DOI-BLM-CO-N040-2017-0093-EA.Jb

United States Department of the Interior Bureau of Land Management

Colorado River Valley Field Office 2300 River Frontage Road Silt, Colorado 81652 970-876-9000

Environmental Assessment DOI-BLM-CO-N040-2017-0093-EA

Proposed Balzac Gulch – Phase 1 Oil and Gas Master Development Plan Project

Terra Energy Partners Rocky Mountain LLC Federal Oil and Gas Lease COC27868 Federal Oil and Gas Lease COC62160 Federal Oil and Gas Lease COC62161 Federal Oil and Gas Lease COC73094

September 2017

It is the mission of the Bureau of Land Management to sustain the health, diversity, and productivity of the public lands for the use and enjoyment of present and future generations.

66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

TABLE OF CONTENTS

1. INTRODUCTION ...... 1 1.1. Project Location ...... 1 1.2. Issues and Concerns Identified during Public Scoping ...... 3 2. EXISTING DEVELOPMENT AND INFRASTRUCTURE ...... 3 2.1. Purpose and Need for the Action ...... 4 2.2. Summary of Lease Stipulations ...... 4 2.3. Plan Conformance Review ...... 5 2.4. Scoping ...... 5 2.5. Decision to be Made ...... 5 3. PROPOSED ACTION AND ALTERNATIVES ...... 6 3.1. Proposed Action ...... 6 3.2. No Action Alternative ...... 25 4. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ...... 25 4.1. Access and Transportation ...... 26 4.2. Air Quality ...... 28 4.3. Fossil Resources ...... 55 4.4. Geology and Minerals ...... 57 4.5. Invasive Nonnative Plants ...... 58 4.6. Lands with Wilderness Characteristics ...... 61 4.7. Native American Religious Concerns ...... 62 4.8. Noise ...... 63 4.9. Realty Authorizations ...... 66 4.10. Socioeconomics ...... 68 4.11. Soils ...... 71 4.12. Special Status Species ...... 74 4.13. Vegetation ...... 82 4.14. Visual Resources ...... 84 4.15. Wastes, Hazardous or Solid ...... 85 4.16. Water Resources – Surface Water and Groundwater ...... 87 4.17. Wildlife –Aquatic and Terrestrial ...... 98 5. CUMULATIVE IMPACTS ...... 103 5.1. Air Resources ...... 103 5.2. Existing Oil and Gas Developments ...... 111 5.3. Summary of Cumulative Impacts ...... 112 6. PERSONS AND AGENCIES CONSULTED ...... 114 7. INTERDISCIPLINARY REVIEW ...... 114 8. REFERENCES CITED ...... 114

APPENDIX

Surface-Use Conditions of Approval ...... COA-1 Downhole Conditions of Approval ...... COA-11 Right-of-Way Amendment Stipulations ...... ROW Stipulations-1

i 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

FIGURES

Figure 1. Balzac Gulch- Phase 1 Master Development Plan Overview Map ...... 2 Figure 2. Plan of Development for PA 22-25 Pad ...... 11 Figure 3. Plan of Development for PA 23-25 Frac Pad ...... 12 Figure 4. Plan of Development for PA 23-26 Pad ...... 13 Figure 5. Plan of Development for PA 23-26 Tank Pad ...... 14 Figure 6. Plan of Development for Cuttings Storage at DOE 1-W-26 Pad ...... 15 Figure 7. Plan of Development for RWF 13-19 Pad ...... 17 Figure 8. Plan of Development for RWF 23-19 Pad ...... 18 Figure 9. Wind Rose, Rifle, Colorado, 2012 to 2016 ...... 30 Figure 10. Nearby PSD Class I and Sensitive Class II Areas ...... 35 Figure 11. Predicted Ozone Concentrations of the CARMMS 2021 Low Development Scenario ...... 105 Figure 12. Fourth Highest Daily Maximum 8-hour Ozone Concentrations ...... 106

TABLES

Table 1. Existing Development within the Balzac Gulch - Phase 1 MDP Project Area ...... 3 Table 2. Project Components and Applicable Lease Stipulations ...... 4 Table 3. Surface and Bottomhole Locations of Proposed Federal Wells ...... 6 Table 4. Proposed Balzac Gulch Developments and Drilling Schedule ...... 8 Table 5. Proposed BLM Rights-of-Way for Balzac Gulch - Phase 1 MDP Project Area...... 9 Table 6. Proposed Disturbance for Project Components ...... 20 Table 7. Traffic Associated with Directional Drilling and Completion Activities ...... 27 Table 8. Mean Monthly Temperature Ranges and Total Precipitation ...... 29 Table 9. Wind Direction Frequency Distribution, Rifle, Colorado, 2012 to 2016 ...... 29 Table 10. Wind Speed Distribution, Rifle, Colorado, 2012 to 2016 ...... 30 Table 11. Ambient Air Quality Standards ...... 32 Table 12. Acute (1-Hour Exposure) RELs ...... 33 Table 13. Non-Carcinogenic Air Toxics Annual Average RfCs ...... 33 Table 14. PSD Class I and Class II Increments ...... 34 Table 15. Background Ambient Air Quality Concentrations ...... 42 Table 16. Gothic Site N and S Deposition Values, 2006 to 2015 ...... 43 Table 17. Background ANC Values for Acid Sensitive Lakes ...... 43 Table 18. Construction Emissions ...... 46 Table 19. Annual Production Emissions ...... 47 Table 20. GHG Emissions ...... 47 Table 21. Maximum Modeled Pollutant Concentrations from Well Construction Activities ...... 48 Table 22. Maximum Modeled Pollutant Concentrations from Well Production Activities ...... 48 Table 23. Maximum Modeled 1-Hour HAP Concentration Impacts ...... 49 Table 24. Maximum Modeled Annual HAP Concentration Impacts ...... 50 Table 25. Long-term Modeled MLE and MEI Cancer Risk Analyses...... 50 Table 26. Maximum Modeled Pollutant Concentrations at PSD Class I and Sensitive Class II Areas ..... 51 Table 27. Maximum Visibility Impacts at Class I and Sensitive Class II Areas ...... 52 Table 28. Geologic Formations within the Project Area...... 57 Table 29. Noxious Weed Observations within the Project Area...... 59 Table 30. COGCC Maximum Permissible Noise Levels...... 64 Table 31. Noise Levels at Typical Construction Sites and along Access Roads ...... 65 Table 32. Existing Realty Authorizations within T6S, R94W, Section 19, 6th P.M...... 66 Table 33. Existing Realty Authorizations within T6S, R94W, Sections 25-27, 6th P.M...... 67 ii 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Table 34. Top Industry Sectors of Garfield County, Second Quarter 2016 ...... 69 Table 35. Soil Description of the Balzac Gulch - Phase 1 Development Area ...... 71 Table 36. Potential for Occurrence of Threatened or Endangered Plant Species ...... 74 Table 37. Potential for Occurrence of Threatened or Endangered Animal Species...... 76 Table 38. BLM Sensitive Vertebrate Species Present or Potentially Present in the Project Area ...... 79 Table 39. Water Quality of the Colorado River at Rulison, 1977 to 1978...... 89 Table 40. Constituents of Typical Hydraulic Fracturing Operations in Tight Gas Formations ...... 97 Table 41. Oil and Gas Emissions from the Eight Western Colorado BLM Planning Areas for the CARMMS 2021 Low Development Scenario ...... 104 Table 42. Modeled Cumulative Pollutant Concentrations (CARMMS 2021 Low Development Scenario) at Class I and Sensitive Class II Areas ...... 108 Table 43. Cumulative Visibility Results for W20 Percent Visibility Days at Class I Areas for the 2008 Base Year and 2021 Low Development Scenario from RFD Sources ...... 109 Table 44. Cumulative Visibility Results for B20 Percent Visibility Days at Class I Areas for the 2008 Base Year and 2021 Low Development Scenario from RFD Sources ...... 109 Table 45. Cumulative RFD Nitrogen and Sulfur Deposition Impacts (CARMMS 2021 Low Development Scenario) at Class I and Sensitive Class II Areas ...... 110 Table 46. Cumulative RFD Impacts on Lakes (CARMMS 2021 Low Development Scenario) within the Class I and Sensitive Class II Areas ...... 110 Table 47. BLM Interdisciplinary Team Authors and Reviewers ...... 114

iii

Left blank for two-sided copying.

66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

1. INTRODUCTION

NUMBER: DOI-BLM-CO-N040-2017-0093-EA

APPLICANTS: Authorizations for Applications for Permit to Drill (APDs): Terra Energy Partners (TEP) Rocky Mountain LLC (“Terra”) formerly known as WPX Energy Rocky Mountain LLC (“WPX”). Contact: Adam Tankersley, 1085 CR 215, Parachute, CO 81635.

Authorization for Natural Gas and Produced Water Pipeline Rights-of-Way (ROWs): Terra Energy Partners Rocky Mountain LLC (“Terra”). Contact: Bryan Hotard, 1085 CR 215, Parachute, CO 81635.

PROJECT NAME: Balzac Gulch – Phase 1 Master Development Plan.

The Balzac Gulch Master Development Plan (BGMDP) is an oil and gas exploration and development program proposed by TEP Rocky Mountain LLC (Terra) over an approximate 1-2 year period. The proposed BGMDP project area is located 9 miles west of Rifle, Colorado and immediately north of Rulison, Colorado on the north side of I-70 in central Garfield County, Colorado (Figure 1).

The BGMDP involves 66 new Federal wells to be drilled and developed with target bottomholes in two Federal leases: COC62161, which is an existing lease held by production from existing wells and COC73094, an undeveloped lease analyzed in the Record of Decision and approved Resource Management Plan Amendment for the Bureau of Land Management’s (BLM's) Roan Plateau Planning Area (decision dated November 14, 2016). Existing well pads would be expanded and used to develop these 66 Federal directional wells. The new wells proposed within Federal lease COC73094 would be drilled from outside the lease boundary.

Terra proposes drilling, completing, and operating 66 Federal directional wells by expanding three existing well pads (RWF 13-19 and PA 23-26 pads located on BLM land and PA 22-25 pad located on private land) and using and upgrading existing access roads and pipeline infrastructure. Terra also proposes expanding the Federal-surface RWF 23-19 pad to serve as a frac pad for development of the RWF 13-19 wells and constructing the private-surface PA 23-25 ancillary frac pad to remotely support well completion work on the PA 22-25 and PA 23-26 wells. Figure 1 shows the location of leases, well pads, roads, and pipelines proposed for development.

The BGMDP is intended to describe a future development strategy given current market conditions and constraints. Implementation of the initial phase of the BGMDP could produce 120 billion cubic feet (bcf) of natural gas over the life of the project, estimated to be 40 years. This MDP is the first phase of a potential two-phase development with a projected total of 165 wells. The potential future development in Phase 2 of the BGMDP would be would be analyzed in a subsequent EA when project details and uncertainties are more fully resolved.

1.1. PROJECT LOCATION

The BGMDP project area encompasses roughly 2,917 acres of Federal and private lands. Surface ownership within the BGMDP project area involves four Federal leases on BLM-administered lands (2,648 acres) and fee leases underlying private lands (269 acres)(Figure 1). All existing access routes to the proposed pads originate from I-70 frontage roads and cross private field development roads; public access is not available to the sites within the project area.

1 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 1. Balzac Gulch- Phase 1 Master Development Plan Overview Map

2 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The legal description for the BGMDP project area covers the following lands, both Federal and private:

Township 6 South, Range 94 West, Section 19, Lots 5-8, 13-16 Township 6 South, Range 95 West, Sections 13, E½, E½W½, Lots 1-4; Section 23, NE¼SW¼, N½SE¼, SE¼NE¼, Lots 1-10; Section 24, NE¼, E½NW¼, SW¼NW¼, N½S½, Lots 1-5; Section 25, NW¼, N½SW¼, W½NE¼, NE¼NE¼; and Section 26 in its entirety, 6th Principal Meridian, Garfield County, Colorado

1.2. ISSUES AND CONCERNS IDENTIFIED DURING PUBLIC SCOPING

Eight various comments were submitted via letter or email from Colorado Parks and Wildlife, Garfield County, Chambers of Commerce, Rifle and Grand Junction, and others generally supporting the Proposed Action. Specific recommendations encouraged the use of best management practices and compensatory mitigation, inclusion of socioeconomic data supporting lease development and generation of tax revenues, and recognition of Terra’s use of existing roads, pads, and pipelines to support and implement the development plan.

2. EXISTING DEVELOPMENT AND INFRASTRUCTURE

Terra currently manages 11 pad locations within the BGMDP project area that support 79 producing wells (34 Federal wells and 45 Fee wells)(Table 1).

Table 1. Existing Development within the Balzac Gulch - Phase 1 MDP Project Area

Existing Pad NEPA Document Wells Drilled Construction Surface Well Pad Disturbance Prepared for Initial as of 2017 Date Ownership (acres) Development (Federal/Fee) W 29-26 September 1987 2.82 Fee N/A 0/2 DOE 1-W-26 August 1989 2.00 Federal CO-140-2005-047-EA 4/0 PA 24-26 June 2002 2.21 Fee N/A 0/1 PA 324-26 June 2002 3.30 Fee CO-140-2001-048-EA 4/7 CO-N040-2013-0025- PA 23-26 August 2002 2.24 Federal 3/0 EA RWF 23-19 July 2004 2.69 Federal CO-140-2001-048-EA 4/0 RWF 13-19 September 2004 2.55 Federal CO-140-2001-048-EA 6/0 CO-140-2004-0033 RWF 324-19 April 2005 2.19 Federal 3/0 DNA RWF 12-19 September 2005 3.22 Federal CO-140-2001-048-EA 6/0 PA 41-25 July 2007 5.12 Fee CO-140-2006-139-EA 4/18 PA 22-25 January 2008 5.52 Fee N/A 0/17 Note: Pads shown in bold are existing pads being re-occupied for use in Balzac Gulch – Phase 1 MDP EA = Previous EA approved for the locations proposed for expansion in the BGMDP. N/A = not applicable – private wells drilled from private surface.

Five of these 11 existing pads (shown in BOLD) are integral components of the Proposed Action, providing the development of 53 new directional wells in Federal lease COC73094 and 13 new directional wells in COC62161. While the DOE 1-W-26 pad would solely be used to store drill cuttings 3

3 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

developed from the PA 23-26 wells, the remaining four existing pads in the BGMDP would be expanded to accommodate drilling and/or completing of the new wells.

The inclusion of all existing well sites in the project area indicates the amount of historical development that has occurred and provides a baseline for the cumulative impacts to be analyzed in the Environmental Assessment (EA).

2.1. PURPOSE AND NEED FOR THE ACTION

The purpose of the Proposed Action is to develop oil and gas resources on Federal Leases COC62161 and COC73094 consistent with existing Federal lease rights. The action is needed to increase the development of oil and gas resources for commercial marketing to the public.

2.2. SUMMARY OF LEASE STIPULATIONS

Table 2 lists each well pad or project component and the applicable lease stipulations that pertain to the proposed operations on that lease. Figure 1 illustrates the lease boundaries. The proposed development of Federal lease COC73094 was specifically analyzed in BLM’s Record of Decision (ROD) and approved Resource Management Plan Amendment for BLM's Roan Plateau Planning Area (decision dated November 14, 2016), including the adoption of the Settlement Agreement (described in Appendix I of the ROD) and specific Base Lease language (Exhibit 3 of the ROD) requiring the operator's consultation with Colorado Parks and Wildlife and BLM to develop terms that minimize impacts to wildlife and other resources (BLM 2016a).

Table 2. Project Components and Applicable Lease Stipulations Surface Legal Well Pad/Location Ownership/ Federal Lease Stipulations Description Lease PA 22-25 Pad plus T6S, R95W Private Private lease - no Federal lease involvement PA 23-25 Frac Pad Section 25 NSO for steep slopes (>50%) Controlled Surface Use (CSU) for erosive soils Surface Frac Lines T6S, R95W Federal CSU for Visual Resource Management (VRM) between PA 23-25 Frac Sections 25 and COC73094 Class II Area Pad and PA 23-26 Pad 26 Timing Limitation (TL) for big game winter habitat (12/1 to 4/30) PA 23-26 Pad PA 23-26 Tank Farm NSO for steep slopes (>50%) PA 23-26 Gas/Water Federal T6S, R95W CSU for erosive soils Pipeline COC62161 Section 26 CSU for VRM Class II Area DOE 1-W-26 Cuttings TL for big game winter habitat (12/1 to 4/30) Storage RWF 13-19 Pad NSO for steep slopes (>50%) Federal T6S, R94W including CSU for erosive soils COC62160 Section 19 RWF 23-19 Frac Pad TL for big game winter habitat (12/1 to 4/30) RWF 13-19 Gas Federal T6S, R94W TL for big game winter habitat (1/1 to 5/31) Pipeline COC27868 Section 19 TL for Raptor Protection

It is important to note that for actions approved under BLM right-of-way grants, stipulations listed in the underlying oil and gas lease are not applied. Instead, stipulations for the proposed ROWs (listed in Appendix) are developed from decisions outlined in Colorado River Valley Field Office (CRVFO) 4

4 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Record of Decision and Approved Resource Management Plan (ROD/RMP), approved on June 12, 2015. As such, the standard big game winter timing limitation placed on the BLM right-of-way grants would be enforced from December 1 through April 30.

2.3. PLAN CONFORMANCE REVIEW

The Proposed Action is subject to, has been reviewed for, and is in conformance with (43 CFR §1610.5 and § 2800, BLM 1617.3) the following plan:

Land Use Plan (LUP) Name: The current land use plan is the Colorado River Valley Field Office (CRVFO) Record of Decision and Approved Resource Management Plan (ROD/ARMP), approved June 12, 2015

Decision Language: Page 106, LRT-GOAL-01, LRT-OBJ-01 – “Provide for the development of transportation systems, utilities, communication sites, and renewable energy resources when such needs are consistent with other resource values.”

Page 111, Oil and Lands and Realty, MIN-OBJ-01 – “Facilitate orderly, economic, and environmentally sound exploration and development of oil and gas resources…using the best available technology.”

Determination: The Proposed Action is in conformance with the LUP cited above because (1) the development of the gas and water gathering pipelines authorized to Terra under various BLM ROWs would provide for reliable and safe transportation of natural gas and produced water, and (2) the issuance of APDs and site ROWs to Terra on the Federal well pads would facilitate the development of the Federal fluid mineral leases.

2.4. SCOPING

NEPA regulations (40 CFR §1500-1508) require that the BLM use a scoping process to identify potential significant issues in preparation for impact analysis. The principal goals of scoping are to allow public participation to identify issues, concerns, and potential impacts that require detailed analysis. The BLM placed information regarding the BGMDP project on its public website on June 8, 2017, for a 30-day public scoping review with a comment deadline scheduled for July 10, 2017. A news release was issued to local media outlets and public notice for the project scoping was filed in the Glenwood Springs Post Independent.

2.5. DECISION TO BE MADE

The primary decision by the BLM upon completion of this EA is (1) whether to authorize the development, operation, and production of 66 Federal wells by Terra into underlying Federal mineral leases, including the development of ancillary roads, pipelines and production equipment; (2) whether to authorize the proposed water lines and gas gathering pipeline upgrades across BLM in Sections 19, 26 and 27 to Terra; and (3) whether to authorize a temporary use permit for surface frac lines proposed across BLM land in Sections 25 and 26 to Terra.

Based on the information presented and analyzed in this EA, the BLM may choose to (a) authorize the project as proposed; (b) authorize the project with modifications developed by the BLM in collaboration with the proponent; or (c) not authorize the project at this time. Options (a) and (b) would include the use of Conditions of Approval (COAs) as mitigation to avoid, minimize, or offset adverse project impacts.

5 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The Decision Record associated with this EA may not constitute the final approval for all actions, such as the issuance of APDs or the approval of ROW grants or temporary use permits associated with the Proposed Action. It does provide the BLM with an analysis from which to base the final approval, if warranted, for individual project components.

3. PROPOSED ACTION AND ALTERNATIVES

3.1. PROPOSED ACTION

The Proposed Action is to drill, complete, produce, and operate 53 new directional oil and gas wells into the nearby Federal lease COC73094 and 13 new directional oil and gas wells into Federal lease COC62161 from two existing, but expanded BLM pads (RWF 13-19 pad in Section 19 and PA 23-26 pad in Section 26), and one existing, but expanded Fee pad (PA 22-25 pad in Section 25)(Figure 1 and Table 3). Success of the proposed development, including any advancement of a second phase, would depend largely on factors out of Terra’s control, such as geologic findings, economics, and viability of commodity markets. Only Federal directional wells are proposed for development in the BGMDP.

Table 3. Surface and Bottomhole Locations of Proposed Federal Wells

Pad Name Lease Well Name Surface Location Bottomhole Location PA 534-24 SWSE Sec. 24 T6S R95W PA 414-24 SWSW Sec. 24 T6S R95W PA 514-24 SWSW Sec. 24 T6S R95W PA 424-24 SESW Sec. 24 T6S R95W PA 524-24 SESW Sec. 24 T6S R95W PA 11-25 NWNW Sec. 25 T6S R95W PA 511-25 NWNW Sec. 25 T6S R95W PA 21-25 NENW Sec. 25 T6S R95W PA 321-25 NENW Sec. 25 T6S R95W PA 421-25 NENW Sec. 25 T6S R95W PA 521-25 NENW Sec. 25 T6S R95W PA 22-25 Pad PA 311-25 NWNW Sec. 25 T6S R95W 25 wells Fee Lease PA 411-25 SENW Sec. 25 T6S R95W NWNW Sec. 25 T6S R95W (Fee surface / PA 541-26 NENE Sec. 26 T6S R95W existing pad) PA 441-26 NENE Sec. 26 T6S R95W PA 543-26 NESE Sec. 26 T6S R95W PA 41-26 NENE Sec. 26 T6S R95W PA 341-26 NENE Sec. 26 T6S R95W PA 342-26 SENE Sec. 26 T6S R95W PA 442-26 SENE Sec. 26 T6S R95W PA 542-26 SENE Sec. 26 T6S R95W PA 43-26 NESE Sec. 26 T6S R95W PA 343-26 NESE Sec. 26 T6S R95W PA 42-26 SENE Sec. 26 T6S R95W PA 443-26 NESE Sec. 26 T6S R95W PA 312-26 SWNW Sec. 26 T6S R95W PA 512-26 SWNW Sec. 26 T6S R95W PA 23-26 Pad PA 422-26 SENW Sec. 26 T6S R95W 27 wells COC62161 PA 522-26 NESW Sec. 26 T6S R95W SENW Sec. 26 T6S R95W (BLM surface / PA 11-26 NWNW Sec. 26 T6S R95W existing pad) PA 612-26 NWNW Sec. 26 T6S R95W PA 311-26 NWNW Sec. 26 T6S R95W 6

6 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Pad Name Lease Well Name Surface Location Bottomhole Location PA 412-26 SWNW Sec. 26 T6S R95W PA 12-26 SWNW Sec. 26 T6S R95W PA 411-26 NWNW Sec. 26 T6S R95W PA 321-26 NENW Sec. 26 T6S R95W PA 421-26 NENW Sec. 26 T6S R95W PA 521-26 NENW Sec. 26 T6S R95W PA 331-26 NWNE Sec. 26 T6S R95W PA 431-26 NWNE Sec. 26 T6S R95W PA 531-26 NWNE Sec. 26 T6S R95W PA 32-26 SWNE Sec. 26 T6S R95W PA 332-26 SWNE Sec. 26 T6S R95W PA 432-26 SWNE Sec. 26 T6S R95W PA 33-26 NWSE Sec. 26 T6S R95W COC73094 PA 333-26 NWSE Sec. 26 T6S R95W PA 433-26 NWSE Sec. 26 T6S R95W PA 533-26 NWSE Sec. 26 T6S R95W PA 34-26 NWSE Sec. 26 T6S R95W PA 534-26 SWSE Sec. 26 T6S R95W PA 334-26 SWSE Sec. 26 T6S R95W PA 532-26 SWNE Sec. 26 T6S R95W PA 423-24 NESW Sec. 24 T6S R95W PA 523-24 NESW Sec. 24 T6S R95W PA 24-24 SESW Sec. 24 T6S R95W PA 324-24 SESW Sec. 24 T6S R95W PA 32-24 SWNE Sec. 24 T6S R95W RWF 13-19 Pad PA 332-24 SWNE Sec. 24 T6S R95W 14 wells PA 432-24 SWNE Sec. 24 T6S R95W COC73094 Lot 14 Sec. 19 T6S R94W (BLM surface / PA 532-24 SWNE Sec. 24 T6S R95W existing pad) PA 333-24 NWSE Sec. 24 T6S R95W PA 433-24 NWSE Sec. 24 T6S R95W PA 533-24 NWSE Sec. 24 T6S R95W PA 34-24 SWSE Sec. 24 T6S R95W PA 334-24 SWSE Sec. 24 T6S R95W PA 434-24 SWSE Sec. 24 T6S R95W

The existing road network serving these pads would undergo minor upgrades, including the addition of new road surfacing prior to heavy traffic use. New buried gas gathering pipelines would be installed to all three of the expanded drill pads to gather the expected gas volumes. Buried water and condensate collection lines would be installed to deliver produced fluids to nearby tank farms serving the PA 23-26 and RWF 13-19 wells.

The existing RWF 23-19 pad on BLM would serve as a remote frac pad providing well completion support for the new wells on the RWF 13-19 pad, while an ancillary pad (PA 23-25) constructed adjacent to the PA 22-25 Fee pad would support remote frac operations for the PA 22-25 and PA 23-26 well completions. Surface steel frac lines would be laid between the PA 23-26 and PA 23-25 frac pad to deliver and flowback fluids for the PA 23-26 well completions, creating the only surface use within Federal lease COC73094. The pad, road, and pipeline upgrades related to the three drill pads and the two remote frac pads would occur in advance of the forecasted drilling start dates shown in Table 4.

7 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Table 4. Proposed Balzac Gulch Developments and Drilling Schedule Existing Drilling Future Wells Planned Legal Wells Well Pad Surface Start (Federal/Fee) Description (Federal/ Date Fee) 2017 2018 Totals T6S, R95W Existing PA 22-25 Fee 0/17 Dec-17 6/0 19/0 25/0 Section 25 T6S, R95W Existing PA 23-26 Federal 3/0 Apr-18 0/0 27/0 27/0 Section 26 T6S, R94W Existing RWF 13-19 Federal 6/0 Aug-18 0/0 14/0 14/0 Section 19 Proposed PA 23-25 Frac T6S, R95W Fee ------Pad 1 Section 25 Proposed PA 23-26 T6S, R95W Federal ------Tank Farm 2 Section 26 T6S, R95W Existing DOE 1-W-26 2 Federal 4/0 ------Section 26 T6S, R94W Existing RWF 23-19 3 Federal 4/0 ------Section 19 Totals -- -- 17/17 -- 6/0 60/0 66/0 1 No new wells are planned on the PA 23-25 Frac Pad (Fee), but the location would serve as remote frac pad for the PA 22-25 and PA 23-26 wells. 2 No new wells are planned on the Proposed PA 23-26 Tank Farm or Existing DOE 1-W-26 pad (used for cuttings storage for the PA 23-26 wells). 3 No new wells are planned on the existing RWF 23-19 Federal pad, but would serve as remote frac pad and tank farm site for the RWF 13-19 pad wells.

Development of 66 wells would involve year-round drilling, such that drilling would commence in December 2017 on the PA 22-25 pad with 25 new Federal wells, then move directly to the PA 23-26 pad with 27 new Federal wells, and then finish out the initial phase of development on the RWF 13-19 pad with 14 new Federal wells in October 2018. Development may be accelerated or delayed based on market conditions and company constraints. To accomplish the plan for development as shown in Table 4, the operator would need an exception to the timing limitations on Federal leases that protect big game winter habitat.

Drilling and completion timeframes would overlap with completions generally beginning 30 days after the first well is spud and ending approximately 60 days after the final well is drilled on the pad. Drilling a single directional well would take an average of 6 days.

Fresh water would be obtained from authorized sources within the Colorado River basin, typically through contractors who have their own legal source of water. Water would be trucked to the new wells to augment drilling operations ensuring the proper consistency of drilling muds for maintaining well control during the drilling process. Water used for well completions would be sourced primarily from Terra’s water recycling program, drastically negating the use of fresh water for frac operations, and the recycled treated water would be delivered in Terra’s existing water line systems, drastically reducing truck traffic on roads. 8

8 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Simultaneous operations (“simops”) would be employed, in which drilling and hydraulic fracturing (fracing) would occur at the same time on the well pads. During simops, the new wells being completed would have equipment featuring the mixing of recycled water, sand, and chemicals and the engines providing the high pressures needed for the completions being remotely staged on the RWF 23-19 BLM pad (in the case of the RWF 13-19 wells) or on the Fee PA 23-25 Frac Pad (in the case of the PA 22-25 and PA 23-26 wells). Surface steel pipelines would be laid between the drill pad and the remote frac pad, delivering pressurized water to the wells to be completed and returning flowback water generated from the completed wells.

Terra’s existing water management facilities and its water line infrastructure in the Anvil Points and Grand Valley areas would deliver water for frac operations and collect frac flowback and produced water without using truck transports. Oil truck transports would periodically haul condensate developed from the wells and stored in the various tanks within the MDP area to off-site processing facilities.

BLM Rights-of-Way Summary. A series of rights-of-way (ROWs) would be authorized for Terra’s use of the existing PA 23-26, RWF 13-19, and RWF 23-19 well pads, and existing pipelines and roads serving those locations, that would support the new wells drilled into nearby Federal lease COC73094 (Figure 1 and Table 5). Site ROWs would be issued for the drilling, completions and production activities of the new wells planned on the RWF 13-19 pad and the PA 23-26 pad. The new access road to be realigned between the RWF 13-19 pad and 23-19 frac pad would also be included in the RWF 13-19 site ROW while the PA 23-26 site ROW would include the new tank pad staged just west of the PA 23-26 pad. New buried pipelines that would gather the natural gas, water, and condensate developed from the new wells on the PA 23-26 and RWF 13-19 pads would need separate BLM ROW authorization. The existing access roads crossing BLM off-lease would also be covered under separate ROWs. Lastly, the surface frac lines staged from the PA 23-25 frac pad across BLM land during the well completion operation for the PA 23-26 wells would require a temporary use permit issued by the BLM.

Table 5. Proposed BLM Rights-of-Way for Balzac Gulch - Phase 1 MDP Project Area

Right-of-Way Type of Right-of-Way ROW Area (acres) ROW length / miles Relating to the RWF 13-19 Well Developments (T6S, R94W, Section 9, 6th P.M.) Well Pad + Frac Pad + New COC78666 4.68 + 2.89 + 0.59 = 8.16 acres 0.18 miles Road Connection1 New 8-inch Buried Gas COC78666-01 5912 feet x 50 feet / 6.79 acres 1.12 miles Pipeline COC78666-02 Existing Access Road 6721 feet x 25 feet / 3.86 acres 1.27 miles Relating to the PA 23-26 Well Developments (T6S, R94W, Section 26, 6th P.M.) COC78667 Well Pad + Tank Pad 6.20 + 0.30 = 6.50 acres N/A COC78667-01 New 8-inch Buried Gas 1528 feet x 50 feet / 1.75 acres 0.29 miles Pipeline COC78667-02 4-inch Produced Water Line 1522 feet x 50 feet / 1.74 acres 0.28 miles COC78667-03 4.5-inch Surface Frac Lines (3) 4951 feet x 50 feet / 5.68 acres 0.94 miles COC78667-04 Existing Access Road 1392 feet x 25 feet / 0.80 acres 0.26 miles 1Length of new road (925 feet) between RWF 13-19 and 23-19 pads is included as ancillary feature of site ROW. Note: The ROW lengths shown in Table 5 reflect the actual distances that the roads and pipelines described in narrative below actually cross BLM lands.

9 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Under the Proposed Action, Terra could implement all or any combination of the following BGMDP developments with the authorization of APDs and related ROWs.

PA 22-25 Project Components (Figures 2 and 3): The following actions would occur on private land.

 Expand the existing private PA 22-25 pad to a 7.28-acre footprint to drill 25 new Federal wells.  Construct a 1.43-acre support pad (PA 23-25 Frac Pad) adjacent to the PA 22-25 pad for remote fracing support for the PA 22-25 and PA 23-26 pads.  Install two 10-inch temporary surface water supply lines (approximately 250 feet each) from the existing 10-inch water line to the PA 23-25 Frac Pad.  Install one 6-inch production water line (approximately 170 feet) from the PA 22-25 pad to the existing 10-inch water line adjacent to the PA 22-25 pad.  Install one 12-inch steel production natural gas line (approximately 3,899 feet) from the PA 22-25 pad to the existing 12-inch natural gas line near the PA 341-35 pad within an existing pipeline corridor on private land.  Install three 4.5-inch steel temporary surface frac lines (approximately 91 feet) from the PA 23- 25 Frac Pad to the PA 22-25 pad.  Construct a new 525-foot-long access road from the PA 22-25 pad to the PA 23-25 Frac Pad.

PA 23-26 Project Components (Figures 4, 5, and 6): The following actions would occur on BLM land

 Expand the PA 23-26 pad creating a 6.20-acre disturbance footprint to drill 27 new Federal wells.  Construct the PA 23-26 tank pad (0.30-acre footprint) located along the existing road south of the PA 23-26 pad to store condensate in two 500 bbl steel tanks and stage one 80 bbl blowdown tank with VOC (volatile organic compound) combustion capabilities.  Bury one 10-inch welded steel natural gas pipeline (approximately 3,769 feet) and one 4-inch water pipeline (approximately 3,769 feet) following existing access road and pipeline corridors to the PA 23-26 pad to tie into existing infrastructure north of the existing East PA Tank Battery.  Remove an existing 3-inch gas line between the W 29-26 pad and the tie-in north of the existing East PA Tank Battery during installation of the 10-inch gas and 4-inch water lines.  Install two 2-inch steel oil lines (approximately 511 feet) from the PA 23-26 pad to the proposed tank battery (PA 23-26 Tank Farm) located south of the PA 23-26 pad along the existing road.  Reroute the existing 2-inch steel flow lines (approximately 374 feet) between the PA 23-26 pad and the DOE 1-W-26 pad into the existing access road to the DOE 1-W-26 pad.  Reroute the existing 2-inch steel temporary surface injection line (approximately 530 feet) between the PA 23-26 pad and the DOE 1-W-26 pad to follow the existing access road.  Install three 4.5-inch steel temporary surface frac lines across BLM land for approximately 5,206 feet between the PA 23-25 Frac Pad and the PA 23-26 pad to deliver high-pressure fluids and gather flowback for the PA 23-26 well completions.  Reroute the existing access road (approximately 350 feet) directly south of the PA 23-26 pad during the pad expansion work to reduce the grade and improve sight distance at the pad entrance.

10 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 2. Plan of Development for PA 22-25 Pad

11 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 3. Plan of Development for PA 23-25 Frac Pad

12 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 4. Plan of Development for PA 23-26 Pad

13 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 5. Plan of Development for PA 23-26 Tank Pad

14 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 6. Plan of Development for Cuttings Storage at DOE 1-W-26 Pad

15 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

 Use the existing open, steep cut slope at the DOE 1-W-26 pad to store excess drill cuttings developed from the PA 23-26 pad and reclaim the DOE 1-W-26 pad site based on a 2.38-acre disturbance footprint. Cuttings would be hauled by truck from the PA 23-26 pad to the DOE 1- W-26 pad and managed to satisfy COGCC Table 910-1 standards.

RWF 13-19 Project Components (Figures 7 and 8):

 Expand the existing RWF 13-19 BLM pad to a 4.68-acre footprint to drill 14 Federal wells.  Realign approximately 925 feet of the access road between the RWF 13-19 pad and the RWF 23- 19 pads to reduce the steep road grade and improve the “blind” road approach onto the RWF 13- 19 pad.  Expand the existing RWF 23-19 BLM pad to a 2.89-acre footprint to continue providing fluids storage at the tank farm and to support remote frac operations for the new wells on the RWF 13- 19 pad.  Install three 4.5-inch surface frac lines (approximately 950 feet) between the RWF 23-19 pad and the RWF 13-19 pad to deliver high pressure fluids for frac operations and gather flowback fluids  Bury approximately 6,163 feet of welded steel 8-inch natural gas pipeline in a combination of existing pipeline or road ROWs between the RWF 13-19 pad and a connection point at Anvil Points Road north of the Rulison Water Management Facility. Reroute approximately 349 feet of the existing 6-inch natural gas pipeline and 368 feet of the 4-inch water line on the RWF 13-19 pad. The 8-inch gas line and 6-inch gas line would be looped or both placed into operation to gather natural gas.  Install two 2-inch flexpipe oil lines for approximately 1,425 feet between the RWF 13-19 pad and the existing tank battery on the RWF 23-19 pad to deliver condensate to the RWF 23-19 tank battery. Continue to use the existing buried produced water line to deliver water from the RWF 13-19 wells to the RWF 23-19 tank farm.  Install an aboveground valve set and 50 feet of 10-inch surface poly line at the existing 10-inch water line adjacent to the RWF 23-19 pad to access the existing buried water line system providing water for the planned well completions on the RWF 13-19 wells.

Summary Statement: The three expanded well pads would develop a total of 66 wells along with associated access roads (1,800 feet or 0.34 mile) and pipelines (14,205 feet or 2.69 miles). Some pipelines would be collocated.

General Project Design Considerations

The Proposed Action would include drilling and completion of the wells, production of natural gas, and associated liquid condensate, proper handling and disposal of produced water and condensate, and interim and final reclamation.

During pad construction, topsoil would be stripped during the initial earthwork and windrowed, where feasible, around the outer edge of the disturbance perimeter to serve as storm water diversions and catchments. Topsoil would remain windrowed and temporarily seeded until interim reclamation is scheduled after all wells on each pad are placed into production. During road and pipeline construction, topsoil would be segregated along both sides of the road or along one edge of the pipeline corridor for later placement back onto the reclaimed ROW. The access roads would have a 20-foot running surface with additional width for drainage ditches and occasional vehicle turnouts. Typical new road and pipeline construction would occur within an average 50-foot-wide disturbance corridor. 16

16 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 7. Plan of Development for RWF 13-19 Pad

17 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 8. Plan of Development for RWF 23-19 Pad

18 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Construction of pads, roads, and pipelines would follow the guidelines established in the BLM Gold Book, Surface Operating Standards for Oil and Gas Exploration and Development (USDI and USDA 2007). The new access roads would be graveled to ensure all-weather accessibility to the pad sites; existing roads would undergo review for spot-graveling needs. A road maintenance program would be required during the production phase of the wells. This program would include, but not be limited to, blading, ditching, culvert installation and cleanout, weed control, and gravel surfacing where excessive rutting or erosion occur. Roads would be maintained in a safe and usable condition.

A closed-loop drilling system would be used during drilling, eliminating the need for a fluid-containing reserve pit. Recovered drilling fluid would be stored on location in steel tanks for reuse. Drill cuttings would be collected from the drill-rig shaker system, mixed with drying agents, and deposited in the cuttings trench or piled on location against the cut slope for later burial during interim reclamation. The cuttings would be tested and remediated per COGCC regulations (Table 910-1 standards) prior to reshaping for interim reclamation. The drilling plan includes a self-contained flare unit to restrict venting. The proposed directional wells with an estimated production life of 40 years would target the Mesaverde and Williams Fork formations within Federal leases COC73094 and COC62161.

The proposed pipeline work would be conducted within existing roadways or pipeline corridors. Strength testing of the pipeline would be accomplished initially by passing reinforced poly pigs through the inside of the line to clean it in sections. Segments of the line would be tested for strength using water, compressed air, or nitrogen, pressurized and held for a set duration. The length of the tested sections would depend on topography and the progress of the installation work.

Standard best management practices would be implemented to ensure disturbed areas on pads, roads, and pipelines are reclaimed in a timely manner.

The Proposed Action would be implemented consistent with the Federal oil and gas leases, Federal regulations (43 CFR 3100), and the operational measures included in the APDs. The operator would be responsible for continuous inspection and maintenance of the access roads, pads, and pipelines.

Summary of the Proposed Project Disturbance

Table 6 provides estimates of initial and long-term disturbance for the proposed developments. Initial disturbance includes the initial surface disturbance associated with the expansion of three existing well pads, expansion/construction of support pads, access roads, and pipelines. Once constructed, the well pads would be stabilized until the last well has been drilled and completed on the pad, at which time interim reclamation would occur.

Long-term disturbance is that portion of the initial disturbance that would remain during production of the wells (after interim reclamation), which includes the working area (unreclaimed portion) of the well pads that support production facilities and maintained roadways. Production would continue as long as economic quantities of natural gas are produced, and could persist over an estimated 40-year life. A portion of the access road disturbance and all disturbance for pipelines would be reclaimed immediately after construction or within the next growing season.

Estimated initial and long-term disturbance for expansion of three existing well pads (PA 22-25, PA 23- 26, and RWF 13-19), expansion of the frac pad (RWF 23-19), and construction of the PA 23-25 frac pad and PA 23-26 tank farm is listed in Table 6. The total project disturbance amounts to 41.47 acres of short-term disturbance with 25 acres occurring on BLM and 16.47 acres on private land. After reclamation has been implemented, the disturbance would be reduced to 8.30 acres (4.66 acres on BLM and 3.64 acres on private) for the long-term life of the project. 19

19 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Table 6. Proposed Disturbance for Project Components

New Total Existing Re-disturbance Disturbance Short-Term Long-term Number or Disturbance Surface (acres) (acres) Disturbance Disturbance Well Pad Length (feet) (acres) Ownership (Federal/ (Federal/ (acres) (acres) (Federal/Private) (Federal/ Private) Private) (Federal/ (Federal/Private) Private) Private) WELL PADS/SUPPORT PADS 1 PA 22-25 Private 0/1 0/4.49 0/2.17 0/0.62 0/7.28 0/2.53 PA 23-25 Frac Pad Private 0/1 0/0 0/0 0/1.43 0/1.43 0/0.92 Subtotal 0/2 0/4.49 0/2.17 0/2.05 0/8.71 0/3.45 PA 23-26 Federal 1/0 0.89/0 1.73/0 3.58/0 6.20/0 1.58/0 PA 23-26 Tank Farm Federal 1/0 0/0 0/0 0.30/0 0.30/0 0.30/0 DOE 1-W-26 Cuttings Federal 1/0 0.64/0 1.37/0 0.37/0 2.38/0 0.51/0 Subtotal 3/0 1.53/0 3.10/0 4.25/0 8.88/0 2.39/0 RWF 13-19 Federal 1/0 0.83/0 1.63/0 2.22/0 4.68/0 1.03/0 RWF 23-19 Frac Pad Federal 1/0 0.76/0 2.04/0 0.09/0 2.89/0 0.79/0 Subtotal 2/0 1.59/0 3.67/0 2.31/0 7.57/0 1.82/0 Total (Federal/Private) 5/2 3.12/4.49 6.77/2.17 6.56/2.05 16.45/8.71 4.21/3.45 ACCESS ROADS PA 23-25 Frac Pad Private 0/525 [525] 0/0 0/0 0/0.70 0/0.70 0/0.19 (new) PA 23-26 Federal 350/0 [350] 0.05/0 0/0 0.59/0 0.64/0 0.11/0 (realignment) RWF 13-19 Federal 925/0 [925] 0.33/0 0/0 0.30/0 0.63/0 0.34/0 (realignment) 1,275/525 Total (Federal/Private) 0.38/0 0/0 0.89/0.70 1.27/0.70 0.45/0.19 [1,800] PIPELINES 2 PA 22-25 (12-inch gas line and 6- Private 0/3,899 0/0 0/0 0/4.40 0/4.40 0/0 inch water line) 3

20 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

New Total Existing Re-disturbance Disturbance Short-Term Long-term Number or Disturbance Surface (acres) (acres) Disturbance Disturbance Well Pad Length (feet) (acres) Ownership (Federal/ (Federal/ (acres) (acres) (Federal/Private) (Federal/ Private) Private) (Federal/ (Federal/Private) Private) Private) PA 23-26 (10-inch gas line, 4-inch Federal/ Private 1,527/2,242 0.94/1.88 0.04/0 0.22/0.42 1.20/2.30 0/0 water line two 2-inch oil lines) 4 (two 2-inch flow lines) Federal 374/0 0.19/0 0/0 0/0 0.19/0 0/0 RWF 13-19 (8-inch gas line) (two 2-inch oil lines, 6- Federal/Private 5,912/251 0.60/0 4.93/0.31 0.36/0.05 5.89/0.36 0/0 inch gas line, and 4-inch water line) 5 7,813/6,392 7.28/7.06 Total (Federal/Private) 1.73/1.88 4.97/0.31 0.58/4.87 0/0 [14,205] [14.34] 5.23/6.37 11.74/2.48 8.03/7.62 25.00/16.47 Grand Total (Federal/Private) 4.66/3.64 [8.30] [11.60] [14.22] [15.65] [41.47] 1 Approximately 62% of the disturbance footprint for well pads would be on land previously disturbed and reclaimed. 2 Some of the proposed pipeline disturbance is not included because it would occur within existing road disturbances. 3 10-inch gas line and 6-inch waterline would be collocated. Water line is 170 feet on private land. 4 10-inch gas line, 4-inch water line and two 2-inch oil lines would be collocated. Oil lines are 511 feet on Federal land. 5 8-inch gas line, 6-inch gas line (349 feet), 4-inch water line (368 feet), and two 2-inch oil lines (1,396 feet) would be collocated.

21 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Details of Proposed Project including Surface Disturbance Expansion of the PA 22-25 Pad. The PA 22-25 pad is an existing 6.66-acre well pad constructed in 2008 on private surface (Figure 2 and Table 6). It currently has 16 producing Fee wells and one plugged and abandoned Fee well. An additional 25 bottomholes extending into Federal leases are proposed. The existing pad footprint would serve the new wells and production equipment. There would be a slight pad expansion of 0.62 acre at the northeast pad corner, resulting in a total pad expansion footprint of 7.28 acres. A new separator bank would be installed along the northwest pad corner and new tanks would be staged directly east of the current tanks in the southwest pad corner. A cuttings trench would be excavated along the south half of the pad with excess material used to implement the pad expansion along the east edge. Existing access to the PA 22-25 pad is sufficient in its current condition.

The PA 23-25 frac pad supporting well completions operations would be constructed on private land directly south of the existing PA 22-25 pad (Figure 3). The frac pad would require 1.43 acre of new disturbance. It would also be used as a frac support pad for proposed wells on the PA 23-26 pad. A 525- foot-long road would be constructed from the PA 22-25 pad to the PA 23-25 frac pad. To support fracing, two 10-inch temporary surface water supply lines (approximately 250 feet each) would be installed from the existing 10-inch water line to the PA 23-25 frac pad and three 4.5-inch steel temporary surface frac lines (approximately 91 feet) from the PA 23-25 frac pad to the PA 22-25 pad. Being a surface frac line that would be placed and pulled across the ground, there would not be a specific allotment for surface disturbance.

