Environmental Assessment Badlands Proposes to Drill 16 Wells

UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF LAND MANAGEMENT

ENVIRONMENTAL ASSESSMENT

BADLANDS PROPOSES TO DRILL 16 WELLS FROM THREE EXISTING WELL PADS

DOI-BLM-UT-G010-2017-0008- EA

October 2017

Location: Uintah County, Utah Sections 29 and 30, T9S, R19E

Applicant/Address: Badlands Production Company 7979 E Tufts Ave., Suite 1150 Denver, CO 80237

Vernal Field Office 170 South 500 East Vernal, Utah 84078 435-781-4400 435-781-4410

BADLANDS PROPOSES TO DRILL 16 WELLS FROM THREE EXISTING WELL PADS

DOI-BLM-UT-G010-2017-0008-EA

TABLE OF CONTENTS

1.0 Introduction ...... 1 Background ...... 1 Purpose and Need for the Proposed Action ...... 2 Conformance with BLM Land Use Plan(s) ...... 2 Relationship to Statutes, Regulations, or Other Plans...... 3 Identification of Issues ...... 3 Resource 1 Air Quality & Greenhouse Gas Emissions ...... 3 Resource 2 Invasive Plants/Noxious Weeds, Soils & Vegetation ...... 3 Resource 3 Paleontology ...... 4 Resource 4 Plants: Threatened, Endangered, Proposed, or Candidate ...... 4 Resource 5 Wildlife: Migratory Birds (Including Raptors) ...... 4 Resource 6 Wildlife: Non-USFWS Designated ...... 4 Resource 7 Wildlife: Threatened, Endangered, Proposed, or Candidate ...... 4 Summary ...... 4 2.0 Description of Alternatives ...... 5 Introduction ...... 5 Alternative A – Proposed Action ...... 5 Roads ...... 6 Pipelines...... 6 Water Used ...... 7 Reclamation ...... 8 Alternative B – No Action ...... 8 Roads ...... Error! Bookmark not defined. Water Used ...... Error! Bookmark not defined.

Reclamation ...... Error! Bookmark not defined. 3.0 Affected Environment ...... 9 Resources/Issues Brought Forward for Analysis ...... 9 Resource 1 Air Quality and Greenhouse Gas Emissions ...... 9 Resource 2 Invasive Plants/Noxious Weeds, Soils, and Vegetation ...... 16 Resource 3 Paleontology ...... 19 Resource 4 Plants: Threatened, Endangered, Proposed, or Candidate ...... 20 Resource 5 Wildlife: Migratory Birds (Including Raptors) ...... 20 Resource 6 Wildlife: Non-USFWS Designated ...... 21 Resource 7 Wildlife: Threatened, Endangered, Proposed, or Candidate ...... 21 4.0 ENVIRONMENTAL IMPACTS ...... 22 4.1 Alternative A – Proposed Action...... 22 Resource 1 Air Quality and Greenhouse Gas Emissions ...... 22 Resource 2 Invasive Plants/Noxious Weeds, Soils, and Vegetation ...... 26 Resource 3 Paleontology ...... 27 Resource 4 Plants: Threatened, Endangered, Proposed, or Candidate ...... 28 Resource 5 Wildlife: Migratory Birds (Including Raptors) ...... 30 Resource 6 Wildlife: Non-USFWS Designated ...... 30 Resource 7 Wildlife: Threatened, Endangered, Proposed, or Candidate ...... 30 Monitoring and/or Compliance ...... 32 4.2 Alternative B – No Action ...... 32 Resource 1 Air Quality and Greenhouse Gas Emmisions ...... 32 Resource 2 Invasive Plants/Noxious Weeds, Soils, and Vegetation ...... 32 Resource 3 Paleontology ...... 32 Resource 4 Plants: Threatened, Endangered, Proposed, or Candidate ...... 32 Resource 5 Wildlife: Migratory Birds (Including Raptors) ...... 33 Resource 6 Wildlife: Non-USFWS Designated ...... 33 Resource 7 Wildlife: Threatened, Endangered, Proposed, or Candidate ...... 33 Monitoring and/or Compliance ...... 33 4.4 Cumulative Impacts ...... 34 Resource 1 Air Quality and Greenhouse Gas Emmisions ...... 34 Resource 2 Invasive Plants/Noxious Weeds, Soils, and Vegetation ...... 36 Resource 3 Paleontology ...... 36 Resource 4 Plants: Threatened, Endangered, Proposed, or Candidate ...... 37

Resource 5 Wildlife: Migratory Birds (Including Raptors) ...... 38 Resource 6 &7 Wildlife: Non-USFWS Designated and THreatened, Endangered, Proposed, or Candidate ...... 38 5.0 CONSULTATION AND COORDINATION ...... 39 Introduction ...... 39 Persons, Groups, and Agencies Consulted ...... 39 Summary of Public Participation ...... 40 List of Preparers ...... 40 6.0 REFERENCES, GLOSSARY AND ACRONYMS ...... 42 Introduction ...... 42 References Cited ...... Error! Bookmark not defined. Glossary of Terms ...... 46 List of Acronyms ...... 47 APPENDICES ...... Error! Bookmark not defined. APPENDIX A: Interdisciplinary Team Checklist ...... 1 APPENDIX B: Photographs from the 42-29-9-19 well pad ...... 1

BADLANDS PROPOSES TO DRILL 16 WELLS FROM THREE EXISTING WELL PADS

DOI-BLM-UT-G010-2017-0008-EA

1.0 INTRODUCTION

This Environmental Assessment (EA) has been prepared to disclose and analyze the environmental consequences of drilling 16 wells on three existing well pads as proposed by Badlands Production Company. The EA is a site-specific analysis of potential impacts that could result with the implementation of a proposed action or alternatives to the proposed action. The EA assists the BLM in project planning and ensuring compliance with the National Environmental Policy Act (NEPA), and in making a determination as to whether any “significant” impacts could result from the analyzed actions. “Significance” is defined by NEPA and is found in regulation 40 CFR 1508.27. An EA provides evidence for determining whether to prepare an Environmental Impact Statement (EIS) or a Finding of No Significant Impact (FONSI) statement. A FONSI statement is a document that briefly presents the reasons why implementation of the selected alternative would not result in “significant” environmental impacts (effects) beyond those already addressed in Vernal Field Office Resource Management Plan (BLM 2008). If the decision maker determines that this project has “significant” impacts following the analysis in the EA, then an EIS would be prepared for the project. If not, a Decision Record (DR) may be signed for the EA approving the alternative selected.

Badlands proposes to drill 16 new gas wells in sections 29 and 30 of T9S R19E. Badlands also proposes to install gas gathering pipeline in sections 25 and 36 of T9S R18E as part of the project. A right-of-way would be required for the portion of pipeline that goes off lease and also for the well pads that have well bores going into a different lease. The proposed project area is located approximately 26 miles southeast of Myton, Utah.

1.1 BACKGROUND

In July 2014, the BLM approved DOI-BLM-UT-G010-2013-0132-EA (EA 2013-0132), Gasco Production Company Proposes to Drill 16 Gas Wells from Three Existing Well Pads (Bureau of Land Management Vernal Field Office, 2014). Shortly thereafter the APD’s were approved and Badlands expanded the 43-30-9-19 Well Pad, drilled four wells, and completed the surface pipelines to all locations. A State Director Review appeal was filed against the project in August 2014 (Southern Utah Wilderness Alliance, 2014), and the decision was affirmed by the Utah State Director later that same month (Bureau of Land Management Utah State Office, 2014). The 16 well project was added to an ongoing District Court Case against the Gasco EIS in November of 2014 through a “Second Amended Complaint” (Second Amended Complaint for Declaratory and Injunctive Relief, 2014). The appeal was refined in July of 2015 through a “Third Amended Complaint” (Third Amended Complaint for Declaratory and Injunctive Relief, 2014). In October 2016 the District Court 1

remanded the EA for corrections (Memorandum Decision and Order, 2016). This EA contains those corrections. See Appendix C.

This EA addresses all 16 wells and their pipelines to provide new NEPA for the entire proposed action, although four wells have already been drilled and the pipelines have already been installed. In addition, this revised EA refers to Badlands Production Company (Badlands) as the operator because during the time of the appeal resolution, Badlands purchased Gasco Production Company. However, GASCO’s Standard Operating Procedures (SOP’s) remain valid for Badlands Production Company. Also the 12 undrilled APDs expired during the time of the appeal resolution, but the company did submit a timely request for extension. If the proposed action alternative is selected at the end of this EA review process, the extension request would be granted, and the 12 APDs would be approved for an additional 2 years.

1.2 PURPOSE AND NEED FOR THE PROPOSED ACTION

The BLM’s need is to respond to Badland’s applications to drill 4 wells on lease UTU-037246, 8 wells on lease UTU-76034, and 4 wells on lease UTU-76262. Specifically, if the proposed action alternative is selected at the end of this EA review process, an extension request would be granted for the 12 undrilled wells, and the four existing wells would be allowed to continue production.

