. Geologic hazards in the vicinity of the Project Area include landslides and earthquakes. With respect to landslides, Map 3.5-2 shows the locations of landslide-related features, such as debris and talus flows, in the Project Area. The hillslope on the opposite side of South Fork Bare Creek from existing Well Pad 42-27 was affected in the past by debris flows and slumps (Map 3.5-2); however, the slope is revegetated indicating the features are not recent.
With respect to earthquakes, the occurrence and risk of natural seismic activity of appreciable magnitude or intensity is low. A comparison of earthquake magnitude and intensity is provided by the United States Geological Survey (USGS, 2016). Of the eighteen magnitude 2.5 or intensity III and greater earthquakes that have been recorded in Sublette County, none were within 20 miles of the Project Area. Because earthquake monitoring began relatively recently (in the early 1900s), other methods for assessing earthquake damage potential are considered more appropriate. Based on ground motion probability maps and specific fault analyses, it is anticipated that an Intensity VII earthquake could occur near Daniel, Wyoming, which is the closest site assessed. During an Intensity VII earthquake (using the Abridged Modified Mercalli Intensity Scale), damage is negligible in buildings of good design. Only in areas where the earthquake intensity increases to Intensity VIII or IX does damage such as changes in well waters and broken underground pipes become evident (Case et al., 2002).
Recent studies of induced seismic activity, such as that associated with wastewater disposal wells indicate that the potential for its occurrence is also low in the vicinity of the Proposed Action (Larsen and Wittke, 2014; Peterson et al., 2016).
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Table 3.5-1 Stratigraphy of the Lander Creek Unit Existing and Proposed Wells1
Bare Creek Unit Soda Unit Soda Unit Klaenhammer Soda Unit Klaenhammer Klaenhammer Soda Unit 42-27 13-16 13-16 23-15 23-15H 33-22 Fed 32-22 42-27H
Geologic 4 4 Age2 Geologic Strata3 Top Thck Top Thck Top Thck Top Thck Top Thck Top Thck Top Thck Top Thck
Alluvium and 5 Est. Est. Est. Q ------Surface ------Surface Surface Glacial Till <100 <100 <100
Hilliard 6 ------1,300 1,300 Blind Bull Shale Upper K Formation -- 2,100 6 Frontier 6 ------1,300 1,300 696 1,300 696 Formation
Aspen Shale 3,114 181 -- -- 1,290 176 2,100 650 2,148 148 -- -- 1,996 145 1,996 145 Dakota 7 2,141 186 2,141 186 Formation Lower K 3,295 1,155 -- -- 1,466 1,165 -- -- 2,296 514 -- 2,141 Bear River Formation7 2,327 333 2,327 333 Gannet Group 4,450 ------2,631 763 2,750 710 2,810 772 -- -- 2,660 738 2,660 738 Stump Sandstone -- -- 3,394 141 3,430 -- 3,582 76 -- -- 80 80 80 80 Upper J Preuss Redbeds -- -- 3,535 163 -- -- 3,658 198 -- -- 200 200 200 200 Twin Creek 8 3,698 831 Limestone Middle J ------3,856 979 -- -- 3,678 977 3,678 977 Gypsum Spring 8 4,529 140 Formation J/T Nugget Sandstone -- -- 4,669 891 -- -- 4,835 833 -- -- 921 921 921 921 Ankareh 9 5,560 282 5,668 322 Chugwate Formation Lower T 9 ------5,576 783 5,576 783 r Thaynes 9 5,842 20 -- -- Limestone
Tertiary Prospect Thrust Fault -- -- 5,862 -- 6,000 -- 5,990 ------6,195 -- --
Tertiary Fort Union -- -- 5,950 264 ------
Mesaverde Formation -- -- 6,214 -- 6,000 600 6,137 758 ------6,359 698 Upper K ? Sandstone10 6,600 300 ------
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Existing and Proposed Wells1
Bare Creek Unit Soda Unit Soda Unit Klaenhammer Soda Unit Klaenhammer Klaenhammer Soda Unit 42-27 13-16 13-16 23-15 23-15H 33-22 Fed 32-22 42-27H
Geologic 4 4 Age2 Geologic Strata3 Top Thck Top Thck Top Thck Top Thck Top Thck Top Thck Top Thck Top Thck Hilliard 6,900 -- 7,057 -- Shale Hot Hilliard 11 Hilliard 9,256 ≤ 555 -- -- 7,200 -- 6,895 -- 7,982 2,045 6943 3,059 -- -- Shale Marker Hilliard 7,325 -- 7,400 -- Silt Frontier -- 10,055 10,027 10,002 Frontier Formation Formation Frontier-1 9,811 ≥ 2,811 -- 10,116 -- 10,088 1,643 10,062 11 Frontier-2 10,292 10,540 10,480 10,505 Frontier-3 10,769 11,085 10,900 11,028 Bear River 11,922 168 11,670 598 Lower K Dakota Formation 12,090 135 12,268 -- Gannet Group 12,225 --
20” to 491’ 14-3/4” to 180’ 10-3/4” to 1,495’ 9-5/8” to 1,218’ 9-5/8” to 1,213’ Casing 13-3/8” to 737’ 9-5/8” to 1,315’ 10-3/4” to 545’ 7-5/8” to 6,056’ 5-1/2” to 11,993’ 5-1/2” to 11,557’ 5-1/2” to 10,557’ 5-1/2” to 10,272’ 5-1/2” to 12,570’
-- 11,086 - 12,445 Plugged & 10,070 - 10,110 Targeting Mesa Abandoned 9,232 - 10,557 Plugged & 10,584 - 10,596 10,575 - 11,154 Target 7,340 Verde Formation Target 7,404 Perforated or Producing Interval Targeting Frontier Abandoned Frontier Frontier Hilliard Shale but plugged Hilliard Shale Frontier Formation Frontier Formation Formation back to Frontier Formation but Formation Formation not completed 11,847 12,570 Total Vertical Depth3 4,582 14,298 Plugged back to 7,699 11,994 Plugged back to 11,573 7,604 10,272 12,175 Total Measured Depth (well length)4 ------11,700 ------19,658 Approximate Length of Horizontal 4 ------4,700 ------12,500 Section 1 Notes: Proposed wells are highlighted in grey. Geologic data for the existing wells obtained from the well records available from the WOGCC (2015). Geologic data for proposed wells obtained from the APDs for the wells (True Oil, 2012). 2 Geologic Ages: Q - Quaternary; K - Cretaceous; J - Jurassic; T- Triassic.
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Existing and Proposed Wells1
Bare Creek Unit Soda Unit Soda Unit Klaenhammer Soda Unit Klaenhammer Klaenhammer Soda Unit 42-27 13-16 13-16 23-15 23-15H 33-22 Fed 32-22 42-27H
Geologic 4 4 Age2 Geologic Strata3 Top Thck Top Thck Top Thck Top Thck Top Thck Top Thck Top Thck Top Thck 3 Variations in stratigraphic nomenclature are noted, along with references for more detail on the variations. 4 Formation tops and Total Vertical Depth are in feet below ground surface; thicknesses (Thck), Total Measured Depth, and horizontal lengths are in feet. 5 “--” indicates information not available from well records reviewed. 6 See Lines and Glass (1975) and Rubey (1973b) for additional information on the correlation of the Blind Bull Formation, Hilliard Shale, and Frontier Formation. 7 See Kirschbaum and Roberts (2005) for additional information on the correlation of the Bear Formation. 8 See Clary et al. (2010) for additional information on the correlation of the Gypsum Spring Formation and Twin Creek Limestone. 9 See Clary et al. (2010) for additional information on the correlation of the Chugwater Formation, Ankareh Formation, and Thaynes Limestone. 10 The APD for this proposed well lists this strata as the Nugget Sandstone; however, this would be inconsistent with the geologic setting, so this sandstone is probably within the Mesaverde Formation. 11 Stratigraphic markers, including the Hilliard Silt Top.
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Map 3.5-2 Landslides
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3.5.2 Environmental Consequences 3.5.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to geologic resources from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.5.2.2 Proposed Action The primary aspect of the Proposed Action that could have environmental consequences to the geologic resources is hydraulic fracturing. The fracturing could directly impact the geologic resources depending on the magnitude and orientation of the fractures created and the potential for induced seismicity during fracturing. Natural seismicity could also have environmental consequences to the Proposed Action; therefore, the discussion of potential environmental consequences related to seismicity includes damage from the Proposed Action as a result of induced seismicity and damage to the Proposed Action as a result of natural or induced seismicity. An indirect impact could be the potential for induced seismicity due to disposal of the fracturing fluid at a designated off-site location. 3.5.2.2.1 Fracture Magnitude and Orientation The Project would result in a permanent increase in the permeability of the target interval within the Hilliard Shale. The purpose of the hydraulic fracturing along specific sections of an oil and/or gas well is to improve the permeability of the target geologic formation, allowing for increased oil and gas flow to a well. Hydraulic fracturing programs are designed to fracture the target formation by injecting fluid under sufficient pressure to fracture the target formation, without excessive pressure which would be operationally inefficient and increase the potential for unanticipated consequences. The injected fluid generally consists of water, chemicals, such as surfactants to improve fluid movement, and a proppant, which is commonly sand. The proppant holds open the newly created fractures after the injection pressure is reduced, and oil and gas can flow through the fractures to the well. Oil and gas essentially cannot be produced from some formations, such as shales, without fracturing of the formation, and properly designed hydraulic fracturing operations are essential for economic and efficient recovery of oil and gas. Additional descriptions of hydraulic fracturing operations are available from EPA (2015d) and Forest Service (2016).
A concern expressed about hydraulic fracturing is the creation of large-scale fractures that, instead of increasing the permeability of the target formation, could connect the oil and gas producing formations with shallower formations that contain better quality water. This concern has been addressed in research into improvements of hydraulic fracturing techniques and into environmental impacts of fracturing. The magnitude and orientation of hydraulically induced fractures depends upon several factors, including the physical properties of the formations penetrated, existing fluids and pressure in the potential oil and gas reservoir, the trajectory of the well bore, and the fracturing techniques.
Evaluations of field data from hydraulic fracturing operations and mathematical modeling of fracture propagation indicate the potential for extensive interconnection of fractures from the
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target formation to geologic formations that are separated stratigraphically and by significant thicknesses is low (Davies et al., 2012; Maxwell, 2011). Recent work, using a new detection method, indicates that the risk of interconnection increases if a substantial system of vertical fractures exists prior to hydraulic fracturing (Davies et al., 2013a). It is unlikely that the Prospect Thrust Fault would provide such a system because the relatively low angle thrust plane parallels the stratigraphic bedding in many locations, the extent of breccia is limited (Ahern, 1981), and movement of fluids along the fault is not evident. 3.5.2.2.2 Natural and Induced Seismicity As noted in Section 3.5.1, the natural seismicity of the area is relatively low. Potential causes of induced seismicity include: oil and gas extraction; fluid injection for enhanced oil recovery; and hydraulic fracturing (Larsen and Wittke, 2014). In general, documented incidents of induced seismicity related to these activities are rare (National Resource Council, 2013 and Hall, 2015). With respect to oil and gas extraction, there has been no evidence for induced seismicity from the on-going oil and gas extraction in the area, and future extraction rates are not anticipated to be sufficient to increase the risk. With respect to fluid injection for enhanced oil recovery, no such enhancement of existing production is planned and is not anticipated if the Proposed Action indicates additional resources can be produced. Therefore, the following discussion of induced seismicity is focused on the potential environmental consequences of hydraulic fracturing.
The induced seismicity created by hydraulic fracturing is generally described as microseismicity or as below the threshold for being felt at the surface, due to the low magnitude and intensity. Documented magnitudes are generally less than 2, with a few incidents ranging up to a magnitude of about 4 (Davies et al., 2013b and Ground Water Protection Council - GWPC, 2015). For comparison, a magnitude 2.5 to 3 earthquake is generally considered the threshold at which earth movement can be felt at the ground surface under the most conditions (USGS, 2016).
Potential Consequences in the Subsurface. Two potential subsurface consequences due to natural seismicity and induced seismicity from hydraulic fracturing include changes to existing subsurface infrastructure (e.g., oil and gas wells) and, because of the proximity to the Prospect Thrust Fault, the potential for fault reactivation.
Subsurface Infrastructure. Damage to oil field facilities, as well as positive impacts on well production, as a result of earthquakes has been documented (e.g., Hamilton et al., 1969; Mirzaei-Paiaman and Nourani, 2012). Much of the available information on earthquake damage is from California. An earthquake in the 1980s near an oil production field in Coalingua, California illustrates the types of damage that could occur (BLM, 2014). A magnitude 6.7 quake triggered landslides, severely damaged pre-1945 buildings, and toppled chimneys. There was minor damage to electric and water utilities, although the power supporting the oil production was interrupted for several days. Anchored oil field equipment and pipelines suffered minor damage. Less than 5 percent of the over 900 active wells were found to have offsets cause by seismic activity.
More recently, there has been interest in the potential impacts of induced seismicity on the cement integrity in the vertical portion of a horizontal well that has been hydraulic fractured. Similar to the cement integrity in a convention well, the cement integrity in a well that has been hydraulically fractured depend on the quality of the well completion (Kim et al., 2016).
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Given the limited natural seismicity and low magnitude of potential induced seismicity anticipated in the vicinity of the Proposed Action, it is unlikely there would be any extensive damage to the subsurface infrastructure. In addition, the federal and state requirements for the well completions, including casing and cementing, reduce the potential for induced seismicity to adversely impact the integrity of the proposed wells.
Fault Reactivation. In addition to assessment of hydraulic fracturing impacts in the field, research has included computer models of situations in which hydraulic fracturing may intersect a fault. The model results indicate that generation of felt seismicity is unlikely (Cheng, 2012; Rutqvist et al., 2015). Microseismic measurements indicate a difference can be detected between seismicity generated by hydraulic fracturing and seismicity generated by fault movement in the vicinity of hydraulic fracturing (Maxwell et al., 2010). Based on this research, hydraulic fracturing is not anticipated to induce seismicity that could be felt at the surface.
Potential Consequences at the Surface. Two potential surface consequences due to natural seismicity and increased seismicity from hydraulic fracturing include renewed movement of landslides and damage to existing surface infrastructure (e.g., ditch diversions).
Landslides. With the exception of the proposed expansion of existing Well Pad 42-27, none of the mapped landslides are in the vicinity of the proposed activities (Map 3.5-2). Given the age of the debris flows and slumps and the limited natural seismicity and low magnitude of potential induced seismicity, it is unlikely there would be any additional landslides at existing Well Pad 42-27.
Surface Infrastructure. Given the limited natural seismicity and low magnitude of potential induced seismicity, it is unlikely there would be any damage to existing surface facilities, particularly given the lack of such facilities. 3.5.2.2.3 Induced Seismicity - Potential Consequences from Off-Site Activities A primary concern about oil and gas operations is the potential for induced seismicity related to injection of fluids in deep disposal wells (Petersen et al., 2016). No off-site disposal of fluids by deep injection is planned; therefore, no indirect environmental consequences are anticipated. The proposed method for off-site disposal of the fluids used for hydraulic fracturing and the associated produced water is trucking the fluids and produced water to the R360 Environmental Solutions facility in LaBarge, Wyoming. This facility uses surface pits for fluid disposal; therefore, no underground consequences are anticipated. 3.5.2.3 Mitigation Alternative For the Mitigation Alternative, the potential for environmental consequences to the geologic resources would be similar to those described for the Proposed Action but would be reduced. The surface and subsurface monitoring, well construction and fracturing techniques, and identified response options to detection of an anomaly during hydraulic fracturing would reduce the potential for aggravation of an unanticipated condition developing during fracturing.
3.6 INVASIVE, NON-NATIVE SPECIES AND NOXIOUS WEEDS
3.6.1 Current Conditions The State of Wyoming lists 26 plants as designated noxious weeds that the Wyoming Weed and Pest Council and Wyoming Board of Agriculture have found to be detrimental, destructive, injurious, or poisonous and should be controlled within the State of Wyoming. Sublette County Weed and Pest is responsible for implementing and pursuing an effective program for the
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control of designated weeds (Wyoming Weed and Pest Council, 2016). Sublette County Weed and Pest District identified six species that are non-native species (Sublette County, 2016) and should be controlled if documented. In 1999-2000, the Forest Service mapped noxious weed infestations in portions of the Forest in Teton County and along the Snake River and Gros Ventre River road corridors (Forest Service, 2000). No other mapped distribution of noxious weeds has been found. The maps did not include the Big Piney Ranger District and the Project Area. The Forest Service (2004) developed a comprehensive noxious weed control management plan to prevent and treat noxious weed infestations in the Forest. Seventeen noxious weed species on the Wyoming Designated Weed List, two species on the Sublette County Declared Weed List, and two other noxious weed species identified by the Forest Service were documented on the Forest (see Table 3.6-1). During July and August, 2011, surveys were conducted to locate invasive weed species designated by the Wyoming Weed and Pest Council for the State of Wyoming and Sublette County (see Table 3.6-1). Surveys focused on and around proposed Well Pads 42-27 and 23- 15 (Hayden-Wing, 2011); no invasive weed species were observed. Table 3.6-1 Noxious Weed Species that Could Occur within the Project Area Documented Common Name/ Sublette County on the Scientific Name 1 Characteristics 2 Status 3 Forest 4,5 State of Wyoming Designated Weed List May occur along Field Bindweed Occurs in cultivated fields and waste places; access roads; 1-100 Yes Convolvulus arvensis reproduces by seeds and root stalks. acres; increasing Common; 5,000- Canada Thistle Initially establishes itself in disturbed soils; 20,000 acres; Yes Cirsium arvense reproduces by seed and creeping rootstock. increasing Uncommon, may occur Leafy Spurge Grows in nearly all soil types and habitats; along access road; Yes Euphorbia esula reproduces by seed and rootstalks. 1-100 acres; increasing Common in gardens, cultivated crops, ditch Relatively common; Perennial Sowthistle banks, and fertile waste areas; reproduces 101-1000 acres; Yes Sonchus arvensis by seed and creeping roots. increasing Occurs in croplands, pastures, rangeland, Quackgrass and roadsides; reproduces by seed or 1-100 acres; static Yes Elymus (Agropyron) repens spreading by rhizomes. Hoary Cress (Whitetop) Prevalent in areas with alkaline or disturbed Prevalent; 1,000-5,000 Cardaria draba (C. soils; reproduces from seed and root Yes acres; increasing pubescens) segments. Occurs in riparian areas, waste areas, Perennial Pepperweed (giant Relatively common; ditches, roadsides, croplands, range and whitetop) 1,000-5,000 acres; Yes meadows, and disturbed areas; reproduces Lepidium latifolium increasing by seed and deep-seated rootstalks. Ox-eye Daisy Found in meadows, roadsides, and waste Scattered; 1-100 Chrysanthemum Yes places; reproduces by seed. acres; new traces leucanthemum Skeletonleaf Bursage Aggressive growth habits; spread mainly by No records; 0 acre; Ambrosia tomentosa creeping roots. never found Franseria discolor Occurs in a variety of habitats and forms Russian Knapweed colonies in cultivated fields, orchards, Scattered records Yes Centaurea repens pastures, and roadsides; reproduces by
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Documented Common Name/ Sublette County on the Scientific Name 1 Characteristics 2 Status 3 Forest 4,5 seeds and creeping rootstocks.
Occurs in rangelands, along roadsides, Yellow Toadflax Scattered; 1-100 waste places, and cultivated fields; Yes Linaria vulgaris acres; increasing reproduces by seed and creeping roots. Found along roadsides and on rangeland; Scattered records; Dalmation Toadflax reproduces by seed and underground 1-100 acres; Yes Linaria dalmatica rootstalks. increasing Scattered records – more common along Scotch Thistle Found along waste areas and roadsides; U.S. Highway 189; 1- Yes Onopordum acanthium very aggressive; reproduces by seed. 100 acres; possibly eradicated? Invades pastures, range and forest lands, Musk Thistle roadsides, waste areas, ditch banks, stream Common; 101-1,000 Yes Carduus nutans banks, and grain fields; reproduces rapidly acres; increasing by seed. Commonly found growing along roadsides, Common Burdock No records; 0 acre; ditch banks, in pastures and waste areas; Arctium minus never found reproduces by seed. Plumeless Thistle Occurs in pastures, stream valleys, fields, No records; 0 acre;
Carduus acanthoides and roadsides; reproduces by seed. never found Occurs along roadsides and disturbed sites Dyers Woad Very few records; 1- and spreads from there to rangeland and Yes Isatis tinctoria 100 acres; declining cropland by seeds. Scattered records; Houndstongue Found in pastures, along roadsides, and in 1-100 acres; Yes Cynoglossum officinale disturbed habitats; reproduces by seed. increasing Common along U.S. Spotted Knapweed Establish in disturbed soils; very aggressive; Highway 189 and 191; Yes Centaurea maculosa reproduces by seed. 1-100 acres; increasing Occurs along roadsides, waste areas, and Diffuse Knapweed Few records; 0 acre; dry rangelands and dominates disturbed . Centaurea diffusa eradicated? areas; reproduces by seed. Infest moist, marshy or wet areas such as Purple Loosestrife One record?; 0 acre; canals, ditches, or lake edges; reproduce by Lythrum salicaria never found seed. Invades wetlands, moist ranges, lake sides, Saltcedar (Tamarisk) Few records; 1-100 stream banks, sandbars, and other saline Tamarix spp. acres; new traces environments; reproduces by seed. Common St. Johnswort Frequently found on sandy or gravelly soils; No records; 0 acre; Yes Hypericum perforatum reproduce by seed or short runners. never found Found along roadsides, waste areas, stream Common Tansy Few records; 1-100 banks, and in pastures; reproduces from Yes Tanacetum vulgare acres; increasing seed and rootstalks. Russian Olive Invade low-lying pastures, meadows, or One record?; 1-100 Yes Elaeagnus angustifolia waterways; reproduces by seed. acres; static Black Henbane Common in pastures, along fencerows, Common; 101-1,000 Yes Hyoscyamus niger along roadsides, and waste areas. acres; increasing Sublette County Declared Weed List Common along U.S. Cheatgrass / Downy Brome Highways 189/191; Bromus tectorum 1,000-5,000 acres;
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Documented Common Name/ Sublette County on the Scientific Name 1 Characteristics 2 Status 3 Forest 4,5 increasing
Hoary Alyssum No records; 1-100
Berteroa incana acres; increasing Scentless Chamomile Can grow up to 3 feet tall. The root system Scattered records Matricaria perforate tends to be large and fibrous but does not along 189/191; 1-100 Yes Tripleurospermum perforatum run or creep. acres; new traces Found in sloughs, wet meadows, along Western Water Hemlock Fairly common; streams and other wet areas; poisonous to Cicuta douglasii unknown; static all types of livestock and to humans. A perennial that grows in grassland on well- Field Scabrious drained, especially basic soils; a member of One record?; 1-100 Yes Knautia arvensis the teasel family with a deeply-penetrating acres; eradicated woody taproot. A recent invasive plant in Sublette County; Austrian Fieldcress A few records; 1-100 reproduces vegetatively by creeping roots, Rorippa austriaca acres; increasing rarely by seed. Other Noxious Weeds on Bridger-Teton National Forest 5 Found in disturbed areas such as roadsides Sulfur Cinquefoil No records; 0 acre; and pastures; colonies are also often seen in Yes Potentilla recta eradicated undisturbed sites; flowers from May to July. Bull Thistle Occurs in pastures, roadsides, and disturbed Few records; 1-100 Yes Cirsium vulgare sites; reproduces by seed. acres; static Sources: 1 Sublette County, 2016. 2 Whitson et al., 1996. 3 Wyoming Weed and Pest Council, 2016; University of Wyoming, 2014. 4 Forest Service, 2000. 5 Forest Service, 2004.
3.6.2 Environmental Consequences 3.6.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. None of the Project-related effects resulting from invasive non-native species that are discussed below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.6.2.2 Proposed Action Alternative Soil disturbance and potential weed distribution due to surface disturbance, increased vehicle traffic, equipment placement and operation, foot traffic, and other activities associated with the Proposed Action could increase the presence of weed species and/or could introduce them into areas that are not currently infested with non-native species.
Clearing vegetation and exposing bare ground surfaces allows invasive species, particularly annuals, to become established at the expense of perennial bunchgrasses (West, 1988). The Proposed Action would affect 5.50 acres of vegetation (Table 2.3-4), in addition to 1.04 acres of
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existing disturbance on Well Pad 42-27. Of those areas affected, 2.74 acres would be affected for the long-term. Successful and timely revegetation efforts are critical for ensuring that disturbed areas would not be infested with invasive and noxious weeds. Surface disturbance that would be revegetated within one growing season of construction would be less likely to be infested by weeds than if left as exposed soil for longer periods. If revegetation efforts are not successful, the likelihood of weed infestation would be much higher. True Oil would reclaim approximately 3.80 acres of disturbance on well pads after the well has been completed, which would minimize the potential for the disturbed areas to be infested with invasive and noxious weeds. All seed mixes for reclamation would be certified “weed-free” and “certified cheatgrass free”, as well as material used for sediment barrier installations, which would further reduce the potential to introduce invasive weed species to the Project Area. Although no additional surface disturbance is required to construct the water supply well on existing Well pad 13-16a, equipment necessary to drill the well, and place the associated temporary surface pipeline within roadside ditches to Well Pad 42-27 and 23-15 could increase the presence of weed species or introduce new species to areas that are not currently infested.
Surveys conducted in and around the Project Area in 2011 did not locate invasive weed species on the Wyoming State or Sublette County weed lists. However, WGFD indicates that Canada thistle has been documented on proposed disturbance for Well Pad 23-15 and Dalmation toadflax has been located within 500 meters of this well pad (WGFD, 2012a); both species have been identified by Forest Service (2004) as priorities for treatment (control). The majority of the weeds listed in Table 3.6-1 are increasing, and have potential to be introduced into the Project Area, especially the weeds that have been documented along U.S. Highway 189. 3.6.2.3 Mitigation Alternative Potential impacts from invasive, non-native species under the Mitigation Alternative would be similar to those described for the Proposed Action. Under this alternative, potential effects from invasive, non-native species would be reduced because True Oil would implement the Forest Service (2004) weed management plan, which includes pre-disturbance surveys, methods for prevention and control, monitoring, reclamation, and treatment. True Oil would monitor for invasive species along reclaimed areas for 3 to 5 years after interim reclamation and throughout the Operations Phase; invasive species would be treated with methods and herbicides approved by the Forest Service.
Additionally, all vehicles and equipment used for construction, reclamation, and abandonment would be cleaned prior to entering and upon departure from the Project Area to prevent the spread of invasive species seeds and propagules, and all gravel, road base, or other delivered soil products used for construction of well pads would be certified weed-free. Upon completion of drilling and as a function of interim reclamation and upon final reclamation, areas designated to be reclaimed would be fenced with fencing sufficient to preclude cattle grazing and recreational use by the public to ensure substantial and sustainable reclamation and prevention of invasive plant infestation and proliferation.
3.7 LAND TENURE, RIGHTS OF WAY AND OTHER USES
3.7.1 Current Conditions The Forest Service Land Status and Encumbrance website was reviewed for rights-of-way and other uses within the Project Area in the Forest (Forest Service, 2015d). There are six authorized roads in the Project Area. No other rights-of-way were identified (see Table 3.7-1). The Project Area is bordered on all sides by Wyoming Range lands withdrawn by the Legacy
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Act of 2009. NFSR 10046 and 10050, used for access to the Project Area, cross the Wyoming Range Withdrawal Area.
The BLM LR2000 database was reviewed for rights-of-way and other uses within the Project Area and along the proposed access routes (BLM, 2015). True Oil’s Soda Lake Pipeline is the only BLM authorized right-of-way within the Project Area (see Table 3.7-1). Three other rights- of-way in the vicinity are roads and one is an authorized oil and gas pipeline just north of the Project Area, along an access route (see Table 3.7-1). Table 3.7-1 Existing Rights-of-Ways within the Project Area and Along the Access Route Case Serial Number Disposition Name Type Location Forest Service – Roads and Special Use Authorizations Bridger-Teton Forest Development T32N 115W Sec. 14, 10046 Authorized National Forest Road 22, 23 & 27 Bridger-Teton Forest Development 10046A Authorized T32N 115W Sec. 22 National Forest Road Bridger-Teton Forest Development T32N 115W Sec. 12 10050 Authorized National Forest Road & 14, 15, 16 Bridger-Teton Forest Development T32N 115W Sec. 10 103500 Authorized National Forest Road & 15 Bridger-Teton Forest Development T32N 115W Sec. 14 10340 Authorized National Forest Road & 20 Bridger-Teton Forest Development 10348 Authorized T32N 115W Sec. 22 National Forest Road BLM Rights-of-Way T32N 115W Sec. 12 WYW-129734 Authorized True Oil, LLC Soda Lake Pipeline & 14 15.8 mile road – County Road 23-117 WYW-070554 Authorized Sublette County access to U.S. Cottonwood-Ryegrass Highway 189 County Road 23-129 WYW-076692 Authorized Sublette County T33N 114W Sec. 29 North Cottonwood Road Access to Soda Unit 33- T33N 114W Sec. 29 WYW-089461 Authorized True Oil, LLC 22 & 32 Black Diamond T33N 114W Sec. 29 WYW-091143 Authorized Oil and Gas Pipeline Energy, Inc. & 30 Sources: BLM, 2015. Forest Service, 2015d, 2015e.
The Forest Service Schedule of Proposed Actions was also reviewed for active or pending projects on forest lands; no existing projects were found within the Project Area (Forest Service, 2015e). The Final Supplemental EIS Oil and Gas Leasing on Portions of the Wyoming Range – Bridger-Teton National Forest (Final Supplemental EIS for leasing) analyzed and disclosed effects of the BLM authorizing leasing of 39,490 acres in the Wyoming Range for oil and gas exploration and development (Forest Service, 2016). Some of the proposed lease parcels are adjacent to the Project Area. In the Record of Decision, the Forest Service (2017) selected the Preferred Alternative which is “no leasing.”
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3.7.2 Environmental Consequences 3.7.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to land tenure, rights of way and other uses from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.7.2.2 Proposed Action Existing rights-of-ways include authorizations for existing roads and pipelines. Some of the roads would be used as access; however, the Proposed Action is not anticipated to have any effect on existing rights-of-way or land uses. 3.7.2.3 Mitigation Alternative Potential impacts to existing land uses under the Mitigation Alternative would be the similar to those described for the Proposed Action. Access for installation of monitoring wells under this alternative could coincide with additional existing authorizations; however, effects are not expected.
3.8 MIGRATORY BIRDS
3.8.1 Current Conditions In 2008, the Forest Service Chief signed a MOU with the FWS to promote the conservation of migratory birds, pursuant to Executive Order (EO) 13186, Responsibilities of Federal Agencies to Protect Migratory Birds (66 FR § 3853). The EO directs agencies to take certain actions to further comply with the migratory bird conventions, the Migratory Bird Treaty Act (MBTA), the Bald and Golden Eagle Protection Act (BGEPA), and other pertinent statutes. The purpose of the MOU is to strengthen migratory bird conservation by identifying strategies that promote conservation and avoid or minimize adverse impacts on migratory birds including management objectives resulting from comprehensive planning efforts (e.g., Partners in Flight Conservation Plan). The MOU outlines that the Forest Service shall evaluate the effects of agency actions on migratory birds within the NEPA process with a focus on migratory species and some non- migratory game bird species that are listed as Birds of Conservation Concern (BCC) along with their priority habitats. The evaluation of agency actions should: balance long-term benefits against any short- or long-term adverse effects; pursue opportunities to restore or enhance the composition, structure, and juxtaposition of migratory bird habitats in the Project Area; consider approaches to the extent practical for identifying and minimizing take that is incidental to otherwise lawful activities including: 1) altering the season of activities to minimize disturbances during the breeding season, 2) retaining the integrity of breeding sites, especially those with long histories of use, and 3) coordinate with the FWS when planning projects that are likely to have a negative effect on migratory bird populations and cooperate in developing approaches that minimize negative impacts and maximize benefits to migratory birds. BCC have been identified by the FWS (2008a) for different Bird Conservation Regions (BCR) in the United States. The entire Project Area is in BCR 10, the Northern Rockies region for which the FWS (2008a) included 22 BCC species. Table 3.8-1 identifies 17 BCC species that could
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occur within the Project Area, based on the species’ known distributions and habitat associations in western Wyoming (WGFD, 2012b). Also included in Table 3.8-1 is the Conservation Priority for species identified by Wyoming Partners in Flight (Nicholoff, 2003). No BCC species were observed on-site during surveys conducted by Hayden-Wing (2011). However, one Breeding Bird Survey route (BBS route - Sauer et al., 2014) conducted by the National Biological Survey, the Soda Lake BBS route (number 92071), included a portion of the Project Area. The following eight BCC species were observed between 1981 and 2005 on the Soda Lake route and could be present within the Project Area: Swainson’s hawk, long-billed curlew, olive-sided flycatcher, willow flycatcher, sage thrasher, Brewer’s sparrow, sage sparrow, and Cassin’s finch. Long-term (1994 to 2013) population trends within BCR 10 are available for some of the 17 BCC species (Sauer et al., 2014) included in Table 3.8-1. The long-term trends within BCR 10 for bald eagle and long-billed curlew indicate their populations are increasing. However, olive-sided flycatcher, sage thrasher, and Cassin’s finch are decreasing in BCR 10. Data compiled for 20 BBS routes within a 75-mile radius surrounding the Project Area (14 routes in Wyoming, three in Utah, and three in Idaho) indicate that local populations of willow flycatcher and Cassin’s finch have been decreasing during the past 20 years, 1995 to 2014 (Table 3.8-1). Populations of other sagebrush-obligate or near-obligate BCC species (Brewer’s sparrows and sage sparrows) in the local area appear to have been stable (neither increasing nor decreasing) during the 20-year period. Wyoming Natural Diversity Database - WYNDD (2014) also provided records of BCC in the Project Area vicinity including (WYNDD, 2014): bald eagle (from 1980 to 2005, within Project Area), peregrine falcon (in 1989, 0.5 mile; 1978, 2.6 miles; 2010, 3.9 miles), and long-billed curlew (from 1991 to 2009, 0.9 mile away). Table 3.8-1 Birds of Conservation Concern within Bird Conservation Region 10 (Northern Rockies) that Occur or May Occur in the Project Area1 Local Observed Trend6 Common Name Conservation in BCR Trend5 1995 to Scientific Name Habitat2 Priority3 Vicinity4 1994 to 2013 2014 Nests in a tree in mixed coniferous or cottonwood- Bald Eagle riparian forest near large lakes Insufficient Haliaeetus Level I Yes Increasing and rivers. Forages on fish, data leucocephalus waterfowls, and carrion in winter. Nests in a tree, occasionally on Swainson’s Hawk a cliff; in most habitats below Level I Yes No trend No Trend Buteo swainsonii 9,000 feet with open areas for foraging. Nests in isolated trees, rock Ferruginous Hawk Insufficient outcrops, artificial structures, Level I No No Trend Buteo regalis data ground near prey base. Nests on high cliff faces, often Peregrine Falcon Insufficient near water; forages in adjacent Level I Yes No trend Falco peregrinus data habitats. Nests on the ground; often in Long-billed Curlew wet-moist meadow grasslands Level I Yes Increasing No Trend Numenius americanus or irrigated native meadows with aquatic areas nearby. Cottonwood-riparian habitats Yellow-billed Cuckoo below 7,000 feet, urban areas. Level II No No Data No Data Coccyzus americanus Usually nests in a shrub; feeds on insects.
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Local Observed Trend6 Common Name Conservation in BCR Trend5 1995 to Scientific Name Habitat2 Priority3 Vicinity4 1994 to 2013 2014 Nests on tree limb or conifer cone in coniferous forests and Calliope Hummingbird Insufficient other woodland/shrubland Level II No No Trend Stellula calliope data habitats. Feeds on nectar, insects. Nests in a cavity of dead or live Lewis’ Woodpecker Insufficient tree in pine-juniper or other Level II No No trend Melanerpes lewis data coniferous forest. Coniferous forests, also aspen, Williamson’s Sapsucker especially after fire. Primary Insufficient Level II No No trend Sphyrapicus thyroideus cavity nester; feeds on insects, data tree sap. Nests often high in a conifer in Olive-sided Flycatcher Insufficient forests from ≈8,000 feet to Level II Yes Decreasing Contopus cooperi data timberline. Nests in fork-branched riparian Willow Flycatcher shrub, including willow, below Level II Yes No trend Decreasing Epidonax traillii 9,000 feet. Nest is usually in deciduous Loggerhead Shrike tree or shrub in pine-juniper Insufficient Level II No No trend Lanius ludovicianus woodland or basin-prairie data shrublands. Nest is concealed in or beneath Sage Thrasher a sagebrush shrub in Level II Yes Decreasing No trend Oreoscoptes montanus sagebrush shrublands. Nests in sagebrush, Brewer’s Sparrow occasionally greasewood, Level I Yes No trend No trend Spizella breweri rabbitbrush in shrublands. Usually nests in or under Sage Sparrow Insufficient sagebrush shrub in sagebrush Level I Yes No trend Amphispiza belli Data shrublands. In alpine grasslands and moss- Black Rosy-Finch forb habitats, barren ground. Level III No No Data No Data Leucosticte atrata Nests on the ground or on cliff. Nests in montane forests with Cassin’s Finch spruce/fir and aspen; also in Level IV Yes Decreasing Decreasing Carpodacus cassinii lower pinyon-juniper woodlands. Notes: 1 Species observed on-site and/or reported on one or more of 20 Breeding Bird Survey routes within 75 miles surrounding the Project Area in Sublette, Fremont, Lincoln, Sweetwater and Teton counties, Wyoming; Randolph, Cache and Rich counties, Utah; Bannock, Bear Lake, Bonneville, Caribou, Teton, and Franklin counties, Idaho between 1995 and 2014. 2 WGFD, 2012b. 3 Conservation Priority from the Wyoming Bird Conservation Plan (Nicholoff, 2003). Level I: Species needs conservation action. Level II: Species’ status requires monitoring. Level III: Species of local interest Level IV: Species of concern but not considered a priority species. 4 BCC species observed in vicinity were reported on the BBS Soda Lake route between 2001 and 2005, and/or included in WYNDD, 2014. 5 Sauer et al., 2014. 6 Linear trends of birds counted per route averaged for data available on 20 Breeding Bird Survey routes within 75 miles surrounding the Project Area (see footnote 1).
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A total of 193 bird species listed as Nearctic and Neotropical migratory birds by the FWS, Division of Bird Habitat Conservation, and protected under the MBTA (FWS, 2010a) have been observed on the 20 BBS routes within 75 miles from the Project Area during the past 20 years. Of those 193 bird species, 133 species might occur in habitats present on or adjacent to the Project Area. During surveys conducted in 2011, 27 migratory birds were observed within 2 miles of the Project Area including three migratory game birds - common snipe, sandhill crane, and mallards (Anas platyrhynchos; see Table 4 in Hayden-Wing, 2011). Nesting chronologies are not available for migratory bird species in the region. For birds observed within 75 miles of the Project Area, the median date that migratory species arrive in Wyoming during spring is April 15. Fall migration for most species is underway by August 15 (Faulkner, 2010). Raptor species observed (not nesting) in the Project Area include American kestrel, golden eagle, great horned owl, and osprey. One active red-tailed hawk nest was observed within 0.5 mile of the Project Area and at least one active northern goshawk nesting territory was detected, based on bird responses to broadcast recorded goshawk vocalizations (Hayden-Wing, 2011). However, no goshawk nest site was found during the 2011 survey.