To support production, a new 6-inch water line (approximately 170 feet) would be buried from the tanks west to the existing 10-inch water line that is buried along the west and north edges of the PA 22-25 pad. The 6-inch water line would be installed adjacent to the existing natural gas line. Separators (six quads/one single) would be placed along the north edge of the pad. The existing separators (four quads) would remain in place and the existing tank battery would remain in place. An additional tank battery would be installed approximately 10 feet to the east of the existing tank battery. Tank batteries would consist of six 500-barrel water tanks, six 300-barrel oil tanks, and one 80-barrel blowdown tank.

A new 12-inch steel natural gas line (approximately 3,899 feet) would be buried within the existing pipeline corridor entirely on private surface from the PA 22-25 pad to a connection point near the PA 341-35 pad. The new 12-inch pipeline would parallel the existing 8-inch natural gas pipeline. The new road and pipeline corridor, with an average disturbance width of 50 feet, would represent 4.40 acres of initial disturbance.

Total disturbance of the PA 22-25 development, including the estimates for the new road serving the PA 23- 25 frac pad and the new gas and water lines (all occurring on private land), would be 13.81 acres initial disturbance and 3.64 acres long-term disturbance (Table 6).

Expansion of the PA 23-26 Pad. The PA 23-26 pad is an existing 0.89-acre well pad constructed in 2006 on Federal surface (Figure 4 and Table 6). It currently has three existing producing Federal wells. The existing pad would be expanded by 3.58 acres to accommodate an additional 27 bottomholes extending into Federal leases. The existing access road would be rerouted for approximately 350 feet and aligned south of the existing valve riser to join the expanded pad near the southwest corner of the pad. Excess material from the pad build would be used to ramp the road to the southside fill slope to make a gentler grade approach. The north side of the road leading to the DOE 1-W-26 pad would also be ramped around the separator footprint that would cover most of the west side of the pad. Total pad disturbance would be 6.20 acres when combining 0.89 acres of existing disturbance, 1.73 acres of re-disturbance of previously disturbed footprint, and 3.58 acres of new disturbance. The 350 feet of new road approach onto the pad would amount to 0.64 acre of short-term impact with 0.11 acre begin attributed to long-term disturbance. 22

22 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The PA 23-25 Frac Pad (discussed above) would also support completions for the PA 23-26 pad. Three 4.5-inch steel temporary surface frac lines (approximately 5,206 feet) would be installed from the PA 23- 25 Frac Pad to the PA 23-26 pad (see discussion below).

Separators (eight quads/one double) would be placed along the west edge of the pad. Two 500-barrel tanks would be placed in the offsite PA 23-26 Tank Farm to be built along the access road to the pad (Figure 5). One 80-barrel blowdown tank would be temporarily installed south of the proposed separators adjacent to the access road during drilling operations. Prior to interim reclamation, the temporary blowdown tank would be relocated onto the production pad. The new tank battery and VOC combuster would involve 0.30 acre of short-term disturbance. Since the storage tanks would be needed on the tank pad throughout the life of the PA 23-26 wells, a 0.30-acre estimate would apply for long-term disturbance as well.

Cuttings would be managed in a cuttings management area along the north side of the pad. Excess cuttings would be hauled to the DOE 1-W-26 pad north of the PA 23-26 pad and buried in the existing cut slope, which would improve site conditions at the DOE 1-W-26 pad (Figure 6). The short-term disturbance related to the cuttings storage and eventual interim reclamation work at the DOE 1-W-26 pad would amount to 2.38 acres with a long-term total of 0.51 acre.

A 10-inch natural gas pipeline (approximately 3,769 feet) and a 4-inch water pipeline (approximately 3,769 feet) would be buried following the existing access road to the PA 23-26 pad to tie into existing infrastructure north of the existing East PA Tank Battery. Two 2-inch steel oil lines (approximately 511 feet) would be buried from the PA 23-26 pad to the proposed PA 23-26 Tank Battery located south of the PA 23-26 pad along the existing road. The existing 2-inch flow lines from the existing wells on the DOE 1-W-26 pad would be rerouted down the existing road to connect back to the separators already on the PA 23-26 pad. The existing 2-inch steel temporary surface injection line would be rerouted to follow the existing access road between the PA 23-26 pad and the DOE 1-W-26 pad. Pipeline disturbances for the PA 23-26 development would total 3.69 acres short-term with 1.39 acres involving BLM land.

The ephemeral drainage along the eastern edge of the pad would be routed through a culvert that would direct flows under the frac operations portion of the pad. Rocks and boulders would be collected and used as riprap material at the culvert inlet and outlet.

The existing slash from the old juniper treatments in the vicinity of the proposed pad work would be hydro-axed during the vegetation clearing of the project perimeter. Heavy concentrations of tree slash could also be windrowed along the outside edge of the pad fillslope to act as a filter regarding soil deposition. The new trees to be removed during the pad expansion work would be hydro-axed as well to reduce the overall fuel-loading component of the site. There are numerous windrows and piles of dead junipers surrounding the pad site that were left after juniper trees were removed many years ago as a wildlife habitat improvement project.

Total disturbance of the PA 23-26 development would be 13.21 acres initial disturbance and 2.50 acres long- term disturbance (Table 6). All but 2.30 acres of the initial disturbance would be on Federal lands.

Surface Frac Lines between PA 23-26 Pad and PA 23-25 Frac Pad. The three 4.5-inch-diameter welded steel temporary surface frac lines (approximately 5,206 feet) would be installed from the PA 23- 25 frac pad to the PA 23-26 pad (Figure 3). The frac lines would operate under high pressure. The main power for the frac jobs would be located at the PA 23-25 pad and would deliver pressurized fluids through the lines to the proposed wells at the PA 23-26 pad. The lines would also transport frac flowback fluids to the PA 23-25 frac pad for reuse or direct delivery into Terra’s water gathering system.

23 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The route from northeast corner north of the PA 23-26 pad goes east along an old two-track route for 0.25-mile and then drops sharply off the mesa and east for another 0.25- mile and across a large unnamed intermittent drainage where a different two-track would be followed to the PA 23-25 pad. Where the lines span the intermittent drainage, the frac lines would be cased inside 10-inch diameter black poly lines with 2-inch-thick walls. The existing two-track for the initial 0.25-mile stretch northeast of the PA 23-26 pad would be seeded following removal of the proposed frac lines.

No disturbance estimate would be allocated to the three high-pressure welded steel surface lines. Resource surveys were conducted along the proposed surface line alignments to avoid potential resource impacts.

Expansion of the RWF 13-19 Pad and RWF 23-19 Frac Pad. The RWF 13-19 pad is an existing 0.83- acre well pad with five producing gas wells constructed in 2004 on Federal surface (Figure 7 and Table 6). The existing pad would be expanded by 2.22 acres and would service 14 additional bottomholes extending into Federal lease COC73094. A cuttings trench would be located along the entire south side of the pad. Total pad disturbance would be 4.68 acres when combining 0.83 acres of existing disturbance, 1.63 acres of re-disturbance of previously disturbed footprint, and 2.22 acres of new disturbance. At the time of pad reshaping and seeding for interim reclamation, the pad disturbance would be reduced to a 1.03-acre footprint for the productive life of the wells.

Topsoil would be windrowed around the RWF 13-19 pad edges except along the north side, where there is a steep drop-off into a drainage. The separators (four quads/one double) would be located along the northwest side of the pad north of the access road to the RWF 12-19 pad to maximize interim reclamation. Trees cleared during the pad expansion would be broken down and tucked into the toe of the fill as a sediment filter.

The nearby RWF 23-19 pad would serve as the frac pad for the 14 proposed wells on the RWF 13-19 pad (Figure 8). The existing pad footprint of 0.76 acre would be expanded with 2.04 acres of re-disturbance and 0.09 acre of new disturbance for a total pad disturbance footprint of 2.89 acres. At the time of pad reshaping and seeding for interim reclamation, the pad disturbance would be reduced to a 0.79-acre footprint.

All existing equipment on the RWF 23-19 pad would remain in place. The existing tank farm facility would continue to serve the existing wells and the 14 wells planned on the adjacent RWF 13-19 pad. A total of eight tanks (three 400-barrel water/four 300-barrel oil/one 80-barrel blowdown) would be staged within the existing containment.

Three 4.5-inch surface frac lines (approximately 950 feet) would be placed alongside the road between the RWF 23-19 pad and the RWF 13-19 pad. Water would be supplied to the location using existing water line infrastructure. An aboveground valve set would be installed on the existing 10-inch water line adjacent to the RWF 23-19 pad. A 10-inch temporary surface poly line (approximately 50 feet) would be installed from the valve set to the RWF 23-19 pad.

Approximately 6,163 feet of welded steel 8-inch natural gas pipeline would be buried primarily within or along the existing roadway or pipeline ROWs between the RWF 13-19 pad and a connection point at Anvil Points Road north of the Rulison Water Management Facility (Figure 7). Approximately 349 feet of the existing 6-inch natural gas pipeline and 368 feet of 4-inch water line would be rerouted on the RWF 13-19 pad. The 8-inch gas line and the 6-inch gas line would be looped. Two 2-inch oil lines (approximately 1,425 feet) would be buried in the road between the RWF 13-19 pad and the existing tank battery on the RWF 23-19 pad.

24 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Due to excessive road grades and a blind spot at the entrance to the existing RWF 13-19 pad, the road between the RWF 13-19 and 23-19 pads would be realigned for approximately 925 feet. The entrance would be adjusted to the south into the hillside to improve safety. Excess material from the cuttings trench excavation would be used to raise the access road between the two pads, thereby reducing the blind spot and improving the road grade and approach. As shown in Table 6, the road realignment work and the installation of buried oil lines and the 8-inch gas pipeline between the RWF 13-19 and 23-19 pads would total 0.63 acre (short-term) and 0.34 acre (long-term).

The RWF 13-19 development, including the RWF 23-19 frac pad expansion, the road realignment, and the 8- inch pipeline upgrades to the Anvil Points Road connection would be 14.09 acres of short-term initial and 2.16 acres long-term disturbance (Table 6). All but 0.36 acre of the initial disturbance would be on Federal lands.

3.2. NO ACTION ALTERNATIVE

Council on Environmental Quality (CEQ) regulations require the BLM to analyze the No Action Alternative in comparison to the Proposed Action. Since all of the oil and gas wells proposed in this project would be developed in Federal minerals, the No Action Alternative would involve a scenario in which none of the 66 new Federal wells would be drilled, completed, or produced, despite their being proposed on existing well pads. Because no new well development would occur, pipeline or road upgrades would not be needed. Similarly, the temporary surface line proposed for installation between the PA 22-25 and PA 23-26 pads would not be needed.

Table 4 lists 17 Federal wells and 17 fee wells presently operating on the existing five well pads related to the Proposed Action. These 34 producing wells would continue to operate using the existing road and pipeline infrastructure on BLM and private land, including the related travel, noise, air quality, water quality, and wildlife impacts associated with such operations over the next 25 to 30 years.

4. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

During its internal scoping process for this EA, pursuant to the National Environmental Policy Act (NEPA), BLM resource specialists identified elements of the natural and human environment as present in the project vicinity and potentially affected by the project. Environmental elements not identified as being present or potentially affected by the project are not analyzed in this EA. Environmental elements identified as present, potentially present, or potentially affected by the project are listed below:

Access and Transportation Native American Religious Vegetation Air Quality Concerns Visual Resource Management Cultural Resources Noise Wastes – Hazardous and Solid Fossil Resources Socioeconomics Water Resources – Surface Water and Geology and Minerals Soils Groundwater Invasive Non-Native Plants Special Status Species Wildlife – Aquatic and Terrestrial Lands with Wilderness Characteristics

The following subsections describe the affected environment (current conditions) and direct and indirect environmental consequences (impacts) of the Proposed Action and No Action Alternative. Potential adverse impacts to the environmental elements addressed in this EA would be avoided, minimized, or offset by design features incorporated into the Proposed Action by Terra in collaboration with the BLM, and by general and site-specific COAs included in the Appendix. Cumulative impacts are summarized in Section 5. 25

25 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

4.1. ACCESS AND TRANSPORTATION

Affected Environment

Separate access routes from various non-adjoining segments of I-70 frontage roads would serve the three pad sites to be developed. The Rulison exit (#81) would be the primary I-70 interchange used to access the project.

The PA 22-25 pad would be accessed directly off the north side of the I-70, Rulison interchange where the road curves west transitioning from pavement to graveled road crossing private lands for approximately 0.3 mile to its terminus at the existing PA 22-25 pad. About 525 feet of new road would be constructed to support the adjacent PA 23-25 frac pad resulting in 0.70 acre of new disturbance on private land.

The PA 23-26 pad in BLM land would be accessed from the south frontage road near the north side of the bridge that passes diagonally over I-70 approximately 3 miles west of the Rulison exit. The private field development road traverses east from the overpass bridge paralleling I-70 and then bears north and east across private and BLM lands onto a mesa where the PA 23-26 and DOE 1-W-26 pads are situated. Approximately 350 feet of new road would be built to improve the road approach and pad entrance at the PA 23-26 pad resulting in 0.64 acres of short-term disturbance on BLM.

Access to the RWF 13-19 pad would be east from exit #81 along the south frontage road to Garfield County Road (CR) 246 (Anvil Points Landfill Road), then north to the end of the pavement where CR 246 provides public access on the gravel road bearing northwest and crossing the shale-laden drainage with a low water crossing. After the drainage crossing, the BLM field development road bears southwesterly along a windy circuitous route for approximately 1.4 miles passing through the RWF 23-19 pad to the RWF 13-19 pad and ending at the RWF 12-19 pad beyond. The route provides suitable all- weather access to the RWF 13-19 and 23-19 pads year-round. Approximately 925 feet of the existing road between the two pads would be realigned to reduce the steep grade from 15% to 10% and eliminate the blind approach onto the RWF 13-19 location. A 36-inch culvert west of the RWF 23-19 pad would be reset and lengthened to accommodate the new road alignment. The short-term disturbance related to the road realignment would amount to 0.63 acre on BLM land with 0.30 acre of disturbance within the existing road corridor and 0.33 acre occurring as new disturbance alongside the old roadway.

Aside from the RWF 13-19 pad accessed by CR 246, public motorized access is not available within the project area. The project area would be accessed by vehicles serving the oil and gas development, including traffic related to construction, drilling, completion, and well production.

Traffic use counts are not available for the existing roads accessing the project area. Aside from drilling and completion operations, oil and gas-related road use would be considered low and specifically focused on pickup traffic to monitor and maintain well production on the existing Terra well pads in the area. Produced water generated from Terra’s producing wells is gathered and delivered to water treatment facilities in buried pipelines, vastly reducing heavy truck traffic in the field.

Environmental Consequences

Proposed Action

Garfield County’s preferred County Road haul routes system would be used (including CR 246), and Terra would be restricted from using other County roads not designated as haul routes for heavy loads. The Proposed Action would result in periods of substantial increases in traffic volume on the preferred 26

26 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

haul routes, the existing private field development roads, and the newly constructed or realigned roads within the project area.

Truck traffic would be greatest during rig-up, drilling, and completion activities. As shown in Table 7, for directional wells, the overall traffic count for each well included in the Proposed Action would be approximately 1,160 vehicles of the types typically associated with the drilling and completion. Once each well is producing, traffic would dramatically decrease to occasional visits in pickups for monitoring or maintenance activities. Produced water generated during the life of each well would be stored at the tank facilities and trucked off-site for recycling. The volume of condensate collected in a tank would require periodic truck visits to remove the oil from the tanks. The well may have to be recompleted once per year, requiring three to five truck trips per day for approximately 7 days. Degradation of field development roads may occur due to travel by heavy equipment, which also results in fugitive dust emissions (Section 4.2) and elevated noise levels (Section 4.8). Mitigation measures applied as COAs (see Appendix) would ensure adequate dust abatement and road maintenance. Table 7. Traffic Associated with Directional Drilling and Completion Activities

Vehicle Class Trips per Well Portion of Total 16-wheel tractor trailers 88 7.6% 10-wheel trucks 216 18.6% 6-wheel trucks 452 39.0% Pickup trucks 404 34.8% Total 1,160 100.0% Source: BLM 2006. Note: Trips by different vehicle types are not necessarily distributed evenly during the drilling and completion process. Drilling and completion activities would occur year- round,

Proposed roads would be constructed with a disturbance corridor approximately 50 feet wide, reduced to 22 feet of finished road surface (including bar ditches) after interim reclamation. A conventional dozer would be used to clear vegetation and large boulders within the proposed limits of disturbance for the planned roads. Earth-moving equipment would be used to segregate and windrow the topsoil along the edge of the proposed road corridor. The roads would be constructed using standard equipment and techniques as described in the Surface Operating Standards for Oil and Gas Exploration & Development – The Gold Book (USDI and USDA 2007). Mitigation measures (Appendix) would be required as conditions of approval for road construction and maintenance operations including, but not limited to dust abatement, ditching, draining, crowning, surfacing, sloping, and dipping the roadbed as necessary. A minimum 6-inch layer of gravel would be applied to the new roads to provide an all-weather travel way. Increased traffic on County roads may cause temporary conflicts with normal traffic, including travel delays and increased vehicle collision rates. Project traffic would also cause an increase in fugitive dust and noise and an increased risk of collision with wildlife. Degradation of County, private, and BLM roads may occur from heavy equipment, resulting in increased maintenance and safety management. Existing field development roads would be maintained and resurfaced as needed with minimum 6-inch layer of gravel.

Of the 1,800 feet of new road construction for the Phase 1 development, approximately 1,275 feet of road would be realigned on BLM and 525 feet of road would be built on private lands. The initial disturbance 27

27 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

estimates would amount to 1.97 acres with 1.27 acres occurring on BLM. After interim reclamation work is completed on the new roads, long term disturbance related to the running surface and associated ditches would total 0.64 acre with most of that disturbance (0.45 acre) occurring on BLM.

No Action Alternative

4.2. AIR QUALITY

Affected Environment

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.

Regional Air Quality

The BGMDP project area is located in western Colorado, in central Garfield County, and is within the Western Slope Region for air quality planning (Colorado Department of Public Health and Environment [CDPHE] 2016a). The Western Slope Region includes nine counties on the western border of Colorado. Air quality concerns in this region are primarily related to ranching, agriculture, mining, energy development, and tourism.

Regional Climate

Climate of the project area is a semi-arid (dry and cold), mid-continental regime, typified by dry, sunny days, clear nights, and large daily temperature changes. The climate and topography of the region are conducive to the formation of temperature inversions. The nearest long-term meteorological measurements were collected at Rifle, Colorado (1910 to 2009), located approximately 12 miles east of the project area at an elevation of 5,320 feet above mean sea level (amsl) (Western Regional Climate Center [WRCC] 2017a).

The annual average total precipitation at Rifle, Colorado, is 11.6 inches, with annual totals ranging from 6.9 inches (1960) to 21.8 inches (1985). Precipitation is evenly distributed throughout the year with slightly higher amounts occurring during the spring and late summer through fall months. The average annual snowfall is 38.5 inches and occurs from fall through spring with the greatest monthly mean snowfall in December and January.

The region has cool temperatures, with the average daily temperature ranging between 9 degrees Fahrenheit (˚F) and 37˚F in January to between 52˚F and 90˚F in July. Extreme temperatures have ranged from -38˚F (1963) to 104˚F (1929). The frost-free period generally occurs from late-May to late- September. Table 8 shows the mean monthly temperature ranges and total precipitation amounts.

28 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Table 8. Mean Monthly Temperature Ranges and Total Precipitation

Mean Temperature Total Precipitation Total Snowfall Month Range (˚F) (inches) (inches) January 9 – 37 0.9 11.0 February 17 – 44 0.8 7.6 March 24 – 54 0.9 3.7 April 31 – 64 1.0 0.8 May 39 – 74 1.0 0.0 June 45 – 84 0.7 0.0 July 52 – 90 1.0 0.0 August 50 – 88 1.1 0.0 September 42 – 77 1.1 0.0 October 31 – 67 1.2 0.5 November 21 – 54 0.9 3.7 December 12 – 39 0.9 11.1 ANNUAL 47.8 (mean) 11.7 38.5 Source: WRCC 2017a

The closest comprehensive wind measurements were collected at the Rifle Colorado Remote Automated Weather Station (RAWS) (WRCC 2017b), located approximately 12 miles east of the project area. Tables 9 and 10 provide the wind direction distribution and wind speed distribution at that site in a tabular format. The annual mean wind speed at the Rifle site is 4.9 miles per hour (mph). A wind rose of years 2012 to 2016 describes the wind pattern for the region (Figure 9). This information indicates that winds originate from the southwest to northwest nearly 41% of the time.

Table 9. Wind Direction Frequency Distribution, Rifle, Colorado, 2012 to 2016

Wind Direction Frequency (percent) Calm 14.3 N 4.1 NNE 3.9 NE 4.1 ENE 5.0 E 5.6 ESE 3.5 SE 3.4 SSE 3.7 S 3.2 SSW 3.0 SW 3.7 WSW 7.6 W 10.5 WNW 10.7 NW 8.2 NNW 5.6

29 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Source: WRCC 2017b Table 10. Wind Speed Distribution, Rifle, Colorado, 2012 to 2016

Wind Speed (mph) Frequency (percent) < 1.3 (Calm) 14.3 1.3 – 4 34.7 4 – 8 31.2 8 – 13 12.9 13 – 19 5.6 19 – 25 1.3 Greater than 25 0.0 Source: WRCC 2017b

Source: WRCC 2017b

Figure 9. Wind Rose, Rifle, Colorado, 2012 to 2016 30

30 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Overview of Regulatory Environment

Air quality impacts from pollutant emissions are limited by regulations, standards, and implementation plans established under the Clean Air Act (CAA), as administered by the CDPHE Air Pollution Control Division (APCD) under authorization of the U.S. Environmental Protection Agency (EPA).

The APCD is the primary air quality regulatory agency responsible for determining potential impacts once detailed industrial development plans have been made, and 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 APCD 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 that meets the requirements set forth under division permit regulations is subject to the Colorado permitting and compliance processes.

Federal air quality regulations adopted and enforced by the CHPHE-APCD 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 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. Federal Land Managers 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 be included for these areas.

The 1977 CAA amendments established visibility as an AQRV for Federal Land Managers to consider. The 1990 CAA 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 that limit permissible levels of air pollutant concentrations and air emissions, and are relevant to the project air-impact analysis, are listed below and described in the subsections that follow:

 National Ambient Air Quality Standards (NAAQS) (40 CFR Part 50) and Colorado Ambient Air Quality Standards (CAAQS) (5 Code of Colorado Regulations - CCR-1001-14)  Hazardous Air Pollutants (HAPs)  PSD (40 CFR Part 51.166)  New Source Performance Standards (NSPS) (40 CFR Part 60)  National Emission Standards for Hazardous Air Pollutants (NESHAPs) (40 CFR Part 63)  Non-Road Engine Tier Standards (40 CFR Part 89)  Colorado Oil and Gas Permitting Guidance Each of these regulations is further described in the following sections.

Ambient Air Quality Standards. The CAA requires the EPA to set NAAQS for pollutants considered to endanger public health and the environment. The EPA has developed NAAQS for seven criteria pollutants: nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), particulate matter less 31

31 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

than 10 microns in effective diameter (PM10), particulate matter less than 2.5 microns in effective diameter (PM2.5), ozone (O3), and lead. Since project sources would not produce lead emissions, lead impacts are not addressed in this document.

The NAAQS include 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 CAAQS are summarized in Table 11.

In Table 11, 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. Although specific air quality monitoring has not been conducted within the project area, all of Garfield County is currently designated as “attainment” by the CDPHE for all criteria pollutants (CDPHE 2016a).

Table 11. Ambient Air Quality Standards

Pollutant Averaging Time Primary/Secondary NAAQS CAAQS 35 ppm 1-hour1 Primary * (40,000 µg/m3) CO 9 ppm 8-hour1 Primary * (10,000 µg/m3)* 100 ppb 1-hour2 Primary * (188 µg/m3) NO 2 53 ppb Annual3 Primary and Secondary * (100 µg/m3) 70 ppb Ozone 8-hour4 Primary and Secondary * (137 µg/m3) 2 3 PM10 24-hour Primary and Secondary 150 µg/m * 24-hour5 Primary and Secondary 35 µg/m3 * 6 3 PM2.5 Annual Primary 12 µg/m * Annual6 Secondary 15 µg/m3 * 75 ppb 1-hour7 Primary * (196 µg/m3) 0.5 ppm SO2 3-hour1 Secondary * (1,300 µg/m3) 3-hour1 Primary and Secondary -- 700 µg/m3 Source: 40 CFR Part 50 1 No more than one exceedance per year. 2 th An area is in compliance with the standard if the 98 percentile of the daily maximum 1-hour NO2 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 th An area is in compliance with the standard if the 98 percentile 24-hour PM2.5 concentration in a year, averaged over 3 years, is less than or equal to the level of the standard. 6 Annual arithmetic mean, averaged over 3 years. 7 th An area is in compliance with the standard if the 99 percentile of daily maximum 1-hour SO2 concentrations in a year, averaged over 3 years, is less than or equal to the level of the standard. Bold indicates the units in which the standard is defined.

32 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Hazardous Air Pollutants. HAPs are 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 subject to 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 include well-site production emissions (benzene, toluene, ethyl benzene, xylenes, n-hexane, and formaldehyde).

Acute Reference Exposure Levels (RELs) are shown in Table 12 (EPA 2014a). RELs are defined as concentrations at or below which no adverse health effects are expected. RELs are not available for ethyl benzene and n-hexane; instead, the available Immediately Dangerous to Life or Health divided by 10 (IDLH/10) values are used. These IDLH values were determined by the National Institute for Occupational Safety and Health (NIOSH) 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 12. Acute (1-Hour Exposure) RELs

Air Toxic REL (µg/m3) Benzene 1,3001 Toluene 37,0001 Ethyl benzene 350,0002 Xylenes 22,0001 n-Hexane 390,0002 Formaldehyde 551 1 Source: EPA Air Toxics Database, Table 2 (EPA 2014a). 2 No REL available for these air toxics. Values shown are from IDLH/10, EPA Air Toxics Database, Table 2 (EPA 2014a).

Long-term exposure to air toxics are 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 air toxics concentrations for all air toxics emitted are compared directly to the non-carcinogenic RfCs shown in Table 13. Long-term exposures to emissions of suspected carcinogenic HAPs (benzene, ethyl benzene, and formaldehyde) are also evaluated based on estimates of the increased latent cancer risk over a 70-year lifetime.

Table 13. Non-Carcinogenic Air Toxics Annual Average RfCs

Air Toxic Non-Carcinogenic RfC (µg/m3) Benzene 30 Toluene 5,000 Ethyl benzene 1,000 Xylenes 100 n-Hexane 700 Formaldehyde 9.8 Source: EPA 2014b

33 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

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 that describes the degree of degradation to the existing air quality 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, national 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 Flat Tops Wilderness, which is approximately 51 kilometers (km) to the east. In a PSD increment analysis, impacts from proposed emissions sources are compared with the allowable limits on increases in pollutant concentrations, which are called PSD increments. PSD increments are established for NO2, PM10, PM2.5, and SO2. These increments are shown in Table 14. The project area is classified as PSD Class II, for which less stringent limits on increases in pollutant concentrations apply.

Table 14. PSD Class I and Class II Increments

PSD Class I PSD Class II Pollutant Averaging Time Increment1 (µg/m3) Increment1 (µg/m3) 1 NO2 Annual 2.5 25 24-hour2 8 30 PM 10 Annual1 4 17 24-hour2 2 9 PM 2.5 Annual1 1 4 3-hour2 25 51 1 SO2 24-hour 5 91 Annual1 2 20 Source: 40 CFR 52.21(c) 1 Annual arithmetic mean. 2 24-hour maximum.

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 Colorado.

In addition to the PSD increments, Class I areas are protected by the Federal Land Managers through management of AQRVs, such as visibility, atmospheric deposition, aquatic ecosystems, flora, fauna, etc. AQRVs have been identified as a concern at several Federal Class I and sensitive Class II areas in the region. The project area is within 200 km of eleven Class I areas and three sensitive Class II areas as shown on Figure 10. Class I areas within 200 km of the project area include the Eagles Nest, Flat Tops, La Garita, Maroon Bells – Snowmass, Mount Zirkel, Weminuche, and West Elk wilderness areas, and Arches, Black Canyon of the Gunnison, Canyonlands, and Rocky Mountain national parks.

Federal Class II areas within 200 km of the project area that are considered sensitive areas include the Raggeds Wilderness, Dinosaur National Monument, and Colorado National Monument. Dinosaur National Monument is regulated as a Class I area for SO2 by the CDPHE. A discussion of the applicable AQRV analysis thresholds is provided below.

34 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 10. Nearby PSD Class I and Sensitive Class II Areas

Visibility. 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% change in light 35

35 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

extinction (approximately equal to a 0.5 change in dv) is the threshold recommended in FLAG (2010) and is considered to contribute to regional haze visibility impairment. A 10% 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 been 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 at 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 Federal Land Manager 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 U.S. Fish and Wildlife Service (USFWS). The DATs represent screening level values for nitrogen and sulfur deposition from project-specific 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 kilogram per hectare per year (kg/ha-yr).

In addition to the project-specific analysis, results from cumulative emission sources are compared to critical load thresholds established for the Rocky Mountain region to assess total deposition impacts. The NPS has provided recent information on nitrogen critical load values applicable for Wyoming and Colorado Class I and sensitive Class II areas (NPS 2014). For Colorado Class I and sensitive Class II areas (with the exception of Dinosaur National Monument) a critical load value of 2.3 kg/ha-yr is applicable for total nitrogen deposition, based on research conducted by Baron (2006) that estimated 1.5 kg/ha-yr as a critical loading value for wet nitrogen deposition for high-elevation lakes in Rocky Mountain National Park, Colorado. For Dinosaur National Monument, which is an arid region, a nitrogen deposition critical load value is based on research conducted by Pardo et al. (2011), which concluded that the cumulative critical load necessary to protect shrublands and lichen communities in Dinosaur National Monument is 3 kg N/ha-yr.

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 in Montana and Bridger Wilderness 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.

Analyses to assess the change in water chemistry associated with atmospheric deposition are performed following the procedures developed by the U.S. Forest Service (USFS) Rocky Mountain Region (USFS 2000). Predicted changes in ANC are compared with the applicable threshold for each identified lake: 10% change in ANC for lakes with background ANC values greater than 25 microequivalents per liter (µeq/L), and a change of less than 1 µeq/L for lakes with background ANC values equal to or less than 25 µeq/L.

New Source Performance Standards. Under Section 111 of the CAA, the EPA has promulgated technology-based emissions standards that apply to specific categories of stationary sources. These

36 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

standards are referred to as 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 Liquid Storage Vessels  Subpart JJJJ – Standards of Performance for Stationary Spark-Ignition Internal Combustion Engines  Subpart OOOO – Standards for Crude Oil and Natural Gas Production  Subpart OOOOa – Standards for Crude Oil and Natural Gas Facilities Subpart A – General Provisions. Provisions of Subpart A apply to the owner or operator of any stationary source that 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 the 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 JJJJ – Stationary 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 (NOX) and volatile organic compound (VOC) emission standards over the phase-in period of the regulation. Owners and operators of stationary SI ICEs 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. 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 that 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 Facilities. 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 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. In April 2017, the EPA announced that it is reviewing this rule and, if appropriate, will initiate reconsideration proceedings to suspend, revise, or rescind this rule (EPA 2017a). 37

37 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

National Emission Standards for Hazardous Air Pollutants. Under Section 112 of the CAA, the EPA has promulgated emissions standards for HAPs that apply to specific source categories. These standards are referred to as 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, ethyl benzene, toluene, and xylenes (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.

Non-Road Engine Tier Standards. The EPA sets emissions standards for non-road diesel engines for hydrocarbons, NOX, 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 will turn over and higher-emitting engines will be replaced with lower-emitting engines.

Colorado Oil and Gas Permitting Guidance. CDPHE Air Quality Control Commission (AQCC) regulations that are applicable to the project are as follows:

 Regulation 3, covering emissions reporting requirements  Regulation 6, which fully adopts the EPA’s Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution found in 40 CFR, Part 60, Subpart OOOO (“NSPS OOOO”)  Regulation 7, which includes extensive VOC reductions and regulates methane emissions from the oil and gas industry

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 (CO2), methane (CH4), nitrous oxide (N2O), 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. Certain GHGs, such as CO2 and CH4, occur naturally in the atmosphere and are also emitted into the atmosphere by human activities. 38

38 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

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 CO2, CH4, and N2O have increased to levels unprecedented in at least the last 800,000 years. From pre-industrial times until today, the global average concentrations of CO2, CH4, and N2O in the atmosphere have increased by around 40%, 150%, and 20%, respectively (Intergovernmental Panel on Climate Change [IPCC] 2013).

Human activities emit billions of tons of CO2 every year. CO2 is primarily emitted from fossil fuel combustion, but has a variety of other industrial sources. CH4 is emitted from oil and natural gas systems, landfills, mining, agricultural activities, and waste and other industrial processes. N2O 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. CO2, CH4, N2O, 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 altering the formation or destruction of GHGs. These gases include CO, NOX, and non-methane VOCs. 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). PM10 typically originates from natural sources and settles out of the atmosphere in hours or days. PM2.5 often originates 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 1%) to virtually certain (99-100% probability) and level of confidence ranging from very low to very high. The findings presented in the 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 (99-100% 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, in global mean sea-level rise, and in changes in some climate extremes. It is extremely likely (95-100% probability) that human influence has been the dominant cause of the observed warming since the mid-20th century (IPCC 2013). Findings 39

39 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

from the 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 from 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 U.S. 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 U.S., 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 the year 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 Southwest region. The Key Messages for this region (NCA 2014b) are as follows:

 Snowpack and streamflow amounts are projected to decline in parts of the Southwest, decreasing surface water supply reliability for cities, agriculture, and ecosystems.  The Southwest produces more than half of the nation’s high-value specialty crops, which are irrigation-dependent and particularly vulnerable to extremes of moisture, cold, and heat. Reduced yields from increasing temperatures and increasing competition for scarce water supplies will displace jobs in some rural communities.  Increased warming, drought, and insect outbreaks, all caused by or linked to climate change, have increased wildfires and impacts to people and ecosystems in the Southwest. Fire models project more wildfire and increased risks to communities across extensive areas. 40

40 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

 Flooding and erosion in coastal areas are already occurring even at existing sea levels and damaging some California coastal areas during storms and extreme high tides. Sea level rise is projected to increase as Earth continues to warm, resulting in major damage as wind-driven waves ride upon higher seas and reach farther inland.  Projected regional temperature increases, combined with the way cities amplify heat, will pose increased threats and costs to public health in southwestern cities, which are home to more than 90% of the region’s population. Disruptions to urban electricity and water supplies will exacerbate these health problems.

Greenhouse Gas Emissions and Climate Change. GHGs projected to be emitted by project sources are CO2, CH4, and N2O. In 2007, the U.S. Supreme Court ruled in Massachusetts v. EPA that the EPA has the authority to regulate GHGs, such as CH4 and CO2 as air pollutants under the CAA. 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. As mentioned above, the EPA NSPS 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. However, this rule is presently under review and the EPA may revise or rescind this rule (EPA 2017a).

EPA’s Greenhouse Gas Reporting Program includes reporting requirements. These reporting requirements, finalized in 2010 under 40 CFR Part 98, will require operators to develop and report annual CH4 and CO2 emissions from equipment leaks and venting, and emissions of CO2, CH4, and N2O from flaring, onshore production stationary and portable combustion emissions, and combustion emissions from stationary equipment.

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 the ability to quantify potential future impacts from GHGs emissions at this scale. When additional information on the impacts of local emissions to climate change is known, such information would be incorporated into USFS and BLM 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 direct effects of BLM actions related to oil and gas development because they do not occur at the same time and place as the action. 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.

Monitored Air Pollutant Concentrations

Monitoring of air pollutant concentrations has been conducted in the region. These monitoring sites are part of several monitoring networks overseen by State and Federal agencies, including: CDPHE, Clean Air Status and Trends Network (CASTNET), Interagency Monitoring of Protected Visual Environments (IMPROVE), and National Atmospheric Deposition Program (NADP) National Trends Network (NTN).

41 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Air pollutants monitored in the region include CO, NO2, O3, PM10, PM2.5, and SO2. 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 were obtained from the CDPHE (CDPHE 2016b) and EPA’s Air Quality System Data Mart (EPA 2017b), and are shown in Table 15. Applicable background concentrations for HAPs (benzene and formaldehyde) were obtained from EPA’s Air Quality System Data Mart (EPA 2017b).

Table 15. Background Ambient Air Quality Concentrations

Measured Background Pollutant Averaging Period Concentration (µg/m3) 1-hour 1,145 CO1 8-hour 1,145 1-hour2 46 NO2 Annual3 6.8 3 PM10 24-hour 33 24-hour 9 3 PM2.5 Annual 3.8 Ozone4 8-hour 122 1-hour 2.6 3-hour 2.6 1 SO2 24-hour 2.6 Annual 2.6 24-hour 1.4 Benzene2 Annual 2.0 24-hour 0.8 Formaldehyde2 Annual 0.9 Sources: CDPHE 2016b and EPA 2017b 1 Williams Willow Creek, 2012. 2 Battlement Mesa, Garfield County, 2016. 3 Battlement Mesa, Garfield County, 2014-2016. 4 Rifle, 2014-2016.

Monitored Visibility

Visibility conditions can be measured as standard visual range (SVR). SVR is the farthest distance at which an observer can just see a black object viewed against the horizon sky; the larger the SVR, the cleaner the air. Continuous visibility-related optical background data have been collected in the Class I areas – Flat Tops Wilderness, White River National Forest (Maroon Bells-Snowmass Wilderness), and Weminuche Wilderness – as part of the IMPROVE program. The average SVR at each of the three sites is historically greater than 150 km and in the most recent reported years, the average SVR has increased to greater than 200 km (IMPROVE 2017a).

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 42

42 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

on an area per year in kilograms per hectare 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 (SO4), nitrate (NO3), and ammonium (NH4); the chemical components of dry deposition include SO4, SO2, nitrogen oxides (NOX), NO3, ammonia (NH3), NH4, and nitric acid (HNO3).

The NADP and the NTN station monitors wet atmospheric deposition and the CASTNET station monitors dry atmospheric deposition at the Gothic site, located east of the project area. The total annual deposition (wet and dry) reported as nitrogen (N) and sulfur (S) deposition for years 2006 through 2015 are shown in Table 16.

Table 16. Gothic Site N and S Deposition Values, 2006 to 2015

Year of Nitrogen Deposition (kg/ha-yr) Sulfur Deposition (kg/ha-yr) Monitoring Wet Dry Total Wet Dry Total 2006 1.41 1.33 2.74 0.69 0.28 0.97 2007 1.25 1.46 2.71 0.52 0.31 0.83 2008 1.09 1.36 2.46 0.63 0.32 0.95 2009 1.41 1.28 2.69 0.81 0.28 1.09 2010 1.45 1.20 2.65 0.73 0.25 0.97 2011 1.31 1.32 2.63 0.62 0.26 0.88 2012 1.28 1.22 2.50 0.48 0.22 0.70 2013 2.14 1.25 3.39 0.84 0.24 1.08 2014 1.75 1.15 2.90 0.64 0.21 0.85 2015 1.95 1.12 3.07 0.72 0.18 0.90 Source: EPA 2017c

Table 17 presents a list of nine lakes in the Flat Tops, Maroon Bells-Snowmass, Raggeds, and West Elk Wilderness Areas that have been identified as acid sensitive lakes. Analyses for potential changes to lake acidity from atmospheric deposition are based on the acid neutralizing capacity (ANC) for the lake. The most recent lake chemistry background ANC data available from the IMPROVE network “Federal Land Manager Environmental Database” (IMPROVE 2017b) are shown in Table 17. The ANC values shown are the 10th percentile lowest ANC values, which were calculated for each lake following procedures provided by the USFS. The years of monitoring data that were currently available, and the number of samples used in the calculation of the 10th percentile lowest ANC values, are provided. Of the nine lakes listed in Table 17, Upper Ned Wilson and Deep Creek lakes are considered by the USFS as extremely sensitive to atmospheric deposition because the background ANC values are less than 25 µeq/L.

Table 17. Background ANC Values for Acid Sensitive Lakes 10th Percentile Number of Monitoring Wilderness Lake Latitude Longitude Lowest ANC 1 Samples Period

Flat Tops Ned Wilson Lake 39° 57’ 41” 107° 19’ 25” 39.0 µeq/L 191 1981-2007

Upper Ned Wilson Flat Tops 39° 57’ 46” 107° 19’ 25” 12.9 µeq/L 143 1983-2007 Lake

43 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

10th Percentile Number of Monitoring Wilderness Lake Latitude Longitude Lowest ANC 1 Samples Period Lower Packtrail Flat Tops 39° 58’ 5” 107° 19’ 24” 29.7 µeq/L 96 1987-2007 Pothole Upper Packtrail Flat Tops 39° 57’ 56” 107° 19’ 23” 48.7 µeq/L 96 1987-2007 Pothole Maroon Bells- Avalanche Lake 39°8’33” 107°5’53” 158.8 µeq/L 55 1991-2010 Snowmass Maroon Bells- Capitol Lake 39°9’42” 107°4’50” 154.4 µeq/L 57 1991-2010 Snowmass Maroon Bells- Moon Lake 39°9’49” 107°3’34” 53.0 µeq/L 54 1991-2010 Snowmass

Raggeds Deep Creek Lake 39°0’30” 107°14’23” 20.6 µeq/L 24 1995-2009

West Elk South Golden Lake 38°46’39” 107°10’58” 111.4 µeq/L 25 1995-2008

Source: IMPROVE 2017b 1 10th Percentile Lowest ANC Values reported.

Environmental Consequences

Proposed Action

The Proposed Action includes the following BMPs, which reduce potential air-quality impacts:

 The new access roads would be graveled to ensure all-weather accessibility to the pad sites and existing roads would undergo review for spot-graveling needs, thereby reducing fugitive dust. A road maintenance program would be required during the production phase of the wells.  A self-contained flare unit would be used to restrict venting during drilling.  Terra would conduct green completions, capturing vented gas.  The use of pipeline infrastructure and centralized facilities (water storage, fracing, fluids collection) would reduce truck traffic, reducing overall emissions.

An air quality modeling analysis was performed to assess the impacts on ambient air quality and AQRVs from potential air emissions due to the Proposed Action. Both near-field and far-field air quality analyses were performed. Potential ambient air quality impacts were quantified and compared to applicable State and Federal ambient air quality standards, PSD increments, and HAP thresholds. AQRV impacts (impacts on visibility, atmospheric deposition, and potential increases in acidification to acid-sensitive lakes) were determined and compared to applicable thresholds.

Near-Field Modeling. A near-field assessment of impacts on ambient air quality was performed to evaluate maximum pollutant impacts within and near the project area resulting from construction and operation. EPA's Guideline (EPA 2005) model, AERMOD (version 16216r), was used to assess these near-field impacts. The near-field modeling used 5 years of meteorological data (2012 to 2016) collected at the Garfield County airport, located approximately 15 miles east of the project area.

The near-field criteria pollutant assessment was performed to estimate maximum potential impacts of CO, NO2, SO2, PM10, and PM2.5 from well pad and road construction, well drilling/completion, and 44

44 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

production emissions sources. Near-field HAP (BTEX, n-hexane, and formaldehyde) emissions from production operations were evaluated for purposes of assessing impacts in the immediate vicinity of the project area for both short-term (acute) exposure assessment and for calculation of long-term human health risk.

The near-field analysis of construction activities included an assessment of PM10 and PM2.5 impacts from fugitive dust and vehicle tailpipe particulate emissions from construction of a new ancillary frac pad (PA 23-25) and road segment. Criteria pollutant impacts were also analyzed from SIMOPS. This modeling scenario included emissions from completion operations located at well pad PA 23-25 and drilling operations located at well pad PA 22-25, and conservatively assumed that these operations would occur continuously at these locations 24 hours per day over an entire year.

The near-field analysis of production operations included an impact assessment for criteria pollutants and HAPs from 66 new wells located at each of the three expanded well pad locations within the project area [RWF 13-19 (14 new wells), PA 23-26 (27 new wells) and PA 22-25 (25 new wells)].

Modeling analyses for well production and drilling/completion operations utilized receptor grids that extended outward at least 1.5 km from the edge of any well pad. Discrete modeling receptors were placed at 25-meter (m) intervals along the edge of the well pads and then at 100-m intervals outward at least 1.5 km. For the construction of the frac pad, the model receptors were placed at 25-m intervals along a boundary 100 meters from the pad and at 100-m intervals extending outward approximately 1.5 km. Terrain elevations for each receptor were developed using the AERMAP (Version 11103) processor along with available digital elevation model data.

Far-Field Modeling. A far-field assessment of ambient air impacts quantified potential air quality impacts to both ambient air concentrations and AQRVs from air pollutant emissions of NOX, SO2, PM10, and PM2.5 expected to result from the Proposed Action. Ambient air quality impacts of NO2, SO2, PM10, and PM2.5 and AQRVs were analyzed at far-field Federal Class I and sensitive Class II areas located within 100 km of the project area. The Class I areas located within 100 km of the project area include the Black Canyon of the Gunnison National Park, Flat Tops Wilderness, Maroon Bells-Snowmass Wilderness, and West Elk Wilderness. Federal Class II areas within 100 km of the project area that are considered sensitive areas include the Raggeds Wilderness and Colorado National Monument. Nine lakes that are designated as acid sensitive and are located within the Flat Tops Wilderness area (Ned Wilson Lake, Upper Ned Wilson Lake, Lower Packtrail Pothole, and Upper Packtrail Pothole), Maroon Bells- Snowmass Wilderness area (Avalanche Lake, Capitol Lake, and Moon Lake), Raggeds Wilderness area (Deep Creek Lake) and West Elk Wilderness area (South Golden Lake) were assessed for potential lake acidification from atmospheric deposition impacts.

The far-field analyses used the EPA-approved version of the CALPUFF modeling system (Version 5.8) along with a windfield developed for year 2011 using the Mesoscale Model Interface Program (MMIF) Version 3.2 (ENVIRON 2015) and the 2011 Weather Research and Forecasting (WRF) meteorological model output that was produced as part of the Three-State Air Quality Study (3SAQS) (University of North Carolina Institute for the Environment and ENVIRON 2015).

The far-field assessment assumed a maximum field-wide emissions scenario with SIMOPS activities occurring continuously over the year.

Impact Significance Criteria. Air quality impacts from pollutant emissions are limited by regulations, standards, and implementation plans established under the CAA, as administered by the CDPHE-APCD under authorization of the EPA. Under FLPMA and the CAA, the BLM cannot conduct or authorize any activity that does not conform to all applicable local, state, tribal, or Federal air quality laws, statutes, 45

45 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

regulations, standards, or implementation plans. As such, significant impacts to air quality from project- related activities would result if it is demonstrated that:

 NAAQS or CAAQS 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 New Source Review process. The New Source Review process would also include an evaluation of potential impacts to AQRVs (such as visibility, aquatic ecosystems, flora, fauna, etc.) performed under the direction of the appropriate Federal Land Managers.