The BLM’s purpose is to allow beneficial use of the applicant’s lease in an environmentally sound manner. Private exploration and production from federal oil and gas leases is an integral part of the BLM oil and gas leasing program under authority of the Mineral Leasing Act of 1920, as amended by the Federal Land Policy and Management Act of 1976 and the Federal Onshore Oil and Gas Leasing Reform Act of 1987. The operator has a valid existing right to extract mineral resources from their federal leases subject to the lease’s terms and conditions. If successful, Badlands would produce commercial quantities of gas from its federal oil and gas lease. There are known hydrocarbon- trapping mechanisms within the project area, based on previously drilled wells and reasoned geologic formation and mineral potential. The BLM oil and gas leasing program encourages development of domestic oil and gas reserves and the reduction of U.S. dependence on foreign energy sources.

1.3 CONFORMANCE WITH BLM LAND USE PLAN(S)

The proposed action and alternatives described below are in conformance with the Vernal Field Office Resource Management Plan, approved 2008 as amended (Bureau of Land Management Vernal Field Office, 2008d). Badlands has a valid existing right to extract mineral resources from leases UTU-037246, UTU-76034, and UTU-76262 subject to the lease’s terms and conditions. The Minerals and Energy Resources Management Objectives encourage the drilling of oil and gas wells by private industry

1) They conform to decisions MIN-1, MIN-2, and MIN-8 on pages 96 and 97, which state(s): “These activities will be allowed in the VPA unless precluded by other program prescriptions.” It has been determined that the proposed action and alternatives would not conflict with other decisions throughout the plan.

2) Although the proposed action and alternative(s) are not specifically mentioned in the plan, they are consistent with its objectives, goals, and decisions as they relate to Oil and Gas programs and/or Mineral and Energy resources as stated on pages 96 and 97 of the RMP. It has been determined that the proposed action and alternative(s) would not conflict with other decisions throughout the plan.

1.4 RELATIONSHIP TO STATUTES, REGULATIONS, OR OTHER PLANS

The subject lands were leased for oil or gas development under authority of the Mineral Leasing Act of 1920, as modified by the Federal Land Policy and Management Act of 1976, and the Federal Onshore Oil and Gas Leasing Reform Act of 1987. The lessee/operator has the right to explore for oil and gas on the lease as specified in 43 CFR 3103.1-2, and if a discovery is made, to produce oil and/or natural gas for economic gain.

There are no comprehensive State of Utah plans for the vicinity of the Proposed Action. The State of Utah School and Institutional Trust Lands Administration (SITLA) have leased much of the nearby state land for oil and gas production. Because the objectives of SITLA are to produce funding for the state school system, and because production on federal leases could further interest in drilling on state leases in the area, it is assumed that the alternatives analyzed, except the No Action Alternative, are consistent with the objectives of the state.

The proposed project is consistent with the Uintah County General Plan, 2011, as amended that encompasses the location of the proposed wells (Uintah County, 2011). In general, the plan indicates support for development proposals such as the Proposed Action through the plan's emphasis on multiple-use public land management practices, responsible use and optimum utilization.

The proposed project is consistent with the Gasco Uinta Basin Field Development EIS Record of Decision (Bureau of Land Management Vernal Field Office, 2012c). That ROD allowed for the drilling of 1,298 new gas production wells. No new well pads are proposed, so the new well pad placement restrictions do not apply. Analysis from the Final EIS (Bureau of Land Management Vernal Field Office, 2012a) has been incorporated into this EA as appropriate.

1.5 IDENTIFICATION OF ISSUES

Chapter 5 summarizes the issue identification process. The ID Team Checklist Appendix A provides the rationale for issues that were considered but not analyzed further.

1.5.1 AIR QUALITY & GREENHOUSE GAS EMISSIONS

Issue 1: Emissions from earth-moving equipment, vehicle traffic, drilling and completion activities, production operations, daily tailpipe and fugitive dust emissions, and other sources could adversely affect air quality and contribute to greenhouse gas (GHG) emissions.

1.5.2 INVASIVE PLANTS/NOXIOUS WEEDS, SOILS & VEGETATION

Issue 1: Development of well pads, pipelines, access roads, and power lines would result in an estimated 0.5 acres of surface disturbance until interim reclamation is successful, which would result in the potential spread and establishment of invasive plants and noxious weeds.

Issue 2: Development of well pads, pipelines, access roads, and power lines would result in an estimated 0.5 acres of surface disturbance until interim reclamation is successful, which would result in direct and indirect impacts to vegetation and soils.

1.5.3 PALEONTOLOGY

Issue 1: Development of well pads, pipelines, access roads, and power lines could result in direct and indirect impacts to paleontological resources.

1.5.4 PLANTS: THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

Issue 1: Development of well pads, pipelines, access roads, and power lines could result in direct and indirect impacts to the Uinta Basin hookless cactus (Sclerocactus wetlandicus).

1.5.5 WILDLIFE: MIGRATORY BIRDS (INCLUDING RAPTORS)

Issue 1: Migratory birds and raptors are present in the Project Area and could be affected by surface disturbance and other project-related activity.

1.5.6 WILDLIFE: NON-USFWS DESIGNATED

Issue 1: Activities associated with the Proposed Action may have adverse effects on general wildlife species and water depletions could affect fish species and fisheries including BLM sensitive species and State of Utah species of concern in the Colorado River Basin.

1.5.7 WILDLIFE: THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

Issue 1: Four endangered fish species are historically associated with the Upper Colorado River Basin and its tributaries. Fresh water used for drilling, completion, and dust suppression activities associated with the Proposed Action would contribute to new water depletions of the Colorado River Basin that could affect these federally-listed fish species.

1.6 SUMMARY

This chapter has presented the purpose and need of the proposed project, as well as the relevant issues, i.e., those elements of the human environment that could be affected by the implementation of the proposed project. In order to meet the purpose and need of the proposed project in a way that resolves the issues, the BLM has considered and/or developed a range of action alternatives. These alternatives are presented in Chapter 2. The potential environmental impacts or consequences resulting from the implementation of each alternative considered in detail are analyzed in Chapter 4 for each of the identified issues.

2.0 DESCRIPTION OF ALTERNATIVES

This chapter describes the alternatives considered by the BLM during preparation of this Environmental Assessment.

2.1 INTRODUCTION

This chapter provides a description of the Proposed Action and No Action Alternative. No additional action alternatives have been identified. This EA considers a No Action Alternative to provide a baseline for comparison of the impacts of the Proposed Action. The Proposed Action integrates the terms and conditions in the GASCO Energy Inc. (now Badlands), Final Environmental Impact Statement (Bureau of Land Management Vernal Field Office, 2012c).

2.1.1 ALTERNATIVE A – PROPOSED ACTION

As stated previously, Badlands had already expanded the 43-30-9-19 well pad by 0.1 acre, drilled an additional four wells on that pad, and completed the surface pipelines to all locations. This alternative includes the impacts from those four wells so that their impacts are disclosed along with the future potential impacts from the remaining 12 wells.

Badlands proposes to drill 16 gas wells from three existing well pads (See the photos in Appendix B and the maps in Appendix D). The existing well pads would be expanded to accommodate the new wells. Badlands also proposes to build approximately 26,587 feet of surface laid gas gathering pipeline. The pipeline would require a right-of-way for the portion of the pipeline that goes off lease. The proposed project area is located approximately 26 miles southeast of Myton, Utah. Table 2-1 lists the well pad by name and the wells that will be drilled from them. Table 2-2 lists the well pads and their associated surface disturbances. If a well is a dry well, then it would be plugged and abandoned as per BLM and State of Utah requirements.

Table 2-1 Well Pad and Well Names Existing Well Pad Proposed Wells Number Federal 31-29 Federal 212-29-9-19, Federal 221-29-9-19, Federal 321-29-9-19, Federal 413-29-19, Federal 213-29-9-19, Federal 412-29-9-19, Federal 414-29-9- 19 Federal 42-29-9-19 Federal 322-29-9-19, Federal 323-29-9-19, Federal 421-29-9-19, Federal 431-29-9-19, Federal 432-29-9-19 Federal 43-30-9-19 Federal 333-30-9-19, Federal 423-30-9-19, Federal 332-30-9-19, Federal 442-30-9-19

Table 2-2 Surface Disturbance Existing Existing New Re-disturbance Surface Total Well # Well Pad Disturbance (Re-open old pit Pipeline2 Disturbance Disturbance Pad Expansion area or other disturbed areas) Federal 0.0 acre 31-29-9- 1.2 acres 0.1 acres 0.8 acres 2.0 acres 19 467 feet Federal 0.0 acre 42-29-9- 1.5 acres 0.3 acres 1.0 acres 2.8 acres 19 9,035 feet Federal 0.0 acre 43-30-9- 1.6 acres 0.1 acres 0.9 acres 2.6 acres 19 17,085 feet 130-foot construction width, 18 foot running surface 230-foot construction width

2.1.1.1 ROADS

Existing roads would be used to access the well pads. No new surface disturbance would result from building new roads.

All vehicular traffic, personnel movement, construction/restoration operations would be confined to existing roadways and/or access routes. Existing roads consist of county roads. In accordance with Onshore Order # 1 (OSO 1) and Best Management Practices (BMPs), Badlands would maintain existing roads in a safe and useable condition. Maintenance for existing roads would continue until final abandonment and reclamation of the well pad. Road maintenance would include but is not limited to, blading, ditching, and/or culvert installation and cleanout. To ensure safe operating conditions, gravel surfacing would be performed where excessive rutting or erosion may occur. Dust control would be performed as necessary to ensure safe operating conditions.