3.8.2 Environmental Consequences 3.8.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to migratory birds from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.8.2.2 Proposed Action The FWS has primary responsibility for administering the MBTA, which prohibits taking, killing, or possessing migratory birds, their parts (feathers, talons), nests or eggs. EO 13186 directed federal agencies to avoid take under the MBTA, whether intentional or unintentional (with BCC as priorities) and implementing conservation measures to restore and enhance habitat for migratory birds, including the development of surface operating standards for oil and gas developments, management of invasive species to benefit migratory birds, minimizing/preventing pollution, or detrimental alteration of habitats utilized by migratory birds, among other commitments. Construction of the Proposed Action would begin July 1 and continue through September, which would overlap with the migratory bird core breeding period (May 15 through July 15) when the majority of migratory birds are constructing nests, incubating eggs, and rearing nestlings. Timing of the Proposed Action could result in unintentional take by direct removal of active migratory bird nests, nest abandonment, displacement of birds, and possible mortality of nestlings (Romin and Muck, 2002). Risk of mortality of nestlings and dependent fledglings is greater if adults abandon nests late in the season or nests are destroyed prior to fledging young and could increase if predators were attracted to areas occupied by humans (Andren, 1994; Chalfoun et al., 2002).
Displacement of nesting migratory birds from adjacent nesting habitats due to noise, human activity and dust associated with natural gas developments could also occur (Ingelfinger and Anderson, 2004). Additionally, noise produced by machinery and other human activities might interfere with bird vocalizations used for territory establishment, mate attraction and selection, food begging and predator alarms (Marler, 2004). Night lighting would be required during
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continuous drilling and nocturnally migrating birds could die or lose a large amount of their energy reserves during migration as a result of encountering artificial light sources (Gauthreux and Belser, 2006). Attractions of migratory birds to night lights on off-shore drilling rigs (Poot et al., 2008), wind turbines (Kerlinger et al., 2010), and other sources (Gauthreux and Belser, 2006) have been documented and similar effects from night lighting at the drilling rig are possible. Artificial night light has also been shown to influence bird vocalizations at dawn and dusk with various studies showing that light pollution affects the reproductive behavior of birds (Kempenaers et al., 2010; DaSilva et al., 2014). Effects to migratory birds would be short-term if related to noise and human presence, and timing of the Project later in the core breeding period could have less consequence to breeding success than if effects occurred earlier in the breeding.
Displacement or avoidance of an area could be long-term if related to habitat removal, alteration and/or fragmentation (Gilbert and Chalfoun, 2011). Expansion of Well Pad 42-27 and construction of Well Pad 23-15 would affect 5.50 acres of vegetation (see Table 3.19-6, below) that could provide suitable nesting habitats for BCC species included in Table 3.8-1; after construction, habitat not necessary for the operation of proposed well pads would be reclaimed. Removal of such small quantities of potential nesting habitat represents a fraction of available habitats in the Project Area (see Table 3.19-1, below) and would not be expected to contribute to a downward trend of BCC observed or suspected in the Project Area (Table 3.8-1). To minimize effects to nesting migratory birds and habitat adjacent to the Proposed Action, water would be used, as needed along access roads and at well pads to minimize fugitive dust during construction and reclamation activities. All material used for sediment barrier installations and seed mixes for reclamation would be certified weed-free to minimize the potential for migratory bird habitat to be infested with invasive and noxious weeds.
Habitat fragmentation has changed the landscape by removing habitat and leaving remnant areas of native habitat less functional, both physically and biologically (Saunders, et al., 1991). Fragmentation of sagebrush shrub-steppe habitats affects breeding densities, nesting success, and nest predation of nesting species (Knick and Rotenberry, 2002). Such effects are typical of large-scale conversion of shrubland to grasslands. Fragmentation of nesting habitat allows predator access to breeding sites used by birds along newly created corridors and through edges of habitats that were previously continuous. Habitat fragmentation contributes to higher rates of nest predation in grasslands (Burger et al., 1994) and at habitat edges (Gates and Gysel, 1978; Marini et al., 1995). Corvids, including common ravens and American crows, are opportunistic predators in areas of human presence and prey on other species’ nests. Although the Proposed Action would remove potentially suitable nesting habitats for migratory birds, habitat removal would occur adjacent to existing disturbance (Well Pad 42-27) or within previously disturbed habitat (Well Pad 23-15) and would minimize additional fragmentation and disturbance to unaltered habitat on the landscape.
The FWS (2016a) recommends implementing spatial and seasonal buffers to minimize visual and auditory impacts associated with human activities near nest sites and help ensure activities do not take breeding birds or their young, since many raptors are particularly sensitive to disturbance during the breeding season. Generally, the FWS considers that raptors may be nesting in an area from January 15 through August 15, but that timeframe varies by species. As a result, Project-related noise and human disturbance in the Project Area between July 1 and September 30 would overlap the period when raptors could be nesting and when nestlings and newly fledged juveniles would be present and depend on adults for foods. Although surveys in the Project Area did not document raptor nests near proposed activities in 2011 (Hayden-Wing, 2011), raptors could be nesting in the Project Area because location of raptor nests may change from year to year due to weather conditions, natural disturbance, nest site fidelity, and other factors.
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3.8.2.3 Mitigation Alternative Under the Mitigation Alternative, the following measures would be implemented to further minimize effects to migratory birds, including raptors. No vegetation clearing would occur between May 15 and July 15 unless surveys were conducted within at least 2 weeks of proposed habitat removal and the absence of nesting migratory birds was documented, unless deemed unnecessary by the Authorized Officer. If nesting migratory birds are documented, vegetation clearing would be delayed until after July 15 or birds have fledged. Additionally, raptor surveys would be conducted prior to Project activities to determine nesting status, unless deemed unnecessary by the Authorized Officer. If raptors are documented nesting within spatial distances in Table 2.3-11 (see Section 2.3.3), then Project activities would not occur until after the seasonal restriction or after birds have fledged. To minimize the potential to attract corvids and other scavengers into the Project Area, the Mitigation Alternative would require trash and garbage to be placed in appropriate closed containers and contents transported to an approved disposal facility. True Oil would implement “dark sky” lighting practices to reduce the effects of artificial light including use of low glare lighting equipment and directing or shielding lighting to reduce glare in adjacent habitat. Additionally, to further minimize the potential to transport or spread noxious weeds into the Project Area and degrade migratory bird habitat, True Oil would implement the Forest Service (2004) weed management plan, and all vehicles and equipment used for construction, reclamation, and abandonment would be cleaned prior to entering and upon departure from the Project Area. Speed limits would also be enforced and where not posted on unpaved access roads, speeds would not exceed levels considered safe for the conditions and would be slow enough to prevent collisions with wildlife and livestock. This would also minimize fugitive dust emissions.
3.9 MINERAL RESOURCES
3.9.1 Current Conditions The primary mineral resources of interest in and around the Project Area are oil and gas. Other mineral resources of historic or potential interest, but not developed currently in the vicinity of the Project Area, include coal bed methane, coal, phosphorus, bentonite, and sand and gravel.
Oil and Gas. In the transition from the Overthrust Belt to the Green River Basin, oil and gas development has been on-going since the 1920s in the LaBarge Complex over 20 miles to the southeast of the Lander Peak Unit (Ver Ploeg, 1979). In the 1940s, development of the Riley Ridge area began about 10 miles to the south of the Lander Peak Unit (BLM, 1983). More recently, the most development of oil and gas resources has been in the Green River Basin east of the Lander Peak Unit. One of the closest units is the Mickelson Creek Unit about 5 miles east of the Lander Peak Unit; however, most of the production is farther to the east and southeast (U.S. Energy Information Administration - USEIA, 2005).
In the immediate vicinity of the Lander Peak Unit (a portion of the former Soda Unit) there are other producing and non-producing oil and gas units (see Map 3.9-1). The Maki Creek Unit, to the northeast of the Lander Peak Unit, produces from the Mesaverde Formation. Discovered in 1980, oil and gas production began in 1989 and continued until 2005 with limited gas production after 2005. The Ote Creek Unit is also to the northeast of the Lander Peak Unit and east of the Maki Creek Unit. The unit was discovered in 1976 and produced from the Fort Union and Mesaverde formations from 1978 through 1992. The largest unit in the vicinity of the Lander Peak Unit is the Mickelson Creek Unit. It was discovered in 1960 and has been producing from the Mesadverde Formation since 1978. The closest well in this unit is about 3 miles east of the Soda 23-15 location.
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Map 3.9-1 Oil and Gas Units
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In the vicinity of the Lander Peak Unit, two test holes were drilled prior to 1981 in sections 15 and 16, T. 32 N., R. 115 W. to test the rocks of Cretaceous through Triassic age in the Prospect Thrust Sheet. Commercial hydrocarbons were not encountered at the drilled depth of approximately 5,500 feet. A geophysical and geological review of the area led to the conclusion that oil and gas should be encountered within Cretaceous age rocks underneath the Prospect Thrust Sheet. This led to the drilling of four wells (Soda Unit 23-15, Soda Unit 13-16A, Soda Unit 33-22, and Soda Unit 42-27) in the years 1981 through 1987. All four Soda Unit wells encountered oil and gas at approximately 10,000 feet within the Cretaceous Frontier Formation in the basin block (Forest Service and BLM, 1988). The Soda Unit 23-15 well was plugged and abandoned in 1995. In 2001, the Klaenhammer 32-22 well was drilled.
Estimated oil and gas reserves in the vicinity of the Lander Peak Unit are on the order of 1,245 to 2,460 million cubic feet of gas and 36,000 to 56,000 barrels of oil per square mile. Estimated reserves are less to the west and greater to the east. Additional development of oil and gas resources along the transition from the Overthrust Belt to the Green River Basin in the eastern portion of the Forest is anticipated to be limited. Except for existing leases, much of the area is in the Wyoming Range Withdrawal Area as defined in the Omnibus Public Land Management Act of 2009 (Public Law 111-11 Title III, Section C – see Map 1.1-1). A recent decision (Forest Service, 2017) selected “no leasing” for five parcels of the leases included in the Final Supplemental EIS for leasing (Forest Service, 2016b) which are within 10 miles of the Project Area.
Coal. Many of the formations underlying the Lander Peak Unit contain coal beds. In the 1900s, there was interest in coal deposits in the vicinity of Lander Peak (Schultz, 1914), for railroad and settler usage. However, these deposits were apparently not extensive or accessible enough or for commercial development.
Phosphorus. The Phosphoria Formation, which is mined for phosphorus elsewhere in Wyoming, outcrops to the west of the Lander Peak Unit (Sheldon et al., 1963 and Rubey, 1973b). The apparent reasons for lack of historic or current development of phosphate resources in the vicinity of the Lander Peak Unit (and elsewhere on the Forest) include variable resource quality, thin and steeply dipping beds, and relative inaccessibility. Future development is considered unlikely (Forest Service, 2015a).
Bentonite. The Wasatch Formation, Hilliard Shale (and associated Frontier Formation) and Aspen Shale all include bentonite layers in Wyoming (Reeside and Cobban, 1960). However, in the vicinity of the Lander Peak Unit, these deposits are apparently not extensive or accessible enough for commercial development (Forest Service, 2002), particularly in comparison with other locations in Wyoming.
Sand and Gravel. The closest consistent development of sand and gravel deposits is near the town of Daniel which is about 24 miles northeast of the Project Area. Given the occurrence of alluvial deposits along the major creek channels, it is likely that minor use of these deposits has occurred sporadically for road work by local residents.
3.9.2 Environmental Consequences 3.9.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to mineral
117 Lander Peak Area Exploratory Proposal Environmental Assessment resources from activities described below for the Proposed Action and other alternatives would occur. No exploratory information on the production potential of the Hilliard Shale via horizontal drilling would be obtained. Any drilling on lands near or adjacent to the Lander Peak Unit could potentially drain oil and gas resources from the Unit, although such drainage is unlikely given the current and projected amount of oil and gas production in the area. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.9.2.2 Proposed Action If the proposed wells are proven feasible, initial production rates would be expected to be highest during the first few years of production, then decline during the remainder of the economic lives of the wells. Natural gas production from the proposed wells would contribute to the draining of hydrocarbon-bearing reservoirs in the Hilliard Formation in the area with an estimated production range of 2.2 to 2.4 billion cubic feet per well over the life of the well (Fanto, 2016). It is not likely that the Proposed Action would have an effect on current or future development including oil and gas developments and coal, phosphorus, bentonite, or sand and gravel. 3.9.2.3 Mitigation Alternative Potential effects to mineral resources under the Mitigation Alternative would be the same as those described for the Proposed Action.
3.10 PALEONTOLOGICAL RESOURCES
3.10.1 Current Conditions In the Lander Peak Project Area there is one mapped formal geologic unit (Cretaceous Blind Bull Formation - Kbb) and two informal Quaternary units (glacial till and younger alluvium/stream deposits – Qm and Qal) (Rubey, 1973; Love and Christiansen, 1985). The regressional Cretaceous Blind Bull Formation was originally identified by Rubey (1973) as interfingering with the lower and upper tongues of the marine Hilliard Formation and is designated as Potential Fossil Yield Classification (PFYC) 3 (see Attachment C). At the type stratigraphic section near the Blind Bull Coal Mine, numerous marine invertebrate fossils were found in a variety of horizons (Rubey, 1973a). Ammonites (Baculites) and pelecypods (five species) are identified as part of either the Niobraran or Coloradan faunas in the upper beds of the Blind Bull Formation, making them correlative to portions of the Upper Cretaceous Frontier Formation in southwestern Wyoming (Rubey, 1973a). Scattered petrified wood and coal seams suggest sequences of deltaic or marshy depositional environments that formed during the retreat of the Cretaceous Epicontinental Seaway. A concretion with bone fragments may be a coprolite (petrified fecal material) from one of the larger marine reptiles in the shallows of this seaway. Thus there is potential for vertebrate fossils in the Blind Bull Formation. Fossiliferous concretions are common in this sequence of strata from Wyoming well into south central Utah (Balsley, 1969; Balsley and Stokes, 1969).
The Quaternary deposits originated from Pleistocene glacial action in the Wyoming Range. Glacial till is composed of a variety of sediment sizes as they are deposited under or directly by glaciers (Qm – PFYC 1 or unknown). They are usually heterogeneous with no evidence of sorting by water. Nearby streams and ponds preserve more homogeneous Pleistocene and Recent sediments (Qal – PFYC 2) derived from reworking of the sediments from the glaciers and from colluvial debris that has been deposited by gravity from the surrounding mountains.
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The potential for fossil resources in these units is generally very low, although near water courses it may be slightly higher, as Pleistocene mega-faunas are occasionally found in bogs, ponds, and stream deposits (e.g., the Snowmastodon Ice Age Site in Colorado – found during construction of the Ziegler Reservoir in 2010) (Miller and others, 2014).
3.10.2 Environmental Consequences 3.10.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to paleontological resources from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.10.2.2 Proposed Action Construction of Well Pad 23-15 would occur on glacial till deposits which are generally considered PFYC 1 or 2 - low sensitivity - meaning that discovery of recognizable fossil remains is unlikely; however, because there is a stream close by, there is the slight possibility for a mega mammal site. Approximately 2.08 acres of the proposed 3.32 acres of disturbance has been previously disturbed and therefore, only 1.24 acres of previously undisturbed vegetation would occur which would be well away from South Cottonwood Creek. It is unlikely that there would be any effect to fossil resources and paleontological monitoring is not recommended (Bilbey, 2016).
Expansion of Well Pad 42-27 would occur within the Blind Bull Formation which has a rating of PFYC 3 – moderate fossil potential because it is known to preserve common Cretaceous marine invertebrate fossils and rarely vertebrate fossil remains. Because no pits would be constructed and the areas for potential impact are relatively flat, it is unlikely that significant fossils would be affected. It is unlikely that there would be any effect to fossil resources and paleontological monitoring is not recommended (Bilbey, 2016). 3.10.2.3 Mitigation Alternative Effects to paleontological resources under the Mitigation Alternative would be similar to those described for the Proposed Action. The potential for occurrence of fossil resources would need to be revisited once the locations for the monitoring wells are determined. If paleontological materials are uncovered during construction, the operator will immediately stop any work which would affect such materials and contact the Authorized Officer. The Authorized Officer will determine what mitigation may be necessary before construction continues.
3.11 RANGE MANAGEMENT
3.11.1 Current Conditions Nearly all of the Project Area (96.5 percent) coincides with the South Cottonwood Allotment. The allotment contains 11,953 acres, 4,570 of which (38 percent) are in the Project Area. Grazing is permitted in the allotment from August 1 to October 5 annually for 1,080 cow/calf pairs.
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The North Piney and Triple Peak allotments coincide with the remaining 3.5 percent of the Project Area (see Map 3.11-1). The North Piney Allotment contains a total of 13,854 acres, of which 24 acres coincide with the southern boundary of the Project Area. The grazing lease for the North Piney Allotment allows the permittee to graze 447 cow-calf pair between July and October. The Triple Peak Allotment contains 10,462 acres, 143 of which are in the northwest corner of the Project Area. This domestic sheep grazing allotment has not been grazed for several years due to range conflicts with native bighorn sheep and the allotment is not likely to be stocked with domestic livestock in the future (Hayward, 2015).
3.11.2 Environmental Consequences 3.11.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to range management resources from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.11.2.2 Proposed Action All surface disturbance under the Proposed Action would occur in the South Cottonwood Allotment; no Project-related activity would occur in the North Piney or Triple Peak allotments. Due to the limited extent of surface disturbance, the Proposed Action would have a marginal impact on potential forage for future livestock grazing on the South Cottonwood Allotment and no impact on grazing on the North Piney or Triple Peak allotments.
Increased vehicle traffic associated with the Proposed Action has the potential to impact domestic livestock largely through increased opportunities for livestock collisions resulting in injury or death to grazing cattle. If the allotment is stocked, there would be an increased risk for collisions. Project-related traffic could also impact domestic livestock by bringing invasive weeds into the Project Area that reduce the yield and quality of forage. 3.11.2.3 Mitigation Alternative Potential effects to range management under the Mitigation Alternative would be similar to those described for the Proposed Action. Under this alternative, damage to range improvements would be avoided and would be repaired immediately if damage occurs. The potential for livestock injuries due to vehicle collisions would be minimized by following posted speed limits and where there is no posted speed limit, speeds would not exceed levels considered safe for the conditions and would be slow enough to prevent collisions with wildlife and livestock on unpaved accessed roads and disturbed areas. To further minimize the potential to transport or spread noxious weeds into the Project Area and compete with or degrade sensitive species and their habitat, True Oil would implement the Forest Service (2004) weed management plan, and all vehicles and equipment used for construction, reclamation, and abandonment would be cleaned prior to entering and upon departure from the Project Area.
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Map 3.11-1 Allotments
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3.12 RECREATION
3.12.1 Current Conditions For purposes of recreation planning, the Forest Service uses Recreation Opportunity Spectrum (ROS) classifications to identify recreational activities that are appropriate for different parts of the forest. The Forest Plan (Forest Service, 2015a) categorizes the Project Area and surrounding environs as ROS Roaded Natural and Semi-Primitive, Motorized areas. Recreation is managed to provide Roaded Natural opportunities in roaded areas and Semi-Primitive opportunities in other areas (Forest Service, 2015a). Roaded Natural opportunities include motorized and non-motorized activities in areas where resource use is evident but harmonious with the natural environment, and semi-private opportunities include activities that use outdoor skills and offer a high degree of interaction with a predominantly unmodified environment (Forest Service, undated).
Consistent with these designations, recreational opportunities in the vicinity of the Project Area encompass a variety of dispersed activities, such as hunting, fishing, scenic driving, off-road motoring, hiking, cross-country skiing, and snowmobiling. Popular fishing destinations include sites along North and South Cottonwood creeks, Spring Creek, and Soda Lake. Big game hunting includes antelope, deer, elk, and moose. Table 3.12-1 show the WGFD Hunt Areas and beginning dates for the season in Hunt Areas.
Table 3.12-1 Big Game Hunt Areas and Beginning Dates1 Big Game Species WGFD Hunt Area 2016 Beginning Date Elk 94 October 15 Moose 24 September 15 (tentative) Deer 143 September 15 Antelope 89 September 10 1 Source: WGFD, 2016a.
Approximately 4 miles north of the Project Area, McDougal Gap Road (NFSR 125) extends west beyond County Road (CR) 23-129 (North Cottonwood Road) and passes over the crest of the Wyoming Range, linking the upper Green River Basin in Sublette County with the Greys River Basin in Lincoln County. The gravel-surfaced road is a popular scenic driving route that is open between July and September. Other recreationists use McDougal Gap Road to access a variety of trails, rivers, and hunting areas.
The Wyoming Range National Recreation Trail runs parallel to the crest of the range west of the Project Area. The nearest trailheads are the McDougal Gap Trailhead, approximately 5 miles northwest of the Project Area, and the North Piney Trailhead, approximately 3.5 miles south of the Project Area. The McDougal Gap Trailhead is accessed via McDougal Gap Road and the North Piney Trailhead is accessed via CR 23-129, NFSR 10050 and NFSR 10046.
Middle Piney Lake is a popular camping, fishing, hiking, and snowmobiling site located approximately 10 miles south of the Project Area. The lake and nearby Middle Piney and Sacajawea campgrounds are the established recreation facilities closest to the Project Area, and are accessed via Wyoming State Highway 350 and CR 23-111 (Middle Piney Road) west out of Big Piney. There are no designated or established recreation sites, campgrounds, or pack and saddle trails in the Project Area.
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3.12.2 Environmental Consequences 3.12.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to recreation resources from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.12.2.2 Proposed Action Project-related traffic, human activity, noise, dust, light, and structures associated with Construction and Operations could affect recreation opportunities and experiences in the Project Area; however, the Project would not prevent recreational use of the Project Area and surrounding region. Scenic quality and naturalness could be slightly diminished, and opportunities for solitude during the Construction Phase (including drilling and completion) could be limited in the immediate area of the construction. Under the Proposed Action, all surface disturbances would occur in ROS Roaded Natural areas. The Project would be consistent with the Recreation Prescriptions for DFC 1B (Well Pads 13-16a and Well Pad 23-15) and DFC 10 (Well Pad 42-27) – see Table 1.5-1.
Within the Project Area, opportunities for solitude near the proposed well pads would be minimized during the Construction Phase and recreationists may seek other destinations in nearby areas. Project-related noise would be inaudible above ambient levels within some distance of the noise source. Noise levels would vary and be considerably less, depending on receptor orientation to the source and intervening forest and topography. Recreationists fishing in Soda Lake (approximately 1 mile west of Well Pad 23-15), may shift to other fishing areas during the Construction Phase. No construction activities are proposed during big game hunting seasons and the Proposed Action is not expected to impact hunting in the Project Area. Big game hunting for moose, deer, and antelope would overlap with the Construction Phase during the month of September and possibly into November. Hunters would most likely seek other areas for hunting during the Construction Phase. Night lighting may affect recreational users during the Construction Phase as well and campers may seek alternate sites. Well Pad 23-15 would no longer be available as a camping site. Effects described above during the Construction Phase would be short-term and temporary. It is not likely that there would any effects to recreational users during the Operations Phase – with the exception of Well Pad 23- 15 no longer being available for camping.
North Cottonwood Road (CR 23-129), NFSR 10050, and NFSR 10046 provide access to several trails, trailheads, fishing streams, and other recreation sites in the Wyoming Range and would be subject to increased traffic and associated dust during the Construction Phase. The Proposed Action would not preclude access to recreational destinations from these roads, but visitors could be exposed to construction traffic and other disruptions. The Proposed Action would not affect established recreation sites at Middle Piney Lake because they use different roads for access.
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3.12.2.3 Mitigation Alternative Potential effects to Recreation under the Mitigation Alternative would be similar to those described above for the Proposed Action. Implementation of dark-sky lighting under this alternative would minimize any effects to recreational users from light during the Construction Phase.
3.13 SOCIOECONOMICS
3.13.1 Current Conditions Sublette County’s economic and social characteristics are closely tied to natural resource-based industries such as agriculture and mineral extraction. Publicly-owned lands cover 80 percent of the county and provide a base for these economic activities, as well as opportunities for recreation and outdoor-based tourism.
Population. Population trends tend to follow job growth, especially in energy dependent states such as Wyoming (Wyoming Department of Administration and Information – WDAI, 2015). Spurred by an expanding natural gas industry, Sublette County had the highest rate of population growth in the state between 2000 and 2010. During this time, the county’s population increased by an average of 5.6 percent per year, for an overall 73 percent population gain over the decade – from 5,920 in 2000 to 10,247 in 2010. Over the same period, Wyoming’s population increased by an average of 1.3 percent per year, for an overall 14 percent population gain (U.S. Census Bureau, 2015a).
Due to steep declines in oil and natural gas prices, employment in Sublette County’s mining sector has fallen since 2011 and population outmigration has followed (WDAI, 2015). Between 2010 and 2014, the county’s population decreased by an average of 0.5 percent per year, for an overall 1.9 percent population loss over the 4-year period. During this time, Wyoming’s population increased 3.6 percent, or 0.9 percent per year (U.S. Census Bureau, 2015a).
Employment. Sublette County’s mining sector is dominated by oil and natural gas extraction and support activities, and has been the primary source of employment in the county since 2004. Additional major employment sectors include Construction, State and Local Government (including public education), and Retail Trade (Bureau of Economic Analysis - BEA, 2014). In 2014, annual wages in Sublette County averaged $61,185. Wages were highest in the Mining ($104,740) and Utilities ($86,958) sectors, and lowest in the Retail Trade ($27,419), Accommodation and Food Services ($23,553), and Arts, Entertainment and Recreation ($22,366) sectors (Bureau of Labor Statistics - BLS, 2015a).
Due to expanding natural gas exploration and development, unemployment rates in Sublette County were lower than the state average between 2000 and 2012. During that time, annual unemployment rates ranged from 1.5 to 5.9 percent in Sublette County and from 2.8 to 6.4 percent in Wyoming. Unemployment rates in both jurisdictions were lowest in 2007 and highest in 2010. Led by job losses in the mining sector, the average annual unemployment rate was 4.5 percent in Sublette County and 4.3 percent in Wyoming (BLS, 2015b).
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Tourism. Travel and tourism are important parts of Sublette County’s economy. The travel industry spans several sectors, including Accommodation and Food Services; Arts, Entertainment and Recreation; Retail Trade; Transportation; Professional Services; and Real Estate, Rental and Leasing. Between 2004 and 2014, overnight-travel and tourism in Sublette County are estimated to have generated between $35.8 million and $53.1 million in annual local spending and to have supported between 390 and 550 local jobs annually. As a portion of total employment, travel-related jobs in Sublette County ranged from a high of 10.8 percent in 2004 to a low of 5.2 percent in 2012. In 2013, travel-related jobs accounted for 5.4 of total county employment (Dean Runyan Associates, 2015; BEA, 2014).
Short-Term Housing. Most of the short-term housing accommodations in Sublette County are located in Pinedale, which is approximately 60 miles from the Project Area. Pinedale has 12 hotels and motels with a combined total of over 490 rooms. Big Piney and Marbleton are closest to the Project Area, and have three motels with a combined total of 74 rooms. RV Parks near the Project Area offer 32 sites in Pinedale, 50 sites in Boulder, and 21 sites in Daniel (Pinedale Travel and Tourism Commission, 2015; TripAdvisor, 2015).
Government Revenues. In Wyoming taxes on oil and natural gas production are a primary source of revenue to state and local governments. Natural gas wells on federal land pay a 12.5 percent federal mineral lease (FML) royalty on the net revenues (gross revenue less transportation and processing costs and administrative charges) from extracted natural gas. The federal government receives 51 percent of FML royalties and Wyoming receives 49 percent. Wyoming allocates approximately half of its portion of FML royalties to the state budget (Wyoming General Fund and Budget Reserve), 37 percent to schools, and 13 percent to highways, roads, cities, towns and counties. Natural gas wells also pay a severance tax equal to 6 percent of the fair market value of natural gas production. Approximately 91 percent of severance tax revenues fund the state budget and the Permanent Wyoming Mineral Trust Fund. The remaining 9 percent of severance tax revenues fund water, highway, road and capital construction projects; and city, town and county budgets (Consensus Revenue Estimating Group, 2015).
Property (ad valorem) taxes account for over 70 percent of the revenues that finance Sublette County government (Lankford, 2015). Property taxes are based on assessed valuations and local taxing rates (mill levies). Combined, minerals and the oil and gas industry account for 96 percent of Sublette County’s valuation (Wyoming Department of Revenue, 2015). Sales and use tax receipts are the second largest source of revenue to Sublette County, and account for approximately 15 percent of the county’s budget (Sublette County, 2015).
County Services. Sublette County provides key services to county residents and workers. The Sublette County Sheriff’s Office provides law enforcement services across the county, including the towns of Pinedale and Big Piney. The Sublette County Rural Health Care District provides family health, urgent care, and emergency medical services. The district has a medical clinic and ambulance station in Pinedale and a clinic and ambulance station in Marbleton. Sublette County Unified Fire is a volunteer fire department with fire stations located in Pinedale, Big Piney-Marbleton, Bondurant, Boulder, Daniel, and the Kendall Valley. The Forest Service is the first responder to fires on NFS lands. The Teton Interagency Dispatch Center dispatches fire responders across Sublette County. Sublette County United Fire often assists with fire suppression on the Forest.
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3.13.2 Environmental Consequences 3.13.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to socioeconomics from activities described below for the Proposed Action would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.13.2.2 Proposed Action True Oil anticipates that all of the labor required for Construction and Operation of the Proposed Action would be drawn from Sublette and Sweetwater counties. Most construction workers would be expected to commute to the Project Area from their place of residence in Sublette County. Some specialized crew members, such as well completion personnel, would be expected to come from Sweetwater County (and possibly Lincoln County) and may temporarily relocate to Sublette County for the duration of their employment.
Due to the limited size and duration of the Project, population and employment trends and the demand for community services in Sublette County would not be affected. The Project would be an economic stimulus to Sublette County, where mining sector jobs have been decreasing since 2011.
The Project would not affect Sublette County’s tourism industry. However, localized impacts could occur through the redistribution of visitors away from sites near the Project Area to sites elsewhere in the Wyoming and Wind River ranges, and increased usage pressures in other portions of the Forest.
The demand for short-term housing accommodations would increase temporarily, especially in Big Piney and Marbleton. The workforce during Construction is expected to peak at 56 workers during well completions, which is within the capacity of local motels. The intensity of the demand on local motels would depend on how many drilling and completion workers chose to stay in Big Piney and Marbleton. There could be upward pressure on motel rates and lower vacancy rates in these communities during well drilling (54 days) and completion (20 days). During these times, some Project workers, recreationists, and other tourists could be in the position of having to travel to Pinedale to secure suitable lodging accommodations.
The Proposed Action would provide economic benefits to federal, state, and Sublette County governments through the generation of FML royalties, severance tax, and property tax revenue on production. The Proposed Action would also generate sales tax revenue to Sublette County from spending by employees, contractors, and individuals whose jobs are supported by the Project. Sublette County would receive use tax revenue from Project expenditures on taxable goods purchased elsewhere and imported into the county for use in the Project Area. Sales and use tax receipts would be highest during the Construction Phase.
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3.13.2.3 Mitigation Alternative Potential effects to socioeconomic resources under the Mitigation Alternative would be the same as those described above for the Proposed Action.
3.14 SOILS
3.14.1 Current Conditions The Project Area is characterized by floodplains along South Cottonwood Creek to long, steep mountain slopes and ridges. Elevation ranges from about 8,300 feet along Cottonwood Creek to about 10,600 feet on the higher ridges. Soils within the Project Area were identified and characterized using the Natural Resources Conservation Service (NRCS) Web Soil Survey spatial and tabular data of Sublette County, Bridger National Forest Wyoming, Western Part WY663, (NRCS, 2015). Sixteen soil mapping units occur in the Project Area (see Map 3.14-1); however, only two soil types would be affected by the Project (see Table 3.14-1).
Soils affected in the Project Area along the South Cottonwood Creek floodplain and adjacent terraces are deep, loamy to extremely cobbly sandy loam textures with 0 to 15 percent slopes. Soil components within the floodplains may have a high water table within 3 feet of the surface from May to July with the potential for brief flooding during these months. The soils on the, moraines, and outwash plains are deep, well drained, silty clay to extremely gravely loamy sand soils with slopes ranging from 0 to 35 percent. The steeper side slopes and mountain ridges are deep, well-drained, silty clay loam to extremely cobbly sandy clay loam soils with slopes ranging from 20 to 55 percent. The soil found in depressions troughs and knolls are deep, well-drained, clay loam to extremely gravely sandy loam soils with slopes that range from 0 to 30 percent.
The water erosion hazards in the Project Area ranges from low in the floodplain to severe on the steeper mountain slopes. The wind erosion hazard of all affected soils in the Project Area is low. Depths to a restrictive layer are greater than 60 inches for all of the soils, most, except floodplain soils, are not prone to flooding or ponding, and none of the soils are saline or sodic. Overall revegetation potential is high except in areas with slopes steeper than 30 percent. The soils have a land capability class of either 6e or 7e indicating they are not suitable for cultivated crops and are limited to pasture, rangeland, forestland, or wildlife habitat due to steep slopes, stoniness, erosion potential, and severe climate.
3.14.2 Environmental Consequences 3.14.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to soils from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, recreation, and grazing.
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Map 3.14-1 Soil Mapping Units
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Table 3.14-1 Limiting Soil Characteristics for Soils Affected Limiting Soil Characteristic Erosion from
5 4
7 11 8
9
12 10
2 3 Soil Mapping
Saline/sodic Saline/sodic Soil Soil Compaction Hydric Soils Soils Hydric Prime Farmland Large Stones Large Water Slopes Steep 6 High Water High Table/ Flooding Wind Reclamation Sensitivity Unit Soil Mapping Unit Name1 Layer Restrictive Outwash Plains/Moraines Cluff family-Inceptic Haplocryalfs-Foxton family, Yes 301 No No No Yes No No No No No No complex, 0 to 15 percent slopes (strength) No Needleton family-Inceptic Haplocryalfs-Owlcreek Moderate 322 No No Yes No No Moderate No No No No family, complex, 5 to 35 percent slopes (slope) (strength) 1 Soil group ratings are based on the dominant soil type for the soil map unit. Inclusions of sensitive soil types may be found within soil map units that do not receive sensitive ratings. 2 Water Erosion – soils sensitive to water erosion have an NRCS rating of high or severe. 3 Wind Erosion – soils sensitive to wind erosion are in the NRCS wind erodibility groups 1 and 2. 4 Steep Slopes – sensitive soils occur in soil map units when slopes are greater than 30 percent. 5 Large Stones – soils with greater than 25 percent cobbles and/or stones in the soil profile can present problems with surface reclamation. Soil with large quantities of large stones hold less available water for plant growth and generally require broadcast seeding methods. 6 Restrictive Soils – soils that have a lithic, paralithic, or other restrictive soil layer within 60 inches of the soil surface. These soils have shallow profiles and hold less available water for plant growth. 7 Saline/Sodic Soils – includes soils with an electrical conductivity of 8 mmhos/cm or greater and/or a Sodium Adsorption Ratio (SAR) of 13 or greater. Saline/sodic soils may require special handling of materials and/or special seed mixes. 8 Soil Compaction – sensitive soils include those with an NRCS rating of high or severe for the category ‘Haul Roads, Log Landings and Soil Rutting. 9 Reclamation Sensitivity – soils having reclamation sensitivity is a combined rating for soils with high or severe erosion potential, steep slopes, large stones, shallow soils and saline or sodic conditions and clayey soils (greater than 40 percent). This also includes soil map units with dominant amounts of rock outcrop. BMPs are generally required to reduce erosion and sedimentation potential in these soils. Restoration of these soils in most cases requires adaptive seed mixtures and implementation of revegetation practices (i.e., scarification, fertilization, proper seeding techniques, mulching, monitoring, etc.) to enhanced revegetation success. Revegetation of areas with extensive rock outcrop may not be possible. 10 High Water Table – NRCS ratings of soils which have a saturated zone in the soil profile within 60 inches of the surface in most years. A saturated zone that lasts for less than a month is not considered a water table. Flooding Hazard - temporary inundation of an area caused by overflowing streams or runoff from adjacent slopes. 11 Hydric Soils – at least one major named map unit soil is included on the county hydric soil list. 12 Prime Farmland – dominant map unit soil is included on either the state or county list of farmland of importance.
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3.14.2.2 Proposed Action The soil series data (i.e., soil mapping unit) from the NRCS Web Soil Survey reports were used to conduct a detailed analysis of the potential impacts to soils resulting from the Proposed Action. Spatial analysis using Geographic Information System (GIS) was completed to determine the number of acres within each soil series (mapping unit) that would be affected by reconstruction of reclaimed Well Pad 23-15 and expansion of Well Pad 42-27 so that potential impacts could be accurately quantified within each soil mapping unit.
Table 3.14-2 provides a listing of soils by landform group and indicates acres and percent of disturbance under the Proposed Action within each group. As indicated in Table 3.14-2, the Proposed Action would disturb a total of 5.50 acres of soils.
Table 3.14-2 Soil Mapping Units Affected by the Proposed Action Soil Mapping Unit Acres Number Soil Mapping Unit Name and Slope (percent) Outwash Plains/Moraines/Mountain Slopes Cluff family-Inceptic Haplocryalfs-Foxton family, 301 2.18 complex, 0 to 15 percent slopes (40) Needleton family-Inceptic Haplocryalfs-Owlcreek 3.32 322 family, complex, 5 to 35 percent slopes (60) Total Disturbance - Proposed Action 5.50
Surface disturbance associated with the Proposed Action has the potential to adversely affect natural soil characteristics and, consequently, soil productivity and restoration potential, during clearing and grading activities. Potential soil impacts include:
• soil erosion/sediment transport due to water, wind, loss of vegetation (including biologic soils crusts) and mass wasting; • soil compaction and damage to soil structure resulting from the movement of heavy construction equipment; • soil mixing or displacement from grading/excavation and reclamation; • rutting from equipment or vehicle traffic; • structural damage to wet or frozen soils and soils with poor drainage; and • introduction of large stones into the topsoil as a result of construction.
Table 3.14-3 provides a summary of the acres of disturbance that would occur to each of the sensitive soil characteristic groups that would be affected by the Proposed Action. The two mapping units that would be affected by the Proposed Action are soil complexes, composed of more than one soil series because the soils are so intermingled that they cannot be mapped separately at the scale of the survey maps. For this analysis, the dominant soil series in the mapping unit was used to assess the sensitive soil characteristics or groups affected by the Proposed Action, although many of the soil series in these soil complexes have similar characteristics. Because NRCS soil survey data for the various soil parameters are typically reported as ranges (i.e., slopes: 12 to 45 percent), the soil mapping unit was considered to be within a sensitive soil group if the specific soil parameter range exceeded the sensitive soil threshold, such as 30 percent for steep slopes. Therefore, this analysis makes the ‘worst-case’
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assumption that all areas of disturbance would occur within the areas of the soil mapping unit that exceed the sensitive soil threshold criteria.
Table 3.14-3 Proposed Surface Disturbance in Sensitive Soils Sensitive Soil Total Percent of Total Characteristic (acres) Disturbance Water Erosion Hazard 0.00 0 Wind Erosion Hazard 0.00 0 Steep Slopes 0.00 0 Large Stones1 5.50 100 Restrictive Layer 0.00 0 Saline/Sodic 0.00 0 Compaction Potential2 2.18 40 Reclamation Sensitivity 0.00 0 High Water Table 0.00 0 Flooding Hazard 0.00 0 Hydric Soils 0.00 0 Prime Farmlands 0.00 0 1 Large Stones – soils with greater than 25 percent cobbles and/or stones in the soil profile can present problems with surface reclamation. Soil with large quantities of large stones hold less available water for plant growth and generally require broadcast seeding methods. 2 Soil Compaction – sensitive soils include those with an NRCS rating of high or severe for the category ‘Haul Roads, Log Landings and Soil Rutting.