Emission Inventory Development. Air pollutant emissions would occur as part of construction and well production. Sources of emissions during construction include vehicle traffic, well pad and road construction, gathering line and pipeline construction, and well drilling and completion. The primary pollutants emitted during construction would be PM10, PM2.5, NOX, CO, SO2, VOCs, and HAPs, including BTEX, n-hexane, and formaldehyde. These activities would temporarily elevate pollutant levels, but impacts would be localized and would occur only for the short-term duration of the activities. Fugitive dust emissions (PM10 and PM2.5) would result from work crews commuting to and from the work site and from the transportation and operation of equipment during construction. Wind-blown fugitive dust emissions would also occur from open and disturbed land during construction.

Emissions from construction were quantified using accepted methodologies, including manufacturer’s emission factors, EPA emission factors and standards, and engineering estimates. Drill rig and completion engines would be Tier 2 or Tier 3 emissions compliant. Maximum annual field-wide criteria pollutant and HAPs emissions resulting from well pad, gathering line, and pipeline construction and from drilling and completion activities are shown in Table 18. The construction emissions also assume that a maximum of 60 wells would be drilled and completed in one year. The total HAPs emissions include benzene, toluene, ethyl benzene, xylenes, n-hexane, and formaldehyde emissions of 0.08, 0.04, 0.0005, 0.02, 0.04, and 0.007 tons per year (tpy), respectively.

Table 18. Construction Emissions

Tons per Year Activity PM10 PM2.5 NOx CO SO2 VOC HAPs Well Pad, Gathering Line, Pipeline, and Road 0.05 0.01 0.01 0.01 <0.01 <0.01 -- Construction Drill Rig Engines 3.50 3.50 103.46 60.02 0.35 6.93 0.10 Drilling and Rig Move 24.94 2.57 2.02 3.99 0.01 0.38 -- Traffic Completion Engines 0.70 0.70 20.13 12.11 0.02 1.35 0.02 Completion Traffic 20.74 2.13 1.46 3.36 <0.01 0.31 -- Completion Venting/Flaring 0.23 0.23 2.12 11.53 -- 1.37 0.08 Maximum Annual 50.15 9.14 129.20 91.02 0.25 10.33 0.20 Emissions

46 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

During field production operations, each of the three expanded well pads would contain a total of 66 new producing wells [RWF 13-19 (14 new wells), PA 23-26 (27 new wells) and PA 22-25 (25 new wells)]. Emissions during this phase would occur from vehicle traffic on roads during routine field operations and maintenance, separator and tank heaters, and workover rigs. There would also be fugitive emissions resulting from the well site equipment.

The primary pollutants emitted would be PM10, PM2.5, NOX, CO, SO2, VOCs, and HAPs. These emissions would impact air quality in the project area over the life of the project. Production equipment is subject to current and future CDPHE Best Available Control Technology (BACT) and Reasonably Achievable Control Technology (RACT) guidance and applicable portions of 40 CFR Part 63 Subparts OOOO and OOOOa, Standards of Performance for Crude Oil and Natural Gas Production. Maximum annual production emissions are summarized in Table 19. The total HAPs emissions include benzene, toluene, ethyl benzene, xylenes, n-hexane, and formaldehyde emissions of 0.16, 0.23, 0.01, 0.09, 0.48, and 0.04 tpy, respectively.

Table 19. Annual Production Emissions

Tons/Year Activity PM10 PM2.5 NOx CO SO2 VOC HAPs Workover Rig Engines 0.02 0.02 0.30 0.28 <0.01 0.02 <0.01 Production Traffic 0.55 0.06 0.01 0.09 <0.01 0.01 -- Separator and Tank Heaters 0.14 0.14 1.78 0.89 -- 0.56 0.08 Production Fugitives ------16.55 0.93 Total Production Emissions 0.71 0.22 2.09 1.26 <0.01 17.14 1.01

Greenhouse Gases. As part of the development of the project emission inventory, an inventory of CO2, CH4, and N2O emissions from field development and production activities was prepared. GHGs were not modeled in either the near-field or far-field impact analyses, but 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.

In the Proposed Action emission inventory, emissions of the greenhouse gases CO2, CH4, and N2O, from new and existing sources, 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 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 its emissions by the associated GWP. The GWPs for the inventoried greenhouse gases are CO2:1, CH4:25, N2O:298 (EPA 2014c). Development and production emissions of CO2e are shown in Table 20.

Table 20. GHG Emissions

Emissions (metric tons per year) Pollutant Development Production

CO2e 17,392 9,459

47 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Modeling Results

Near-Field Modeling. Air pollutant dispersion modeling was performed to quantify maximum potential PM10, PM2.5, NOX, CO, SO2, and HAP impacts from construction and production. AERMOD was used to model the maximum potential emissions of PM10, PM2.5, NOX, CO, and SO2 that could occur from the Proposed Action well pad/road construction, drilling/completion and production sources. Ozone impacts from this project are estimated as part of a regional air modeling study titled the Colorado Air Resource Management Modeling Study (CARMMS)(BLM 2016b), discussed in Section 5.1.

Table 21 presents the maximum modeled air pollutant concentrations that could occur from construction activities; and Table 22 presents the maximum impacts that could occur from well production.

Table 21. Maximum Modeled Pollutant Concentrations from Well Construction Activities

Concentration (µg/m3) Averaging Pollutant Direct Period Background Total Predicted NAAQS CAAQS Modeled 1-hour 2,290 1,145 3,430 40,000 40,000 CO 8-hour 1,180 1,145 2,330 10,000 10,000 1-hour 105 46.0 151 188 188 NO 2 Annual 35.5 6.8 42.3 100 100 1-hour 4.9 2.6 7.5 196 196 SO 2 3-hour 3.5 2.6 6.1 1,300 700

PM10 24-hour 93.7 33.0 127 150 150 24-hour 23.4 9.0 32.4 35 35 PM 2.5 Annual 7.7 3.8 11.5 12 12 Notes: Modeled highest second-high value shown for all short-term averaging periods, with the following exceptions: th  NO2 1-hour value is calculated as the 5-year average of the 8 highest daily maximum 1-hour concentrations.  SO2 1-hour value is the maximum 1-hour concentration. th  PM2.5 24-hour value is the maximum 8 highest concentration.

Table 22. Maximum Modeled Pollutant Concentrations from Well Production Activities

Concentration (µg/m3) Averaging Pollutant Direct PSD Class II Total Period Background NAAQS CAAQS Modeled Increment 1 Predicted 1-hour 30.4 -- 1,145 1,175 40,000 40,000 CO 8-hour 10.0 -- 1,145 1,155 10,000 10,000 1-hour 34.1 -- 46.0 80.1 188 188 NO 2 Annual 2.0 25 6.8 8.8 100 100 1-hour 0.022 -- 2.6 2.6 196 196 3-hour 0.016 512 2.6 2.6 1,300 700 SO 2 24-hour 0.007 91 ------Annual 0.002 20 ------24-hour 6.8 30 33.0 39.8 150 150 PM 10 Annual 1.7 17 ------24-hour 4.4 9 9.0 13.4 35 35 PM 2.5 Annual 1.7 4 3.8 5.5 12 12 1 PSD demonstrations are informational only and do not constitute a regulatory increment consumption analysis. Notes: Modeled highest second-high value shown for all short-term averaging periods, with the following exceptions: th  NO2 1-hour value is calculated as the 5-year average of the 8 highest daily maximum 1-hour concentrations.  SO2 1-hour value is the maximum 1-hour concentration. th  PM2.5 24-hour value is the maximum 8 highest concentration. 48

48 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

When maximum modeled concentrations from the modeled scenarios are added to representative background concentrations, it is demonstrated that the total ambient air concentrations are less than the applicable NAAQS and CAAQS. In addition, direct-modeled concentrations resulting from production activities are below the applicable PSD Class II increments. Note that the emissions from well development activities would be temporary and would not consume PSD increment, and as a result are excluded from increment comparisons.

Although the form of the 1-hour NAAQS is a 3-year average (see Table 11), a 5-year averaging period is used herein following EPA guidance (EPA 2010) for 1-hour NO2 modeling when using NWS airport meteorological data in the analysis. For the 1-hour NO2 NAAQS/CAAQS compliance demonstrations for well development activities (Table 21), the modeled NO2 impact presented above represents a 5-year average of the eighth-highest daily maximum 1-hour concentrations from combined well production and well drilling and completion operations. The 5-year average of the eighth highest daily maximum 1-hour NO2 concentrations was developed using the maximum eighth highest daily maximum 1-hour concentrations from two years of drilling and completion operations, and from 3 years of well production activities at the three expanded well pads.

Modeling was performed to estimate the maximum impacts that could occur from HAP emissions generated by production sources. Potential maximum acute (short-term/1-hour) HAP concentrations are shown in Table 23 compared with the acute RELs (EPA 2014a). 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 IDLH/10 values are used. These IDLH values are determined by NIOSH and were obtained from EPA's Air Toxics Database (EPA 2014a). As shown in Table 23, the maximum predicted acute HAP concentrations are below the threshold levels.

Table 23. Maximum Modeled 1-Hour HAP Concentration Impacts

Concentration (µg/m3) Air Toxic Direct Modeled Background 1 Total Predicted REL Benzene 4.9 1.4 6.3 1,300 Toluene 8.0 -- 8.0 37,000 Ethyl benzene 0.2 -- 0.2 350,0002 Xylenes 3.1 -- 3.1 22,000 n-Hexane 17.1 -- 17.1 390,0002 Formaldehyde 1.3 2.0 3.3 55 1 Available 24-hour background concentration data for year 2016 from Battlement Mesa (EPA 2017b) used as an estimate of 1-hour background data. 2 No REL available for these air toxics. Values shown are from IDLH/10, EPA Air Toxics Database, Table 2 (EPA 2014a).

Analyses were also performed for long-term (annual) HAP concentrations resulting from production sources. The potential annual HAP concentrations are shown in Table 24 compared to non-carcinogenic RfCs (EPA 2014b). An RfC is defined by EPA as the daily inhalation concentration at which no long- term adverse health effects are expected. As shown in Table 24, the maximum modeled annual HAP impacts are below the RfC levels.

49 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Table 24. Maximum Modeled Annual HAP Concentration Impacts

Concentration (µg/m3) Air Toxic Direct Modeled Background Total Predicted RfC Benzene 0.41 0.8 1.21 30 Toluene 0.65 -- 0.65 5,000 Ethyl Benzene 0.02 -- 0.02 1,000 Xylenes 0.25 -- 0.25 100 Formaldehyde 0.04 0.9 0.94 9.8 n-Hexane 1.4 -- 1.4 700 1 Background concentration data for year 2016 from Battlement Mesa (EPA 2017b).

Long-term exposures to emissions of suspected carcinogens (benzene, ethyl benzene, and formaldehyde) were evaluated based on estimates of the increased latent cancer risk over a 70-year lifetime. This analysis presents the potential incremental risk from these pollutants, and does not represent a total risk analysis. The potential cancer risks were calculated using the maximum predicted annual concentrations and EPA's chronic inhalation unit risk factors (URFs) for carcinogenic constituents (EPA 2014a). Two estimates of cancer risk are presented: 1) a most likely exposure (MLE) scenario; and 2) a maximum exposed individual (MEI) scenario. The estimated cancer risks are adjusted to account for duration of exposure and time spent at home.

The adjustment for the MLE scenario is assumed to be 9 years, which corresponds to the mean duration that a family remains at a residence (EPA 1993). This duration corresponds to an adjustment factor of 9/70 = 0.13. The duration of exposure for the MEI scenario is assumed to be 40 years (i.e., the life of the project), corresponding to an adjustment factor of 40/70 = 0.57. A second adjustment is made for time spent at home versus time spent elsewhere. For the MLE scenario, the at-home time fraction is 0.64 (EPA 1993) and it is assumed that during the rest of the day the individual would remain in an area where annual air toxics concentrations would be one-quarter as large as the maximum annual average concentration. Therefore, the final MLE adjustment factor is (0.13) x [(0.64 x 1.0) + (0.36 x 0.25)] = 0.095. The MEI scenario assumes that the individual is at home 100% of the time, for a final MEI adjustment factor of 0.57 (0.57 x 1.0).

For each constituent, the cancer risk is computed by multiplying the maximum predicted annual concentration by the URF and by the overall exposure adjustment factor. The cancer risks for both constituents are then summed to provide an estimate of the total potential inhalation cancer risk.

The modeled long-term risks from benzene, ethyl benzene, and formaldehyde emissions resulting from field production emissions are shown in Table 25.

Table 25. Long-term Modeled MLE and MEI Cancer Risk Analyses Direct Modeled Unit Risk Factor Exposure Analysis Air Toxic Concentration Cancer Risk 1/(µg/m3) Adjustment Factor (µg/m3) Benzene 0.41 7.8 x 10-6 0.095 3.0 x 10-7 MLE Ethyl Benzene 0.02 2.5 x 10-6 0.095 3.9 x 10-9 Formaldehyde 0.04 1.3 x 10-5 0.095 4.9 x 10-8 Total Combined 3.6 x 10-7 50

50 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Benzene 0.41 7.8 x 10-6 0.57 1.8 x 10-6 MEI Ethyl Benzene 0.02 2.5 x 10-6 0.57 2.4 x 10-8 Formaldehyde 0.04 1.3 x 10-5 0.57 2.9 x 10-7 Total Combined 2.1 x 10-6

The estimated risk for the MLE scenario is below a one-in-one-million (0.0001%) cancer risk level. Under the MEI scenario, the estimated cancer risk associated with long-term exposure to these suspected carcinogens is slightly greater than a one-in-one-million risk level. The maximum impacts occur immediately adjacent to the well pads. The approximate distance from a well pad where the cancer is below a one-in-one-million cancer risk level for the MEI analysis is 0.25 miles.

Far-Field Modeling. Far-field modeling at Class I and sensitive Class II areas within 100 km of the project area was performed using the CALPUFF model to quantify potential air quality impacts to both ambient air concentrations and AQRVs from emissions of NOX, SO2, PM10, and PM2.5 at levels expected to result from the Proposed Action. Class I and sensitive Class II areas analyzed include the Class I Black Canyon of the Gunnison National Park, Flat Tops Wilderness, Maroon Bells-Snowmass Wilderness, and West Elk Wilderness, and the Class II Raggeds Wilderness and Colorado National Monument.

The far-field assessment assumed a field-wide maximum emissions scenario that included emissions from completion operations located at the ancillary frac pad PA 23-25 and drilling operations located at well pad PA 22-25, and conservatively assumed that these operations would continuously occur 24 hours per day over an entire year. The scenario is similar to the scenario modeled as part of the near-field analysis for the drilling and completion operations; however, it included field-wide completion and drilling traffic emissions (associated with all roads within the project area) whereas the near-field scenario only included traffic emissions to those well pads. The modeled field-wide emissions included 50.9 tpy of PM10, 9.4 tpy of PM2.5, 135.4 tpy of NOX, and 0.4 tpy of SO2. These emissions are an overestimate of the maximum project emissions that are shown earlier given that the drilling and completion operations are assumed to occur continuously over the year.

Class I and Sensitive Class II Area PSD Increment Comparison. The direct-modeled concentrations of NO2, SO2, PM10, and PM2.5 at Class I and sensitive Class II areas are provided in Table 26 for comparison to applicable PSD Class I and Class II increments. As shown in Table 26, these values are well below the PSD increments.

Table 26. Maximum Modeled Pollutant Concentrations at PSD Class I and Sensitive Class II Areas Concentration (µg/m3) Location Pollutant Averaging Time Direct Modeled PSD Increment

NO2 Annual 0.0002 2.5 3-hour 0.0002 25 SO2 24-hour 0.0001 5 Black Canyon of the Gunnison Annual 0.000003 2 National Park 24-hour 0.028 8 PM 10 Annual 0.001 4 24-hour 0.023 2 PM 2.5 Annual 0.001 1

NO2 Annual 0.0008 2.5 Flat Tops Wilderness 3-hour 0.0002 25 SO2 24-hour 0.00004 5 Annual 0.00001 2 51

51 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Concentration (µg/m3) Location Pollutant Averaging Time Direct Modeled PSD Increment 24-hour 0.032 8 PM 10 Annual 0.003 4 24-hour 0.026 2 PM 2.5 Annual 0.002 1

NO2 Annual 0.0005 2.5 3-hour 0.0002 25 SO2 24-hour 0.00004 5 Maroon Bells - Snowmass Annual 0.000005 2 Wilderness 24-hour 0.022 8 PM 10 Annual 0.002 4 24-hour 0.018 2 PM 2.5 Annual 0.002 1

NO2 Annual 0.0002 2.5 3-hour 0.0002 25 SO2 24-hour 0.00005 West Elk Wilderness Annual 0.000002 2 24-hour 0.019 8 PM 10 Annual 0.001 4 24-hour 0.016 2 PM 2.5 Annual 0.001 1

NO2 Annual 0.0002 25 3-hour 0.0001 512 SO2 24-hour 0.00003 91 Raggeds Wilderness Annual 0.000003 20 24-hour 0.017 30 PM 10 Annual 0.002 17 24-hour 0.014 9 PM 2.5 Annual 0.001 4

NO2 Annual 0.0009 25 3-hour 0.0002 512 SO2 24-hour 0.0001 91 Colorado National Monument Annual 0.00001 20 24-hour 0.035 30 PM 10 Annual 0.003 17 24-hour 0.026 9 PM 2.5 Annual 0.002 4

AQRV Impacts

Visibility Impacts. Visibility impacts at Class I and sensitive Class II areas were calculated following FLAG 2010 (Table 27).

Table 27. Maximum Visibility Impacts at Class I and Sensitive Class II Areas

Location Maximum Impact (Δdv) Black Canyon of the Gunnison Wilderness 0.10 Flat Tops Wilderness 0.12 Maroon Bells/Snowmass Wilderness 0.08

52 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Location Maximum Impact (Δdv) West Elk Wilderness 0.07 Raggeds Wilderness 0.06 Colorado National Monument 0.11

The visibility analysis indicated zero days predicted above the 0.5 delta-deciviews (change in deciviews, Δdv) threshold at any of the Class I and sensitive Class II areas. The maximum predicted visibility impact is 0.12 Δdv, occurring at the Flat Tops Wilderness.

Deposition Impacts. Potential direct atmospheric deposition impacts within Class I and sensitive Class II areas were also calculated for Proposed Action sources. At all Class I and sensitive Class II areas, the maximum direct total (wet and dry) N and S deposition are predicted to be well below the DAT established for both nitrogen and sulfur in western Class I areas (0.005 kg/ha-yr). The maximum predicted deposition impacts occurred at the Flat Tops Wilderness and are 0.0014 kg/ha-yr (N) and 0.00004 kg/ha-yr (S).

In addition, potential changes in ANC, resulting from potential N and S deposition from Proposed Action source emissions, were calculated for nine sensitive lakes within the Flat Tops, Maroon Bells-Snowmass, Raggeds, and West Elk Wilderness areas. For all lakes, the estimated changes in ANC are all predicted to be less than the significance thresholds (USFS 2000). The estimated change in ANC is 0.002% at Avalanche Lake, 0.003% at Capitol Lake, 0.007% at Moon Lake, 0.027% at Lower Packtrail Pothole, 0.016% at Upper Packtrail Pothole, 0.020% at Ned Wilson Lake and 0.002% at South Golden Lake (compared to the 10% threshold), and a 0.005 μeq/L change at Deep Creek Lake and 0.008 μeq/L change at Upper Ned Wilson Lake (compared to a 1.0 μeq/L threshold for extremely sensitive lakes).

Regional Climate Change

Greenhouse Gas Emissions. According to the U.S. Global Change Research Program (2009), global warming is unequivocal, and the global warming that has occurred over the past 50 years is primarily human-caused. Standardized protocols designed to measure factors that may contribute to climate change, and to quantify climatic impacts, are presently unavailable. Therefore, impact assessment of specific impacts related to anthropogenic activities on global climate change cannot be accurately estimated. Moreover, specific levels of significance have not yet been established by regulatory agencies. Therefore, climate change analysis for the purpose of this assessment is limited to accounting for GHG emission changes that would contribute incrementally to climate change.

The maximum GHG emissions resulting from the Proposed Action are estimated at 26,851 metric tons per year (0.03 million metric tons [MMT]) of CO2e. To place the project GHG emissions in context, the GHG emissions in year 2015 from the top five emitting coal-fired power plants in Colorado ranged from 3.1 to 8.4 MMT (EPA 2017d). In addition, 0.03 MMT is approximately equivalent to 0.0004% of the total 2015 U.S. CO2e emissions (6,586 MMT [EPA 2017d]). Predicting the degree of impact any single emitter of GHGs may have on global climate change, or on the changes to biotic and abiotic systems that accompany climate change, is not possible at this time. Consequently, the controversy relates to the extent that GHG emissions resulting from continued oil and gas development may contribute to global climate change, as well as the accompanying changes to natural systems that cannot be quantified or predicted. The degree to which any observable changes can, or would, be attributable to the Proposed Action cannot be reasonably predicted at this time.

53 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

No Action Alternative

3.3 CULTURAL RESOURCES

Affected Environment

A number of intensive (Class III) cultural resource linear and block inventories including CRVFO# 1117- 03, CRVFO# 1113-13, CRVFO# 1113-10 and CRVFO# 1113-16 were completed specifically for the Balzac Gulch Master Development Plan - Phase I Project or other oil & gas developments in the project area. Additionally, several dozen other inventories were previously conducted within a mile of the current project’s proposed well pads and linear routes/alignments.

Environmental Consequences

Proposed Action

Literature reviews of known cultural resource surveys and known sites in the project area were undertaken of the CRVFO cultural resource files and the Colorado Historical Society’s Office or Archaeology and Historic Preservation COMPASS website. The literature review for this project determined that six previously recorded sites occur within the project area: 5GF173, 5GF2204, 5GF2205, 5GF2828, 5GF455.6 and 5GF4897. Due to the small number of eligible resources in the project area, the Area of Potential Effect (APE) for this project is viewed as the actual area of disturbance for the pads and linear routes.

Of the cultural sites previously recorded, two are eligible sites (5GF.2828 and 5GF.4897) and were located and reevaluated during the current inventory. Neither of these historic properties will be affected by the Balzac Gulch Development Phase 1 Project. Additionally, one prehistoric site (5GF5401) and two isolates (5GF.5402 and 5GF.5403) were newly recorded. Site 5GF.5401 does not meet any of the criteria for eligibility and is field evaluated as not eligible for listing on the National Register of Historic Places.

As currently designed, the implementation of the Proposed Action would have no direct impacts to known “historic properties.” Although a proposed pipeline route comes close to the eligible cultural site 5GF.4897, project re-design has the pipeline routed within an existing pipeline disturbance just outside the site boundary and the site will thus not be affected by the proposed construction. Consequently, the BLM made a determination of “No Historic Properties Affected.” This determination was made in accordance with the 2001 revised regulations [36 CFR 800.4(d)(1)] for Section 106 of the National Historic Preservation Act (NHPA 16U.S.C 470f), the BLM/State Historic Preservation Officer (SHPO) Programmatic Agreement (2012) and Colorado Protocol (2014)]. Additional consultation with the Colorado SHPO’s office in ongoing.

Cultural resource types typically found in the surrounding areas include prehistoric open camps, lithic scatters, historic ditches, historic structures, historic trash scatters/dumps and isolated prehistoric and historic finds. “Historic properties” are cultural resources that are eligible or potentially eligible for inclusion on the NRHP. Isolated finds are by definition not eligible to the NRHP.

54 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Although no known eligible sites within the Areas of Potential Effect will be affected, indirect, short-term cumulative impacts from the temporary increased access and the presence of project personnel could result in a range of impacts to known and undiscovered cultural resources in the vicinity of the project location. These impacts could range from accidental damage or vandalism to illegal collection and excavation.

In addition to site specific COA’s, a Standard Education/Discovery COA for cultural resource protection would be attached to the APDs as a COA (see Appendix). The importance of all cultural COAs would be stressed to the operator and their contractors, including informing them of their responsibilities to protect and report any cultural resources encountered during construction operations.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to cultural resources from project implementation would be avoided. Impacts related to vandalism or accidental disturbance of previously unidentified cultural resources would continue for the next 25 to 30 years of operation of the existing wells, but at a lower level than under the Proposed Action.

4.3. FOSSIL RESOURCES

Affected Environment

The predominant bedrock formations present at or near the surface within the project area are the Shire member of the Wasatch Formation (including the Fort Union Formation or equivalent at its base) and the Anvil Points, Garden Gulch, and Parachute Creek members of the Green River Formation. Both formations are overlain by areas of Quaternary gravels and earthflow deposits. Occurring in varying thicknesses, these Quaternary sediments are considered Potential Fossil Yield Classification Class 2, defined as having a low probability of fossil occurrence. Class 2 geologic units are not likely to contain vertebrate or scientifically significant invertebrate fossils.

Both the Wasatch and Green River Formations are considered BLM Condition 5 formations, defined as an area that is known to contain vertebrate fossils or noteworthy occurrences of invertebrate fossils. These types of fossils are known to occur or have been documented, but may vary in occurrence and predictability. The Wasatch Formation is divided into the early Eocene Shire, and the Paleocene Molina and Atwell Gulch members, while the Eocene Green River Formation is divided into the Parachute Creek, Garden Gulch, Douglas Arch, Cow Ridge, and Anvil Points members.

All members of the Wasatch Formation contain vertebrate fossils in varying abundances (Murphy and Daitch 2007). Rocks of the Wasatch Formation are lithologically similar throughout the Piceance Creek Basin as heterogeneous continental fluvial deposits with interfingering channel sandstone beds and overbank deposits consisting of variegated claystone, mudstone, and siltstone beds (Franczyk et al. 1990). Eocene mammals have been found in the lower part of the Shire member.

Fossils historically identified in the Wasatch are archaic mammals—including marsupials, representatives of two extinct orders of early mammals (pantodonts and creodonts), artiodactyls (deer-like even-toed ungulates), ancestral horses and other perissodactyls (odd-toed ungulates), carnivores, and primates—as well as birds, lizards, turtles, crocodilians, gars and other fishes, freshwater clams, gastropods (snails), and other invertebrates (BLM 1999). 55

55 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The Green River Formation consists of fine-grained lacustrine and fluvial-lacustrine rocks that were deposited in the Eocene Lake Uinta. The lake expanded early in its history, during the Long Point transgression (Johnson 1985), to cover much of the Piceance and Uinta Basins. The Green River Formation has yielded hundreds of invertebrate and plant fossils and more than 60 vertebrate taxa have been described from the formation, including crocodiles, boa constrictors, and birds.

Environmental Consequences

Proposed Action

The locations of roads, pads, and pipelines are primarily located in the Wasatch Formation. The Green River Formation is located north of any surface disturbance, and is not likely to be impacted by the proposed action. Although mapped as the predominant bedrock formation of the project area, field inspection revealed the Wasatch Formation exposed only in a few outcrops found on cliff faces and landslide exposures. Most of the project impacts occur on thick Quaternary deposits. The thickness of the Quaternary sediments cannot be accurately determined, but construction activities have the potential to affect adversely any important fossils present in the underlying Wasatch and Green Formations. The greatest potential for impacts is associated with excavation of shallow bedrock that may be unearthed during well pad and facilities (especially pipeline) construction. In general, alluvium, colluvium, and other unconsolidated sediments are much less likely than bedrock to contain well-preserved fossils.

An examination of the BLM paleontology database indicates that there are 11 known fossil discovery sites within a 1-mile radius of the project area. Areas covered with vegetation and soil cover do not usually yield fossil resources, but inspections should be conducted for proposed facilities that are located on or within 200 feet of Wasatch or Green River Formation bedrock surface exposures. As such, a paleontological survey was conducted by Western Colorado Paleontological Services May 24 and 25, 2017 (GRI Report 1117-03). Bedrock exposures within 200 feet of proposed disturbance were inspected for fossils. Searches resulted in two discoveries. The first (5GF5430) is an isolated vertebrate bone fragment from the Shire Member of the Wasatch Formation. While generally considered scientifically significant, this find is isolated and does not grade into a body fossil, and therefore this locality is determined not scientifically significant. The other find (5GF431) consists of small fragments of marine invertebrate fossils, which are not scientifically significant.

Because of the discoveries during the recent surveys, as well as other paleontological localities in the project vicinity, it is recommended that TEP use a qualified paleontological monitor during construction that would adversely affect bedrock or outcrops.

No Action Alternative

56 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

4.4. GEOLOGY AND MINERALS

Affected Environment

The project area is located near the eastern margin of the Colorado Plateau physiographic province (Fenneman 1946), a region characterized by dissected plateaus of strong relief. A broad, asymmetric, southeast-northwest trending structural basin, the Piceance Basin contains stratified sediments ranging in age from Cambrian through middle Tertiary up to 20,000 feet thick. The basin lies between the White River uplift to the northeast, the Gunnison uplift to the south, and the Uncompahgre swell to the west (George 1927, Weiner and Haun 1960). Table 28 lists the geologic formations within the project area.

Table 28. Geologic Formations within the Project Area Map Formation Name Age Characteristics Location Symbol Unconsolidated Subangular to subrounded pebble, Streams, outwash, and Qg Pleistocene gravel deposits. cobble, and boulder gravels. terraces. Fine-to coarse-grained sandstone Tgl Green River Tertiary and few layers of siltstone and oil Outcrops and ledges. shale. Variegated claystone, some Steep slopes and Two Wasatch Tertiary sandstone and conglomerate. outcrops. Source: Donnell et al. 1989

The predominant bedrock exposures within the proposed development area are the Tertiary Green River and Wasatch Formations. The Green River Formation is composed of alternating layers of fine-grained sandstones and laminated to massive marlstone. The Green River Formation overlies the Wasatch Formation, which consists of variegated siltstone, claystone, and sandstones and ranges from 1,000 to 2,500 feet thick. The Wasatch Formation is underlain unconformably by the Mesaverde Group. The Mesaverde Group is composed of mudstones and sandstones with interlayered coal beds and ranges in thickness from about 3,000 to over 7,000 feet. The Mesaverde Group has also been referred to as the Mesaverde Formation, which includes informal subdivisions based on gas productivity characteristics.

The Mesaverde Group is the target zone of the proposed drilling program. Comprised of the Williams Fork and Iles Formations, sediments of the Mesaverde Group are marine sandstones transitional to non- marine beds of coal, shale, and sandstone. These sediments were deposited marginal to the great Cretaceous seaway. The oscillating shoreline of this sea, due to the rise and fall of sea level, left behind a complex of transgressive and regressive sedimentary sequences of nearshore and offshore sediments that define the Mesaverde Group.

Production of natural gas and associated liquid condensate is derived from three reservoir intervals in the Wasatch, Williams Fork, and Iles Formations. The latter two make up the Upper Cretaceous Mesaverde Group. The proposed drilling program would target the sandstone sequences of the Upper Williams Fork Formation, which provide most of the natural gas production volumes (Lorenz 1989). The upper portions of the Williams Fork include fluvial point bar, floodplain, and swamp deposits. The Lower Williams Fork Formation includes delta-front, distributary channel, strandplain, lacustrine (lake), and palustrine (swamp) environments (Hemborg 2000), while the sandstones and coalbeds of the Iles Formation were deposited in a wave-dominated coastal setting (Johnson 1989, Lorenz 1989).

The hydrocarbon source rocks are interbedded and thermally mature gas-prone shales, mudstones, siltstones, and coals. The reservoir rocks are the fine to medium-grained Williams Fork 57

57 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

sandstones, varying in thickness from less than 10 feet to more than 50 feet (Spencer and Wilson 1988), creating an interbedded relationship between source and reservoir. The trapping mechanism of the gas is both stratigraphic (related to lithology) and diagenetic (related to post-depositional process).

No commercial deposits of coal, oil shale, uranium, precious metals, limestone, sand and gravel, gypsum, or other leasable, locatable, or salable minerals are believed to occur within or beneath the project area.

Environmental Consequences

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. Substantial reserves have been known since the late 1950s to be trapped within the tight sands of these reservoirs, but only within the last decade, and particularly within the last few years, has the integrated application of new technologies turned the tight gas sands of the Mesaverde Group into a profitable play (Kuuskraa 1997). Natural fracture detection, advanced log analysis, more rigorous well completions and recompletions, and denser spacing have increased the amount of recoverable gas within these reservoirs.

Natural gas production from the proposed wells would contribute to the draining of hydrocarbon-bearing reservoirs within the Mesaverde Group in this area, an action that would be consistent with BLM objectives for mineral production. Hydraulic fracturing would be utilized to create fractures within the formation to allow gas production from the wells. In recent years, public concern has been voiced regard potential impacts of hydraulic fracturing from “micro-earthquakes” and from contamination of freshwater aquifers. Potential impacts of hydraulic fracturing are addressed in the section on Water Quality- Groundwater.

No Action Alternative

4.5. INVASIVE NONNATIVE PLANTS

Affected Environment

State-listed noxious weeds are designated by the Colorado Department of Agriculture. Management of these weeds is regulated under the Colorado Noxious Weed Act, Title 35, Article 5.5. Botanical surveys conducted from April 24 to May 1, 2017 identified state-listed noxious weeds occurring within the BGMDP project area, as well as other nonnative plant species that can also have detrimental impacts on native plant communities (WWE 2017a and WWE 2017b). The proposed project would occur within areas of existing well pads, pipelines, and access roads on a combination of BLM and private lands. In association with these previous disturbances, noxious weeds and other nonnative plant species have become established. Fourteen Colorado State listed noxious weed species were observed within the project area. Noxious weeds were commonly observed near and along existing disturbances such as access roads and pipeline ROWs. Cheatgrass, field bindweed, halogeton, and redstem filaree were observed throughout the project area; however, mapping of these species was not feasible due to their

58 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

widespread abundance. Noxious weeds observed in the project area are described in Table 29. Weed infestations for specific portions of the project area are described below.

The most common problematic plant species not listed by the State of Colorado or by Garfield County and encountered during the survey included annual wheatgrass (Erymopyrum triticeum), Russian-thistle (Salsola iberica), and kochia (Kochia scoparia). All of these species have the potential to become invasive, particularly in disturbed areas.

Table 29. Noxious Weed Observations within the Project Area Common and Scientific State Listing Recorded Locations Name Status Bull thistle Isolated occurrence observed along western B List Cirsium vulgare end of proposed waterline. Thinly scattered throughout the project area Cheatgrass C List along ridgetops and hillsides. More dense Bromus tectorum along valley bottoms. Field bindweed C List Scattered along existing disturbances. Convolvulus arvensis Halogeton B List Scattered along existing disturbances. Halogeton glomeratus Hounds-tongue Found scattered along drainages outside the B List Cynoglossum officinale noxious weed buffer. Observed scattered inside and outside the Musk thistle B List noxious weed buffer near the RWF 23-19 Carduus nutans Frac Pad. Redstem filaree Common along areas of previous C List Erodium cicutarium disturbance. Russian knapweed Observed in an isolated patch near existing B List Acroptilon repens well pad. Scotch thistle B List Isolated occurrence near PA 23-25 Frac Pad. Onopordum acanthium Tamarisk Found in scattered patches throughout the B List Tamarix ramosissima project area. Source: WWE 2017a.

Expansion of the PA 22-25 Pad plus New PA 23-25 Frac Pad. One State List B noxious weed species (Scotch thistle - Onopordum acanthium) is present in an isolated occurrence near the PA 23-25 Frac Pad. One State List B noxious weed species (Tamarisk – Tamarix ramosissima) is present in the area proposed for additional disturbance on the PA 22-25 Pad.

Surface Frac Lines between PA 23-26 Pad and 23-25 Frac Pad. Two State List B noxious weed species are present along the route of the surface frac lines, Tamarisk and Hounds-tongue (Cynoglossum officinale).

Expansion of the PA 23-26 Pad. No noxious weeds were found within the survey area for the PA 23-26 Pad or the nearby Tank Pad.

Expansion of the RWF 13-19 Pad. No noxious weeds were found within the survey area for the RWF 13-19 Pad.

59 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Expansion of the RWF 23-19 Frac Pad. One State List B noxious weed species (Musk thistle Carduus nutans) is present in an isolated occurrence near the RWF 23-19 Frac Pad. Additional occurrences were found within the survey area for special status plants but outside of the weed survey buffer.

Environmental Consequences

Proposed Action

Under the Proposed Action, a total of 41.47 acres would be disturbed, including 25.00 acres on BLM land and 16.47 acres on private land. Following construction, drilling, and well completions, interim reclamation would occur on all areas not needed for ongoing operations. A total of 8.30 acres would remain as long-term disturbance, including 4.66 acres on BLM land and 3.64 acres on private land. Temporary reclamation on BLM land would consist of seeding with native plant species in accordance with the reclamation COAs presented in the Appendix. The composition of seed mixes used for reclamation on private lands would be at the discretion of the landowner.

Surface-disturbing activities, such as those proposed for this project, provide an opportunity for the invasion and establishment of nonnative plant species, particularly when these species are already present in the surrounding area. The mechanisms for this invasion and establishment are three-fold. Removal of native vegetation removes the competition from native plants for resources, including water and soil nutrients, opening up niches for invasive species (Parendes and Jones 2000). Linear disturbances, such as roads, provide corridors of connected habitat along which invasive plants can easily spread (Gelbard and Belnap 2003). Well pad construction and subsequent well drilling and operations activities, as well as new road construction and installation of gathering lines and pipelines, require construction equipment and motorized vehicles which often transport invasive plant seeds either alone or in mud clods on the vehicle undercarriage or tires and deposit them in disturbed habitats along access roads and at well pad sites (Zwaenepoel et. al. 2006; Schmidt 1989).

Noxious weeds and other invasive species are well adapted to colonize and dominate in disturbed ground. They generally do not require well-developed soils, can out-compete native species for resources, produce prodigious quantities of seeds, and have seeds that can survive for many years or even decades within the soil. When weeds establish on a site, they can also significantly alter the composition of the soil microbial community of bacteria and fungi, making it increasingly more difficult over time for native species to reestablish on the site (Hierro et. al. 2006, Reinhart and Callaway 2006, Vinton and Goergen 2006, Vogelsgang and Bever 2009). Due to the quantity and longevity of weed seeds and the effects of weeds on the soil, once these invasive species have established on a site they are difficult to eliminate.

Most of the project area has a history of disturbance associated with oil and gas development, and all of the project area has a history of livestock grazing. As a result, noxious weed occurrences are concentrated primarily near existing disturbance areas, although species that readily attach to the hair of livestock, such as hounds-tongue and cheatgrass, are more widely scattered. However, much of the previously undisturbed areas are essentially free of noxious weeds and other non-native species. With new project disturbances, the potential for increased establishment of noxious weeds and other undesirable plants following construction activities is high. Movement of soil by construction equipment could be expected to spread weed seeds throughout the project area, and the total area of disturbed habitat would increase. Vehicles and equipment could also transport new noxious weed species to the site, where they would have disturbed habitats in which to establish.

Installation of temporary surface pipelines would cause minimal disturbance, however workers and vehicles installing the pipeline could act as vectors to spread weed seeds. Cheatgrass and hounds-tongue 60

60 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

in particular have seeds that attach easily to clothing if personnel walk through existing occurrences. If the ground is wet and muddy, weed seeds could also be transported in mud sticking to boots. To mitigate the invasive species risk, treatment of existing noxious weed infestations would be required prior to starting construction, and the standard weed control COA would be attached to APDs to require periodic monitoring and weed control practices to ensure that these weedy plants are controlled (Appendix). Establishment of native plant species is also crucial in preventing the establishment and spread of invasive nonnative plant species. Therefore, the standard reclamation COAs would also be attached to APDs to require seeding with an appropriate native seed mix and monitoring of reclamation seeding results (Appendix).

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Impacts associated with new or expanding weed infestations during implementation of the Proposed Action would not occur. However, impacts associated with ongoing well production and with other activities and resource uses, including grazing of livestock, and with natural processes such as drought and wildland fires, would continue.

4.6. LANDS WITH WILDERNESS CHARACTERISTICS

Affected Environment

The Southeast Cliff Unit was found to contain wilderness characteristics in the updated inventory report of February 2016. The unit of 13,705 acres is located in Garfield County, approximately 4 miles northwest of Rifle. The unit’s northern boundary is located on the southeastern and southern cliff edge of the Roan Plateau and includes lands south of the JQS road, east of Cottonwood Gulch, and north of private lands located north of I-70. The Southeast Cliff Unit was found to have wilderness characteristics in 2014 was updated to include lands farther south and west based on new information.

Naturalness. Due to the unit’s steep and rugged topography and lack of public access routes, most of the area is inaccessible and appears to have been affected primarily by the forces of nature. The unit's boundaries were created to exclude all wilderness inventory roads (including oil and gas pad access roads) and oil and gas pads and associated developments (including surface pipelines or obviously disturbed linear area with underground pipelines). In addition, unnatural areas were excluded around the West Garfield landfill where trash had dispersed onto public land, and the waste oil shale depository.

Outstanding Opportunities for Solitude. The Southeast Cliff Unit provides visitors a variety of outstanding opportunities for solitude in some remote portions of the unit. The rugged topography and diverse vegetation provide natural screening and opportunities for seclusion in some areas. Outside sights and sounds are apparent in other areas of the unit. However, outstanding opportunities do not have to be everywhere in the unit for these criteria to be present.

Outstanding Opportunities for Primitive and Unconfined Recreation. The Southeast Cliff Unit offers visitors outstanding opportunities for primitive and unconfined recreation. Access is limited due to surrounding private land and the steepness of the cliffs. This, along with difficult terrain, restricts most visitors to undeveloped recreation activities in most of the unit excluding the top 113 acres on top of the plateau. However, visitors have excellent opportunities to enjoy undeveloped types of recreation such as hiking, backpacking, sightseeing, camping, wildlife viewing, and hunting in the portions where they can access. 61

61 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Supplemental Values. Portions of this unit were identified as “Significant” conservation sites for biodiversity by the CNHP in 1996. One element, the Parachute penstemon, has been found in only one other location. The unit includes the “Yellow Slide,” which historically has been claimed, probably erroneously, to be a meteor impact site. The unit supports multiple elements identified by the CNHP report, including 1) cliff-nesting raptors such as the American peregrine falcon and golden eagle; 2) two watch-listed butterfly species; 3) several oil shale endemic plants including the Parachute penstemon; 4) montane grasslands; 5) excellent scenic opportunities; 6) big game refuge (security, seclusion) areas important during hunting seasons; and 7) geologic values.

Environmental Consequences

Proposed Action

Expansion on and between the RWF 13-19 Pad and the RWF 23-19 Pad would change the naturalness boundary of the Southeast Cliff unit by removing less than 3 acres. Expansion to PA 23-26 Pad would also change the naturalness boundary by removing less than 4 acres. The BGMDP surface frac lines (welded steel lines) would create a temporary linear surface feature across 6S 95W sec. 25 and 26. This would change the naturalness boundary by eliminating 198 acres between PA 23-26 Pad and PA 22-25 Pad south of the frac lines at the time they existed on the ground. Therefore, the total unit would decrease in size from 13,705 acres to about 13,500 acres to keep the unit natural. However, these frac lines are temporary so that long-term impact is minimal, as the boundary would be re-adjusted in the future once the frac lines were removed. This would not affect outstanding opportunities for solitude or primitive and unconfined recreation, nor the supplemental values of the unit.

The Roan Plateau Planning Area Record of Decision and Approved Resource Management Plan Amendment (BLM 2016a) made the decision that the BLM would not manage to protect wilderness characteristics for this unit.

No Action Alternative

4.7. NATIVE AMERICAN RELIGIOUS CONCERNS

Affected Environment

The proposed Balzac Gulch Master Development Plan project is located within a larger area identified by the Ute Tribes as part of their ancestral homeland. A cultural resource inventory specific to this project was completed in addition to a number of previous inventories (see section on Cultural Resources) were conducted to determine if there were any areas that might be culturally sensitive to Native Americans. Although numerous cultural resources were identified in this and prior inventories; no historic properties are currently known to be located in the project’s Area of Potential Effect.

62 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Environmental Consequences

Proposed Action

At present, no Native American concerns are known within the project area and none were identified during the inventories. The proposed Balzac Gulch Master Development Plan project is located within a larger area identified by the Ute Tribes as part of their ancestral homeland. Several cultural resource inventories (see the section on Cultural Resources) were conducted specifically for this project to determine if there were any areas that might be culturally sensitive to Native Americans. No areas were identified during the inventories and none are currently known by the CRVFO within the proposed Balzac Gulch Master Development Plan project area. If new data are identified or disclosed, new terms and conditions may have to be negotiated to accommodate their concerns. Although the Proposed Action would have no direct impacts, increased access and personnel at the site could indirectly impact previously unidentified Native American resources ranging from illegal collection to vandalism.

The NHPA requires that if newly discovered cultural resources are identified during project implementation, work in that area must stop and the agency Authorized Officer notified immediately (36 CFR 800.13). The Native American Graves Protection and Repatriation Act (NAGPRA), requires that if inadvertent discovery of Native American Remains or Objects occurs, activity must cease in the area of discovery, a reasonable effort made to protect the item(s) discovered, and immediate notice made to the agency Authorized Officer, as well as the appropriate Native American group(s) (IV.C.2). Notice may be followed by a 30-day delay (NAGPRA Section 3(d)).

Further actions also require compliance under the provisions of NHPA and the Archaeological Resource Protection Act. Black Hills Plateau Production, LLC will notify its staff and contractors of the requirement under the NHPA, that work must cease if cultural resources are found during project operations. A standard Education/Discovery COA for the protection of Native American values would be attached to the ROW Agreement (see Appendix). The importance of these COAs should be stressed to the operator and its contractors, including informing them of their responsibilities to protect and report any cultural resources encountered. The operator and its contractors would be made aware of the requirements under the NAGPRA.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to Native American religious concerns associated with implementation of the Proposed Action would not occur. Potential impacts due to vandalism or accidental disturbance of previously unidentified cultural resources would be reduced compared to the Proposed Action but not eliminated.

4.8. NOISE

Affected Environment

The project area is located about 4.5 miles northeast of the Town of Parachute and about 4.25 miles west of the City of Rifle in a rural setting characterized by I-70 traffic, oil and gas development, wildlife habitat, ranching, and sparse residences. Noise levels in the area are generally created by traffic on roads and by activities associated with oil and gas development, the latter primarily during construction,

63 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

drilling, and completion activities. The nearest residence is more than 2,000 feet to the east of the PA 22- 25 pad. Commercial buildings are located about 350 feet from the PA 22-25 pad.

Noise is generally described as unwanted sound and may be measured with an A-weighted decibel (dBA) scale. The decibel scale is logarithmic, not linear, because the range of sound that can be detected by the human ear is so great that it is convenient to compress the scale. A dBA scale accounts for the lesser sensitivity of the human ear to low and high frequencies, which are in turn weighted less on the dBA scale than on the standard dB scale. Each 10-unit increase on the decibel scale increases the sound intensity by a factor of 10.