Badlands would employ construction BMPs and the Conditions of Approval (COAs) in the APD to control onsite and offsite erosion, and keep disturbed areas along access roads free of trash during operations.

2.1.1.2 PIPELINES

Approximately 26,587 feet of 12-inch diameter or smaller steel surface laid gas gathering pipeline is proposed for construction within a 30-foot right of way adjacent to the existing roads and existing pipeline. Above-ground installation would not require clearing of vegetation or blading of the surface. The roads and /or well pads would be utilized for construction activities and staging of the pipeline. The 30 feet ROW would be utilized for maintenance and repairs.

Badlands proposes to install temporary 12” or smaller water transfer lines on the surface between either existing or refurbished reserve pits. The temporary transfer lines would be utilized to transport frac fluid being injected and/or recovered during the completion process and would be laid adjacent to existing access roads. Upon completion of the frac operation, the liquids transfer 6

lines will be flushed with fresh water and purged with compress air. The contents of the transfer lines will be flushed into a water truck for delivery to another reserve pit or disposal pond.

2.1.1.3 WATER USED

Badlands is anticipating using as much recycled produce water as possible for drilling and completions of the wells. Approximately 5 acre-feet of water would be needed to drill and complete each well, with possibly 1 acre-foot of fresh water per well need to supplement the recycled produced water. Up to 16 acre-feet of fresh water would be needed for this project.

Fresh water for drilling and completion operations would be obtained from the following source:

Permit # 41-3530 Duchesne County Water Conservancy District: Public Water Supplier.

Water would be hauled to the location over the existing roads. No water wells would be drilled on leases UTU-037246, UTU-76034 and UTU-76262.

Produced Fluids Disposal

Badlands would use a reserve pit to contain the de-watered drill cuttings and completion fluids. The reserve pit would be constructed to minimize the accumulation of surface precipitation runoff into the pit via appropriate placement of subsoil storage areas and/or construction of berms and/or ditches, etc. The reserve pit would be lined with an impermeable liner. The liner would be a synthetic material 16 mil or thicker. The bottom and side wall of the pit would be void of any sharp rocks that could puncture the liner. The liner would be installed over smooth fill subgrade that is free of pockets, loose rocks, or other materials (i.e. sand, sifted dirt, bentonite, straw, etc.) that could damage the liner.

After evaporation and when dry, the reserve pit liners would be cut off, ripped and/or folded back (as safety considerations allow) as near to the mud surface as possible and hauled to a landfill or buried on location prior to backfilling the pit with a minimum of four feet of soil material. Any fluids remaining 90 days after date of completion and /or determination of inactivity would be removed (as weather conditions allow) to an approved site and the pit reclaimed.

For the protection of livestock and wildlife, all open pits (excluding flare pits) would be fenced to prevent wildlife or livestock entry. Total height of pit fencing would be at least 42 inches and corner posts would be cemented and/or braced in such a manner as to keep the fence tight at all times. Standard steel, wood, or pipe post shall be used between the corner braces. Maximum distance between any 2 fence posts shall be no greater than 16 feet. Siphons, catchments, and absorbent pads would be installed to keep hydrocarbons produced by the drilling rig or other equipment on location from entering the reserve pit. Hydrocarbon contaminated pads, and/or soils would be disposed of in accordance with state and federal requirements.

Where necessary and if conditions (freeboard, etc.) allow, produced liquids from newly completed wells may be temporarily disposed of into pits for a period not to exceed 90 days as per Onshore Order Number 7 (OSO 7). Subsequently, permanent produced water disposal methods would be employed in accordance with OSO 7. Badlands proposes to store produced water in a 300 barrel tank, and periodically haul the water to a State of Utah approved commercial disposal site.

2.1.1.4 RECLAMATION

Well pad expansion would start with vegetation clearing and topsoil stripping to a depth determined by the BLM. Badlands would save 4 to 8 inches of topsoil for subsequent reclamation. Badlands would stockpile excess soil and brush removed from the well pad in an area adjacent to the well pads, which would be saved for future reclamation of the well pad. Construction materials for the well pads would include native sand/soil/rock materials present in the area. Badlands would use standard cut-and-fill techniques using a bulldozer, grader, front-end loader, scraper, track hoe, or backhoe to level the well pads. Badlands would divert drainages that cross the well location around the well pad by using ditches, water diversion drains or berms.

Badlands will follow the procedure that is laid out in the Reclamation and Weed Plan for Badlands (formerly GASCO) Production Company that is on file with the Vernal Field Office BLM.

This seed mix shall be used for well site, access road, and pipeline (as applicable).

Squirreltail 4.00 lbs/acre Siberian Wheatgrass 2.00 lbs/acre Bluebunch Wheatgrass 3.00 lbs/acre Shadscale Saltbush 0.50 lbs/acre Fourwing Saltbush 0.50 lbs/acre Gardner’s Saltbush 0.50 lbs/acre Scarlet Globemallow 0.10 lbs/acre Total 10.60 lbs/acre

2.1.2 ALTERNATIVE B – NO ACTION

Under the No Action Alternative, Badlands would not be allowed to drill the proposed wells. To provide a baseline for comparison of the impacts between the Proposed Action and No Action Alternatives, this alternative assumes that the four wells were not drilled.

However, if this alternative is selected in the final Decision, the four wells would be plugged and reclaimed according to previously described protocol. The three existing host wells and pads would continue to exist and produce.

3.0 AFFECTED ENVIRONMENT

This chapter presents the potentially affected existing environment (i.e., the physical, biological, social, and economic values and resources) of the impact area as identified in the Interdisciplinary Team Checklist found in Appendix A and presented in Chapter 1 of this assessment. This chapter provides the baseline for comparison of impacts/consequences described in Chapter 4.

3.1 RESOURCES/ISSUES BROUGHT FORWARD FOR ANALYSIS

3.1.1 AIR QUALITY AND GREENHOUSE GAS EMISSIONS

3.1.1.1 AMBIENT AIR QUALITY The Project Area is located in the Uinta Basin, a semiarid, mid-continental climate regime typified by dry, windy conditions, limited precipitation and wide seasonal temperature variations subject to abundant sunshine and rapid nighttime cooling. The Uinta Basin is designated as unclassified by the EPA under the Clean Air Act. This classification indicates that the an attainment designation has not yet been made. However, in October 2016, the Governor of Utah recommended that the Basin be classified as non-attainment of the 8-hour ozone standard. The 2015 design value for the Uintah County is 79 ppb. A design value is a statistic developed from actual monitored data that describes the air quality status of a location relative the level of the NAAQS. Design values are typically used to designate and classify nonattainment areas, as well as to assess progress towards meeting the NAAQS. The EPA is reviewing their recommendation and formal designations are anticipated in October 2017.

NAAQS are standards that have been set for the purpose of protecting human health and welfare with an adequate margin of safety. Pollutants for which standards have been set include ground level ozone, (O3), sulfur dioxide (SO2), nitrogen dioxide (NO2), and carbon monoxide (CO), and particulate matter less than 10 microns in diameter (PM10) or 2.5 microns in diameter (PM2.5). Airborne particulate matter consists of tiny coarse-mode (PM10) or fine-mode (PM2.5) particles or aerosols combined with dust, dirt, smoke, and liquid droplets. PM2.5 is derived primarily from the incomplete combustion of fuel sources and secondarily formed aerosols, whereas PM10 is primarily from crushing, grinding, or abrasion of surfaces. Table 3-1 lists ambient air quality background values for the Uinta Basin and NAAQS standards.

Table 3-1: Utah and National Ambient Air Quality Standards Pollutant Averaging Utah National National Form of the National Time Standards Primary Secondary Standards Concentration Standards Standards Ozone 8-Hour 0.070 0.070 0.070 Annual fourth-highest (O3) (ppm) daily maximum 8-hour concentration, averaged over 3 years. Carbon 1-Hour 35 35 - Not to be exceeded more Monoxide (ppm) than once per year. (CO) 9

Table 3-1: Utah and National Ambient Air Quality Standards Pollutant Averaging Utah National National Form of the National Time Standards Primary Secondary Standards Concentration Standards Standards Carbon 8-Hour 9 9 - Not to be exceeded more Monoxide (ppm) than once per year. (CO) Sulfur 1-Hour 75 75 - 99th percentile of 1-hour Dioxide (ppm) daily maximum (SO2) concentrations averaged over 3 years. Sulfur 3-Hour 0.51 - 0.5 Not to be exceeded more Dioxide (ppm) than once per year. (SO2) Nitrogen 1-Hour 100 100 - 98th percentile of 1-hour Dioxide (ppb) daily maximum (NO2) concentrations, averaged over 3 years Nitrogen Annual 53 53 53 Annual mean Dioxide Average (NO2) (ppb) 2 PM10 24-Hour 150 150 150 Not to be exceeded more (µg/m3) than once per year on average over 3 years. 2 th PM2.5 24-Hour 35 35 35 98 percentile, averaged (µg/m3) over 3 years 2 PM2.5 Annual 15 12 15 Annual mean, averaged Average over 3 years (µg/m3) Lead Rolling 3 0.15 0.15 0.15 Not to be exceeded Month Average (µg/m3) 1 Secondary standard. 2 PM10 indicates particulate matter smaller than 10 microns in aerodynamic diameter, PM2.5 is particulate matter smaller than 2.5 microns in aerodynamic diameter. Source: (EPA, 2016)

Existing point and area sources of air pollution within the Uinta Basin include the following:

• Exhaust emissions (primarily CO, NOx, PM2.5, and HAPs) from existing natural gas fired compressor engines used in transportation of natural gas in pipelines; • Natural gas dehydrator still-vent emissions of CO, NOx, PM2.5, and HAPs; • Gasoline and diesel-fueled vehicle tailpipe emissions of VOCs, NOx, CO, SO2, PM10, and PM2.5; • Oxides of sulfur (SOx), NOx, fugitive dust emissions from coal-fired power plants, and coal mining/ processing;

• Fugitive dust (in the form of PM10 and PM2.5) from vehicle traffic on unpaved roads, wind erosion in areas of soil disturbance, and road sanding during winter months; and, • Long-range transport of pollutants from distant sources.