As shown in Table 3.14-3, construction could affect soils that have a high content of coarse fragments and are easily compacted. These characteristics can make soils difficult to reclaim. The invasion of noxious weeds into disturbed areas could occur on all soil types, but the potential for weed invasion is typically greater on soils that are difficult to reclaim due to their sensitive characteristics. Based on the NRCS soil survey data (NRCS, 2015), the wind erosion hazard of undisturbed soil indicates that these soils are generally not susceptible to blowing. Soil disturbance such as grading/blading when soils are dry would increase the wind erosion hazard of soil in the short-term, especially soils subject to construction traffic until soils have crusted, settled, or revegetated or have been compacted.
Large Stones. Soils likely to be composed of more than 25 percent rock fragments are included as sensitive soils. Soils with large volumes of cobbles or stones can present problems with reclamation because they hold less available water for plant growth and may require broadcast rather than drill seeding methods when large rocks on the surface prevent drill seeding methods. As indicated in Table 3.14-3, the two soil map units affected by the Proposed Action contain 25 percent or more large stones. However, most of the higher coarse fragment content is in subsoil horizons rather than in surface horizons.
Compaction. Soil compaction results when internal pore space is reduced due to physical pressure exerted on the surface. Compaction can result in soil conditions that reduce infiltration, permeability and gaseous and nutrient exchange rates within the soil. These processes are critical to viability of vegetative species. Physical resistance to root growth can occur when soils are compacted. Unmitigated soil compaction can result in long-term reductions in soil productivity and increased erosion due to increased runoff. Soils in the group sensitive to
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compaction were determined based on the NRCS rating of High or Severe for the category ‘Haul Roads, Log Landings and Soil Rutting. Soil ratings in this group are based on unified soil texture classification, rock fragments on or below the surface depth to a restrictive layer, depth to a water table and on slope. As shown in Table 3.14-3, 2.18 acres of Mapping Unit 30 affected by the expansion of Well Pad 42-27 are susceptible to compaction. During reclamation, adequate scarification of disturbed surfaces, by ripping, disking or other measures is necessary to ensure revegetation success and to minimize erosion and sedimentation potentials. 3.14.2.3 Mitigation Alternative Potential effects to soils under the Mitigation Alternative are the same as those described above for the Proposed Action.
3.15 SPECIAL AREAS AND DESIGNATIONS
3.15.1 Current Conditions Wilderness and Areas with Wilderness Potential. Protected wilderness areas in the Forest include the Bridger, Gros Ventre, and Teton Wilderness Areas and the Palisade and Shoal Creek Wilderness Study Areas (WSAs). From the Project Area, the Bridger Wilderness is approximately 45 miles east/northeast, the Gros Ventre Wilderness is approximately 37 miles north, and the Teton Wilderness is approximately 78 miles north. The Palisade WSA is approximately 33 miles northwest of the Project Area and the Shoal Creek WSA is approximately 35 miles north of the Project Area.
Areas that have the potential to be considered for future wilderness designation include Inventoried Roadless Areas (IRA) and Areas with Wilderness Potential. The 1983 Roadless Area Review and Evaluation (RARE II) survey identified Roadless Areas that include at least 5,000 acres and are without development and substantially natural in character. Areas with Wilderness Potential are tracts of 5,000 acres or more that lie outside existing wilderness that are identified and evaluated during Forest Plan revisions for administrative recommendation to Congress for wilderness designation.
The majority of the Project Area is in a roaded area as categorized by RARE II (see Map 3.15- 1). A portion of the South Wyoming Range IRA, which covers a total of 85,706 acres, extends into the northwest corner of the Project Area and a portion of the Little Cottonwood Creek IRA, which covers a total of 4,874 acres, is in the far eastern section of the Project Area.
In 2008, the Forest Service identified 10,832 acres around the South Wyoming Range IRA as an Area with Wilderness Potential. This land does not include the Project Area. The Little Cottonwood Creek IRA does not meet the size criteria for an area of wilderness potential, but includes a unique and special geologic feature, the Red Castles, that could be administratively designated as a way of recognizing the area (Forest Service, 2009a). Neither the South Wyoming Range Area with Wilderness Potential nor the Little Cottonwood Creek IRA was recommended for wilderness designation in the Forest Plan (Forest Service, 2015a).
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Map 3.15-1 Roadless Areas
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Management Area. The Project Area is located in Management Area 25 – Cottonwood Creek. Management Area 25 includes 48,500 acres (1.4 percent of the Forest) that are managed for timber harvest, oil and gas, livestock production, and other commercial activities. MA 25 is characterized by a mixed conifer forest type that ranges from sapling-sized trees in burned and harvested areas to large pole/small saw log-sized trees in areas that have not been harvested during the last 50 years. Old growth timber is rare in the area. In addition to resource development, MA 25 is managed to provide wildlife habitat, watershed protection, dispersed recreation, and visual resources.
Map 1.5-1 shows the DFCs coinciding with the Project Area including DFC 1B, DFC 10, and DFC 12. Nearly all (98 percent) of the DFCs coinciding with the Project Area are managed for resource development.
3.15.2 Environmental Consequences 3.15.2.1 No Action Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to wilderness and areas with wilderness potential or within Management Area 25 from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.15.2.2 Proposed Action No Wilderness Areas or Wilderness Study Areas are in or near the Project Area, and therefore, the Proposed Action would not impact existing wilderness resources in the Forest. No Areas with Wilderness Potential coincide with the Project Area, and all surface disturbance associated with the Proposed Action would occur outside IRAs (see Map 3.15-1). Therefore, the Proposed Action would not impact potential wilderness resources in the Forest.
The Proposed Action is consistent with the management objectives established for DCFs in the Project Area. Under the Proposed Action, the majority of surface disturbance and activity would occur in DFC 1B (reconstruction of Well Pad 23-15 and installation of water supply well), where minerals exploration and development are encouraged. Well Pad 42-27 would be located in DFC 10, which is available for minerals exploration and development. No surface disturbance would in occur in DFC 12, which is managed for backcountry big-game hunting, dispersed recreation, and wildlife security. 3.15.2.3 Mitigation Alternative Potential effects to wilderness and areas with wilderness potential under the Mitigation Alternative would be similar to those described for the Proposed Action; however, under this alternative, there would be some activity outside the Project Area within the Little Cottonwood Creek IRA for drilling water monitoring wells MW-01 and MW-02. No roads would be constructed or reconstructed under this alternative and no trees would be cut; both monitoring wells would be placed adjacent to existing roads and existing roads would be used to access the wells for monitoring. The monitoring wells would be located in DFC 10. All activities would be consistent with the management objectives.
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3.16 THREATENED, ENDANGERED, PROPOSED, CANDIDATE, AND SENSITIVE ANIMAL SPECIES
3.16.1 Current Conditions The FWS (2016b) identified nine wildlife species listed as threatened, endangered, or candidate species under the ESA that should be considered in effects analysis for the Project (see Table 3.16-1). The species include four endangered Colorado River Fish species including bonytail, Colorado pikeminnow, humpback chub, and razorback sucker. The Colorado River Fish are included because the Project would require water to be withdrawn from the Upper Colorado River Basin and would potentially affect the four endangered fish species and their designated critical habitats downstream from the Project. The FWS also identified the Canada lynx, grizzly bear, and yellow-billed cuckoo listed as threatened. The gray wolf as a non-essential experimental population (managed under section 10(j) of the ESA) is currently treated as a species proposed for listing on all lands outside of National Park Service lands and National Wildlife Refuges where they are treated as threatened. The North American wolverine is included as a proposed species; on April 4, 2016 United States District Court for the District of Montana vacated the FWS August 13, 2014 withdrawal of its proposed rule to list the distinct population segment of the North American wolverine as threatened under the ESA (Defenders of Wildlife v. Jewell et al., 2016). The FWS (2016b) identified four ESA-listed wildlife species in association with the Platte River in Nebraska that could be affected by water-related activities and/or water use in the Platte River Basin. They include pallid sturgeon, interior least tern, whooping crane, and piping plover. The Project would not result in any water withdrawn from the Platte River Basin.
Table 3.16-1 Threatened and Endangered Species Listed under the ESA that Could Potentially Occur in the Project Area
Common Name, Included Scientific Name ESA Status1 in EA Reason for Exclusion MAMMALS Canada lynx Threatened with Yes Lynx canadensis Critical Habitat Grizzly bear Threatened Yes Ursus arctos horribilis Non-essential Gray wolf Experimental Yes Canis lupus Population –Proposed North American wolverine Proposed Threatened Yes Gulo gulo (luscus) BIRDS Whooping crane Endangered with No water depletion in the Platte No Grus americana Critical Habitat River Basin Piping plover Endangered with No water depletion in the Platte No Charadrius melodus Critical Habitat River Basin Interior Least tern Threatened with No water depletion the Platte River No Sterna antillarum Critical Habitat Basin Yellow-billed Cuckoo Threatened with Yes Coccyzus americanus Critical Habitat Proposed FISH Pallid sturgeon Endangered with No water depletion in the Platte No Scaphirhynchus albus Critical Habitat River Basin
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Common Name, Included Scientific Name ESA Status1 in EA Reason for Exclusion Colorado pikeminnow Endangered with Yes Ptychocheilus Lucius Critical Habitat Razorback sucker Endangered with Yes Xyrauchen texanus Critical Habitat Bonytail Endangered with Yes Gila elegans Critical Habitat Humpback chub Endangered with Yes Gilia cypha Critical Habitat 1 FWS, 2016b.
Threatened, Endangered, and Proposed Species
Canada Lynx. Canada lynx within the contiguous United States were listed as threatened in 2000 (FWS, 2000). The FWS identified significant threats to the lynx including threats by destruction, modification, or curtailment of the species’ habitat or range within the Northern Rockies/Cascades and Southern Rockies. Lynx habitats have been adversely affected by timber harvest, mostly within western boreal forests (subalpine fir/spruce forest). However, timber harvest levels on federal lands in the West have declined since the 1990’s and reduction of early successional habitats with concomitant reductions of snowshoe hare (Lepus americana) habitats may have affected lynx in some areas (FWS, 2000). The FWS concluded that lynx populations in the contiguous United States occur at naturally low densities, generally maintained by limited abundance of primary prey (snowshoe hare) which in turn results from patchy distribution of transitional boreal forest habitat. Canada lynx are specialized predators that are highly dependent on snowshoe hare although they may also prey opportunistically on squirrels, mice, beaver, muskrat, birds, young ungulates, and some carrion when hare populations decline. Lynx are generally found in boreal forest in association with snowshoe hare habitat or habitat of other suitable prey species. Mature forest stands are used by lynx for denning, cover, and travel corridors (Ruggiero et al., 2000). Early successional stands with high densities of shrub and seedlings are optimal for hares, and subsequently provide important habitat for lynx foraging activities. Lynx inhabit coniferous forests interspersed with thickets of trees and shrubs, rocky outcrops, and large woody debris that are often used for den sites. They are highly mobile, and often explore outside their home ranges. Breeding populations are not possible without an adequate snowshoe hare population (FWS, 2006). The Northern Rockies Lynx Management Direction prepared by Forest Service (2007a) provides management direction to conserve and promote the recovery of lynx, including establishment of Lynx Analysis Units (LAU) to focus conservation activities. LAUs approximate the size of the home range for a female lynx and contain year-round habitat components. An objective of lynx conservation is to maintain good quality and distribution of denning and foraging resources within a LAU to help assure survival and reproduction by adult females, which is critical to sustain the overall lynx population (Interagency Lynx Biology Team, 2013). The Project Area is mainly (approximately 4,703 acres) within the Cottonwood LAU with a small portion (approximately 33 acres) in the South Beaver LAU. The Cottonwood Creek LAU is 48,372 acres (75.6 square miles). A map of lynx habitat updated by the Forest Service in 2015 (see Lynx Habitat Mapping Criteria and Procedures in Appendix B, Forest Service, 2007a), shows 32,377 acres (50.6 square miles) of habitat within the Cottonwood Creek LAU, although approximately 1,718 acres are currently
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not suitable habitat due to forest practices including clearcutting (28.1 percent), precommercial thinning (34.5 percent), other silvicuture (5.2 percent), and wildfire (32.2 percent). Over time, these areas will become suitable habitats as forest succession progresses and snowshoe hare populations occupy denser early seral forest (Interagency Lynx Biology Team, 2013). The remainder of the Cottonwood Creek LAU is suitable lynx habitat composed of a mixture of deciduous (aspen) and coniferous forests, similar to the forested components within the Project Area described in Section 3.19, Vegetation. In the Northern Rockies Lynx Management Direction (Forest Service, 2007a), the Forest Service recommends that LAUs not have more than 30 percent of the lynx habitat in unsuitable conditions, described as vegetation that is too short to provide winter snowshoe hare habitat. In the Cottonwood Creek LAU, unsuitable habitat is about 5 percent of the total mapped lynx habitat. Within the Project Area, approximately 3,719 acres of mixed forest/woodland habitat is present, which could provide suitable habitat for lynx including aspen, whitebark pine, whitebark pine mix, spruce/subalpine fir mix, and lodgepole pine mix (Table 3.16-2). Approximately 182 acres of habitat within the Project Area is unsuitable for lynx and includes approximately 77 acres of precommercial thinning conducted during 1999 and 2000 and 105 acres that were burned by the Triple Fire in 2005. Unsuitable habitat comprises approximately 4.7 percent of the approximate 3,900 acres of forested habitat in the Project Area. Table 3.16-2 Areas of Suitable Lynx Habitat for Five Forest Cover Types within in the Project Area. Tree Area (acres) in Tree Canopy Cover Category 2 Forest Cover Size Total Type (dbh) 1 10–19% 20-29% 30–39% 40–49% 50-59% 60-69% 70-100% Areas <5 in - - - 3.53 - - 2.32 5.85 5-10 in 0.92 - 23.67 27 12.52 2.53 9.11 75.75 Aspen >10 in 0.18 - 0.25 0.99 - - -- 1.42 Total 1.10 0.00 23.92 31.52 12.52 2.53 11.43 83.02 <5 in ------0 5-10 in - 0.47 21.63 40.27 47.29 3.51 - 113.17 Whitebark Pine >10 in 5.05 4.85 22.98 18.08 43.08 - - 94.04 Total 5.05 5.32 44.61 58.35 90.37 3.51 0.00 207.21 <5 in ------0 Whitebark Pine 5-10 in - - 14.99 56.37 27.76 - - 99.12 Mix >10 in - 4.51 24.41 10.74 11.6 - - 51.26 Total 0.00 4.51 39.40 67.11 39.36 0.00 0.00 150.38 <5 in ------0 Spruce/Subalpine 5-10 in 1.11 1.09 101.45 395.43 185.6 - - 684.68 Fir Mix >10 in 11.37 8.59 60.11 118.94 139.24 - - 338.25 Total 12.48 9.68 161.56 514.37 324.84 0.00 0.00 1022.93 <5 in ------0 Lodgepole Pine 5-10 in 11.83 171.22 538.84 593.07 92.48 13.87 1421.31 Mix >10 in 5.72 15.87 98.24 269.62 400.4 37.94 6.08 833.87 Total 5.72 27.70 269.46 808.46 993.47 130.42 19.95 2255.18 <5 in 0 0 0 3.53 0 0 2.32 5.85 5-10 in 2.03 13.39 332.96 1057.91 866.24 98.52 22.98 2394.03 Total Areas >10 in 22.32 33.82 205.99 418.37 594.32 37.94 6.08 1318.84 Total 24.35 47.21 538.95 1479.81 1460.56 136.46 31.38 3718.72 <5 in 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.1% 0.2% Percent of Total 5-10 in 0.1% 0.4% 9.0% 28.4% 23.3% 2.6% 0.6% 64.4% Suitable Habitat >10 in 0.6% 0.9% 5.5% 11.3% 16.0% 1.0% 0.2% 35.5% Total 0.7% 1.3% 14.5% 39.8% 39.3% 3.7% 0.8% 100.0% 1 dbh, diameter at breast height, of trees 2 Forest Service, 2007b.
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In the Forest, snowshoe hare densities were lowest in young, low density lodgepole pine stands as well as in late seral stands of mixed whitebark pine spruce fir forest (Berg et al., 2012). Based on available data in Table 3.16-2, stands with either of these characteristics appear to be limited within the Project Area. Alternatively, snowshoe hare densities were highest in multi- story thick spruce-fir forests and hare densities were high in dense, young lodgepole pine stands (30 to 70-year-old regenerating lodgepole pine). In those stands, tree basal area, horizontal cover, and tree canopy cover increased as stem density increased in the 30 to 70- year-old lodgepole pine stands (Berg et al., 2012). Based on summary data in Table 3.16-2, there are no stands of dense, young lodgepole pine with high canopy cover and trees <5 inches dbh. Horizontal cover and tree canopy were the most significant predictors of hare density in western Wyoming (Interagency Lynx Biology Team, 2013) and mature, multistory spruce-fir forests characterized by high horizontal cover provide important snowshoe hare winter habitat (see Standard VEG S6 in Forest Service, 2007b). Hayden-Wing (2011) evaluated horizontal vegetative cover in forested areas within 200 feet of each of the three existing well pads in the Project Area. A 6-foot high subdivided coverboard was used during summer 2011 to evaluate horizontal cover at ground level then elevated to six feet above ground to mimic horizontal cover for snow 6-feet deep; four measurements per sample plot were made 10 meters away from an observer. According to interim survey guidance (Bertram and Claar, 2009), thresholds for horizontal cover in winter should be equal to or greater than 35 percent horizontal cover and equal to or greater than 48 percent horizontal cover in summer. Hayden-Wing sampled within eight plots adjacent to the existing well pads. The overall average for summer horizontal cover (coverboard at ground level) was 31 percent while the overall average for winter horizontal cover (coverboard elevated 6 feet) was 23 percent. Both averaged values were below the seasonal thresholds, specified above. However, averages for one plot adjacent to well pad 23- 15 were above the summer threshold at 74 percent and above the winter threshold at 67 percent. Overall, the horizontal cover evaluated on-site, within 200 feet of the existing pads, was low, indicative of poor quality summer and winter habitat for snowshoe hares. In addition to snowshoe hares, lynx prey on red squirrels (Tamiasciurus hudsonicus), their second most important food item (Interagency Lynx Biology Team, 2013). Snowshoe hares and red squirrels were observed in the Project Area in 2011 (Hayden-Wing, 2011). According to Interagency Lynx Biology Team (2013), red squirrel densities tend to be highest in older, closed- canopy forests that have substantial quantities of coarse woody debris, and lower in young stands that lack cone production. Although there is no data on downed coarse woody debris in the Project Area, approximately 28.5 percent of the suitable lynx habitat is within coniferous forest stands with tree dbh >10 inches and canopy cover > 40 percent (Table 3.16-2) which is likely to be suitable as red squirrel habitats, supporting a secondary prey base for Canada lynx. Canada lynx have been repeatedly observed within the Project Area over time. In 1996, an adult male lynx was captured in the Forest west of Merna, approximately 15 miles north of the Project Area and an adult female lynx was captured in 1997; both animals were radio-collared. Locations of the radio telemetered male lynx indicate it likely crossed the Project Area between 1996 and 2000 (Laurion and Oakleaf, 2000). In addition to the two telemetered animals, the WGFD estimated there were 5 to 7 lynx in the general vicinity of the Merna study area during winter 1997-1998 based on snow track surveys (including the Cottonwood Creek drainage) but that estimate declined to 3 to 4 lynx after winter 1998-1999 (Laurion and Oakleaf, 1999). Squires et al. (2003) conducted snow track surveys for lynx in the vicinity of the Project Area in winter 2000 during which one set of lynx tracks was observed near North Cottonwood Creek and three sets of tracks were found in the Cottonwood Creek watershed north of the Project Area. In 2001, lynx tracks were reported in the Beaver Creek watershed (also north of the
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Project Area); Squires et al. (2003) concluded that at least four lynx inhabited the Wyoming Range. When Canada lynx were listed as threatened in 2000 (FWS, 2000), the listing included lynx within Colorado that were introduced between 1999 and 2007. During that time, the Colorado Parks and Wildlife reintroduced 218 Canada lynx to the San Juan Mountains in southwestern Colorado (Shenk, 2005). These animals are not designated as experimental under section 10(j) of the Endangered Species Act. The FWS recognized the reintroduction as important though not essential for recovery of lynx (FWS, 2006). Since their reintroduction, several radio-telemetered lynx from Colorado emigrated to the Forest. Locations for ten lynx (six males and four females) from 2004 to 2010 were made available to the Forest Service and show occupancy in the Forest for more than one year by two lynx, both females. Locations of one male lynx within the Project Area between July 2006 and July 2007 indicate presence within or near the Project Area during winter and early spring. A female lynx was present within or near the Project Area during fall and winter 2004 and another male lynx passed to the west of the Project Area in June, moving south after wintering on the Shoshone National Forest northwest of Dubois during 2005. Critical habitat was initially designated for Canada lynx in 2006 but was revised in 2009 (FWS, 2009a) and again in 2014 (FWS, 2014a). The Project Area is within critical habitat Unit 5. All designated critical habitat contains the following Primary Constituent Elements (PCEs) for lynx which identify the physical or biological features that provide for a species’ life history processes and are essential to the conservation of the species: PCE 1 - Boreal forest landscapes that support a mosaic of differing successional forest stages and contain the following: a. Presence of snowshoe hares and their preferred habitat conditions, which include dense understories of boughs that protrude above the snow, and mature multistoried stands with conifer boughs touching the snow surface; b. Winter conditions that provide and maintain deep fluffy snow for extended periods of time; c. Sites for denning that have abundant coarse woody debris, such as downed trees and root wads; and d. Matrix habitat (e.g., hardwood forest, dry forest, non-forest, or other habitat types that do not support snowshoe hares) that occurs between patches of boreal forest in close juxtaposition (at the scale of a lynx home range) such that lynx are likely to travel through such habitat while accessing patches of boreal forest within a home range.
To varying degrees, the components of PCE 1 are present within the Project Area: presence of snowshoe hares and their preferred habitat conditions are expected in some locations (see discussion of conifer stand characteristics and horizontal vegetation cover, above). Matrix habitat that may not support snowshoe hares but which would serve as a travel corridor is very likely present. Snow conditions will vary from year to year but overall winter snow in the Project Area is expected to meet PCE 1c. There have been no evaluations of potential lynx denning sites in the Project Area but given that 35.5 percent of all lynx habitat within the Project Area consists of trees with dbh >10 inches (see Table 3.16-2, above), it is reasonable to expect coarse woody debris as downed trees, root wads, and/or snags to be present in those older stands and may even be present in younger stands with trees 5 to 10 dbh. Grizzly Bear. The grizzly bear was included on the 1967 list of native fish and wildlife threatened with extinction under the Endangered Species Preservation Act of 1966 (FWS, 1967) before enactment of the Endangered Species Act of 1973. Subsequent to the Endangered Species Act, FWS (1975) listed grizzly bears as a threatened species in 1975. Grizzly bears declined as
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mountainous areas of western United States were settled and human-caused mortality was the principal affect, whether due to habitat deterioration, commercial trapping, livestock depredation control, and unregulated hunting (FWS, 2007a). Habitat destruction and degradation associated with rural development, recreation, roads, energy and mineral developments continue to threaten grizzly bears as well as human-caused mortality (FWS, 2007a). Critical habitat for the grizzly bear has not been designated. The Grizzly Bear Recovery Plan (Plan), originally approved in 1982, was revised in 1993 and addressed grizzly bear recovery in four ecosystems within the contiguous 48 states (FWS, 1993). The plan recognized that recovery required minimizing human-bear conflicts and limiting loss and degradation of habitats because of human actions, among other needed actions that focus on gaining knowledge about bears and imparting that knowledge to the public and defined six recovery zones in the United States that included the Yellowstone Grizzly Bear Recovery Zone (YGBRZ). The Plan specified numbers of females with cubs as a goal within the YGBRZ and within 10 miles of the recovery zone and criteria for the distribution of females with cubs and provided goals or desired limits for human-caused bear mortalities that would be necessary to achieve the species’ recovery. In 2007, the FWS (2007b) revised approaches to estimating minimum allowable number of females with cubs of the year and sustainable mortality limits based on new information, and analytical techniques developed/employed since 1993. The 2007 revision provided a map showing boundaries for the Yellowstone grizzly bear Distinct Population Segment (DPS), the Primary Conservation Area (PCA, same as the YGBRZ) within which habitat standards in the Conservation Strategy are applied (Interagency Conservation Strategy Team, 2007), the Conservation Strategy Management Area within which all population and mortality standards will be monitored and calculated, the current distribution of grizzly bears as of 2004, and Suitable Habitat defined by the FWS. The FWS (2013a) submitted another revision: Grizzly Bear Recovery Plan Draft Revised Supplement: Revised Demographic Recovery Criteria for the Yellowstone Ecosystem in which new approaches and scientific protocols were developed to update estimates of population size and requiring sustainable mortality rates instead of specifying mortality rates for specific sex and age groups as defined in the 2007 revision. The 2013 revision also designated a Monitoring Area within which all demographic criteria are assessed. Although not within the YGBRZ, the Project Area is within the Yellowstone Grizzly Bear DPS and within the Conservation Strategy Management Area, as defined in the 2007 recovery plan revision. The Project Area is also within the Current Distribution of Bears (Occupied Range from 2000 to 2014) as delineated by the Interagency Grizzly Bear Study Team (2015a). The mapped Occupied Range utilized all verified grizzly bear location data (often GPS telemetry locations from radio collared bears) and has shown that the grizzly bear distribution increased 38 percent from 2004 to 2010 with much of the expansion in the southern region of the species range (Bjornlie et al., 2014). An additional increase of 16 percent in the distribution as of 2014 is seen as filling in suitable habitat that was formerly unoccupied by grizzly bears (Bjornlie, 2014). Nearly 82 percent of the Project Area (approximately 3,833 acres) coincides with grizzly bear Occupied Range. The Project Area provides limited suitable habitat conditions for grizzly bears. Grizzly bears in the Yellowstone ecosystem used diverse habitat mixtures of forest, moist meadows grasslands riparian habitats throughout their annual cycle but used dense forests for resting, hiding and security cover (FWS, 1993). Most use of forested habitat cover was in stands interspersed with open habitats such as grass and forb meadows (FWS, 1993). Similar to the vegetation composition within the entire Project Area described in Section 3.19, below, vegetation composition within the Project Area coinciding with grizzly bear Occupied Range is 85.1 percent forested, consisting of aspen (2.2 percent), whitebark pine (5.4 percent), whitebark pine mix (3.9
140 Lander Peak Area Exploratory Proposal Environmental Assessment percent), spruce/subalpine fir mix (26.9 percent), and lodgepole pine (46.7 percent). The remaining 12.9 percent of the area is open vegetation in small patches, all less than 100 acres, including mountain big sagebrush, grassland/forbland, tall forbland, willow, riparian herbland, and other barren or sparsely vegetated sites. Approximately 25.4 acres in the Project Area that coincide with grizzly bear Occupied Range have been affected by roads, well pads and gathering line disturbances. The gathering line disturbances (11 acres) were revegetated and now consist of herbaceous and shrub vegetation. Grizzly bears have large home ranges, up to 300 square miles for females and 500 square miles for males (FWS, 2007a). Grizzly bears are solitary throughout most of the annual cycle except during mating and when sows are with cubs. Grizzlies are omnivores; they require food with sufficient calories to enable lipid deposition prior to hibernation and will prey or scavenge available food including ground squirrels, ungulates, carrion and garbage where available and will consume roots, bulbs, tubers fungi, and tree cambium to meet protein requirements if animal food is unavailable (FWS, 1993). Stored fat sustains bears during winter and is necessary for embryological development during gestation; embryos may not implant if a sow does not have sufficient fat reserves (FWS, 2007a). Four seasonal foods are important to grizzly bears in the Greater Yellowstone Area and include ungulates (elk, deer, moose), spawning cutthroat trout, seeds of whitebark pine, and army cutworm moths (Interagency Conservation Strategy Team, 2007). The Project Area provides spring-summer-fall ranges for ungulates (elk, mule deer, moose) and is used for calving (parturition) by elk (see Section 3.24, Wildlife, below). Neonatal big game and carrion from winter mortalities can be important sources of protein in spring (Interagency Conservation Strategy Team, 2007; Interagency Grizzly Bear Study Team, 2015b) Colorado cutthroat trout are present in South Cottonwood Creek and Bare Creek and likely spawn within or adjacent to the Project Area. Whitebark pine forests and whitebark pine mixed forests cover 356.3 acres within the northwest and southwest portions of the Project Area that coincides with grizzly bear Occupied Range. No information has been found about presence or abundance of army cutworm moths in the area but where present (alpine talus and slopes), moths are an important source of digestible energy in the fall that can sustain grizzly bears through hibernation and contribute to bears’ reproductive success (Interagency Conservation Strategy Team, 2007; Interagency Grizzly Bear Study Team, 2015b). Grizzly bear conflicts with livestock have been documented in the Horse Creek drainage, approximately 11 miles north of the Project Area. Recurring conflicts with livestock have occurred on the Horse Creek Allotment during the 5-year period, 2005 to 2014 (Interagency Grizzly Bear Study Team, 2015b). Livestock depredations and human conflicts have occurred throughout the Greater Yellowstone Ecosystem (GYE): from 1992 to 2000, Gunther et al. (2004) documented 995 grizzly bear-human conflicts in the GYE of which 74 human-caused grizzly bear mortalities resulted for defense of life and property. Most human injuries, property damage (includes camping equipment, vehicles, cabins, shed, pets, other personal property) and conflicts involving anthropogenic food (includes garbage, grease, pet food, bird seed, livestock feed, other edible human-related attractants) occurred during late hyperphagia season, from first of September until den entrance (Gunther et al., 2004). Most livestock depredations occurred during early hyperphagia (from mid-July to end of August) following den emergence and grizzly bear estrus during which bears consume elk calves, over-wintered whitebark pine seeds, and spawning cutthroat trout (Gunther et al., 2004).
Gray Wolf. The FWS removed gray wolves in Wyoming from the list of Endangered Species in 2012, declaring the population had recovered and no longer required the status of non-essential experimental population (FWS, 2012) and management of gray wolves was returned to the state. In September 2014, the U.S. District Court for the District of Columbia vacated the delisting of wolves in Wyoming and reinstated the 2009 final rule (FWS, 2009b) regulating the
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gray wolf in Wyoming as a non-essential experimental population. In order to comply with recent court orders, the FWS (2015a) issued a final rule in February 2015 reinstating regulatory protections under the Endangered Species Act for the gray wolf in Wyoming. For purposes of section 7 consultation under the Endangered Species Act, gray wolves in most of Wyoming are treated as a proposed species; for federal actions that may affect gray wolves on lands outside of National Parks and National Wildlife Refuges, section 7(a)(4) applies. Wolves in Wyoming are currently listed and protected under the Endangered Species Act, with additional flexibility provided for their management under the provisions of the special regulations promulgated for this non-essential experimental population (see FWS, 2015a). Suitable wolf habitats include a year-round prey base of ungulates and alternate prey, semi- secluded denning and rendezvous sites, and sufficient space with minimal exposure to humans. Preferred prey include big game species; deer, elk, and moose. Wolves den in late March or early April and are sensitive to human disturbance near active den sites. A wolf pack territory can range from 50 square miles to more than 1,000 square miles. Wolf pack rendezvous sites are often a mosaic of meadows and hillside timber, with a water source available in the vicinity (FWS, 1987). In 2014, the WGFD provided monitoring information on three known wolf packs from 5 to 40 miles north of the Project Area. In 2014, the following were minimum pack sizes for the three packs (WGFD et al., 2015): Daniel pack, two wolves; Dell Creek pack, eight wolves; Horse Creek pack, five wolves. Wolves from the Daniel and Dell Creek packs were legally harvested in 2014 and two other wolves, one from Daniel and another from Horse Creek pack, were killed but not from legal harvest or as control actions. At one time, the Daniel pack, discovered in 2003, contained 16 to 17 individuals in an area estimated to be at a minimum of 2 miles from the Project Area (Daniel pack polygon data from WYNDD, 2014). From 2011 to 2012, six observations of wolves – three of them legal harvests – were reported from the WGFD Wildlife Observation System within 5 miles of the Project Area (WYNDD, 2014). As the wolf population in the Greater Yellowstone Ecosystem grew, so did too did livestock depredations. However, the FWS began a more aggressive approach to wolf control in 2006 following confirmed depredation of livestock and the number of livestock lost since then has declined even with an increasing wolf population (WGFD et al., 2015). Livestock depredations have been reported by Wolf Hunt Areas, all of which are north of the Project Area. The Project Area is not within the Wolf Trophy Game Management Area (WGFD, 2011). Wolves have also preyed on and displaced wintering elk on feedgrounds (Dean et al., 2004). Wolves may be lethally removed if they displace elk from a feedground causing one of three conflict situations as defined in Wyoming’s Wolf Management Plan (WGFD, 2011). In 2003, wolves displaced elk from the North Piney feedground about 7 miles south of the Project Area to the Bench Corral feedground, 20 miles east of the Project Area (Dean et al., 2004). Both the feedgrounds and the Project Area are outside of the Wolf Trophy Game Management Area and so would be managed as Predatory Animals under Wyoming’s Wolf Management Plan. The 2014 court order places gray wolves under federal protection and suspends the take of gray wolves in Wyoming as specified in the state Wolf Management Plan. With the decrease of wolf numbers in the Daniel pack and recent undocumented reproduction (WGFD et al., 2015), the presence of wolves on elk ranges in the Project Area is less likely although the presence of a seasonal prey base does not negate the possibility. Wolverine. Wolverines in the Project Area were proposed for listing as threatened under Endangered Species Act (FWS, 2013b) but the proposed action was withdrawn in 2014 (FWS, 2014b). On April 4, 2016 United States District Court for the District of Montana vacated the FWS August 13, 2014 withdrawal of its proposed rule to list the distinct population segment of
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the North American wolverine as threatened under the ESA (Defenders of Wildlife v. Jewell et al., 2016); the wolverine remains a proposed threatened species. Wolverines in Wyoming inhabit subalpine coniferous forests, especially dense continuous stands in remote areas (WGFD, 2012b, WGFD, 2010a). They feed on carrion and live prey including mule deer, elk, moose, rabbits, hares, porcupines, beaver, squirrels, chipmunks, marmots, mice, birds, gophers, berries in the summer, and carrion in late winter/early spring (WGFD, 2012b). Parturition occurs in natal dens covered with snow and accessed through snow. Natal or birthing dens are used only briefly, and the kits are soon moved to maternal dens until later in the spring (Beauvais and Johnson, 2004). Deep, persistent, and reliable spring snow cover during the denning period from mid-April through mid-May is the best overall predictor of wolverine occurrence in the contiguous United States (Aubry et al., 2007). The Forest represents the southern-most extent of known wolverine distribution in the Rocky Mountains, with the exception of a few infrequent wolverine documentations in Colorado and Utah. There have been multiple reports of wolverines from areas north and south of the Project Area between 1971 and 1978 in Hoak et al. (1982). One of the observations reported from 1973 was of two adults and one young in an area about 3.7 miles from the Project Area (Wyoming Natural Diversity Database - WYNDD, 2014), indicating wolverines had reproduced in the vicinity. Snow-track surveys were conducted for lynx and other forest carnivores in the vicinity of the Project Area and elsewhere in the Wyoming Range during winters from 2000 to 2002 (Squires et al., 2003); no wolverine tracks were reported. Forest Service (2016) indicates that the Forest does have wolverines present, but available information suggests that numbers and density are extremely limited. The Project Area provides limited suitable habitat conditions for wolverines. Suitable habitat could include a mix of approximately 3,898 acres of five forest/wooded types (Table 3.19-1, below): aspen, whitebark pine, whitebark pine mix, spruce/subalpine fir mix, and lodgepole pine mix. A portion of the Project Area (approximately 106 acres) burned during the 2005 Triple fire and may have affected some potential suitable habitats.
Yellow-billed Cuckoo. The FWS (2014c) listed the Western DPS of yellow-billed cuckoo as threatened under the Endangered Species Act in 2014. The western Distinct Population Segment closely aligns with the defined range of the western yellow-billed cuckoo subspecies as partially described in the 12-month finding (2001) determining listing the species as threatened was warranted but precluded by higher priorities (FWS, 2001). The western DPS includes suitable habitat within low- to moderate-elevation areas west of the crest of the Rocky Mountains in Canada, Mexico, and the United States, including the Colorado River Basin in western Wyoming. The FWS (2014d) has mapped areal ranges within which proposed projects may affect listed, proposed, and/or candidate species (areas of influence). Projects within the delineated ranges should be considered relative to section 7 consultations under the Endangered Species Act. The FWS has mapped the Green River Basin, including South Fork Cottonwood Creek and Bare Creek within the Project Area as section 7 consultation range (area of influence) for yellow-billed cuckoo. Yellow-billed cuckoos are considered a riparian-obligate species and are usually found in large tracts of cottonwood/willow habitats with dense sub-canopies, but may also be found in urban areas with tall trees (FWS, 2007c). The decline of the western yellow-billed cuckoo is primarily due to loss and degradation of riparian habitat loss from numerous factors including alteration of hydrology caused by dams, water diversions, management of riverflow that differs from natural hydrological patterns, channelization, and levees and other forms of bank stabilization that encroach into the floodplain. In addition, conversion of floodplains and native riparian vegetation for agricultural and invasions of nonnative vegetation, often in monotypic stands, reduces the
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suitability of riparian habitat for the western yellow-billed cuckoo (FWS, 2014c). In Wyoming, habitat for the species has and continues to decline as a result of nonnative plant (tamarisk) invasion; yellow-billed cuckoo are not found in areas that are totally dominated by tamarisk with the complete lack of willows or cottonwoods (FWS, 2014c). Loss of riparian habitat may cause a highly fragmented landscape, which in combination with lack of immigration, reduced populations of prey species (food items), pesticides, and collisions with tall vertical structures during migration (communication towers, can reduce breeding success through increased predation rates and barriers to dispersal by juvenile and adult western yellow-billed cuckoos (FWS, 2014b). Other threats to riparian habitat include long-term drought and climate change. Critical habitat for yellow-billed cuckoos was also proposed in 2014 (FWS, 2014d), including Wyoming, but no critical habitat was proposed in the Project Area. The closest proposed critical habitat unit is in Sweetwater County on the Green River (part of Seedskadee National Wildlife Refuge) about 64 miles southeast of the Project Area. The FWS (2014d) identified three PCEs: • PCE 1 - Riparian woodlands with mixed willow-cottonwood vegetation or other native riparian vegetation in contiguous or nearly contiguous patches >325 feet wide and >200 acres or more. Suitable patches would contain one or more nesting groves, which are generally willow-dominated, have above average canopy closure (greater than 70 percent), and have a cooler, more humid environment than the surrounding riparian and upland habitats (FWS, 2014d). • PCE 2 - Presence of a prey base consisting of large insect fauna and tree frogs for adults and young in breeding areas during the nesting season and in post-breeding dispersal areas (FWS, 2014d). • PCE 3 - Dynamic riverine processes that cause sediment movement and deposits that allow seedling germination and promote plant growth, maintenance, health, and vigor (e.g. lower gradient streams and broad floodplains, elevated subsurface groundwater table, and perennial rivers and streams) that allow seedling germination and promote plant growth, maintenance, health, and vigor leading to riparian vegetation with variously aged patches (FWS, 2014d). Riparian vegetation in the Project Area consists of approximately 183 acres of riparian willows and other shrubs bordering South Cottonwood Creek and forks of Bare Creek (see Table 3.19- 1, below) but no overstory of cottonwood-willows that could provide suitable nesting groves (e.g., PCE 1) occur in the Project Area. No yellow-billed cuckoos have been reported on any of the 21 Breeding Bird Survey routes within 75 miles from the Project Area during the past 20 years (see Section 3.8, Migratory Birds). Yellow-billed cuckoos (Western DPS) have been reported along the Lower Green River Basin from Seedskadee National Wildlife Refuge to Flaming Gorge Reservoir and west to the Bear River Drainage during 1970’s and early 1980’s (see Figure 2, in Bennett and Keinath, 2001).