Sound levels have been calculated for areas that exhibit typical land uses and population densities. In rural recreational areas, ambient sound levels are typically 30 to 40 dBA (EPA 1974, Harris 1991). As a basis for comparison, the sound level of a normal conversation between two people standing five feet apart is 60 dBA.

Environmental Consequences

Proposed Action

The Proposed Action would increase the frequency of noise. Noise levels would increase during construction activities, well drilling and completions, and periodic maintenance activities. The noise would be most noticeable along the roads used to haul equipment and at the pad location.

Drilling, completion, and operation of oil and gas wells and production facilities are subject to COGCC noise control regulations (COGCC 2014). Oil and gas operations at any well site, production facility, or gas facility are to comply with COGCC’s maximum permissible noise levels (Table 30) at a distance of 350 feet from the noise source. During the daytime, noise levels may be increased 10 dBA for a period not to exceed 15 minutes in any 1-hour period. The allowable noise level for periodic, impulsive, or shrill noises is reduced by 5 dBA from the levels shown. Operations involving pipeline or gas facility installation or maintenance, the use of a drilling rig, completion rig, and workover rig are subject to the maximum permissible noise levels for industrial zones.

Given the location of the project activities and current activities in the area, the light industrial standard is applicable. The allowable noise level for periodic impulsive or shrill noises is reduced by 5 dBA from the levels shown (COGCC 2014).

Table 30. COGCC Maximum Permissible Noise Levels

Noise Level at 350 feet from the Source (dBA) Zone Daytime Nighttime (7:00 A.M. to 7:00 P.M.) (7:00 P.M. to 7:00 A.M.) Residential/Agricultural/Rural 55 50 Light Industrial 70 65 Industrial 80 75 Source: COGCC 2014

Short-term increases in noise levels would characterize the pipeline, road, and well pad construction. Based on the Inverse Square Law of Noise Propagation (Harris 1991), the typical noise level for

64 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

construction sites is about 68 dBA at 350 feet (Table 31). Project-related noise levels would be approximately 59 dBA at a distance of 1,000 feet, approximating active commercial areas (EPA 1974).

Table 31. Noise Levels at Typical Construction Sites and along Access Roads

Noise Level (dBA) Equipment 50 feet 350 feet 1,000 feet Air Compressor, Concrete Pump 82 65 56 Backhoe 85 68 59 Bulldozer 89 72 63 Crane 88 71 62 Front End Loader 83 66 57 Heavy Truck 88 71 62 Motor Grader 85 68 59 Road Scraper 87 70 61 Tractor, Vibrator/Roller 80 63 54 Sources: BLM 1999; La Plata County 2002

Using this information, anticipated noise levels for the project would be equivalent to the noise standards for daytime operations (defined as 7:00 a.m. to 7:00 p.m.) in the light industrial zone at a distance of 350 feet (Tables 30 and 31). At a distance of 2,000 feet (the distance to the nearest residence), the anticipated levels would approximate the daytime standard for the residential/agricultural/rural zone.

Traffic noise would be elevated with implementation of the Proposed Action. The greatest increase would be along access roads during the drilling and completion phases. To minimize truck traffic, the project would use existing water line systems to transport water. Based on the La Plata County data presented in Table 31, approximately 71 dBA of noise (at 350 feet) would be created by each fuel and water truck. Less noise would be created by smaller trucks and passenger vehicles, such as pickup trucks and sport utility vehicles. Although the duration of increased noise from this source would be short, it would occur repeatedly during the drilling and completion phases.

Noise impacts would decrease during the production phase but would remain as background noise. During maintenance and well workover operations, noise levels would temporarily increase above those associated with routine well production.

No Action Alternative

65 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

4.9. REALTY AUTHORIZATIONS

Affected Environment

Within the Balzac Gulch MDP – Phase 1project area, there are numerous existing realty authorizations. Table 32 lists the BLM mineral leases, associated lessees, and various types of rights of way (ROW) and ROW holders located within Section 19, Township 6 South, Range 94 West, 6th P.M.

Table 32. Existing Realty Authorizations within T6S, R94W, Section 19, 6th P.M.

Oil and Gas Leases and Realty Action Serial Numbers Communitization Agreements Powerlines Access Roads Pipelines Other Leases COC27868 -Terra COC62160 -Terra COC70860-Terra COC40249 - DOE- COC69836 -Terra? COC30381 - Quest COC74870 -Terra Communitization WAPA COC76427 - Terra Corporation COC748780A - Agreement(s) COC73900 - Terra Terra COC42343 -Terra COC4234 4 - Terra COC60132-Terra

There are two oil and gas leases held by Terra that cover the project area within Section 19, T6S, R94W: lease (COC62160) covers Lots 3-8 and Lots 13-15; and lease (COC27868) covers Lots 9-12 and Lots 16- 18. Three Communitization Agreements are also authorized to Terra (CAs) in Section 19:

o CA (COC42343) covering gas production from the Wasatch Formation in Lots 3, 4, 9, and 10 o CA (COC42344) covering gas production from the Mesaverde Formation in Lots 3-10 o CA (COC60132) covering gas production from the Mesaverde Formation in Lots 11-18

Quest Corporation held a BLM ROW (COC30381) for a buried telephone line in Lot 3, which was recently relinquished and closed in 2017.

The Department of Energy (DOE) Western Area Power Administration (WAPA) holds a BLM ROW (COC40249) in lots 9 and 10, which allows the use of the DOE 1-M-19 well pad and access to the pad across the existing BLM road. Since the transfer of Naval Oil Shale Reserves 1 and 3 from the DOE to the BLM in the late 1990s, this ROW is no longer necessary and would be subject to relinquishment by the BLM as time allows.

Pipeline ROW (COC70860) issued to Terra authorizes the operation of a 24-inch buried natural gas gathering line from the Webster Hill compressor to the Rabbit Bush compressor in Section 19, Lots 9, 10, 12, and 13. In that same corridor, Terra also holds ROW (COC74870) for a 10-inch produced water pipeline that runs from the PA 22-35 well pad in the NW¼ of Section 30, and ROW (COC74780A) for a 6-inch produced water pipeline that runs from the Rulison Evaporation Facility in Section 20.

Other existing ROW authorizations in Section 19 include:

o COC69836 issued to Anvil Points authorizing an 8-acre spent oil shale repository o COC76427 issued to Terra which authorizes produced water disposal within federal pore space in Lot 12, Section 19 emanating from a fee well (RMV 205-20) located in SW¼NW¼ of Section 20 66

66 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

o COC73900 issued to Terra which authorizes produced water disposal within federal pore space from two fee wells (RWF 32-30 and RWF 332-40 pads) situated in Lot 17 and as allowed under the terms of a communitization agreement

Table 33 lists the BLM mineral leases, associated lessees and various types of rights of way (ROW) and ROW holders located within Sections 25, 26, and 27, Township 6 South, Range 94 West, Sixth P.M.

Table 33. Existing Realty Authorizations within T6S, R94W, Sections 25-27, 6th P.M.

Oil and Gas Leases and Realty Action Serial Numbers Communitization Agreements Powerlines Access Roads Pipelines Other Leases COC62161-Terra COC73094 -Terra COC63150 - Mobil COC66404 - Terra COC70860 - Terra Communitization Oil Corp COC66664 - Terra COC35161- COC74870 - Terra Agreement(s) COC76267 - Terra PSCo COC748780A - COC62730 -Terra COC63154 - COC76268 - Terra Terra COC62731 - Terra Mobil Oil Corp COC76269 - Terra COC62732 -Terra COC66630 -Terra COC66631-Terra

Two oil and gas leases held be Terra cover the project area within Section 19, T6S, R94W:

o Lease (COC62161) covering Lots 3-6 and N½SW¼ of Section 26 and Lots 1-8 and W½W½ and N½SE¼ in Section 27 o Lease (COC73094) covering the NW¼NE¼, N½NW¼, SW¼NW¼, NW¼SW¼ in Section 25, and Lots 1,2,7,8, and N½SE¼, SW¼SE¼ in Section 26

Five Communitization Agreements (CAs) are authorized to Terra within the Sections listed:

o CA (COC62730) covering gas production from the Wasatch Formation in the SW¼ of Section 26 o CA (COC62731) covering gas production from the Wasatch Formation in the SE¼ of Section 27 o CA (COC62732) covering gas production from the Wasatch Formation in the SW¼ of Section 27 o CA (COC66630) covering gas production from the Mesaverde Formation in Lots 3-6 and the SW½ of Section 26 o CA (COC66631) covering gas production from the Mesaverde Formation in the S½ of Section 27

Public Service Company of Colorado (PSCo) holds a BLM right-of-way (COC63561) for a 13.1 mile, 69kv, Shoshone-Palisade overhead electric transmission line in the NW¼ of Section 25.

Mobil Oil Corp holds two authorizations: COC63154 for 3.15 miles of access road easement in the S½SW¼ of Section 26, and COC63150 for 6.65 miles of road easement in the S½SW¼ of Section 27.

Pipeline ROW (COC70860) was issued to Terra authorizing the operation of a 24-inch buried natural gas gathering line from the Webster Hill compressor to the Rabbit Bush compressor in Lots 9, 10, 12, 13. In that same corridor, Terra is also authorized ROW (COC74870) for a 10-inch produced water pipeline that

67 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

runs from the RWF 22-35 well pad in the NW¼ of Section 30, and ROW (COC74780A) for a 6-inch produced water pipeline that runs from the Rulison Evaporation Facility in Section 20.

Other existing ROW authorizations include:

o Department of Energy (DOE) Naval Oil Shale Reserve (NOSR) ROW (COC66404) in the SE¼SW¼ of Section 27; o Department of Energy (DOE) Naval Oil Shale Reserve (NOSR) ROW (COC66664) in the SW¼S½ of Sections 26 and 27; o Terra ROW (COC76267) for a salt water disposal (SWD) well number DOE 1- W-26 and a 4- inch buried Flexsteel produced water pipeline located in Lot 6 and the NE¼SW¼ of Section 26 and SE¼SE¼ of Section 27; o Terra ROW (COC76268) for SWD well number DOE 1- W-27 and a 4-inch buried Flexsteel produced water pipeline located in NW¼SE¼ of Section 27; o Terra ROW (COC76269) for SWD well number DOE 2- W-27 and a 4-inch buried Flexsteel produced water pipeline located in NE¼SE¼ and SE¼SE¼ of Section 27. o Tosco Corp and Puckett Land Co. held ROW (COC66659) for a 1.63 mile-long easement on an access road in the SE¼SE¼ of Section 26; the road was closed in 2013. Environmental Consequences

Proposed Action

Table 5 lists the eight various ROWs to be issued allowing the development of Federal wells that are being drilled into the adjacent Federal lease (COC73094) essentially from two existing yet expanded locations known as the PA 23-26 pad and the RWF 13-19 pad (Figure 1). Potential impacts to any of the existing BLM rights-of-way (ROWs) listed in Tables 32 and 33 by the lease operations or ROWs proposed by Terra would be mitigated based on written maintenance and use agreements between Terra and the various existing ROW holders.

No Action Alternative

4.10. SOCIOECONOMICS

Affected Environment

The project area is located in Garfield County, which has a land area of 2,958 square miles (Garfield County 2016). The county seat is Glenwood Springs; other municipalities include Carbondale, New Castle, Silt, Rifle, Parachute, and Battlement Mesa. I-70 traverses the county east to west with a network of county and private roads servicing the project area.

68 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The western portion of Garfield County contains the majority of the County’s oil and gas development. The eastern portion is more heavily influenced by socioeconomic trends related to locally available tourism and recreation resources, as well as those nearby in Aspen, Beaver Creek, and Vail. The population of the county grew an annual average of approximately 2.5% from 2000 to 2009, but decreased to an annual average growth of 0.8% from 2010 to 2015 due to the national economic downturn, resulting in a net increase of 27% from 44,240 to 58,082 residents (Colorado Department of Local Affairs [CDOLA] 2016). The population in Garfield County is forecasted to nearly double to 112,684 residents in 2050 (CDOLA 2015). According to the most recent census that was conducted in 2010, Garfield County has a population density of 19 people per square mile, with approximately ¾ of the population residing in urban areas and ¼ of the population in rural areas (U.S. Census Bureau 2012). The total civilian preliminary labor force (not seasonally adjusted) for Garfield County was 29,463 people in October 2016; the unemployment rate was 3.2% (Colorado Department of Labor and Employment [CDLE] 2016). In the second quarter of 2016, the industry groups with the highest percentage of people employed in the County were Health Care and Social Assistance (13%), Accommodation and Food Services (12%), Construction (12%), Retail Trade (12%), and Education Services (11%). Table 34 lists the top 10 industries in Garfield County for the second quarter of 2016. Table 34. Top Industry Sectors of Garfield County, Second Quarter 2016

Rank Job Sector Employees 1 Health Care and Social Assistance 3,328 2 Accommodation and Food Services 3,135 3 Construction 3,123 4 Retail Trade 3,115 5 Education Services 2,732 6 Public Administration 1,779 7 Administration, Support, Waste Management, and Remediation 1,318 8 Professional, Scientific, and Technical Services 1,095 9 Mining 1,002 10 Transportation and Warehousing 766 Total 21,393 Mean Total Number of People Employed in the County 25,832 County’s Employed Labor Force in the Top Ten Industry Sectors 83% Source: Garfield County 2016

Annual personal income in Garfield County has also risen, growing from $1.38 billion in 2000 to $2.94 billion in 2015 (U.S. Bureau of Economic Analysis 2016). Annual personal income decreased from $2.47 billion in 2008 to $2.04 billion in 2010, but has been steadily increasing since 2010. Similarly, annual per capita income decreased from $44,490 in 2008 to $36,387 in 2010, but has annually increased at a mean rate of 6% from $36,387 in 2010 to $50,556 in 2015. Based on the 2010 U.S. Census, Garfield County has 23,301 housing units (Garfield County 2016a). Approximately one-third of the population rents and the other two-thirds are homeowners. Housing prices vary; however, all of the municipalities except Parachute have median housing prices higher than the State. The communities of Parachute, Rifle, Silt, and New Castle (the western portion of Garfield County) are considered to have the most affordable housing, while the communities of Glenwood Springs 69

69 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

and Carbondale have the least affordable housing, which is largely influenced by more limited space for residential development and greater proximity to resort facilities. The County has a very low vacancy rate of 3.65%. Garfield County’s current economy is similar to its historic economy, i.e., based on natural resource development, agriculture, regional services, and tourism. The population and development is concentrated in the Roaring Fork and Colorado River valleys, balancing the expanse of public lands (comprising 60% of the County) and lightly populated areas. Natural resource development, specifically natural gas, in the western portion of the County is a major contributor of the economy. Production of natural gas in Garfield County increased dramatically between 2000 and 2012, from 70 billion cubic feet (BCF) in 2000 to 702 BCF in 2012 (COGCC 2016). This natural gas boom was partly driven by a rise in prices. Gas prices declined since 2012, consequently decreasing natural gas production in the County. Natural gas production in the County has been decreasing annually since 2012. In 2015, the County produced 556 BCF of natural gas. The State of Colorado issued 2,269 permits to drill in 2015, which was a decrease from the 4,190 permits issued in 2014 (COGCC 2015). Garfield County was the second-most active county in the State, issuing 495 permits to drill in 2015 (down from 1,066 permits in 2014). Property tax revenue, payments in lieu of taxes (PILT), and Federal mineral royalties benefit State and local governments. Property tax revenue from oil and gas development is a major source of public revenue in Garfield County. In 2015, the oil and gas assessed valuation in Garfield County was approximately $2.4 billion, or about 70% of the total property tax assessed valuation (Garfield County 2016b). The PILT are distributed by the Federal government to local governments to offset losses in property taxes due to nontaxable Federal lands within their boundaries and compensate for the costs to support such lands. In Fiscal Year 2016, Garfield County received approximately $3 million (U.S. Department of the Interior 2016). Federal mineral royalties are levied on oil and gas produced from Federal mineral leases. Lessees pay royalties equal to 12.5% of the wellhead value of oil and gas produced from public land. About half of the royalties are distributed to State and local governments. The NEPA process requires a review of the environmental justice issues as established by Executive Order 12898 (February 11, 1994). The order established that each Federal agency identify any “disproportionately high and adverse human health or environment effects of its programs, policies, and activities on minority and low-income populations.” In accordance with guidance from the Council on Environmental Quality (CEQ), minority populations should be identified when either the minority population of the affected area exceeds 50%, or the minority population of the affected areas is 10% greater than the surrounding area. Low-income populations should be identified when the low-income population of the affected areas is 10% greater than the surrounding area. In consideration of the Proposed Action, minority and low-income populations were not meaningfully greater than the surrounding area; therefore, environmental justice is not analyzed further. Environmental Consequences

Proposed Action

The Proposed Action would have minor positive impacts on the local economy of Garfield County through the creation of additional job opportunities in the oil and gas industry and in supporting trades and services. In addition, Garfield County would receive additional tax and royalty revenues. The Proposed Action could result in negative social impacts including changing the character of the area, reducing scenic quality, increasing dust levels especially during construction, and increasing traffic.

70 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

No Action Alternative

4.11. SOILS

Affected Environment

The locations of the Proposed Action are generally south-to-southeast-facing at elevations between 5,160 and 5,750 feet amsl, and slopes ranging from 3% to 75%. Six soil types would be disturbed and are described in Table 35 (U.S. Department of Agriculture [USDA] 2016), arranged by decreasing proportion of the proposed disturbance area.

Table 35. Soil Description of the Balzac Gulch - Phase 1 Development Area Disturbance Project Soil Map Unit Description (acres) Components PA 23-26 well pad, Well-drained soils on mountainsides. Originates from access road, and stony, basaltic alluvium derived from sandstone and 66 – 75% of pipelines shale. The topsoil depth is 4 inches with variable soil Torriorthents- PA 23-26 Tank and rock. Non-saline to very slightly saline. Rapid Camborthids- 12.6 Farm runoff. Moderately low to moderately high Rock outcrop 10% of RWF 23-19 permeability. Very severe erosion hazard. complex, steep Frac pad Reclamation may be challenging due to steep slopes, DOE 1-W-26 water erosion, and rock outcrops. Cuttings Well-drained soil on alluvial fans and valley sides. RWF 13-19 well Originates from alluvium derived from basalt and/or pad, access road, alluvium derived from sandstone and shale. The 59 – Potts- water line, oil topsoil varies from a 4-inch-thick loam to an 8-inch- Ildefonso lines, 6-inch gas thick stony loam. Non-saline to slightly saline. 11.6 complex, 25 to line, 59% of 8- Moderate to very rapid runoff. Moderately high to 45% slopes inch gas line high permeability. Severe erosion hazard. 90% of RWF 23-19 Reclamation may be challenging due to steep slopes, Frac Pad large rock fragments, and water erosion. Well-drained soil on terraces and fans. Originates from highly saline alluvium derived from sandstone PA 22-25 well pad, 3 – Arvada and shale. The topsoil is a 3-inch loam. Slightly water line, and loam, 1 to 6% saline to strongly saline. Rapid runoff. Moderately 11.6 49% of gas line slopes low to moderately high permeability. High shrink- PA 23-25 Frac Pad swell. Slight erosion hazard. Reclamation may be and access road challenging due to excessive sodium and salt.

71 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Disturbance Project Soil Map Unit Description (acres) Components Well-drained soil on alluvial fans and valley sides. Originates from alluvium derived from sandstone and shale. The topsoil is an 11-inch-thick channery loam. 51% of PA 22-25 47 – Nihill Slow runoff. Non-saline to slightly saline. gas line channery loam, 3.1 Moderately high to high permeability. Moderate 13% of RWF 13-19 6 to 25% slopes erosion hazard. Reclamation may be challenging due gas line to steeper slopes, large rock fragments, and water erosion. Well-drained soil on breaks and hillsides. Originates from very calcareous, mixed, stony alluvium derived from basalt. The topsoil varies from a 4-inch-thick 35 – Ildefonso- gravelly loam to an 8-inch-thick stony loam. Non- 28% of RWF 13-19 Lazear complex, 1.8 saline to slightly saline. Moderate to very rapid gas line 6 to 65% slopes runoff. Low to high permeability. Moderate erosion hazard. Reclamation may be challenging due to steep slopes, large rock fragments, and water erosion. Well-drained soil on valley sides and mesas. Originates from alluvium derived from basalt and/or alluvium derived from sandstone and shale. The 57 – Potts- topsoil varies from a 4-inch-thick loam to an 8-inch- Ildefonso 25% of PA 23-26 thick stony loam. Non-saline to slightly saline. Slow 0.9 complex, 3 to pipelines to rapid runoff. Moderately high to high 12% slopes permeability. Slight erosion hazard. Reclamation may be challenging due to steep slopes, large rock fragments, and water erosion. Sources: USDA 2016

Environmental Consequences

Proposed Action

The majority of the proposed disturbance area (62%) is either existing or previously disturbed (Table 6). While the slopes of the proposed disturbance would generally be level to fairly moderate (from 3 to 30%), about 250 feet (100 feet on BLM land) of the western portion of the proposed PA 23-26 pipeline route would traverse 45-to-50-percent slopes of the Torriorthents-Camborthids-Rock outcrop complex (a fragile soil) within an existing ROW. About 430 feet of the surface frac pipeline would descend a 35 to 55% slope; however, this pipeline would be temporary and, in contrast to the other pipelines, would not disturb the surface. The Proposed Action would impact soil characteristics and productivity. Additional potential impacts would include:  Erosion due to water, wind, loss of vegetation, and mass wasting  Compaction and damage to soil structure from heavy construction equipment  Mixing or displacement from grading, excavation, stockpiling, and reclamation  Rutting from equipment or vehicle traffic  Structural damage to wet or frozen soils and soils with poor drainage  Introduction of large stones or rocks into the topsoil

72 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The Proposed Action would increase soil loss, decrease soil productivity, and increase sediment available for transport to surface waters. Infestations of noxious weeds resulting from soil disturbance could also affect soil productivity. The potential for soil transport to surface waters would increase as a function of slope, proximity to streams, and type of disturbance. Impacts would be minimized by implementing stormwater management BMPs, stockpiling and windrowing topsoil, controlling erosion, and rehabilitating disturbed surfaces as quickly as feasible.

In general, the portion of the project area that would be affected by the Proposed Action has level to moderate (from 3 to 30%) slopes that would minimize the potential for sediment transport. However, activities would cause slight increases in local soil loss, loss of soil productivity, and sediment available for transport to surface waters. Potential for such soil loss and transport would increase as a function of slope, feature (pad, road, or pipeline route) to be constructed, and proximity to streams and drainages.

About 58% of the proposed disturbance area has soils with a severe to very severe erosion hazard, and 12% of the area to be disturbed consists of soils with a moderate erosion hazard. Another 28% of the disturbance has high shrink-swell potential. To minimize impacts to fragile soils, the proposed locations of well pads, roads, and pipelines were selected to utilize existing or previously disturbed areas. These existing or previously disturbed areas are stable.

About 250 feet (100 feet on BLM land) of the western portion of the proposed PA 23-26 pipeline route would traverse 45 to 50% slopes of the Torriorthents-Camborthids-Rock outcrop complex within an existing ROW. Despite the very severe erosion hazard rating of this area, the existing pipeline ROW corridor is stable within which the proposed pipeline would be installed. About 430 feet of the surface frac pipeline would descend a slope of 35 to 55% on this same soil with a very severe erosion hazard; however, this pipeline would be temporary and, in contrast to the other pipelines, would not disturb the surface. Particular care would be taken to ensure that proper BMPs, including the COAs listed in the Appendix, are used to prevent erosion and slope instability due to the development.

Long-term soil protection could be achieved by continued road and pad maintenance to reduce erosion (e.g., graveled roads, crowned road surfaces, and storm-water management), minimization of the long- term pad footprints through interim reclamation measures, and remediation of contaminated soils.

During interim and final reclamation, Terra and RRG would be responsible for revegetating the disturbance area until self-sustaining communities of desirable plants have established and for monitoring and controlling infestations of noxious weeds and other invasive non-native plants. Most of the surface disturbance would be temporary and thus reclaimed and revegetated. The stipulations presented in the Appendix for salvaging and handling of soils, revegetation, and control of weeds are expected to result in minimal long-term loss of soil and soil productivity in the project area.

In order to avoid excess material at the PA 23-26 well pad, the drill cuttings from the wells developed at the PA 23-26 pad would be buried adjacent to the steep cut slope of the existing DOE 1-W-26 pad. This additional volume of material would assist the reshaping of the pad to natural contours and facilitate successful interim and final reclamation of the DOE 1-W-26 pad. The Proposed Action includes the following BMPs, which reduce potential soil impacts:  Construction of pads, roads, and pipelines would follow the guidelines established in the BLM Gold Book, Surface Operating Standards for Oil and Gas Exploration and Development (USDI and USDA 2007).  The new access roads would be graveled to ensure all-weather accessibility to the pad sites; existing roads would undergo review for spot-graveling needs. 73

73 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

 During road and pipeline construction, topsoil would be segregated along both sides of the road or along one edge of the pipeline corridor for later placement back onto the reclaimed ROW.  During pad construction, topsoil would be windrowed, where feasible, around the outer edge of the disturbance perimeter to serve as stormwater diversions and catchments, and temporarily seeded until interim reclamation is scheduled after all of the wells on the pad are placed into production.  A closed-loop drilling system would be used during drilling, eliminating the need for a fluid- containing reserve pit. Recovered drilling fluid would be stored on location in steel tanks for reuse.  Drill cuttings would be tested and remediated per COGCC regulations (Table 910-1 standards) prior to reshaping for interim reclamation.  Standard best management practices would be implemented to ensure disturbed areas on pads, roads, and pipelines are reclaimed in a timely manner. No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to soils from implementation of the Proposed Action would not occur. However, impacts associated with other activities and resource uses, including grazing of livestock, and with natural processes such as drought and wildland fires would continue to occur.

4.12. SPECIAL STATUS SPECIES

Federally Listed, Proposed, or Candidate plant Species

Affected Environment

According to the latest species list from the USFWS, two Federally listed plant species may occur within or be impacted by actions occurring in Garfield County. Table 36 lists these species and summarizes information on their habitat associations, potential for occurrence in the project vicinity based on known geographic range and habitats present, and potential for adverse impacts from the Proposed Action. There is no suitable habitat present within or adjacent to the project area for any of these two Federally listed plant species.

Table 36. Potential for Occurrence of Threatened or Endangered Plant Species

Range or Potentially Species and Status Occurrence Habitat Association Habitat in Affected? Vicinity? Rocky hills, mesa slopes, Desert shrubland with and alluvial benches in salt Colorado hookless shadscale, galleta grass, desert shrub communities; cactus black sagebrush, Indian often with well-formed Yes No (Sclerocactus glaucus) ricegrass grading upward microbiotic crusts; can – Threatened into big sagebrush and occur in dense cheatgrass sagebrush/pinyon-juniper 4,500 to 6000 feet

74 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Range or Potentially Species and Status Occurrence Habitat Association Habitat in Affected? Vicinity? Desert shrubland with four Sparsely vegetated, steep wing saltbush, shadscale, slopes in chocolate-brown, DeBeque phacelia greasewood, broom gray, or red clay on Atwell (Phacelia submutica) snakeweed, bottlebrush Yes No Gulch and Shire Members, – Threatened squirreltail and Indian Wasatch Formation; 4,700 ricegrass, grading upward to 6,200 feet into scattered junipers

Environmental Consequences

Proposed Action

Colorado hookless cactus were not observed during surveys conducted from April 24 to May 1, 2017. Additionally, no DeBeque phacelia or its suitable habitat were observed during surveys. Because no occurrences of any Federally listed plant species are known or expected within or near the project area, the Proposed Action, the determination for both Federally listed threatened plant species is “No Effect.”

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to the two Federally listed threatened plant species from implementation of the Proposed Action would not occur. Because no suitable habitat for Colorado hookless cactus or DeBeque phacelia occurs within 300 meters of the project area, the No Action Alternative would have “No Effect” on these species.

BLM Sensitive Plant Species

Affected Environment

The only BLM sensitive plant species with the potential to occur in the project area is De Beque milkvetch (Astragalus debequaeus). De Beque milkvetch occurs on varicolored, fine textured, seleniferous, saline soils of the Atwell Gulch Member of the Wasatch Formation at elevations ranging from 5,100 to 6,400 feet. No De Beque milkvetch were observed during surveys conducted from April 24 to May 1, 2017 (WWE 2017a and 2017b).

Environmental Consequences

Proposed Action

Because no occurrences of De Beque milkvetch are known within or near the project area, the Proposed Action would have no effects on this species.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would 75

75 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to BLM sensitive plant species from implementation of the Proposed Action would not occur. However, any impacts associated with continued operation of the existing oil and gas facilities would extend over the next 25 to 30 years. Impacts resulting from other activities and resource uses, including grazing of livestock, and with natural processes such as drought and wildland fires, would also continue to occur.

Federally Listed, Proposed, or Candidate Wildlife Species

Affected Environment

Federally listed, proposed, or candidate species potentially occurring within or affected by actions in Garfield County include eight species of vertebrate wildlife. Table 37 lists these species and summarizes information on their distribution, habitat associations, and potential to occur or be adversely affected.

Table 37. Potential for Occurrence of Threatened or Endangered Animal Species

Potentially Potentially Species and Status Distribution in Region Preferred Habitats Present in Adversely Vicinity? Affected? Dispersed use in in upper Subalpine spruce-fir Canada lynx (Lynx montane and subalpine forests; also lodgepole canadensis) – No No zones of Colorado pine and aspen to as low as Threatened mountains. upper montane. Yellow-billed cuckoo Major rivers and (Coccyzus americanus), Large cottonwood stands tributaries of western, Distinct Western with tall shrub understory No No northwestern, and south- Population Segment- – along rivers. central Colorado. Threatened No historic occurrence in Mexican spotted owl Rocky cliffs in canyons area; present in (Strix occidentalis with closed-canopy No No southwestern Colorado lucida) – Threatened coniferous forests. and southern Front Range. Razorback sucker General: Deep, slow runs, Colorado River and major (Xyrauchen texanus) – pools, and eddies. Yes Yes tributary rivers, including Endangered Spawning: silt to gravel mainstem Colorado River substrates in shallow water Colorado pikeminnow upstream to town of Rifle and seasonally flooded (Ptychocheilus lucius) – in CRVFO. Yes Yes Endangered overbank areas. Humpback chub (Gila Mainstem Colorado River Yes Yes cypha) -- Endangered and major tributaries – Rocky runs, riffles, and Bonytail chub (Gila upstream to Black Rocks near rapids in swift, deep rivers. Yes Yes elegans) – Endangered Utah state line. *Green Lineage Clean, cool headwaters Colorado River Identified in 60 streams in streams and ponds isolated cutthroat trout Colorado River basin No No from other strains of cutthroat (Oncorhynchus clarki including CRVFO area. trout. ssp.) – Threatened

76 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Potentially Potentially Species and Status Distribution in Region Preferred Habitats Present in Adversely Vicinity? Affected? *Green Lineage = Relict populations of cutthroat trout indigenous to the Colorado/Gunnison/Dolores River drainages. Currently protected under the ESA pursuant to prior listing of the greenback cutthroat trout (O. c. stomias) pending completion of genetic and morphometric studies and taxonomic reassessment of native cutthroat trout in Colorado.

Environmental Consequences

Proposed Action

The Canada lynx, greater sage-grouse, Mexican spotted owl, distinct western population segment of the yellow-billed cuckoo, and Green Lineage Colorado River cutthroat trout are not expected to occur in the project vicinity based on documented occurrences and habitat types present. Therefore, the Proposed Action would have “No Effect” on these species.

Razorback Sucker, Colorado Pikeminnow, Humpback Chub, and Bonytail Chub. These four species of Federally listed big-river fishes occur within the Colorado River drainage basin near or downstream from the project area. Designated Critical Habitat for the razorback sucker and Colorado pikeminnow includes the Colorado River and its 100-year floodplain west (downstream) from the town of Rifle. This portion of the Colorado River lies a few miles northeast of the project area. The nearest known habitat for the humpback chub and bonytail is within the Colorado River approximately 70 miles downstream from the project area. Occasionally, the bonytail is in Colorado west of Grand Junction, but its range does not extend east from that point. Only one population of humpback chub, at Black Rocks west of Grand Junction, is known to exist in Colorado.

The four endangered Colorado River fishes are assumed likely to be affected by the consumptive use of water taken from the Colorado River basin to support activities associated with the Proposed Action. Depletions in flows in the Colorado River and major tributaries are a major source of impacts to these fishes due to changes in the flow regime that reduce the availability and suitability of spawning sites and habitats needed for survival and growth of the larvae. Principal sources of depletion in the Colorado River basin include withdrawals for agricultural or industrial uses, withdrawals for municipal water supplies, and evaporative losses from reservoirs. On average, approximately 0.77 acre-feet of Colorado River water is consumed during activities related to each oil and gas well. This is equivalent to approximately 0.04 cubic feet per second (cfs) of water throughout the typical 10-day drilling period for an oil and gas well in the CRVFO area.

In 2008, the BLM prepared a Programmatic Biological Assessment (PBA) addressing water-depleting activities associated with BLM’s fluid minerals program in the Colorado River Basin in Colorado. In response to this PBA, the USFWS issued a Programmatic Biological Opinion (PBO) (ES/GJ-6-CO-08-F- 0006) on December 19, 2008. The PBO concurred with BLM’s effects determination of “May Affect, Likely to Adversely Affect” for the Colorado pikeminnow, humpback chub, bonytail chub, or razorback sucker as a result of depletions associated with oil and gas projects. To offset the impacts, the BLM has set up a Recovery Agreement, which includes a one-time fee per well. The estimated depletions from the Proposed Action would be added to the CRVFO tracking log and submitted to the USFWS per the PBA/PBO at the end of the year to account for depletions associated with BLM’s fluid mineral program. The calculated mitigation fees are used by the USFWS for mitigation projects and contribute to the recovery of these endangered species through restoration of habitat, propagation, and genetics

77 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

management, instream flow identification and protection, program management, non-native fish management, research, and monitoring, and public education.

Other potential impacts to these species include inflow of sediments from areas of surface disturbance and inflow of chemical pollutants related to oil and gas activities. Construction activities would increase the potential for soil erosion and sedimentation. Although a minor temporary increase in sediment transport to the Colorado River may occur, it is unlikely that the increase would be detectable above current background levels. In any case, the Federally listed, proposed, or candidate fish species associated the Colorado River are adapted to naturally high sediment loads and would not be affected.

In contrast to inflow of sediments, the inflow of chemical pollutants could impact the endangered big- river fishes if concentrations are sufficient to cause acute effects. The potential for adverse impacts would be limited to the Colorado pikeminnow and razorback sucker, the two species known to occur within the CRVFO area. Spills or other releases of chemical pollutants as a result of oil and gas activities are infrequent in the CRVFO area due to the various design requirements imposed by BLM and the State of Colorado. In the event of a spill or accidental release into an ephemeral drainage that could flow to the Colorado River, the operator would be required to implement its Spill Prevention, Control, and Countermeasures (SPCC) plan, including such cleanup and mitigation measures as required by BLM or the State. For these reasons, and because any spills into the Colorado River would be rapidly diluted to levels below that are not deleterious, or even detectable, the potential for adverse impacts from chemical releases is not considered significant.

Based on the above, the BLM has determined that inflow of sediments and chemicals into the Colorado River would have “No Effect” on the endangered big river fishes. In the unlikely event of a spill with the potential to affect, or documented occurrence of an effect, the USFWS would initiate discussions with the involved parties to identify appropriate remedies.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to Federally listed, proposed, or candidate threatened or endangered wildlife species from implementation of the Proposed Action would not occur. However, any impacts associated with continued operation of the existing oil and gas facilities would extend over the next 25 to 30 years. Impacts resulting from other activities and resource uses, including grazing of livestock, and with natural processes such as drought and wildland fires, would also continue to occur.

BLM Sensitive WILDLIFE Species

Affected Environment

Table 38 lists BLM sensitive vertebrate wildlife species that are known to occur in the region and, if present, could potentially be adversely affected by the Proposed Action. Potential impacts to the species listed are discussed following the table.

78 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Table 38. BLM Sensitive Vertebrate Species Present or Potentially Present in the Project Area Potential for Common Name Habitat Occurrence Fringed myotis (Myotis thysanodes) Roosting: Caves, trees, mines, and buildings. Spotted bat Foraging: Pinyon-juniper, montane conifers, and semi-desert Possible (Euderma maculatum) shrubs. Townsend’s big-eared bat (Corynorhinus townsendii) Rocky Mountain bighorn sheep typically inhabit steep, precipitous mountain and canyon terrain with good visibility Rocky Mountain bighorn and escape terrain. The CRVFO includes the Glenwood Absent sheep (Ovis canadensis) Canyon, Derby Creek, Deep Creek and Battlement Mesa herds. Additional herds inhabit nearby USFS lands. Montane and subalpine coniferous forests and aspen forests; Northern goshawk may move to lower elevation pinyon/juniper woodland in Possible (Accipiter gentilis) search of prey during winter. Open, rolling and/or rugged terrain in grasslands and shrub- Ferruginous hawk steppe communities; also grasslands and cultivated fields; (Buteo regalis) Absent nests on cliffs and rocky outcrops. Fall/ winter resident, non-

breeding. Nesting/Roosting: cliffs and trees. Forages widely over open habitats, including grasslands and sagebrush, particularly in Golden eagle areas with abundant rabbits. Suitable mixes of sagebrush and Likely (Aquila chrysaetos) cliffs can support high concentrations. Primary forages include small rodents, lagomorphs, and carrion during winter. Nesting/Roosting: Mature cottonwood forests along rivers. Nests and roosts Bald eagle Foraging: Fish and waterfowl along rivers and lakes; may feed along Colorado (Haliaeetus leucocephalus) on carrion, rabbits, and other foods in winter. River Nesting: Cliffs, usually near a river, large lake, or ocean. Peregrine falcon Foraging: Waterfowl on rivers and lakes; upland fowl in open Likely (Falco peregrinus) grassland or steppe. Sage-grouse are found only in areas where sagebrush is abundant, providing both food and cover. Sage-grouse prefer relatively open sagebrush flats or rolling sagebrush hills. In winter, sagebrush accounts for 100% of the diet for these birds. In late winter, males begin to concentrate on traditional strutting grounds or leks. Females arrive at the leks 1-2 weeks later. Leks can occur on a variety of land types (windswept Greater sage-grouse ridges, knolls, flat areas of sagebrush, and flat bare openings in (Centrocercus Absent the sagebrush. Breeding occurs on the leks and in the adjacent urophasianus) sagebrush, typically from March through May. Females and their chicks remain largely dependent on forbs and insects for food well into early fall. Within the CRVFO, greater sage- grouse are present in the northeastern part of the Field Office in the Northern Eagle/Southern Routt population, and in the northwestern part of the Field Office in the Parachute/Piceance/Roan population. Use a variety of habitats within sagebrush, mountain shrub, and riparian areas. From spring to fall a component of denser Columbian sharp-tailed riparian or mountain shrub vegetation is important for escape grouse (Tympanuchus Absent cover. Winter habitat contains a dominant component of phasianellus columbiana) deciduous trees and shrubs. In Colorado, leks typically occur in sagebrush. 79

79 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Potential for Common Name Habitat Occurrence Nest in colonies on vertical rock faces, near waterfalls or in Black swift (Cypseloides dripping caves. Birds arrive in Colorado in June and take all Absent niger) summer to raise a single nestling. Adults forage widely on aerial insects. Brewer’s sparrow Extensive stands of sagebrush, primarily Wyoming sagebrush Possible (Spizella breweri) on level or undulating Terrain. Midget faded rattlesnake Cold desert of NW Colorado, SW Wyoming, and NE Utah, (Crotalus oreganus primarily in sagebrush with rock outcrops and exposed canyon Possible concolor) walls. Boreal toad (Anaxyrus Habitat is found in montane wetlands and associated uplands Absent boreas) between 8,000 and 11,000 feet in elevation Northern leopard frog Clean, perennial waters in slow-flowing streams, wet Absent (Lithobates pipiens) meadows, marshes, and shallows of clean ponds and lakes. Bluehead sucker Primarily smaller streams with a rock substrate and mid to fast- Present in (Catostomus latipinnis) moving waters; also shallows of larger rivers. Colorado River Flannelmouth sucker Runs, riffles, eddies, and backwaters in large rivers. (Catostomus discobolus ) Present in Roundtail chub (Gila Colorado River Slow-moving waters adjacent to fast waters in large rivers. robusta) *Blue Lineage Colorado Headwaters streams and ponds with cool, clear waters isolated River cutthroat trout Absent from populations of non-native cutthroats and rainbow trout. (Oncorhynchus clarki ssp.) *Blue Lineage = Relict populations of cutthroat trout indigenous to the Yampa/Green River drainages but widely transplanted throughout the state. Managed as a BLM sensitive species pursuant to prior designation of the Colorado River cutthroat trout (O. c. pleuriticus) pending completion of genetic and morphometric studies and taxonomic reassessment of native cutthroat trout in Colorado.

Environmental Consequences

Proposed Action

Fringed Myotis, Spotted Bat, and Townsend’s Big-eared Bat. No caves or other suitable roosting sites occur in the project area. Loss of large trees, potentially also used for roosting, would be negligible. Loss of habitat above which the bats could search for aerial prey would also be minimal, and disturbance due to construction activities would not occur at night when the bats are feeding.

Northern Goshawk. This species is mostly limited to spruce/fir or aspen forests, such as atop the Roan Plateau, Battlement Mesa, and other areas that reach subalpine elevations. However, goshawks may migrate to lower elevation pinyon/juniper or Douglas-fir habitats during winter and therefore could make occasional, transitory use of the project area for winter foraging. Goshawks feed primarily on small birds but also on diurnal small mammals (rabbits, chipmunks, etc.).

Golden Eagle. Golden eagles live in open and semi-open country featuring native vegetation across most of the Northern Hemisphere. They avoid developed areas and uninterrupted stretches of forest and are found in mountains to 12,000 feet, canyonlands and rimrock terrain, and along cliffs and bluffs. Golden eagles nest on cliffs and steep escarpments in grassland, chaparral, shrubland, forest, and other vegetated areas. The most likely use of the project area would be for foraging, although nesting has occurred along the nearby cliffs north of the project.

80 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Bald Eagle. Although bald eagles nest and roost along the Colorado River in the project vicinity, the potential for use of the actual project area is low. Any such use would most likely be by an individual hunting across large expanses of open upland habitats during winter. The project area would represent a small portion of such potential winter hunting habitat, and the reclaimed grass-forb community would provide better habitat for prey than the current shrubland types.

Peregrine Falcon. Peregrine falcons nest along cliff bands south and north of the project and hunt for waterfowl along the Colorado River or other birds across open terrain. Use of the project area is unlikely, except for infrequent, transitory overflights while traveling between the Colorado River and the cliff bands to the north.

Brewer’s Sparrow. Although the habitat is marginal in the project area, nesting by this species is possible. The 60-day TL to prohibit removal of vegetation during the period May 1 to July 1 (Appendix) would avoid or minimize the potential for impacts to nesting Brewer’s sparrows. Construction activities outside this period could cause individuals to avoid the disturbance while feeding. However, this impact would be limited in duration at any point along the corridor, and individuals are expected to feed across very large home ranges outside the nesting season, thus minimizing the severity of this potential indirect impact.

Midget Faded Rattlesnake. This viper is a small, pale-colored subspecies of the common and widespread Great Basin rattlesnake, although some authorities consider it a genetically distinct species. Although movement patterns of midget faded rattlesnakes are not well known, they are believed to be limited to a few hundred meters from den sites. The limited distribution and small home range make this snake susceptible to impacts from human disturbance (Parker and Anderson 2007). Threats include direct mortality from vehicles traveling on roads and pads, off-highway vehicle use throughout the landscape, capture by collectors, and livestock grazing. As access increases into previously undeveloped areas, the risk of encounters with humans would increase, resulting in some cases of mortality or collection. Several rocky outcrops that could potentially provide suitable denning habitat for rattlesnakes were located, however, no snakes were observed during surveys (WestWater 2017a).

Flannelmouth Sucker, Bluehead Sucker, and Roundtail Chub. As with the ecologically similar Colorado River endangered fishes described above, the flannelmouth sucker and roundtail chub are adapted to naturally high sediment loads and therefore would not be affected by increased sediment transport to the Colorado River. Furthermore, protective COAs for water quality (Appendix) would minimize this potential. However, these species are vulnerable to alterations in flow regimes in the Colorado River (including evaporative loses from dams and depletions from withdrawal of water for irrigation or municipal water supplies) that affect the presence of sandbars and seasonally flooded overbank areas needed for reproduction. The amount of depletion in flows associated with this project is not expected to have a significant adverse impact on the survival or reproductive success of these species.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to BLM sensitive wildlife species from implementation of the Proposed Action would not occur. However, any impacts associated with continued operation of the existing oil and gas facilities would extend over the next 25 to 30 years. Impacts resulting from other activities and resource uses, including grazing of livestock, and with natural processes such as drought and wildland fires, would also continue to occur.

81 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

4.13. VEGETATION

Affected Environment

The project would be located north of I-70 along the foothills of the Roan Plateau. The foothills are divided by intermittent and ephemeral drainages that generally flow south into the Colorado River. Slopes in the area are steep, rising rapidly from the valley floor to the Roan Plateau. Vegetation communities in the project area are composed of pinyon/juniper woodlands along many of the ridgetops and sideslopes, Basin big sagebrush shrublands along valley bottoms, mixed Wyoming sagebrush shrublands and grasslands along other ridgetops and sideslopes, barren steep-sided hillsides, and reclaimed pipeline rights-of-way.

Although there has been extensive oil and gas development in the area, the remaining undisturbed vegetation contains diverse native species. Woody plants include alderleaf mountain mahogany (Cercocarpus montanus), antelope bitterbrush (Purshia tridentata), basin big sagebrush (Artemisia tridentata spp. tridentata), broom snakeweed (Gutierrezia sarothrae), fourwing saltbush (Atriplex canescens), Gambel’s oak (Quercus gambelii), greasewood (Sarcobatus vermiculatus), Mormon tea (Ephedra viridis), pinyon pine (Pinus edulis), rubber rabbitbrush (Ericameria nauseosa), shadscale saltbush (Atriplex confertifolia), Utah juniper (Sabina utahensis), Utah serviceberry (Amelanchier utahensis), and Wyoming sagebrush (Artemisia tridentata ssp. wyomingensis). Succulents observed were brittle prickly-pear (Opuntia fragilis), mountain ball cactus (Pediocactus simpsonii), and Harriman’s yucca (Yucca harrimaniae).