Two year-round air quality monitoring sites were established in summer 2009 near Red Wash (southeast of Vernal, Utah) and Ouray (southwest of Vernal). These monitors were certified as Federal Reference Monitors in fall of 2011, which means they can be used to make a NAAQS compliance determination. The complete EPA Ouray and Redwash monitoring data can be found at: http://www.epa.gov/airexplorer/index.htm

Monitoring sites have recorded numerous exceedences of the 8-hour ozone standard during the winter months (January through March since, except 2012 and 2015) (Bingham Research Center Utah State University, 2016) (Figure 7-8, Table 7-3 and Section 6.1). High concentrations of ozone are being formed under a “cold pool” process that occurs when stagnate air conditions form with very low mixing heights under clear skies, with snow-covered ground, and abundant sunlight. These conditions, combined with area precursor emissions (NOx and VOCs), can create intense episodes of ozone. The high numbers did not occur in January through March 2012 and 2015 due to a lack of snow cover. This phenomenon has also been observed in similar locations in Wyoming. Winter ozone formation is a newly recognized issue, and the methods of analyzing and managing this problem are still being developed.

Further research is ongoing to identify ozone precursor sources that contribute to observed ozone concentrations, and the chemical interactions that occur. Some studies that have contributed to this knowledge include the Uinta Basin Ozone Studies (UBOS) series (Utah Department of Environmental Quality, 2017a). The 2011 UBOS identified that ozone episodes occur Basin wide, that the highest values are found in the Central Basin), and that ozone concentration decreases with elevation increases. The 2012 UBOS found that: snow cover and inversions are necessary for winter ozone episodes, oil and gas operations are responsible for 89-99 percent of VOC and 57-61 percent of NOx emissions, VOC controls may reduce ozone but their effectiveness is unknown, and voluntary “ozone action day” measures may reduce ozone peaks. The 2013 UBOS found that reflection of sunlight from the snow significantly increases the rate of ozone formation, NOx reduction may not reduce and may increase ozone formation, nitrous acid (HONO) and formaldehyde contribute to the creation of chemically reactive radicals that drive ozone formation, reducing formaldehyde may reduce ozone, and it is unknown if HONO reductions will reduce ozone. The 2014 UBOS found that HONO is not a major winter ozone episode radical source, ozone formation at the Horse Pool study site is sensitive to VOC reductions and may be sensitive to NOx reductions, formaldehyde and other aldehydes are the dominant radical sources in the Basin, and aromatic VOCs including toluene and xylene are important sources of radicals. The 2016 UBOS (Bingham Research Center Utah State University, 2016) (Section 7.3.1) showed that ozone exceedances occurred when snow depth, inversion length, and total UV radiation were all maximized in proximity to oil and gas activity, and decrease with elevation (the inversions lessen with elevation and are more likely to be broken up by passing storms). The highest ozone concentrations center around Ouray, Seven Sisters, and Horsepool, as has been observed in previous years. Seven Sisters and Horsepool have the highest density of oil and gas wells of any part of the Uinta Basin, and Ouray is nearby and is the site with the lowest elevation. The 2016 UBOS further predicts, based on statistical regression analysis, that 38% of Uinta Basin winters are

expected to have no exceedances of the NAAQS, and 46% are expected to be in attainment with three or fewer exceedances (Bingham Research Center Utah State University, 2016).

Similarly, the Utah Division of Environmental Quality and others have developed emission inventories to characterize and quantify the air pollutants in the Basin, as well as provide data for computer modeling (Utah Division of Environmental Quality, 2017b). Some of these inventories include the 2011 Uinta Basin Oil and Gas Emissions Estimates Technical Document, the WRAP Phase III Emissions Inventory, and the 2013 Uinta Basin Non-Road Mobile Inventory. The 2011 Uinta Basin Oil and Gas Emissions Estimates Technical Document updates a 2006 five-county estimate of oil and gas emissions to reflect actual production increases in the Basin. The WRAP Phase III inventory includes all criteria pollutant emissions for all point and area sources for oil and gas basins throughout the six state study region for the base year 2007, with projections to 2012. The 2013 Uinta Basin Non-Road Mobile Inventory identifies emissions from vehicle miles-traveled for light- and heavy-duty trucks, and non-road diesel equipment, which comprises 10 percent of the total oil and gas emission inventory in the Basin.

Collection and analysis of PM2.5 was targeted in the 2011 Uinta Basin Ozone Study (Energy Dynamics Laboratory Utah State University Research Foundation, 2011). PM2.5 concentrations during the study period were well below the NAAQS. Chemical speciation of the PM2.5 samples taken during the study found that 80% of the PM2.5 collected was particle-bound carbon, suggesting strong local or regional contributions of the oil and gas industry to the atmospheric hydrocarbon in the Uinta Basin airshed (Section 4.6). The 2016 Uinta Basin Ozone Study (Bingham Research Center Utah State University, 2016) (Section 7.3.2) reported that periods with higher ozone also tend to have higher PM2.5, and that PM2.5 values in Vernal and Roosevelt have exceeded EPA standards more than other sites (including Ouray which has the highest ozone values). Uinta Basin th monitoring has recorded two years wherein the 98 percentile of annual PM2.5 data exceeded the EPA standard (Myton in 2011 and Roosevelt in 2013 – see Table 7-5). Unlike ozone, PM2.5 in the Uinta Basin appears to be dependent on proximity to urban and oil and gas sources (not oil and gas sources alone), since the highest PM2.5 has been observed in or near urban areas. The highest 2- year average of annual 98th percentile data was 31.5 µg/m3 in Vernal for years 2012 through 2014 (Section 7.3.2).

Table 3-2 provides representative ambient background data for the region encompassing the Uinta Basin, where available, based on 2015 Design Values unless otherwise specified (https://www.epa.gov/air-trends/air-quality-design-values).

Table 3-2: Ambient Air Quality Background Values Averaging Monitor AQS Pollutant Background Concentration Period(s) Site ID Vernal SO2 1-hour 5 ppb 490475632

Annual 3 ppb Vernal NO2 1-hour 54 ppb 1 490472003

PM10 24-hour -- --

Table 3-2: Ambient Air Quality Background Values Averaging Monitor AQS Pollutant Background Concentration Period(s) Site ID

Annual 5.7 ug/m3 2 Vernal PM2.5 24-hour 22 ug/m3 3 490471004

8-hour 1.7 ppm Salt Lake City CO 1-hour 3.3 ppm 490353006

Vernal O3 8-hour .079 ppm 490472003 1 2014 Design Value 2 Invalid design value due to monitor data completeness or quality. 3 2014-2016 design value for the Vernal monitor.

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 impacts. The EPA has classified 187 air pollutants as HAPs. Examples of listed HAPs associated with the oil and gas industry include formaldehyde, benzene, toluene, ethylbenzene, isomers of xylene (BTEX) compounds, and normal-hexane (n-hexane). EPA established National Emission Standards for Hazardous Air Pollutants (NESHAP) for certain categories of stationary sources.

3.1.1.2 GREENHOUSE GASES AND CLIMATE CHANGE “Climate change” refers to any significant change in the measures of climate lasting for an extended period of time. In other words, climate change includes major changes in temperature, precipitation, or wind patterns, among other effects, that occur over several decades or longer. “Global warming” refers to the recent and ongoing rise in global average temperature near Earth's surface. It is caused mostly by increasing concentrations of greenhouse gases in the atmosphere. Global warming is causing climate patterns to change. However, global warming itself represents only one aspect of climate change. Climate is both a driving force and limiting factor for ecological, biological, and hydrological processes, and has great potential to influence resource management.

Climate change science continues to expand and refine our understanding of the impacts of anthropogenic GHG emissions. CEQ’s first Annual Report in 1970 referenced climate change, indicating that “[m]an may be changing his weather.” It is now well established that rising global atmospheric GHG emission concentrations are significantly affecting the Earth’s climate. These conclusions are built upon a scientific record that has been created with substantial contributions from the United States Global Change Research Program (USGCRP)1. Studies have projected the effects of increasing GHGs on many resources normally discussed in the NEPA process, including

1 See Global Change Research Act of 1990, Pub. L. 101–606, Sec. 103 (November 16, 1990). For additional information on the USCGCRP, visit http://www.globalchange.gov.

water availability, ocean acidity, sea-level rise, ecosystem functions, energy production, agriculture and food security, air quality and human health.