Endangered Colorado River Fish. Four species of Colorado River Basin fish, the bonytail, Colorado pikeminnow, humpback chub and razorback sucker, are listed as endangered (FWS, 1970, 1980 and 1991). Primary threats to all four endangered fish species are from stream flow regulation and habitat modification, including coldwater dam releases, habitat loss, and blocked migration corridors, as well as competition from non-native fish species, pesticides, and pollution (FWS, 1980; FWS, 2002a). Cold temperatures in water below dams, reduced flows, and introduced fish species affected pikeminnow, razorback sucker, bonytail and humpback chub reproduction and survival (FWS, 2002b, FWS, 2002c) and blocked migration corridors, as well as competition from non-native fish species, pesticides, and pollution (FWS, 2002c). The Colorado pikeminnow, razorback sucker, and humpback chub were historically found in the Green River, downstream of the Wyoming-Utah border which is now inundated by Flaming
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Gorge Reservoir. These species may have been seasonal residents in Wyoming within the Green River but were extirpated from the Green River in Wyoming following construction of the Flaming Gorge Dam. Bonytail may have been present in Wyoming although historical records may not discern bonytail from similar species (WGFD, 2010a). The four species have been extirpated from Wyoming. In Colorado, Colorado pikeminnows are found in the Green, Yampa, Little Snake, White, Colorado, Gunnison, San Juan, and Dolores rivers (Woodling, 1985; FWS, 2002b); in the Green River pikeminnows are known from Lodore Canyon downstream to the confluence with the Colorado River. Naturally reproducing populations of razorback suckers are only found in the middle Green River in Utah and in an off-channel pond in the Colorado River near Grand Junction (FWS, 2002d). Razorback suckers occupy the Green River from its confluence with the Yampa River through its length within Uintah County and in the Duchesne River in Utah (FWS, 2008b). The known historic distribution of humpback chubs includes portions of the mainstem Colorado River and four of its tributaries: the Green, Yampa, White, and Little Colorado (FWS, 2002c), but recent monitoring has reported humpback chubs in the Desolation Canyon-Gray Canyon reaches of the Green River (FWS, 2002c). Bonytails have recently been restocked in the Green River above the Lodore Canyon near Brown’s Park, Colorado and within the lower reaches of the Yampa River near its confluence with the Green River at Echo Park (FWS, 2005) Critical habitat (FWS, 1994) has been designated for all four species in the Green River and its 100-year floodplain from the confluence with the Yampa River in Moffat County, Colorado, through Utah to the confluence with the Colorado River, in Wayne County, and the Colorado River to Lake Powell. Three PCEs of the critical habitat include water, physical habitat and the biological environment (FWS, 1994). The water PCE includes quantity of water with sufficient quality (adequate temperature, dissolved oxygen, lack of contaminants, nutrients, turbidity) that would provide for a life stage for each of the listed species at a specific location (FWS, 1994). The physical habitat PCE provides spawning, nursery feeding and rearing habitats, or access to those habitats and is found in river channels as well as bottom lands, side channels, secondary channels, oxbows, backwaters and other areas within the 100-year floodplain of the Green River, which when inundated, provides habitats for the species’ various life stages (FWS, 1994). Floodplains that have been previously developed are not likely to provide PCEs (FWS, 1994). The biological environment PCE includes food resources for the listed species. Predation and competition by other species are additional components of the biological environment that are of concern because introduced, nonnative fish species have limited population growth of listed species at some locations (FWS, 1994). Forest Service Sensitive and Other Special Status Animal Species
A requirement of the National Forest Management Act (as described in the implementing regulations at 36 CFR 219 19) is that fish and wildlife habitats on NFS lands be managed to maintain viable populations of existing native and desired non-native vertebrate species in the planning area. The Forest Service identifies sensitive animal and plant species that should be managed to ensure population viability and to preclude trends toward endangerment that would result in listing under the Endangered Species Act. In 2013, the Forest Service, Region 4 (Forest Service, 2013b) identified 6 mammals, 12 birds, 32 herpetofauna, and 5 fish species that are considered sensitive wildlife and could occur within the Bridger-Teton National Forest. Based on known distributions and habitat requirements, 14 of those species could occur in the Project Area (Table 3.16-3). Some of the sensitive species are proposed for listing or candidate species under the Endangered Species Act and are included above, and some species were identified as Species of Concern by the FWS. According to Forest Service Manual 2670, there must be no impacts to sensitive species without an analysis of the significance of adverse
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effects on the populations, its habitat, and on the viability of the species as a whole (Forest Service, 2002). In addition to the discussion, below, a detailed analysis of Project effects to individual Forest Service sensitive species that could occur in the Project Area is included in Attachment D, Biological Evaluation for Sensitive Species and Management Indicator Species Report. Several of the Forest Service sensitive species in Table 3.16-3 were also identified as Management Indicator Species (MIS) for the Forest, as directed by the National Forest Management Act of 1976. The Forest Plan (Forest Service, 2015a) identifies seven ecological indicator species as having important requirements provided by specific habitats (see Table 3.16-3): the pine marten inhabiting older coniferous forest; Brewer’s sparrow inhabiting sagebrush shrub; cutthroat trout, indicative of riparian habitat; bighorn sheep indicative of mountain meadow habitat; boreal toad and boreal chorus frog as indicators of wetland habitat; and aspen (discussed below in Section 3.19, Vegetation) as the indicator species for aspen habitat. All of these ecological MIS have been found within the Project Area or documented in the Project vicinity. Also, the Forest Plan (Forest Service, 2015a) identified six species as Harvest Indicator Species. Four of those are big game animals, discussed below in Section 3.24, and two are trout. The MIS species are also included in the Biological Evaluation for Sensitive Species and Management Indicator Species Report (Attachment D). In addition to Forest Service sensitive species and MIS, the WGFD (2010a) revised the State Wildlife Action Plan (SWAP) which identifies Wyoming Species of Greatest Conservation Needs (SGCN) and assigns each species at risk of population decline and/or habitat threats/loss a Native Species Status number, 1 through 4 (included in Table 3.16-3). The SWAP also assigns priorities for conservation of SGCN species ranging from Tier I, highest priority to Tier III, lowest priority. Species that are either known to occur in the Project Area or could occur in the Project Area are included in Table 3.16-3. Mammals. Two Forest Service MIS species included in Table 3.16-3 have been reported in the Project Area or vicinity (WYNDD, 2014): American marten within 0.2 mile of the Project Area and Rocky Mountain bighorn sheep that is also a Forest Service sensitive species. There is one report (WGFD Wildlife Observation System) of bighorn sheep within the Project Area from 1983 and several observations made at higher elevations within 5 miles south of the Project Area during the 1990s and early 2000s (WYNDD, 2014). An estimated 1,319 acres within the Project Area are deciduous and coniferous forest stands with trees larger the 10 inches dbh that likely represent late successional or old growth stands (see Table 3.16-2). Those areas may be inhabited by pine martens, although no pine martens were observed during surveys conducted for the Project in 2011 (Hayden-Wing, 2011). Yearlong and winter bighorn sheep habitat is mapped further than 6 miles south of the Project Area, which correlates to most observations of bighorn sheep at higher elevations 5 miles south of the Project Area (WYNDD, 2014). Bighorn sheep may occur in the Project Area occasionally but not on a regular basis. Birds. On-site biological surveys were conducted during July and August 2011 (Hayden-Wing, 2011) during which five of the species included in Table 3.16-3 were observed: northern goshawk, sandhill crane, sage thrasher, American three-toed woodpecker, and Brewer’s sparrow. Birds in Table 3.16-3 that have also been identified by the FWS (2008a) as Birds of Conservation Concern (BCC) for the Project Area are discussed in Section 3.8.
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Table 3.16-3 Forest Service Sensitive Animal Species and Wyoming Species of Greatest Conservation Need Not Listed Under the Endangered Species Act that Could Potentially Occur in the Vicinity of the Project Area Common Name Potential Federal State Scientific Name Habitat 1 Occurrence 2 Sensitive3 SGCN4 Mammals Dwarf Shrew Coniferous forests, aspen, mountain-foothills shrublands. Nests in a NSS3 Possible Sorex nanus burrow; feeds on carrion of small mammals, arthropods. Tier II Vagrant Shrew Riparian shrub, moist meadow grasslands, bogs, and other riparian NSS4 Possible Sorex vagrans marsh habitats. Nests in burrow, feeds on invertebrates. Tier III Western Small-footed Myotis Sagebrush-grasslands; eastern great plains. Buildings used for roosts, NSS4 Possible Myotis ciliolabrum nurseries; Hibernates in caves, mines. Feeds on flying insects. Tier II Long-eared Myotis Ponderosa pine, juniper, cottonwood riparian; roosts in caves, NSS3 Possible Myotis evotis buildings, and mines. Forages over water. Tier II Little Brown Myotis Coniferous and deciduous forests, sagebrush-grasslands, riparian NSS4 Possible Myotis lucifugus shrub, urban areas. Roosts in caves, buildings. Forages over water. Tier II Long-legged Myotis Coniferous and deciduous forests, basin-prairie and mountain-foothills NSS3 Possible Myotis Volans shrublands, riparian areas. Tier II Big Brown Bat Coniferous and deciduous forests, basin-prairie and mountain-foothills. NSS4 Possible Eptesicus fuscus Roosts and hibernates in buildings, occasionally in rock crevices. Tier II Pygmy Rabbit Dense, tall stands of big sagebrush often along intermittent streams or NSS3 Unlikely FWS SOC Brachylagus idahoensis riparian areas in sagebrush-grasslands. Tier II White-tailed Prairie Dog Basin-prairie shrublands, sagebrush-grasslands, shortgrass/mindgrass Unlikely FWS SOC Cynomys leucurus grasslands. Nests in burrow. Northern Flying Squirrel NSS4 Coniferous forests. Nests in cavity or leaf nest in tree. Possible Glaucomys sabrinus Tier II Forest American Marten Mature spruce-fir forests, also lodgepole pine, Douglas-fir. Considered Documented NSS4 Service R4 Martes Americana and old-growth conifer obligate. In vicinity Tier II MIS Northern River Otter Lakes, streams, moist meadows, marsh-swamp wetlands in aspen, NSSU Possible Lontra Canadensis cottonwood-riparian and riparian shrub vegetation. Tier II Forest Rocky Mountain Bighorn Sheep Cliffs, rock outcrops, coniferous forests, mountain foothills and alpine Documented Service R4 NSS4 Ovis canadensis canadensis grasslands and meadows. In vicinity Sensitive Tier II and MIS Birds Forest Trumpeter Swan Marshes, lakes, rivers. Nests on a muskrat house, a very small island, NSS2 Possible Service R4 Cygnus buccinators or a piece of floating bog. Present on BBS routes within 75 miles. Tier II Sensitive Northern Pintail Marshes and lakes in association with most habitats below 8,000 feet. NSS3 Possible Anas acuta Present on BBS routes within 75 miles. Tier II Canvasback NSS3 Marshes, lakes, rivers. Present on BBS routes within 75 miles. Possible Aythya valisineria Tier II
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Common Name Potential Federal State Scientific Name Habitat 1 Occurrence 2 Sensitive3 SGCN4 Redhead NSS3 Marshes, lakes, rivers. Present on BBS routes within 75 miles. Possible Aythya americana Tier II Lesser Scaup NSS3 Marshes, lakes, rivers. Present on BBS routes within 75 miles. Possible Aythya affinis Tier II Barrow’s Goldeneye Nests in cavity, aspen, cottonwood-riparian, mixed conifers by NSS3 Possible Bucephala islandica marshes, lakes rivers. Present on BBS routes within 75 miles Tier II Forest Harlequin Duck NSS3 Rivers and lakes in mountainous areas. Possible Service R4 Histrionicus histrionicus Tier II Sensitive Forest Common Loon Lakes above 6,000 feet, lower elevations during migration. Present on NSS1 Unlikely Service R4 Gavia immer BBS routes within 75 miles. Tier I Sensitive Clark’s Greebe Marshes, lakes. Nest is a floating platform of reeds in shallow water. NSSU Unlikely Aechmophorus clarkia Present on BBS routes within 75 miles. Tier II American Bittern Marshes; Nests on dry ground above the water or mud in emergent NSS3 Possible Botaurus lentiginosus vegetation. Present on BBS routes within 75 miles. Tier II Snowy Egret Marshes, lakes, rivers. Nests in bulrushes or cattails, or in a shrub on NSS3 Unlikely Egretta thula an island. Present on BBS routes within 75 miles. Tier II Black-crowned Night-Heron Marshes, lakes. Nests in a low shrub or on the ground on an island or NSS3 Possible Nycticorax nycticorax in bulrushes or cattails. Present on BBS routes within 75 miles. Tier II White-faced Ibis Marshes, wet-moist meadows, lakes, irrigated meadows. Nests in NSS3 Unlikely Plegadis chihi bulrushes or cattails. Present on BBS routes within 75 miles. Tier II Basin-prairie and mountain-foothills shrublands, wet-moist meadows, Forest Greater Sage-grouse alfalfa, irrigated native meadows. Nests on the ground under a Documented Service R4 NSS2 Centrocercus urophasianus sagebrush shrub. Feeds on vegetation, especially sagebrush in the in Vicinity Sensitive Tier I winter; forbs; insects. Designated Priority Habitat on-site. FWS SOC Forest Coniferous forests, cottonwood-riparian near large lakes and rivers. Service R4 Bald Eagle Documented NSS2 Forages in open habitats during the winter. Present on BBS routes Sensitive Haliaeetus leucocephalus in vicinity Tier I within 75 miles. FWS SOC/BCC Forest Northern Goshawk Coniferous forests, especially Douglas fir and lodgepole pine, aspen. Documented NSSU Service R4 Accipiter gentilis Present on BBS routes within 75 miles. on-site Tier I Sensitive Most habitats below 9,000 feet with open areas for foraging. Nests in Swainson’s Hawk Documented NSSU an old nest, usually magpie, in a coniferous or deciduous tree. Present FWS BCC Buteo swainsoni in vicinity Tier II on BBS routes within 75 miles. Most habitats below 8,500 feet. Nests in an old nest, usually magpie, Merlin NSSU in a coniferous or deciduous tree. Present on BBS routes within 75 Possible Falco columbarius Tier III miles. Peregrine Falcon Nests on a ledge or in a hole on a tall cliff in most habitats. Present on Documented Forest NSS3 Falco peregrinus BBS routes within 75 miles. in vicinity Service R4 Tier II
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Common Name Potential Federal State Scientific Name Habitat 1 Occurrence 2 Sensitive3 SGCN4 Sensitive FWS BCC Wet-moist meadow grasslands, sedge meadows, irrigated native and Sandhill Crane Documented NSS4 introduced meadows, small grains, marshes. Present on BBS routes Grus canadensis on-site Tier II within 75 miles. Shortgrass, mixed grass prairies, sagebrush-grasslands. Often Mountain Plover NSSU associated with prairie dog towns. Present on BBS routes within 75 Unlikely FWS SOC Charadrius montanus Tier I miles. Sagebrush-grasslands; eastern great plains, wet-moist meadow Long-billed Curlew Documented NSS3 grasslands; irrigated native meadows. Present on BBS routes within FWS BCC Numenius americanus in vicinity Tier II 75 miles. Franklin’s Gull Marshes, lakes, scavenges in most open habitats; Nests on a floating NSS3 Unlikely Larus pipixcan platform. Present on BBS routes within 75 miles. Tier II Black Tern Marshes, aquatic areas. Nests on a floating mat of dead vegetation, NSS3 Unlikely Chlidonias niger often on a muskrat house. Present on BBS routes within 75 miles. Tier II Forster’s Tern Marshes, aquatic areas. Nests on the ground close to water or on a NSS3 Unlikely Sterna forsteri floating mat in emergents. Present on BBS routes within 75 miles. Tier II Forest Boreal Owl Documented NSS3 Subalpine conifer forests with snags for nesting cavities. Service R4 Aegolius funereus in vicinity Tier II Sensitive Northern Pygmy-owl Lodgepole pine, Douglas-fir, Englemann spruce-subalpine fir; Cavity Documented NSSU
Glaucidium gnoma nester in snag. Present on BBS routes within 75 miles. in vicinity Tier II Grasslands, basin-prairie shrublands, agricultural areas. Nests in Burrowing Owl Documented NSSU mammal burrow, especially prairie dogs. Present on BBS routes within Athene cunicularia in vicinity Tier II 75 miles. Forest Great Gray Owl Lodgepole pine, Douglas-fir, Englemann spruce-subalpine fir; Nests in Documented NSSU Service R4 Strix nebulosi abandoned buteo hawk nest. in vicinity Tier I Sensitive Basin-prairie shrublands, grasslands, marshes, irrigated native Short-eared Owl NSS4 meadows. Nests on the ground, Present on BBS routes within 75 Possible Asio flammeus Tier II miles. Lewis’ Woodpecker Ponderosa pine savannah, pine/juniper, other coniferous forests. NSSU Possible FWS BCC Melanerpes lewis Present on BBS routes within 75 miles. Tier II Forest Three-toed Woodpecker Lodgepole pine, Douglas fir, other coniferous forests that have Documented NSSU Service R4 Picoides dorsalis recently burned. Present on BBS routes within 75 miles. in vicinity Tier II Sensitive Willow Flycatcher Riparian shrub including willow, hawthorn, water birch, alder; below Documented NSS4 FWS BCC Empidonax traillii 9,000 feet. Present on BBS routes within 75 miles. in vicinity Tier II Sage Thrasher Basin-prairie and mountain-foothills shrublands. Nest is concealed in Documented NSS4 FWS BCC Oreoscoptes montanus or beneath a sagebrush shrub. Present on BBS routes within 75 miles. on-site Tier II Brewer’s Sparrow Basin-prairie and mountain-foothills shrublands, especially sagebrush. Documented Forest NSS4 Spizella breweri Present on BBS routes within 75 miles. on-site Service R4 Tier II
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Common Name Potential Federal State Scientific Name Habitat 1 Occurrence 2 Sensitive3 SGCN4 MIS FWS BCC Sage Sparrow Basin-prairie and mountain-foothills shrublands. Usually nests in or Documented NSS4 FWS BCC Amphispiza belli under sagebrush. Present on BBS routes within 75 miles. in vicinity Tier II Amphibians Forest Boreal Toad In wet areas of foothills, montane and alpine zones from 8,000 to Documented Service R4 NSS1 Anaxyrus boreas boreas 11,000 feet. on-site Sensitive and Tier I MIS Forest Columbia Spotted Frog Ponds, wetland, and small streams from mountain foothills to higher Documented NSS3 Service R4 Rana luteiventris elevation coniferous forests. in vicinity Tier II Sensitive Forest Boreal Chorus Frog Moist margins of marshes, ponds, small lakes, creeks, up to 12,000 Documented Service R4 Pseudacris maculate feet. in vicinity MIS Fish Forest Colorado River Cutthroat Trout Documented Service R4 NSS2 Cold clear water in rocky, steep gradient streams. Oncorhynchus clarkii pleuriticus on-site Sensitive Tier II and MIS Rainbow Trout Cold rivers, streams, and other water. Possible MIS Oncorhynchus mykiss 1 WGFD, 2012b; WYNDD, 2014. 2 Potential Occurrence: Unlikely: May or may not occur in Sublette County but no suitable habitat is present. Possible: Occurs in Sublette County and the Forest, suitable habitat is present, may have been observed in the region but not observed at the Site. Documented in vicinity with records of species provided by WYNDD, 2014 and Sauer et al., 2014. 3 Federal Sensitive: Forest Service Sensitive Species in Region 4 (Forest Service, 2013b) and Management Indicator Species (MIS) in the Forest (Forest Service, 2015a). FWS Species of Concern (SOC) and Candidate species under the Endangered Species Act (ESA-C). FWS Birds of Conservation Concern (BCC). 4 State Species of Greatest Conservation Concern (SGCN) identified in the State Wildlife Action Plan (WGFD, 2010a): Native Species Status: NSS2, population or distribution is restricted, declining with possible extirpation; severe limiting factors may or may not be increasing. NSS3, population or distribution is restricted, declining but extirpation not imminent; severe limiting factors are not increasing. NSS4, population or distribution may be declining or stable; severe limiting factors are not increasing or are moderate and may increase in severity. NSSU, status unknown until additional information is obtained. State Wildlife Action Plan priorities for conservation of SGCN species: Tier I - highest priority, Tier II - moderate priority, Tier III - lowest priority.
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Multiple goshawk vocal responses were recorded though no nest structure was found. The survey results indicated that the Project Area coincides with at least one active goshawk territory (Hayden-Wing, 2011). A new goshawk nest in the vicinity of the Project Area was documented in 2012-2013 during surveys supported by WGFD and conducted by the Rocky Mountain Bird Observatory to detect nesting goshawks within the Wyoming Range (Berven, 2014). In addition, records of northern goshawks 1978, 1982, 1984, and 1993 from the Wyoming Natural Diversity Database (WYNDD, 2014) coincide with the Project Area. Surveys for American three-toed woodpeckers were conducted in the Project Area during August, 2011 (Hayden-Wing, 2011) with broadcast acoustical surveys; a total of five three-toed woodpecker responses were recorded during surveys. Previously, multiple detections of three- toed woodpeckers were made during surveys conducted in 2009 by the WGFD in an area of the Wyoming Range that included the Project Area. Records of sage thrashers and Brewer’s sparrows from WYNDD overlap, occur within, or are adjacent to the Project Area, some of them reported from the Soda Lake Breeding Bird Survey route (number 92071); approximately 2.8 miles of the Soda Lake BBS route crosses the Project Area (BBS routes are typically 24.5 miles long). The Soda Lake route had been surveyed annually 18 times between 1981 and 2005, the last year surveyed. Sage thrashers had been reported on the route during 5 years and Brewers’ sparrow during 17 of the last 18 observation years (Sauer et al., 2014). Other species in Table 3.16-3 have been documented in the Project Area vicinity including (WYNDD, 2014): bald eagle (from 1980-2005, within Project Area), peregrine falcon (in 1989, 0.5 mile; 1978, 2.6 miles; 2010, 3.9 miles), long-billed curlew (from 1991-2009, 0.9 mile away), boreal owl (in 2009, 2.8 miles away), northern pygmy owl (in 2009, 0.7 mile away), burrowing owl (in 2009, 4.4 miles), and great gray owl (in 1988, 1 mile away). Many of the bird species reported in the vicinity are likely to have nested in the Project Area based on available habitat (see Table 3.19-1, below). Greater sage-grouse was petitioned for listing under the Endangered Species Act in 2003. In 2010, the FWS determined that listing greater sage-grouse as threatened or endangered throughout its range was warranted but precluded by other activities (FWS, 2010b). Following a court-ordered obligation to issue a listing decision by September 30, 2015, the FWS (2015c) determined that listing greater sage-grouse under the Endangered Species Act was not warranted, basing their decision on new information and regulatory mechanisms in various plans developed by federal agencies and states since 2010 that reduce threats to the species on 90 percent of breeding habitats across the range of greater sage-grouse. Greater sage- grouse is also a Species of Greatest Conservation Concern identified in the Wyoming State Wildlife Action Plan (WGFD, 2010b) as a Tier I species with highest priority for conservation and with Native Species Status of NSS2, a species with population or distribution that may be declining or stable; severe limiting factors are not increasing or are moderate and may increase in severity.
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The Forest Service in cooperation with the BLM, amended land use management plans to include protections of the greater sage-grouse and its habitat through land use allocations that limit or eliminate new surface disturbance in Priority Habitat Management Areas (PHMAs) and Sagebrush Focal Areas, and minimize surface disturbance in General Habitat Management Areas (GHMAs). PHMA on NFS lands in Wyoming are identified as having the highest habitat value for maintaining sustainable sage-grouse populations; core habitats are the most important breeding and nesting habitat within PHMA. Approximately 233.48 acres of the Project Area coincide with PHMA (core habitat) as defined by the Forest Service (2015b), of which only 158.41 acres is potentially suitable habitat (see Map 3.16-1). PHMA within the Project Area is represented by Mountain Big Sagebrush with 25 to 100 percent canopy cover (118.94 acres) that might provide some nesting and brood-rearing habitats, and Mountain Big Sagebrush with less canopy cover (39.47 acres with 10 to 24 percent canopy cover) that might be more suitable as nesting habitat. PHMA in the Project area is on the far edge of a narrow, delineated area of PHMA along South Cottonwood Creek and near forested habitat. GHMA lands are outside of PHMA and are occupied by sage-grouse seasonally or year-round. The Project Area overlaps approximately 10 acres of GHMA; however, only 2.6 acres of GHMA within the Project Area provide potentially suitable habitat (2.27 acres of Mountain Big Sagebrush and 0.33 acres of Silver Sagebrush/Shrubby Cinquefoil). No herbaceous vegetation that might serve as brood-rearing habitat coincides with GHMA or PHMA inside the Project Area but is found elsewhere in the Project Area. Areas are managed for breeding and nesting within 5.3 miles from occupied leks to encompass the seasonal movements and habitat use of 90-95 percent of sage-grouse associated with the lek (Forest Service, 2015b). There are no occupied leks within the Project Area. The closest occupied lek (Mickelson Creek) is approximately 4.9 miles east of the Project Area on private land; however, Forest Service-delineated PHMA within the Project Area is greater than 5.3 miles from the Mickelson Creek lek. Vehicle access to the Project Area from U.S. Highway 189 would follow the Cottonwood-Ryegrass Road to Ryegrass Junction and continue on Cottonwood Road to the Forest boundary. Access roads from U.S. Highway 189 pass through PHMA for about 17.7 miles (see Map 3.16-2). Based on data available through 2015, there are 27 occupied leks within 5.3 miles of roads accessing the Project Area; leks all occur within the PHMA and are greater than 0.25 mile from the access roads, with the exception of one lek (273 feet from access road). WGFD defines an occupied lek as one that has been active at least one strutting season within the prior ten years while an active lek has been attended by male sage- grouse during the strutting season in a given year (Forest Service, 2015b).
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Map 3.16-1 Greater Sage-Grouse Habitat
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Map 3.16-2 Greater Sage-Grouse Habitat and 5.3-Mile Lek Buffers
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Peak counts of males attending leks during spring are used as a population index to evaluate trends in greater sage-grouse populations (Connelly et al., 2004). The WGFD compiled annual peak counts of males attending leks through 2015. Peak counts of males, averaged each year for active leks within 5.3 miles of vehicle access roads to the Project Area, indicate that the local population in the vicinity of the access route has been increasing for the past 5 years \2011 to 2015 following some variability during the previous 5 years, 2006 to 2010 (Figure 3.16-1).
Figure 3.16-1 Average Peak Counts of Greater Sage-Grouse Males at Active Leks within 5.3 miles of Access Roads from U.S. Highway 189 into the Project Area from 2006 through 2015
Amphibians. Within the Project Area, there are 34.8 acres of open water, 13.3 acres of emergent wetlands/riparian, and 183.0 acres of forested/shrub wetland/riparian that might provide suitable habitat for Forest Service sensitive and MIS species (see Table 3.19-1,below). On-site biological surveys were conducted during July and August 2011 (Hayden-Wing, 2011) during which one adult boreal toad and a boreal toad call were reported within the Project Area along the West Fork Bare Creek, and one adult boreal chorus frog was detected along South Fork Bare Creek in late July 2011, and two adult boreal chorus frogs were detected along West Fork Bare Creek along with dozens of metamorphosed boreal chorus frogs. Amphibians observed probably reproduced in the areas where they were found. Additionally, multiple records from Forest Service (2016) and WYNDD (2014) indicate boreal toads are likely breeding in the Project Area along the margin of Soda Lake, South Cottonwood Creek, Trailer Creek, and the confluence of Bare Creek and South Cottonwood Creek. Within the Project Area and vicinity, boreal chorus frogs are common in low gradient and wetland areas (Forest Service, 2016). No Columbia spotted frogs were observed in the Project Area during on-site surveys in 2011 (Hayden-Wing, 2011), and surveys conducted for amphibians by WGFD in 2002 within the South Cottonwood Creek drainage in the Project Area did not document Columbia spotted frogs (Wright and Zafft, 2004). Columbia spotted frogs have been found in Nylander Creek, a tributary to North Cottonwood Creek approximately 4.3 miles north of the Project Area (Wright and Zafft, 2004).
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Fish. The Forest Service includes two trout species as MIS – harvester indicator species (Table 3.16-3): rainbow trout and Colorado cutthroat trout (also a Forest Service sensitive species). Rainbow trout are not native to Wyoming but have been introduced to Wyoming and other Rocky Mountain states. Limited stocking of rainbow trout had occurred in South Cottonwood Creek (WGFD, 2014), but WGFD is no longer stocking rainbow trout in streams, including those on the Forest, to reduce hybridization and competition with native cutthroat trout (Forest Service, 2011). No rainbow trout were reported from snorkel surveys conducted in South Cottonwood Creek, Bare Creek, and South Fork Bare Creek during August and September, 2011 (Hayden-Wing, 2011). In 1999, the Colorado River cutthroat trout was petitioned for listing as threatened or endangered. However, the FWS (2007d) determined that listing the subspecies under the Endangered Species Act was not warranted at the time. Competing species (i.e., brown trout) are predatory on cutthroat trout. Introduced rainbow and brook trout can be viewed as both competitive and hybridizing species (Hirsch et al., 2013). Juvenile cutthroat trout suffer high mortality rates in the presence of brook trout and brook trout continue to replace some populations of Colorado River cutthroat trout; presence of brook trout can lead to recruitment failure of cutthroat trout (Young, 2008). Rainbow trout and non-native subspecies of cutthroat trout, (e.g., Yellowstone cutthroat trout) have been extensively introduced into waters originally containing Colorado River cutthroat trout. Unlike brook trout or brown trout, rainbow trout and non-native cutthroats do not replace Colorado River cutthroat trout but they do hybridize (Young, 2008). Adult and juvenile Colorado cutthroat trout were observed during on-site surveys conducted by Hayden-Wing (2011) applying standardized inventory data collections defined in R1/R4 Fish and Fish Habitat Standard Inventory Procedures Handbook (Overton et al., 1997). The surveys were conducted in Bare Creek, South Fork Bare Creek, West Fork Bare Creek, and South Cottonwood Creek from the Forest boundary to the confluence with Hidden Basin Creek during September, 2011. Counts of cutthroat trout and brook trout were made within stream reaches of varying lengths during snorkel surveys conducted in August and September, 2011 (Hayden- Wing, 2011). Fish in four different size categories (<100 cm, 100-200 cm, 200-300 cm, >300 cm) were counted for both species in the sampled stream reaches in South Cottonwood Creek, Bare Creek, and South Fork Bare Creek (no fish were reported in West Fork Bare Creek). Results of the surveys are provided in Table 3.16-4.
Overall, densities of Colorado River cutthroat trout (average counts per meter of habitat sampled) were higher in Bare Creek than in South Cottonwood Creek, especially densities of smaller fish <100 cm long. The same was observed in South Fork Bare Creek although there were fewer samples. Brook trout appeared to be absent in South Fork Bare Creek and their presence in Bare Creek was considerably less than in South Cottonwood Creek. Densities of brook trout were higher than densities of Colorado River cutthroat trout in South Cottonwood Creek.
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Table 3.16-4 Results of Fish Counted During Snorkel Surveys Conducted on Three Streams within the Project Area During August and September, 2011 1 South Cottonwood 3 4 2 Bare Creek South Fork Bare Creek Creek Average Average Average Fish Total Fish Count per Total Fish Count per Total Fish Count per Size Category Counted Meter Counted Meter Counted Meter Colorado River Cutthroat Trout in Size Category: <100 cm 82 0.03 91 0.11 26 0.13 100-200 cm 114 0.05 31 0.04 3 0.01 200-300 cm 44 0.02 9 0.01 2 0.01 >300 cm 31 0.01 1 0.00 0 0 All Sizes 271 0.11 132 0.16 31 0.15 Brook Trout in Size Category: <100 145 0.06 4 0.00 0 0 100-200 281 0.12 3 0.00 0 0 200-300 137 0.06 2 0.00 0 0 >300 37 0.02 0 0.00 0 0 All Sizes 600 0.25 9 0.01 0 0 1 Data from Hayden-Wing, 2011. 2 South Cottonwood Creek Parameters: Number of Reaches = 10; Total Samples = 110; Total Length of Habitat Sampled = 2,378.3 meters 3 Bare Creek Parameters: Number of Reaches = 8; Total Samples = 98; Total Length of Habitat Sampled = 847.2 meters. 4 South Fork Bare Creek Parameters: Number of Reaches = 2; Total Samples = 34; Total Length of Habitat Sampled = 200.1 meters.
Populations of Colorado River cutthroat trout in South Cottonwood Creek and Bare Creek are conservation populations, defined as naturally reproducing and recruiting population of native cutthroat trout that is managed to preserve the historical genome and/or unique genetic, ecological, and/or behavioral characteristics in the Conservation Strategy for Colorado River Cutthroat Trout (Onchorhynchus clarkii pleuriticus) in the States of Colorado, Utah and Wyoming (CRCT Coordination Team, 2006). However, they are not core conservation populations which are greater than 99 percent genetically pure, and considered representative of the historic genome of the native cutthroat trout (CRCT Coordination Team, 2006). Genetic analysis of Colorado cutthroat trout in South Cottonwood Creek and Bare Creek indicates both hybridized and unaltered populations present in South Cottonwood Creek (hybrids with brook trout and Yellowstone cutthroat trout) and analysis of cutthroat trout in Bare Creek indicates minimal hybridization with brook trout (Forest Service, 2011). In August 2015, the WGFD began a project to restore genetically pure Colorado River cutthroat trout in Bare Creek. The plan calls for the removal of non-native and hybridized trout species within the upper headwaters of Bare Creek. Once non-natives have been removed, a self- sustaining Colorado River cutthroat trout population can be re-established as a core conservation population through transplants from nearby sources. The entire length of Bare Creek was treated using the piscicide rotenone in August 2015. Once re-established, they can persist and be managed without continual competition and hybridization from non-native fish species. The entire project will continue for the next year with plans to restock native Colorado River cutthroat trout, as well as other native fish species, by the year 2017 (WGFD, 2015).
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3.16.2 Environmental Consequences 3.16.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to threatened, endangered, or proposed animal species and their critical habitat, Forest Service sensitive, and other special status animal species from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.16.2.2 Proposed Action 3.16.2.2.1 Threatened, Endangered, and Proposed Animal Species Terrestrial Species. Construction and operation of the Proposed Action could directly and/or indirectly affect threatened and proposed wildlife species, if present in the Project Area through direct mortality, removal and alteration of habitat, and species displacement as a result of increased noise and human presence.
Direct Mortality. Project-related traffic during construction of the Proposed Action would increase the amount of traffic on Project access roads which could increase the risk of vehicle-caused mortality. Increased traffic would be short-term and temporary, occurring during the summer months (July 1 through September). Peak Project-related traffic would occur as well pads are constructed and wells are drilled and completed (see Section 2.3.2, Traffic). Rig mobilization/demobilization and well completions are expected to have the highest vehicle requirements. Major highways and paved roads generally have higher speed limits than non- paved roads and are a higher potential source of vehicle-caused mortality to wildlife. Collisions with vehicles are a significant source of mortality for lynx (Shenk and Ivan, 2010; Aubry et al., 1999; Ruediger et al., 2000), and traffic in the later afternoon and early evening during the summer could increase the potential for lynx to be hit by a vehicle because they are generally active at dusk in summer (Kolbe and Squires, 2007). Wolverines are also vulnerable to vehicle-related mortality. Vehicle-related mortality is low compared to other human-caused mortalities reported for grizzly bears and wolves (Interagency Grizzly Bear Study Team, 2015b; FWS, 2012). Although unlikely, if these species are present in the Project Area, one could be killed by Project-related traffic that would access the Project Area 24 hours per day during construction. Project-related effects to these species during long-term production would be unlikely because traffic would be minimal. Project-Related Noise. Background noise levels are not available for the Project Area. Local conditions such as traffic, topography, and high winds characteristic of the region can alter background noise conditions. In the past, sound levels (decibels – dBA, weighted on A-scale standard for human hearing) at outdoor rural residential locations of about 40 dBA, averaged for day and night periods (see for example, EPA, 1974) have been accepted as standard and FWS (2003) has used 40 dBA as an ambient noise standard in the Olympic National Forest. It is expected that construction noise in remote areas that are relatively free from noise would have a potential to disturb wildlife.
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Noise levels from typical construction equipment used to construct well pads including graders and scrapers, are 84 to 85 dBA, 50 feet away (Federal Highway Administration, 2006). Noise from the equipment would attenuate to ambient levels (40 dBA) from 2,920 to 3,200 feet away within line-of-sight of the equipment. However, intervening dense vegetation reduces noise by 5 dBA for every 100 feet of vegetation up to maximum reduction of 10 dBA over 200 feet of intervening forest (Washington State Department of Transportation - WSDOT, 2011). With the tree cover present in the Project Area, equipment noise is expected to attenuate to ambient level from 1,160 to 1,270 feet away. Noise levels during well drilling and completion were recently measured by Behrens and Associates, Inc. (Behrens, 2016) within the Jonah Year-Round Development Project Area in Sublette County, east of the Project Area. Sound level measurements were made at an Ensign 157 Rig and Unit 326 Drilling Rig and at an existing Haliburton completion. Maximum sound power levels ranged from 108.3 dBA at the Ensign Rig to 110.0 dBA at the Unit Rig. At the Halliburton completion site, sound power levels were 118.1 dBA. Behrens modeled unmitigated noise levels from these sources to various distances across the Jonah landscape. Based on modelled attenuation distances for sound levels from the Ensign 157 Rig, noise may attenuate to 40 dBA 5,840 feet away within line-of-sight of the drill rig and 2,822 feet away with over 200 feet of intervening forest. Sound levels from the Haliburton completion site would attenuate to 40 dBA ambient levels 9,205 feet away within line-of-sight and 4,330 feet away with over 200 feet of intervening forest. A certain level, pattern, or noise intensity during the Construction Phase could affect wildlife behavior or habitat use with the possibility that a change in individual’s behavior may occur and use of nearby habitats may be precluded. Construction noise could disturb grizzly bear foraging activities because activities would coincide with the early hyperphagia and late hyperphagia seasons (Gunther et al., 2004) during which grizzly bears seek and consume large quantities of food. Project-related noise could also disturb dispersing or foraging wolverines, wolves, or lynx resulting in avoidance of the area. However, Project-related noise would be inaudible above ambient levels for some distance from the noise source. Noise would vary and be considerably less, depending on receptor orientation to the source and intervening forest and topography. There is a small chance that grizzly bears, wolverines, lynx, or gray wolves, if present in the Project Area at the time of construction would detect Project-related noise above ambient forest noise. There would be a much smaller chance that these species, if present during Operations would detect Project-related noise and a chance that Project-related noise could interfere with wolf communication is assumed to be very remote. The response of these species to Project- related noise would likely be similar to their response to other anthropogenic noise including noise related to recreation, hunting, and logging that may already occur within the area. It is possible though unlikely that yellow-billed cuckoos could nest in riparian willows within the Project Area. Riparian willows along South Cottonwood Creek are as close as 1,600 feet to Well Pad 23-15 and on South Fork Bare Creek, willows are as close as 300 feet from the center of Well Pad 42-27. Construction noise could be audible in portions of riparian willow habitats in the Project Area. If nesting within noise-detection distances, yellow-billed cuckoos could be disturbed during the nesting period because Project activities would be occurring during peak nesting from mid-July through early August. Human Activity. Wildlife species within proximity to Project activities may be disturbed and avoid the Project Area, similar to effects discussed above for noise. However, human presence can attract some species, particularly scavengers. Attractants can also lead to wildlife-human conflicts. For example, grizzly bears attracted to human use areas can cause human injuries and property damage (Gunther et al., 2004), which could result in unnecessary lethal control of the problem bear.