Common forbs present include basin daisy (Platyschkuhria integrifolia), bedstraw (Galium sp.), Bigelow’s tansy-aster (Dieteria bigelovii), bulbous springparsley (Cymopterus bulbosus), cat’s eye (Oreocarya spp.), clasping pepperweed (Lepidium perfoliatum), common dandelion (Taraxacum officinale), common plantain (Plantago major), common yarrow (Achillea millefolium), crescent milkvetch (Astragalus amphioxys), crispleaf buckwheat (Eriogonum corymbosum), curlycup gumweed (Grindelia squarrosa), curveseed butterwort (Ceratocephala testiculata), hoary Townsend-daisy (Townsendia incana), lambs-quarters (Chenopodium album), long-leaf phlox (Phlox longifolia), margined stickseed (Lappula marginata), mountain pepperweed (Lepidium montanum), narrowleaf stoneseed (Lithospermum incisum), Navajo fleabane (Erigeron concinnus), nineleaf biscuitroot (Lomatium triternatum), northwestern Indian paintbrush (Castilleja angustifolia), pallid milkweed (Asclepias cryptoceras), perennial rockcress (Boechera perennans), pointed gumweed (Grindelia fastigiata), point- tip twinpod (Physaria floribunda), prickly-lettuce (Lactuca serriola), purple mustard (Chorispora tenella), rayless tansy-aster (Machaeranthera grindelioides), rock goldenrod (Petradoria pumila), rush skeletonplant (Lygodesmia juncea), scarlet gilia (Ipomopsis aggregata), scarlet globemallow (Sphaeralcea coccinea), sego lily (Calochortus nuttallii), sharpleaf twinpod (Physaria acutifolia), yellow sweet-clover (Melilotus officinale), tufted evening primrose (Oenothera caespitosa), Utah sweetvetch (Hedysarum boreale), wavyleaf thistle (Cirsium undulatum), wild alyssum (Alyssum simplex), yellow milkvetch (Astragalus flavus), and yellow salsify (Tragopogon dubius).

Common grasses present include brome grass (Bromus sp.), crested wheatgrass (Agropyron cristatum), mutton grass (Poa fendleriana), Salina wildrye (Leymus salinus), Sandberg bluegrass (Poa secunda), slender wheatgrass (Elymus trachycaulus), smooth brome (Bromus inermis), and western wheatgrass (Pascopyrum smithii). All of these are native perennials except smooth brome, an introduced species.

82 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Environmental Consequences

Proposed Action

Under the Proposed Action, a total of 41.47 acres would be disturbed, including 25.00 acres on BLM land and 16.47 acres on private land. Following construction, drilling, and well completions, interim reclamation would occur on all areas not needed for ongoing operations. A total of 8.30 acres would remain as long-term disturbance, including 4.66 acres on BLM land and 3.64 acres on private land. Interim reclamation would consist of seeding in accordance with the reclamation COAs presented in the Appendix. A seed mix consisting of native grasses, forbs, and shrubs would be used on BLM land, but for portions of the project located on private land, the composition of seed mixes used for reclamation would be at the discretion of the landowner.

Adjacent native vegetation would not be directly impacted, but could be indirectly impacted by increased dust deposition on leaves. Dust levels could be expected to increase above ambient levels in the short term from pad expansion, well drilling, new road construction, and new pipeline installation. Increased dust levels can negatively impact plants by clogging stomatal openings in the leaves, impeding gas exchange and reducing the ability of plants to take in carbon dioxide. Dust on the leaf surface can also effectively reduce light availability at the leaf surface. Light and carbon dioxide are both critical for plants to conduct photosynthesis, and reductions in either can reduce the quantity of carbohydrates plants can produce through photosynthesis, and thereby reduce plant growth and seed production. Dust on leaf surfaces can also facilitate plant tissue uptake of toxic pollutants (Thompson et. al. 1984, Farmer 1993, Sharifi et. al. 1997).

Additional indirect impacts to adjacent vegetation could occur from noxious weeds and other non-native plants associated with project area disturbances. The proposed removal of native vegetation would increase the site’s vulnerability to invasion and establishment of noxious weeds and other non-native invasive plant species, particularly with the existing widespread establishment of noxious weeds and other non-native species. Neighboring vegetation would also become more vulnerable to invasion by noxious weeds and other non-native species. Ground disturbance combined with vehicle traffic and construction equipment provides both excellent habitat and vectors for invasive species, particularly when these species are already present within the soil seed bank (Schmidt 1989, Parendes and Jones 2000, Gelbard and Belnap 2003, Larson 2003, Zaenepoel et. al. 2006). Invasive non-native species can negatively affect native plant communities, both directly through competition for resources, and indirectly through alteration of soil microbial communities (Klironomos 2002, Hierro et. al. 2006, Reinhart and Callaway 2006, Vogelsang and Bever 2009). Herbicide treatments of weeds can also result in negative effects or mortality to desirable plants if they are co-occurring or located nearby and vulnerable to the specific chemical being applied (BLM 2007).

Implementation of COAs for noxious weeds and temporary reclamation (Appendix) would reduce the risk of establishment and spread of noxious weeds and other invasive non-native plants through the judicious use of herbicides in combination with prompt reestablishment of desirable vegetation through interim reclamation.

No Action Alternative

83 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

extend over the next 25 to 30 years. Impacts resulting from other activities and resource uses, including grazing of livestock, and with natural processes such as drought and wildland fires, would also continue to occur.

4.14. VISUAL RESOURCES

Affected Environment

The proposed BGMDP project area is located 9 miles west of Rifle, Colorado, and north of Rulison, Colorado, on the north side of I-70 in central Garfield County, Colorado. The drilling and completion of the 66 proposed Federal wells would occur on three existing well pads (two BLM pads and one fee pad) slated for pad expansion to accommodate the new developments. Additionally one existing BLM pad (RWF 23-19) and one new private pad (PA 23-25) would serve as frac support pads. Existing infrastructure from previous developments on private and BLM land would primarily be used to develop and directionally drill the new 66 Federal wells.

The private land within the BGMDP area occurs along the I-70 corridor and Colorado River where existing surface disturbance and oil/gas field developments are clustered north of the I-70 and the Rulison interchange in particular. The existing PA 22-25 fee pad and its associated PA 23-25 frac pad would be located on the valley floor, generally hidden from direct view from I-70 travelers by oil field businesses and their storage yards. Mesas dominated with pinyon/juniper woodlands and sagebrush openings are situated at the western and eastern edges of the project area directly above the river valley and north of I- 70. The existing RWF 13-19 and RWF 23-19 pads are located on the eastern mesa, out of view from the highway. The western mesa supports the existing PA 23-26 pad, which is well hidden from I-70. The middle and upper slopes and ridges are dominated by Balzac Gulch and its unnamed side gulches, which gather shale debris from the flanks of the Roan Plateau during summer thunderstorms and deposit the sediment onto the valley floor. The majority of the project area is typified by steep ridges and canyon sideslopes dotted with juniper trees and an occasional Douglas-fir tree. This rough topography with its variegated lenses of exposed geologic formations would remain undeveloped aside from the historical Anvil Points Mine Road, evident in the landscape between Rulison and Rifle.

The proposed surface frac lines would be laid across the juniper-dominated woodlands on BLM land between the existing PA 23-26 pad on the western mesa and the PA 23-25 frac pad on the valley floor northwest of the Rulison interchange.

The BLM portion of the project area consists of lands classified as Visual Resource Management (VRM) Class II, as identified by the 2015 Colorado River Valley Field Office Approved Resource Management Plan and Record of Decision (BLM 2015).

The management objective of VRM Class II is to retain the existing character of the landscape. The level of change to the characteristic landscape should be low. Management activities may be seen, but should not attract the attention of the casual observer. Any changes must repeat the basic elements of form, line, color, and texture found in the predominant natural features of the characteristic landscape.

The flatter, more developed portion of the project area is on private lands where Federal lease terms regarding visual concerns are not applicable. BLM VRM objectives do not apply to non-BLM lands, and visual values for those lands are only protected by landowner discretion. However, the BLM makes recommendations to mitigate impacts to scenic values on non-BLM lands. The existing PA 22-25 pad slated for more extensive expansion is not readily visible from I-70 because of intervening equipment storage yards on private lands.

84 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Environmental Consequences

Proposed Action

As outlined in the section on Access and Transportation, frontage roads along either side of the highway would provide access to the three expanded well pads and the two proposed frac pads. Short road segments would be built or realigned and connect to the existing road infrastructure providing improved access to the project area. The proposed pipeline upgrades would occur within existing utility corridors on flat terrain or alongside existing roads. Impacts to visual resources on BLM land would be minimal given the relatively minor amount of new surface disturbance associated with the pad expansion of the existing well sites, the installation of buried pipelines within existing disturbances, and the short, well- screened length of access roads. The majority of the proposed developments would not be apparent from I-70 or a County Road except as background view from county roads along the south side of the river valley.

The temporary installation of three welded steel, rust-colored frac support lines serving the PA 23-26 well completion operations would readily blend into the landscape and not draw attention of a casual observer.

Short-term visual impacts due to the expansion of four well pads and construction of one new frac support pad with associated access roads, gas gathering pipelines, water collection pipelines, and condensate pipelines would occur within the project area. Contrast would be created in the landscape by removing vegetation, exposing bare ground, and creating distinct lines and forms in the landscape. There would also be an increase in the presence of drilling rigs, heavy equipment (e.g. dozers, graders, track hoes), and vehicular traffic with an increase in dust and light pollution. Long-term impacts associated with the Proposed Action include added production equipment, which would increase the existing visual contrast associated with human modifications already present in the area.

Additional reductions in contrast would be realized by implementing the standard Best Management Practices (BMPs) related to reclamation and facility paint colors, and screening the production facilities from view (Appendix). With these mitigation measures, long-term visual impacts would be reduced, and the Proposed Action would be expected to meet VRM Class II objectives.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to visual resources from implementation of the Proposed Action would not occur. However, impacts associated with continued operation of existing facilities would extend over the next 25 to 30 years. Impacts resulting from other activities and resource uses would also continue to occur.

4.15. WASTES, HAZARDOUS OR SOLID

Affected Environment

Federal laws regulating hazardous wastes or other hazardous materials include:

 The Oil Pollution Act (Public Law 101-380, August 18, 1990). This law prohibits discharge of pollutants into waters of the U.S., which by definition would include any tributary or dry wash that eventually connects with the Colorado River.

85 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (Public Law 96-510 of 1980). This law provides for liability, compensation, cleanup, and emergency response for hazardous substances released into the environment. It also provides national, regional, and local contingency plans. Applicable emergency operations plans in place include the National Contingency Plan (40 CFR 300, required by section 105 of CERCLA), the Region VIII Regional Contingency Plan, the Colorado River Sub-Area Contingency Plan (these three are EPA plans), the Mesa County Emergency Operations Plan (developed by the Mesa County Office of Emergency Management), and the BLM CRVFO Hazardous Materials Contingency Plan.

 The Resource Conservation and Recovery Act (RCRA) (Public Las 94-580, October 21, 1976). This law regulates the use of hazardous substances and disposal of hazardous wastes. Note: While oil and gas lessees are exempt from RCRA, ROW holders are not exempt from this legislation. RCRA strictly regulates the management and disposal of hazardous wastes. Most of the drilling and production wastes that would be generated by the Proposed Action would be exempt from the RCRA hazardous waste regulations (e.g., produced water, produced gas). However, the exemption would not mean that these wastes present no hazard to human health and the environment, nor would the exemption relieve the operator from corrective action to address releases of exempt wastes. In addition, BLM Instruction Memoranda WO-93-344 and CO-97-023 require that all NEPA documents list and describe any hazardous and/or extremely hazardous materials that would be produced, used, stored, transported, or disposed of as a result of a project. Practices commonly used in oil and gas developments are dictated by various Federal and State laws and regulations and the BLM standard lease terms and stipulations that would accompany any authorization resulting from this analysis. Environmental Consequences

Proposed Action

Pollutants potentially spilled or otherwise accidentally released during the construction phase of the project would include diesel fuel, hydraulic fluid, and lubricants associated with the operation of heavy equipment. These materials would be used during construction of the pad, road, and pipelines and for refueling and maintaining the vehicles and equipment. Potentially harmful substances used in the construction and operation phases would be kept onsite in limited quantities and trucked to and from the site as required. No hazardous substance, as defined by 40 CFR 355 would be used, produced, stored, transported, or disposed of in amounts above threshold quantities. Waste generated by construction activities would not be exempt from hazardous waste regulations under the oil and gas exploration and production exemption of RCRA. Exempt wastes include those associated with well production and transmission of natural gas through the gathering lines and the natural gas itself. With the exception of produced hydrocarbons, ethylene glycol (antifreeze), lubricants, and amine compounds, chemicals subject to reporting under Title III of the Superfund Amendments and Reauthorization Act in quantities of 10,000 pounds or more would not be used, produced, stored, transported, or disposed of during construction or operation of the facilities. None of the chemicals used in construction meets the criteria for an acutely hazardous material/substance or the quantities criteria per BLM Instruction Memorandum No. 93-344. In addition, no extremely hazardous substance, as defined in 40 CFR 355, would be produced, used, stored, transported, or disposed of during construction or operation of the facilities in amounts above threshold permissible quantities. Solid waste (human waste, garbage, etc.) would be generated during construction activities and, to a larger extent, during drilling and completion operations since the workforce would increase during those 86

86 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

activities. Trailers housing workers would be outfitted with self-contained sewage collection system; regular trash collection would occur throughout the drilling and well completion process. Because of the use or production of solid and hazardous wastes, the potential exists for accidental contamination of surface water or groundwater. While uncommon, an accident could occur that would result in a release of one or more of these materials directly or indirectly into surface waters or in a way that poses a potential for transport to groundwater. For example, improper casing and cementing of the boreholes could result in the contamination of groundwater resources. Releases are also possible from tanks used for storage on the pad, from haul trucks used to transport materials to and from the pad, or from pipelines. Storage tanks on the pad are required to be placed within an area of secondary containment equal to 110% of the volume of the enclosed tanks. In the event of any release of a hazardous substance to the environment in reportable quantities, the responsible party is required to implement a Spill Prevention, Control, and Countermeasures (SPCC) Plan and is liable for cleanup and monetary damages. Depending on the scope of the accident, the SPCC Plan or the CRVFO contingency plan would apply. These laws, regulations, standard lease stipulations, and contingency plans and emergency response resources are expected to mitigate any potential hazardous or solid waste issues associated with the Proposed Action. No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Impacts associated with any generation, use, disposal, or accidental release of hazardous materials from implementation of the Proposed Action would not occur. However, the potential for impacts associated with hazardous materials resulting from continued operation of existing facilities would extend over the next 25 to 30 years.

4.16. WATER RESOURCES – SURFACE AND GROUND

SURFACE WATER

Affected Environment

The project area is located north of the Colorado River, between Parachute and Rifle, Colorado, within the Cache Creek-Colorado River sub-watershed (Hydrologic Unit Code 140100050702). Both of the proposed expanded pads in Section 19 drain approximately 0.5 miles south across nearly level ground, then descend steep badland slopes, and are conveyed beneath I-70, U.S. Highway 6, and the Union Pacific Railroad tracks before reaching the Colorado River. The proposed pads in Section 25 on private surface are adjacent to an unnamed ephemeral channel that crosses I-70, Highway 6, and the railroad before its confluence with the Colorado River, which is about 0.3 miles downstream of the pads. The proposed PA 23-26 expanded pad is adjacent to an unnamed ephemeral channel that flows over level ground for about 0.3 mile and then descends steep badlands. These drainages are within Stream Segment COLCLC04a, otherwise known as “all tributaries, including wetlands, to the Colorado River from the confluence with the Roaring Fork River to a point immediately below the confluence with Parachute Creek,” which has the following classifications:

 Agriculture: These surface waters are suitable or intended to become suitable for irrigation of crops usually grown in Colorado and which are not hazardous as drinking water for livestock.

87 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

 Aquatic Life Cold 2: These are waters that are not capable of sustaining a wide variety of cold or warm water biota, including sensitive species, due to physical habitat, water flows or levels, or uncorrectable water quality conditions that result in substantial impairment of the abundance and diversity of species.  Recreation N (Not Primary Contact Use): These surface waters are not suitable or intended to become suitable for primary contact recreation uses.  Water Supply: These surface waters are suitable or intended to become suitable for potable water supplies. After receiving standard treatment, these waters will meet Colorado drinking water regulations and any revisions, amendments, or supplements thereto (CDPHE 2017). Stream Segment COLCLC04a is on Colorado’s Monitoring and Evaluation list for temperature, total phosphorus, and sulfate, and on the Clean Water Act’s Section 303(d) list of impaired waters for selenium (CDPHE 2016c).

The majority of the proposed PA 23-26 pipeline disturbance area would drain westward, into an unnamed ephemeral tributary of the Colorado River. This drainage is within Stream Segment COLCLC11g, “all tributaries to the Colorado River on the north side of the Colorado River from a point immediately below Cottonwood Creek to the confluence with Parachute Creek,” which has three of the same classifications as the previously discussed Stream Segment COLCLC04a – Agriculture, Aquatic Life Cold 2, Recreation N – but not water supply (CDPHE 2017). This Stream Segment is not on Colorado’s Monitoring and Evaluation list or on the Clean Water Act’s Section 303(d) list of impaired waters (CDPHE 2016c).

The project area drainages contribute to Stream Segment COLCLC02a, “Mainstem of the Colorado River from immediately below the confluence with Rifle Creek to immediately above the confluence of Rapid Creek.” This stretch is classified as:

 Agriculture.  Aquatic Life Warm 1: These are waters that 1) currently are capable of sustaining a wide variety of warm water biota, including sensitive species, or 2) could sustain such biota but for correctable water quality conditions. Waters shall be considered capable of sustaining such biota where physical habitat, water flows or levels, and water quality conditions result in no substantial impairment of the abundance and diversity of species.  Recreation E: (Existing Primary Contact Use): These surface waters are used for primary contact recreation or have been used for such activities since November 28, 1975.  Water Supply (CDPHE 2017). This reach of the Colorado River is on Colorado’s Monitoring and Evaluation list for sediment (CDPHE 2016c).

Instantaneous discharge was measured and water-quality samples were collected at Stream Site No. 09092570 (Colorado River at Rulison) by the U.S. Geological Survey (USGS) in 1977 and 1978 approximately 0.25 mile south of the project area boundary (USGS 2017). The USGS conducted monthly sampling events from April 1977 through January 1978. During that time, the streamflow of the Colorado River measured from 1,300 cubic feet per second (cfs) in November to 4,160 cfs in June. The temperature of the river measured between 1.5 degrees Celsius (°C) in December and 21 °C in July. The specific conductance ranged from 540 to 1,380 microSiemens per centimeter (µS/cm) at 25°C in June and November, respectively. Table 39 presents the water-quality results of the ten monthly sampling events. Note that the laboratory analysis results of the samples collected in September 1977 are generally inconsistent with the other monthly results. 88

88 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Table 39. Water Quality of the Colorado River at Rulison, 1977 to 1978

Parameter 4/8/1977 5/18/1977 6/3/1977 7/8/1977 8/10/1977 9/21/1977 10/14/1977 11/17/1977 12/6/1977 1/18/1978 Temperature (degrees Celsius) 11 13 18 21 19 14.5 10 5 1.5 2.5 Instantaneous Discharge (cfs) 1,560 2,600 4,160 2,000 2,000 1,800 1,600 1,300 1,500 1,500 Specific Conductance (µS/cm 1,200 860 540 970 980 1,120 1,090 1,380 1,270 1,320 at 25°C) Hydrogen Ion (mg/L) 0.00001 0.00001 0.00003 0.00001 0.00006 0.00005 0.00001 0.00001 0.00006 0.00001 Dissolved Oxygen (mg/L) 10.4 10.2 8.9 9.2 7.9 18 10.6 10.4 10.8 11.2 Chemical Oxygen Demand 17 13 22 37 12 7.3 15 88 37 41 (mg/L) pH (standard units) 8.1 8.2 7.6 8.3 7.2 13 8.2 8 7.2 7.9 Carbon Dioxide (mg/L) 2 1.4 4.4 1.3 16 130 1.7 3.2 18 3.6 Acid Neutralizing Capacity 130 110 90 130 130 160 140 160 150 150 (mg/L as CaCO3) Bicarbonate (mg/L) 160 140 110 160 160 0 170 200 180 180 Carbonate (mg/L) 0 0 0 0 0 0.26 0 0 0 0 Total Nitrogen (mg/L) 0.4 1 1.7 0.25 0.38 0.24 0.77 0.25 0.31 0.93 Organic Nitrogen (mg/L as N) 0.28 0.92 1.4 0.2 0.33 < 0.010 0.66 0.13 0.16 0.51 Ammonia (mg/L as N) 0.06 < 0.010 0.07 < 0.010 0.01 0.24 0.01 0.07 0.04 0.11 Ammonia + Organic Nitrogen 0.34 0.92 1.5 0.2 0.34 0.02 0.67 0.2 0.2 0.62 (mg/L as N) Nitrate + Nitrite (mg/L as N) 0.06 0.09 0.2 0.05 0.04 0.03 0.1 0.05 0.11 0.31 Phosphorus (mg/L as P) 0.02 0.05 0.02 < 0.010 0.04 250 < 0.010 0.01 < 0.010 0.09 Organic Carbon (mg/L) 3.6 210 160 4.1 230 120 2.7 330 290 1.9

Hardness (mg/L as CaCO3) 250 96 65 230 98 76 250 160 140 280 Noncarbonate Hardness (mg/L 120 63 48 100 67 15 110 95 84 140 as CaCO3) Calcium (mg/L) 74 13 8.6 70 15 130 73 22 19 82 Magnesium (mg/L) 17 99 53 14 120 3.6 17 180 150 19 Sodium (mg/L) 160 3 1.9 120 3.5 52 150 4.3 3.8 160 Sodium Adsorption Ratio 4.4 50 42 3.4 53 4.2 4.1 54 53 4.1

89 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Parameter 4/8/1977 5/18/1977 6/3/1977 7/8/1977 8/10/1977 9/21/1977 10/14/1977 11/17/1977 12/6/1977 1/18/1978 Sodium Fraction of Cations 57 3.4 2.7 52 4 180 56 5.2 4.6 55 (%) Potassium (mg/L) 4.8 130 76 3.9 180 140 4.4 260 210 4.4 Chloride (mg/L) 230 130 76 180 110 0.3 200 180 150 230 Sulfate (mg/L) 160 0.2 0.6 110 0.3 8 160 0.3 0.1 160 Fluoride (mg/L) 0.3 7.8 17 0.3 7.7 51 0.4 7.5 8.5 0.3

Silica (mg/L as SiO2) 7.1 74 118 7.3 57 632 7.2 37 42 9.6 Arsenic (µg/L) < 1.0 516 337 < 1.0 583 3,070 1 849 715 < 1.0 Iron (µg/L) 80 3,620 3,790 40 3,150 0.86 70 2,980 2,900 20 Lead (µg/L) M 0.7 0.46 U 0.79 0 M 1.15 0.97 M Manganese (µg/L) 50 0 0.09 M 0.01 -- 20 0.09 0.05 30 Selenium (µg/L) 1 -- -- < 1 -- -- < 1 -- -- 2 Instantaneous Discharge (cubic 44 -- -- 57 -- -- 45 -- -- 42 meters per second) Dissolved Solids (mg/L) 733 -- -- 585 -- -- 696 -- -- 756 Dissolved Solids (short tons 3,090 -- -- 3,160 -- -- 3,010 -- -- 3,060 per day) Dissolved Solids (short tons 1 -- -- 0.8 -- -- 0.95 -- -- 1.03 per acre-foot)

Ammonia (mg/L as NH4) 0.08 -- -- 0 -- -- 0.01 -- -- 0.14 Mercury (µg/L) < 0.50 -- -- < 0.50 -- -- < 0.10 -- -- < 0.10 Source: USGS 2017 M = presence verified but not quantified U = analyzed for but not detected

90 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Environmental Consequences

Proposed Action

Potential impacts to surface water from the Proposed Action are associated with surface-disturbing activities, water use, road use, waste management, and the use, storage and transportation of fluids (i.e., chemicals, condensate, and produced water). Surface-disturbing activities associated with the well pads, roads, and pipelines result in loss of vegetation cover, soil compaction and displacement, increased volume and velocity of runoff, and increased sedimentation and impacts to overall surface water quality.

Stormwater management of the roads and pads would reduce erosion. As proposed, these measures would include limiting cut slope steepness, crowning road surfaces, installing culverts and drainage systems, and applying gravel to all upgraded roads in the project area to a compacted thickness of 6 inches (Appendix).

Fresh water would be obtained from approved commercial water sources and would be trucked to the new wells to augment drilling. Water used for well completions would be sourced primarily from Terra’s water recycling and water line delivery systems.

Oil and gas waste management practices have the potential to contaminate soils and surface water. Contamination of soils could cause long-term reduction in site productivity, resulting in increased erosion and potential sediment and contaminant delivery to nearby waterways during runoff. The use, storage, and transportation of fluids, such as produced water, hydraulic fracturing fluids, and oil condensate, have an associated risk of spills that could affect water resources. Elements of the Proposed Action are designed to minimize and mitigate risks to surface waters associated with the release and migration of drilling fluids, produced water, and condensate. A closed-loop drilling system would be implemented. Drill cuttings would be collected from the drill rig a shaker system, mixed with drying agents, tested and remediated per COGCC standards, and either deposited in the cuttings trench or stacked against the cut slope for later burial during interim reclamation. Completions would be conducted either onsite or from remote locations.

In addition to individual containment measures, each pad would have berms to contain an accidental release. In the event of an accidental release, produced water and condensate would be confined for cleanup in a containment area to prevent migration to surrounding soils or surface waters. Pipelines associated with the transport of these liquids would be pressure-tested to detect leakage prior to use. Implementation of COAs for mitigating impacts to surface waters (Appendix) would minimize risks of adverse impacts associated with construction and ongoing production activities.

To minimize impacts to natural resources, including surface water, the proposed locations of well pads, roads, and pipelines utilize existing or previously disturbed areas, and are designed to avoid or minimize impacts to drainages. The northeast corner of the proposed expanded PA 22-25 was rounded to avoid an adjacent drainage. The proposed expanded PA 23-26 well pad overlies the head of a drainage channel; a culvert would be installed and maintained the length of the span to ensure the continued function of the channel. The proposed pipelines from the PA 23-26 well pad to the southwest would be within the existing road alignment and the existing pipeline ROW.

The temporary surface lines proposed for installation between the PA 22-25 and PA 23-26 pads follow an existing two-track road for most of its length. The temporary lines would cross an ephemeral drainage channel. To minimize potential impacts to resources, the location of the drainage crossing was selected within a relatively straight section of a generally sinuous, deep channel. The pipelines would be

91 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

perpendicular to the line of flow and cased inside 10-inch-diameter black poly lines with 2-inch-thick walls.

The Proposed Action includes, but is not limited to, the following BMPs that reduce potential surface water impacts:

 Construction of pads, roads, and pipelines would follow the guidelines established in the BLM Gold Book, Surface Operating Standards for Oil and Gas Exploration and Development (USDI and USDA 2007).  The new access roads would be graveled to ensure all-weather accessibility to the pad sites; existing roads would undergo review for spot-graveling needs.  During pad construction, topsoil would be windrowed, where feasible, around the outer edge of the disturbance perimeter to serve as a stormwater diversion and catchment, and temporarily seeded until interim reclamation is scheduled after all of the wells on the pad are placed into production.  A closed-loop drilling system would be used. Recovered drilling fluid would be stored on location in steel tanks for reuse.  The development would be largely supported by existing pipeline infrastructure to a centralized water storage facility and remote fracing.  Water used for well completions would be sourced primarily from Terra’s water recycling program, drastically negating the use of fresh water for frac operations, and the recycled treated water would be delivered in Terra’s existing water line systems, drastically reducing truck traffic on roads.  Disturbed areas on pads, roads, and pipelines would be reclaimed in a timely manner. The Appendix includes additional measures to minimize impacts to surface water resources. For instance, a road maintenance program would be required during the production phase of the wells. This program would include, but not be limited to blading, ditching, culvert installation and cleanout, weed control, and gravel surfacing where excessive rutting or erosion occur. The operator would be responsible for continuous inspection and maintenance of the access roads, pads, and pipelines.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to surface waters from implementation of the Proposed Action would not occur. However, any impacts associated with continued operation of the existing oil and gas facilities would extend over the next 25 to 30 years. Impacts resulting from other activities and resource uses, including grazing of livestock, and with natural processes such as drought and wildland fires, would also continue to occur.

WATERS OF THE U.S.

Affected Environment

The Proposed Action may affect seven potential jurisdictional waters of the U.S., including one perennial stream, three ephemeral streams, two drainages without an ordinary high water mark, and a stock pond 92

92 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

with wetland vegetation along its banks. Section 404 of the Clean Water Act requires a Department of the Army permit from the U.S. Army Corps of Engineers (USACE) prior to discharging dredged or fill material into waters of the U.S. as defined by 33 CFR Part 328.

Environmental Consequences

Proposed Action

The seven potential jurisdictional waters of the U.S. that may be affected by the Proposed Action are described below along with associated design features, BMPs, and mitigation measures that avoid or minimize potential impacts to waters of the U.S.

 The proposed 8-inch gas pipeline from the RWF 13-19 pad to a pipeline adjacent to Anvil Points Road would cross a perennial stream with a 15-foot-wide channel. This welded steel pipeline would span the drainage. As a ROW mitigation measure (Appendix), Terra would be required to provide specific details of this pipeline span to the BLM for review and approval prior to construction.  The existing road between the RWF 13-19 pad and the RWF 23-19 Frac Pad crosses an ephemeral drainage. A culvert exists at this crossing. To manage this drainage effectively, the existing culvert would be removed and replaced with a larger culvert with a new alignment to improve the conveyance of flow (Appendix).  The northeast corner of the proposed expansion of the PA 22-25 pad was designed to avoid a potential water of the U.S.  The proposed temporary surface frac lines between the PA 22-25 and PA 23-26 pads would perpendicularly cross a relatively straight section of a sinuous, deep ephemeral drainage, and would be inside casing that spans the drainage.  The proposed expansion of the PA 23-26 well pad overlies the head of a drainage channel; a culvert would be installed and maintained the length of the span to ensure the continued function of the channel.  The proposed pipelines from the PA 23-26 well pad to the southwest would be within the existing road alignment and the existing pipeline ROW. The existing road alignment and pipeline ROW cross an ephemeral drainage, where culverts and extensive rock gabions exist.  The Proposed Action avoids the stock pond with wetland vegetation along its banks.

Impacts to waters of the U.S. from the planned features of the Proposed Action would be addressed by the USACE through the agency’s permitting system. A COA listed in the Appendix requires that the operator obtain a formal jurisdictional determination by the USACE prior to any construction that could affect waters of the U.S. and verification that the impacts do not require a permit.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to Waters of the U.S. from implementation of the Proposed Action would not occur. However, any impacts associated with continued operation of the existing oil and gas facilities would extend over the next 25 to 30 years. Impacts resulting from other activities and resource uses, including

93 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

grazing of livestock, and with natural processes such as drought and wildland fires, would also continue to occur.

GROUNDWATER

Affected Environment

The Lower Piceance Basin contains both alluvial and bedrock aquifers (CGS 2003). Unconsolidated alluvial aquifers are the most productive aquifers in the region (EPA 2004) and are defined as narrow, thin deposits of sand and gravel formed primarily along stream courses, in this case, along the Colorado River and its tributaries. Alluvial well depths are generally less than 200 feet and water levels typically range between 100 to 150 feet. Well yield is dependent upon the intended use of the well, well construction design, sediment type and saturated thickness. Domestic wells are limited to 15 gallons per minute (gpm) administratively, while municipal wells are designed and constructed for maximum yield.

The principal bedrock aquifers of the Piceance Basin are the Uinta Formation and the Parachute Creek Member of the Green River Formation, and are defined as the upper and lower Piceance Basin aquifer systems. The Uinta Formation consists of discontinuous layers of sandstone, siltstone, and marlstone and is less permeable than the hydrologically connected upper Parachute Creek Member (Robson and Saulnier 1981). The uppermost Uinta Formation also contains a shallow, perched aquifer that is separate from the upper aquifer unit (Cole et al. 1995). The upper Piceance Basin aquifer is underlain by the Mahogany confining unit, and correlates with the Mahogany Zone, the principal oil shale unit of the Piceance Basin. The Mahogany Zone separates the upper aquifer from the lower. The lower aquifer consists of the fractured marlstone of the lower part of the Parachute Creek Member. The thickness of the upper and lower aquifer units average 700 and 900 feet, respectively (CGS 2003). Both upper and lower aquifer systems are present beneath higher portions of the project area, but no water wells are completed within either the upper or lower bedrock aquifers units as described above. Beneath these two aquifer systems is a confining unit consisting of the Wasatch Formation and the lower two members of the overlying Green River Formation. Some fresh-water wells are completed in localized water-bearing intervals within this unit.

Below the Wasatch Formation is the Cretaceous-aged Mesaverde aquifer. This aquifer consists of sandstone with interbedded shale and coal of the Williams Fork Formation and the marine sands and shales of the Iles Formation. The depth to the top of this aquifer beneath the project area is more than 5,000 feet below ground surface (bgs), far too deep for economic development. Studies of the potentiometric surface performed by Glover et al. (1998) indicate that water from the Mesaverde aquifer does discharge into the Colorado River and its alluvium downstream from the town of Parachute.

Water quality of the upper Piceance Basin aquifer is relatively good, ranging in Total Dissolved Solid (TDS) levels from 500 to 1,000 milligrams per liter (mg/L). In the lower unit, TDS concentrations increase from 1,000 to 10,000 mg/L along basin flow paths. Waters with TDS values in excess of 1,000 mg/L are generally unsuitable for potable supply. Although no primary (health-based) water quality standard has been established for TDS, the secondary (aesthetic or non-health-based) standard for TDS in drinking water is 500 mg/L or less (EPA 2006). Water quality of the Mesaverde aquifer is highly variable, with concentrations of dissolved solids ranging from less than 1,000 mg/L in many of the basin- margin areas to more than 10,000 mg/L in the central part of the Piceance Basin (EPA 2004). In general, areas of the aquifer that are recharged by infiltration from precipitation or surface water contain relatively fresh water. However, water quality in the Piceance Basin is generally poor overall due to the presence of nahcolite deposits and salt beds throughout the basin. Only very shallow waters such as those from the surficial Wasatch Formation are used for drinking water (EPA 2004).

94 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

According to the Colorado Division of Water Resources (CDWR), 44 registered wells are located within a 1-mile buffer of the proposed pads and roads. Of these, 17 were listed as domestic/household or commercial/industrial. These water wells have depths between 20 and 270 feet, with water yields ranging between 1.5 and 15 gallons per minute (gpm). Other wells identified within the buffer are listed as monitoring wells, or were canceled or denied.

Environmental Consequences

Proposed Action

Potential impacts to groundwater resources from the proposed development would include contamination of the groundwater with produced water, drilling mud, and petroleum constituents. Hydraulic fracturing would be incorporated to create additional pathways to facilitate gas production. Agents called “proppants” used to prop open the fractures are mixed with both fresh water and produced water. These typically include sand, aluminum, glass, or plastic beads, with less than 1% of other compounds such as corrosion-, friction-, and scale-inhibitors (EnerMax Inc. 2007). Fracing is used to create secondary porosity fractures, held open by proppants, allowing the otherwise trapped gas to migrate up the borehole for production.

Hydraulic fracturing would be conducted at 5,000 feet or more bgs. Drilling scenarios are developed to prevent fluids and produced hydrocarbons from migrating upward into fresh water zones. Also see the discussion of hydraulic fracturing on groundwater resources in the section of this EA on Geology and Minerals. Geologic and engineering reviews are conducted to ensure that the cementing and casing programs are adequate to protect all downhole resources. With proper construction practices, drilling practices, and BMPs, no significant adverse impact to groundwater aquifers is anticipated to result from the project (see Downhole COAs in Appendix).

Potential Impacts of Hydraulic Fracturing During Oil and Gas Well Completions

For decades, oil and gas companies and independent geophysicists have used state of the art equipment to monitor microseismic activity—defined as a “faint” or “very slight” tremor—during hydraulic fracturing to optimize well completions and to gather information about fracture dimensions and propagation (Warpinski 2009). These data give an indication about the magnitude of seismic activity associated with hydraulic fracturing, dimensions of resultant fractures in geologic formations, and probability for induced fractures to extend into nearby aquifers, if present. Research indicates that microseismic activity created by hydraulic fracturing occurs at Richter magnitude 1.0 or less (Warpinski and Zimmer 2012). In comparison, a magnitude 3 earthquake is the threshold that can be felt at the ground surface. The Richter magnitude scale is base-10 logarithmic, meaning that a magnitude 1.0 tremor is 1/100th the amplitude of a magnitude 3 tremor. The National Academy of Sciences reviewed more than 100,000 oil and gas wells and waste water disposal wells around the world and concluded that “incidences of felt induced seismicity appear to be very rare,” with only one such documented occurrence (NAS 2012).

The dimensions of induced fractures have been measured with field monitoring equipment (including microseismic “listeners”) and in laboratory tests and have been compared to three-dimensional (3D) hydraulic fracture models. Researchers have successfully validated these models for fracturing in “tight gas” reservoirs including those in the Piceance Basin. Results of the analyses show that fractures resulting from completions of oil and gas wells can be predicted (Zhai and Sharma 2005, Green et al. 2009, Palisch et al. 2012) and that the length of fractures in relation to well depth can be estimated.

Hydraulically induced fracture orientation in relation to the wellbore depends upon the downhole environment (i.e., rock mechanics, minimum and maximum principle stress directions, rock physical 95

95 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

properties, etc.) and the wellbore trajectory. In vertical or normal directional wells such as in the Mesaverde formation—the predominant hydrocarbon-producing formation in the CRVFO area—fracture growth is primarily lateral or outward from the wellbore, with minimal secondary fractures extending at some angle away from the lateral fractures. In horizontal wells such as being used to develop deep marine shales, fracture growth from the wellbore is mainly determined by the orientation of the wellbore in relation to the principal stresses of the rock. Fracture growth toward the surface is limited by barriers such as variations in stress and lithology, as is also the case in vertical and normal directional wells. In some horizontal wells, fracture growth is similar to that in vertical or normal directional wells due to wellbore trajectory along the maximum principal stress direction. Analysis of data from thousands of wells indicates fracture extent (length) of less than 350 feet in the vast majority of cases, with outliers of 1,000 to 2,000 feet (Maxwell 2011, Davies et al. 2012). The extreme outlier lengths are associated with fractures in thick deposits of lithologically uniform marine shales.

The potential height of hydraulically induced fractures in horizontal drilling is reduced in layered sediments in which a propagating fracture encounters a change in rock type or a bedding plane within a formation or a contact between formations. When these features are encountered, the fracture either terminates or to a lesser extent reorients along the generally horizontal bedding plane or formation contact instead of continuing upward across it. In the CRVFO area, natural gas production is primarily from vertically stacked, lenticular tight sands of the Mesaverde formation using vertical and directional wells. These tight-sand lenses are a few tens of feet thick or less. More recently, advances in horizontal drilling technology have allowed enhanced development of deeper marine shales such as the Niobrara formation. These tight-shale deposits are a few hundreds to thousands of feet thick in the CRVFO area compared to many hundreds or thousands of feet in some other gas-producing regions. The thickness of hydrocarbon-bearing strata in this area limits the vertical growth of primary and secondary fractures resulting from hydraulic stimulation.

Based on a review of available information on microseismic monitoring and fracture dimensions, Fisher and Warpinski (2011) concluded that fractures from deep horizontal wells are not a threat to propagate across the long vertical distances (thousands of feet) needed to reach fresh-water aquifers much closer to the surface. This conclusion applies to the CRVFO area, and is also applicable to much shallower potable groundwater sources consisting of unconsolidated alluvium (streambed deposits) associated with the Colorado River and major tributaries. In general, alluvial water wells in the CRVFO extend to depths of less than 200 feet, with few in the range of 400 feet. Typical water levels in these wells range from 50 to 100 feet deep. Impacts to water quality of shallow fresh-water wells are highly improbable as a result of hydraulic fracturing, which occurs at depths of 5,000 to 11,000 feet below ground surface.

In addition to vertical separation of several thousand feet between the upper extent of fractures and fresh-water aquifers are requirements by the BLM and COGCC for proper casing and cementing of wellbores to isolate the aquifers penetrated by a wellbore. BLM requires that surface casing be set from 800 to 1,500 feet deep, based on a geological review of the formations, aquifers, and groundwater. Cement is then pumped into the space between the casing and surrounding rock to prevent fluids from moving up the wellbore and casing annulus and coming in contact with shallow rock layers, including fresh-water aquifers. BLM petroleum engineers review well and cement design and final drilling and cementing logs to ensure that the cement has been properly placed. When penetration of groundwater and freshwater aquifers is anticipated, BLM inspectors may witness the cementing of surface casing and subsequent pressure testing to ensure that the space between the casing and borehole wall is sealed.

No single list of chemicals currently used in hydraulic fracturing exists for western Colorado, and the exact combinations and ratios used by operators are considered proprietary. However, the general types of compounds and relative amounts used are well known and relatively consistent (Table 40). Since fracture jobs are tailored to the downhole environment and companies are aware of the concerns 96

96 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

involving hydraulic fracturing, the chemicals listed in Table 40 may or may not be used, and the information is provided solely as general information.

Although a variety of chemicals additives are used in hydraulic fracturing—the examples in Table 40 being drawn from a total of 59 listed on the FracFocus website—the vast bulk of fluid injected into the formation during the process is water mixed with sand, representing 99.51% of the total by volume in the typical mixture shown in Table 40. The sand listed in the table is used as a proppant to help keep the newly formed fractures from closing.

Table 40. Constituents of Typical Hydraulic Fracturing Operations in Tight Gas Formations Additive Typical Percent by Common Use of Example Function* Type* Example* Volume** Compound Hydrochloric Dissolves mineral cement in Swimming pool chemical and Acid 0.123 acid rocks and initiates cracks cleaner Eliminates bacteria in the water Disinfectant; sterilizer for Biocide Glutaraldehyde 0.001 that produce corrosive or medical and dental equipment poisonous by-products Used in hair coloring, as a Ammonium Allows delayed breakdown of Breaker 0.010 disinfectant, and in manufacture persulfate the gel of household plastics Creates a brine carrier fluid that Used in low-sodium table salt Clay Potassium 0.060 prohibits fluid interaction with substitutes, medicines, and IV stabilizer chloride formation clays fluids Used as preservative in Corrosion Prevents corrosion of the well Formic acid 0.002 livestock feed; used as lime inhibitor casing remover in toilet bowl cleaners Maintains fluid viscosity as Used in laundry detergents, Crosslinker Borate salts 0.007 temperature increases hand soaps, and cosmetics Used as a flocculant in water Friction “Slicks” the water to minimize Polyacrylamide 0.088 treatment and manufacture of reducer friction paper Gelling Thickens the water to help Used as a thickener, binder, or Guar gum 0.056 agent suspend the sand propping agent stabilizer in foods Prevents precipitation of metal Used as flavoring agent or Iron control Citric acid 0.004 oxides preservative in foods Increases the viscosity of the Used in soaps, shampoos, Surfactant Lauryl sulfate 0.085 fluid detergents, and foaming agents Sodium hydroxide used in pH Sodium Adjusts pH of fluid to maintain soaps, drain cleaners; acetic acid adjusting hydroxide, 0.011 the effectiveness of other used as chemical reagent, main agent acetic acid components ingredient of vinegar Scale Sodium Prevents scale deposits in the Used in dishwashing liquids and 0.043 inhibitor polycarboxylate pipe other cleaners Ethanol, Winterizing isopropyl Added as necessary as stabilizer, Various cosmetic, medicinal, -- agent alcohol, drier, and anti-freezing agent and industrial uses methanol Total Additives 0.49 Total Water and Sand 99.51 *FracFocus Chemical Disclosure Registry, fracfocus.org/chemical-use/what-chemicals-are-used **USDOE 2009

97 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Following completion of fracturing activities, the pressure differential between the formation—a result of several thousand feet of overlying bedrock—and the borehole that connects with the surface causes most of the injected fluids to flow toward the borehole and then upward to the surface along with the hydrocarbon fluids released from the formation. The composition of this mixture, called flowback water, gradually shifts over a period of several days to a few months as injected fluids that have not yet migrated back to the wellbore or reacted with the native rock are carried out of the formation. In 2011, the COGCC published an analysis of hydraulic fracturing technology use in the state and potential risks to human health and the environment. The introduction to that report included the following paragraph:

“Hydraulic fracturing has occurred in Colorado since 1947. Nearly all active wells in Colorado have been hydraulically fractured. The COGCC serves as first responder to incidents and complaints concerning oil and gas wells, including those related to hydraulic fracturing. To date, the COGCC has not verified any instances of groundwater contaminated by hydraulic fracturing.”

Based on the information summarized above, the CRVFO has concluded that properly implemented hydraulic fracturing of oil and gas wells drilled within its boundaries for the purpose of accessing Federal fluid minerals or for accessing private fluid minerals from BLM surface lands does not represent a significant adverse impact to human health and the environment.

No Action Alternative

4.17. WILDLIFE –AQUATIC AND TERRESTRIAL

AQUATIC ORGANISMS

Affected Environment

The Proposed Action would occur in an area of highly dissected terrain containing a number of ephemeral drainages. Due to the short stream lengths and small watersheds of ephemeral streams potentially affected by the Proposed Action, fish species do not occur. Aquatic macroinvertebrates most likely to occur include water striders, water boatmen, predaceous diving beetles, and the aquatic larvae of caddisflies and true flies such as biting midges, nonbiting midges, and mosquitoes. Amphibians, if present, would probably be limited to spadefoots and true toads, which are adapted to seasonal flow regimes in arid environments.

The Colorado River is located approximately 0.5 miles from the proposed pad. In addition to the fish species identified in the special status fish section, fish surveys in the upper reaches of the Colorado River conducted by CPW and BLM have documented mountain whitefish (Prosopium williamsoni) and speckled dace (Rhinichthys osculus), as well as rainbow trout (Oncorhynchus mykiss) and brown trout (Salmo trutta), both non-native sportfish widely stocked throughout the region. The two trout have been widely introduced in mountainous areas of Colorado because of their tolerance for slightly warmer waters than the cutthroat trout and its ability to reproduce successfully in streams with small flows.

98 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Environmental Consequences

Proposed Action

Implementation of the Proposed Action has the potential to result in increases in erosion and sedimentation into nearby drainages and eventually the Colorado River. Because the Proposed Action includes summer use of the project areas, it is likely that roads and pads would not be muddy for extended periods. Roads are generally drier and in better condition during the non-winter months and consequently are less prone to erosion. Vehicular use during muddy road conditions could contribute to increased erosion of sediments into nearby ephemeral washes and eventually the Colorado River. The potential increase of sedimentation into the Colorado River would probably be nominal given background sediment loads currently carried by the river. Sediment-intolerant aquatic wildlife could be negatively affected, as increased erosion potential would persist and impair water and habitat quality. Measures to minimize erosion and sedimentation of aquatic environments are included in the COAs (Appendix).