Based primarily on the scientific assessments of the USGCRP, the National Research Council, and the Intergovernmental Panel on Climate Change (IPCC), in 2009 the Environmental Protection Agency (EPA) issued a finding that the changes in our climate caused by elevated concentrations of greenhouse gases in the atmosphere are reasonably anticipated to endanger the public health and public welfare of current and future generations. Broadly stated, the effects of climate change observed to date and projected to occur in the future include more frequent and intense heat waves, longer fire seasons and more severe wildfires, degraded air quality, more heavy downpours and flooding, increased drought, greater sea-level rise, more intense storms, harm to water resources, harm to agriculture, ocean acidification, and harm to wildlife and ecosystems. This EA includes a qualitative and quantitative analysis of possible greenhouse gas emissions that could occur as a result of reasonably foreseeable oil and gas development.

It is accepted within the scientific community that global temperatures have risen at an increased rate and the likely cause is gases that trap heat in the atmosphere, referred to as greenhouse gases (GHG). GHGs are composed mostly of carbon dioxide (CO2), nitrous oxide (N2O), methane (CH4), water vapor, and ozone. The greenhouse gas effect is the process in which the radiation from the sun that heats the surface of Earth gets blocked by GHG molecules in Earth’s atmosphere. Since GHGs are composed of molecules that absorb and emit infrared electromagnetic radiation (heat), they form an intrinsic part of the greenhouse effect.

Greenhouse gases are often presented using the unit of Metric Tons of CO2 equivalent (MT CO2e) or Million Metric Tons (MMT CO2e), a metric to express the impact of each different greenhouse gas in terms of the amount of CO2 making it possible to express greenhouse gases as a single number. For example, 1 ton of methane would be equal to 25 tons of CO2 equivalent, because it has a global warming potential (GWP) 25 times that of CO2 (EPA, 2017d).

As defined by EPA, the GWP provides “ratio of the time-integrated radiative forcing from the instantaneous release of one kilogram of a trace substance relative to that of one kilogram of CO2.” The GWP of greenhouse gas is used to compare global impacts of different gases and used specifically to measure how much energy the emissions of one ton of gas will absorb over a given period of time (e.g. 100 years), relative to the emissions of one ton of CO2. The GWP accounts for the intensity of each GHG’s heat trapping effect and its longevity in the atmosphere. The GWP provides a method to quantify the cumulative effects of multiple GHGs released into the atmosphere by calculating carbon dioxide equivalent for the GHGs.

• Carbon dioxide (CO2), by definition, has a GWP of 1 regardless of the time period used because it is the gas being used as the reference. CO2 remains in the climate system for a very long time due to the natural carbon cycle which continuously releases and absorbs carbon and carbon dioxide. Anthropogenic sources of CO2 emissions have substantially increased since the Industrial Revolution causing increases in the atmospheric concentrations of CO2 that will last thousands of years (EPA, 2017d). • Methane (CH4) is estimated to have a GWP of 28-36 times that of CO2 over 100 years. CH4 emitted today lasts about a decade on average, which is much less time than CO2, but CH4 also absorbs much more energy than CO2. The net effect of the shorter lifetime and higher energy absorption is reflected in the GWP. The methane GWP also accounts for some 14

indirect effects, such as the fact that methane is a precursor to ozone, and ozone is in itself a greenhouse gas (EPA, 2017c). • Nitrous Oxide (N2O) has a GWP of 265-298 times that of CO2 for a 100-year timescale. N2O emitted today remains in the atmosphere for more than 100 years, on average (EPA, 2017d). Table 3-4 contains GHGs regulated by USEPA and global warming potentials.

Table 3-4: GHG Regulated by USEPA and Global Warming Potentials

Air Pollutant Chemical Symbol/ Global Warming Potential Acronym

Carbon Dioxide CO2 1

Methane CH4 28-36

Nitrous Oxide N2O 298

Hydrofluorocarbons HFCs Varies

Perfluorocarbons PFCs Varies

Sulfur hexafluoride SF6 22,800

Source: (EPA, 2017d)

The IPCC concluded that “warming of the climate system is unequivocal” and “most of the observed increase in global average temperatures since the mid-20th century is very likely due to the observed increase in anthropogenic GHG concentrations” (IPCC, 2007). Extensive research and development efforts are underway in the field of carbon capture and sequestration (CCS) technology, which could help direct management strategies in the future. The IPCC has identified a target worldwide “carbon budget” to estimate the amount of CO2 the world can emit while still having a likely chance of limiting global temperature rise to 2°C above pre-industrial levels. The international community estimates this budget to be 1 trillion tonnes of carbon (WRI, n.d.).

Because GHGs circulate freely throughout Earth’s atmosphere, climate change is a global issue. The largest component of global anthropogenic GHG emissions is CO2. Global anthropogenic carbon emissions reached about 7,000,000,000 MT per year in 2000 and an estimated 9,170,000,000 MT per year in 2010 (Boden, Marland, & Andres, 2013). Oil and gas production contributes to GHGs such as CO2 and methane. Natural gas systems were the largest anthropogenic source category of CH4 emissions in the United States in 2014 with 176.1 MMT CO2e of CH4 emitted into the atmosphere. Those emissions have decreased by 30.6 MMT CO2e (14.8 percent) since 1990 (EPA, 2017c).

Global mean surface temperatures have increased nearly 1.0°C (1.8°F) from 1890 to 2006 [ (Herring, 2007)]. The IPCC indicated that by the year 2100, global average surface temperatures would increase 1.4 to 5.8°C (2.5 to 10.4°F) above 1990 levels (IPCC, 2007). The National Academy of Sciences (Hansen, et al., 2006) has confirmed these findings, but also indicated that there are 15

uncertainties regarding how climate change may affect different regions. Observations and predictive models indicate that average temperature changes are likely to be greater in the Northern Hemisphere. Data indicate that northern latitudes (above 24° N) have exhibited temperature increases of nearly 1.2°C (2.1°F) since 1900, with nearly a 1.0°C (1.8°F) increase since 1970 alone. It also shows temperature and precipitation trends for the conterminous United States. For both parameters we see varying rates of change, but overall increases in both temperature and precipitation.

In recent years, many states, tribes, and other organizations have initiated GHG inventories, tallying GHG emissions by economic sector. The U.S. EPA provides links to statewide GHG emissions inventories (EPA, 2017b). Guidelines for estimating project-specific GHG emissions are available (URSC, 2010), but some additional data, including the projected volume of oil or natural gas produced for an average well or number of wells (as well as other factors described in Chapter 4 Air Quality) were used to provide GHG estimates.

3.1.2 INVASIVE PLANTS/NOXIOUS WEEDS, SOILS, AND VEGETATION

3.1.2.1 VEGETATION The proposed project and surrounding areas are underlain by the Uinta Formation. Soils in proximity to the proposed project are Motto-Muff-Rock outcrop complex, 2 to 25 percent slopes (Natural Resources Conservation Service, 2003). The ecological site descriptions are desert shallow clay (mat saltbush), desert alkali bench (Castlevalley saltbush), desert shallow loam (shadscale), alkali flat (greasewood), and desert shallow loam (shadscale). The primary ecological systems in the project area are inter-mountain basins mixed salt desert scrub and inter-mountain basins greasewood flat (USGS-DOI 2017). For a list of common plant species that occur within or near the proposed project see the Table below. The area surrounding the proposed project has been impacted historically by roads and livestock grazing. Table 3.5 identifies common plant species observed during the special status plant survey for the project (Brunson, 2017).

Table 3.5. Plant Species Identified in Project Area. COMMON/DOMINANT SPECIES IN SURVEY Common Name AREA Scientific Name Shrubs Atriplex confertifolia shadscale Atriplex corrugata mat saltbush Atriplex gardneri Gardner's mat saltbush Bassia americana greenmolly Ephedra torreyana Torrey ephedra Ericameria nauseosa rubber rabbitbrush Gutierrezia sarothrae broom snakeweed Leptodactylon pungens pricklyphlox Picrothamnus desertorum budsage Sarcobatus vermiculatus greasewood Tetradymia nuttallii Nuttall's horsebrush Tetradymia spinescens spiny horsebrush

Table 3.5. Plant Species Identified in Project Area. COMMON/DOMINANT SPECIES IN SURVEY Common Name AREA Scientific Name Grasses/Graminoids Achnatherum hymenoides indian ricegrass Elymus elymoides squirreltail Hesperostipa comata needle-and-thread Hilaria jamesii curlygrass, galleta grass Forbs Allium textile textile onion Astraglus flavus yellow milkvetch Camissonia scapoidea barestem camissonia Chaenactis steveioides annual dustymaiden Cymopterus bulbosus bulbous desertparsley Enceliopsis nutans noddinghead Eriogonum inflatum desert trumpet Lepidium montanum mountain pepperplant Lupinus pusillus sand lupine Malocothrix torreyi Torrey desert dandelion Oenothera caespitosa desert evening-primrose Oenothera pallida pale evening-primrose Platyschkuria integrifolia basindaisy Sclerocactus wetlandicus Uinta Basin hookless cactus Sphaeralcea coccinea scarlet globemallow Sphaeralcea parvifolia Smallleaf globemallow Townsendia incana Townsend’s daisy

The most common vegetation community types identified within the Project Area are described below.