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Loss or Alteration of Habitat. Construction of the Proposed Action would remove approximately 5.50 acres of habitat (see Table 3.19-6, below), less than 0.1 percent of available habitat within the Project Area: 2.18 acres to expand existing Well Pad 42-27 and 3.32 acres to reconstruct Well Pad 23-15. Most habitat affected for expansion of existing Well Pad 42-27 is previously reclaimed vegetation on the margin of existing well pad disturbance. Some dispersed sagebrush occurs beyond reclaimed vegetation. Reconstruction of Well Pad 23-15 would mostly affect vegetation cover types reestablished from the reclamation of a previous well pad, as well as a small proportion of unaltered grassland/forbs and mountain big sagebrush adjacent to reclaimed vegetation. Habitat affected by the Project is not expected to provide suitable habitat for listed species or their preferred prey. No riparian habitat would be removed by the Proposed Action; therefore, no effects to yellow-billed cuckoos are anticipated.
Colorado River Endangered Fish. During construction, approximately 180,450 barrels (7,578,900 gallons) of water per year would be required for drilling, completion, and dust control (see Table 2.3-6), and a small amount of water may be required for hydrostatic testing of a new gathering line. Approximately 9 percent of water required per year would be obtained from the proposed water supply well on existing Well Pad 13-16a, whereas the remaining water requirements would be obtained from municipal sources that could directly and/or indirectly affect the Colorado River Endangered Fish species and their critical habitat through water depletions from the Colorado River system. Upstream depletions may contribute to the destruction or adverse modification of designated critical habitat by reducing water quantity which could affect sufficient water quality requirements of temperature, dissolved oxygen, lack of contaminants, nutrients, and turbidity (necessary for each life stage). A Recovery Implementation Program Recovery Action Plan (RIPRAP) was developed by the Upper Colorado River Basin Endangered Fish Recovery Program, initiated in January 1988. RIPRAP serves as the reasonable and prudent alternative to avoid jeopardy and provide recovery to the endangered fishes by depletions from the Upper Colorado River Basin. RIPRAP is also intended to provide the reasonable and prudent alternatives which avoid the likely destruction or adverse modification of critical habitat, to the same extent as it does to avoid the likelihood of jeopardy. Under the Recovery Program in Wyoming, proponents of new water projects which undergo section 7 Endangered Species Act consultation with a depletion of less than 100 acre-feet per year are not required to pay a one-time depletion fee. Average annual depletion for the Lander Peak Project is estimated to be 23.3 acre-feet. 3.16.2.2.2 Forest Service and Other Special Status Animal Species Terrestrial Species. Construction and operation of the Proposed Action could directly and/or indirectly affect Forest Service sensitive, Forest Service MIS, and other special status wildlife species, if present in the Project Area similar to Project effects discussed above for threatened and proposed wildlife species. Impacts would generally be more substantial during critical seasons such as winter (overwintering) or the spring/summer breeding season (small mammals, and reptiles). Timing of the Proposed Project (July 1 through September 30) should minimize effects to Forest Service sensitive and MIS wildlife species, and other special status wildlife species in the Project Area; Project disturbances during long-term production would be minimal and are not likely to affect these species.
Direct Mortality. Project-related traffic and operation of heavy equipment during construction of the Proposed Action could result in wildlife mortalities, especially for species that are inconspicuous (small mammals), those with limited mobility (amphibians), burrowing species, wildlife with behavioral activity patterns (i.e., nocturnal activity) making them vulnerable, and wildlife that may scavenge roadside carrion (Leedy, 1975; Bennett, 1991; Forman and
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Alexander, 1998). It is possible that boreal toads, boreal chorus frogs, or Columbian spotted frogs migrating from over-wintering habitat to breeding areas, or moving away from breeding areas after laying eggs could occur in the Proposed Action area. Traffic associated with construction and operation of the Project could increase the likelihood of killing amphibians especially because they are slow, weak leapers and will travel during day or night (Forest Service, 2016; McGee and Keinath, 2004), but timing of the Proposed Action (July 1 through September) would minimize potential effects because likely migrations would occur in the spring or fall. Direct effects to species could also occur during construction, especially burrowing, fossorial species. Project-related Noise and Human Presence. Noise and human presence associated with construction of the Proposed Action (drilling and completion) and vehicles accessing the Project Area could disturb and displace sensitive, MIS, and special status wildlife in the Project Area. Noise would be detected by wildlife if above ambient background levels, assumed to be 40 dB in a rural setting (non-wilderness- see EPA, 1974), although tree cover near the Proposed Action would dampen noise in nearby habitats. Vehicular traffic would be expected to affect wildlife within the Project Area for some distance away from the Proposed Action, including access roads (see Rost and Bailey, 1979; Easterly et al., 1991). Disturbance and/or displacement associated with Project construction and operation would be short-term and temporary because Project activities would occur from July 1 through September and noise would not be continuous. Project-related noise and human disturbance associated with Project activities from July 1 to September 30 could temporarily affect nesting birds, if present in the Project Area (see Table 3.16-3) because the timing of Project activities overlaps known breeding and nesting seasons. Sagebrush habitats within the Project Area and along the access route to the Project Area may provide some early brood-rearing habitat and upland meadows or stream bottoms may provide succulent herbaceous vegetation commonly used during late brood-rearing (mid-July through mid-September). Vehicle traffic noise and construction noise could be audible in brood-rearing riparian/wetland habitats and result in avoidance of habitat in proximity to the disturbance. The Proposed Action could attract predators of sage-grouse to the Project Area and vicinity and facilitate nest predation. Corvids are often attracted to areas of human development (Marzluff and Neatherlin, 2006). Corvids are effective nest predators of greater sage-grouse, taking eggs and possibly recently hatched chicks, and their abundance has been related to higher nest predation rates of sage-grouse (Hagen, 2009). Corvids also prey on nests of other birds, especially in fragmented forests (Andren, 1992; Marzluff et al., 2007). If the Proposed Action caused increased populations of corvids, greater sage-grouse and other birds nesting within the vicinity of the Project Area could be affected. Night Lighting. Night lighting would be required during continuous drilling which could affect Forest Service sensitive and MIS species, as well as other special status wildlife species in the Project Area. Night lighting has been shown to act as a barrier to bat movements (Kuijper et al., 2008) and reduce bat activity in the immediate vicinity (Stone et al., 2009). Night lighting could affect other nocturnally active mammals by disrupting foraging behaviors and increasing risks of predation, similar to the influence of different light intensities during lunar phases (Beier, 2006). Owls are more successful capturing prey under low light intensities because small mammal prey are more active than during the light of a full moon (Speicher et al., 2011). Though evidence is limited, artificial night lighting may affect animal movements along corridors connecting habitat patches in the Project Area (Beier, 2006; Longcore and Rich, 2004).
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Attractions of migratory birds to night lights on off-shore drilling rigs (Poot et al., 2008), wind turbines (Kerlinger et al., 2010), and other sources (Gauthreux and Belser, 2006) have been documented and similar effects from night lighting at the drilling rig are possible. Nocturnally migrating birds could die or lose a large amount of their energy reserves during migration as a result of encountering artificial light sources (Gauthreux and Belser, 2006). Artificial night light has also been shown to influence bird vocalizations at dawn and dusk with various studies showing that light pollution affects the reproductive behavior of birds (Kempenaers et al., 2010; DaSilva et al., 2014). Loss or Alteration of Habitat. Expansion of Well pad 42-27 and construction of reclaimed Well Pad 23-15 would affect 5.50 acres (see Table 3.19-6, below) of habitat potentially used by some Forest Service sensitive and MIS wildlife species, and other special status terrestrial wildlife species (see Habitat, Table 3.16-3). Removal of vegetation could reduce forage, reduce hiding cover and thermal shelter, and displace wildlife. However, potential effects to wildlife would be expected to be short-term and minimal because most wildlife habitat affected by the Proposed Action would be adjacent to existing disturbance (existing access roads and well pads) or within previously disturbed habitat, and habitat removed represents less than 0.1 percent of available wildlife habitat in the Project Area. Noxious weeds and fugitive dust could interfere with wildlife habitat adjacent to proposed Well Pads and access roads. To minimize the potential to introduce invasive weed species to the Project Area, all material used for sediment barrier installations and seed mixes for reclamation would be certified weed-free. Water applied to unpaved roads and well pads during construction would reduce fugitive dust and potential effects to adjacent wildlife habitat. Approximately 0.28 acre of Mountain Big Sagebrush would be removed during expansion of existing Well Pad 42-27; however, Well Pad 42-27 is not within designated management areas for greater sage-grouse habitat use and no leks occur within 5.3 miles of proposed disturbance. Therefore, no effects to greater sage-grouse or supporting habitat would be expected as a result of construction (including drilling and completion) and operation (long-term production) of this well pad. Well Pad 23-15 is located approximately 530 feet within the outer delineated limits of designated PHMA for greater sage-grouse. Construction of Well Pad 23-15 would remove 0.18 acre of Mountain Big Sagebrush with canopy cover from 25 to 100 percent, which could provide some nesting and brood-rearing sage-grouse habitat, as discussed above. However, it is unlikely that sagebrush habitat removed during construction of Well Pad 23-15 would provide nesting or brood-rearing habitat because the closest occupied lek to the well pad is over 6.5 miles away and no sage-grouse activity has been reported in the Project Area. Additionally, the proposed well pad site is surrounded by Spruce/Subalpine coniferous forest that could provide perches for potential predators and would likely be avoided by sage-grouse. Given the location of the proposed well pad more than 6.5 miles from the nearest occupied lek in an area mostly surrounded by forested habitat and the limited amount of big sagebrush present, the well pad would not include important breeding and nesting habitats for greater sage-grouse, consistent with the concept of priority-core habitat management areas on the Forest. No evidence of sage- grouse use or presence was observed in the Project Area (Hayden-Wing, 2011). Construction (including drilling, and completion) would occur after July 1 through approximately September 30. That period coincides with a portion of early brood-rearing and late brood-rearing but avoids periods of lek attendance, nesting, and wintering. Because the proposed location of Well Pad 23-15 occurs within Forest Service delineated PHMA, which is comparable to WGFD delineated sage grouse core area, the Forest Service
162 Lander Peak Area Exploratory Proposal Environmental Assessment determined it was necessary to analyze potential effects to sage-grouse using the WGFD Density and Disturbance Calculation Tool (DDCT). The WGFD provides direction in determining the “evaluation area” to use with the DDCT, which considers the presence of sage-grouse leks within 4 miles of the proposed disturbance, an area of 4 miles around the proposed disturbance, and/or presence of sage-grouse core area (i.e., Forest Service-delineated PHMA). No sage-grouse leks occur within 4 miles of proposed disturbance; the closest lek is the Mickelson Creek Lek located approximately 6.5 miles east of proposed disturbance for Well Pad 23-15. Therefore, the Forest Service analyzed the effects of the proposed disturbance for Well Pad 23-15 on approximately 2,292 acres of Forest Service- delineated sage-grouse habitat (PHMA) within 4 miles of proposed Well Pad 23-15 that occurs within PHMA: approximately 1,567.2 acres along South Cottonwood Creek and approximately 724.9 acres along North Cottonwood Creek (see Map 3.16-3). Well Pad 23-15 would be constructed in Section 23; currently there are no well pads in Section 23 related to oil and gas development. Therefore, construction of Well Pad 23-15 in the evaluation area would meet the density threshold of no more than an average of one pad per 640 acres. Total existing disturbance in the DDCT evaluation area is estimated to be 60.55 acres. The proposed disturbance for Well Pad 23-15 would include 3.32 acres of additional disturbance in the DDCT evaluation area, totaling 63.87 acres in disturbance, which would be much less than the 5% or 114.6 acres disturbance threshold. The Project would be consistent with standards provided in the Greater Sage-grouse Record of Decision (Forest Service, 2015b) and the requirements set forth in the Wyoming Governor’s Executive Order for Greater Sage- Grouse Core Area Protection (State of Wyoming, 2015). Recommendations for Development of Oil and Gas Resources within Important Wildlife Habitats (WGFD, 2010b) specify no surface occupancy extending 500 feet from the outermost perimeter of wetlands and riparian corridors to maintain habitat effectiveness and functional integrity. No riparian or wetland habitat would be removed by the Proposed Action (see Table 3.19-6). However, the Proposed Action is within 500 feet of creeks, wetlands, and riparian, which could affect important habitat for terrestrial species: proposed expansion of Well Pad 42-27 is within 170 feet of South Fork Bare Creek and 120 feet of shrub-dominated riparian habitat adjacent to South Fork Bare Creek, and existing Well Pad 13-16a (water supply well) is within 120 feet of riparian habitat associated with South Cottonwood Creek (located 200 feet north), as well as within 175 feet of shrub-dominated wetland across NFSR 10050. Creeks within the Project Area could provide breeding habitats for boreal toads, boreal chorus frogs, and Columbian spotted frogs. If present, boreal toads, boreal chorus frogs, and/or Columbian spotted frogs could be affected by impacts to water quality through release of toxic substances and sedimentation from ground surfaces that could degrade occupied streams and affect breeding, tadpole, and juvenile toad habitat. Sedimentation can reduce food availability, water and environmental quality, and habitats used by aquatic organisms resulting in decreased plant, zooplankton, and insect abundance and biomass that would affect aquatic food chains and could affect boreal toads during different life stages (Henley et al., 2000). These potential impacts would be prevented by implementation of True Oil’s SWPPP and overall sedimentation control measures included in the Proposed Action and described in Section 2.3.2. Existing BMPs at Well Pad 13-16a should be adequate to prevent additional sediment delivery to South Cottonwood Creek. Additionally, potential impacts to water quality resulting from erosion and sediment transport and from spills and leaks would be reduced through improvements to the existing Well Pad 42-27 including a new diversion ditch, and sediment traps around the expanded well pad, new BMPs, and replacement of current earthen berms around tanks with corrugated steel berms with liners. The existing tanks on Well Pad 42-27 would be moved further away from South Fork Bare Creek.
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Map 3.16-3 Greater Sage-Grouse DDCT Evaluation Area - Detail
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Fish Species. The Conservation Agreement for Colorado River Cutthroat Trout in the States of Colorado, Utah, and Wyoming (2006) was developed to assure the long-term viability of cutthroat trout throughout their historic range and includes provisions that areas currently supporting cutthroat trout will be maintained, while other areas will be managed for increased abundance. Under the Proposed Action, no riparian vegetation would be removed and no alteration of natural drainage channels would occur. Additionally, no new roads would be constructed; existing roads would be improved, where necessary for safe access. Expansion of existing Well Pad 42-27 is within 170 feet of South Fork Bare Creek and construction and operation have the potential to route fine sediments to the nearby stream. Sediment can smother spawning gravels and increase mortality of eggs and embryos, reduce the abundance of invertebrate prey and reduce quality of rearing habitat, abrade gills and impair respiration, and cause fish to avoid impacted stream reaches (Newcombe and Jensen, 1996). Hydrologic modeling (Attachment E) predicts that sediment delivery to South Cottonwood Creek from runoff during development of Well Pad 23-15 is highly unlikely. Likewise, modeling, predicts a very low probability of sediment delivery to South Fork Bare Creek from expansion of Well Pad 42-27. Expansion of Well Pad 42-27 under the Proposed Action could have an annual 2 percent chance for sediment transport of 0.001 ton/acre and a 1 percent chance for sediment transport of 0.002 ton/acre to South Fork Bare Creek which equates to 3 pounds or 1,361 grams potentially entering the creek each year. These analyses represent worst-case possibilities that 100-year or 50-year precipitation and runoff events occur at proposed Well Pad 23-15 and Well Pad 42-27. Further, the TBSM/WEPP modeling estimates of sediment entry to South Fork Bare Creek and South Cottonwood Creek all assume that no preventative measures have been implemented. Measures that effectively eliminate any chance of sediment entry from infrequent storm and runoff events would preclude any effects from the Proposed Action. Recommendations made by HydroGeo (Attachment E) to eliminate sediment entry are included as design features. Additionally, potential impacts would be prevented by implementation of True Oil’s SPCC Plan and SWPPP and overall sedimentation control measures included in the Proposed Action and described in Section 2.3.2 such as the use of BMPs, conducting interim reclamation as soon as possible, and constructing berms to channel any sediment flow to sediment traps which would discharge to an armored detention basin dissipating flow energy. No adverse effects from sediment delivery to Colorado cutthroat trout, rainbow trout, or their habitat are expected from construction and operation of the Proposed Action. Existing Well Pad 13-16a is located approximately 200 feet from South Cottonwood Creek. No expansion of this well pad is proposed for construction and operation of the water supply well. Existing BMPs at Well Pad 13-16a should be adequate to prevent additional sediment delivery to South Cottonwood Creek; no effects to Colorado cutthroat trout or rainbow trout are expected from construction or operation of the water supply well. Colorado cutthroat trout and rainbow trout could be affected by impacts to water quality through inadvertent spills and releases of diesel fuel and other chemicals during construction (including drilling and completion). This activity would be short-term and temporary, and effects resulting from inadvertent release of substances would be minimized by implementation of the SWPPP and the SPCC Plans. Additional and improved BMPs applied to the existing Well Pad 42-27 would further reduce potential impacts to water quality from transport of sediment or spills and leaks. Based on known distribution in the Project Area, habitat associations, and potential threats to Forest Service sensitive species, the Proposed Action may affect sensitive species through one or more of the effects described above, but is not expected to cause a trend to federal listing or loss of viability (see also Attachment D, Biological Evaluation of Sensitive Species and Management Indicator Species Report).
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3.16.2.3 Mitigation Alternative Effects to threatened, endangered, or proposed animal species and their critical habitat, Forest Service sensitive, and other special status animal species under the Mitigation Alternative would be similar to those described for the Proposed Action.
To minimize the potential for collisions with wildlife species as well as reduce effects of fugitive dust on wildlife habitat adjacent to access roads, speed limits would be enforced and where not posted on unpaved access roads, speeds would not exceed levels considered safe for the conditions and would be slow enough to prevent collisions with wildlife and livestock. To reduce the potential for grizzly bears and other scavengers (corvids) to be attracted to the Project Area, trash and garbage would be placed in appropriate caged containers and the container and contents transported to an approved disposal facility. All containers will be equipped with bear- resistant openings. True Oil would implement “dark sky” lighting practices to reduce the effects of artificial light including use of low glare lighting equipment and directing or shielding lighting to reduce glare in adjacent habitat. To further minimize the potential to transport or spread noxious weeds into the Project Area and degrade wildlife habitat, True Oil would prepare and implement an Integrated Weed Management Plan for the Lander Peak Project, and all vehicles and equipment used for construction, reclamation, and abandonment would be cleaned prior to entering and upon departure from the Project Area. True Oil would provide environmental awareness training to all employees to address consequences of poaching and provide information about federal and state wildlife laws.
Potential impacts to surface water quantity and quality would be potentially less than those described for the Proposed Action because all chemicals, solvents, and fuels would be kept at least 150 feet away from streams and riparian areas and all refueling would occur at least 150 feet away from streams and riparian areas. Further, monitoring of surface water would occur at seven locations including three locations along South Cottonwood Creek, two locations on South Fork Bare Creek, and one location on Soda Lake. Data collected would be used to establish baseline and report conditions in the event of a spill, leak, or other unanticipated condition. If necessary, Construction or Operations would be adjusted according to measures outlined in the Water Sampling and Analysis Plan.
3.17 THREATENED, ENDANGERED, CANDIDATE AND SENSITIVE PLANT SPECIES
3.17.1 Current Conditions Threatened, Endangered, Proposed, and Candidate Species
The FWS (2016b) identified one ESA-listed species in association with the Platte River in Nebraska that could be affected by water-related activities and/or water use in the Platte River Basin: western prairie fringed orchid (Platanthera praeclara). The Project would not result in any water withdrawn from the Platte River Basin; therefore, this species would not be affected by the Proposed Action or alternatives and is not considered further. The FWS (2016b) did identify one candidate plant species that could occur in the Project Area: whitebark pine. In July 2011, the FWS responded to a 2008 petition requesting that whitebark pine be listed as endangered throughout its range. In the 12-month finding, the FWS determined that listing whitebark pine was warranted but precluded by higher priorities (FWS, 2011). Whitebark pine is discussed above in Section 3.19, Vegetation.
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Forest Service Sensitive and Other Special Status Plant Species The Forest Service, Region 4 (Forest Service, 2013b), identified 18 plant species as sensitive and which are known or suspected to occur on the Forest. Six plant species are identified as sensitive species (Forest Service, 2015a) as directed by the National Forest Management Act of 1976. Four of the sensitive plant species in the Forest Plan (2015a) are included on the Region 4 sensitive species list for the Forest (Table 3.17-1). Whitebark pine is also a sensitive species in the Forest that occurs in the Project Area; see Section 3.19, Vegetation. Table 3.17-1 Forest Service Plant Sensitive Species Not Listed Under the Endangered Species Act that Could Potentially Occur in the Project Area in Sublette County Common Name Potential Scientific Name Habitat 1 Occurrence 2 Federal Sensitive3 Vascular Plants Occurs mostly in disturbed areas including Payson’s Milkvetch Documented in Forest Service R4 burns, clear cuts, road cuts in sandy soils with Astragalus paysonii vicinity Sensitive sparse herbaceous cover; 5,850 to 9,600 feet. Creeping Twinpod Generally the plant occurs at elevations between Documented in Forest Service R4 Physaria integrifolia v. 6,500 and 8,600 feet on barren, rocky, Region Sensitive monticola calcareous hills and slopes. On moist sites on north-facing limestone, SOC Boreal Whitlow-grass Documented in dolomite or volcanic slopes, cliffs, and riparian Forest Service Draba borealis vicinity areas; 6,200 to 8,550 feet. Sensitive On windswept, gravelly, calcareous ridgecrests, semi-open slopes and rocky floodplains often Payson’s Bladderpod Documented in Forest Service R4 associated with sagebrush grasslands. Also on Lesquerella paysonii vicinity Sensitive disturbed roadside, dry stream channels, rocky clearings in forests. Tolerates poor soils, steep slopes, and windy exposures. Found at alpine tree line and Forest Service R4 Whitebark Pine Within Project subalpine elevations. May occur as a climax Sensitive Pinus albicaulis Area species or codominant with other species at FWS ESA-C seral stages. May live for 500 years or more. Shultz’ Milkvetch Associated with subalpine forb communities on Documented in Forest Service Astragalus shallow rock soils from 8,800 to 11,500 feet vicinity Sensitive shultziorum elevation. 1 WGFD, 2012b; WYNDD, 2014. 2 Potential Occurrence: Unlikely: May or may not occur in Sublette County but no suitable habitat is present. Possible: Occurs in Sublette County and the Forest, suitable habitat is present, may have been observed in the region but not observed at the Site. Documented in vicinity with records of species provided by WNDD, 2014. 3 Federal Sensitive: Forest Service Sensitive Species in Region 4 (Forest Service, 2013b). FWS Species of Concern (SOC) and Candidate species under the Endangered Species Act (ESA-C).
During July and August 2011, Hayden-Wing (2011) searched for sensitive plant species in the vicinity of proposed Well Pads 23-15 and 42-27; no sensitive plant species were found. However, an examination of records for plant species specimens in the collection of the Rocky Mountain Herbarium (2014) at the University of Wyoming and records provided by Wyoming Natural Diversity Database (WYNDD, 2014) revealed that four species of sensitive plants occur within 3 to 4 miles of the Project Area: Payson’s milkvetch was recorded within 2.1 miles on a sandy roadcut and roadbed (Heidel, 2012); historical occurrences of Payson’s bladderpod were collected within 3.5 to 4 miles; Boreal whitlow-grass was collected approximately 4 miles northwest; and the closest Shultz’ milkvetch specimen was reported 1.3 miles northwest but most specimens were reported 8 miles south in the vicinity of Mount McDougal. The closest record of creeping twinpod (or bladderpod) occurs within 10 miles of the Project Area (WYNDD, 2014).
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3.17.2 Environmental Consequences 3.17.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to endangered, threatened, candidate or Forest Service sensitive plant species from activities described below for the Proposed Action would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.17.2.2 Proposed Action No areas of whitebark pine would be directly affected by the Proposed Action (see Table 3.19- 6). Based on distribution of whitebark pine within the southwest and northwest portions of the Project Area (see Map 3.19-1), no effects to whitebark pine would be expected.
Surveys for Forest Service sensitive plants were conducted in the vicinity of proposed Well Pads 23-15 and 42-27; no sensitive plants were documented. It is not expected that expansion of Well Pad 42-27 or construction of Well Pad 23-15 would affect sensitive plants. However, no surveys along proposed access roads were conducted. Based on habitat associations (Table 3.17-1), two sensitive species that have been documented in close proximity of the Project Area could occur along existing access roads or within previously disturbed areas: Payson’s milkvetch and Payson’s bladderpod. If present, individuals might be within range of fugitive dust generated by vehicular traffic on dirt/gravel roads. Damage or mortality to individual plants as a result of decreased light transmission due to dust deposited directly on leaves or other photosynthetic surfaces could occur due to clearing vegetation, operation of earth-moving equipment, and increased traffic along roads. Dust from Project-related traffic could impair photosynthesis, gas exchange, transpiration, leaf morphology, and stomata function (Farmer, 1993; Sharifi et al., 1997; Rai et al., 2009). Dust could also interfere with plant reproduction by disrupting pollinator activities and plants’ physiology (Lewis, 2013). Water would be used, as needed for dust suppression along access roads and at well pads to minimize effects from fugitive dust during the flowering season. Vehicular traffic on proposed access roads and during construction and operation of the Proposed Action could introduce or increase the presence of invasive weed species that could outcompete Forest Service sensitive species, if present along access roads in the Project Area. All material used for sediment barrier installations and seed mixes used for reclamation would be certified weed-free to reduce the potential to introduce invasive weed species to the Project Area. 3.17.2.3 Mitigation Alternative Effects to Forest Service sensitive plant species under the Mitigation Alternative would be similar to those described for the Proposed Action. To further minimize the potential to transport or spread noxious weeds into the Project Area and compete with or degrade sensitive species and their habitat, True Oil would implement the Forest Service (2004) weed management plan, and all vehicles and equipment used for construction, reclamation, and abandonment would be cleaned prior to entering and upon departure from the Project Area. Speed limits would also be enforced and where not posted on unpaved access roads, speeds would not exceed levels considered safe for the conditions and would be slow enough to prevent collisions with wildlife and livestock which would minimize fugitive dust emissions.
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3.18 TRANSPORTATION/ACCESS
3.18.1 Current Conditions From the north, the Project Area is accessed by exiting U.S. Highway 191 at the Daniel Junction and turning south onto U.S. Highway 189. The access route travels approximately 1.8 miles to the town of the Daniel and continues another 1.1 mile to CR 23-117 (Cottonwood-Ryegrass Road). From the south, the Project Area is accessed via northbound U.S. Highway 189. The southern point of entry onto CR 23-117 intersects U.S. 189 approximately 13.2 miles north of Big Piney. From here, the access route stays on U.S. Highway 189 and continues north for 9.3 miles to the northern point of entry on CR 23-117 entry (see Map 1.3-1.).
From the northern junction of U.S. Highway 189 and CR 23-117, the access route travels west on CR 23-117 approximately 12.7 miles to CR 23-116 (Cottonwood Myrna Road). The access route turns left onto CR 23-116 and heads south approximately 1.1 mile to Ryegrass Junction, where it turns right and continues west on CR 23-129 (North Cottonwood Road) for approximately 9.3 miles to the junction of NFSR 10050. The access route turns left onto NFSR 10050 and travels approximately 3.0 miles in a generally southwest direction to the junction of NFSR 10050 and NFSR 10046. The access route to Well Pad 42-27 turns left (south) at the junction and proceeds approximately 3.0 miles southwest to the well pad. From the junction, the access route to Well Pad 23-15 stays on NFSR 10050 and continues approximately 1.4 miles to the pad’s access road. The access route turns left onto the access road and travels approximately 0.4 mile south to the well pad.
During construction, materials and supplies would be transported to the Project Area from Rock Springs and Pinedale and workers would commute from surrounding rural areas and communities, including Big Piney, Boulder, Daniel, Marbleton, and Pinedale.
The Wyoming Department of Transportation (WYDOT) maintains U.S. Highway 189, U.S. Highway 191, and Wyoming State Highway 351. Sublette County maintains CR 23-117 and CR 23-116 on a year-round basis and provides summer maintenance on CR 23-129. The county provides snow removal on CR 23-117 and CR 23-116, but not CR 23-129 (Pape, 2015).
Between 2010 and 2013, traffic decreased on Wyoming State Highway 351 and on U.S. Highway 189 between Big Piney and Daniel Junction. With the exception of road segments near south Pinedale, traffic also decreased on U.S. Highway 191 between Rock Springs and Daniel Junction. In 2013 annual average daily traffic (AADT) on U.S. Highway 189 averaged 2,598 vehicles between Big Piney and Daniel Junction. In 2013, AADT on U.S. Highway 191 averaged 4,499 vehicles on road segments between Rock Springs and Wyoming State Highway 351, 3,851 vehicles between Wyoming State Highway 351 and Pinedale, and 2,339 vehicles between Pinedale and the Daniel Junction. In 2013 AADT on Wyoming State Highway 351 averaged 923 vehicles (WYDOT, 2015).
Sublette County recorded traffic volumes on CR 23-117 and CR 23-129 in June 2015. The traffic counts included 121 vehicles on CR 23-117 and 59 vehicles on CR 23-129 (Pape, 2015).
3.18.2 Environmental Consequences 3.18.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to
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transportation and access from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.18.2.2 Proposed Action Potential impacts to access and transportation could include road degradation, increases in traffic volumes, and a potential for increased crashes. The highest traffic volumes associated with the Proposed Action would occur during well completion. Compared to 2013 traffic levels, Project traffic during well completion could increase daily traffic volumes between 2 and 9 percent on affected segments of U.S. Highway 189, less than 3 percent on affected segments of U.S. Highway 191, and approximately 6 percent on Wyoming State Highway 351. Project construction would result in noticeable traffic increases on CR 23-117 and CR 23-129. During well completions, traffic on CR 23-117 could be twice as high and traffic on CR 23-129 could be three times as high traffic volumes recorded in June 2015.
These impacts would occur for approximately 40 days over the Project’s 3-year construction period. Slightly lower traffic impacts would occur during rig mobilization and demobilization, which would take place for approximately 20 days during construction. Traffic impacts would be lower during drilling and other construction activities.
Vehicles associated with Project operations would result in negligible increases in traffic volumes on U.S. Highway 189, U.S. Highway 191, and Wyoming State Highway 351. Compared to June 2015 traffic levels, vehicles associated with Project operations could increase traffic on CR 23-117 by 2 percent and traffic on CR 23-129 by 3 percent. 3.18.2.3 Mitigation Alternative Potential impacts to transportation and access under the Mitigation Alternative would be similar to those described for the Proposed Action. Additional roads would be used to install monitoring wells and for sampling the monitoring wells and surface water locations; however, these activities would be intermittent and existing roads would be used.
3.19 VEGETATION
3.19.1 Current Conditions Existing vegetation in the Project Area was mapped using the mid-level existing vegetation map (1:100,000) prepared for the Forest to support their Forest Plan Revision (Forest Service, 2007a). Vegetation map types were characterized by map unit (dominant land cover), tree and shrub canopy closure class, and tree size class (Forest Service, 2007a). Existing disturbances (roads, well pads, gathering lines, and pipelines) within the Project Area were digitized from aerial photography, available photographs of the proposed alternatives, and wetlands from National Wetland Inventory (FWS, 2010b) were combined with mapped Forest vegetation to provide a more accurate baseline for the Project Area (see Map 3.19-1). Existing vegetation within the Project Area is a mosaic of deciduous aspen forest/woodland (2 percent), coniferous forest/woodlands of whitebark pine (5 percent), whitebark pine mix (3 percent), spruce/subalpine fir mix (22 percent), lodgepole pine mix (51 percent), shrubland dominated by mountain big sagebrush (10 percent), herbaceous grass and forbland including reclaimed/reestablished vegetation in previous disturbed areas (2 percent), and riparian vegetation, mostly willows (3 percent) (Table 3.19-1).
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Map 3.19-1 Vegetation Cover Types
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Table 3.19-1 Vegetation Cover Types, Areas, and General Locations within the Project Area Area Vegetation Cover Type 1 (acres) General Location Deciduous Forest/Woodland Southeast and east, on west-facing slopes along South Fork Aspen 88.85 Bare Creek, 8,400 to 9000 feet. Coniferous Forest/Woodlands Southwest, on northeast-facing slopes >9,200 feet; North, on Whitebark Pine 234.38 south slopes above Lander Creek >9,000 feet. South and southwest, on northeast-facing slopes >9,200 feet; Whitebark Pine Mix 160.68 North, on south slopes above Lander Creek >9,000 feet. Spruce/Subalpine Fir Mix 1,022.95 Throughout Project Area in patches below 9,800 feet. Lodgepole Pine Mix 2,391.13 Throughout Project Area at elevations below 9,400 feet. Shrubland Silver Sagebrush/Shrubby Cinquefoil 6.15 Along South Cottonwood Creek. Mountain Big Sagebrush 423.94 East and southeast at lower elevations <8,600 feet. Herbaceous Vegetation Grassland\Forbland 78.34 Southeast in isolated patches. Tall Forbland 22.39 Extreme southeast, head of South Fork Bare Creek. Riparian Vegetation Riparian – Willow 52.37 Bordering South Cottonwood Creek and forks of Bare Creek. Riparian Herbaceous 2.57 Few isolated patches. Wetland-Open Water 2 Open Water 34.84 Creeks, lakes, and ponds. Emergent Wetlands 10.72 Vicinity of South Cottonwood Creek, South Fork Bare Creek. South Cottonwood, Trailer, South Fork, West Fork, Bare Forested/Shrub Wetland 130.68 creeks. Limited or No Vegetation Sparse Vegetation 26.95 Few patches at high elevations >9,400 feet. Barren\Rock 8.59 West-facing slopes >9,200 feet. Urban/Developed 29.51 Existing roads and well pads. Reclaimed Vegetation Reclaimed/Reestablished Vegetation 11.00 Existing pipeline/gathering line disturbance. Total 4,736.04 1 Forest Service, 2007a. 2 FWS, 2010a.
The Forest Service (2009b) reviewed the status, conditions, and trends of vegetation in the Forest using the same mapped vegetation layer applied in Table 3.19-1 to support their Forest Plan Revision. Data provided in the 2009 monitoring report are used to evaluate local vegetation conditions in the Project Area relative to conditions on the Forest. Aspen. Aspen woodlands cover only 1.9 percent of the Project Area. Forest-wide, aspen contributes to 5 percent of the vegetated area and 8 percent of all forested vegetation types. Structural stages of aspen in the Project Area somewhat mirror current conditions of aspen in the Forest with the greatest discrepancy in the extent of larger tree sizes and limited area compared to current forest conditions (Table 3.19-2). Aspen in the Project Area falls short of desired conditions with limited younger size stands and older size stands, both of which are necessary to insure persistence of aspen on the landscape (Forest Service, 2009b).
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Table 3.19-2 Current Aspen Structural Stage Distribution in the Forest and in the Project Area Compared to Desired Conditions Stands with Tree dbh Proportion of (percent) Aspen on Forest Setting < 5 inches 5 to 10 inches > 10 inches (percent) Forest-Wide 10 81 9 8 Current Conditions Project Area 6.6 89.4 4.0 1.9 Current Conditions Forest-Wide 20-40 30-50 30-40 N/A Desired Conditions Source: Forest Service, 2009b. Disturbance by fire, mechanical treatments, or other events is essential to regenerate aspen suckers, create age class diversity, and remove conifer competition. Removal of conifers and sagebrush adjacent to the aspen clone is essential to expand the clone size. Live aspen stems provide nutrients to the roots and keep them alive which is critical for aspen proliferation in the Forest (Forest Service, 2009b page 21). Whitebark Pine. The Forest Service considers whitebark pine (Pinus albicaulis) to be a keystone species of high elevation ecosystems (Forest Service, 2009b) and has determined it to be a sensitive plant species (see Section 3.17, above). In addition to its status as a sensitive plant species, listing of whitebark pine as threatened or endangered under the Endangered Species Act has been found to be warranted but precluded by higher priority actions by the FWS (2011) and is currently listed as a candidate species under the Endangered Species Act (see Section 3.17, above). Fire suppression has led to more mature and densely stocked stands; perpetuation of whitebark pine is dependent on occasional fire disturbance homogeneous landscape patterns (Forest Service, 2009b). In the Forest, mixed severity fires were common in whitebark pine communities at a frequency of 50 to 150 years but stand-replacing fires were not common, occurring at 400 year intervals (Forest Service, 2009b). Based on fire history data in the Forest (Forest Service, 2013a), wildfire in the Project Area has been limited to approximately 106 acres that burned during the Triple Fire in 2005 and small fires ranging from 0.1 to 8 acres each, that burned in 1961, 1976, 1977, 1985, 1988, and 1993. The relative absence of fire in the Project Area may have contributed to the current reduced complexity of whitebark pine structural stages and absence of regenerating stands. The current structural stage distribution does not correspond with desired conditions (Table 3.19-3). Table 3.19-3 Current Whitebark Pine Structural Stage Distribution in the Forest and in the Project Area Compared to Desired Conditions Stands with Tree dbh Proportion of (Percent) Forested Area Setting < 5 inches 5 to 10 inches > 10 inches (Percent) Forest-Wide 3 31 66 19 Current Conditions Project Area 0 61.8 38.2 8.3 Current Conditions Forest-Wide 15+ 45 40 N/A Desired Conditions Source: Forest Service, 2009b.