No Action Alternative

Since all of the oil and gas wells proposed in this project would be developed in Federal minerals, the No Action Alternative would involve a scenario in which none of the 66 new Federal wells would be drilled, completed, or produced, despite their being proposed on existing well pads. Because no new well development would occur, pipeline or road upgrades would not be needed. Similarly, the temporary surface line proposed for installation between the PA 22-25 and PA 23-26 pads would not be needed.

Table 4 lists 17 Federal wells and 17 fee wells presently operating on the existing five well pads related to the Proposed Action. These 34 producing wells would continue to operate using the existing road and pipeline infrastructure on BLM and private land, including the potential impacts to aquatic biota associated with such operations over the next 25 to 30 years.

MIGRATORY BIRDS

Affected Environment

The project area includes pinyon-juniper woodlands, sagebrush grasslands, and some Gambel’s oak thickets. Given this vegetation, the project area provides cover, forage, breeding, and nesting habitat for a variety of migratory birds.

Species on the U.S. Fish and Wildlife Service (2008) list of Birds of Conservation Concern (BCC) for the project region include two species associated with pinyon-juniper woodlands, the pinyon jay (Gymnorhinus cyanocephalus) and juniper titmouse (Baeolophus griseus). Another BCC species, Cassin’s finch (Haemorhous cassinii), nests in higher elevation montane and subalpine conifer forests but commonly moves into pinyon-juniper woodlands following nesting and throughout winter. None of these species was observed during the most recent survey (WWE 2016a, 2016b, 2016c). Non-BCC species associated with this habitat type include the broad-tailed hummingbird (Selasphorus platycercus), black- chinned hummingbird (Archilochus alexandri), western kingbird (Tyrannus verticalis), Say’s phoebe (Sayornis saya), plumbeous vireo (Vireo plumbeus), Townsend’s solitaire (Myadestes townsendii), American robin (Turdus migratorius), mountain bluebird (Sialia sialis), blue-gray gnatcatcher (Polioptila caerulea), black-throated gray warbler (Setophaga nigrescens), chipping sparrow (Spizella passerina), lark sparrow (Chondestes grammacus), and lesser goldfinch (Spinus psaltria).

99 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Areas of mountain shrubs such as mountain-mahogany and serviceberry, although limited, have the potential to attract additional non-BCC species such as the black-headed grosbeak (Pheucticus melanocephalus) and spotted towhee (Pipilo maculata).

Sagebrush habitats may support one BCC species associated almost entirely with sagebrush steppe, the Brewer’s sparrow (Spizella breweri), as well as other migrants such as the western meadowlark (Sturnella neglecta), vesper sparrow (Pooecetes gramineus), and lark sparrow. Based on the extent and quality of the sagebrush, the habitat is marginal for Brewer’s sparrow and outside the normal range of the sagebrush sparrow (Artemisiopiza bellii), another obligate on sagebrush occurring in the Wyoming Basin of northwestern Colorado.

Oakbrush and mixed mountain shrub habitats in the area are suitable for migrants such as common poorwill (Phalaenoptilus nuttallii), dusky flycatcher (Empidonax oberholseri), Woodhouse’s scrub-jay (Aphelocoma woodhouseii), mountain chickadee (Poecile gambeli), Virginia’s warbler (Oreothlypis virginiae), MacGillivray’s warbler (Geothlypis tolmiei), spotted towhee, green-tailed towhee (P. chlorurus), black-headed grosbeak, and lazuli bunting (Passerina amoena).

Additional passerine (perching) birds commonly found in the area include year-round residents such as the common raven (Corvus corax), American crow, black-billed magpie, and house finch (Haemorhous mexicanus).

Raptors potentially nesting in the area include the red-tailed hawk (Buteo jamaicensis), Swainson’s hawk (B. swainsoni), Cooper’s hawk (Accipiter cooperii), sharp-shinned hawk (A. striatus), American kestrel (Falco sparverius), great horned owl (Bubo virginiana), and long-eared owl (Asio otus), the latter uncommonly. A small owl potentially nesting in the area, the flammulated owl (Psiloscops flammeolus), is a BCC species. Other additional BCC raptors nesting in the vicinity and potentially visiting the project area during foraging are the golden eagle and prairie falcon (Falco mexicanus), both potential transients from suitable nesting sites on cliffs and rocky bluffs throughout the area. The carrion-feeding turkey vulture (Cathartes aura) is also likely to search the area for food. Two BCC species that nest in the general project region but are not expected to forage within or near the site, the bald eagle and peregrine falcon, are BLM sensitive species (see the section on Special Status Species).

A raptor survey completed in May 2017 did not identify any occupied nests within 0.25 mile of the proposed development. Due to the transitory nature of many raptor species, the area would need to be resurveyed if the development is to be initiated in subsequent raptor nesting seasons (Appendix).

.Environmental Consequences

Proposed Action

The Proposed Action would result in a loss of nesting, roosting, perching, and foraging habitat for migratory birds on disturbed areas and reduce habitat effectiveness adjacent to areas where disturbance- related effects could be expected. The various new pads and pad expansions in the area would result in 25.19 acres of surface disturbance with 16.45 acres occurring on BLM. These changes to the habitat could negatively affect bird species that require large expanses of intact habitat. Habitat fragmentation could result in increased competition, increased exposure to predators, and a higher likelihood of nest parasitism. It is also possible that individual nests could be destroyed if the well pad, pipeline, and production facilities are constructed during the nesting season.

In addition to the physical loss of habitat and habitat fragmentation, it is possible that during construction activities, individual birds could be displaced to adjacent habitats due to noise and human presence. 100

100 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Effects of displacement could include increased risk of predation or failure to reproduce if adjacent habitat is at carrying capacity. Furthermore, impacts to birds at the species or local population level could include a change in abundance and composition as a result of cumulative habitat fragmentation from energy development in the larger area. Impacts to migratory bird species that nest in pinyon-juniper and sagebrush habitats can be minimized by avoiding surface-disturbing activities during the nesting season. take place outside the nesting season.

All migratory bird species are protected by the Migratory Bird Treaty Act (MBTA), which makes it unlawful to pursue, hunt, kill, capture, possess, buy, sell, purchase, or barter any migratory bird, including the feathers or other parts, nests, eggs, or migratory bird products. In addition to the MBTA, Executive Order 13186 sets forth the responsibilities of Federal agencies to implement further the provisions of the MBTA by integrating bird conservation principles and practices into agency activities and by ensuring that Federal actions evaluate the effects of actions and agency plans on migratory birds. Consistent with Executive Order 13186 and BLM Colorado guidelines, CRVFO has established as a COA (Appendix) a Timing Limitation (TL) prohibiting initiation of vegetation removal or ground-disturbing activities during the period May 15 to July 15, the peak period for incubation and brood rearing among migratory birds in the project vicinity. The BLM may grant an exception to this COA if surveys by a qualified biologist during the nesting season of BCC species potentially present indicate no active nests within 30 meters (100 feet) of the disturbance area.

Also for the protection of migratory birds is a COA (Appendix) specifying that any pits containing fluids must be fitted with one or more devices to avoid or minimize exposure to the fluids by migratory birds. Such exposures could result in acute toxicity or compromised insulation or buoyancy due to dissolution of protective oil on the feathers.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to migratory birds from implementation of the Proposed Action would not occur. However, any impacts associated with continued operation of the existing oil and gas facilities would extend over the next 25 to 30 years. Impacts resulting from other activities and resource uses, including grazing of livestock, and natural processes such as drought and wildland fires, would also continue to occur.

OTHER TERRESTRIAL SPECIES

Affected Environment

The project area would be located in medium density pinyon-juniper woodlands with openings of sagebrush; dense mountain brush becomes more predominant at the higher elevations of the project area with aspen stands at the highest elevations. Understory vegetation consists of mostly native grasses and forbs with some cheatgrass. Given these vegetation types, the area provides cover, forage, breeding, and nesting habitat for a variety of big game and small game species as well as nongame species.

MAMMALS

The project area is within overall ranges of mule deer (Odocoileus hemionus) and Rocky Mountain elk (Cervus elaphus nelsonii). Because of its low elevation, the project area consists of both winter range and severe winter range for mule deer, meaning that it receives most use by animals that have migrated 101

101 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

downslope to where temperatures are milder, snowcover thinner and less persistent, and forage more readily available. In addition to these migrant animals, a small number of mule deer reside in the general vicinity year-round. Winter densities of big game animals in a given area are dependent on the type of habitat present and the severity of the winter. Severe winter range is the portion of overall winter range used primarily during the most severe winters in terms of temperatures and, especially, snow cover. Consequently, severe winter range is typically at the lower margins of overall winter range and often comprised of plant species that are not necessarily ideal as forage but remain available when higher quality winter range is covered with deep snow.

Large carnivores potentially present in the project vicinity include the mountain lion (Felis concolor), which moves seasonally with its preferred prey, the mule deer, and the black bear (Ursus americanus). Two smaller carnivores, the coyote (Canis latrans) and bobcat (Lynx rufus), are also present throughout the region in open habitats and broken or wooded Terrain, respectively, where they hunt for small mammals, reptiles, and ground-dwelling birds. Other small carnivores potentially present are the raccoon (Procyon lotor) and striped skunk (Mephitis mephitis), and their analogous relatives the ringtail (Bassariscus astutus) and spotted skunk (Spilogale gracilis) in drier and more rugged, higher terrain and along smaller drainages.

Small mammals present within the planning area include rodents such as the rock squirrel (Otospermophilus variegatus), golden-mantled ground squirrel (Callospermophilus lateralis), least chipmunk (Tamias minimus), and packrat (bushy-tailed woodrat) (Neotoma cinerea), and lagomorphs such as the desert cottontail (Sylvilagus audubonii). Rodents and, to a lesser extent, lagomorphs are the primary prey base for a variety of avian and mammalian predators.

REPTILES AND AMPHIBIANS

The project area is within elevational range of most reptile species known to occur in Garfield County. Species most likely to occur include the short- horned lizard, (Phrynosoma hernandesi), western fence lizard (Sceloporus undulatus), tree lizard (Urosaurus ornatus), and gopher snake (bullsnake) (Pituophis catenifer) in pinyon-juniper woodlands, sagebrush shrublands, or grassy clearings. Other reptiles potentially present along riparian areas are the milk snake (Lampropeltis triangulum), western terrestrial garter snake (Thamnophis elegans), and smooth green snake (Liochlorophis vernalis).

The area is also within the known range of Woodhouse’s toad (Anaxyrus woodhousii), and western chorus frog (Pseudacris triseriata). Within the CRVFO and vicinity, Woodhouse’s toad occurs primarily along ephemeral washes that do not support fish and contain pools of water for a period of at least a few weeks every spring. The western chorus frog occurs primarily in cattail and bulrush wetlands and along the vegetated margins of seasonal or perennial ponds and slow-flowing streams.

Environmental Consequence

Proposed Action

Direct impacts to terrestrial wildlife from the Proposed Action may include mortality, disturbance, nest abandonment/nesting attempt failure, or site avoidance/displacement from otherwise suitable habitats. These effects could result from the 25.19 acres of habitat loss or modification, increased noise from vehicles and operation of equipment, increased human presence, and collisions between wildlife and vehicles. Impacts would be more substantial during critical seasons such as winter (deer and elk) or the spring/summer breeding season (raptors, songbirds, amphibians).

102

102 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Deer and elk are often restricted to smaller areas during the winter months and may expend high amounts of energy to move through snow, locate food, and maintain body temperature. Disturbance during the winter can displace wildlife, depleting much-needed energy reserves and may lead to decreased over winter survival. To minimize impacts to wintering big game, a Timing Limitation (TL) stipulation would be applied from December 1 through April 30 annually (Appendix). A big game TL requires that no construction, drilling or completion activities shall occur during the period of restriction. Terra has expressed a desire for year-round drilling to complete the drilling schedule outlined in Table 4, which would require an annual exception to the TL. Terra has been working in consultation with the BLM and CPW to develop a plan that would mitigate impacts that would potentially impair habitat value should a TL exception request be pursued.

Additional, indirect habitat loss may occur if increased human activity (e.g., traffic, noise) associated with infrastructure causes intolerant species to be displaced or alter their habitat use patterns. The extent of indirect habitat loss varies by species, the type and duration of the disturbance, and the amount of screening provided by vegetation and topography. In general, disturbance-related impacts are temporary, with patterns of distribution and habitat use returning to predisturbance conditions rather quickly when disturbance stops.

No Action Alternative

Under this alternative, none of the proposed 66 new wells and associated infrastructure would be approved, but the 17 Federal wells and 17 fee wells currently on the five existing well pads would continue to operate using the existing road and pipeline infrastructure on BLM and private lands. Therefore, impacts to mammals, reptiles, and amphibians from implementation of the Proposed Action would not occur. However, any impacts associated with continued operation of the existing oil and gas facilities would extend over the next 25 to 30 years. Impacts resulting from other activities and resource uses, including grazing of livestock, and with natural process such as drought and wildland fires, would also continue to occur.

5. CUMULATIVE IMPACTS

5.1. AIR RESOURCES

Regional Ozone and Cumulative Air Quality and AQRV Analyses

As part of the adaptive management strategy for managing air resources within the BLM planning areas, the BLM conducted a regional air modeling study to evaluate potential impacts on air quality from future mineral development in Colorado and northern New Mexico. The CARMMS (BLM 2016b) assesses predicted impacts on air quality and AQRVs from projected increases in oil and gas development. For instance, the CARMMS accounts for all existing and future development within the BGMDP project area, as well as within the nearby Bull Mountain, Black Hills, Fram Whitewater Unit, and North Fork Mancos project areas. The CARMMS includes potential impacts using projections of oil and gas development up to a maximum of 10 years in the future to reflect realistic estimations of development projections and technology improvements.

The CARMMS includes cumulative air quality and AQRV impact assessments from future year (year 2021) oil and gas development on Federal and non-Federal lands within 13 separate Colorado BLM planning areas as well as mining within the Colorado BLM planning areas. CARMMS also includes emissions from other regional sources, including oil and gas emissions throughout the modeling domain, which encompasses all of Colorado, western Arizona, western Utah, and north-central New Mexico and extends into southern Wyoming, western Nebraska, western Kansas, and northwest Texas. 103

103 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The CARMMS includes use of the Comprehensive Air-quality Model with extensions (CAMx) photochemical grid model (PGM) to estimate air quality and AQRV impacts for both a base case year (2008) and future year (2021). Emissions from all source types (anthropogenic and natural) are included in the CAMx modeling.

As part of the CARMMS, future year 2021 emissions estimates were developed for three development scenarios for the 13 Colorado planning areas. These are year 2021 high, medium, and low oil and gas development scenarios. Modeling results from the CARMMS are applicable for use in estimating potential ozone formation from regional emissions and project emissions, and for determining the maximum contribution of project sources to regional ozone formation. The CARMMS results are also applicable for project cumulative air quality and AQRV analyses. Given the level of oil and gas development that has occurred within the Colorado BLM planning areas since 2008 and the projected future development through year 2021, the CARMMS 2021 low oil and gas development scenario is most representative of the expected future oil and gas development within the planning areas and is used to describe the potential ozone formation from the BGMDP project area sources and for summarizing the cumulative air quality and AQRV analyses.

The CARMMS analysis includes the following eight BLM planning areas in western Colorado:

 Roan Plateau portion of the Colorado River Valley Field Office  Colorado River Valley Field Office outside of the Roan Plateau  Grand Junction Field Office  Kremmling Field Office  Little Snake Field Office  Tres Rios Field Office  Uncompahgre Field Office  White River Field Office The oil and gas emissions from wells on BLM-administered (Federal) lands, non-Federal lands, and totals for eight western Colorado BLM planning areas (the CARMMS 2021 Low Development Scenario) are shown in Table 41.

Table 41. Oil and Gas Emissions from the Eight Western Colorado BLM Planning Areas for the CARMMS 2021 Low Development Scenario

Emissions (tons per year) Scenario NOX VOCs CO SO2 PM10 PM2.5 Federal Wells 7,939 13,950 7,369 190 1,233 424 Non-Federal Wells 17,139 30,075 15,346 69 3,191 846 All Wells 25,078 44,025 22,715 259 4,424 1,270

The maximum future year field-wide development and production emissions from project sources are as follows: 129.2 tpy NOX, 17.1 tpy VOCs, 91.0 tpy CO, 0.3 tpy SO2, 50.2 tpy PM10 and 9.1 tpy PM2.5, and these emissions are included as part of the Roan Plateau portion of the CRVFO planning area emissions and in the eight western Colorado BLM planning area emissions totals shown in Table 41.

104

104 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Regional Ozone Impacts

The CARMMS included estimates of future year regional ozone impacts using two analysis methods. One method uses the change in the PGM concentrations between the base year (DVB) (year 2008) and future year (DVF) (year 2021) simulations to scale observed ozone concentrations from monitoring sites to obtain projected future year ozone concentrations. This method utilized EPA’s Modeled Attainment Test Software (MATS) (Abt Associates 2012) projection tool with the CAMx 2008 Base Year and 2021 High Development Scenario ozone concentrations to estimate ozone impacts. The second method uses the absolute modeling results from the CAMx model to estimate ozone impacts.

Figure 11 presents the CAMx predicted ozone concentrations using MATS. The current year base design values (DVBs) indicate areas of ozone exceedances of the NAAQS (70 ppb) in Colorado, eastern Utah, southern Wyoming, northeast Arizona, and northern New Mexico with the maximum concentrations near Denver and Salt Lake City.

2008 Ozone DVB 2021 Ozone DVF

2021 DVF – 2008 Ozone DVB Differences

Figure 11. Predicted Ozone Concentrations of the CARMMS 2021 Low Development Scenario

105

105 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The maximum DVB of 82.0 ppb is estimated just northwest of Denver (Figure 11, top left). The base year DVBs also indicate that areas near the project area in Garfield County are above the 70 ppb NAAQS, in the range of 71 to 73 ppb. For the 2021 Low Development Scenario, the area of 2021 ozone DVF exceedances is slightly reduced from the base year with a peak DVF of 78.3 ppb still northwest of Denver (Figure 11, top right). The Low Development Scenario indicates that the ranges of future year concentrations near the project area are slightly reduced from the base year. The 2021 DVF – 2008 DVB difference plot (Figure 11, bottom) shows mainly ozone reductions with the largest reduction in the Denver and Salt Lake City areas but ozone increases in the Western Slope Region counties, with the largest increases within southeastern Mesa County and central Montrose County. In the vicinity of the project area, certain areas have ozone reductions of up to 6.0 ppb while other areas have ozone increases of up to 1.0 ppb. The areas with increases in ozone are mainly south and east of the project area.

The CAMx absolute modeling results are presented in Figure 12. The ozone NAAQS is defined as the 3- year average of the 4th highest daily maximum 8-hour ozone concentrations. Because CARMMS only has 1 year of modeling results, the 2021 4th highest daily maximum 8-hour ozone concentrations are used for the NAAQS comparison metric.

CARMMS 2008 Base Case CARMMS 2021 Low Development Scenario

Difference of 2008 and 2021

Figure 12. Fourth Highest Daily Maximum 8-hour Ozone Concentrations

106

106 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Figure 12 displays the 4th highest ozone concentrations for the 2008 Base Case and the 2021 Low Development Scenario and their differences. For the 2008 Base Case, ozone exceedance areas occur in Colorado, eastern Utah, southern Wyoming, northeast Arizona, and northern New Mexico. The maximum ozone concentrations are estimated near Denver, Salt Lake City, and northern New Mexico, and on the border of Utah/Arizona (Figure 12, top left). The 2008 Base Case also indicates that areas near the project area in Garfield County are above the 70 ppb NAAQS, in the range of 71 to 73 ppb. In the 2021 Low Development Scenario, the area of ozone exceedances is slightly reduced, although increases in ozone concentrations are estimated in the Uinta Basin (Figure 12, top right).

The 2021 Low Development Scenario also indicates a slight reduction in ozone concentrations near the project area; however, areas nearby remain above the 70 ppb NAAQS, in the range of 71 to 73 ppb. The 2021-2008 ozone differences (Figure 12, bottom) show more decreases than increases, and the areas of ozone increases tend to occur in oil and gas development areas, such as the Denver-Julesberg, Piceance, and Uinta Basins. Small areas near the project area have ozone reductions of up to 3.0 ppb. As indicated in the CARRMS report, the maximum contribution to year 2021 regional ozone formation from the Roan Plateau portion of the CRVFO planning area’s Federal oil and gas sources is 1.1 ppb (BLM 2016b). Given that the Roan Plateau portion of the CRVFO planning area’s oil and gas emissions include 1,248 tpy NOX and 2,208 tpy VOCs, and that the maximum future year emissions from project sources include 129 tpy NOX and 17.1 tpy VOCs, the contribution to regional ozone from project sources would likely be less.

Cumulative Air Quality and AQRV Impacts

The CARMMS 2021 low oil and gas development modeling analysis presents a scenario that includes future year 2021 projected Federal and non-Federal oil and gas emissions throughout the 4-kilometer grid CARMMS domain plus mining on BLM-administered lands in Colorado. This scenario, which includes future year oil and gas emissions from the 13 Colorado BLM planning areas plus the Mancos Shale area in Northern New Mexico, and emissions from the Piceance Basin in Colorado and Uinta Basin in Utah, is presented herein to describe cumulative impacts of the Proposed Action. For the BGMDP cumulative analysis, these cumulative oil and gas emissions and mining emissions are considered reasonably foreseeable development (RFD) emissions.

The CARMMS included impact assessments at 55 PSD Class I and sensitive Class II areas, and at 58 lakes throughout the CARMMS modeling domain, which included each of the Class I and Class II areas and lakes that have been included in the project’s CALPUFF impacts analyses. For the project’s cumulative assessment, the CARMMS impacts are presented for the PSD Class I and sensitive Class II areas and lakes that were included in the CALPUFF analyses.

Air Quality Impacts. The modeled concentrations of NO2, SO2, PM10, and PM2.5 at Class I and sensitive Class II areas resulting from cumulative RFD source emissions are provided in Table 42 for comparison to applicable PSD Class I and Class II increments. All values are well below the PSD increments.

Visibility Impacts. Visibility impacts due to RFD oil and gas emissions and mining emissions were examined following the procedures provided by the USFWS and NPS (USFWS and NPS 2012). These procedures use EPA’s MATS to project the base year’s observed visibility impairment for the best 20% (B20%) and worst 20% (W20%) days to the future year using the 2008 Base Case and 2021 Low Development Scenario modeling results (which include contributions from all source categories (including anthropogenic and natural) with and without emissions from RFD sources.

107

107 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Table 42. Modeled Cumulative Pollutant Concentrations (CARMMS 2021 Low Development Scenario) at Class I and Sensitive Class II Areas (µg/m3)

Location Pollutant Averaging Time Concentration PSD Increment

NO2 Annual 0.120 2.5 3-hour 0.040 25 SO2 24-hour 0.014 5 Black Canyon of the Gunnison Annual 0.003 2 National Park 24-hour 0.434 8 PM 10 Annual 0.080 4 24-hour 0.385 2 PM 2.5 Annual 0.068 1 NO2 Annual 0.265 2.5 3-hour 0.054 25 SO2 24-hour 0.027 5 Annual 0.004 2 Colorado National Monument 24-hour 0.688 8 PM 10 Annual 0.115 4 24-hour 0.550 2 PM 2.5 Annual 0.100 1 NO2 Annual 0.259 2.5 3-hour 0.082 25 SO2 24-hour 0.033 5 Annual 0.005 2 Flat Tops Wilderness 24-hour 0.877 8 PM 10 Annual 0.176 4 24-hour 0.872 2 PM 2.5 Annual 0.154 1 NO2 Annual 0.189 2.5 3-hour 0.029 25 SO2 24-hour 0.012 5 Maroon Bells/Snowmass Annual 0.003 2 Wilderness 24-hour 0.520 8 PM 10 Annual 0.156 4 24-hour 0.450 2 PM 2.5 Annual 0.131 1 NO2 Annual 0.201 25 3-hour 0.028 25 SO2 24-hour 0.013 5 Annual 0.003 2 Raggeds Wilderness 24-hour 1.178 8 PM 10 Annual 0.232 4 24-hour 1.139 2 PM 2.5 Annual 0.209 1 NO2 Annual 0.121 2.5 3-hour 0.034 25 SO2 24-hour 0.011 5 Annual 0.003 2 West Elk Wilderness 24-hour 0.683 8 PM 10 Annual 0.182 4 24-hour 0.669 2 PM 2.5 Annual 0.167 1 108

108 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Tables 43 and 44 display the cumulative visibility results for the 2021 Low Development Scenario and RFD sources for W20 percent and B20 percent days, respectively. Note that because MATS was used and MATS only includes observed data for Class I areas, cumulative visibility results are presented for just the Class I areas. As is indicated in Table 43, from the 2008 Base Year to the 2021 Low Development Scenario future year, the W20 percent visibility metric is estimated to improve at each of the Class I areas. The biggest improvement is a reduction of 0.80 dv that occurs at the Maroon Bells- Snowmass Wilderness and goes from 8.68 dv in 2008 to 7.88 dv in 2021. RFD emissions are estimated to contribute a maximum of 0.15 dv to the 2021 W20 percent days visibility at Black Canyon of the Gunnison National Park.

Table 43. Cumulative Visibility Results for W20 Percent Visibility Days at Class I Areas for the 2008 Base Year and 2021 Low Development Scenario from RFD Sources W20 Visibility (Δdv) IMPROVE 2021 Low Class I Area State 2008 2021 Contribution Site Improvement Base Low from RFD from 2008 Black Canyon of the CO WEMI1 9.95 9.21 0.74 0.15 Gunnison National Park Flat Tops Wilderness CO WHRI1 8.68 8.00 0.68 0.14 Maroon Bells-Snowmass CO WHRI1 8.68 7.88 0.80 0.07 Wilderness West Elk Wilderness CO WHRI1 8.68 8.05 0.63 0.07

Cumulative visibility results at Class I areas for the B20 percent days are provided in Table 44. From 2008 to 2021, the B20 percent days visibility is estimated to improve in all Class I areas. The largest B20 percent visibility improvement is a 0.20 dv reduction at the Flat Tops Wilderness, from 0.69 to 0.49 dv. The maximum contribution from RFD sources to 2021 B20 percent visibility metrics is 0.10 dv, occurring at the Flat Tops Wilderness.

Table 44. Cumulative Visibility Results for B20 Percent Visibility Days at Class I Areas for the 2008 Base Year and 2021 Low Development Scenario from RFD Sources B20 Visibility (Δdv) IMPROVE 2021 Low Class I Area State 2008 2021 Contribution Site Improvement Base Low from RFD from 2008 Black Canyon of the CO WEMI1 2.25 2.13 0.12 0.08 Gunnison National Park Flat Tops Wilderness CO WHRI1 0.69 0.49 0.20 0.10 Maroon Bells-Snowmass CO WHRI1 0.69 0.51 0.18 0.03 Wilderness West Elk Wilderness CO WHRI1 0.69 0.56 0.13 0.04

Deposition Impacts. Potential atmospheric deposition impacts within Class I and sensitive Class II areas were calculated for cumulative RFD sources and are shown in Table 45. The maximum direct total (wet and dry) nitrogen and sulfur depositions are predicted to be well below the cumulative analysis thresholds of 2.3 kg/ha-yr for nitrogen and 5 kg/ha-yr for sulfur at all Class I and sensitive Class II areas. The maximum total nitrogen and sulfur deposition rates are approximately 13% and 0.2% of the cumulative analysis thresholds, occurring at the Flat Tops Wilderness.

109

109 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Table 45. Cumulative RFD Nitrogen and Sulfur Deposition Impacts (CARMMS 2021 Low Development Scenario) at Class I and Sensitive Class II Areas Maximum N Deposition Maximum S Deposition Location (kg/ha-yr) (kg/ha-yr) Black Canyon of the Gunnison National Park 0.178 0.003 Colorado National Monument 0.221 0.003 Flat Tops Wilderness 0.307 0.009 Maroon Bells/Snowmass Wilderness 0.230 0.007 Ragged Wilderness 0.210 0.006 West Elk Wilderness 0.194 0.005

Potential changes in ANC from baseline conditions resulting from potential nitrogen and sulfur deposition from cumulative RFD source emissions were calculated for nine sensitive lakes within the Class I and sensitive Class II wilderness areas. The estimated change in ANC for each lake is shown in Table 46. The estimated changes in ANC are all predicted to be above the applicable significance thresholds (less than a 10% change in ANC for lakes with ANC values greater than 25 μeq/L, and a 1.0 μeq/L change in ANC for lakes with background ANC values equal to or less than 25 µeq/L) at Ned Wilson and Upper Ned Wilson Lakes and Lower Packtrail Pothole in the Flat Tops Wilderness, and at Deep Creek Lake in the Raggeds Wilderness. The greatest percent change for lakes with ANC values greater than 25 μeq/L is 8.0% at Lower Packtrail Pothole. The greatest ANC change for lakes with background ANC values equal to or less than 25 µeq/L is 2.4 µeq/L at Upper Ned Wilson Lake.

Table 46. Cumulative RFD Impacts on Lakes (CARMMS 2021 Low Development Scenario) within the Class I and Sensitive Class II Areas 10th ANC ANC Percentile Nitrogen Sulfur Wilderness Sensitive Relative Absolute Lowest ANC Deposition Deposition Area Lake Change Change Value (kg/ha-yr) (kg/ha-yr) (µeq/L) (µeq/L) (µeq/L) Ned Wilson 39.0 0.251 0.008 6.1 n/a Lake Upper Ned 12.9 0.251 0.008 n/a 2.4 Wilson Lake Lower Flat Tops Packtrail 29.7 0.251 0.008 8.0 n/a Pothole Upper Packtrail 48.7 0.251 0.008 4.9 n/a Pothole Avalanche 158.8 0.230 0.007 1.2 n/a Lake Maroon Bells Capitol Lake 154.4 0.227 0.007 1.4 n/a Moon Lake 53.0 0.227 0.007 4.2 n/a Deep Creek Raggeds 20.6 0.181 0.007 n/a 2.2 Lake South Golden West Elk 111.4 0.166 0.007 1.6 n/a Lake

110

110 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Greenhouse Gas Impacts

Continued field development, operation of well site equipment, and associated vehicle traffic would result in minor cumulative contributions to atmospheric GHGs. Oil produced under the Proposed Action would be refined to produce a wide range of fuel products for consumer or commercial use. The combustion of these fuels would generate GHGs, which would be controlled through applicable GHG emission control regulations (emissions standards) or by applicable air permit requirements.

Other industrial operations in the area would also contribute to GHG emissions through the use of carbon fuels (natural gas, liquefied petroleum gas, and diesel), and through the use of electricity produced using carbon fuels. Other anthropogenic activities, such as residential wood and open burning, as well as biogenic sources, also contribute GHGs to the atmosphere. These would be more dispersed, but also more sustained, than the emissions from this oil and gas development, which has a finite lifespan.

While significance levels exist to determine PSD applicability and emissions control requirements for GHGs, policies regulating specific GHG concentration levels and their potential for significance with respect to regional or global impacts have not been established for GHGs. As stated in Section 4.2, the maximum GHG emissions resulting from the Proposed Action are estimated at 26,851 metric tons per year (0.03 MMT) of CO2e. To place the project GHG emissions in context, the GHG emissions in year 2015 from the top five emitting coal-fired power plants in Colorado ranged from 3.1 to 8.4 MMT (EPA 2017d. In addition, 0.03 MMT is approximately equivalent to 0.0004% of the total 2015 U.S. CO2e emissions (6,586 MMT) (EPA 2017d); 0.06 MMT is approximately equivalent to 0.0009% of the total 2011 nationwide CO2e emissions. Given the state of the science, it is not possible to associate specific actions with the specific global impacts, such as potential climate effects. Because there are no tools available to quantify incremental climate changes associated with these GHG emissions, the analysis cannot reach conclusions as to the extent or significance of the project-specific emissions on global climate. The potential impacts of climate change represent the cumulative aggregation of all worldwide GHG emissions.

5.2. EXISTING OIL AND GAS DEVELOPMENTS

The Balzac Gulch MDP – Phase 1 project encompasses two Federal leases to be developed along the south-facing ridges and drainages of the Roan Plateau. Lease COC73094 is one of the Federal leases “below the rim” that was analyzed in the Roan Plateau EIS/RMPA (BLM 2016a). Aside from Federal lease COC62161 (held by production) that underlies 320 acres of the westernmost portion of the MDP area containing 14 new bottomholes, the majority of the bottomhole targets proposed on this MDP would fall within Federal lease COC73094. The vast area below the Roan Plateau rim between Parachute and West Rifle (known as the Wheeler to Webster Mesa MDP) has previously been developed under a series of NEPA documents prepared since the early 2000’s to address and analyze the majority of in-fill oil and gas development “below the rim” of the Roan Plateau (Table 1). Because of the delays in completing the Roan Plateau EIS/RMPA, Federal lease COC73094 remains the only undeveloped Federal lease parcel within the former Wheeler to Webster Mesa MDP boundary between Parachute and West Rifle. From a cumulative impact analysis standpoint, the surrounding federal and private oil and gas leases below the rim of the Roan Plateau (aside from the recently available COC73094) have reached or will reach in the near future the maximum amount of development possible with 10-acre spacing. In short, COC73094 is currently an undeveloped strip of Federal land that, with the Balzac Gulch MDP, will eventually reach full field development of the available 10-acre bottomholes.

111

111 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

In reviewing COGCC data regarding existing oil and gas fields, the new Federal wells proposed for development in Sections 19 and 24 would fall within the Rulison Field while the wells falling within Sections 25 and 26 would be within the Parachute Field. Focusing on the Balzac Gulch MDP boundary, Terra, the sole operator of oil and gas wells in the project area, currently manages 11 pad locations within the project area supporting 79 producing wells - 34 Federal wells and 45 Fee wells (Table 1). Six of the 11 existing pads are located on BLM land and support 26 Federal wells while two private-surface pads have eight Federal wells and 25 fee wells. Three other pads on private land support only fee wells, totaling 20 fee wells. With the full development of the planned 66 Federal wells in the Balzac Gulch MDP – Phase 1, the total amount of Federal wells producing oil and gas within the MDP boundary would rise to 100 wells, an increase of 194%. Although there are no new fee wells proposed in the BGMDP – Phase 1 project, the total well count for the project area would increase 84%. Under the No Action Alternative, the 66 Federal wells described in the Proposed Action would not be drilled, having essentially no effect on cumulative impacts since only Federal wells are being considered.

5.3. SUMMARY OF CUMULATIVE IMPACTS

Adverse cumulative impacts in the CRVFO gas-producing region have included:

 Direct habitat loss, habitat fragmentation, and decreased habitat effectiveness  Increased risk of adverse impacts to special status plant and animal species  Expansion of noxious weeds and other invasive species  Increased potential for runoff, erosion, and sedimentation of surface waters  Increased potential for adverse impacts on fresh-water aquifers and domestic water wells  Increased fugitive dust from construction of the well pad, access road, and pipelines  Increased gaseous emissions, including VOCs and priority pollutants, from vehicles, compressors, and other internal combustion sources and from oil and gas production facilities  Increased potential for spills and other releases of chemical pollutants  Increased traffic on state, county, and local roads  Increased noise, especially along access and haul roads  Increased risk of damage to cultural and paleontological resources  Decreased solitude and scenic quality In addition to these potential adverse (negative) cumulative impacts have been positive (beneficial) cumulative impacts, including the increased availability of a valuable and important commodity, increased direct and indirect employment, and enrichment of Federal, State, and County/Local coffers from royalties, PILT, property taxes, and/or sales taxes. Cumulative impacts associated with the Proposed Action would include those noted above for previous oil and gas projects in the CRVFO area and nearby portions of the CRVFO.

It should also be noted that new technologies and increasingly stringent Federal and State regulatory requirements have reduced the impacts of oil and gas developments in recent years. This trend is expected to continue, as evidenced by implementation of the Colorado Air Resources Protection Protocol (CARPP), which incorporates the CARMMS process. Using the air emissions inventory tool 112

112 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

incorporated into CARMMS, the BLM will assess project emissions, in combination with periodically updated meteorological and regional air quality data, to determine if exceedances of standards occur that are potentially related to oil and gas and, if so, to evaluate additional mitigation.

Based on the above, the relatively small scale of the project in terms of surface disturbance and duration and the stringent environmental and operational protections imposed by BLM, COGCC, and CDPHE on both Federal and Fee wells is expected to avoid significant cumulative adverse impacts in the project region as well as significant direct and indirect impacts.

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 the other past, present, and reasonably foreseeable future actions...” The following narrative describes past, present, and reasonably foreseeable actions known to BLM that may occur within the broader project vicinity.

Historically, habitat loss or modification in the CRVFO areas was characteristic of agricultural, ranching lands, rural residential, with localized industrial impacts associated with the railroad and I-70 corridors and the small communities. More recently, the growth of residential and commercial uses, utility corridors, oil and gas developments, and other rural industrial uses (e.g., gravel mining along the Colorado River) has accelerated the accumulation of impacts in the area. Cumulative impacts have included (1) direct habitat loss, habitat fragmentation, and decreased habitat effectiveness; (2) increased potential for runoff, erosion, and sedimentation; (3) expansion of noxious weeds and other invasive species; (4) increased fugitive dust from construction of oil and gas pads, roads, and pipelines and associated truck travel; (5) increased noise, especially along access and haul roads; (6) increased potential for spills and other releases of chemical pollutants; (7) decreased scenic quality, and (8) increased air emissions from construction, drilling, completions and well production operations.

Although none of the cumulative impacts was described in the 2015 RMP/ROD (BLM 2015) as significant, and while new technologies and regulatory requirements have reduced the impacts of some activities, many existing and future actions will continue or begin to have adverse effects on various elements of the human and natural environment. Anticipated impacts for existing and future actions range from negligible to locally major, and primarily negative, for specific resources.

The primary bases for this assessment are twofold: First, although the rate of development, including oil and gas development, has slowed in recent years due to the general economic downturn and depressed natural gas prices, some development continues to occur, adding to the previous residential, commercial, and industrial growth and to the previous habitat loss, modification, and fragmentation. Second, residential and commercial expansion, as well as most of the oil and gas development, has occurred on private lands where mitigation measures designed to protect and conserve resources may not be in effect to the same extent as on BLM lands. However, COGCC regulations enacted in recent years have closed considerably the former gap between the potential environmental impacts associated with development of private versus Federal fluid mineral resources.

Based on the above, the Proposed Action would contribute to the collective adverse impact for some resources. Although the contribution would be minor, the Proposed Action would contribute incrementally to the collective impact to air quality, native vegetation, migratory birds, terrestrial wildlife, and other resources.

113

113 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

6. PERSONS AND AGENCIES CONSULTED

Terra Energy Partners – Adam Tankersley, Jeff Kirtland, Eric Dekam, Kevin Moore, Bryan Hotard, Kyle Kohl, Brandon Sagrillo WestWater Engineering – Amie Wilsey Dave Kubeczko – Colorado Oil and Gas Conservation Commission Taylor Elm – Colorado Parks and Wildlife

7. INTERDISCIPLINARY REVIEW

BLM staff from the CRVFO and personnel from Edge Environmental who participated in the preparation of this EA, including review of survey results submitted by the operator’s consultants, evaluation of impacts likely to occur from implementation of the Proposed Action, and identification of appropriate COAs to be attached and enforced by BLM, are listed in Table 47.

Table 47. BLM Interdisciplinary Team Authors and Reviewers

Name Title Areas of Participation Cultural Resources, Native American Religious John Brogan Archaeologist Concerns Invasive Nonnative Species, Special Status Plants, Mary Bloomstran Edge Environmental Vegetation EA Project Lead, Access & Transportation, Jim Byers Natural Resource Specialist Socioeconomic, Visual Resources, Wastes- Hazardous or Solid Vanessa Caranese Geologist Geology and Minerals, Groundwater, Paleontology Supervisory Natural Resource Allen Crockett, Ph.D. Technical Review, NEPA Review Specialist Stephen Garcia Petroleum Engineer Downhole COAs Kimberly Leitzinger Outdoor Recreation Planner Wilderness Laura Millard Realty Specialist Realty Authorizations Migratory Birds, Special Status Species Animals, Sylvia Ringer Wildlife Biologist Aquatic and Terrestrial Wildlife Air Quality, Noise, Soils, Surface Water, Waters of Carmia Woolley Physical Scientist the U.S.

Participation by the BLM Interdisciplinary Team included site visits to assess existing conditions, comparing proposed activities and locations with resource information in the BLM’s corporate GIS database, interacting with the project proponent and its contractors to improve the project design, and identifying appropriate management actions and mitigation measures for avoiding, reducing, or offsetting adverse impacts, and ensuring compliance with the 2015 CRVFO ARMP/ROD.

8. REFERENCES CITED

Abt Associates. 2012. Modeled Attainment Software, User’s Manual. Abt Associates Inc., Bethesda, MD. October. (http://www.epa.gov/ttn/scram/guidance/guide/MATS-2-5-1_manual.pdf).

Angold, P.G. 1997. The impact of a road upon adjacent heathland vegetation: effects on plant species composition. Journal of Applied Ecology 34:409-417.

114

114 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Auerbach, N.A., M.D. Walker, and D.A. Walker. 1997. Effects of roadside disturbance on substrate and vegetation properties in arctic tundra. Ecological Applications 7:218-235.

Baron, J. S. 2006. Hindcasting Nitrogen Deposition to Determine an Ecological Critical Load. Ecological Applications, 16(2), 2006, pp 433-439.

Bureau of Land Management (BLM). 1999. Oil & Gas Leasing & Development – Final Supplemental Environmental Impact Statement. Glenwood Spring Field Office, Colorado.

______. 2006. Final Roan Plateau Resource Management Plan Amendment & Environmental Impact Statement, Volume III, Appendix C. Glenwood Springs Field Office, Colorado.

______. 2007. Final biological assessment, vegetation treatments on BLM lands in 17 western states. Reno, NV.

______. 2015. Colorado River Valley Field Office (CRVFO) Record of Decision and Approved Resource Management Plan (ROD/RMP), approved June 12, 2015.

______. 2016a. Roan Plateau Planning Area including Naval Oil shale Reserves Number 1 and 3 Record of Decision and Resource Management Plan Amendment, approved November 14, 2016.

______. 2016b. Colorado Air Resource Management Modeling Study (CARMMS) with Updated Mancos Shale Modeling, 2021 Modeling Results for the High, Low and Medium Oil and Gas Development Scenarios (CARMMS 1.5 Final Report), Bureau of Land Management, New Mexico State Office, Santa Fe, New Mexico. March.

Cole, R.D., G.J. Daub, and L.K. Weston. 1995. Review of geology, mineral resources, and ground-water hydrology of Green River Formation, north-central Piceance Creek Basin, Colorado. In W.R. Averett (Ed.), The Green River Formation in Piceance Creek and Eastern Uinta Basins: Grand Junction, Colorado, Grand Junction Geological Society, p. 63-81.

Colorado Department of Labor and Employment (CDLE). 2016. Summary Area Profile for Garfield County, Colorado. Colorado LMI Gateway. Available online at: https://www.colmigateway.com/vosnet/Default.aspx. Accessed on December 7, 2016. Colorado Department of Local Affairs (CDOLA). 2015. Preliminary Population Forecasts by County, 2010 to 2050. October 2015. Available online at: https://demography.dola.colorado.gov/population/population-totals-counties/#population-totals-for- colorado-counties. Accessed on December 7, 2016. ______. 2016. Demographic Profiles – County. Available online at: https://demography.dola.colorado.gov/population/data/profile-county/. Accessed on December 7, 2016.

Colorado Department of Public Health and Environment (CDPHE). 2016a. Colorado Air Quality Data Report 2015. Air Pollution Control Division. October 2016.

______.. 2016b. Colorado Department of Public Health and Environment, Air Pollution Control Division, Letter from Nancy Chick to Susan Connell, Carter Lake Consulting, LLC, Summary of background air pollution estimates for the Whitewater Unit, Fram Operating LLC, BLM NEPA Air Analysis. November 23, 2016.

115

115 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

_____. 2016c. Water Quality Control Commission, Regulation No. 93. Colorado’s Section 303(d) List of Impaired Waters and Monitoring and Evaluation List. Effective November 30, 2016. Available online at: https://www.colorado.gov/pacific/sites/default/files/93_2016%2811%29.pdf. Accessed on August 23, 2017.

_____. 2017. Water Quality Control Commission, Regulation No. 37. Classifications and Numeric Standards for Lower Colorado River Basin. Effective June 30, 2017. Available online at: https://www.colorado.gov/pacific/sites/default/files/37_2017%2806%29.pdf. Accessed on August 23, 2017.

Colorado Geological Survey (CGS). 2003. Ground Water Atlas of Colorado, Special Publication 53:97- 106.

Colorado Oil and Gas Commission (COGCC). 2014. Aesthetic and Noise Control Regulations. Available online at: https://cogcc.state.co.us/documents/reg/Rules/LATEST/800Series.pdf. Accessed on September 5, 2017.

______. 2015. COGCC GIS Online database and interactive map. Available online at: http://dnrwebmapgdev.state.co.us/mg2012app/.

______2016. Annual Production in Garfield County, 2000 to 2016. Available online at: http://cogcc.state.co.us/data.html. Accessed on December 14, 2016.

Davies, R. J., S. Mathias, J. Moss, S. Hustoft, and L Newport. 2012. Hydraulic Fractures: How far can they go? Marine and Petroleum Geology 37(1):1-6. November.

Donnell, J.R., W.E. Yeend, and M.C. Smith. Geologic Map of the Grand Valley Quadrangle, Garfield County, CO. 1:24,000 Scale. Map MF-1883.

EnerMax, Inc. 2007. Hydraulic fracturing. http://www.enermaxinc.com/hydraulic-fracturing.

ENVIRON. 2015. The Mesoscale Model Interface Program (MMIF) Version 3.2, Draft User’s Manual. Prepared for Environmental Protection Agency Office of Air Quality Planning and Standards, Air Quality Assessment Division, Air Quality Modeling Group, Research Triangle Park, North Carolina. July 24, 2015.

Farmer, A.M. 1993. The effects of dust on vegetation – a review. Environmental Pollution 79:63-75.

Federal Land Managers’ Air Quality Related Values Workgroup. 2010. Federal Land Managers’ Air Quality Related Values Work Group (FLAG) Phase I Report – Revised (2010). U.S. Forest Service-Air Quality Program, National Park Service-Air Resources Division, U.S. Fish and Wildlife Service-Air Quality Branch. October 2010.

Field, J.P., J. Belnap, D.D. Breshears, J.C. Neff, G.S. Okin, J.J. Whicker, T.H. Painter, S. Ravi, R.C. Reheis, and R.L. Reynolds. 2010. The ecology of dust. Frontiers in Ecology and the Environment 8:423-430.

Fenneman, N. M. 1946. Physical subdivisions of the United States (Map): U.S. Geological Survey, 1:700,000, 1 sheet.