3.1.2.1.1 INTER-MOUNTAIN BASINS BIG SAGEBRUSH SHRUBLAND

This ecological system occurs throughout much of the western U.S., typically in broad basins between mountain ranges, plains and foothills between 1500 and 2300 m (~4900 – 7500 ft) elevation. Soils are typically deep, well‐drained and non‐saline. These shrublands are dominated by Artemisia tridentata ssp. tridentata (basin big sagebrush) and/or Artemisia tridentata ssp. wyomingensis (Wyoming big sagebrush). Scattered Juniperus spp. (juniper), Sarcobatus vermiculatus (greasewood), and Atriplex spp. (saltbush) may be present in some stands. Ericameria nauseosa (rubber rabbitbrush), Chrysothamnus viscidiflorus (sticky rabbitbrush), Purshia tridentata (antelope bitterbrush), or Symphoricarpos oreophilus (mountain snowberry) may codominate disturbed stands (e.g., in burned stands, these may become more predominant). Perennial herbaceous components typically contribute less than 25% vegetative cover. Common graminoid species can include Achnatherum hymenoides (Indian ricegrass), Bouteloua gracilis (blue grama), Elymus lanceolatus (thickspike wheatgrass), Hesperostipa comata (needleandthread), Leymus cinereus (basin wildrye), Hilaria jamesii (James galleta), Pascopyrum smithii (western wheatgrass), Poa secunda (Sandberg bluegrass), or Pseudoroegneria spicata (bluebunch wheatgrass). Some semi‐

natural communities are included that often originate on abandoned agricultural land or on other disturbed sites. In these locations, Bromus tectorum (cheatgrass) or other invasive weeds can be abundant.

3.1.2.1.2 INTER-MOUNTAIN BASINS MIXED SALT DESERT SCRUB

This widespread shrub-steppe system is dominated by perennial grasses and forbs, and it occurs throughout much of the northern Great Basin and Wyoming. Soils are typically deep and nonsaline, often with a microphytic crust. Shrubs may increase following heavy grazing and/or fire suppression activities. The vegetation is characterized by a typically open to moderately dense shrubland that are comprised of one or more saltbush species such as shadscale saltbush (Atriplex confertifolia) or Gardner saltbush (Atriplex gardneri). Other shrubs that may be present to co- dominant including Wyoming big sagebrush (Artemisia tridentata ssp. wyomingensis), yellow rabbitbrush (Chrysothamnus viscidiflorus), rubber rabbitbrush (Ericameria nauseosa), Torrey Mormon tea (Ephedra torreyana), spiny hopsage (Grayia spinosa), winterfat (Krascheninnikovia lanata), bud sagebrush (Picrothamnus desertorum), or shortspine horsebrush (Tetradymia spinosa). Other co-dominant and characteristic plant species observed in this vegetation type during clearance surveys include thickspike wheatgrass (Elymus lanceolatus), broom snakeweed (Gutierrezia sarothrae), plains pricklypear (Opuntia polyacantha), Hood phlox (Phlox hoodii), longleaf phlox (Phlox longifolia), scarlet globemallow (Sphaeralcea coccinea), small-leaf globemallow (Sphaeralcea parvifolia), and James’ galleta (Pleuraphis jamesii). These shrublands and steppe habitats are the most prevalent native vegetation community in the Project Area.

3.1.2.1.3 INTER-MOUNTAIN BASINS GREASEWOOD FLAT

This vegetation cover type occurs throughout much of the western U.S. in intermountain basins and extends onto the western Great Plains. It typically occurs near drainages on stream terraces and flats or may form rings around more sparsely vegetated playas. Sites typically have saline soils and a shallow water table. They may flood intermittently but remain dry for most growing seasons. This vegetation cover type usually occurs as a mosaic of multiple communities, with open to moderately dense shrublands dominated or codominated by greasewood (Sarcobatus vermiculatus), fourwing saltbush (Atriplex canescens), or shadscale saltbush (Atriplex confertifolia). Occurrences are often surrounded by mixed salt desert scrub.

3.1.2.1.4 INTERMOUNTAIN BASINS SEMI-DESERT SHRUB STEPPE

This vegetation cover type includes open-canopied shrublands of typically saline basins, alluvial slopes, and plains across the intermountain western U.S. Substrates are often saline and calcareous, medium- to fine-textured, alkaline soils, but they can include some coarser-textured soils. The vegetation is characterized by a typically open to moderately dense shrubland composed of one or more saltbush species, with a sparse to moderately dense herbaceous layer dominated by perennial grasses.

Characteristic grasses include Indian ricegrass (Achnatherum hymenoides), blue grama (Bouteloua gracilis), saltgrass (Distichlis spicata), needle-and-thread grass (Hesperostipa comata), James’ galleta (Pleuraphis jamesii), Sandberg bluegrass (Poa secunda), and alkali sacaton (Sporobolus airoides).

Characteristic shrub species include fourwing saltbush (Atriplex canescens), Greene’s rabbitbrush (Chrysothamnus greenei), yellow rabbitbrush (Chrysothamnus viscidiflorus), rubber rabbitbrush (Ericameria nauseosa), broom snakeweed (Gutierrezia sarothrae), and winterfat (Krascheninnikovia lanata). Scattered big sagebrush subspecies (Artemisia tridentata) may be present but do not dominate.

3.1.2.2 INVASIVE PLANTS / NOXIOUS WEEDS

According to data collected for the National Invasive Species Information Management System [NISIMS] a BLM database that reports and tracks infestations of invasive species) the State of Utah designated Class B noxious weed perennial pepperweed (Lepidium latifolium), and the Class C noxious weed saltcedar (Tamarix ramosissima) have been identified in and near the Project Area. In addition, NISIMS data identifies an infestation of the invasive plant species Russian olive (Eleagnus angustifolia) near the Project Area. Table 3.6 identifies common invasive plants and noxious weeds observed during the project’s special status plant survey (Brunson, 2017).

Table 3.6. Invasive or Noxious Plant Species Identified in Project Area. Introduced Species/Invasive plants/Noxious Weeds Alyssum desertorum desert alyssum Bromus tectorum cheatgrass Halogeton glomeratus halogeton Lappula occidentalis western stickseed Tamarix ramosissimum tamarisk

3.1.2.3 SOILS Geologic formations in the Uinta Basin include Tertiary and Cretaceous age sediments, which consist mainly of lacustrine deposits containing clay, silt, and lime. Elevations in the Project Area range from approximately 5,100 feet to 5,318 feet. Soils in the area consist predominantly of clay, clay loam, and sandy loam. The proposed wells, pipelines, and associated infrastructure would be located primarily on rolling hills (Bureau of Land Management Vernal Field Office, 2016). Cryptobiotic soils or, biological soil crusts were observed during onsite visits at the proposed well locations. These soils typically consist of soil cyanobacteria, lichens, and mosses, which are well developed and increase the stability of otherwise easily eroded soils (Belknap, 2016). Biological soil crusts are generally found where there are openings in the vascular plant cover and protect open areas from wind and water erosion (Bureau of Land Management Vernal Field Office, 2008d).

3.1.3 PALEONTOLOGY

The proposed well pad expansions and pipeline were surveyed for paleontology resources. Outcrops and erosional surfaces were checked within the proposed construction areas to determine if fossils were present and to assess needs when found. The probability for impacting scientifically important paleontological resources during construction was determined to be high in this area. The route of the proposed pipeline and the well pad expansion areas showed signs of scientifically important fossils at multiple locations.

3.1.4 PLANTS: THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

3.1.4.1 UINTA BASIN HOOKLESS CACTUS (SCLEROCACTUS WETLANDICUS) Uinta Basin hookless cactus is a perennial herb and a member of the cactus family. It is federally listed as threatened and is endemic to the Uinta Basin. It consists of a perennial succulent shoot, solitary or rarely branching, globose, ovoid or cylindrical. Individuals are usually 3 to 9 centimeters in diameter and 4 to 12 centimeters tall. Each spine cluster, areoles, usually consists of one large (15 to 29 millimeters) central spine, three to four lateral central spines, and six to ten radial spines. From late April to May, Uinta Basin hookless cactus produces 2.5 to 5-centimeter high, pink to violet flowers.

The ecological amplitude of Uinta Basin hookless cactus is wide, being found from clay badlands up to the pinion-juniper habitat. The preferred habitat occurs on river benches, valley slopes, and rolling hills consisting of xeric, fine textured, clay soils, derived from the Duchesne River, Green River, Mancos, and Uinta formations, overlain with a pavement of large, smooth, rounded cobble. The typical plant community in Uinta Basin hookless cactus habitat is the salt desert shrub community.