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Throughout most of its range, whitebark pine is declining due to infections of blister rust, infestations of mountain pine beetles, competing vegetation, and effects due to climate change (Forest Service, 2009b). Young pines and cone-bearing branches of reproductive trees are particularly susceptible to blister rust which has reduced recruitment, indicated by only 3 percent of all whitebark pine stands in younger seral stage in the Forest (Table 3.19-3). Available data indicates that whitebark pine stands in young structural age classes do not occur within the Project Area. Of the 3,897.99 acres of forest/woodland vegetation in the Project Area, 395.06 acres or 8.3 percent are whitebark pine or mixed stands, less than the forest-wide distribution. Older age classes of whitebark pine are reduced in the Project Area compared to current forest- wide conditions. The extent of blister rust infection and mountain pine beetle infested trees in the Project Area has not been determined. The Greater Yellowstone Whitebark Pine Monitoring Working Group (GYWPMWG), an interagency collaboration, established a long-term monitoring program to document the health and status of whitebark pine across the Greater Yellowstone Ecosystem (GYE), including the Wyoming Range and Project Area, to detect changes in infection white pine blister rust, infestations of mountain pine beetle, and other factors affecting whitebark pine. Baseline conditions were evaluated from 2004 to 2007 and serve to compare surveys conducted in staggered sequence (every two years for mountain pine beetle and every four years for blister rust) at specified sites (time-step survey sampling). Although the Project Area has not been surveyed, there are survey locations south and west of the Project Area. Sites closest to the Project Area (and others in Sample Panel 3 distributed throughout the GYE, see Figure 1 in GYWPMWG, 2015) were surveyed in 2008 and 2012 only for mountain pine beetle and surveyed in 2010 and 2014 for blister rust and mountain pine beetle. Data for all Panel 3 Sites, including those closest to the Project Area, showed a somewhat constant rate in blister rust infection from 2010 to 2014; overall the proportion of trees infected with blister rust in the GYE ranges between 20 to 30 percent (GYWPMWG, 2015). Mortality of tagged whitebark pine trees increased between 2010 and 2014, especially for larger size trees with 29 percent showing infestation by mountain pine beetles and 71 percent having died of fire, blister rust; a combination of fire, mountain pine beetle, and/or blister rust; or with other factors, such as wind damage, animal damage, or unknown causes (GYWPMWG, 2015). Mountain pine beetle infestation is widespread and varies in severity throughout the GYE but evidence of mountain pine beetle infestation was present on 72 percent of all sampled units by the end of 2014. Nevertheless, wildfire played a significant role in whitebark pine mortality during the survey period (GYWPMWG, 2015). Subalpine Fir/Englemann Spruce. Subalpine fir and Englemann spruce are often associated with lodgepole pine, Douglas-fir, aspen, and whitebark pine in the Forest. Of the 3,897.99 acres of forest/woodland vegetation in the Project Area, 1,022.95 acres or 21.6 percent are mixed stands of subalpine fir/Englemann spruce forests, similar to the forest-wide distribution. High severity fires within subalpine fir/spruce communities are characteristic of the role fire has played in the vegetation community and contributed to stand and landscape structural and species diversity. Stand replacing fires in subalpine fir and spruce community types occur at 100 to 300 year intervals while mixed severity fires occur every 50 to 80 years (Forest Service, 2009b). Trees are mostly mature but spruce-fir vegetation in the Project Area mostly falls within intermediate tree sizes; there are no regenerating stands in the Project Area and young stands are rare in the Forest (Table 3.19-4). As noted above, the fire history in the Project Area indicates infrequent and limited burns that has likely limited the structural diversity in subalpine fir/spruce forests. The current structural stage distribution does not correspond with desired conditions (Table 3.19-4).
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Table 3.19-4 Current Spruce/Fir Structural Stage Distribution in the Forest and in the Project Area Compared to Desired Conditions Stands with Tree dbh Proportion of (percent) Forested Area Setting < 5 inches 5 to 10 inches > 10 inches (percent) Forest-Wide 0.6 41 58 24 Current Conditions Project Area 0 66.9 33.1 21.6 Current Conditions Forest-Wide 3 to 10 30 65 to 75 N/A Desired Conditions Source: Forest Service, 2009b.
Lodgepole Pine. This vegetation type makes up the largest percentage of any forested vegetation in the Forest. Of the 3,897.99 acres of forest/woodland vegetation in the Project Area, 2,391.13 acres or 50.5 percent are mixed stands of lodgepole pine, similar to the forest- wide distribution (Table 3.19-5). According to the Forest Service (2009), at least 75 percent of lodgepole pine communities is mature and subject to infestations by mountain pine beetles which currently are at epidemic levels in the forest. The beetles will continue to kill stands of mature lodgepole pine for the next several years thus beginning the beetle, fire, regeneration cycle described above (Forest Service, 2009b). Fire exclusion in stand replacing fire regimes, such as lodgepole pine, subalpine fir, and spruce communities, has promoted homogeneous landscape patterns even though stand replacing fires are within the natural ranges of these forest types. Current conditions within the Project Area do not correspond to desired conditions (Table 3.19-5) in the Forest.
Table 3.19-5 Current Lodgepole Pine Structural Stage Distribution in the Forest and in the Project Area Compared to Desired Conditions Stands with Tree dbh Proportion of (percent) Forested Area Setting < 5 inches 5 to 10 inches > 10 inches (percent) Forest-Wide 5 43 52 37 Current Conditions Project Area 0 62.9 37.1 50.5 Current Conditions Forest-Wide 10+ 30 to 40 30 to 50 N/A Desired Conditions Source: Forest Service, 2009b.
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3.19.2 Environmental Consequences Table 3.19-6 lists the proposed disturbance by vegetation cover type for each alternative. The Mitigation Alternative would have the same disturbance as the Proposed Action.
Table 3.19-6 Estimated Disturbance by Vegetation Type Proposed Action/ Mitigation Alternative Vegetation Type (acres) Well Pad 42-27 Mountain Big Sagebrush 0.28 Reclaimed/Reestablished 1.90 Vegetation Total 2.18 Well Pad 23-15 Mountain Big Sagebrush 0.18 Grassland/Forbland 0.97 Reclaimed/Reestablished 2.08 Vegetation Urban/Developed/Roads 0.09 Total 3.32 Grand Total 5.50 3.19.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to vegetation from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.19.2.2 Proposed Action Construction of the Proposed Action would directly impact vegetation, primarily by removal. Expansion of existing Well Pad 42-27 (1.04 acres) would affect an additional 2.18 acres of vegetation, including 1.90 acres of revegetated/reclaimed cover types associated with previous reclamation of the existing Well Pad 42-27 (generally grass and forbs) (Table 3.19-6). Reconstruction of Well Pad 23-15 would affect approximately 3.32 acres of vegetation (Table 3.19-6), where similar to the expansion of Well Pad 42-27 would mostly affect vegetation cover types reestablished from the reclamation of a previous well pad (2.08 acres). No vegetation removal would occur for construction of the water supply well on existing Well Pad 13-16a and for the temporary surface water line. Expansion of Well Pad 42-27, rather than construction of a new well pad would minimize additional fragmentation and reconstruction of Well Pad 23-15 on previously disturbed vegetation would minimize disturbance to unaltered vegetation cover types.
Approximately 3.80 acres of habitat would be reclaimed with “certified weed-free” and “certified cheatgrass free” seed approved by the Forest Service immediately after well pad drilling and completion, if weather allows or during the following growing season: approximately 1.91 acres for Well Pad 42-27 and 1.89 acres for Well pad 23-15 (see Table 2.3-4). Direct impact to grasslands, including reclaimed/reestablished vegetation mostly consisting of grass and forbs would be expected to be a short-term disturbance (reestablished within 5 years of disturbance),
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whereas impacts to shrub-dominated vegetation would persist for more than 5 years. For example, sagebrush can take up 10 to 15 years to become reestablished (West, 1988). After the wells have been plugged and abandoned, final reclamation would occur within one year and would obtain levels of revegetation approximate to adjacent vegetation cover types and original contours.
Indirect impacts to vegetation by the Proposed Action may occur from dust created during construction (including drilling and completion) and increased traffic, changes in hydrology and soil characteristics, and an increase in noxious weeds, resulting in alteration of vegetation cover and species composition. Invasive, non-native species could become established in cleared, disturbed areas and result in infestations that may limit or prohibit growth of native and/or desirable species. Weed seeds or cuttings of some species could be transported naturally (wind and water) or accidentally (vehicles or other equipment) to the disturbed areas. Weed seeds may be present in the native soil materials and the removal of vegetative cover and soil disturbance may promote weed establishment at the expense of desirable species. Although surveys conducted for the Proposed Action did not document State-listed or Sublette County- listed invasive weed species (Hayden-Wing, 2011), weeds on the State and County list are known to occur in the Project Area and/or have been documented on the Forest (see Table 3.6- 1; Forest Service, 2004; WGFD, 2012a). Reclamation as soon as possible after drilling and completion would minimize the potential for weeds to become established at disturbed sites. Well pad construction and Project-related traffic along existing access roads could create fugitive dust that may affect photosynthetic processes of native vegetation adjacent to proposed well pads and access roads. Water applied to unpaved roads and well pads during construction would reduce fugitive dust and potential effects to adjacent vegetation. 3.19.2.3 Mitigation Alternative Effects to vegetation under the Mitigation Alternative would be similar to those described for the Proposed Action. To further minimize the potential to transport or spread noxious weeds into the Project Area and compete with or degrade natural vegetation cover types, True Oil would implement the Forest Service (2004) weed management plan, and all vehicles and equipment used for construction, reclamation, and abandonment would be cleaned prior to entering and upon departure from the Project Area. Speed limits would also be enforced and where not posted on unpaved access roads, speeds would not exceed levels considered safe for the conditions and would be slow enough to prevent collisions with wildlife and livestock. This would minimize fugitive dust emissions.
3.20 VISUAL RESOURCES
3.20.1 Current Conditions Visual resources are the visible physical features of a landscape that convey scenic value. Scenic resources are important to the expectations and experiences of visitors and local residents. The area is generally conifer forested hills with stands of aspen dotted along roads and drainages. The existing landscape character currently reflects influences of natural processes and human activities. Changes in landscape character are managed by the Forest using Visual Management System objectives.
The DFCs applied to Management Area 25 within the Project Area include DFC 1B, which are achieved by applying Visual Quality Objectives (VQO) of Partial Retention or Modification and DFC 10, which are achieved by applying VQO of Retention, Partial Retention, and Modification (see Table 1.5-1). Retention objectives call for activities which are not visually evident. Changes in their qualities of size, amount, intensity, direction, pattern, etc., should not be evident. Partial
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Retention objectives call for activities to remain visually subordinate to the characteristic landscape. Activities can also create form, line, color, or texture which are found infrequently or not at all in the characteristic landscape. The Modification objective management activities may visually dominate the original characteristic landscape. Activities which are predominately facilities such as buildings, signs, and roads, should be patterned on established landscape so that its visual characteristics are compatible with the natural surroundings.
3.20.2 Environmental Consequences 3.20.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to visual resources from activities described below for the Proposed Action would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.20.2.2 Proposed Action Visual resources would be impacted by surface disturbing activities, fugitive dust, and the presence of wells and production facilities. These activities would create impacts to visual resources on a localized scale including contrasts in line, form, color and texture, depending upon site-specific landscape characteristics. The VQOs described above both for DFC 1B (Well Pad 23-15) and DFC 10 (Well Pad 42-27) would continue to be met.
Surface disturbance for well pad construction would be the major cause of visual resource impacts. The disturbance would present marked breaks and changes in the texture of the vegetation and landform patterns present. Well pad surface disturbance would impact visual line and texture elements in much the same way. Cut and fill effects would also introduce distinct color and texture contrasts by exposing bare soils in areas where native vegetation and top soil comprise the existing landscape color elements. Lighting on the well pads during the Construction Phase would be evident at night.
Effects to scenic resources would be minimized by painting all production equipment to match the surrounding terrain with colors approved by the Forest Service. The equipment would be placed on location to reasonably minimize visual impact. Well pads would be re-contoured and revegetated to blend with the natural topography as soon as possible after construction, leaving 2.74 acres of disturbance (1.43 acres for Well Pad 23-15 and 1.31 acres for Well Pad 42-27).
Existing Well Pad 42-27 is located with the 500 foot buffer of NFSR 10046. Expansion of Well Pad 42-27 would also be within the 500 foot buffer of NFSR 10046. Lease stipulations do not allow construction within the 500 foot road buffer without an exception to the stipulation. 3.20.2.3 Mitigation Alternative Effects to visual resources under the Mitigation Alternative would be similar to those described above for the Proposed Action. Under this alternative, lighting on the well pads during construction would follow “dark sky” lighting practices which would reduce any effects from lighting (see Section 2.3.3). Upon completion of drilling activities and as a function of interim reclamation, a vegetative visual screening or buffer would be planted between the adjacent primary roads and well pads 13-16a and 42-27. Tree sizes would be evenly distributed between the sizes of 2 foot to 8 foot. Trees would be transplanted from nearby areas as designated by
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the forest timber program. Trees would be acquired via the Forest Service commercial tree purchase process so as to plant trees most acclimated to the area. Trees would be transplanted according to industry best planting practices which includes season of transplant and method of transplanting. Number of trees should range between twenty and fifty trees per well pad based on input from the Forest Visual Resource Specialist and as decided by the Authorized Officer.
3.21 WASTES, HAZARDOUS OR SOLID
3.21.1 Current Conditions Hazardous and solid wastes are not a part of the natural environment; however, they could be introduced into the environment as a result of implementation of the Proposed Action, as described below.
3.21.2 Environmental Consequences 3.21.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related effects from wastes described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.21.2.2 Proposed Action A variety of wastes would be generated during drilling, well completion, and post-completion operations. Hazardous materials would also be used on site. These wastes and hazardous materials are described below.
Drill Cuttings. Drill cuttings from the well bore (mainly shale, sand, and miscellaneous rock minerals) and drilling fluids (mud) would be generated. Drilling muds may contain small concentrations of a variety of contaminants, including mercury, cadmium, arsenic, and hydrocarbons, which could adversely affect soil and water resources if released into the environment. Drill cuttings from each well bore are exempt from regulation under Subtitle C of the Resource Conservation and Recovery Act (RCRA) but are still subject to other portions of the Rule. If testing (in accordance with requirements in APD approvals) shows the cuttings cannot be buried on-site, they would be disposed off-site at R360 Environmental Solutions located at 1427 Calpet Road in LaBarge, Wyoming.
Water from Hydraulic Fracturing. Water used during hydraulic fracturing could adversely affect soil and water resources if released to the environment; however, excess water would be stored in temporary tanks (closed loop system) prior to reuse or disposal. Any non-recycled drilling fluids would truck to disposal at R360 Environmental Solutions located at 1427 Calpet Road in LaBarge, Wyoming.
Hazardous Materials. A variety of materials typical of oil and gas development could be present on site including lubricants, diesel fuel, gasoline, solvents, and hydraulic fluids, particularly during construction (including drilling and completion). Hazardous materials may include drilling mud and cementing products that are primarily inhalation hazards and materials that may be necessary for well completion/stimulation such as flammable or combustible
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substances and acids/gels (corrosives). Hazardous materials stored on site could adversely affect soil and water resources if released to the environment; however, no hazardous substances or wastes would be stored on the location after completion of a well. All hazardous substances brought to the location would have a Safety Data Sheet (SDS) and would be properly handled so as to not cause harm to the environment or people.
Other Solid Wastes. Other solid wastes associated with drilling and well completion would include human waste and trash. Portable, self-contained chemical toilets at worksites would be used for human waste disposal. Portable toilet and domestic wastewater holding tanks would be pumped and the contents hauled away for disposal at an approved sewage disposal facility on a timely basis. All garbage and non-flammable waste material would be disposed of at an approved, off-site facility. Other solid waste could adversely affect soil and water resources if released to the environment.
Produced Fluids. Produced water and condensate would be stored on-site in tanks until it would be removed by truck. Produced water is typically high in salinity and typically contains petroleum hydrocarbons and BTEX (benzene, toluene, ethyl benzene, and xylene) constituents. The aboveground tanks would remain on site for the life of the well(s). Long-term, undetected leaks from tank batteries are a potential source of groundwater contamination. Corrosion of steel tanks over the long term is quite likely. The high salt content of the produced water could very likely contribute to this process. Potential releases of produced water could occur from tanking, piping, and transport trucks. This could be the result of an accident, or tank/piping failure; however, all tanks and processing equipment would be surrounded by secondary containment adequate to retain at least 110 percent of the volume of the largest vessel with sufficient freeboard/storage for precipitation in the event of a release.
Surface waters could be negatively impacted by spills of produced water or oil, or hazardous materials stored at the pad. In cases where petroleum hydrocarbon or BTEX concentrations in contaminated soil are above regulatory limits, soil would be removed and disposed of at an approved facility. There is also the potential for diesel fuel spills from ruptured fuel tanks. Diesel spills generally require removal of contaminated soils. Any spill meeting reportable criteria would immediately be reported to the Forest Service District and proper authorities as defined by the EPA. Prompt response is necessary in the case of diesel or produced water spills in order to minimize negative impacts to surface/groundwater, plant and wildlife resources. With incorporation of design features and effective response (implementation of the SPCC Plan Plan), direct, indirect impacts from wastes would be expected to be minimal. 3.21.2.3 Mitigation Alternative Potential effects from wastes under the Mitigation Alternative would be the same as those described above for the Proposed Action.
3.22 WATER RESOURCES
3.22.1 Current Conditions – Surface Water The Project Area is on the eastern side of the Wyoming Range, and the drainages in the area originate in the high mountain valleys and generally flow east out of the mountains onto the high plains of the Green River Basin. The Project Area includes two primary drainages - South Cottonwood Creek and Bare Creek (Map 3.22-1). An aerial photograph showing the drainages in the Project Area is shown on Map 3.22-2. South Cottonwood Creek and Bare Creek converge about 1 mile east of the Project Area. The combined drainage, South Cottonwood Creek, flows east and is tributary to the Green River about 35 miles downstream of the Project Area.
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Map 3.22-1 Subwatersheds
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Map 3.22-2 Surface Water Features and Photo Locations
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South Cottonwood Creek drains from west to east across the northern portion of the Project Area. Lander Creek and Trailer Creek drain into South Cottonwood Creek from the north and south, respectively, and the natural Soda Lake is about 1,000 feet south of South Cottonwood Creek. Photos 3.22-1 and 3.22-2 show South Cottonwood Creek and Soda Lake, respectively, and the photo locations are shown on Photo 3.22-1. The drainage area for South Cottonwood Creek upstream from its confluence with Bare Creek is about 15,000 acres, of which about 11,000 acres is upstream from the Project Area, as shown on Map 3.22-1 (Forest Service, 2005).
Although the singular term ‘Soda Lake’ is frequently used, the area includes three ponds or small lakes. The largest, westernmost lake is sometimes referred to as West Soda Lake, and the area is referred to as the Soda Lake Pond(s). To avoid confusion with other features named Soda Lake in the area, the term ‘Cottonwood’ may be added to indicate the proximity to South Cottonwood Creek. Combined, the three ponds cover an area of about 27 acres (WGFD, 2014).
Photo 3.22-1 South Cottonwood Creek – Looking Upstream from Approximate Location of the Eastern Border of the Project Area (Hayden Wing, 2011)
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Photo 3.22-2 Soda Lake – From Forest Service Air Quality Survey, August 2001
The South Fork of Bare Creek drains from south to northeast along the eastern portion of the Area. The West Fork of Bare Creek drains from west to east across the middle of the Project Area into the South Fork of Bare Creek. Photo 3.22-3 shows South Fork of Bare Creek, and the photo location is shown on Map 3.22-2. The Bare Creek watershed is about 5,300 acres (Forest Service, 2005), and much of the watershed is within the Project Area (Map 3.22-1).
Photo 3.22-3 Bare Creek – Looking Upstream in Eastern Portion of Lander Peak Unit (Hayden-Wing, 2011)
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Surface Water Flow. The Project Area lies within a precipitation shadow on the eastern side of the Wyoming Range. However, annual precipitation is still substantial, with an average annual water depth of approximately 34 inches. The majority of precipitation falls in the form of snow in the late fall, winter, and spring months. Although highly variable, late spring, summer, and fall thunderstorms contribute significant amounts of rain during the year (Forest Service and BLM, 1988).
Maximum snow accumulation occurs in late April. Snowmelt commences in mid- to late April at the lower elevations and in mid- to late May at upper elevations, and terminates in mid-June to early July depending on elevation. In response, several minor streamflow increases occur in April and May when lowland snowmelt occurs. Annual peak flows occur from late May into early June in response to snowmelt at middle to upper elevations. Streamflows decline from this peak to base flow levels, which are reached in mid- to late August. Other increases in stream discharge occur in response to thunderstorms primarily during the summer and fall. Minimum flows occur during the January through March period (Forest Service and BLM, 1988).
The streamflows in the upper elevations of the Project Area are characteristic of mountainous areas with steep gradients. As the elevations and gradients decrease downstream, South Cottonwood Creek has developed a relatively wide floodplain, ranging from 100 feet to up to 2,000 feet wide, with a more sinuous, meandering channel (Forest Service and BLM, 1988).
Available streamflow data is limited. A stream gauging station on South Cottonwood Creek has been monitored sporadically since 1983. The station is within the Project Area, about ¼ mile below the confluence of Lander Creek and South Cottonwood Creek (Map 3.22-2). The station was monitored year-round by the USGS in 1983 and 1984, and then monitored during the irrigation season from 1985 through 1990 by the WSEO. The station was again re-established by the WSEO in late 2011. The available streamflow data collected from that station from 1985 through 1990 is summarized in Table 3.22-1, and the streamflow data collected since 2011 is shown on Figure 3.22-1. The data illustrates the considerable variation, from almost 0 to over 400 cubic feet per second (cfs), due to snowmelt and thunderstorms.
Table 3.22-1 Mean Monthly Creek Streamflow Measurements, (cfs), 1983 – 1990 Monitoring Station 091913 - South Cottonwood Creek Near Big Piney, Wyoming (Drainage Area = 21.4 square miles) Year Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 1983 22.4 17.2 127.0 10.2 8.6 8.6 8.2 24.6 19.3 151.0 43.4 24.3 1984 21.6 18.3 14.0 15.4 11.4 11.1 9.6 42.8 167.0 123.0 36.4 19.9 1985 140.0 48.0 25.0 18.7 1986 305.0 127.0 38.0 24.0 1987 1988 120.0 36.7 20.9 14.7 1989 160.0 94.8 38.8 22.0 1990 142.0 57.0 25.6 25.2 Source: Western Water Consultants, 1992.
A set of flow estimates along South Cottonwood Creek and Bare Creek from late August through September 2011 is available as part of the 2011 biological survey, and the data from Appendix IV of the survey report (Hayden-Wing, 2011) is summarized in Table 3.22-2, below.
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Figure 3.22-1 Available Surface Water Flow Data from South Cottonwood Creek – Gaging #9191300 (WSEO, 2016)
As part of the standardized habitat description (Overton et al., 1997), streamflows were estimated for each reach of the creek. In South Cottonwood Creek, the streamflows above the confluence with Bare Creek ranged from about 32 to 38 cfs along the reaches, with one exception. In two reaches, above the confluence with Bare Creek, the streamflow estimates were higher, 52 and 59 cfs, possibly due to the difficulty of measuring flows in these reaches because of the number of plunge pools and extent of beaver activity. No consistent increase or decrease is evident until close to the confluence with Bare Creek, where the streamflows increased from about 41 cfs just below the confluence to 72 cfs about a mile below the confluence. The flows in Bare Creek were less than 10 percent of the flows in South Cottonwood Creek. The flows are also relatively consistent, ranging from about 1.6 to 3.3 cfs, with one exception. The one exception is 6.56 cfs, which may be an estimation error. No consistent increase or decrease is evident.
Historically, South Cottonwood Creek and Bare Creek have been subject to natural and man- made influences which affected the channel characteristics. In particular, beaver dams are not uncommon along the creeks (Hayden-Wing, 2011). As part of the ‘tie hacking’ operations in the early 1900s, a surge dam was constructed on Bare Creek to retain water to flush railroad ties cut from local timber down the creeks to the Green River. Other activities associated with the tie hacking operations included construction of villages, isolated cabins, and roads (Schoen, 2015). A survey map from the mid-1940s notes an “unfinished dam” on South Cottonwood Creek (U.S. Department of the Interior, 1945), although no information on the ultimate purpose of the dam was found. The dam was apparently never finished or was removed. In 1940, the Bare Creek Fire burned over 10,000 acres, including portions of the Bare Creek watershed, and the 1,000- acre Cottonwood Fire in 1956 also burned portions of the watershed in the Project Area (Forest Service, undated and 2005). More recently, timber harvesting, fuels management and forest treatments, stream crossing construction and improvements have affected the channels (Forest Service, 2005). Proposed work includes repairs on South Cottonwood Creek after flood damage (Forest Service, 2015f).
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Table 3.22-2 Streamflow Measurements - September 2011 K (Surface Q Correction Coefficient) Reach Time Width Depth (no Length Number 1 (seconds) (m) (m) dimension) (m) m3/s ft3/s Comments South Cottonwood Creek 1 9.01 8.33 0.26 0.85 10 2.04 72.16 Eastern Forest boundary. This reach starts with headgate of 2 10.24 8.93 0.24 0.85 10 1.78 62.83 irrigation ditch; note is probably insignificant Δ in flow due to diversion." Confluence with Bare Creek at top of 3 14.7 4.1 0.49 0.85 10 1.16 41.02 reach. 4 10.1 5.2 0.38 0.85 10 1.66 58.73 -- 5 8.4 6.3 0.17 0.85 10 1.08 38.27 -- 8.4 6.3 0.17 0.80 10 1.02 36.02 -- Measurements included in comments. 'k' 6 assumed to be same as for other 'Q' in 12.0 5.2 0.42 0.80 10 1.46 51.55 reach. Several plunge pools, created by log placement, noted in comments. Confluence with Lander Creek at top of 7 19.2 7.3 0.28 0.85 10 0.90 31.96 reach. Confluence with channel draining Soda 8 19.2 7.3 0.28 0.85 10 0.90 31.96 Lake Complex at bottom of reach. In top of reach, note is "side channel right 9 13.8 6.8 0.24 0.85 10 1.01 35.50 side from hillside spring." Confluences with Trailer and Hidden Basin Creeks at bottom and top of reach, 10 12.7 6.1 0.24 0.85 10 0.98 34.60 respectively. In middle of reach, note is "side channel right side from hillside spring." Bare Creek Confluence with South Cottonwood Creek 1 6.53 1.63 0.13 0.80 3.6 0.093 3.30 at bottom of reach. Reported Q - 0.099 m3/s. 2 8.4 1.4 0.08 0.85 4.0 0.045 1.60 -- 3 16.7 1.7 0.18 0.85 5.0 0.078 2.75 --
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K (Surface Q Correction Coefficient) Reach Time Width Depth (no Length Number 1 (seconds) (m) (m) dimension) (m) m3/s ft3/s Comments 4 51.3 2.0 0.18 0.90 10.0 0.063 2.23 Reported Q = 0.071 m3/s. 5 65.1 2.0 0.21 0.85 10.0 0.055 1.94 -- 6 33.3 1.9 0.18 0.85 10.0 0.087 3.08 -- 58.9 3.8 0.18 0.80 20.0 0.186 6.56 Unusual length.
25.7 1.6 0.22 0.80 6.0 0.066 2.32 Measurements included in comments. 'k' 7 assumed to be same as for other 'Q' in reach. Q for 6m length reported as 0.093 21.8 2.1 0.11 0.80 10.0 0.085 2.99 m3/s. 8 6.8 1.1 0.13 0.85 3.5 0.063 2.21 -- South Bare Creek 1 5.2 0.9 0.06 0.85 3.0 0.026 0.94 -- 2 8.0 1.0 0.06 0.85 2.1 0.013 0.47 Stream subterranean in parts of reach. West Bare Creek 1 42.0 1.7 0.14 0.90 5.0 0.026 0.90 -- In lower part of reach insignificant side channel from springs on hill right side." In 2 5.8 0.83 0.06 0.85 5.0 0.036 1.29 upper part of reach, creek is dry or stagnant pools. 1 Hayden-Wing, 2011. Reaches are numbered from downstream to upstream.
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Surface Water Quality. South Cottonwood Creek is designated as a Class 2AB stream by WDEQ-WQD, and all but one of its tributaries within the Project Area are designated as Class 2AB streams by WDEQ (2013b). The exception is Lander Creek, which is classified as Class 3B. Bare Creek is also designated as Class 2AB. The designated uses for the WDEQ use- based water classifications 2AB and 3 are listed in Table 3.22-3. No surface water quality data has been found for the Project Area (or within 1 to 2 miles around it), but the surface water quality within the area is considered good to excellent for livestock, agricultural, and domestic uses based on visual observation and the fisheries quality.
Table 3.22-3 WDEQ Use Based Surface Water Classifications – Classes 2AB and 3B 1
Game Fish Scenic Value Fish Consumption Other Aquatic Life Agriculture Industry Recreation Wildlife Class Game Fish Non - Drinking Water 2AB Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes 3B No No No No Yes Yes Yes Yes Yes Yes 1 Source: WDEQ, 2013b.
3.22.2 Environmental Consequences – Surface Water 3.22.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to surface water quantity and quality from activities described below for the Proposed Action and other alternatives would occur. Under this alternative, any opportunities described below in Section 3.22.2.2 for reducing potential impacts to surface water quality with expansion of existing Well Pad 42-27 through construction of new berms, installation of new BMPs, and use of corrugated steel berms with liners would not be realized. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.22.2.2 Proposed Action Surface Water Quantity. No measurable diminution or increase in surface water flows would be anticipated in the South Cottonwood Creek watershed as a result of implementing the Proposed Action. No damming or diversions would be made in or outside channels or riparian areas, other than temporary stormwater control berms on well pads and any necessary berms around tanks or other facilities on the well pads. No surface water would be withdrawn for any purpose, nor any discharge made to stream channels.
The proposed new water supply well on existing Well Pad 13-16a would provide a portion of the water supply needed for well construction (including drilling and completion) and for dust control. The permitted depth and pumping rate for the proposed water supply well are 200 feet and 30 gallons per minute (gpm) (approximately 0.1 cfs), respectively. Based on the anticipated production interval (Attachment B), the groundwater tapped by this well would include
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groundwater from the shallow, alluvial aquifer and from the shallowest, consolidated geologic formation, the Blind Bull Formation. For comparison, the base flow rate in South Cottonwood Creek was estimated to be about 2,244 gpm (5 cfs) about 2 miles downstream of the Project Area. This estimate was from a statistical model of the flow rates including the driest years on record (Western Water Consultants, 1992). Using the data in Table 3.22-2, the base flow farther upstream, e.g., in the Project Area, would probably be less than, potentially one-half to one-third of, the base flow downstream or about 1 to 2 cfs. Even if it were assumed that the well was pumped continuously, which would not be the case, and all of the groundwater pumped from the well would have contributed to the base flow of the creek (or all the water pumped from the well infiltrated from the creek), the impact would be minimal.
Surface Water Quality. During Construction (including drilling and completion), which is anticipated to take 2 to 3 years (Section 2.3.2), potential impacts of the Proposed Action to surface water quality in the South Cottonwood Creek watershed could include erosion and sedimentation from disturbed areas, and contamination by spills and leaks. If the wells are put into production (Section 2.3.2), interim reclamation would reduce the erosion and sedimentation potential during the life of the Project, which is expected to be about 20 years. On-site activity would also be less, reducing the potential for contamination by spills and leaks. Once reclamation requirements are met (Section 2.3.2), there would be no potential for impacts.
Erosion and deposition are naturally occurring processes in the watershed. As with any project which creates new surface disturbance and alters physical properties of the soil, there is the potential for some increased erosion and deposition of soil in surface waters. The proposed expansion of Well Pad 42-27 is within the 500 foot stream buffer (within 200 feet) of South Fork Bare Creek. Lease stipulations do not allow construction within the 500 foot stream buffer without a waiver.
To evaluate the quantities of soil that could contribute to the sediment load in the surface waters, potential impacts due to erosion and sediment transport were analyzed using the Tahoe Basin Sediment Model of the Water Erosion Prediction Project model (TBSM/WEPP). The modeling approach is described in Attachment E. The model did not include the use of BMPs, which would further reduce any sediment transport, but the model report did include recommendations for BMPs. The results of the evaluation are included in Attachment E and are summarized below:
• Existing Reclaimed Area – Well Pad 23-15: No sediment from the existing reclaimed area reaches the wetland adjacent to South Cottonwood Creek; • Reconstructed Well Pad 23-15: No change from existing reclaimed area. It is unlikely that sediment transport from the reconstructed Well Pad 23-15 would impact the wetland adjacent to South Cottonwood Creek, and a road is between the pad and the creek, so the road would be a more likely source (if any) than the pad; • Existing Well Pad 42-27: The probability that 0.001 tons/acre of sediment or more reaches the South Fork Bare Creek is 2 percent in any given year; and • Expansion of Well Pad 42-27: The probability that sediment reaches the South Fork Bare Creek is the same as for existing Well Pad 42-27. The amount of sediment might increase slightly, as the area of the well pad increases.
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True Oil would implement BMPs included as recommendations in the HydroGeo Report (Attachment E) to minimize potential effects to South Fork Bare Creek from erosion and sediment transport. BMPs include construction of diversion ditches around well pads to prevent sediment loss from the area including direction of channel surface water flow to one or more sediment traps. Flows from the traps would discharge to an armored detention basin that would dissipate the flow energy and prevent erosion. All disturbed areas would be revegetated as soon as possible after disturbance. With successful and timely implementation of the BMPs, impacts to water quality and flow to wetlands and streams resulting from erosion and sediment flow would be minimal and short-term.
Under this alternative, potential impacts to water quality resulting from erosion and sediment transport and from spills and leaks would be reduced (even though the proposed expansion is within the 500 foot stream buffer of South Fork Bare Creek) because a new berm would be constructed around the expanded well pad, new BMPs would be installed (as discussed above in Section 2.3.2.1), and current earthen berms around tanks on the existing well pad would be replaced with corrugated steel berms with liners.
Potential impacts to surface waters would be directly related to spills and leaks of industrial chemicals. Potential contaminants include diesel, gasoline, lubricants, and other materials associated with construction and operations. The potential for leaks and spills to affect surface waters would be greatly reduced by implementation of measures included in True Oil’s SPCC Plan and SWPPP and other Project Design Features such as secondary containment designed to prevent contamination of soil and runoff water. With implementation of the above described measures, potential impact to surface water would be prevented except during very rare events or accidents. Section 3.22.4 Environmental Consequences - Groundwater, below, provides additional detail regarding impacts to groundwater levels and quality from the Proposed Action. 3.22.2.3 Mitigation Alternative Similar to the Proposed Action, no measurable impacts to surface water quantity are anticipated. Potential impacts to surface water quality under the Mitigation Alternative would be similar but potentially less than those described for the Proposed Action. Under this alternative, all chemicals, solvents, and fuels would be kept at least 150 feet away from streams and riparian areas and all refueling would occur at least 150 feet away from streams and riparian areas. This would reduce the potential for leaks and spills to impact surface water quality compared to the Proposed Action because in the event of a leak or spill, liquids would have to travel a greater distance to reach streams and/or riparian areas compared to the Proposed Action. This would allow additional time for spill response as well.
Site-specific data collection (streamflow measurements and water quality sampling) would occur prior to construction, during construction, and during operations. The data would provide information on the magnitude of flows, the constituent concentrations, and the natural variability in the surface water flows and quality. The proposed sampling locations (see Map 2.3-4) were selected to minimize potential impacts to the environmental resources. The locations are close to existing access to the creeks and Soda Lake to minimize vehicle or foot traffic. The quantities of water required for sampling are not significant compared to the streamflows. Monitoring would be conducted in accordance with the Sampling and Analysis Plan (see Section 2.3.3). Depending on monitoring results, operational revisions may be necessary.
3.22.3 Current Conditions – Groundwater Quantity and Quality In the Project Area, the groundwater occurrence is strongly controlled by the geologic structural setting and by the lithology of the geologic formations (see Section 3.5, Geologic Resources).
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Within the Prospect Thrust Sheet, the stratigraphic displacements due to the regional faulting of the geologic formations result in aquifers of limited areal extent, compared to the regional aquifers in the formations below the thrust sheet and to the east of the thrust sheet in the Green River Basin.
On a regional scale, thrust faults can act as barriers to groundwater flow (Huntoon, 1983), due in part to the juxtaposition of strata with different hydrologic properties. The dip of the formations to the west in the Prospect Thrust Sheet is also anticipated to reduce the potential for groundwater movement from the thrust sheet to the basin. In most sedimentary deposits, the vertical permeability is less that the horizontal permeability due to the influence of the depositional layers (Bear, 1975). If tilted, as in the Prospect Thrust Sheet (Figure 3.22-2), the highest permeability is still generally in the direction of the depositional layers. Therefore, horizontal groundwater movement from the geologic strata on the Prospect Thrust Sheet, ‘across’ the thrust fault, to the strata in the Green River Basin is anticipated to be limited (Ahern, 1981).
Lithologic variations in the geologic formations also affect the groundwater occurrence. In particular, the depositional environments resulted in interbedded shales, which are relatively impermeable, and more permeable sandstones. As a result, the extent of water-bearing zones which could be tapped for water supply may be limited laterally and vertically by the stratification of the geologic deposits and heterogeneity within those deposits. Perched aquifers may also be present.
The general hydrologic properties of the geologic strata underlying the Project Area and its vicinity are summarized in Table 3.22-4, and the cross-sections in Figure 3.22-2 illustrate the relative positions of the strata. No site-specific groundwater quantity or quality data is available within or in the vicinity of the Project Area because there are only a few shallow water wells, all of which are at least 1 mile east of the Project Area and on the east side of the Prospect Thrust Fault. The focus of the data collection from existing oil and gas wells was generally on the deeper formations from which oil and gas production was anticipated, so geologic and geophysical logs for most of the wells start a few hundred feet below surface. General hydrogeologic information is available from regional studies, and that information is generally organized by geologic strata. As noted above, the available information on the hydrogeologic conditions is summarized in Table 3.22-4, and the cross-sections in Figure 3.22-2 illustrate the relative positions of the strata.
The extent of surface and groundwater interaction along the drainages in the Project Area is also relatively unknown. According to Lines and Glass (1975), there is significant groundwater contribution to the stream flow in this area, although no major springs are noted in the area. An estimate of the streamflows, by month, for the driest years on record provides a basis for estimating the groundwater contribution to South Cottonwood Creek (Western Water Consultants, 1992). During October through March, the estimated flow rate for the driest years on record is about 2,244 gpm (5 cfs) just downstream of the Project Area. Because there is little snowmelt or rain during these months, this streamflow rate could be considered the base flow, i.e., the groundwater contribution to South Cottonwood Creek above that location. For comparison, individual springs yielding over 1,000 gpm (2.2 cfs) occur elsewhere in the Overthrust Belt from the same formations present in the vicinity of the Project Area (Eddy-Miller et. al., 1996).