116

116 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Fisher, K., and N. Warpinski. 2011. Hydraulic-Fracture-Height Growth: Real Data. SPE Production & Operations Journal 27(1):8-19. SPE-145949-PA. http://dx.doi.org/10.2118/145949-PA.

Fox, D., A.M. Bartuska, J G. Byrne, E. Cowling, R. Fisher, G.E. Likens, S.E. Lindberg, R.A. Linthurst, J. Messer, and D.S. Nichols. 1989. A Screening Procedure to Evaluate Air Pollution Effects on Class I Wilderness Areas. General Technical Report RM-168. USDA. Forest Service, Rocky Mountain Forest and Range Experiment Station, Fort Collins, Colorado. 36 pp.

Franczyk, K.J., J.K. Pitman, and D.J. Nichols. 1990. Sedimentology, mineralogy, and depositional history of some Uppermost Cretaceous Lowermost Tertiary rocks along the Utah Book and Roan Cliffs east of the Green River: U.S. Geological Survey Bulletin 1787:27 pp.

Garfield County. 2016. About Garfield County. Available online at: http://www.garfield-county.com/about-garfield-county/index.aspx. Accessed on December 7, 2016.

______. 2016a. Garfield County Profile, New Energy in the Wild West. Available online at: http://www.garfield-county.com/economic-development/garfield-county-profile.aspx. Accessed on December 14, 2016.

______. 2016b. 2015 Abstract of Assessment and Tax Levies, Garfield County, Colorado. Available online at: http://www.garfield-county.com/assessor/documents/2015-Abstract-brochure.pdf. Accessed on December 14, 2016.

George, R.D. 1927. Geology and natural resources of Colorado. University of Colorado, Boulder.

Gelbard, J.L., and J. Belnap. 2003. Roads as conduits for exotic plant invasions in a semiarid landscape. Conservation Biology 17(2):420-432.

Gieselman, T.M. 2010. Changes in grassland community composition at human-induced edges in the south Okanagan. Master of Science Dissertation. The University of British Columbia, Vancouver.

Glover, K.C., D.L. Naftz, and L.J. Martin, 1998. Geohydrology of tertiary rocks in the Upper Colorado River basin in Colorado, Utah, and Wyoming, excluding the San Juan Basin, regional aquifer-system analysis. U.S. Geological Survey Water-Resources Investigations Report 96-4105.

Green, C.A., R.D. Barree, and J.L. Miskimins. 2009. Hydraulic-Fracture-Model Sensitivity Analysis of a Massively Stacked, Lenticular, Tight Gas Reservoir. SPE Production & Operations Journal 24(1):66-73. SPE 106270-PA. February.

Harris, C.M. 1991. Handbook of acoustical measurements and noise control, McGraw-Hill, Inc., New York.

Hemborg, T.H. 2000. Gas production characteristics of the Rulison, Grand Valley, Mamm Creek, and Parachute Fields, Garfield County, Colorado: Turning marginally economic basin-centered tight-gas sands into profitable reservoirs in the Southern Piceance Basin. Colorado Geological Survey, Resource Series 39. Denver.

117

117 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Hierro, J.L., D. Villarreal, O. Eren, J.M. Graham, and R.M. Callaway. 2006. Disturbance facilitates invasion: the effects are stronger abroad than at home. The American Naturalist 168(2):144-156.

Interagency Monitoring of Protected Visual Environments (IMPROVE). 2017a. Regional Haze Rule Summary Data (1988 – 2015), Natural Haze Levels II, Using the Revised (New) IMPROVE Algorithm. Available online: http://vista.cira.colostate.edu/Improve/rhr-summary-data/. Accessed in August 2017. ______. 2017b. U.S. Forest Service Water Quality Data, Federal Land Manager Environmental Database. Available online: http://views.cira.colostate.edu/fed/DataWizard/Default.aspx?dsfil=water/. Accessed in May 2017. Intergovernmental Panel on Climate Change (IPCC). 2013. Climate Change 2013: The Physical Science Basis, Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. [Stocker, T. F., D. Qin, G. K. Plattner, M. Tignor, S. K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex, and P. M. Midgley (eds.)] Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. 1,535 pp.

Johnson, R.C., 1985, Early Cenozoic history of the Uinta and Piceance Creek Basins, Utah and Colorado, with special reference to the development of Eocene Lake Uinta United States: Rocky Mountain Section, Society of Economic Paleontology and Mineralogy: Denver, Colo., p. 247–276.

Johnson, R.C. 1989. Geologic history and hydrocarbon potential of late Cretaceous-age, low- permeability reservoirs, Piceance Basin, western Colorado: U.S. Geological Survey Bulletin 1787, Evolution of sedimentary basins-Uinta and Piceance Basins, chapter E, 51 p.

Johnston, F.M., and S.W. Johnston. 2004. Impacts of road disturbance on soil properties and on exotic plant occurrence in subalpine areas of the Australian Alps. Arctic, Antarctic, and Alpine Research 36:201-207.

Klironomos, J.N. 2002. Feedback with soil biota contributes to plant rarity and invasiveness in communities. Nature, 417:67-70.

Kuuskraa, V.A. 1997. Producing massively stacked lenticular sands of Colorado’s Piceance Basin: Gas Tips – A Publication of Gas Research Institute GRI-97/0206:4-11.

La Plata County, Colorado. 2002. Final La Plata County Impact Report. October.

Larson, D.L. 2003. Native weeds and exotic plants: relationships to disturbance in mixed-grass prairie. Plant Ecology 169:317-333.

Lorenz, J.C. 1989. Reservoir sedimentology of rocks of the Mesaverde Group, multiwall experiment site and east-central Piceance Basin, northwest Colorado. In B.E. Law and C.W. Spencer, C.W. (Eds.), Geology of tight gas reservoirs in the Pinedale Anticline area, Wyoming, and at the multiwall experiment site, Colorado: U.S. Geological Survey Bulletin 1886:K1-K24.

Maxwell, S.C. 2011. Hydraulic Fracture Height Growth. Canadian Society of Exploration Geophysicists (CSEG) Recorder. November.

Murphy, P.C., and D. Daitch. 2007. Paleontological overview of oil shale and tar sands areas in Colorado, Utah, and Wyoming, p. 58.

118

118 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

National Academy of Sciences (NAS). 2012. Induced Seismicity Potential in Energy Technologies. National Academy Press, Washington, DC.

National Climate Assessment (NCA). 2014a. J.M. Melillo, T.C. Richmond, and G.W. Yohe, eds. 2014: Climate Change Impacts in the United States: The Third National Climate Assessment. U.S. Global Change Research Program, 841 pp. doi: 10.7930/J0Z31WJ2.

______. 2014b. G. Garfin, G. Franco, H. Blanco, A. Comrie, P. Gonzalez, T. Piechota, R. Smyth, and R. Waskom, 2014: Ch. 20: Southwest. Climate Change Impacts in the United States: The Third National Climate Assessment, J.M. Melillo, T.C. Richmond, and G.W. Yohe, Eds., U.S. Global Change Research Program, 462–486. doi:10.7930/J08G8HMN. Accessed online: http://nca2014.globalchange.gov/report/regions/southwest.

National Oceanic and Atmospheric Administration (NOAA). 2013. National Climate Data Center. State of the Climate: Global Analysis for Annual 2013. National Climate Data Center, December 2013. Accessed online: http://www.ncdc.noaa.gov/sotc/global/2013/13.

National Park Service (NPS). 2014. National Park Service Air Resources Division, Email from Andrea Stacy NPS to Charis Tuers BLM Wyoming State Office regarding applicable critical load values for Wyoming and Colorado, August 15, 2014.

Palisch, T.T., M.A. Chapman, and J. Godwin. 2012. Hydraulic Fracture Design Optimization in Unconventional Reservoirs: A Case History. Paper SPE 160206 presented at the Annual Technical Conference and Exhibition, San Antonio, TX. October 8-10.

Parendes, L.A., and J.A. Jones. 2000. Role of light availability and dispersal in exotic plant invasion along roads and streams in the H.J. Andrews Experimental Forest, Oregon. Conservation Biology 14(1):64-75.

Pardo, L.H., M.E. Fenn, C.L. Goodale, L.H. Geiser, C.T. Driscoll, E.B. Allen, J.S. Baron, R. Bobbink, W.D. Bowman, C.M. Clark, B. Emmett, F.S. Gilliam, T.L. Greaver, S.J. Hall, E.A. Lilleskov, L. Liu, J.A. Lynch, K.J. Nadelhoffer, S.S. Perakis, M.J. Robin-Abbott, J.L. Stoddard, K.C. Weathers, and R.L. Dennis. 2011. Effects of nitrogen deposition and empirical nitrogen critical loads for ecoregions of the United States. Ecological Applications. 21(8): 3049–3082.

Parker, J. M., and S. H. Anderson. 2007. Ecology and behavior of the midget faded rattlesnake (Crotalus oreganus concolor) in Wyoming. Journal of Herpetology 41:45–51

Reinhart, K.O., and R.M. Callaway. 2006. Soil biota and invasive plants. New Phytologist 170:445-447.

Robson, S.G., and G.J. Saulnier, Jr. 1981. Hydrogeochemistry and simulated solute transport, Piceance Basin, northwestern Colorado. U.S. Geological Survey Professional Paper 1196, 65 p.

Schmidt, W. 1989. Plant dispersal by motor cars. Vegetatio, 80:147-152.

Sharifi, M.R., A.C. Gibson, and P.W. Rundel. 1997. Surface dust impacts on gas exchange in Mojave Desert shrubs. Journal of Applied Ecology 34(4):837-846.

Spencer, C.W., and Wilson, R.J., 1988. Petroleum geology and principal exploration plays in the Uinta- Piceance-Eagle Basins Province, Utah and Colorado: U.S. Geological Survey Open-File Report 88-450- G, 35 p. 119

119 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Thompson, J.R., P.W. Mueller, W. Fluckiger, and A.J. Rutter. 1984. The effect of dust on photosynthesis and its significance for roadside plants. Environmental Pollution (Series A), 34:171-190.

University of North Carolina Institute for the Environment and ENVIRON. 2015. Three State Air Quality Study (3SAQS) Weather Research Forecast Model Year 2011 Modeling Application/Evaluation. Prepared for Western Regional Air Partnership c/o CIRA, Colorado State University, Fort Collins, CO. March 2015.

U.S. Bureau of Economic Analysis. 2016. Personal Income Summary, Garfield County, 2000 to 2015. Available online at: http://www.bea.gov/iTable/iTable.cfm?ReqID=70&step=1.#reqid=70&step=30&isuri=1&7022=20&702 3=7&7024=non-industry&7033=-1&7025=4&7026=08045&7027=-1&7001=720&7028=- 1&7031=08000&7040=-1&7083=levels&7029=20&7090=70. Accessed on December 8, 2016.

U.S. Census Bureau. 2012. 2010 Census of Population and Housing, Population and Housing Unit Counts. CPH-2-7. Colorado. U.S. Government Printing Office, Washington, DC. Available online at: http://www.census.gov/prod/cen2010/cph-2-7.pdf. Accessed on December 7, 2016.

U.S. Department of Agriculture (USDA). 2016. Natural Resources Conservation Service Web Soil Survey. Available online at: https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx. Accessed on August 23, 2017.

U.S. Department of Energy (DOE). 2009. Modern Shale Gas Development in the United States: A Primer. National Energy Technology Laboratory, Morgantown, WV, and Office of Fossil Energy, Washington, DC. April.

______. 2013. U.S. Energy Information Administration U.S. Natural Gas Wellhead Price. http://www.eia.gov/dnav/ng/hist/n9190us3a.htm.

______. 2016. U.S. Energy Information Administration U.S Natural Gas Wellhead Price. http://www.eia.gov/dnav/ng/hist/n9130us3m.htm

U.S. Department of the Interior. 2016. Fiscal Year 2016 Payments In Lieu of Taxes National Summary. Available online at: https://www.doi.gov/pilt/resources/annual-reports. Accessed on December 14, 2016.

U.S. Department of the Interior and U.S. Department of Agriculture (USDI and USDA). 2007. Surface operating standards and guidelines for oil and gas exploration and development. The Gold Book. Fourth edition.

U.S. Environmental Protection Agency (EPA). 1974. Information on noise levels identified as requisite to protect public health and welfare with an adequate margin of safety. EPA-550/9-74-004, Arlington, VA.

______1993. Superfund's Standard Default Exposure Factors for the Central Tendency and Reasonable Maximum Exposure. Preliminary Review Draft.

______. 2004. Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs. Document #EPA 816-R-04-003. Office of Ground Water and Drinking Water Drinking Water Protection, Washington, DC.

120

120 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

______. 2005. Guideline on Air Quality Models. Updated 2005. Environmental Protection Agency Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. Published in Federal Register, Vol. 70, No. 216, November 9, 2005.

______. 2006. Drinking water standards and health advisories, EPA 822-R-06-013, August 2006. Available online.

______. 2010. Applicability of Appendix W Modeling Guidance for the 1-hour NO2 National Ambient Air Quality Standard. U.S. Environmental Protection Agency, Office of Air Quality and Planning Standards, Research Triangle Park, North Carolina. June.

______. 2014a. Dose-Response Assessment for Assessing Health Risks Associated With Exposure to Hazardous Air Pollutants, Table 2, Acute Dose-Response Values for Screening Risk Assessments (9/18/2014). Technology Transfer Network - Air Toxics Web Site. Available online at: https://www.epa.gov/fera/dose-response-assessment-assessing-health-risks-associated-exposure- hazardous-air-pollutants. Accessed in August 2017.

______. 2014b. Dose-Response Assessment for Assessing Health Risks Associated With Exposure to Hazardous Air Pollutants, Table 1, Prioritized Chronic Dose-Response Values (5/9/2014). Technology Transfer Network - Air Toxics Web Site. Available online at: https://www.epa.gov/fera/dose-response- assessment-assessing-health-risks-associated-exposure-hazardous-air-pollutants. Accessed in August 2017.

______. 2014c. 40 CFR Part 98. Mandatory Greenhouse Gas Reporting. Final Rule, Table A-1 to Subpart A of Part 98 – Global Warming Potentials. Published in Federal Register, December 11, 2014. 79 FR 73779.

______. 2016. Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: A Rule by the Environmental Protection Agency on 06/03/2016 40 CFR Part 60 Subpart OOOOa, EPA-HQ-OAR-2010-0505, FRL-9944-75-OAR, RIN 2060-AS30. Available online at: https://www.federalregister.gov/articles/2016/06/03/2016-11971/oil-and-natural-gas-sector-emission- standards-for-new-reconstructed-and-modified-sources. Accessed in August 2017.

______. 2017a. Review of the 2016 Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources. 40 CFR Part 60, FRL-9961-09-OAR. Federal Register Vol. 82, No. 63, April 4, 2017. Available online: https://www.federalregister.gov/documents/2017/04/04/2017- 06658/review-of-the-2016-oil-and-gas-new-source-performance-standards-for-new-reconstructed-and- modified. Accessed on April 12, 2017.

______. 2017b. Air Data: Air Quality Data Collected at Outdoor Monitors Across the US. Monitor Values Report. Available online: https://www.epa.gov/outdoor-air-quality-data/monitor-values-report. Accessed in August 2017.

______. 2017c. Clean Air Status and Trends Network (CASTNET) Gothic (GTH161). Available online: https://www3.epa.gov/castnet/site_pages/GTH161.html. Accessed in August 2017.

______. 2017d. Greenhouse Gas Emissions, Draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2015. Available online at: https://www.epa.gov/ghgemissions/draft-inventory-us- greenhouse-gas-emissions-and-sinks-1990-2015. February 22, 2017.

121

121 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

U.S. Fish and Wildlife Service and National Park Service (USFWS and NPS). 2012. Letter on Cumulative Visibility Metric Approach from Sandra V. Silva, Chief, Branch of Air Quality, U.S. Fish and Wildlife Service and Carol McCoy, Chief, Air Resource Division, National Park Service to Kelly Bott, Wyoming Department of Environmental Quality. February 10.

U.S. Forest Service (USFS). 2000. Screening Methodology for Calculating ANC Change to High Elevation Lakes, User's Guide. U.S. Department of Agriculture (USDA) Forest Service, Rocky Mountain Region. January 2000.

U.S. Geological Survey (USGS). 2017. National Water Information System: Web Interface. USGS 09092570 Colorado River at Rulison, CO. Available online at: https://nwis.waterdata.usgs.gov/nwis/inventory/?site_no=09092570&agency_cd=USGS. Accessed on August 24, 2017.

U.S. Global Change Research Program. 2009. Global Climate Change Impacts in the United States. Cambridge University Press. New York, New York. Available online: https://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf. Accessed March 2, 2017.

Vinton, M.A., and E.M. Goergen. 2006. Plant-soil feedbacks contribute to the persistence of Bromus inermis in tallgrass prairie. Ecosystems, 9:967-976.

Vogelsgang, K.M., and J.D. Bever. 2009. Mycorrhizal densities decline in association with nonnative plants and contribute to plant invasion. Ecology 90 (2):399-407.

Warpinski, N.R., J. Du, and U. Zimmer. 2012. Measurements of Hydraulic-Fracture Induced Seismicity in Gas Shales. Paper SPE 151597 presented at the SPE Hydraulic Fracture Technology Conference, The Woodlands, TX. February 6-8.

Weiner, R.J., and J.D. Haun. 1960. Guide to the Geology of Colorado. Geological Society of America.

Western Regional Climate Center. 2017a. Historical climate data for Rifle, Colorado (057031). Available online at: https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?co7031. Accessed in August 2017.

______. 2017b. Remote Automated Weather Station (RAWS) USA Climate Archive. Meteorological observations collected at Rifle Colorado Site. Available online at: https://wrcc.dri.edu/cgi-bin/rawMAIN.pl?coCRIF. Accessed in August 2017.

WestWater Engineering (WWE). 2017a. Terra Energy Partners Balzac Gulch Development Project Phase 1 Biological Survey Report, Biological Survey Report. Grand Junction, CO.

______. 2017b. Terra Energy Partners Balzac Gulch Development Project Phase 1 Biological Survey Report, Biological Survey Report Addendum. Grand Junction, CO.

Zhai, Z., and M.M. Sharma. 2005. A New Approach to Modeling Hydraulic Fractures in Unconsolidated Sands. Paper SPE 96246 presented at the SPE Annual Technical Conference and Exhibition, Dallas, TX.

Zwaenepoel, A., P. Roovers, and M. Hermy. 2006. Motor vehicles as vectors of plant species from road verges in a suburban environment. Basic and Applied Ecology 7:83-93

122

APPENDIX

Balzac Gulch Master Development Plan Project – Phase 1

SURFACE-USE CONDITIONS OF APPROVAL

FOR APPLICATIONS FOR PERMIT TO DRILL AND APPLICABLE TO PAD SITE AND ACCESS ROAD RIGHTS-OF-WAY

GENERAL COAS APPLICABLE TO ALL PROJECT-RELATED SURFACE DISTURBANCE

PROJECT-SPECIFIC SURFACE-USE COAS APPLICABLE TO PROJECT COMPONENTS PROJECT-SPECIFIC MITIGATION MEASURES APPLICABLE TO SPECIFIC COMPONENTS PA 22-25 Well Pad, PA 23-25 Frac Pad, Road, and Pipelines PA 23-26 Well/Frac Pad, Tank Pad, Road, and Pipelines DOE 1-W-26 Cuttings Storage RWF 13-19 Well Pad, Road, and Pipeline RWF 23-19 Frac Pad Surface Frac Lines between the PA 23-25 Frac Pad and PA 23-26 Pad

DOWNHOLE CONDITIONS OF APPROVAL

RIGHT-OF-WAY AMENDMENT STIPULATIONS

APPLICABLE TO GAS PIPELINE CONSTRUCTION AND OPERATION ACTIVITIES

PROJECT-SPECIFIC MITIGATION MEASURES

Left blank for two-sided copying.

SURFACE-USE CONDITIONS OF APPROVAL Balzac Gulch Master Development Plan Project DOI-BLM-CO-N040-2017-0093-EA

Note: The following Conditions of Approval (COAs) will be identified as Mitigation Measures and remain in full force and effect for the following Site and Road Rights-of-ways issued for the Balzac Gulch Master Development Plan EA: COC78666, COC78666-02, COC78667, COC78667-04.

GENERAL COAS APPLICABLE TO ALL PROJECT-RELATED SURFACE DISTURBANCE

1. Administrative Notification. The operator shall notify the BLM representative at least 48 hours prior to initiation of construction. If requested by the BLM representative, the operator shall schedule a preconstruction meeting, including key operator and contractor personnel, to ensure that any unresolved issues are fully addressed prior to initiation of surface-disturbing activities or placement of production facilities. No construction activities shall commence without staking of pad construction limits, pad corners, and road/pipeline centerlines and disturbance corridors.

2. Road Construction and Maintenance. Roads shall be crowned, ditched, surfaced, drained with culverts and/or water dips, and constructed to BLM Gold Book standards. Initial gravel application shall be a minimum of 6 inches. The access roads would have a 20-foot running surface with additional width for drainage ditches and occasional vehicle turnouts. Typical new road and pipeline construction would occur within an average 50-foot wide disturbance corridor. Generally, culvert locations shall be identified during the road pioneering by BLM/Terra field personnel and installed after buried pipelines are installed.

The operator shall provide timely year-round road maintenance and cleanup on the access roads. A regular schedule for maintenance shall include, but not be limited to, blading, ditch and culvert cleaning, road surface replacement, and dust abatement. When rutting within the traveled way becomes greater than 6 inches, blading and/or gravelling shall be conducted as approved by the BLM. (Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development, The Gold Book, Fourth Edition—Revised 2007, BLM/WO/ST-06/021+3071/REV 07.)

a. Road Construction Staking. The road centerline would be flagged and staked prior to the start of tree/brush clearing and/or earthwork within the planned disturbance corridor. The edges of disturbance for the road and pipeline would be established with flagging before the tree clearing work is completed. Consideration shall be given to the extra pipeline construction space needed during the road corridor staking. b. Construction Best Management Practices. The following BMPs proposed by the operator would be incorporated into the construction techniques to address any saturated or fragile soil conditions, seeps, springs, or slumps encountered during the actual road pioneering:

 During the initial road pioneering, a surface disturbance corridor shall be established with sufficient area to allow trenching, spoil storage, and pipeline burial within the roadway disturbance corridor.  Road structures and cut/fill instability issues, if present, shall be mitigated with soil and slope reinforcement including, but not limited to; soil importation, mechanical compaction, design, and installation of synthetic geogrids, aggregated subgrade and road base, mechanically stabilized earth walls, and gabion buttress walls and mattresses.

COA-1 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

 Surface runoff shall be mitigated with, but not limited to, the installation of CMP culverts, borrow ditches, diversion berms, riprap and other diversionary structures as required by site conditions.  Subsurface ground water shall be mitigated with the installation of several alternatives including, but not limited to; gravel pack drains, French drains, and collection sumps as required by site conditions.  During road and/or pipeline construction, topsoil would be segregated along both sides of the road or along one edge of the pipeline corridor for later placement back onto the reclaimed right- of-way. 3. Drill Cuttings Management. Cuttings generated from the numerous planned well bores shall be worked through a shaker system on the drill rig, mixed with a drying agent, if necessary, and deposited in the planned cuttings trench or piled on location against the cut slope for later burial during the interim reclamation earthwork. The cuttings shall be remediated per COGCC regulations (Table 910-1 standards) prior to earthwork reshaping related to well pad interim reclamation.

4. Dust Abatement. The operator shall implement dust abatement measures as needed to prevent fugitive dust from vehicular traffic, equipment operations, or wind events. The BLM may direct the operator to change the level and type of treatment (watering or application of various dust agents, surfactants, and road surfacing material) if dust abatement measures are observed to be insufficient to prevent fugitive dust.

5. Drainage Crossings and Culverts. Construction activities at perennial, intermittent, and ephemeral drainage crossings (e.g. burying pipelines, installing culverts) shall be timed to avoid high flow conditions. Construction that disturbs any flowing stream shall utilize either a piped stream diversion or a cofferdam and pump to divert flow around the disturbed area.

Culverts at drainage crossings shall be designed and installed to pass a 25-year or greater storm event. On perennial and intermittent streams, culverts shall be designed to allow for passage of aquatic biota. The minimum culvert diameter in any installation for a drainage crossing or road drainage shall be 24 inches. Crossings of drainages deemed to be jurisdictional Waters of the U.S. pursuant to Section 404 of the Clean Water Act may require additional culvert design capacity. Due to the flashy nature of area drainages and anticipated culvert maintenance, the U.S. Army Corps of Engineers (USACE) recommends designing drainage crossings for the 100-year event. Contact the USACE Colorado West Regulatory Branch at 970-243-1199.

Pipelines installed beneath stream crossings shall be buried at a minimum depth of 4 feet below the channel substrate to avoid exposure by channel scour and degradation. Following burial, the channel grade and substrate composition shall be returned to pre-construction conditions.

6. Jurisdictional Waters of the U.S. The operator shall obtain appropriate permits from the U.S. Army Corps of Engineers (USACE) prior to discharging fill material into Waters of the U.S. in accordance with Section 404 of the Clean Water Act. Waters of the U.S. are defined in 33 CFR Section 328.3 and may include wetlands as well as perennial, intermittent, and ephemeral streams. Permanent impacts to Waters of the U.S. may require mitigation. Contact the USACE Colorado West Regulatory Branch at 970-243-1199.

7. Reclamation. The goals, objectives, timelines, measures, and monitoring methods for final reclamation of oil and gas disturbances are described in Appendix I (Surface Reclamation) of the 1998 Draft Supplemental EIS (DSEIS). Specific measures to follow during interim reclamation are described below.

COA-2 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

a. Reclamation Plans. In areas that have low reclamation potential or are especially challenging to restore, reclamation plans will be required prior to APD approval. The plan shall contain the following components: detailed reclamation plats, which include contours and indicate irregular rather than smooth contours as appropriate for visual and ecological benefit; timeline for drilling completion, interim reclamation earthwork, and seeding; soil test results and/or a soil profile description; amendments to be used; soil treatment techniques such as roughening, pocking, and terracing; erosion control techniques such as hydromulch, blankets/matting, and wattles; and visual mitigations if in a sensitive VRM area.

b. Deadline for Interim Reclamation Earthwork and Seeding. Interim reclamation to reduce a well pad to the maximum size needed for production, including earthwork and seeding of the interim reclaimed areas, shall be completed within 6 months following completion of the last well planned to be drilled on that pad as part of a continuous operation. If a period of greater than one year is expected to occur between drilling episodes, BLM may require implementation of all or part of the interim reclamation program.

Reclamation, including seeding, of temporarily disturbed areas along roads and pipelines, and of topsoil piles and berms, shall be completed within 30 days following completion of construction. Any such area on which construction is completed prior to December 1 shall be seeded during the remainder of the early winter season instead of during the following spring, unless BLM approves otherwise based on weather. If road or pipeline construction occurs discontinuously (e.g., new segments installed as new pads are built) or continuously but with a total duration greater than 30 days, reclamation, including seeding, shall be phased such that no portion of the temporarily disturbed area remains in an unreclaimed condition for longer than 30 days. BLM may authorize deviation from this requirement based on the season and the amount of work remaining on the entirety of the road or pipeline when the 30-day period has expired.

If requested by the project lead NRS for a specific pad or group of pads, the operator shall contact the NRS by telephone or email approximately 72 hours before reclamation and reseeding begin. This will allow the NRS to schedule a pre-reclamation field visit if needed to ensure that all parties are in agreement and provide time for adjustments to the plan before work is initiated.

The deadlines for seeding described above are subject to extension upon approval of the BLM based on season, timing limitations, or other constraints on a case-by-case basis. If the BLM approves an extension for seeding, the operator may be required to stabilize the reclaimed surfaces using hydromulch, erosion matting, or other method until seeding is implemented.

c. Topsoil Stripping, Storage, and Replacement. All topsoil shall be stripped following removal of vegetation during construction of well pads, pipelines, roads, or other surface facilities. In areas of thin soil, a minimum of the upper 6 inches of surficial material shall be stripped. The BLM may specify a stripping depth during the onsite visit or based on subsequent information regarding soil thickness and suitability. The stripped topsoil shall be stored separately from subsoil or other excavated material and replaced prior to final seedbed preparation. The BLM best management practice (BMP) for the Windrowing of Topsoil shall be implemented for well pad construction whenever topography allows.

d. Seedbed Preparation. For cut-and-fill slopes, initial seedbed preparation shall consist of backfilling and recontouring to achieve the configuration specified in the reclamation plan. For compacted areas, initial seedbed preparation shall include ripping to a minimum depth of 18 inches, with a maximum furrow spacing of 2 feet. Where practicable, ripping shall be conducted

COA-3 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

in two passes at perpendicular directions. Following final contouring, the backfilled or ripped surfaces shall be covered evenly with topsoil.

Final seedbed preparation shall consist of scarifying (raking or harrowing) the spread topsoil prior to seeding. If more than one season has elapsed between final seedbed preparation and seeding, and if the area is to be broadcast-seeded or hydroseeded, this step shall be repeated no more than 1 day prior to seeding to break up any crust that has formed.

If directed by the BLM, the operator shall implement measures following seedbed preparation (when broadcast-seeding or hydroseeding is to be used) to create small depressions to enhance capture of moisture and establishment of seeded species. Depressions shall be no deeper than 1 to 2 inches and shall not result in piles or mounds of displaced soil. Excavated depressions shall not be used unless approved by the BLM for the purpose of erosion control on slopes. Where excavated depressions are approved by the BLM, the excavated soil shall be placed only on the downslope side of the depression.

If directed by the BLM, the operator shall conduct soil testing prior to reseeding to identify if and what type of soil amendments may be required to enhance revegetation success. At a minimum, the soil tests shall include texture, pH, organic matter, sodium adsorption ratio (SAR), cation exchange capacity (CEC), alkalinity/salinity, and basic nutrients (nitrogen, phosphorus, potassium [NPK]). Depending on the outcome of the soil testing, the BLM may require the operator to submit a plan for soil amendment. Any requests to use soil amendments not directed by the BLM shall be submitted to the CRVFO for approval.

e. Seed Mixes. A seed mix consistent with BLM standards in terms of species and seeding rate for the specific habitat type shall be used on all BLM lands affected by the project (see Attachment 1 of the letter provided to operators dated September 9, 2014).

For private surfaces, the menu-based seed mixes are recommended, but the surface landowner has ultimate authority over the seed mix to be used in reclamation. The seed shall contain no prohibited or restricted noxious weed seeds and shall contain no more than 0.5% by weight of other weed seeds. Seed may contain up to 2.0% of “other crop” seed by weight, including the seed of other agronomic crops and native plants; however, a lower percentage of other crop seed is recommended. Seed tags or other official documentation shall be submitted to BLM at least 14 days before the date of proposed seeding for acceptance. Seed that does not meet the above criteria shall not be applied to public lands.

f. Seeding Procedures. Seeding shall be conducted no more than 24 hours following completion of final seedbed preparation.

Where practicable, seed shall be installed by drill-seeding to a depth of 0.25 to 0.5 inch. Where drill-seeding is impracticable, seed may be installed by broadcast-seeding at twice the drill- seeding rate, followed by raking or harrowing to provide 0.25 to 0.5 inch of soil cover or by hydroseeding and hydromulching. Hydroseeding and hydromulching shall be conducted in two separate applications to ensure adequate contact of seeds with the soil.

An exception to these seeding requirements shall be made for seeding of sagebrush. Sagebrush seeding shall occur prior to winter snowfall, or on top of snow. Sagebrush may be sown either by broadcast seeding, or, if not on snowpack, by placing the seed in the fluffy seed box of a seed drill, with the drop tube left open to allow seed to fall out on the ground surface.

COA-4 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

If interim revegetation is unsuccessful, the operator shall implement subsequent reseedings until interim reclamation standards are met.

g. Mulch. Mulch shall be applied within 24 hours following completion of seeding in project areas within pinyon-juniper, sagebrush shrubland, and/or salt desert shrub habitat types. Mulch may consist of either hydromulch or of certified weed-free straw or certified weed-free native grass hay crimped into the soil. Mulch shall not be used within mountain shrub or spruce-fir forest habitat types, unless requested or approved by the BLM.

NOTE: Mulch is not required in areas where erosion potential mandates use of a biodegradable erosion-control blanket (straw matting).

h. Erosion Control. Cut-and-fill slopes shall be protected against erosion with the use of water bars, lateral furrows, or other BMPs approved by the BLM. Additional BMPs such as biodegradable wattles, weed-free straw bales, or silt fences shall have be employed as necessary to reduce transport of sediments into the drainages. The BLM may, in areas with high erosion potential, require use of hydromulch or biodegradable blankets/matting to ensure adequate protection from slope erosion and offsite transport of sediments and to improve reclamation success.

i. Site Protection. The pad shall be fenced to BLM standards to exclude livestock grazing for the first two growing seasons or until seeded species are firmly established, whichever comes later. The seeded species will be considered firmly established when at least 50% of the new plants are producing seed. The BLM will approve the type of fencing.

j. Monitoring. The operator shall conduct annual monitoring surveys of all sites categorized as “operator reclamation in progress” and shall submit an annual monitoring report of these sites, including a description of the monitoring methods used, to the BLM by December 31 of each year. The monitoring program shall use the four Reclamation Categories defined in Appendix I of the 1998 DSEIS to assess progress toward reclamation objectives. The annual report shall document whether attainment of reclamation objectives appears likely. If one or more objectives appear unlikely to be achieved, the report shall identify appropriate corrective actions. Upon review and approval of the report by the BLM, the operator shall be responsible for implementing the corrective actions or other measures specified by the BLM.

8. Weed Control. The operator shall regularly monitor and promptly control noxious weeds or other undesirable plant species as set forth in the Glenwood Springs Field Office Noxious and Invasive Weed Management Plan for Oil and Gas Operators, dated March 2007. A Pesticide Use Proposal (PUP) must be approved by the BLM prior to the use of herbicides. Annual weed monitoring reports and Pesticide Application Records (PARs), including GPS data in accordance with the February 27, 2014, letter to operators, shall be submitted to BLM by December 1.

9. Big Game Winter Range Timing Limitation. To minimize impacts to wintering big game, no construction, drilling or completion activities shall occur during a Timing Limitation (TL) period from December 1 through April 30 annually, as determined by the Federal lease stipulation and BLM road rights-of-way that provide access to the existing BLM pads: PA 23-26, RWF 13-19 and RWF 23-19.

10. Bald and Golden Eagles. It shall be the responsibility of the operator to comply with the Bald and Golden Eagle Protection Act (Eagle Act) with respect to “take” of either eagle species. Under the Eagle Act, “take” includes to pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest and disturb. “Disturb” means to agitate or bother a bald or golden eagle to a degree that causes, 5

COA-5 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

or is likely to cause, based on the best scientific information available, (1) injury to an eagle; (2) a decrease in its productivity by substantially interfering with normal breeding, feeding, or sheltering behavior; or (3) nest abandonment by substantially interfering with normal breeding, feeding, or sheltering behavior. Avoidance of eagle nest sites, particularly during the nesting season, is the primary and preferred method to avoid a take. Any oil or gas construction, drilling, or completion activities planned within 0.5 mile of a bald or golden eagle nest, or other associated activities greater than 0.5 miles from a nest that may disturb eagles, shall be coordinated with the BLM project lead and BLM wildlife biologist and the USFWS representative to the BLM Field Office (970-876-9051).

11. Raptor Nesting. To protect nesting raptors, a survey shall be conducted prior to construction, drilling, or completion activities that are to begin during the raptor nesting season (February 1 to August 15). The survey shall include all potential nesting habitat within 0.25 mile of a well pad or 0.125 mile of an access road, pipeline, or other surface facility. Results of the survey shall be submitted to the BLM. If an active raptor nest is located within the buffer widths specified above, a TL will be applied by the BLM to preclude initiation of construction, drilling, and completion activities during a 60-day period appropriate for the specific raptor species. The operator is responsible for complying with the MBTA, which prohibits the “take” of birds or of active nests (those containing eggs or young), including nest failure caused by human activity (see COA for Migratory Birds).

12. Migratory Birds – Birds of Conservation Concern. Pursuant to BLM Instruction Memorandum 2008- 050, all vegetation removal or surface disturbance in previously undisturbed lands that provide potential nesting habitat for Birds of Conservation Concern (BCC) is prohibited from May 15 to July 15. An exception to this TL may be granted if nesting surveys conducted no more than one week prior to surface-disturbing activities indicate that no BCC species are nesting within 30 meters (100 feet) of the area to be disturbed. Nesting shall be deemed to be occurring if a territorial (singing) male is present within the distance specified above. Nesting surveys shall include an audial survey for diagnostic vocalizations in conjunction with a visual survey for adults and nests. Surveys shall be conducted by a qualified breeding bird surveyor between sunrise and 10:00 AM under favorable conditions for detecting and identifying a BCC species. This provision does not apply to ongoing construction, drilling, or completion activities that are initiated prior to May 1 and continue into the 60-day period at the same location.

13. Migratory Birds – General. It shall be the responsibility of the operator to comply with the Migratory Bird Treaty Act (MBTA) with respect to “take” of migratory bird species, which includes injury and direct mortality resulting from human actions not intended to have such result. To minimize the potential for the take of a migratory bird, the operator shall take reasonable steps to prevent use by birds of fluid-containing pits associated with oil or gas operations, including but not limited to reserve pits, produced-water pits, hydraulic fracturing flowback pits, evaporation pits, and cuttings trenches. Liquids in these pits—whether placed or accumulating from precipitation—may pose a risk to birds as a result of ingestion, absorption through the skin, or interference with buoyancy and temperature regulation.

Based on low effectiveness of brightly colored flagging or spheres suspended over a pit, the operator shall install netting with a mesh size of 1 to 1.5 inches, and suspended at least 4 feet above the fluid surface, on all pits into which fluids are placed, except for storage of fresh water in a pit that contains no other material. The netting shall be installed within 24 hours of placement of fluids into a pit. The requirement for netting does not apply to pits during periods of continuous, intensive human activity at the pad, such as drilling and hydraulic fracturing phases or, as pertains to cuttings trenches, during periods of active manipulation for cuttings management, remediation of contaminated materials, or other purposes.

COA-6 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

14. Fossil Resources. All persons associated with operations under this authorization shall be informed that any objects or sites of paleontological or scientific value, such as vertebrate or scientifically important invertebrate fossils, shall not be damaged, destroyed, removed, moved, or disturbed. If in connection with operations under this authorization any of the above resources are encountered the operator shall immediately suspend all activities in the immediate vicinity of the discovery that might further disturb such materials and notify the BLM of the findings. The discovery must be protected until notified to proceed by the BLM.

Where feasible, the operator shall suspend ground-disturbing activities at the discovery site and immediately notify the BLM of any finds. The BLM would, as soon as feasible, have a BLM- permitted paleontologist check out the find and record and collect it if warranted. If ground- disturbing activities cannot be immediately suspended, the operator shall work around or set the discovery aside in a safe place to be accessed by the BLM-permitted paleontologist.

15. Cultural Education/Discovery. All persons in the area who are associated with this project shall be informed that if anyone is found disturbing historic, archaeological, or scientific resources, including collecting artifacts, the person or persons would be subject to prosecution.

If subsurface cultural values are uncovered during operations, all work in the vicinity of the resource will cease and the Authorized Officer with the BLM notified immediately. The operator shall take any additional measures requested by the BLM to protect discoveries until they can be adequately evaluated by the permitted archaeologist. Within 48 hours of the discovery, the SHPO and consulting parties will be notified of the discovery and consultation will begin to determine an appropriate mitigation measure. BLM in cooperation with the operator will ensure that the discovery is protected from further disturbance until mitigation is completed. Operations may resume at the discovery site upon receipt of written instructions and authorization by the authorized officer.

Pursuant to 43 CFR 10.4(g), the holder must notify the authorized officer, by telephone, with written confirmation, immediately upon the discovery of human remains, funerary items, sacred objects, or objects of cultural patrimony on Federal land. Further, pursuant to 43 CFR 10.4 (c) and (d), the holder must stop activities in the vicinity of the discovery that could adversely affect the discovery. The holder shall make a reasonable effort to protect the human remains, funerary items, sacred objects, or objects of cultural patrimony for a period of thirty days after written notice is provided to the authorized officer, or until the authorized officer has issued a written notice to proceed, whichever occurs first.

Antiquities, historic ruins, prehistoric ruins, and other cultural or paleontological objects of scientific interest that are outside the authorization boundaries but potentially affected, either directly or indirectly, by the Proposed Action shall also be included in this evaluation or mitigation. Impacts that occur to such resources as a result of the authorized activities shall be mitigated at the operator's cost, including the cost of consultation with Native American groups.

Any person who, without a permit, injures, destroys, excavates, appropriates or removes any historic or prehistoric ruin, artifact, object of antiquity, Native American remains, Native American cultural item, or archaeological resources on public lands is subject to arrest and penalty of law (16 USC 433, 16 USC 470, 18 USC 641, 18 USC 1170, and 18 USC 1361).

16. Visual Resources. Production facilities and pipeline risers shall be placed to avoid or minimize visibility from travel corridors, residential areas, and other sensitive observation points—unless directed otherwise by the BLM due to other resource concerns—and shall be placed to maximize reshaping of cut-and-fill- slopes and interim reclamation of the pad. 7

COA-7 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The BLM may direct that cleared trees and rocks be salvaged and redistributed over reshaped cut- and-fill slopes or along linear features. The disturbance width of the road/pipeline corridors shall vary to help reduce a visual “straight line” edge and create opportunities to blend the developments into the landscape.

Aboveground facilities shall be painted Shadow Gray to minimize contrast with existing surrounding vegetation or rock outcrops.

17. Range Management. Range improvements (fences, gates, reservoirs, pipelines, etc.) shall be avoided during development of natural gas resources to the maximum extent possible. If range improvements are damaged during exploration and development, the operator will be responsible for repairing or replacing the damaged range improvements. If a new or improved access road bisects an existing livestock fence, steel frame gate(s) or a cattleguard with associated bypass gate shall be installed across the roadway to control grazing livestock.

18. Windrowing of Topsoil. Topsoil shall be windrowed around the pad perimeter to create a berm that limits and redirects stormwater runoff and extends the viability of the topsoil per BLM Topsoil Best Management Practices (BLM 2009 PowerPoint presentation available upon request from Glenwood Springs Field Office). Topsoil shall also be windrowed, segregated, and stored along pipelines and roads for later spreading across the disturbed corridor during final reclamation. Topsoil berms shall be promptly seeded to maintain soil microbial activity, reduce erosion, and minimize weed establishment.

19. Interim Reclamation Related to Drilling Phases. Within 1 year of completion of all exploratory wells proposed on a pad or within one year of completion of all development wells on a pad (whichever the situation may be), the operator would stabilize the disturbed area by recontouring, mulching, providing runoff and erosion control, replacing topsoil as directed, and seeding with BLM-prescribed native seed mixes (or landowner requested seed mix on Fee surface), and conducting weed control, as necessary. In cases where the exploratory drilling and development drilling on a single pad occur more than 1 year apart, slopes shall be recontoured to the extent necessary to accommodate seeding, and seed mixes required by BLM or requested by the private landowner shall be applied to stabilize the soil between visits per direction of the BLM.

PROJECT-SPECIFIC SURFACE-USE COAS APPLICABLE TO PROJECT COMPONENTS

Vegetation Clearing on Pads/Roads/Pipeline. Hydro-axe equipment shall be used to clear woody vegetation and trees within from the staked and/or flagged pad, pipeline, and road construction limits prior to topsoil stripping, windrowing, or storage. Any dead juniper tree piles or dead tree windrows from that fall within the disturbance perimeter of the pad, pipelines or road shall also be hydro-axed to reduce the fuel loading from the concentrated piles of dead trees.

Hydraulic Fracturing Limitations: To satisfy the air emission thresholds forecasted by the operator during the APD permitting process, the average duration of hydraulic fracturing shall not exceed 25 hours per well, utilizing no more than eighteen 2,000-hp Tier 2 engines.

Storm Water Design: A detailed storm water plat shall be submitted with the APD, addressing the location and size of ditches and planned structures to control run-on and runoff from the development, and demonstrating suitable drainage diversion and containment around the pad perimeter including any excess material storage piles.

COA-8 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

PROJECT-SPECIFIC MITIGATION MEASURES APPLICABLE TO SPECIFIC COMPONENTS

PA 22-25 Well Pad, PA 23-25 Frac Pad, Road, and Pipelines

The northeast corner of the well pad shall be pulled away from the existing drainage, providing a distance that allows suitable space for establishment and maintenance of storm water structures and avoids any direct impacts from the pad reconstruction to the drainage course.

PA 23-26 Well/Frac Pad, Tank Pad, Road, and Pipelines

Hydro-axe equipment shall be used to clear vegetation from the staked and/or flagged pad and road construction limit of disturbance perimeter prior to topsoil stripping and windrowing or storage. Any dead juniper tree piles or windrows from historic wildlife treatment that fall within the disturbance perimeter for the PA 23-26 pad or road shall also be hydro-axed to reduce the fuel loading from those old piles.

The drainage along the east edge of the pad expansion work shall be redirected through a minimum 36- inch-diameter culvert to be installed under the frac pad as illustrated on Construction plats. The inlet and outlet of the long culvert shall be armored with rock to help direct flows into and out from the culvert.

During interim reclamation of the PA 23-26 pad, the frac pad portion shall be recontoured back to natural grades and the culvert removed. The ephemeral drainage (with the culvert removed) shall be re- established to similar course and grade that existed prior to pad expansion work.

To help reduce the proposed 17% grade of the DOE 1-W-26 access road coming off the PA 23-26 pad at west end of the cuttings management area, a longer road ramp could be built along the south edge of the cuttings area thereby lengthening the road and lessening the overall grade.

DOE 1-W-26 Cuttings Storage

Excess cuttings generated from the PA 23-26 wells shall be hauled and stored against the “opened” cutslope at the DOE 1-W-26 pad per the DOE 1-W-26 Construction Layout. After the cuttings storage is completed, the steep cutslope and side ridges shall be recontoured to help provide material to cap the cuttings. The prescribed area on the Construction Layout north of the DOE 1-W-26 cutslope shall be stripped of topsoil and blended into the reshaped cutslope. Topsoil shall be re-spread across the finished grade of the DOE 1-W-26 pad. Any trees cleared during the operation to lay back the cutslope shall be broken down and laid across the finished slope to deter erosion.

RWF 13-19 Well Pad, Road, and Pipeline

At the northern construction limit of the RWF 13-19 pad, no surface disturbance shall occur onto the steep north-facing slope. No sidecasting of material shall be allowed; suitable space shall be provided along the north edge of pad disturbance for functioning storm water structures such as staked straw bales or straw wattles.

Storm water plat for this location shall specifically identify drainage and structure locations along the south edge of the pad expansion focusing on drainage flow around the cuttings trench and the SE pad corner.