The proposed project is located entirely within an area that the U.S. Fish and Wildlife Service (USFWS 1994) identified as being potential habitat Uinta Basin hookless cactus. During August through October 2012, SWCA Environmental Consultants surveyed the proposed project to a distance of 300 feet from the edge of the proposed surface disturbance of two of the three well pad expansions: the 42-29-9-19 and the 31-29-9-19. Surveys were also done within 300 feet of the ROW of an existing surface pipeline connecting these wells to existing infrastructure. This pipeline will be upgraded to a larger surface pipeline placed within the same ROW. During these surveys, 78 plants were identified within 300 feet of the existing well pads, well pad expansion areas, and pipeline ROW. The closest plant to proposed construction or disturbance is within 47 feet of the pipeline. In 2011, Sclerocactus surveys were conducted within 400 feet of the proposed expansion of the 43-30-9-19 wellpad. No individuals were found.

Additionally, on May 10, 2017, BLM botanists conducted clearance, spot check, and meander surveys as per standard protocols and as per the EA and consultation requirements (see BLM and USFWS 2012). For wellpad 31-29, 100% clearance surveys were conducted in 2014 by a third party, so the BLM conducted spot check surveys only. For wellpad 42-29, 100% clearance surveys were conducted in 2012 by a third party, so the BLM conducted another 100 percent clearance survey in the area within 300 feet of the proposed disturbance (mostly north of the existing wellpad). The BLM avoided re-survey in areas of known Sclerocactus points to avoid additional disturbance within habitat (though the BLM did relocate several points). The BLM instead focused the clearance survey efforts on areas immediately adjacent to known points that overlapped with the disturbance buffer. No new individuals were found.

3.1.5 WILDLIFE: MIGRATORY BIRDS (INCLUDING RAPTORS)

All migratory birds and their nests are protected from take or disturbance under the Bald Eagle and Golden Eagle Protection Act (BEGEPA) of 1940 (16 U.S.C., 668-668d, 54 Stat. 250) and the Migratory Bird Treaty Act (MBTA) of 1918 (16 U.S.C., 703 et seq.). These protection laws were implemented for the protection of avian species. Unless permitted by regulations, it is unlawful to 20

pursue, hunt, kill, capture, possess, buy, sell, purchase, or barter any species covered under these Acts. In addition, Executive Order 13186 sets forth the responsibilities of federal agencies to further implement the provisions of these Acts 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 protected avian species.

Within the proposed project areas there are no documented raptor or migratory bird nests. The following addresses additional migratory birds that may utilize the project areas for nesting activities, including those species classified as Priority Species by the Utah Steering Committee and Utah Partners-in-Flight2.

3.1.5.1 PINION-JUNIPER/DESERT SHRUB/SAGEBRUSH American robin, blue-gray gnatcatcher, Brewer’s blackbird, Brewer’s sparrow, cliff swallow, grasshopper sparrow, gray flycatcher, greater sage-grouse, lazuli bunting, mountain bluebird, orange-crowned warbler, rock wren, Say’s phoebe, song sparrow, black-billed magpie, black- capped chickadee, black-throated sparrow, northern flicker, northern mockingbird, vesper sparrow, violet-green swallow, warbling vireo, western kingbird, yellow-breasted chat, yellow warbler (J.R. Parrish, 2002) and mountain plover.

3.1.6 WILDLIFE: NON-USFWS DESIGNATED

3.1.6.1 SPECIAL STATUS FISH This project would remove water from the Green River or White River in order to drill the wells and hydrostatically pressure test the pipelines. There are three special status fish species that are endemic to the Colorado River Basin, including the Green River: roundtail chub (Gila robusta), flannelmouth sucker (Catostomus latipinnis), and bluehead sucker (Catostomus discobolus). The roundtail chub is a state-listed threatened species, while the two suckers are species of special concern due to declining population numbers and distribution.

3.1.7 WILDLIFE: THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

3.1.7.1 COLORADO RIVER FISH SPECIES The USFWS has identified four federally listed fish species historically associated with the Upper Colorado River Basin, including the Green River, as being within the project area: Colorado pikeminnow (Ptychocheilus lucius), humpback chub (Gila cypha), bonytail (Gila elegans), and razorback sucker (Xyrauchen texanus). These fish are federally and state-listed as endangered and have experienced severe population declines due to flow alterations, habitat loss or alteration, and introduction of non-native fish species. The Green River and its 100-year floodplain have been designated Critical Habitat for these four endangered fish species (U.S. Fish and Wildlife Service, 1994).

2 Utah Partners-in-Flight is a cooperative partnership among federal, state, and local government agencies as well as public organizations and individuals organized to emphasize the conservation of birds not covered by existing conservation initiatives. 21

4.0 ENVIRONMENTAL IMPACTS

This chapter presents the expected effects from implementing the alternatives to the resources of concern. Direct effects are caused by the action and occur at the same time and place. Indirect effects are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable.

4.1 ALTERNATIVE A – PROPOSED ACTION

The following are the impacts expected from the implementation of the Proposed Action to the resources of concern.

4.1.1 AIR QUALITY AND GREENHOUSE GAS EMISSIONS

4.1.1.1 AMBIENT AIR QUALITY This Proposed Action is considered to be a minor air pollution source under the Clean Air Act at present control technology on some emissions sources (e.g. drill rigs) is not required by regulatory agencies. The Proposed Action would result in different emission sources associated with two project phases: well development and well production. Annual estimated emissions from the Proposed Action are summarized in Table 4.1.

Table 4.1. Proposed Action Annual Emissions (tons/year) 1

Development Development Production per Production Pollutant per Well Total Well Total Project Total NOx 14.20 227.20 2.20 35.20 262.40 CO 3.20 51.20 3.20 51.20 102.40 SOx 0.90 14.40 0.00 0.00 14.40 PM10 0.70 11.20 0.03 0.48 11.68 PM2.5 0.30 4.80 0.01 0.16 4.96 VOC 2.50 40.00 6.50 104.00 144.00 Benzene 0.03 0.48 0.13 2.08 2.56 Toluene 0.02 0.32 0.09 1.44 1.76 Ethylbenzene 0.02 0.32 0.22 3.52 3.84 Xylene 0.00 0.00 0.07 1.12 1.12 n-Hexane 0.05 0.80 0.08 1.28 2.08 Formaldehyde 0.00 0.00 0.00 0.00 0.00 1 Emissions include 16 producing well(s) and associated operations traffic during the year in which the project is developed.

Well development includes NOx, SO2, and CO tailpipe emissions from earth-moving equipment, vehicle traffic, drilling, and completion activities. Fugitive dust concentrations would occur from vehicle traffic on unpaved roads and from wind erosion where soils are disturbed. Drill rig and

fracturing engine operations would result mainly in NOX and CO emissions, with lesser amounts of SO2. These emissions would be short-term during the drilling and completion phases.

During well production, continuous NOx, CO, VOC, and HAP emissions would originate from well pad separators, condensate storage tank vents, and daily tailpipe and fugitive dust emissions from operations traffic. Road dust (PM10 and PM2.5) would also be produced by vehicles servicing the wells.

Under the proposed action, emissions of NOx and VOC, ozone precursors, are 262.40 tons/yr for NOx, and 144 tons/yr of VOC (Table 4.1). Emissions would be dispersed and/or diluted to the extent where any local ozone impacts from the Proposed Action would be indistinguishable from background conditions.

This proposed project is directly below the Monument Butte EIS project area. The Monument Butte EIS conducted updated near field modeling from oil and gas wells and infrastructure sources located in close proximity to each other (Kleinfelder, 2015). Table 1-2 reported the maximum impacts for near field PM10, PM2.5, CO, NO2, and SO2. The maximum near field impacts for PM10 and PM2.5 were from construction and development of the well field, the maximum impacts for all other pollutants were from well or infrastructure operations. All impacts, when added to the background, remained below the NAAQS (Section 1.4).

The primary sources of HAPs are from oil storage tanks and smaller amounts from other production equipment. Small amounts of HAPs are emitted by construction equipment. These emissions are estimated to be minor and less than 1 ton per year.

The Monument Butte EIS far field model for 3,750 wells found that the 0.5 and 1.0 deciview (dV) change analysis thresholds were exceeded at the closest sensitive Class II area, and there was one day at the nearest Class I area where the maximum dV change was greater than 1.0, but the 98th percentile was less than 1.0. The scenario modeled was full Monument Butte project production plus maximum drilling frequency (an unlikely scenario). The potential impacts are much less than the PSD increments (Bureau of Land Management Vernal Field Office, 2016) (Section 4.2.1.1.4). As a result, this 16 well project is not anticipated to impact visibility on nearby Class I or II areas.

The BLM has developed Best Management Practices (BMPs), which are mitigation measures applied to oil and natural gas drilling and production to help ensure that energy development is conducted in an environmentally responsible manner. The BLM encourages industry to incorporate and implement BMPs to reduce impacts to air quality through reduction of emissions, surface disturbances, and dust from field production and operations. Measures applicable to this project are contained in the Gasco Record of Decision, Attachment 2 Table 3.23, the most applicable of which are listed in the mitigation section below. Additionally, the BLM encourages oil and

3 The Gasco EIS contained an air quality adaptive management requirement that required the development of a strategy to analyze and employ enhanced air quality mitigation measures within 1 year of a monitored ozone exceedance after the ROD signature. That exceedance occurred in January 2013. Although a formal strategy has not yet been developed, Badlands has been proactively reducing existing and preventing new emissions as documented in three letters sent to the BLM (Beatty & Wozniak on behalf of Badlands Production Co, 2016) (Beatty & Wozniak on behalf of Badlands Production Co, 2017) (Beatty & Wozniak on behalf of Badlands Production Co, 2017).

natural gas companies to adopt other proven, cost-effective technologies and practices that improve operational efficiency and reduce natural gas emissions.