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Table 3.22-4 General Hydrologic Properties of the Geologic Strata in the Lander Peak Unit
General Hydrologic Properties - Strata West of the Prospect Thrust Fault General Hydrologic Properties - Strata East of the Prospect Thrust Fault Geologic Age Geologic Strata 1 Groundwater Availability
Other than the Wasatch Formation, the alluvial Geologic Age Geologic Strata (1) Groundwater Availability deposits are probably the most widely used as a water source in the Green River Basin. The Other than alluvial deposits, this formation is water availability in the alluvial deposits depends probably the most widely used as a water source in Alluvial Deposits in large part on the thickness of the deposits. In Quaternary the Green River Basin. The availability of water (Alluvium and Glacial Till) alluvium, coarser sand and gravel deposits depends on the extent of more permeable would yield more water than finer slit and clay sandstones and conglomerates interbedded with deposits. Glacial materials would generally be Tertiary Wasatch Formation less permeable shales (Welder, 1968; Lines & difficult to drill with highly variable lithologies Glass, 1975). Mineralized water may be present (Welder, 1968). depending on local geology (Welder, 1968), e.g., Hilliard The Hilliard Shale is considered an aquitard, and increased sulfate concentrations where gypsum is Shale the Frontier Formation is considered a minor present. Blind Bull aquifer (Ahern, 1981). Sandstone layers within Upper Cretaceous Formation the Frontier Formation (or Blind Bull Formation) The availability of water depends on the extent of Frontier Formation may yield moderate quantities of water (Lines more permeable sandstones interbedded with less and Glass, 1975; Clary et al., 2010). Tertiary Fort Union permeable shales (Welder, 1968). Oil and gas Aspen Shale Described as discontinuous aquifers with local producing formation in the vicinity of the Lander Dakota Formation confining beds (Ahern, 1981; Clary et al., 2010). Peak Unit. Bear River Formation Lines and Glass (1975) group all but the Gannet Considered a major aquifer (Clary et al., 2010) Lower Cretaceous Group with the Blind Bull and associated although availability of water depends on extend of formations and include the Granite Group with Mesaverde Formation sandstones interbedded with sitlstones and shales Gannet Group the formations below through the Nugget (Ahern, 1981). Oil and gas producing formation in Sandstone. the vicinity of the Lander Peak Unit. Stump Sandstone Described as aquitards (Ahern, 1981) or Upper Cretaceous The Hilliard Shale is considered an aquitard, and Upper Jurassic Hilliard Shale Preuss Redbeds relatively impermeable (Lines and Glass, 1975). the Frontier Formation is considered a minor aquifer (Ahern, 1981). Sandstone layers within the Twin Creek Limestone The Twin Creek Limestone is considered a minor Middle Frontier Formation (or Blind Bull Formation) may aquifer, and the Gypsum Spring Formation is Jurassic Gypsum Spring Formation Frontier Formation yield moderate quantities of water (Lines & Glass, considered a confining unit. 1975; Clary et al., 2010). Jurassic/ Nugget Sandstone Considered a major aquifer. 1 See Table 3.5-1 for additional information on the geologic strata and Figures 3.5-1 and 3.22-2 for geologic cross- Triassic sections. Ankareh Formation Ahern (1981) considers the Ankareh Formation a minor aquifer and the Thaynes Limestone a major aquifer, and groups them with the Nugget Chugwater Sandstone. Lines and Glass (1975) do not group Lower Triassic Thaynes Limestone them with the sandstone, although the relative productivity is considered the same, and note the productivity of the limestone depends on secondary permeability.
193 Lander Peak Area Exploratory Proposal Environmental Assessment
Figure 3.22-2 Geologic Cross-Section in the Vicinity of the Lander Peak Unit
Within the Lander Peak Unit, groundwater quality in the water-bearing strata within the Prospect Thrust Sheet is anticipated to be good to excellent for domestic, livestock, and agricultural uses. Possible exceptions would be in the less permeable strata, e.g., shale layers, and in areas of localized mineralization, such as gypsum-rich layers. Beneath the Prospect Thrust Sheet, the groundwater quality is anticipated to be poorer because of the formation depths and mineralization. Two formations that provide water supply elsewhere in the Green River Basin, the Frontier and Mesaverde formations, are the oil and gas producing formations in the Project Area and nearby oil and gas units (Section 3.9), so the water quality is expected to be poor.
3.22.4 Environmental Consequences – Groundwater Quantity and Quality 3.22.4.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to groundwater resources from activities described above for the Proposed Action and other alternatives would occur. The reduced potential for leaks and spills to impact groundwater described below under the Proposed Action would not be realized because existing Well Pad
194 Lander Peak Area Exploratory Proposal Environmental Assessment
42-27 would remain in its current condition. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.22.4.2 Proposed Action Groundwater Quantity - Water Supply. Impacts to groundwater quantity would be greatest during well drilling and completion, because groundwater is generally used as the well drilling fluid and as the hydraulic fracturing fluid. Once a well is in production, groundwater is generally not needed unless used as a water supply for the personnel working in the oil and gas unit.
The proposed new water supply well for use during well construction and completion drilling in the Lander Peak Unit would provide a portion of the supply needed for well drilling and completion. The permitted depth and pumping rate for the proposed well are 200 feet and 30 gpm (≈0.067 cfs), respectively. Based on the anticipated production interval (Attachment B), the groundwater tapped by this well would include groundwater from the shallow, alluvial aquifer and from the shallowest, consolidated geologic formation, the Blind Bull Formation. For comparison, the base flow rate in South Cottonwood Creek is estimated to be about 2,244 gpm (5 cfs), about 2 miles downstream of the Project Area. This estimate was from a statistical model of the flow rates including the driest years on record (Western Water Consultants, 1992). Using the data in Table 3.22-2, the base flow farther upstream, e.g., in the Project Area, would probably be less than, potentially one-half to one-third of, the base flow downstream or about 1 to 2 cfs. Even if it were assumed that the well was pumped continuously, which would not be the case, and that all of the groundwater pumped from the well would have contributed to the base flow of the creek (or all the water pumped from the well infiltrated from the creek), the impact would be minimal.
The proposed water well is permitted by the WSEO for up to 700,000 gallons per year (16,666 barrels per year). The remainder of the supply needed for well construction and completion is proposed to come from a municipal source. As listed in Table 2.3-6, a total of about 10,416,000 gallons (360,800 barrels) would be needed during Construction. The proposed water well could supply up to 1,400,000 gallons (130,000 barrels) of the water needed (i.e., 700,000 gallons per year over a 2-year construction period), resulting in about 9,000,000 gallons that would be needed from a municipal source. Assuming the well drilling and completion took place over a two-year period and the water usage requirements were consistent over that time, the water requirements would be on the order of about 10 gpm. However, the water usage requirements could vary and are anticipated to be highest during hydraulic fracturing. During the three weeks for hydraulic fracturing, the rate of water usage could increase to about 65,000 barrels over 20 days, or about 90 gpm. (For comparison, the water supply for a fish hatchery is on the order of 1,000 gpm (WGFD, 2016b), and the water usage would be a very small percentage (much less than 1 percent) of the annual municipal and domestic water usage in the Green River Basin (WEA, 2014).
Once production begins, the primary water supply requirement is for dust control. Due to the substantial reduction in traffic during production, it is anticipated the water supply for dust control would be substantially less than during well construction and completion.
Groundwater Quantity – Water Movement Within and Between Aquifers. Impacts to groundwater quantity due to water exchange within and between aquifers could originate due to problems with well construction drilling, completion, and maintenance resulting in well casing and cementing failure. Such problems are precluded by cemented casing sealing the well off
195 Lander Peak Area Exploratory Proposal Environmental Assessment
from shallow and valley fill aquifers, and sealing the boring between them. Each piece of casing would be cemented and the cement seal tested by geophysical logs to ensure integrity.
Impacts to groundwater quantity due to water exchange within and between aquifers could originate due to changes to naturally occurring subsurface geologic conditions, such as during hydraulic fracturing. As discussed in Section 3.5, the extent of the influence of the hydraulic fracturing is not anticipated to be sufficient to allow for any increased permeability outside of the Hilliard Shale.
Groundwater Quality - Spills and Leaks. Impacts to groundwater quality can originate from surface/shallow sources related to oil and gas construction and production. These sources are most often spills and leaks from equipment and facilities such as trucks, tanks, and pipelines. Impacts to groundwater quality can also originate from deeper sources related to oil and gas construction and production. The potential for groundwater quality impacts is generally greatest during well construction and completion, although the potential exists throughout the life of a project.
The potential for surface leaks and spills to affect groundwater would be greatly reduced by the Project Design Features described in Chapter 2. By avoiding surface impacts, the potential for downward leakage of spills or leaks into the groundwater is reduced. For example, with the expansion of Well Pad 42-27, existing earthen berm containment on the well pad would be replaced with corrugated steel berms with liners for containment and new berms would be placed around the expanded well pad making the potential for spill and leaks to reach groundwater is less likely. The use of protective drilling and completion procedures (Section 2.3.2), such as casing through the shallow anticipated groundwater, e.g., the alluvium, reduces the potential for contamination of shallow groundwater.
Groundwater Quality - Water Movement Within and Between Aquifers. Impacts to groundwater quality can also originate from deeper sources related to oil and gas construction and production. These sources are most often due to naturally occurring subsurface geologic conditions and due to problems with well drilling, completion, and maintenance resulting in well casing and cementing failure. As discussed in Section 3.5.2, no geologic impacts are anticipated which could, in turn, result in groundwater quality impacts. Creation of new pathways between aquifers, such as along a fracture or fault, is not anticipated; therefore, increased groundwater movement within and between aquifers, which could impact groundwater conditions, is not anticipated. Once a well is properly abandoned at the end of a project, the risk of groundwater quality impacts greatly diminishes. 3.22.4.3 Mitigation Alternative Potential impacts to groundwater quantity and quality under the Mitigation Alternative would be similar to those described for the Proposed Action. Under this alternative, potential effects to groundwater from leaks and spills would be reduced because all chemicals, solvents, and fuels would be kept at least 150 feet away from streams and riparian areas and all refueling would occur at least 150 feet away from streams and riparian areas. Under this alternative, site- specific water quality data would be obtained prior to construction, during construction, and during operations as described above in Section 2.3.3. The data would provide information on groundwater elevations, constituent concentrations, and the natural variability in the water levels and quality. Monitoring would be conducted in accordance with the Sampling and Analysis Plan (see Section 2.3.3). Depending on monitoring results, operational revisions may be necessary.
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3.22.5 Current Conditions – Water Use and Water Rights Water use in the Project Area and surrounding area is relatively limited. There are few water rights on record with the WSEO for lands within the Forest. Most of the water rights are to the east of the Project Area.
Surface Water Use and Water Rights. The major uses of surface water in the Project Area relate to recreation, wildlife, and fish habitat. A major use downstream of the Project Area is irrigation of pastures and hayfields. The surface water rights in the South Cottonwood Creek and Bare Creek drainages are summarized in Table 3.22-5.
Table 3.22-5 Surface Water Rights 1 WR Priority Facility Stream Number Date Holder Name Uses Location Source Comments South Cottonwood Creek and Bare Creek Watershed (Upstream of Project Area) None Listed. South Cottonwood Creek and Bare Creek Watershed (Within Project Area)
Lower Soda T32N, P7522.0R Reservoir Forest Lake Fishing R115W, Soda Lake & CR 01/31/1973 FIS Capacity - Service Preserve Sec15 Creek CR07/427 18.78 acre-feet Reservoir SW1/4NW1/4
South Cottonwood Creek and Bare Creek Watershed (Downstream of Project Area and Upstream of Mickelson Creek Field) WY right is in T32N, R115W, Section 11, all others in T32N, R115, Sec 12 South Wyoming Cottonwood T32N, Water Creek R115W, Flow - 17 cfs P74.0F 06/27/1989 W Development Instream Sec11 2.9 miles long Commission Flow SW1/4SW1/4 Segment 1 P3993.0D 06/09/1902 G.W. Booker Booker Ditch IRR_SW 17.85 cfs Teepee Ditch South CR 06/09/1902 M. Mills Act Booker IRR_SW Cottonwood 4.42 cfs CC18/068 Creek Ditch T32N, R115W, Teepee Ditch CR Sec12 06/09/1902 C. Mills Act Booker IRR_SW 2.28 cfs CC18/069 SW1/4NE1/4 Ditch
CR 06/09/1902 W. Booker Booker Ditch IRR_SW 5.57 cfs CC20/077
1 WSEO records as of 1/7/2016. Includes all records except those designated as Cancelled, Expired, or Incomplete.
No surface water rights upstream of the Project Area were listed in the WSEO records. Within the Project Area, the Forest Service has a water right associated with Soda Lake, and the listed use for that right is fishing. Downstream of the Project Area and upstream of the Mickelson Creek Field (see Section 3.22.5), there are five water rights listed in the records. One of the rights is for 17 cfs of instream flow, and that right is held by the Wyoming Water Development Commission for about 3 miles of the creek in T32N, R115W, Section 11. The other rights are in T32N, R115W, Section 12, and these four rights are all associated with the Booker Ditch. The combined appropriation for these four rights is about 30 cfs.
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South Cottonwood Creek has been considered as a site for a water storage reservoir to meet future water needs. Studies have evaluated on-channel and off-channel sites, and the closest potential site to the Project Area would be in T32N, R115W, Section 12. At present, there is no indication that construction of a reservoir would occur (Sunrise Engineering et al., 2014)).
Groundwater Use and Water Rights. No water wells are known to occur within the Project Area, and the WSEO records do not indicate there are any water wells within the Project Area. Table 3.22-6 lists the water rights for wells and springs in the township in which the Project Area is located, T32N, R115W, and the surrounding townships.
True Oil has obtained a permit from the WSEO for a water well within the Project Area. A copy of that permit is included in Attachment B. The well would be used as the water supply during well drilling and as part of the water supply during well completion. The permitted well depth for the water well is 200 feet, which should be within the Frontier Formation (Section 3.5-1), and the permitted pumping rate is 30 gpm (≈ 0.067 cfs).
There is one existing water right for a well or spring in T32N, R115W, in which the Project Area is located. That right is listed as a well. However, the well depth is listed as only 2 feet, and it is described as a "spring box" which produces about 2 gpm piped to two water troughs. The water source is probably a spring in Section 34, to the south of the Project Area in the upper portion of the drainage to the South Fork of Bare Creek at an elevation of about 9,260 feet.
To the west of the Project Area, there are only eight water right locations for wells or springs listed in T31N through T33N, R116 W. All but one of these are registered to the Forest Service, and none of the wells are over 120 feet deep. The highest permitted pumping rate for any of the wells or springs is 25 gpm (≈ 0.056 cfs). In addition to being at least 5 miles from the Project Area, these wells are within the Overthrust Belt, on the west side of Wyoming Range, and probably on the west side of the Darby Thrust Fault (see Section 3.5.1).
In the townships to the south and north of the Project Area, T31N and T33N, R115W, respectively, there are only two water rights listed for a well or spring. Both of these are listed as wells but appear to be associated with springs.
To the east of the Project Area, in T31N through T33N, R114W, there are eighteen water rights listed for wells or springs. All but four of the rights are for wells, and none of the wells are over 130 feet deep. The highest permitted pumping rate for any of the wells or springs is 25 gpm. These rights on are on the east side of the Prospect Thrust Fault and within the Green River Basin (see Section 3.5.1).
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Table 3.22-6 Groundwater Rights
Total Static Quarter/ Flow(cfs)/ Total Water Priority Quarter Appropriation Depth Level Well or WR Number Date Holder Facility Name Uses Section Section (gpm) (feet) (feet) Spring? Comments Township 31 North, Range 114 West
W.T. Close, 1 1 P49590.0W 08/27/1979 Close #1 STK 06 NE /4SW /4 10 4 -4 Well M.D. W.T. Close, 1 1 P49591.0W 08/27/1979 Close #2 STK 06 NW /4NW /4 10 3 -4 Well M.D. Although listed as spring, also 1 1 lists stream P5485.0D 05/27/1903 W.E. Rowe Rowe Ditch IRR_SW 22 SW / 4 NE / 4 3.23 Spring source as Spring Creek (22-31-114).
Fredell Place DOM_GW; 1 1 P92697.0W 08/03/1993 C&W Davis 24 SE /4SE /4 10 80 28 Well (1) STK
G.M. Mickelson- 1 1 P25245.0P 12/31/1960 DOM_GW 29 NE /4SW /4 1 120 -1 Well Mickelson North Pieny #5 Township 31 North, Range 115 West
Forest Roaring Fork DOM_GW; 1 1 P195618.0W 04/25/2011 17 NE /4NW /4 5 2 0.5 Well Service Spring No. 1 STK Township 31 North, Range 116 West
Forest Corral Guard 1 1 P152117.0W 06/23/2003 DOM_GW 16 NW /4NW /4 7 70 Well Service Station Township 32 North, Range 114 West
High 1 1 P154376.0W 10/06/2003 Lonesome HLR #1 DOM_GW 11 SE /4NE /4 15 126 16 Well
Ranch Mickelson Mickelson- 1 1 P25241.0P 12/31/1930 Land & South DOM_GW 11 SE /4NE /4 5 100 30 Well
Livestock Co. Cottonwood #2 Mickelson Mickelson- 1 1 P25242.0P 12/31/1916 Land & South STK 11 SE /4NE /4 2 90 -1 Well
Livestock Co. Cottonwood #3
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Total Static Quarter/ Flow(cfs)/ Total Water Priority Quarter Appropriation Depth Level Well or WR Number Date Holder Facility Name Uses Section Section (gpm) (feet) (feet) Spring? Comments
Fear NGC-Beecher 1 1 P58935.0W 11/09/1981 STK 21 SE /4SE /4 5 5 -4 Well Ranches, Inc. Spring #1 1 1 P96673.0W 08/15/1994 C. Price Price Spring STK 28 NE /4SW /4 14 2 1 Well
Cottonwood Tin Cabin DOM_GW; 1 1 P106421.0W 06/26/1997 Capital Ltd. 30 NE /4SW /4 1.31 2 -4 Well Spring STK Part.
DOM_GW; 1 1 P102114.0W 04/18/1996 J. Malinski Jon #2 33 SW /4SW /4 12 63 22 Well STK Township 32 North, Range 115 West
Forest Forest Service 1 1 P88728.0W 06/29/1992 STK 34 SW /4NE /4 2 2 -4 Well Service #1 Township 32 North, Range 116 West
Forest North Marten 1 1 P72740.0W 06/12/1986 STK 21 SW /4SE /4 22 5 -4 Well Service Creek W D Township 33 North, Range 114 West
High Cottonwood 1 1 P97744.0W 11/07/1994 Lonesome Horse Pasutre STK 09 SW /4NW /4 5 8 0 Well
Ranches, Inc. Spring CR 1 1 Although listed 03/26/1952 E. Meeks Mariety Canal IRR_SW 15 NW /4SE /4 0 Spring CC64/405 as spring, also lists stream CR 03/26/1952 E. Meeks Mariety Canal IRR_SW 15 NW1/4SE1/4 0 Spring source as CC64/406 Spring Creek. Permit issued to True Oil, and after use of the well as Mickelson/True 1 1 water supply P137023.0W 08/07/2001 G. Mickelson DOM_GW 21 SE /4NW /4 25 110 15 Well Water Well for oil/gas well drilling, permit transferred to landowner Mickelson.
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Total Static Quarter/ Flow(cfs)/ Total Water Priority Quarter Appropriation Depth Level Well or WR Number Date Holder Facility Name Uses Section Section (gpm) (feet) (feet) Spring? Comments Cottonwood Guard Station P19397.0D Water Supply Forest 1 1 & CR 07/01/1940 System DOM_SW 30 SE / 4 SW / 4 0.01 Spring Service CC58/354 Pipeline - Unnamed Spring High DOM_GW; 1 1 P110701.0W 07/01/1998 Lonesome Jon #3 33 SW /4SE /4 20 60 20 Well STK Ranch Township 33 North, Range 115 West
Forest Nylander 1 1 P195619.0W 40658 STK 11 SE /4NE /4 5 1 0.5 Well Service Spring No. 1 Township 33 North, Range 116 West
1 1 P144944.0W 06/20/2002 R.A. Litchfield Litchfield #2 DOM_GW 11 SW /4SW /4 15 100 60 Well
Forest Forest Park 1 1 P106148.0W 06/11/1997 MIS 21 NW /4NE /4 5 120 43 Well Service Well No. 1
CR Forest Forest Park 1 1 06/11/1997 MIS 21 NW /4NE /4 5 Well UW10/535 Service Well No. 1 P34893.0D Forest Park Forest DOM_SW; 1 1 & CR CC 12/05/2011 Feedground 21 SW /4SW /4 0.01 Spring Service STO 92/287 Spring No. 1
Forest Buck Creek W 1 1 P72732.0W 06/12/1986 STK 22 SE /4NE /4 19 5 -4 Well Service D Forest South Twin 1 1 P72739.0W 06/12/1986 STK 35 NW /4NE /4 25 5 -4 Well Service Creek Spring
Source: WSEO records as of 1/7/2016. Includes all records except those designated as Cancelled, Expired, or Incomplete.
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3.22.6 Environmental Consequences – Water Use and Rights 3.22.6.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to water uses from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.22.6.2 Proposed Action No measurable impacts to the quantities of water available for surface water uses are anticipated. As discussed in Section 3.22.2, there are potential impacts to surface water quality, which could in turn, impact surface water uses. The primary concern is due to spills and leaks which could result in degradation of water quality, such that recreational and agricultural uses would be diminished or curtailed.
No impacts to groundwater uses are anticipated due to the lack of such uses in and near the Project Area and the limited potential impacts to the groundwater resources (Section 3.22.4). 3.22.6.3 Mitigation Alternative Potential impacts to water use and rights under the Mitigation Alternative are the same as those described for the Proposed Action.
3.23 WETLANDS AND RIPARIAN ZONES
3.23.1 Current Conditions Wetlands are subject to protection under federal law and Executive Order 11990, regardless of land ownership. The EPA and the U.S. Army Corps of Engineers use the following definition of wetland to administer the Clean Water Act’s Section 404 permit program for dredge and fill activities: those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs and similar areas (40 CFR § 230.3 and 33 CFR § 328.3).
Potential wetlands for proposed Well Pads 42-27 and 23-15 were field-evaluated by Hayden- Wing in 2011; no wetlands were located in areas proposed for ground disturbing activities (Hayden-Wing, 2011). Review of the NWI database also indicated that a palustrine scrub-shrub wetland is located approximately 250 feet southwest of the proposed expansion of Well Pad 42- 27 near South Fork Bare Creek. The NWI database identified a freshwater pond on existing Well Pad 13-16a; however, no pond is present at this existing well pad.
Riparian areas occur as narrow zones adjacent to drainages and wetland areas. Perennial systems that support riparian zones located within the Project Area include South Cottonwood Creek, Bare Creek, South Fork Bare Creek, and West Fork Bare Creek (see Map 3.22-2). A Level II R1/R4 fish and fish habitat inventory was conducted for Bare Creek, South Fork Bare Creek, West Fork Bare Creek, and South Cottonwood Creek including a description of riparian habitat on the left and right banks of each stream (Hayden-Wing, 2011) using riparian
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community codes included in Overton et al. (1997). Within the Project Area along Bare Creek and South Fork Bare Creek, riparian areas within 30 meters of the stream are dominated by riparian willow shrub canopy that is greater than 10 percent with a riparian grass, forb, and sedge community, and some areas with upland subalpine fir. Along South Cottonwood Creek near the confluence of Bare Creek, riparian areas are mostly represented by riparian sedges, grasses, and forbs with less than 10 percent shrub cover, but further downstream riparian areas begin to be dominated by more riparian willow and shrub cover greater than 10 percent (see Appendix IV in Hayden-Wing, 2011). Numerous active beaver dams (56 documented; Hayden- Wing, 2011) were observed in the streams during survey efforts in the Project Area and contribute to the riparian and stream conditions.
3.23.2 Environmental Consequences 3.23.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to wetland and riparian zones from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.23.2.2 Proposed Action No wetlands or riparian vegetation would be removed from the expansion of Well Pad 42-27 or construction of Well Pad 23-15 (see Table 3.19-6, above); no direct effects to wetlands or riparian vegetation are expected. No additional surface disturbance would be necessary to construct the water supply well on existing Well Pad 13-16a or place the temporary surface water line; however, the temporary water line would cross West Fork Bare Creek with willow- dominated riparian area (shrub-dominated wetland) approximately 225 feet in width. It would also cross an unnamed waterbody with fringe wetland near Well Pad 13-16a. The water supply line would be temporary, lasting only during the drilling and completion of each of the two wells. The temporary line would be monitored daily for leaks; however any effects to wetland riparian areas would be minimal because it would be fresh water.
Potential effects to riparian vegetation or wetlands within 500 feet of the Proposed Action could occur from introduction or spread of invasive weeds that may displace native riparian species, fugitive dust created during construction, and increase in sedimentation or change in hydrology. South Fork Bare Creek is approximately 170 feet from the edge of the proposed expansion of Well Pad 42-27 and the nearest willow-dominated riparian vegetation is 120 feet. Also, a scrub- shrub wetland is located 250 feet from proposed expansion of Well Pad 42-27. There are no wetlands or riparian areas in close proximity to proposed Well Pad 23-15; the closest wetland is 1,500 feet west of proposed disturbance near Soda Lake and closest riparian vegetation is 1,142 feet north of the proposed well pad adjacent to South Cottonwood Creek. Existing Well Pad 13-16a is located approximately 200 feet from South Cottonwood Creek riparian vegetation; existing BMPs would be adequate to prevent effects to willow-dominated riparian vegetation along South Cottonwood Creek.
HydroGeo, Inc. (Attachment E) analyzed potential impacts due to erosion and sediment transport for the proposed expansion of Well Pad 42-27 and construction of Well Pad 23-15; without BMPs; with implementation of BMPs included in well pad design (see Section 2.3.2) little, if any sediment would be transported to willow-dominated riparian areas and scrub-shrub
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wetland near Well Pad 42-27 and hydrological characteristics would not be expected to change. All material used for sediment barrier installations and seed mixes for reclamation would be certified weed-free, which would reduce the potential to introduce invasive weed species to the Project Area. Additionally, water applied to well pads during construction would reduce fugitive dust and potential effects to riparian and wetland vegetation. With implementation of the BMPs incorporation into the well pad design (see Section 2.3.2), little or no measurable effects to wetlands or riparian vegetation from the Proposed Action would be expected. 3.23.2.3 Mitigation Alternative Potential impacts to wetlands and riparian vegetation under the Mitigation Alternative would be similar but potentially less than those described for the Proposed Action. To further minimize the potential to transport or spread noxious weeds into the Project Area and compete with or degrade natural vegetation cover types, True Oil would implement the Forest Service (2004) weed management plan, and all vehicles and equipment used for construction, reclamation, and abandonment would be cleaned prior to entering and upon departure from the Project Area. Under this alternative, the water supply well would not be drilled and the temporary water line not used. Any potential temporary and minimal effects to wetlands/riparian area described above for the temporary water line would not occur.
3.24 WILDLIFE
3.24.1 Current Conditions Terrestrial Wildlife. Based on habitats present in the Project Area (see Table 3.19-1, above) and distribution of species (Orabona et al., 2012), a variety of species of amphibians, reptiles, and mammals could occupy habitats within the Project Area and vicinity. During surveys conducted for the Project, several wildlife species were documented including beaver (Caster canadensis), coyote (Canis latrans), elk (Cervus elaphus), moose (Alces alces), mule deer (Odocoileus hemionus), pronghorn (Antilocapra americana), least chipmunk (Tamias minimus), meadow vole (Microtus pennsylvanicus), red squirrel (Tamiasciurus hudsonicus), snowshoe hare, pocket gopher (Thomomys spp.), Wyoming ground squirrel (Spermophilus elegans), and tiger salamander (Ambystoma tigrinum; Hayden-Wing, 2011). Forest Service sensitive animal species are discussed above in Section 3.16. Four big game species that occur within the Project Area and along access roads – elk, mule deer, pronghorn, and moose – are MIS in the Forest identified as harvest species (Forest Service, 2015a). The Forest Plan also includes bighorn sheep as a harvest MIS but the Project Area does not coincide with any habitats occupied by bighorns; yearlong range used by bighorn sheep is 6.5 miles south of the Project Area. Trophy game species potentially present in the Project Area include mountain lion (Felis concolor) and black bear (Ursus americanus). The Project Area coincides with seasonal habitats used by mule deer (spring-summer-fall ranges), elk (spring-summer-fall and parturition ranges), and moose (spring-summer-fall ranges). Access to the site passes through pronghorn ranges (spring-summer-fall and crucial winter yearlong ranges), as well as spring and fall migration corridors, although there is no pronghorn use of the Project Area. The Project access partially coincides with mule deer spring- summer-fall and crucial winter ranges, elk spring-summer-fall ranges, and moose spring- summer-fall, parturition, and crucial winter ranges. Map 3.24-1 shows big games ranges and Map 3.24-2 shows big game migration routes in relation to the Project Area. These species are included in the Biological Evaluation for Sensitive Species and Management Indicator Species Report (Attachment D), and discussed further, below. Data summarized below were compiled from the WGFD Annual Big Game Herd Unit Reports from 1991 through 2014 and Annual Reports of Big Game.
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Map 3.24-1 Big Game Ranges
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Map 3.24-2 Big Game Migration Routes
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Elk within the Piney Herd Unit (the local population area) inhabit spring-summer-fall ranges and parturition ranges (used during calving) within the Project Area. Cow elk give birth between late May and mid-June although cows with calves may remain on parturition ranges for a time after birth, depending on habitat and weather conditions. The entire Project Area is used as spring- summer-fall range with the same vegetation composition as described above in Section 3.19, Vegetation. Elk migration routes cross access roads to the Project Area from U.S. Highway 189. Migration routes connect spring-summer-fall ranges with winter range and crucial winter range east of the Project Area and associated with the Bench Corral feedground, operated during winter by the WGFD. Data from elk collared on the Bench Corral feedground with GPS telemetry show migration corridors and areas of high use (stopover points) during spring- summer and fall-winter periods (Fralik, 2012). The data indicate high use areas for elk crossing the Cottonwood Road west of Ryegrass Junction to the Forest boundary during fall-winter movements but lower use during the spring-summer migration. Stopover points are key areas during migration that coincide with areas where plant phenology allows individuals to maximize energy intake (Sawyer and Kauffman, 2011). Available data indicate that elk movements do not pass through the Project Area. The most recent (2014) population estimate is 3,700 elk in the Piney Herd Unit. The modeled population indicates that the post-harvest population has been declining over the past decade, 2005 to 2014, while the total elk harvest has increased, mostly due to the increasing harvest of cows during that period. The hunting season structure with an emphasis on harvesting cow elk is an effort to reduce the post-season population to the management objective of 2,400 elk (Fralick, 2015a). Elk are sensitive to roads open to motorized use and tend to avoid roads (Rowland et al., 2004). Open roads reduce the amount of habitat used and available to elk, and negatively impact elk by increasing energy expenditure, stress levels, and make them more vulnerable to illegal harvest. Forest Service (2016) conducted a “habitat effectiveness” analysis to determine effects of roads on elk use of available foraging, breeding, security, and parturition habitat, which also included the Project Area. Results of the Forest Service analysis demonstrated that areas intended to benefit elk summer habitat and maintain moderate use were not negatively affected by roads open to travel in the Project Area (see Figure A-33 in Appendix A in the Draft Supplemental EIS for leasing– Forest Service, 2016a). Security areas are areas that big game retreat for safety when disturbance to their usual range is intensified and are characterized by vegetation structure (hiding cover), isolation, steep topography, and inaccessibility in the landscape (Forest Service, 2016). Guidelines developed by Hillis et al. (1991) were used by Forest Service (2016a) to calculate the amount of available secure elk habitat for the Draft Supplemental EIS for leasing, which also included the Project Area. The guidelines recommend that security areas consist of ≥ 250 acres of contiguous habitat consisting of forest blocks with similar canopy structure, are ≥ 0.5 mile from an open road, and comprise ≥ 30 percent of an analysis unit be used to evaluate security levels. Results from the Forest Service (2016) analysis indicate that security habitat in the Project Area fall below the 30 percent minimum habitat security guideline (see Figures A-36 and A-38 in Appendix A in the Draft Supplemental EIS for leasing – Forest Service, 2016a). Mule deer within the Wyoming Range Herd Unit inhabit spring-summer-fall ranges within the Project Area. The spring-summer-fall range within the Project Area has the same vegetation composition as described above in Section 3.19, Vegetation. Mule deer migration routes cross access roads to the Project Area connecting spring-summer-fall ranges with winter-yearlong range and crucial winter-yearlong range east of the Project Area. Access to the Project on Cottonwood-Ryegrass Road would pass through crucial winter range for almost 13 miles between U.S. Highway 189 and Ryegrass Junction. Similar to the stopover points during
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migrations, described above for elk, mule deer also utilize stopover sites (Fralick, 2015b) during migration to increase consumption of nutritious forage. However, available data suggests that mule deer movements do not pass through the Project Area. The most recent (2014) post-harvest population estimate is 34,200 mule deer in the Wyoming Range Herd Unit. The modeled population indicates that the post-harvest population has been relatively stable over the past decade, 2005 to 2014, averaging 33,720 mule deer. However, the current population is below the population objective for Wyoming Range mule deer herd of 50,000 deer. Fawn production was relatively low between 2008 and 2011, averaging 0.613 fawn per doe but recent fawn productivity had increased to 0.765 fawn per doe in the 2014 post- harvest population. Antlered-only hunting and the near absence of doe and fawn harvest has failed to produce the sustained population increase since the late 1990s (Fralick, 2015b). A couple of studies have been initiated by the Wyoming Cooperative Fish and Wildlife Research Unit (Coop Unit) and WGFD on deer within the Wyoming Range mule deer herd that are expected to provide better understanding of how habitat, nutrition, and predation influences population growth in the Wyoming Range Herd Unit (see Appendices A and B in Fralick, 2015b). Moose within the Sublette Herd Unit inhabit spring-summer-fall ranges within the Project Area. The spring-summer-fall range within the Project Area has the same vegetation composition as described above in Section 3.19, Vegetation. Moose migration routes parallel access roads to the Project Area connecting spring-summer-fall ranges with crucial winter-yearlong ranges and parturition ranges east of the Project Area. Access roads to the Project Area pass through crucial winter-yearlong range for about 4.5 miles west of U.S. Highway 189 and in the vicinity of North Cottonwood Creek near Ryegrass Junction. The current management objective is 1,500 moose within the 3,306 square-mile herd unit (Clause, 2015). Population estimates in 2013 identify approximately 1,400 moose in the Sublette Herd Unit, approximately 6.7 percent below the herd objective (Forest Service, 2016). However, trend counts conducted during mid-winter for 3 years (2011 to 2013) averaged 1,323 moose in the herd unit so the population is increasing (Forest Service, 2016). Calf production has been relatively consistent over the past ten years, 2005 to 2014 averaging 0.403 calf per cow but only 0.334 calf per cow were observed in 2014. Mortalities documented during spring affect female moose survival but cause(s) of the mortalities has not been determined. Factors such as habitat conditions, nutrition, disease, and/or predation may be limiting population growth in this herd unit (Clause, 2015). The parasitic carotid artery worm, Elaephora schneideri infected 52 percent of all hunter-harvested moose that were examined in the Sublette Herd Unit in 2009 (Henningsen et al., 2012). Severe cases of winter ticks (Dermacentor albipictus) may be adversely affecting moose in this herd unit, as well (Samuel et al., 2000). The Coop Unit and the WGFD conducted a study from 2010 through 2014 to evaluate survival and fecundity of female moose, rates of juvenile recruitment, and seasonal home ranges in the Hoback Basin, north of the Project Area. The study determined that most adult mortalities in this population occurred during the late spring when fat reserves were at their minimum, which could be attributed to poor summer foraging habitat conditions along the Wyoming Range front (Oates et al., 2014). Pronghorn within the Sublette Herd Unit inhabit spring-summer-fall ranges adjacent to but outside of the Project Area. The Project Area is out of occupied pronghorn habitat. Access to the Project Area passes entirely through spring-summer-fall range and crosses crucial winter- yearlong habitat farther south along U.S. Highway 189. However, pronghorn migration routes cross Cottonwood Ryegrass Road, linking spring-summer-fall range with the crucial winter- yearlong range: migration generally occurs in the spring from March through June and in the fall
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from October through December (Sawyer et al., 2005). Similar to the stopover points during migrations, described above for elk, pronghorn also utilize stopover sites (Seidler and Beckmann, 2012) that coincide with the Cottonwood Ryegrass Road. Available information indicates that pronghorn movements do not pass through the Project Area (see Figures A-53 through A-59 in Appendix A in the Draft Supplemental EIS for leasing– Forest Service, 2016a). The current (2014) pronghorn population is estimated at 31,300 but the current management objective is 48,000 pronghorn (Burke, 2015). The population declined after the winter of 2010 to 2011 due to high over-winter mortality. According to the current population model, there were an estimated 52,961 animals in the 2010 post-harvest population but only 29,075 pronghorn in 2011. The model indicates a gradual increase since 2011 to 31,280 animals in the 2014 post- harvest population (Burke, 2015). Fawn production in 2014 increased to 0.737 fawn per doe from 0.628 fawn per doe the year before, possibly due to increased precipitation during summer 2014 in the northern portion of the herd unit (Burke, 2015) which includes the vicinity of the Project Area. Fish Species. The Project Area is within the Cottonwood Creek 5th field watershed (HUC 1404010106) in the Upper Colorado River Basin. In addition to Colorado cutthroat trout (discussed above in Section 3.16, Forest Service Sensitive Animal Species), the WGFD fisheries database shows mountain whitefish (Prosopium williamsoni), mountain sucker (Catostomus platyrhynchus), flannelmouth sucker (Catostomus latipinnis), speckled dace (Rhinichthys osculus), and mottled sculpin (Cottus bairdii) as occurring within the Cottonwood Creek watershed. The fish species that potentially occur in perennial streams in the Project are known to spawn at several times during the year: mountain whitefish spawn in October, mountain suckers spawn in late spring and early summer, and mottled sculpins spawn between February and June (Baxter and Stone, 1995).
3.24.2 Environmental Consequences 3.24.2.1 No Action Alternative Under the No Action Alternative, the proposed well pads would not be expanded/constructed, gathering lines would not be installed, the water supply well would not be drilled, and two natural gas wells would not be drilled, completed, and operated. No Project-related impacts to wildlife from activities described below for the Proposed Action and other alternatives would occur. Forest Service management and currently permitted activities in the Project Area, and associated impacts, would continue. These would include activities and impacts associated with oil and gas development, pipelines, access roads, habitat management, agricultural irrigation, recreation, and grazing. 3.24.2.2 Proposed Action Terrestrial Species. Construction of the Proposed Action could directly or indirectly affect terrestrial wildlife species present in the Project Area through direct mortality, disturbance, removal and alteration of available habitat, and/or displacement. Impacts would generally be more substantial during critical seasons such as winter (big game) or the spring/summer breeding season (small mammals, reptiles, amphibians). Timing of the Proposed Project (July 1 through September 30) should minimize effects to wildlife species in the Project Area, and Project disturbances during long-term production would be minimal and are not likely to affect wildlife species. Project-related traffic and operation of heavy equipment during construction of the Proposed Action could result in wildlife mortalities, especially for species that are inconspicuous (lizards,
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snakes and small mammals), those with limited mobility, burrowing species (mice and voles), wildlife with behavioral activity patterns (i.e., nocturnal activity) making them vulnerable, and wildlife that may scavenge roadside carrion (Leedy, 1975; Bennett, 1991; Forman and Alexander, 1998). For example, it is possible that amphibians migrating from over-wintering habitat to breeding areas, or moving away from breeding areas after laying eggs could occur in the Proposed Action area, but timing of the Proposed Action (July 1 through September) would minimize potential effects because likely migrations would occur in the spring or fall. Potential effects to big game by vehicle collisions to and from the Project Area are expected to be minimal because construction (including drilling and completion) and long-term production would occur after July 1 through approximately September 30, which would be outside the use of big game crucial winter ranges and migration routes along access roads shown on Maps 3.24-1 and 3.24-2. Additional human access associated with the Project within wildlife habitats could increase poaching of wildlife (Comer, 1982). Noise and human presence associated with construction of the Proposed Action (drilling and completion) and vehicles accessing the Project Area could disturb and displace wildlife in the Project Area. Noise would be detected by wildlife if above ambient background levels, assumed to be 40 dB in a rural setting (non-wilderness- see EPA, 1974), although tree cover near the Proposed Action would dampen noise in nearby habitats. Vehicular traffic would be expected to affect mule deer, elk, moose, and pronghorn distributions within the Project Area for some distance away from the Proposed Action, including access roads (see Rost and Bailey, 1979; Easterly et al., 1991); similar reactions by other terrestrial species would be expected. Disturbance and/or displacement associated with Project construction and operation would be short-term and temporary because Project activities would occur from July 1 through September and noise would not be continuous. Night lighting would be required during drilling and could temporarily affect wildlife species in the Project Area. Night lighting has been shown to act as a barrier to bat movements (Kuijper et al., 2008) and reduce bat activity in the immediate vicinity (Stone et al., 2009). Night lighting could affect other nocturnally active mammals by disrupting foraging behaviors and increasing risks of predation, similar to the influence of different light intensities during lunar phases (Beier, 2006). Telemetered mountain lions avoided areas lit by artificial lighting during dispersal (Beier, 1995). Though evidence is limited, artificial night lighting may affect animal movements along corridors connecting habitat patches in the Project Area (Beier, 2006; Longcore and Rich, 2004).