Excess material generated from pad expansion work shall be used to construct the new road alignment between the RWF 13-19 and 23-19 pads. Sufficient excess material shall be stockpiled on the RWF 13- 9

COA-9 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

19 pad in vicinity of western edge on either die of the road to the RWF 12-19 pad to ensure the cuttings trench can be reclaimed and closed after COGCC Tale 910-1 testing.

Given the amount of new trees to be cleared for the new road alignment between the two pads, a hydro- axe machine shall be used to clear trees on the pad expansion for the RWF 13-19 and the new road corridor.

A longer culvert with an improved alignment that better resembles the course of the drainage shall be installed in the large drainage between the RWF 13-19 and 23-19 pads. Coordination with pipeline work shall be needed to ensure the culvert upgrade can be accomplished given the existing and new pipelines planned for this area.

Specific details of the 8-inch gas pipeline span across a drainage near the Anvil Points Road shall be submitted to the BLM for review and approval prior to construction.

RWF 23-19 Frac Pad

At the northern construction limit of the RWF 23-19 pad, no surface disturbance shall occur onto the steep north-facing slope. No sidecasting of material shall be allowed; suitable space shall be provided along the north edge of pad disturbance for functioning storm water structures such as staked straw bales or straw wattles.

Excess material generated from pad expansion work shall be used to construct the new road alignment between the RWF 13-19 and 23-19 pads. The west and east edges of the RWF 23-19 pad can be used for storage of excess material not needed for the road realignment work.

A new water line connection (valve with cover) at the east end of the RWF 23-19 pad shall be created to provide water delivery access for frac operations.

Surface Frac Lines between the PA 23-25 Frac Pad and PA 23-26 Pad

The installation of the three welded steel 4½-inch surface lines shall use the existing two-track as a work platform between the two pads as much as possible. From the NE corner of the PA 23-26 pad where the lines would be welded, the lines shall be pushed and directed along the existing two-track and then pushed down the steep slope in a manner that minimizes damage to any standing trees. A landing area (estimated width of 75 feet) for the steel lines bearing down the steep slope shall be established with flagging prior to installation. Spanning of the main drainage shall occur upgradient from the two-track crossing in a manner that reduces the span length and avoids trees and weak-appearing slopes or drainage walls. The portion of each steel line spanning the high-walled drainage shall be cased inside a segment of 10-inch poly water line featuring 2-inch-thick walls to act as a protective sleeve. The steel lines shall be anchored at the PA 23-26 and along the alignment as needed to maintain the lines in place during their installation and operation. The lines shall be tested initially after installation and periodically during their operation to ensure they have suitable integrity to deliver fluids without failure or spill.

During the decommissioning of the steel surface frac lines, any disturbed, bare segments of the old two- track shall be roughened and seeded to establish desirable vegetation and reclaim the old roadway.

COA-10 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

BUREAU OF LAND MANAGEMENT Colorado River Valley Field Office 2300 River Frontage Road Silt, CO 81652

Drilling Conditions of Approval Applications for Permit to Drill

Operator: TEP Rocky Mountain LLC Lease Number: COC73094 Pad: PA 22-25 Surface Location: Garfield County, SE¼NW¼, Section 25, T6S, R95W

1. Twenty-four hours prior to (a) spudding, (b) conducting BOPE tests, (c) cementing/running casing strings, and (d) within 24 hours after spudding, the CRVFO shall be notified. One of the following CRVFO inspectors shall be notified by phone. The contact number for all notifications is: 970-876- 9064. The BLM CRVFO inspectors are Marlan Deaton, Ed Fancher, Greg Rios, Alex Provstgaard, Brandon Jamison, Jennifer Robinson. 2. A CRVFO petroleum engineer shall be contacted for a verbal approval prior to commencing remedial work, sidetracking operations, plugging operations on newly drilled boreholes, changes within the drilling plan, changes to the well design, changes or variances to the BOPE, deviating from conditions of approval, and conducting other operations not specified within the APD. Contact the petroleum engineer for verbal approvals (contact information below). 3. If a well control issue or failed test (e.g., kick, blowout, water flow, formation integrity test, casing failure, or a bradenhead pressure increase) arises during drilling or completions operations, the petroleum engineer shall be notified within 24 hours from the time of the event. IADC/Driller’s Logs and Pason Logs (mud logs) shall be forwarded to the CRVFO – Petroleum Engineer, 2300 River Frontage Road, Silt, CO 81652 within 24 hours of a well control event. 4. The BOPE shall be tested and conform to Onshore Order No. 2 for a 3M system and recorded in the IADC/Driller’s log. 5. Flexible choke lines shall meet or exceed the API SPEC 16C requirements. Flexible choke lines shall have flanged connections and configured to the manufacturer’s specifications. The flexible choke lines shall be anchored in a safe and workmanlike manner. At minimum, all connections shall be effectively anchored in place for safety of the personnel on location. Manufacturer specifications shall be kept with the drilling rig at all times and immediately supplied to the authorized officer/inspector upon request. Specifications at a minimum shall include acceptable bend radius, heat range, anchoring, and the working pressure. All flexible choke lines shall be free of gouges and deformations, and as straight/short as possible. 6. Electrical/mechanical mud monitoring equipment shall be function tested prior to drilling out the surface casing shoe. As a minimum, this equipment shall include a pit volume totalizer, stroke counter, and flow sensor. 7. All flare lines must be effectively anchored in place prior to drilling out the surface casing shoe. The discharge of the flare lines shall be a minimum of 100 feet from the wellhead and targeted at bends. The panic line shall be a separate line (not open inside the buffer tank) and effectively anchored. All lines shall be downwind of the prevailing wind direction and directed into a flare pit, which cannot be the reserve pit. The flare system shall use an automatic ignition. Where noncombustible gas is likely or expected to be vented, the system shall be provided supplemental fuel for ignition and maintain a continuous flare. 11

COA-11 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

8. On the first well drilled on this pad, a triple combo open-hole log shall be run from the base of the surface borehole to surface and from the TD to the bottom of the surface casing shoe. This log shall be submitted within 48 hours in .las and .pdf format to the CRVFO – Petroleum Engineer, 2300 River Frontage Road, Silt, CO 81652. Contact 970-876-9000 for clarification. 9. Submit the (a) mud/drilling log (e.g., Pason disc), (b) driller’s event log/operations summary report, (c) production test volumes, (d) directional survey, and (e) Pressure Integrity Test results within 30 days of completed operations (i.e., landing tubing) per 43 CFR 3160-9(a). 10. Whether the well is completed as a dry hole or as a producer, the “Well Completion and Recompletion Report and Log” (Form 3160-4) shall be submitted not later than 30 days after completion of the well or after completion of operations being performed, in accordance with 43 CFR 3164. In accordance with 43 CFR 3162.4(b), a complete set of electrical/mechanical logs shall be submitted in .LAS format with standard Form 3160-4, Well Completion or Recompletion Report and Log. 11. Should the well be completed for production, the AO will be notified when the well is placed in a producing status. Such notification shall be a written notification sent no later than five (5) days following the date on which the well is placed on production. 12. All off-lease storage, off-lease measurement, or commingling on-lease or off-lease shall have prior written approval from the AO. 13. Water Use. The Operator shall provide the volumes of fresh water and reused/recycled water used during project development. The volumes per well shall be identified by each development phase (construction, drilling, and completion) and by activity (e.g., dust abatement, pipeline hydrostatic testing, and drilling and completion operations). The water volumes shall be identified in an attachment to the BLM Form 3160-4, “Well Completion or Recompletion Report and Log” (completion report) submitted to the BLM Field Office. All volumes shall be reported in barrels per well. For reporting the water used during construction, submit the total water used for construction with the first completion report. Volumes of water used for subsequent activities (drilling and completing an additional well on the pad, dust abatement) shall be included in subsequent completion reports. If additional water is used subsequently on or for the benefit of the subject pad submit the water volumes by sundry notice as above.

Well Name/No.: API No.: County: Well Pad: Operator: Water Use (barrels) Construction Drilling Completion Activity Reused/ Reused/ Fresh Fresh Fresh Recycled Recycled Road/Pipeline/Pad Dust Abatement Pipeline Hydrostatic Testing Cementing Mud Acid Wash/ Hydraulic Fracturing

COA-12 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

14. “Sundry Notice and Report on Wells” (Form 3160-5) shall be filed for approval for all changes of plans and other operations in accordance with 43 CFR 3162.3-2.

Contact Information

Bob Hartman Stephen Garcia Petroleum Engineer Petroleum Engineer Office: (970) 244-3041 Office: (970) 876-9031 Cell: (970) 589-6735 Cell: (970) 456-2138 [email protected] [email protected]

List of Wells Proposed Proposed Pad Surface Hole Location Bottomhole Location Well PA 534-24 SWSE Sec. 24 T6S R95W PA 414-24 SWSW Sec. 24 T6S R95W PA 514-24 SWSW Sec. 24 T6S R95W PA 424-24 SESW Sec. 24 T6S R95W PA 524-24 SESW Sec. 24 T6S R95W PA 11-25 NWNW Sec. 25 T6S R95W PA 511-25 NWNW Sec. 25 T6S R95W PA 21-25 NENW Sec. 25 T6S R95W PA 321-25 NENW Sec. 25 T6S R95W PA 421-25 NENW Sec. 25 T6S R95W PA 521-25 NENW Sec. 25 T6S R95W PA 311-25 NWNW Sec. 25 T6S R95W PA 22-25 Pad PA 411-25 SENW Sec. 25 T6S R95W NWNW Sec. 25 T6S R95W PA 541-26 NENE Sec. 26 T6S R95W PA 441-26 NENE Sec. 26 T6S R95W PA 543-26 NESE Sec. 26 T6S R95W PA 41-26 NENE Sec. 26 T6S R95W PA 341-26 NENE Sec. 26 T6S R95W PA 342-26 SENE Sec. 26 T6S R95W PA 442-26 SENE Sec. 26 T6S R95W PA 542-26 SENE Sec. 26 T6S R95W PA 43-26 NESE Sec. 26 T6S R95W PA 343-26 NESE Sec. 26 T6S R95W PA 42-26 SENE Sec. 26 T6S R95W PA 443-26 NESE Sec. 26 T6S R95W

COA-13 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

BUREAU OF LAND MANAGEMENT Colorado River Valley Field Office 2300 River Frontage Road Silt, CO 81652

Drilling Conditions of Approval Applications for Permit to Drill

Operator: TEP Rocky Mountain LLC Lease Number: COC62161, COC73094 Pad: PA 23-26 Surface Location: Garfield County, NE¼SW¼, Section 26, T6S, R95W

1. Twenty-four hours prior to (a) spudding, (b) conducting BOPE tests, and (c) cementing/running casing strings, and (d) within 24 hours after spudding, please leave message at the following contact number: 970-876-9064. The BLM CRVFO inspectors are Marlan Deaton, Ed Fancher, Greg Rios, Alex Provstgaard, Brandon Jamison, and Jennifer Robinson. Please contact one of the following petroleum engineers with emergency, drilling or completion issues: Bob Hartman at (970) 589-6735, [email protected], or Stephen Garcia at (970) 456-2138, [email protected]. 2. A CRVFO petroleum engineer shall be contacted for a verbal approval prior to commencing remedial work, sidetracking operations, plugging operations on newly drilled boreholes, changes within the drilling plan, changes to the well design, changes or variances to the BOPE, deviating from conditions of approval, and conducting other operations not specified within the APD. Contact the petroleum engineer for verbal approvals (contact information above). 3. If a well control issue or failed test (e.g., kick, blowout, water flow, casing failure, or a bradenhead pressure increase) arises during drilling or completions operations, the petroleum engineer shall be notified within 24 hours from the time of the event. IADC/Driller’s Logs and Pason Logs (mud logs) shall be forwarded to the CRVFO – Petroleum Engineer, 2300 River Frontage Road, Silt, CO 81652 within 24 hours of a well control event. 4. The BOPE shall be tested and conform to Onshore Order No. 2 for a 3M system and recorded in the IADC/Driller’s log. 5. Air and/or mist drilling requires BLM petroleum engineers notification and approval. 6. Flexible choke lines shall meet or exceed the API SPEC 16C requirements. Flexible choke lines shall have flanged connections and configured to the manufacturer’s specifications. The flexible choke lines shall be anchored in a safe and workmanlike manner. At minimum, all connections shall be effectively anchored in place for safety of the personal on location. Manufacturer specifications shall be kept with the drilling rig at all times and immediately supplied to the Authorized Officer (AO) or inspector upon request. Specifications at a minimum shall include acceptable bend radius, heat range, anchoring, and the working pressure. All flexible choke lines shall be free of gouges and deformations, and as straight/short as possible. 7. Chronologic drilling progress reports must be emailed directly to the BLM CRVFO petroleum engineers on a daily basis. Reports shall include daily mud reports, details of casing that has been run and its cementing, water flows, lost circulation zones, hydrocarbon shows and other information that describes drilling conditions.

COA-14 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

8. Electrical/mechanical mud monitoring equipment shall be function tested prior to drilling out the surface casing shoe. As a minimum, this equipment shall include a pit volume totalizer, stroke counter, and flow sensor. 9. A gas buster shall be functional and all flare lines effectively anchored in place, prior to drilling out the surface casing shoe. The discharge of the flare lines shall be a minimum of 100 feet from the wellhead and targeted at bends. The panic line shall be a separate line (not open inside the buffer tank) and effectively anchored. All lines shall be downwind of the prevailing wind direction and directed into a flare pit, which cannot be the reserve pit. The flare system shall use an automatic ignition. Where noncombustible gas is likely or expected to be vented, the system shall be provided supplemental fuel for ignition and maintain a continuous flare. 10. On the first well drilled on this pad, a triple combo open-hole log shall be run from the base of the surface borehole to surface and from the TD to the bottom of the surface casing shoe. This log shall be submitted within 48 hours in .las and .pdf format to the CRVFO – Petroleum Engineer, 2300 River Frontage Road, Silt, CO 81652. Contact 970-876-9000 for clarification. 11. Submit the (a) mud/drilling log (e.g., Pason disc), (b) driller’s event log/operations summary report, (c) production test volumes, (d) directional survey, and (e) Pressure Integrity Test results within 30 days of completed operations (i.e., landing tubing) per 43 CFR 3160-9 (a). 12. Notify the BLM Petroleum Engineer two weeks prior to commencing completion operations. 13. Whether the well is completed as a dry hole or as a producer, the “Well Completion and Recompletion Report and Log” (Form 3160-4) shall be submitted not later than 30 days after completion of the well or after completion of operations being performed, in accordance with 43 CFR 3164. In accordance with 43-CFR 3162.4(b), submit a complete set of electrical/mechanical logs in .LAS format with standard Form 3160-4, Well Completion or Recompletion Report and Log. 14. Not later than the 5th business day after any well begins production on which royalty is due anywhere on a lease site or allocated to a lease site, or resumes production in the case of a well which has been off production for more than 90 days, the operator shall notify the AO by letter or sundry notice, Form 3160-5, or orally to be followed by a letter or sundry notice, of the date on which such production has begun or resumed. If the well is completed for production, the AO shall be notified when the well is placed in a producing status. Such notification may be sent by telegram or other written communication, not later than five (5) days following the date on which the well is placed on production. 15. A schematic facilities diagram as required by 43 CFR 3162.7-5 (b.9.d.) shall be submitted to the appropriate District Office within sixty (60) days of installation or first production, whichever occurs first. All site security regulations as specified in Onshore Oil & Gas Order No. 3 shall be adhered to. All product lines entering and leaving hydrocarbon storage tanks will be effectively sealed in accordance with 43 CFR 3162.7-5 (b.4). 16. All off-lease storage, off-lease measurement, or commingling on-lease or off-lease shall have prior written approval from the AO. 17. “Sundry Notice and Report on Wells” (Form 3160-5) shall be filed for approval for all changes of plans and other operations in accordance with 43 CFR 3162.3-2. 18. Water Use. The purpose of this COA is to assist the BLM in ensuring that water depletions associated with Federal oil and gas development activities are adequately covered by the USFWS Programmatic Biological Opinion for the four endangered Colorado River fishes.

COA-15 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The Operator shall provide the volumes of fresh water and reused/recycled water used during project development using the following table. The volumes per well shall be identified by each development phase (construction, drilling, and completion) and by activity (e.g., dust abatement, pipeline hydrostatic testing, drilling, and completion operations). The water volumes shall be identified in an attachment to the BLM Form 3160-4, “Well Completion or Recompletion Report and Log” (completion report) submitted to the BLM Field Office. All volumes are to be reported in barrels per well. The Operator shall submit the total volume of water used during construction of a pad with the first well completion report of the pad. Volumes of water used for subsequent activities (drilling and completing an additional well on the pad, dust abatement) shall be included in subsequent completion reports.

Contact Information

Bob Hartman Stephen Garcia Petroleum Engineer Petroleum Engineer Office: (970) 244-3041 Office: (970) 876-9031 Cell: (970) 589-6735 Cell: (970) 456-2138 [email protected] [email protected]

COA-16 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

List of Wells Proposed Proposed Pad Surface Location Bottomhole Location Well PA 312-26 SWNW Sec. 26 T6S R95W PA 512-26 SWNW Sec. 26 T6S R95W PA 422-26 SENW Sec. 26 T6S R95W PA 522-26 SENW Sec. 26 T6S R95W PA 11-26 NWNW Sec. 26 T6S R95W PA 612-26 NWNW Sec. 26 T6S R95W PA 311-26 NWNW Sec. 26 T6S R95W PA 412-26 SWNW Sec. 26 T6S R95W PA 12-26 SWNW Sec. 26 T6S R95W PA 411-26 NWNW Sec. 26 T6S R95W PA 321-26 NENW Sec. 26 T6S R95W PA 421-26 NENW Sec. 26 T6S R95W PA 521-26 NENW Sec. 26 T6S R95W PA 23-26 Pad PA 331-26 NESW Sec. 26 T6S R95W NWNE Sec. 26 T6S R95W PA 431-26 NWNE Sec. 26 T6S R95W PA 531-26 NWNE Sec. 26 T6S R95W PA 32-26 SWNE Sec. 26 T6S R95W PA 332-26 SWNE Sec. 26 T6S R95W PA 432-26 SWNE Sec. 26 T6S R95W PA 33-26 NWSE Sec. 26 T6S R95W PA 333-26 NWSE Sec. 26 T6S R95W PA 433-26 NWSE Sec. 26 T6S R95W PA 533-26 NWSE Sec. 26 T6S R95W PA 34-26 NWSE Sec. 26 T6S R95W PA 534-26 SWSE Sec. 26 T6S R95W PA 334-26 SWSE Sec. 26 T6S R95W PA 532-26 SWNE Sec. 26 T6S R95W

COA-17

Left blank for two-sided copying.

Balzac Gulch Master Development Plan – Phase 1 TEP Rocky Mountain LLC

Right-of-Way COC78666-01 8-inch Natural Gas Pipeline serving RWF 13-19 Pad Right-of-Way COC78667-01 8-inch Natural Gas Pipeline serving PA 23-26 Pad Right-of-Way COC78667-02 4-inch Natural Gas Pipeline serving PA 23-26 Pad Right-of-Way COC78667-03 4½-inch Surface Frac Pipelines serving PA 23-26 Pad Right-of-Way COC78666 RWF 13-19 Well Pad Site Right-of-Way COC78666-01 8-inch Natural Gas Pipeline serving RWF 13-19 Pad Right-of-Way COC78666-02 Access Road serving RWF 13-19 Pad Right-of-Way COC78667 PA 23-26 Well Pad Site Right-of-Way COC78667-01 8-inch Natural Gas Pipeline serving PA 23-26 Pad Right-of-Way COC78667-02 4-inch Produced Water Line serving PA 23-26 Pad Right-of-Way COC78667-03 Three 4.5-inch Temporary Surface Frac Lines serving PA 23-26 Pad Right-of-Way COC78666-04 Access Road serving PA 23-26 Pad

STIPULATIONS APPLICABLE TO PIPELINE CONSTRUCTION AND OPERATION ACTIVITIES

1. Administrative Notification. The holder shall contact the authorized officer at least 48 hours prior to the anticipated start of construction and/or any surface disturbing activities. The authorized officer may require and schedule a preconstruction conference with the holder prior to the holder's commencing construction and/or surface disturbing activities on the right-of-way. The holder and/or his representative shall attend this conference. The holder's contractor, or agents involved with construction and/or any surface disturbing activities associated with the right-of-way, shall also attend this conference to review the stipulations of the grant including the plans(s) of development.

2. Construction. All pipeline construction and maintenance shall follow the Gold Book Standards (USDI and USDA 2007) and requirements specified by the USACE as part of its authorization of the project under Section 404 of the Clean Water Act. The holder shall construct the welded steel gas gathering lines, flanged flexsteel or fused poly water or condensate lines, operate, and maintain the facilities, improvements, and structures within the limits of the ROW granted and in conformity with the plan of development (including the Pipeline Plan and Profile Sheets) approved and made part of the grant amendment. Any relocation, additional construction, or use not in accord with the approved plan of development shall not be initiated without the prior written approval of the authorized officer.

A copy of the complete ROW grant, including all stipulations and the approved plan of development, shall be made available on the ROW area during construction, operation, and termination. Noncompliance with the above will be grounds for an immediate temporary suspension of activities if it constitutes a threat to public health and safety or the environment.

3. Pipeline Construction Control and Limit-of-Disturbance Staking. Construction control and limit-of- disturbance stakes shall be placed before construction and maintained in place to ensure conformance to the approved project plan. Any markers that are disturbed, displaced, or removed shall be repositioned or replaced before construction proceeds. Pipeline edges shall be marked by construction control stakes to ensure construction in accordance with the specifications. Stakes shall be visible from one to the next and be staked with no more than 100-foot stationing. Any missing or displaced stakes shall be promptly replaced before construction proceeds in proximity to the missing or displaced stakes.

ROW Stipulations-1 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

The width of ROW clearing shall be minimized to avoid undue disturbance to vegetation. Where topsoil salvage and storage is not necessary, brush clearing shall be limited to removal of aboveground vegetation to avoid disturbance of root systems, reducing fugitive dust.

4. As-Built Survey. An “as-built” centerline survey of the right-of-way crossing Federal land, provided by a Certified Land Surveyor licensed to work in the State of Colorado, shall be provided to the BLM within 2 months of completion of the project.

5. Other Required Approvals and Permits. This authorization is contingent upon receipt of and compliance with all appropriate Federal, state, county and local, permits. The holder shall be responsible for obtaining all necessary environmental clearances and permits from all agencies (U.S. Army Corps of Engineers, Colorado Parks and Wildlife, Colorado Department of Transportation, Colorado Department of Public Health and Environment, Garfield County Road and Bridge, and City of Rifle) before commencing any work under this permit. Without all clearances and permits, this permit shall be not in effect. Operator shall assume all responsibility and liability related to potential environmental hazards encountered in connection with work under this permit.

6. Hazardous Waste/Liability/Waste Disposal. The holder(s) shall comply with all applicable Federal laws and regulations existing or hereafter enacted or promulgated. In any event, the holder(s) shall comply with the Toxic Substances Control Act of 1976, as amended (15 U.S.C. 2601, et seq.) with regard to any toxic substances that are used, generated by, or stored on the right-of-way or on facilities authorized under this right-of-way grant. (See 40 CFR, Part 702-799 and especially, provisions on polychlorinated biphenyls, 40 CFR 761.1-761.193.) In addition, any release of toxic substances (leaks, spills, etc.) in excess of the reportable quantity established by 40 CFR, Part 117 shall be reported as required by the Comprehensive Environmental Response, Compensation and Liability Act of 1980, Section 102b. A copy of any report required or requested by any Federal agency or State government as a result of a reportable release or spill of any toxic substances shall be furnished to the authorized officer concurrent with the filing of the reports to the involved Federal agency or State government.

7. Fire Prevention and Control Stipulations a. The Holder shall indemnify the United States for any and all injury, loss or damage to life or property, including fire suppression costs, the United States may suffer as a result of losses, claims, demands or judgments caused by Holder’s use or occupancy of public lands under this grant or permit. b. The Authorized Officer may suspend or terminate in whole, or in part, any notice to proceed which has been issued when, in his or her judgment, conditions arise which result in the approved terms and conditions being inadequate to protect the public health and safety or to protect the environment. c. Holder shall maintain the ROW in a safe, usable condition. d. When performing construction and maintenance (including emergency repairs) activities during the “closed” fire season (May 10 to October 20), as set by Colorado State Law, or during any other closed fire season prescribed by the BLM Colorado State Director, the Holder, including any persons such as contractors, etc. working on their behalf, shall equip at least one on-site vehicle with firefighting equipment, including, but not limited to, fire suppression hand tools (i.e. shovels, rakes, Pulaski’s, etc.), a 16-20 pound fire extinguisher, and a sufficient supply of water for initial attack, with a mechanism to effectively spray the water (i.e. backpack pumps, water sprayer, etc.).

ROW Stipulations-2 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

e. During conditions of extreme fire danger or when the State of Colorado and/or the BLM Colorado State Director issues a fire restriction order, operations shall be limited or suspended in specific areas, or additional mitigation measures may be required by the BLM Authorized Officer. f. In accordance with 43 CFR 2805.12(d) (or subsequent revisions), the Holder shall do everything reasonable to prevent fires on or in the immediate vicinity of the ROW. The Holder will immediately report fires to the BLM Authorized Officer or local fire dispatch (GJ dispatch 970- 257-4800) and take all necessary fire suppression actions, when safe to do so, with their personnel and equipment on any fires they cause to ignite. 1. Holder shall maintain the condition of the origin area of the fire from further damage to enable the Fire Investigator to properly assess the origin area and cause of the fire. The Holder shall report to the Fire Investigator or BLM Incident Commander and shall not enter into the origin area on fires unless given permission to do so.

2. The Holder will cooperate with the BLM in its efforts to investigate, suppress and respond to all future fires. The duty to “cooperate” includes, but is not limited to, the following duties regardless of whether BLM is on the scene:

i. The duty to provide the BLM (Authorized Officer or local fire dispatch (GJ dispatch 970- 257-4800) with reasonable and timely notice concerning all fires involving the Holder’s facilities, or discovered during routine operations. ii. The duty to share factual information with the BLM concerning fires, including but not limited to the names of Holder’s employees and/or contractors with knowledge of the incident; and to allow employees and/or contractors to be interviewed by BLM’s investigators regarding factual information relating to a fire. iii. It is the duty of the Holder to preserve the point of ignition, fire scene and reasonably account to the BLM for Holders actions taken at the scene of a fire. iv. The duty to minimize disturbance of potential evidence located at the scene; to not engage in any evidence collection or destructive testing without BLM and or its counsel’s express written consent; to properly handle and preserve any evidence collected and to make all documents and evidence, including expert reports, available to the BLM in a rapid and timely manner upon request of BLM and/or its counsel. v. The duty to not hamper the BLM investigation of origin and cause of the fire; and to reasonably assist BLM’s investigation at the scene. vi. The duty to provide information upon request of BLM and/or its counsel concerning the construction, monitoring, inspection, maintenance and/or repairs of any of Holder’s facilities located at or adjacent to a fire. vii. The duty to provide information upon request of BLM and/or its counsel concerning the monitoring, inspection, and or alteration by Holder of any condition on public land, including but not limited to, public land adjacent to any of the Holder’s facilities. viii. The duty, during BLM fire suppression efforts: to defer to and follow the instructions of the BLM’s Incident Commander regarding activities within the boundaries of the fire and checking in and out of the fire; and to recognize BLM’s primary authority over the incident scene. 8. Subsequent Maintenance and Repairs. The holder shall not initiate any construction or other surface- disturbing activities, including those associated with routine or other non-emergency repair or

ROW Stipulations-3 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

maintenance actions, within the limits of the ROW without prior written authorization of the BLM. Any notice to proceed shall authorize construction or use only as therein expressly stated and only for the particular location or use therein described.

9. Notice Prior to Termination. At least 90 days prior to termination of the ROW, the holder shall contact the BLM to arrange a joint inspection of the ROW. This inspection will be held to agree to an acceptable termination and rehabilitation plan. This plan shall include, but is not limited to, removal of surface facilities and recontouring and revegetation of any areas disturbed by the removal of surface facilities. Commencement of termination activities shall not occur without the prior written approval of the BLM.

10. Road Maintenance. Any roads impacted by construction activities for the Balzac Gulch Phase 1 project shall be restored to the following conditions: crowned, ditched, surfaced, drained with culverts and/or water dips, and constructed to BLM Gold Book standards. A follow-up gravel application, after pipeline construction work has removed any road surfacing from roads adjacent to the pipeline corridor, shall be a minimum of 6 inches unless otherwise authorized by the BLM. The holder shall provide timely road maintenance and cleanup on the access roads. Road maintenance shall include, but not be limited to, blading, ditch and culvert cleaning, road surface replacement, and dust abatement. When rutting within the traveled way becomes greater than 6 inches, blading and/or gravelling shall be conducted as approved by the BLM.

11. Dust Abatement. The holder shall implement dust abatement measures as needed to prevent fugitive dust from vehicular traffic, equipment operations, or wind events. The BLM may direct the holder to change the level and type of treatment (watering or application of various dust agents, surfactants, and road surfacing material) if dust abatement measures are observed to be insufficient to prevent fugitive dust.

12. Drainage Crossings and Culverts. Construction activities at perennial, intermittent, and ephemeral drainage crossings (e.g., burying pipelines, installing culverts) shall be timed to avoid high flow conditions. Construction that disturbs any flowing stream shall utilize either a piped stream diversion or a cofferdam and pump to divert flow around the disturbed area.

13. Jurisdictional Waters of the U.S. The holder shall obtain appropriate permits from the U.S. Army Corps of Engineers (USACE) prior to discharging fill material into Waters of the U.S. in accordance with Section 404 of the Clean Water Act. Waters of the U.S. are defined in 33 CFR Section 328.3 and may include wetlands as well as perennial, intermittent, and ephemeral streams. Permanent impacts to Waters of the U.S. may require mitigation. Contact the USACE Colorado West Regulatory Branch at 970-243-1199.

ROW Stipulations-4 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

14. Reclamation. The goals, objectives, timelines, measures, and monitoring methods for final reclamation of oil and gas disturbances are described in Appendix I (Surface Reclamation) of the 1998 Draft Supplemental EIS (DSEIS). Specific measures to follow during interim reclamation are described below.

a. Reclamation Plans. In areas that have low reclamation potential, reclamation plans will be required prior to grant approval. The plan shall contain the following components: Detailed reclamation plats, which include contours and indicate irregular rather than smooth contours as appropriate for visual and ecological benefit; timeline for drilling completion, interim reclamation earthwork, and seeding; soil test results and/or a soil profile description; amendments to be used; soil treatment techniques such as roughening, pocking, and terracing; erosion control techniques such as hydromulch, blankets/matting, and wattles; and visual mitigations if in a sensitive VRM area.

b. Deadline for Interim Reclamation Earthwork and Seeding.

Reclamation, including seeding, of temporarily disturbed areas along roads and pipelines, and of topsoil piles and berms, shall be completed within 30 days following completion of construction. Any such area on which construction is completed prior to December 1 shall be seeded during the remainder of the early winter season instead of during the following spring, unless the BLM approves otherwise based on weather. If road or pipeline construction occurs discontinuously or continuously but with a total duration greater than 30 days, reclamation, including seeding, shall be phased such that no portion of the temporarily disturbed area remains in an unreclaimed condition for longer than 30 days. The BLM may authorize deviation from this requirement based on the season and the amount of work remaining on the entirety of the road or pipeline when the 30-day period has expired.

If requested by the project lead NRS for a specific purpose, the holder shall contact the NRS by telephone or email approximately 72 hours before reclamation and reseeding begin. This will allow the NRS to schedule a pre-reclamation field visit if needed to ensure that all parties are in agreement and provide time for adjustments to the plan before work is initiated.

The deadlines for seeding described above are subject to extension upon approval of the BLM based on season, timing limitations, or other constraints on a case-by-case basis. If the BLM approves an extension for seeding, the holder may be required to stabilize the reclaimed surfaces using hydromulch, erosion matting, or other method until seeding is implemented.

c. Topsoil Stripping, Storage, and Replacement. All topsoil shall be stripped following removal of vegetation during construction of the pipeline, and other related facilities. In areas of thin soil, a minimum of the upper 6 inches of surficial material shall be stripped. The BLM may specify a stripping depth during the onsite visit or based on subsequent information regarding soil thickness and suitability. The stripped topsoil shall be stored separately from subsoil or other excavated material and replaced prior to final seedbed preparation. The BLM best management practice (BMP) for the Windrowing of Topsoil shall be implemented for pipeline construction whenever topography allows.

d. Seedbed Preparation. For cut-and-fill slopes, initial seedbed preparation shall consist of backfilling and re-contouring to achieve the configuration specified in the reclamation plan. For compacted areas, initial seedbed preparation shall include ripping to a minimum depth of 18 inches, with a maximum furrow spacing of 2 feet. Where practicable, ripping shall be conducted

ROW Stipulations-5 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

in two passes at perpendicular directions. Following final contouring, the backfilled or ripped surfaces shall be covered evenly with topsoil.

If directed by the BLM, the holder shall implement measures following seedbed preparation (when broadcast seeding or hydroseeding is to be used) to create small depressions to enhance capture of moisture and establishment of seeded species. Depressions shall be no deeper than 1 to 2 inches and shall not result in piles or mounds of displaced soil. Excavated depressions shall not be used unless approved by the BLM for the purpose of erosion control on slopes. Where excavated depressions are approved by the BLM, the excavated soil shall be placed only on the downslope side of the depression.

If directed by the BLM, the holder shall conduct soil testing prior to reseeding to identify if and what type of soil amendments may be required to enhance revegetation success. At a minimum, the soil tests shall include texture, pH, organic matter, sodium adsorption ratio (SAR), cation exchange capacity (CEC), alkalinity/salinity, and basic nutrients (nitrogen, phosphorus, potassium [NPK]). Depending on the outcome of the soil testing, the BLM may require the holder to submit a plan for soil amendment. Any requests to use soil amendments not directed by the BLM shall be submitted to the CRVFO for approval.

e. Seed Mixes. The seed mix presented in Table A-1 of this appendix shall be used in reclamation of the proposed pipeline and ancillary surface disturbances on BLM lands and is recommended for use on private lands. For private lands, the holder may use an alternative seed mix if requested by the landowner, except for lands owned by the holder.

The seed shall contain no prohibited or restricted noxious weed seeds and shall contain no more than 0.5% by weight of other weed seeds. Seed may contain up to 2.0% of “other crop” seed by weight, including the seed of other agronomic crops and native plants; however, a lower percentage of other crop seed is recommended. Seed tags or other official documentation shall be submitted to the BLM at least 14 days before the date of proposed seeding for acceptance. Seed that does not meet the above criteria shall not be applied to public lands.

f. Seeding Procedures. Seeding shall be conducted no more than 24 hours following completion of final seedbed preparation.

An exception to these seeding requirements shall be made for seeding of sagebrush. Sagebrush seeding shall occur prior to winter snowfall, or on top of snow. Sagebrush may be sown by broadcast seeding, or, if not on snowpack, or by placing the seed in the fluffy seed box of a seed drill, with the drop tube left open to allow seed to fall out on the ground surface.

ROW Stipulations-6 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

If interim revegetation is unsuccessful, the holder shall implement subsequent reseedings until interim reclamation standards are met.

g. Mulch. Mulch shall not be used within mountain shrub or spruce-fir forest habitat types, unless requested or approved by the BLM.

NOTE: Mulch is not required in areas where erosion potential mandates use of a biodegradable erosion-control blanket (straw matting).

h. Erosion Control. Cut-and-fill slopes shall be protected against erosion with the use of water bars, lateral furrows, or other BMPs approved by the BLM. Additional BMPs, such as biodegradable wattles, weed-free straw bales, or silt fences, shall be employed as necessary to reduce transport of sediment into drainages. The BLM may require the use of hydromulch or biodegradable blankets/ matting to ensure adequate protection from slope erosion and offsite transport of sediment and to improve reclamation success.

i. Monitoring. The holder shall conduct annual monitoring surveys of all sites categorized as “reclamation in progress” and shall submit an annual monitoring report of these sites, including a description of the monitoring methods used, to the BLM by December 31 of each year. The monitoring program shall use the four Reclamation Categories defined in Appendix I of the 1998 DSEIS to assess progress toward reclamation objectives. The annual report shall document whether attainment of reclamation objectives appears likely. If one or more objectives appear unlikely to be achieved, the report shall identify appropriate corrective actions. Upon review and approval of the report by the BLM, the holder shall be responsible for implementing the corrective actions or other measures specified by the BLM.

15. Weed Control. The holder shall regularly monitor and promptly control noxious weeds or other undesirable plant species as set forth in the Glenwood Springs Field Office Noxious and Invasive Weed Management Plan for Oil and Gas Operators, dated March 2007. A Pesticide Use Proposal (PUP) must be approved by the BLM prior to the use of herbicides. Annual weed monitoring reports and Pesticide Application Records (PARs), including GPS data in accordance with the February 27, 2014, letter to operators, shall be submitted to BLM by December 1.

16. Wetlands and Riparian Zones. The operator shall reclaim temporarily disturbed wetlands or riparian areas. The operator shall consult with the BLM Colorado River Valley Field Office to determine appropriate mitigation, including verification of native plant species to be used in reclamation.

17. Big Game Winter Range Timing Limitation. To minimize impacts to wintering big game, no construction, drilling or completion activities shall occur during a Timing Limitation (TL) period from December 1 through April 30 annually.

18. Bald and Golden Eagles. It shall be the responsibility of the holder to comply with the Bald and Golden Eagle Protection Act (Eagle Act) with respect to “take” of either eagle species. Under the Eagle Act, “take” includes to pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest and disturb. “Disturb” means to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, based on the best scientific information available, (1) injury to an eagle; (2) a decrease in its productivity by substantially interfering with normal breeding, feeding, or sheltering behavior; or (3) nest abandonment by substantially interfering with normal breeding, feeding, or sheltering behavior. Avoidance of eagle nest sites, particularly during the nesting season, is the primary and preferred method to avoid a take. Any oil or gas construction activities planned within 0.5 mile of a bald or golden eagle nest, or other associated activities greater than 0.5 miles from a nest that may

ROW Stipulations-7 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

disturb eagles, shall be coordinated with the BLM project lead and BLM wildlife biologist and the USFWS representative to the BLM Field Office (970-876-9051).

19. Raptor Nesting. To protect nesting raptors, a survey shall be conducted prior to construction activities that are to begin during the raptor nesting season (February 1 to August 15). The survey shall include all potential nesting habitat within 0.25 mile of a well pad or 0.125 mile of an access road, pipeline, or other surface facility. Results of the survey shall be submitted to the BLM. If an active raptor nest is located within the buffer widths specified above, this TL will be applied to preclude initiation of construction within the specified buffer distances until the young have fledged or the nest has failed for a natural cause. The operator is responsible for complying with the MBTA, which prohibits the “take” of birds or of active nests (those containing eggs or young), including nest failure caused by human activity (see COA for Migratory Birds).

20. Migratory Birds – Birds of Conservation Concern. Pursuant to BLM Instruction Memorandum 2008- 050, all vegetation removal or surface disturbance in previously undisturbed lands providing potential nesting habitat for Birds of Conservation Concern (BCC) is prohibited from May 15 to July 15. An exception to this TL may be granted if nesting surveys conducted no more than one week prior to surface-disturbing activities indicate that no BCC species are nesting within 30 meters (100 feet) of the area to be disturbed. Nesting shall be deemed to be occurring if a territorial (singing) male is present within the distance specified above. Nesting surveys shall include an audial survey for diagnostic vocalizations in conjunction with a visual survey for adults and nests. Surveys shall be conducted by a qualified breeding bird surveyor between sunrise and 10:00 AM under favorable conditions for detecting and identifying a BCC species. This provision does not apply to ongoing construction activities that are initiated prior to May 1 and continue into the 60-day period at the same location.

21. Migratory Birds – General. It shall be the responsibility of the holder to comply with the Migratory Bird Treaty Act (MBTA) with respect to “take” of migratory bird species, which includes injury and direct mortality resulting from human actions not intended to have such result.

22. Fossil Resources. All persons associated with operations under this authorization shall be informed that any objects or sites of paleontological or scientific value, such as vertebrate or scientifically important invertebrate fossils, shall not be damaged, destroyed, removed, moved, or disturbed. If in connection with operations under this authorization any of the above resources are encountered the holder shall immediately suspend all activities in the immediate vicinity of the discovery that might further disturb such materials and notify the BLM of the findings. The discovery must be protected until notified to proceed by the BLM.

Where feasible, the holder shall suspend ground-disturbing activities at the discovery site and immediately notify the BLM of any finds. The BLM would, as soon as feasible, have a BLM- permitted paleontologist check out the find and record and collect it if warranted. If ground- disturbing activities cannot be immediately suspended, the holder shall work around or set the discovery aside in a safe place to be accessed by the BLM-permitted paleontologist.

23. Cultural Education/Discovery. All persons in the area who are associated with this project shall be informed that if anyone is found disturbing historic, archaeological, or scientific resources, including collecting artifacts, the person or persons would be subject to prosecution.

ROW Stipulations-8 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

evaluated by the permitted archaeologist. Within 48 hours of the discovery, the SHPO and consulting parties will be notified of the discovery and consultation will begin to determine an appropriate mitigation measure. BLM in cooperation with the holder will ensure that the discovery is protected from further disturbance until mitigation is completed. Operations may resume at the discovery site upon receipt of written instructions and authorization by the authorized officer.

Antiquities, historic ruins, prehistoric ruins, and other cultural or paleontological objects of scientific interest that are outside the authorization boundaries but potentially affected, either directly or indirectly, by the Proposed Action shall also be included in this evaluation or mitigation. Impacts that occur to such resources as a result of the authorized activities shall be mitigated at the holder's cost, including the cost of consultation with Native American groups.

24. Windrowing of Topsoil. Topsoil shall be windrowed to create a berm that limits and redirects stormwater runoff and extends the viability of the topsoil per BLM Topsoil Best Management Practices (BLM 2009 PowerPoint presentation available from the Colorado River Valley Field Office). Topsoil shall also be windrowed, segregated, and stored along pipelines and roads for later spreading across the disturbed corridor during final reclamation. Topsoil berms shall be promptly seeded to maintain soil microbial activity, reduce erosion, and minimize weed establishment.

25. Range Management. Range improvements (fences, gates, reservoirs, pipelines, etc.) shall be avoided during development of oil and natural gas resources to the maximum extent possible. If range improvements are damaged during exploration and development, the holder will be responsible for repairing or replacing the damaged range improvements. If the proposed pipeline alignment bisects an existing livestock fence, a temporary fence shall be installed during construction in the area to control grazing livestock. The temporary fence shall be installed on a daily basis. A steel-frame gate or a cattleguard with associated bypass gate shall be installed across the roadway to control grazing livestock.

26. Visual Resources. To the extent practicable, existing vegetation shall be preserved when clearing and grading for the pipeline. The BLM may direct that cleared trees and rocks be salvaged and redistributed over the right-of-way. All aboveground facilities shall be painted Shadow Gray to minimize contrast with adjacent vegetation or rock outcrops.

PROJECT-SPECIFIC MITIGATION MEASURES

Agreements with Other Holders. Potential impacts to the existing BLM ROWs from lease operations or by the rights-of-way would be mitigated based on written maintenance and use agreements between Red

ROW Stipulations-9 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA

Rock Gathering, LLC, and the existing ROW holders. Such agreements shall be obtained and verified with the BLM prior to any disturbance or construction across or adjacent to an existing right-of-way.

Monuments. The holder shall protect all survey monuments found within the right-of-way. Survey monuments include, but are not limited to, General Land Office and Bureau of Land Management Cadastral Survey Corners, reference corners, witness points, U.S. Coastal and Geodetic benchmarks and triangulation stations, military control monuments, and recognizable civil (both public and private) survey monuments. In the event of obliteration or disturbance of any of the above, the holder shall immediately report the incident, in writing, to the authorized officer and the respective installing authority if known.

Where General Land Office or Bureau of Land Management right-of-way monuments or references are obliterated during operations, the holder shall secure the services of a registered land surveyor or a Bureau cadastral surveyor to restore the disturbed monuments and references using surveying procedures found in the Manual of Surveying Instructions for the Survey of the Public Lands in the United States, latest edition. The holder shall record such survey in the appropriate county and send a copy to the authorized officer. If the Bureau cadastral surveyors or other Federal surveyors are used to restore the disturbed survey monument, the holder shall be responsible for the survey cost.

Saturated Soil Conditions. When saturated soil conditions exist on access road or along the pipeline ROW, any type of construction shall be halted until soil material dries out or is frozen sufficiently for construction to proceed without undue damage and erosion to soils.

Soils and Erosion. Cuts and fills shall be minimized when working on slopes in excess of 30% and on fragile soils. Cut-and-fill slopes shall be stabilized through revegetation practices with an approved seed mix shortly following construction activities to minimize the potential for slope failures, erosion, and soil loss. Slopes adjacent to drainages shall be protected with BMPs designed to minimize sediment transport. The BLM may require the holder to utilize special construction or reclamation techniques to ensure subsequent slope stability and facilitate revegetation success.

Stormwater Management. The operator shall comply with its SWMP and shall install and maintain such other adaptive BMPs as necessary and appropriate for the location. Specific attention shall be given to avoiding or minimizing the transport of eroded soils and other surficial materials to drainages that could transport the eroded materials into perennial stream reaches. Stormwater BMPs may also serve in conjunction with the SPCC to reduce or avoid the transport of chemical pollutants spilled or released in proximity to drainages. Staging, refueling, and storage areas shall be located at least 300 feet from any reservoir, lake, wetland, or natural perennial or seasonally flowing stream.

Vehicle Speeds. To minimize fugitive dust, associated risks to special status plants or their pollinators, and risks of injury or mortality of wildlife, the holder shall ensure that all project-related traffic adhere to a speed limit of 25 mph, or lower speed limit if posted by Garfield County or as directed by the BLM.

Reporting Requirement for Hydrostatic Pipeline Testing: The method of pipeline pressure testing has not been identified. If hydrostatic pipeline pressure testing is the selected method, the Operator shall disclose to the BLM, prior to implementation, the source(s) of water, volume of water to be used, and details of the manner in which the water is to be delivered, collected and reused/disposed.

Surface Frac Lines

The installation of the three welded steel 4½-inch surface lines shall use the existing two-track as much as possible across the entire alignment. The lines shall be pushed down the steep slope in a manner that minimizes damage to any standing trees. A landing area (estimated width of 50 feet) for the steel lines

ROW Stipulations-10 66 Federal Wells, Balzac Gulch - Phase 1 MDP DOI-BLM-CO-N040-2017-0093-EA bearing down the steep slope shall be established with flagging prior to installation. Spanning of the main drainage shall occur upgradient from the two-track crossing in a manner that reduces the span length and avoids trees and weak-appearing slopes or drainage walls. The portion of each steel line spanning the high-walled drainage shall be cased inside a segment of 10-inch poly water line featuring 2-inch thick walls to act as a protective sleeve.

ROW Stipulations-11