Expansion of Well pad 42-27 and construction of reclaimed Well Pad 23-15 would affect 5.50 acres (see Table 3.19-6, above) of habitat potentially used by big game (spring-summer-fall range) and other terrestrial wildlife species. The Project is consistent with the Big Game Habitat Guideline for DFCs 1B and 10 which state “sufficient habitat should be provided to maintain desired populations and distribution of big-game species.” The Project would affect 5.50 acres of habitat and is not expected to alter desired populations and distribution of big-game species.
Removal of vegetation could reduce forage, reduce hiding cover and thermal shelter, and displace wildlife. However, potential effects to wildlife would be expected to be short-term and minimal because most wildlife habitat affected by the Proposed Action would be adjacent to existing disturbance (existing access roads and well pads) or within previously disturbed habitat, and habitat removed represents less than 0.1 percent of available wildlife habitat in the Project Area. Noxious weeds and fugitive dust could interfere with native vegetation species adjacent to proposed well pads, and many weeds are unpalatable to wildlife (Whitson et al., 1996). To minimize the potential to introduce invasive weed species to the Project Area, all material used for sediment barrier installations and seed mixes for reclamation would be certified weed-free.
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Water applied to unpaved roads and well pads during construction would reduce fugitive dust and potential effects to adjacent vegetation.
Fish Species. Creeks within the vicinity of the Proposed Action could provide suitable habitat for fish species that are known or potentially occur in the Project Area. If present, fish species could be affected by impacts to water quality through spills and leaks, as well as sedimentation from ground surfaces that could degrade occupied streams and affect adjacent riparian habitat or nearby wetlands. Sediment could smother fish spawning gravels and increase mortality of eggs and embryos, reduce the abundance of invertebrate prey and reduce quality of rearing habitat, and cause fish to avoid impacted stream reaches (Newcombe and Jensen, 1996). Under the Proposed Action, no riparian vegetation would be removed and no alteration of natural drainage channels would occur. Expansion of existing Well Pad 42-27 is within 170 feet of South Fork Bare Creek and construction and operation have the potential to route fine sediments to the nearby stream. As discussed above for Colorado cutthroat trout, these potential impacts would be prevented by implementation of True Oil’s SPCC Plan and SWPPP, and overall sedimentation control measures included as Project Design Features (see Section 2.3.2) such as the use of BMPs, conducting interim reclamation as soon as possible, and constructing diversion ditches to channel any sediment flow to sediment traps which would discharge to armored detention basins, dissipating flow energy. Additional and improved BMPs applied to the existing Well Pad 42-27 would further reduce potential impacts to water quality from transport of sediment or spills and leaks. 3.24.2.3 Mitigation Alternative Effects to big game and other terrestrial wildlife and fish species under the Mitigation Alternative would be similar to those described for the Proposed Action. However, to minimize the potential for collisions with big game and other wildlife species as well as reduce effects of fugitive dust on wildlife habitat adjacent to access roads, speed limits would be enforced and where not posted on unpaved access roads, speeds would not exceed levels considered safe for the conditions and would be slow enough to prevent collisions with wildlife and livestock. True Oil would implement “dark sky” lighting practices to reduce the effects of artificial light including use of low glare lighting equipment and directing or shielding lighting to reduce glare in adjacent habitat. Additionally, to further minimize the potential to transport or spread noxious weeds into the Project Area and degrade wildlife habitat, True Oil would implement the Forest Service (2004) weed management plan, and all vehicles and equipment used for construction, reclamation, and abandonment would be cleaned prior to entering and upon departure from the Project Area. True Oil would provide environmental awareness training to all employees to address consequences of poaching and provide information about federal and state wildlife laws.
Potential impacts to surface water quantity and quality would be potentially less than those described for the Proposed Action because all chemicals, solvents, and fuels would be kept at least 150 feet away from streams and riparian areas and all refueling would occur at least 150 feet away from streams and riparian areas. Further, monitoring of surface water would occur at seven locations including three locations along South Cottonwood Creek, two locations on South Fork Bare Creek, and one location on Soda Lake. Data collected would be used to establish baseline and report conditions in the event of a spill, leak, or other unanticipated condition. If necessary, construction or operations would be adjusted according to measures outlined in the Water Sampling and Analysis Plan.
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4.0 CHAPTER 4 - CUMULATIVE EFFECTS
4.1 INTRODUCTION
NEPA requires federal agencies to consider the cumulative effects of proposals under their review. Cumulative effects are defined in the CEQ regulations 40 CFR §1508.7 as “…the impact on the environment that results from the incremental impact of the action when added to other past, present, and reasonably foreseeable actions regardless of what agency…or person undertakes such other actions.” The CEQ states that the “cumulative effects analyses should be conducted on the scale of human communities, landscapes, watersheds, or airsheds” using the concept of “project impact zone” or more simply put, the area that might be affected by the Proposed Action.
The cumulative effects analysis typically encompasses broader areas and timeframes than the analysis of direct and indirect effects. The actions and effects selected for analysis depend on access to reasonably available data. The Lander Peak Project was considered in the cumulative analysis completed for the Draft Supplemental EIS for leasing and Final Supplemental EIS for leasing (Forest Service, 2016a and 2016b). This analysis is a subset of that analysis and is specific to the Lander Peak Project effects.
4.2 CUMULATIVE EFFECTS ANALYSIS AREAS
To analyze cumulative effects specific to each of the affected resources detailed in Chapter 3, four cumulative effects analysis areas (CEAAs) have been selected (Table 4.2-1). Common analysis areas have been used for different resources, where such usage is logically defensible. The four areas were selected to provide an appropriate scale in which effects could be reasonably analyzed rather than minimized (by increasing the size of the analysis area) or magnified (by reducing the size of the analysis area).
Table 4.2-1 Cumulative Effects Analysis Areas CEAA Resources Rationale The Lander Peak area was included Continental Divide-Creston Project in the modeling, analyses, and Air Quality assessments completed for the CD- (Map 4.2-1) C Project. Effects associated with these Sublette County Environmental Justice; resources occur where Socioeconomics; concentrations of people are (Map 1.1-1) Transportation/Access located, within the stream of commerce, and along roads. Cottonwood Creek, Muddy Creek, and North Piney Creek-Green River Fire and Fuels; Invasive, Non-native Potential effects of the Proposed watersheds Species; Migratory Birds; Special Action would not be likely to result in Areas and Designations; Threatened any issues to these resources (520,565 acres) & Endangered & Sensitive Animals & outside of this area. Plants; Water Resources; Wildlife (Map 4.2-2) Cultural Resources; Geologic Resources; Land Tenure, Rights-of- Cumulative impacts to these Project Area Way, and Other Uses; Mineral resources would be limited to the Resources; Paleontological Project Area because the effects (4,736 acres) Resources; Range Management; would not act in combination with Recreation; Soils; Tribal and Native similar effects outside the Project (Map 4.2-2) American Religious Concerns; Area. Vegetation; Visual Resources; Wastes; Wetlands & Riparian Zones
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Map 4.2-1 CD-C Project 4/12 km Domain
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Map 4.2-2 Cumulative Effects Analysis Areas
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4.3 PAST, PRESENT, REASONABLY FORESEEABLE ACTIONS
Generally, past and present activities (natural and man-made) that have affected and are affecting the Project Area and surrounding areas include:
• commercial timber harvest • oil and gas exploration and development; • rights-of-ways (power lines, pipelines, roads); • prescribed and natural wildland fire; • drought; • wildlife utilization; • vegetation treatments beyond commercial timber harvest; • stream restoration • climate change; • livestock grazing; • recreation (i.e., hunting, camping, fishing, firewood gathering, etc.); and • off-highway vehicle (OHV) use.
Reasonably foreseeable actions must have a high probability of occurrence and be defined well enough to be included in an analysis; therefore, considered actions are those for which the Forest Service has accepted permit applications. Table 4.3-1 describes specific past and present activities/projects, where details are known, as well as reasonably foreseeable actions that may occur within the CEAAs. It is assumed the effects of the past projects or activities listed are included as part of the existing condition in the affected environment.
4.4 CUMULATIVE EFFECTS TO INDIVIDUAL RESOURCES
4.4.1 Air Quality and Climate The Continental Divide-Creston (CD-C) Project Final EIS (BLM, 2016b) is used for addressing cumulative impacts for the Lander Peak Area Project cumulative air quality and AQRV assessment, including regional ozone formation. For the CD-C impact analysis, the CAMx (Comprehensive Air quality Model with Extensions; ENVIRON, 2010) photochemical grid model (PGM) was used to predict maximum potential regional-wide ambient air quality and AQRV impacts at federal PSD Class I and other sensitive PSD Class II areas, as well as designated acid-sensitive lakes. The CD-C Project analysis included a regional air quality assessment (including ozone) and AQRV analysis for southwest Wyoming including the region surrounding the Lander Peak Area Project. The analyses were performed using the CAMx model and two years of meteorological data, years 2005 and 2006. The CD-C analysis analyzed regional impacts for a base case year 2008 and for future year 2022.
The CD-C analysis included impact assessments at 12 PSD Class I and sensitive Class II areas, and at 19 sensitive lakes throughout the CD-C Project modeling domain, including Class I and sensitive Class II areas and sensitive lakes nearby the Lander Peak Area Project. The nearby Class I and sensitive Class II areas in the CD-C analysis are the Class I Bridger and Fitzpatrick Wilderness Areas, and Class II Popo Agie and Gros Ventre Wilderness Areas and Wind River Roadless Area. The nearby sensitive lakes included in the CD-C analysis are Black Joe, Deep Hobbs, Lazy Boy and Upper Frozen lakes in the Bridger Wilderness Area, Ross Lake in the Fitzpatrick Wilderness Area, and Lower Saddlebag Lake in the Popo Agie Wilderness Area.
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Table 4.3-1 Past, Present and Reasonably Foreseeable Activities/Projects Activity/Project Year Description Effects 3 mi temporary road. Maki Vegetation Project 2,300 ac Aspen Restoration Effects to lynx habitat within Cottonwood Creek LAU.~830 acres 2005-2008 273 ac Conifer Treatment – Timber Sale is Cut/Sold all timber would be burned and converted to unsuitable lynx habitat harvesting is complete for Maki Halverson Timber Sale 165 ac Regeneration harvest and salvage Located in the Cottonwood Creek LAU 2008-2012 All harvesting/timber removal is competed—Sale is closed ~ 165 acres converted to unsuitable lynx habitat South Cottonwood Timber Sale 200 ac Regen harvest and salvage – Timber Sale is Closed – All Located in the Cottonwood Creek LAU 2008-2013 timber/wood products have been removed. ~200 acres converted to unsuitable lynx habitat Located in Snyder Basin High severity fire, burned approximately 64,220 acres in the southern Wyoming Range (75% of the fire burned on NFS, 19% burned on BLM, 1% on state, 5% on private lands). Burn included approximately 4,640 acres, or 11.7% of the lands Fontenelle Fire Rehabilitation actions included: under review for leasing. 2012 On NFS lands, 28 miles of firelines were waterbarred and 3 miles High forest mortality, stand replacing of fireline seeded. On BLM lands, a total 1.5 miles of handline were rehabilitated and 3.5 miles of dozer line were rehabilitated and seeded. 2 3 mi temporary road Nylander Timber Sale 144 acres regeneration harvest and sanitation – Timber sale is Located in the Cottonwood Creek LAU 2012-2015 active – Sale anticipated to close in 2016. Brush disposal and ~144 acres converted to unsuitable lynx habitat Knutson-Vandenberg funded activities anticipated through 2021. Old Indian Trail Maki Creek Construct a small trail puncheon across Maki Creek on the Old Small-scale effects to streambanks in the immediate vicinity of the Crossing Project Indian Trail. stream crossing. 2015 1 mi relocation; 1 mi reconstruction; 13.8 mi temporary road. Cottonwood II Vegetation 2,099 acres; replace culvert on the 10050 Rd to restore a failing Effects to lynx habitat within Cottonwood Creek LAU~1,060 acres Management Project fish barrier on Bare Creek (2015). converted to unsuitable lynx habitat; ground disturbance in immediate 2007-present The ROD was signed in 2007 Cottonwood II EIS is the NEPA area to restore a failing fish barrier documentation. 0.3 mi temporary road 0.3 mile temporary road 109 acres thinning Bare Mt. 1 – activities Bare Mtn Post & Pole 1, 2 & 3 completed 2015; Bare Mt. 2 – harvest completed 2015, pile Located in the Cottonwood Creek LAU 2008-present burning in 2015-2016; Bare Mt. 3 – harvest anticipated through 2017; pile burning anticipated 2017-2018. Cottonwood Aspen Rx Burn Located in the Cottonwood Creek LAU 1,058 ac Prescribed burn 2008-present ~1.058 acres converted to unsuitable lynx habitat 3 mi temporary road Located in the Birch-South Beaver and South Beaver LAUs Fontenelle Fire Salvage 466 acres of fire killed timber harvesting. Multiple timber sales are Will affect up to 466 acres of fire killed timber through mechanical 2014-2018 active in the area – Sales will be active thru 2018 harvesting. No lynx habitat will be affected
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Activity/Project Year Description Effects South Cottonwood Creek Road and Trailhead Flood Damage Add stream and floodplain roughness and relocate South Localized disturbance in stream and floodplain Restoration Cottonwood Creek Trailhead 2016 Middle Piney Dam Reconstruction of the dam, and reconstruction of dam access Localized disturbance during reconstruction activities along access 2017 road road and dam. Drill, complete, produce, and eventually reclaim up to 31 new oil Exact placement of infrastructure is currently unknown; however, it LaBarge Platform Exploration and and gas wells on an estimated 18 new well pads. Estimated total appears that the direct disturbance would primarily take place in Development short term surface disturbance would be up to 120 acres and total Wyoming big sagebrush habitat. Only a portion of this project occurs (In Progress) long term surface disturbance would be up to 50 acres. Project within BLM shared LAUs – no portion of the project occurs within lifespan would be 40 to 50 years. UFSF LAUs. The primary direct impact would be disturbance to 496.9 acres of Development of injection wells for hydrogen sulfide, carbon Rand’s Butte Sour Gas Project Wyoming big sagebrush habitat, but a variety of other habitats would dioxide, natural gas, and helium with ancillary facilities. Surface (Denbury) be impacted to a lesser degree (including aspen, grassland, and disturbance would total up to 872 acres over the short term and (In Progress) other shrub land types). Project occurs within portions of the Birch- 54.6 acres over the long term (project life of 40 years). South Beaver BLM shared LAU Drill up to 238 natural gas wells on 159,928 acres of leases held These leases occur within sage-brush, aspen and conifer forest by ExxonMobil on FS and BLM lands. As of 2005, 26 wells have Riley Ridge Natural Gas Project habitat types on BLM and FS lands; 28,971 and 26,719 lease acres been approved and drilled (9 of which were drilled on USFS (In Progress, projects include: Lake occur on FS and BLM lands respectively, and within the LaBarge and lands). The approval to construct a new pad and drill additional Ridge, Fogerty) Birch-South Beaver LAUs. Existing wells have impacted some lynx wells on FS lands in the Birch-South Beaver LAU is currently habitat acres, but impacted acreages are not currently available. being planned. Oil and Gas Leasing Decision in The 2011 decision not to authorize leasing was withdrawn to allow Portions of the Wyoming Range -- The preferred alternative resulted in no leasing and, therefore, no further analysis. A new Final Supplemental EIS was issued in Supplemental Analysis effects. 2016. The new decision was issued in January 2017. (In Progress)
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The CD-C study analyzed both CD-C sources and maximum emissions from reasonably foreseeable development (RFD) sources within the large study area which encompassed the Lander Peak Project Area. The Lander Peak Area Project was not included in RFD because it was not yet proposed at the time of the study, however the cumulative emissions from other RFD projects included in the Upper Green River Basin likely provide an estimate of the maximum cumulative emissions that could occur within the region.
A listing of RFD projects and emissions which were included in the study is presented in Table 4.4-1. Map 4.2-1 indicates the locations of each of the RFD projects and illustrates the extents of CD-C modeling domain. Regional emissions inventories for all other source type categories were quantified for the entire study area shown on Map 4.2-1. Emissions of CO, NOx, SO2, PM10, and PM2.5, and VOC were inventoried for both the 2008 baseline year and for year 2022. A complete discussion of the emissions inventories included in the cumulative study is reported in Section 2 of the CD-C Project Air Quality Technical Support Document - AQTSD (BLM, 2016c).
Table 4.4-1 RFD Emissions within the CD-C Project Study Area Emissions (tpy) RFD Project Inventory Year NOx VOC CO SO2 PM10 PM2.5 CD-C - Proposed Action 2022 4,742 14,716 8,588 2 2,235 455 CD-C – Existing Wells 2022 1,757 42,249 1,852 2 449 153 Beaver Creek 2016 105 85 103 0 89 14 LaBarge Platform 2027 676 1,534 383 96 110 36 NPL 2022 472 310 623 10 968 145 Monell Arch 2021 253 276 220 8 33 17 Moneta Divide 2018 1,035 3,662 364 0 1,108 140 BLM Rock Springs Field Office 2031 998 3,318 2,369 1 516 93 BLM Little Snake Field Office - Alt B (Preferred) 2021 559 2,712 1,103 3 378 55 BLM Kremmling Field Office - Alt. C (Preferred) 2028 738 5,914 191 3 2,473 408 BLM White River Field Office 2021 3,320 8,564 7,054 20 1,037 198 BLM Colorado River Valley Field Office 2021 2,287 9,240 4,525 8 916 155 BLM Grand Junction Field Office - Alt B (Preferred) 2018 3,373 2,686 4,160 135 2,397 525 BLM Uncompahgre Field Office - Alt. D (Preferred) 2028 3,271 2,498 3,327 138 1,118 494 Bird Canyon 2020 658 641 481 5 250 64 Moxa Arch Existing Wells 2018 1,550 19,596 1,178 1 232 79 Moxa Arch Proposed Action New Wells 2018 1,186 1,647 1,776 0 583 124 Moxa Arch Proposed Action ROD Wells 2018 64 166 128 0 30 6 Hiawatha Existing Wells (CO &WY) 2017 318 4,136 352 0 41 9 Hiawatha Proposed Action New Wells (CO & WY) 2017 1,555 919 1,861 1 318 100 Pinedale * 1,381 2,286 1,250 53 53 79 Jonah Infill Drilling Project 2008 1,099 2,705 686 62 62 28 Total 31,397 129,860 42,574 548 15,396 3,377 *Based on the Pinedale Supplemental EIS Alternative C Phase II emissions levels. 4.4.1.1 Criteria Pollutants Impacts The CD-C cumulative modeling analysis estimated potential impacts to ambient air concentrations from air pollutant emissions of NOx, SO2, PM10, PM2.5, VOCs, and CO expected to result from RFD sources emissions and other cumulative (regional) emissions sources. The estimated impacts in the vicinity of the Lander Peak Area Project are discussed below. Regional Ozone Impacts. The CD-C analysis included estimates of future year regional ozone impacts using two analysis methods. One method uses the change in the PGM modeled concentrations between base case or current year (DVC) (year 2008) and future year (DVF) (year 2022) simulations to scale observed ozone concentrations from monitoring sites to obtain projected future year ozone concentrations. This method utilized EPA’s Modeled Attainment
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Test Software (MATS) (Abt Associates, 2012) projection tool with the CAMx 2008 Base Case and 2022 scenario ozone concentrations to estimate ozone impacts. The second method uses the absolute modeling results from the CAMx model to estimate ozone impacts. Two years of meteorology (2005 and 2006) were modeled with CAMx. The Project Area is located within the UGRB ozone nonattainment area. EPA has recently proposed to determine that this area attained the 2008 NAAQS by the applicable attainment date of July 20, 2015, based on complete, quality-assured and certified ozone monitoring data for 2012–2014 (EPA, 2015a). On October 1, 2015, the EPA lowered the ozone NAAQS from 75 ppb (established in 2008) to a more stringent value of 70 ppb (EPA, 2015b). The EPA expects to issue detailed guidance on the designation process in 2016, but has indicated that attainment designations for the 2015 NAAQS will be based on 2014-2016 data. State recommendations for designations of attainment and nonattainment areas are due to EPA by October 1, 2016 and EPA has a statutory obligation to finalize designations by October 1, 2017. Therefore, at the time of writing of this document, the attainment status of the Project Area and all Wyoming counties under the 2015 NAAQS is not yet known and the designations under the 2008 NAAQS remain in place.
The CAMx predicted current year DVCs indicate areas where ozone concentrations are near the NAAQS (70 ppb) in the vicinity of the Lander Peak Area Project in 2008 (68 to 71 ppb range) with the concentrations slightly decreasing in year 2022. The estimated ozone concentrations using absolute CAMx model results indicates ozone concentrations in the vicinity of the Lander Peak Area Project that are above the 70 ppb NAAQS for both the base year 2008 and future year 2022. The estimated absolute model ozone concentrations in the vicinity of the Project Area is in the 73 to 76 ppb range in both the base year 2008 and future year 2022 with concentrations decreasing slightly in 2022. The 2-year average of the absolute model ozone concentrations is in the 71 to 73 ppb range in the vicinity of the Project Area. A detailed discussion of the ozone analysis is provided in Section 4.5.4 of the CD-C AQTSD (BLM, 2016c).
The UGRB ozone non-attainment area was designed as a non-attainment area for ozone primarily as a result of high ozone episodes that occurred during the winter. Given that the Lander Peak Area Project would not operate during the winter, the project would not contribute to any regional wintertime ozone formation.
Regional NO2, SO2, CO, PM10, and PM2.5 Impacts. The results of the cumulative modeling showed that NO2, SO2, CO, PM10, and PM2.5 concentrations in the vicinity of the Lander Peak Area Project would be well below the applicable NAAQS and WAAQS. Additional detail on the modeling results are provided in Section 4.5.3 of the CD-C AQTSD (BLM, 2016c). 4.4.1.2 AQRV Impacts Visibility modeling indicated improved visibility in 2022 compared to the 2006 to 2010 baseline years at the nearby Class I and Class II areas for both the best and worst 20 percent days. Impacts from RFD sources on 2022 haze are estimated to vary between 0.01 dv and 0.16 dv among the nearby Class I and Class II areas. Deposition modeling estimated cumulative nitrogen (N) deposition impacts at all Class I and sensitive Class II areas near the Lander Peak Area Project would be above the critical load thresholds. Estimated sulfur (S) deposition impacts would be below the 5.0 kg/ha-yr threshold at all areas.
Modeling results for cumulative sources indicated that there would be no acid neutralizing capacity (ANC) changes at any of the seven nearby lakes that exceed the 10 percent threshold or the ΔANC<1 microequivalents per liter (µeq/L) threshold for the two extremely sensitive
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lakes. In addition, the cumulative assessment shows that N and S deposition into the sensitive lakes in 2022 would be lower than in 2008 due to regional emissions reductions. This potentially results in an increase in ANC of the sensitive lakes over this time frame, with the lakes becoming more resilient to acid deposition in future years than during the baseline period. 4.4.1.3 Climate Change Impacts As discussed in Section 3.2 above, the current scientific consensus is that anthropogenic emissions of GHGs are causing the global climate system to warm, and the amount of GHGs emitted globally will determine the magnitude of climate change throughout this century (NCA, 2014a). Forecasts of changes in the climate system under different GHG emissions scenarios are made with global climate models. In Wyoming, the number of hot days and warms nights is predicted to increase leading to “increased demand for water and energy and impacts on agricultural practices” (NCA, 2014b).
The GHGs to be emitted by the Lander Peak Area Project, and from other RFD projects in the study area, are CO2, CH4, and N20, all of which have atmospheric lifetimes on the order of years. Emissions of GHGs from any particular source become well-mixed throughout the global atmosphere. GHG emissions from all sources contribute to the global atmospheric burden of GHGs, and it is not possible to attribute a particular climate impact in any given region to GHG emissions from a particular source.
Wyoming Basin Ecoregional Assessment. In recognizing the need for additional information to support planning and decision making over large geographic areas, the BLM has recently developed a Landscape Approach which includes the Rapid Ecoregional Assessment (REA) program. The overall goals of the REA are to identify important ecosystems and wildlife habitats at broad spatial scales; identify where these resources are at risk from development, wildfire, invasive species, and climate change; quantify cumulative effects of anthropogenic stressors as required under NEPA; and assess current levels of risk to ecological resources across a range of spatial scales and jurisdictional boundaries by assessing all lands within an ecoregion. A Rapid Ecoregional Assessment has been developed for the Wyoming Basin (Carr and Melcher, 2015).
As part of the Wyoming Basin REA, a climate analysis was developed which included a reasonably foreseeable range of projected changes in temperature, precipitation, and hydroclimate variables for the Wyoming Basin. The “reasonably foreseeable” concept is modeled after the same concept for “reasonably foreseeable development scenarios” required for federal land use planning and is intended to reflect a range of potential future conditions due to natural variability and uncertainty in the global climate models. Key points from the Wyoming Basin REA climate analysis are excerpted here:
• Temperatures in the Wyoming Basin have warmed by almost 2ºF in the past 30 years, which is statistically significant. In contrast, precipitation does not show a statistically significant trend compared to precipitation variability of the recent past. • Based on the climate models evaluated for the REA, the Wyoming Basin is projected to warm by about 2.5ºF, with a modeled range of 1.5 to 3.5ºF by 2030. The projected increase in temperature is higher for the period ending in 2060, with an average increase of about 4.9ºF and a range from 2.7 to 4.9ºF. • Projections indicate an increase in the minimum temperatures of the coldest days, and an increase in the frequency and temperature of the hottest days. Projected temperatures for
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2060 indicate that summers may be as warm as or warmer than the hottest summers in the recent climate. • Climate projections do not show a dramatic change in annual average precipitation. Historical variability in precipitation is high. • Snow water equivalent on April 1 is projected to decrease by at least 20 percent or more by 2030 in many areas, although not in the higher mountains. Based on projections of earlier snowmelt and runoff, soil moisture has the potential to increase earlier in the spring and dry out earlier in the growing season. • Paleoclimate reconstructions of streamflow show considerable variability in records within the last 500 years, including years-to-decades of wetter or drier conditions in reconstructed streamflows. • The projected changes in temperature and shifts in precipitation and streamflow variables have implications for the Wyoming Basins ecosystems. These could include changes in elevation of climate zones, shifts in timing of peak streamflow, shifts in the seasonal pattern of soil moisture, and a longer growing season.
4.4.2 Cultural The CEAA for cultural resources is the Project Area. Project effects to cultural resources would not be anticipated; therefore cumulative effects would not be increased.
4.4.3 Environmental Justice The CEAA for environmental justice is Sublette County. Cumulative effects would not be expected because the Project would not result in disproportionately high and adverse human health or environmental effects on minority or low-income populations.
4.4.4 Fire and Fuels The CEAA for fire and fuels is the watershed boundaries. With implementation of the measures in the fire management plan, risks of ignition during Project activities would be avoided or minimized and cumulative effects would not occur or would be minimal. On-going effects would continue under the No Action Alternative.
4.4.5 Geologic Resources The CEAA for geologic resources is the Project Area and the area extending east to the surface expression of the Prospect Thrust Fault. Cumulative effects to geologic resources within the CEAA would be limited to True Oil’s existing development (four existing wells) and the Project effects (see Section 3.5.2) because True Oil holds the leases within that boundary and there are no other APDs.
4.4.6 Invasive, Non-native Species The CEAA for invasive, non-native species is the watershed boundaries. Project effects from the spread of invasive or non-native species would be avoided or minimized through implementation of the Forest Service (2004) weed management plan; therefore, no incremental increase in cumulative effects is expected to occur over what is already occurring. On-going effects would continue under the No Action Alternative.
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4.4.7 Land Tenure, Rights-of-Way and Other Uses The CEAA for land tenure is the Project Area. Project effects would not be anticipated; therefore, cumulative effects would not be increased.
4.4.8 Migratory Birds The CEAA for migratory birds is the watershed boundaries. Migratory birds are generally protected and/or avoided for any activities on public land. There are no specific data that quantify impacts to migratory birds as a result of grazing or recreation. However, impacts to migratory birds from recreation activities would include destruction of native vegetation or nesting areas from off road vehicles that traveled off of established roadways. Impacts to migratory birds from grazing include trampling and consumption of vegetation of nesting areas near streams or riparian areas. Impacts from wildland fire would include total destruction of the existing habitat and potential alteration of the habitat thereafter. Impacts to migratory birds and their habitat from the Project would be mainly the removal of vegetation and noise; when added to past, present and reasonably foreseeable projects, cumulative effects are expected to be minimal.
4.4.9 Mineral Resources The CEAA for mineral resources is the Project Area. Cumulative effects to mineral resources within the CEAA would be limited to True Oil’s existing development (four existing wells) and the Project effects (see Section 3.9.1).
4.4.10 Paleontological Resources The CEAA for paleontological resources is the Project Area. Project effects would not be anticipated; therefore, cumulative effects would not be expected.
4.4.11 Range Management The CEAA for range management is the Project Area. Cumulative effects, if any, would be minimal due to the Project’s low likelihood to affect the South Cottonwood Allotment. On-going effects would continue under the No Action Alternative.
4.4.12 Recreation The CEAA for recreation is the Project Area. Cumulative effects to recreational resources within the CEAA would be limited to the Project effects (see Section 3.12.2) because there are no other on-going projects or reasonably foreseeable projects within the CEAA. On-going effects would continue under the No Action Alternative.
4.4.13 Socioeconomics The CEAA for socioeconomics is Sublette County. Because the Project would not affect population and employment trends and may temporarily affect short-term housing accommodations and local tourism, cumulative effects within the County would be expected to be minimal.
4.4.14 Soils The CEAA for soils is the Project Area. Cumulative effects to soils (e.g., erosion, compaction) occur as a result of various natural (wildfire) and man-made factors (vegetation treatments, recreation). Although soils are generally negatively affected by these impacts, they have not resulted in any major or high intensity impacts to soil quality on a large spatial or temporal scale within the CEAA. The Proposed Project could result in additional impacts to soil resources;
222 Lander Peak Area Exploratory Proposal Environmental Assessment however, with implementation of Project Design Features such as adherence to the SWPPP and SPCC Plan, cumulative effects to soils would be minimal.
4.4.15 Special Areas and Designations The CEAA for special areas and designations is the watershed boundaries. Project effects would not be anticipated; therefore, cumulative effects would not be increased.
4.4.16 Threatened, Endangered, Proposed, Candidate, and Sensitive Animal Species The CEAA for threatened, endangered, proposed, candidate and sensitive animal species is the watershed boundaries. These species are generally protected and/or avoided for any activities on public lands but may not be protected for actions on private lands unless they are actually federally-listed or state-protected. Nearly all sensitive species would be affected by the past, present, and reasonably foreseeable actions (i.e., wildland fire, grazing, noxious weed proliferation, oil and gas exploration, dispersed recreation, etc.) unless effects were avoided or mitigated. Although the Project may affect sensitive species (see Section 3.16.2), it is not expected to cause a trend to federal listing or loss of viability; therefore, cumulative effects to these species would be minimal.
4.4.17 Threatened, Endangered, Proposed, Candidate, and Sensitive Plant Species The CEAA for threatened, endangered, proposed, candidate and sensitive plant species is the watershed boundaries. Project effects would not be expected although increased traffic could increase dust effects if sensitive plants were located along access roads; therefore, cumulative effects would not increase or would be minimal.
4.4.18 Transportation/Access The CEAA for transportation/access is Sublette County; however Project effects would be noticeable within a much smaller area along the rural routes accessing the Project Area. These noticeable effects would also last for a temporary timeframe. Given the short duration of Project effects, cumulative effects would be minimal. On-going effects would continue under the No Action Alternative.
4.4.19 Tribal and Native American Religious Concerns The CEAA for Tribal and Native American Religious Concerns is the Project Area. Project effects would not be anticipated; therefore cumulative effects would not be increased. On-going effects would continue under the No Action Alternative.
4.4.20 Vegetation The CEAA for vegetation is the Project Area. Cumulative effects that could impact vegetation within the CEAA include: wildland fire, dispersed recreation (i.e., hunting, camping, etc.), grazing, and increased invasive and noxious weed presence. These effects would continue under the No Action Alternative. With implementation of reclamation measures described in Section 2.3.2, cumulative impacts resulting from the Proposed Project would be minimal.
4.4.21 Visual Resources The CEAA for visual resources is the Project Area. Cumulative effects to visual resources within the CEAA would be limited to the Project effects (see Section 3.20.2) because there are no reasonably foreseeable activities within the CEAA.
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4.4.22 Wastes, Hazardous or Solid The CEAA potentially affected by Project-generated wastes is the Project Area. Through implementation of BMPs, including the SPCC Plan, Project effects would be avoided or minimized; therefore cumulative impacts would not be expected or would be minimal.
4.4.23 Water Resources The CEAA for water resources is the watershed boundaries. The Project would be expected to have a very small or no effect on surface water quantity or quality and groundwater quantity or quality; therefore, cumulative effects would not be increased or would be minimal.
4.4.24 Wetlands and Riparian Zones The CEAA for wetlands and riparian zones is the Project Area. Because the Project would not be expected to affect wetlands or riparian zones, cumulative effects would not be increased.
4.4.25 Wildlife The CEAA for wildlife is the watershed boundaries. Wildlife would be affected by the past, present, and reasonably foreseeable activities, such as: grazing, wildland fires, vegetation treatments, and recreation. Cumulative effects could include: reduction of suitable habitat/habitat fragmentation; animal displacement; decreased reproduction success; increased vehicle/wildlife collisions; and/or increased illegal harvest. However, because the timing of the Project would minimize effects to wildlife species, the cumulative effects to wildlife would be expected to be minor within the scope of the CEAA.
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5.0 CHAPTER 5 - CONSULTATION AND COORDINATION
5.1 AGENCY PARTICIPATION
The following agencies were consulted or otherwise participated in the EA process:
Wyoming Department of Environmental Quality Wyoming Game and Fish Department Wyoming State Engineers Office Sublette County
5.2 PREPARERS AND REVIEWERS
Forest Service Interdisciplinary Team NAME AREA OF RESPONSIBILITY Don Kranendonk District Ranger Anita DeLong Planning and Document Control Justin Snyder Geologic, Mineral, Soils, and Paleontological Resources Ronna Simon Water Resources, Wetland and Riparian Zones Rusty Kaiser TES Plants and Animals, Wildlife, Migratory Birds Randall Griebel Chad Hayward Invasive, Non-Native Species, Vegetation, Range Management Terry Svalberg Air Quality and Climate Jamie Schoen Cultural Resources, Native American Religious Concerns Paul Archual GIS Justin Snyder Wastes – Hazardous or Solid Travis Wetlzler Mary Greenwood Recreation, Special Areas and Designations Bernadette Barthelenghi Visual Resources
BLM Interdisciplinary Team NAME AREA OF RESPONSIBILITY Douglas Linn Document Review Larry Zuckerman Document Review Janet Bellis Air Quality and Climate, Water Resources Charis Tuers Air Quality and Climate
Edge Environmental, Inc. Name Resource/Responsibility Mary Bloomstran Project Manager, Document Control and Review Document Control and Review, Cultural Resources, Native American Carolyn Last Religious Concerns, Wastes – Hazardous or Solid Jim Zapert Air Quality and Climate Susan Connell Dan Duce Soils, Land Tenure, Rights-of-Way, and Other Uses Nikie Gagnon Roberta Hoy Geologic Resources, Mineral Resources, Water Resources Recreation, Range Management, Fire and Fuels, Special Areas and Josh Moro Designations, Visual Resources Archie Reeve Invasive, Non-Native Species, Vegetation, Wetlands and Riparian Rebecca Buseck Zones, TES Plants and Animals, Wildlife, Migratory Birds Sandra Goodman Socioeconomics, Transportation and Access, Environmental Justice Sue Ann Bilbey Paleontological Resources Joseph Thomas GIS
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6.0 CHAPTER 6 – REFERENCES
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Berg, N. D., E. M. Gese, J. R. Squires, and L. M. Aubry. 2012. Influence of forest structure on abundance of lynx prey species in western Wyoming. Journal of Wildlife Management 76(6):1480-1488. Bertram, T. and J. Claar. 2009. Horizontal Cover – Interim Guidance for Assessing Multi-storied Stands Within Lynx Habitat. Unpublished, Draft Report. U.S. Forest Service, Rocky Mountain Field Experiment Station, Missoula, Montana. Berven, J. 2014. Wyoming Range Northern Goshawk (Accipiter gentilis) Nest Search and Monitoring. Pages 149 to 184 in A.C. Orabona and N. Cudworth (editors). Threatened, Endangered, and Nongame Bird and Mammal Investigations Annual Completion Report. Wyoming Game and Fish Department, Cheyenne, Wyoming. Bilbey, S. 2016. President, Uinta Paleontological Associates, Inc. Email Communication with Edge Environmental, Inc. September 3. Bjornlie, D. 2014. Grizzly Bear Distribution in the Greater Yellowstone Ecosystem: 2014 Update. Wyoming Game and Fish Department, Lander, Wyoming. Bjornlie, D.D., D.J. Thompson, M.A. Haroldson, C.C. Schwartz, K.A. Gunther, S.L. Cain, D.B. Tyers, K.L. Frey, and B.C. Aber. 2014. Methods to Estimate Distribution and Range Extent of Grizzly Bears in the Greater Yellowstone Ecosystem. Wildlife Society Bulletin 38(1):182- 187. Bureau of Economic Analysis. 2014. Regional Economic Data – GDP and Personal Accounts. Table CA25N. November. Accessed online: www.bea.gov. Bureau of Labor Statistics. 2015a. Quarterly Census of Employment and Wages. Accessed online: www.bls.gov/cew. Bureau of Labor Statistics. 2015b. Local Area Unemployment Statistics. Accessed online: www.bls.gov/lau. Bureau of Land Management. 1983. Draft Environmental Impact Statement, Riley Ridge Natural Gas Project. Bureau of Land Management. 2008. Final Supplemental Environmental Impact Statement for the Pinedale Anticline Oil and Gas Exploration and Development Project, Sublette County, Wyoming. BLM Pinedale Field Office. Pinedale Wyoming, and Wyoming State Office. Cheyenne, Wyoming. Bureau of Land Management. 2014. Environmental Assessment - Huntington Valley Oil and Gas Exploration Project. DOI-BLM-E200-NV-2014-0003-EA. Accessed online: http://www.blm.gov/nv/st/en/fo/elko_field_office/blm_information/nepa/noble_energy_huntin gton.html. Bureau of Land Management. 2015. Land and Mineral Legacy Rehost System – LR2000. Case Recordation Reports. Accessed online: http://www.blm.gov/lr2000/index.htm. November. Bureau of Land Management. 2016a. Environmental Assessment, Jonah Year-Round Development Project, WY-100-EA16-36, U.S. Department of the Interior, Bureau of Land Management High Desert District - Pinedale Field Office, Wyoming, March 2016. Bureau of Land Management. 2016b. Final Environmental Impact Statement, Continental Divide-Creston Natural Gas Development Project, U.S. Department of the Interior, Bureau of Land Management High Desert District - Rawlins Field Office, Wyoming, April 2016. Bureau of Land Management. 2016c. Environmental Impact Statement, Continental Divide- Creston Natural Gas Development Project, Air Quality Technical Support Document, U.S.
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