In October 2012, the EPA promulgated air quality regulations for completion of hydraulically fractured gas wells (Environmental Protection Agency, 2012). These rules include measures that reduced the emissions of volatile organic compounds during gas well completions, for example utilizing a process known as a “green” completion in which natural gas brought up during flow back is captured in tanks rather than in open fluid pits. Other measures to reduce emissions are included in the EPA’s Natural Gas STAR program. The EPA U.S. inventory data shows that industry’s implementation of BMPs proposed by the EPA’s Natural Gas STAR program has reduced emissions from oil and gas exploration and development (EPA, 2017c).

4.1.1.2 GREENHOUSE GASES AND CLIMATE CHANGE This EA includes a qualitative and quantitative analysis of possible greenhouse gas emissions that could result from oil and gas development associated with the proposed action. The primary sources of GHG emissions include the following:

• Fossil fuel combustion for construction and operation of oil and gas facilities – vehicles driving to and from production sites, engines that drive drill rigs, etc. These produce CO2 in quantities that vary depending on the age, types, and conditions of the equipment as well as the targeted formation, locations of wells with respect to processing facilities and pipelines, and other site-specific factors; • Fugitive CH4 – CH4 that escapes from wells (both gas and oil), oil storage, and various types of processing equipment. This is a major source of global CH4 emissions. These emissions have been estimated for various aspects of the energy sector, and starting in 2011, producers are required under 40 CFR 98, to estimate and report their CH4 emissions to the USEPA; and • Combustion of produced oil and gas – it is expected that future operations would produce marketable quantities of oil and/or gas. Combustion of the oil and/or gas would release CO2 into the atmosphere. Fossil fuel combustion is the largest source of global CO2.

In recent years, many states, tribes, and other organizations have initiated GHG inventories, tallying GHG emissions by economic sector. The U.S. EPA provides links to statewide GHG emissions inventories (EPA, 2017a). Guidelines for estimating project-specific GHG emissions are available (URSC, 2010), but some additional data, including the projected volume of oil or natural gas produced for an average well, number of wells (as well as other factors described in Section 4.1.1.1) were used to provide GHG estimates.

Potential direct greenhouse gas emissions for a single well have been estimated based on the maximum emissions calculated for Alternative D in the Greater Monument Butte FEIS (Chapter 4 page 4-26 Table 4.2.1.4.1-1), which is the most recent NEPA calculation of GHG in the lease area (Bureau of Land Management Vernal Field Office, 2016). Total Greenhouse Gas Warming Potential (GWP), which includes direct and indirect emissions of carbon dioxide, methane, and nitrous oxide from an oil or gas well (including well development and production) are 2,284 tons per year (tpy) CO2e for a single oil well, and 2,415 tons per year CO2e for a single gas well. For the 16 proposed gas wells, this would equate to 38,640 tpy CO2e.

Indirect Downstream GHG emissions are estimated based on an average cumulative production rate of 24,120 barrels of oil, and 421,302 MCF gas over the life of a well, based on the production history for the fields and regions in which the parcels are located. (UDOGM, 2017a). Indirect GHG emissions are also only calculated for carbon dioxide based on combustion of the product. Using an EPA emissions factor of 0.43 Metric tons of CO2 per Barrel of oil (U.S. Energy Information Administration , 2016), and 0.054717 MT of CO2 per MCF of gas (EPA, 2017) indirect GHG emissions can be estimated at 33,423.94 metric tons per well. For total assumed emissions for this 16 well gas project, this would equate to 0.875472 MT of CO2 per MCF of gas. Actual GHG emissions may range from zero (assuming no lease parcels sold or developed) to an indeterminate upper range based on realized production rates, control technology, and physical characteristics of any oil produced.

Although this EA presents a quantified estimate of potential GHG emissions associated with the proposed development, there is significant uncertainty in the estimates due to uncertainties with regard to eventual production volumes and variability in flaring, construction, and transportation. Since there are no applicable emission thresholds or standards, is not possible to assign a “significance” value or impact to these numbers. The emissions estimates themselves are presented as a proxy for impact.

The estimates above provide a complete GHG lifecycle of a well from site inspection to possible indirect emissions through combustion. A rough estimate was possible using publicly available information and using estimates from future production for reasonably foreseeable development. With respect to the rough estimates of indirect CO2 emissions, it is difficult to discern with certainty what end uses might be reasonably foreseeable for the fuels extracted from a particular leasehold. For instance, some end uses include combustion of transportation fuels, fuel oils for heating and electricity generation, as well as production of asphalt and road oil, and the feedstocks used to make chemicals, plastics, and synthetic materials. The BLM does not exercise control over the specific end use of the oil and gas produced from any individual federal lease. The BLM has no authority to direct or regulate the end use of the produced oil and/or gas. The BLM can only provide an estimate of potential GHG emissions using national approximations of where or how the end use may occur.

The Social Cost of Carbon (SCC) reflects the monetary cost incurred by the emission of one additional metric ton of carbon dioxide. The BLM finds that including monetary estimates of the SCC in its NEPA analysis for this Proposed Action would be of limited use in analyzing and selecting between alternatives in this EA because the BLM is not doing a cost-benefit analysis for other resources in this NEPA document. The BLM does not believe monetizing only SCC would be instructive. The CEQ regulation states (in part), “…for the purposes of complying with the Act, the weighing of the merits and drawbacks of various alternatives need not be displayed in a monetary cost-benefit analysis and should not be when there are important qualitative considerations.”

BLM encourages oil and natural gas companies to adopt other proven, cost-effective technologies and practices that improve operational efficiency and reduce natural gas emissions.

4.1.1.3 MITIGATION MEASURES

• All internal combustion equipment would be kept in good working order. • Water or other approved dust suppressants would be used at construction sites and along roads, as determined appropriate by the Authorized Officer. • Open burning of garbage or refuse would not occur at well sites or other facilities. • Drill rigs would be equipped with Tier II or better diesel engines • During completion, no venting would occur, and flaring would be limited as much as possible. Production equipment and gathering lines would be installed as soon as possible. • Flare hydrocarbon gases at high temperatures in order to reduce emissions of incomplete combustion through the use of multi-chamber combustors; • Telemetry will be installed to remotely monitor and control production. • All new and replacement internal combustion gas field engines of less than or equal to 300 design-rated horse power must not emit more than 2 grams of NOx per horsepower-hour. This requirement does not apply to gas field engines of less than or equal to 40 design-rated horsepower-hour. • All new and replacement internal combustion gas field engines of greater than 300 design rated horsepower must not emit more than 1.0 grams of NOx per horsepower- hour. • Green completions would be used for all well completion activities where technically feasible. 4.1.1.4 RESIDUAL IMPACTS The above mitigation measures may reduce, but will not eliminate, emissions from the proposed action.

4.1.2 INVASIVE PLANTS/NOXIOUS WEEDS, SOILS, AND VEGETATION

The Proposed Action would disturb a total of 0.5 acres of soils and vegetation. Under the Proposed Action, reclamation would occur on approximately 40 percent of the total disturbance. Impacts to soils and vegetation would be partially mitigated by reclamation of disturbed areas with native vegetation and control of noxious and invasive weeds by mechanical and chemical treatment (see Chapter 2). Direct and indirect impacts to soils and vegetation include mixing of soil horizons, soil compaction, short-term loss of topsoil and site productivity, loss of soil/topsoil through erosion, clearing of

vegetation, invasion and establishment of introduced, undesired plant species. Loss of soil/topsoil in disturbed areas would reduce the re-vegetation success of seeded native species due to increased competition by annual weed species. Annual weed species are adapted to disturbed conditions, and have less stringent moisture and soil nutrient requirements than do perennial native species. The severity of these invasions would depend on the success of reclamation and re-vegetation, and the degree and success of noxious weed control efforts. Additional analysis of these impacts are included in the Gasco Final EIS section 4.13 (Bureau of Land Management Vernal Field Office, 2012a). The project would contribute an estimated additional 3.0 tons of soil per acre per year above the current natural erosion rate for the first year of development. After the first year, the soil erosion attributed to the project would reduce to 1.5 tons per acre per year until the access roads, pipelines, and well pads are fully reclaimed. Erosion rates are higher during the first year due to disturbance during construction. Additional analysis of these impacts are included in the Gasco Final EIS section 4.10 (Bureau of Land Management Vernal Field Office, 2012a). 4.1.2.1 MITIGATION MEASURES

• All reclamation activities will comply with the Green River Reclamation Guidelines • All vehicles and equipment shall be cleaned either through power-washing, or other approved method, if the vehicles or equipment were previously operated outside the Uinta Basin, to prevent weed seed introduction. • All disturbance areas shall be monitored for noxious weeds annually, for a minimum of three growing seasons following completion of project or until desirable vegetation is established • Noxious and invasive weeds will be controlled by the proponent throughout the area of project disturbance. • Noxious weeds will be inventoried and reported to BLM in the annual reclamation report. Where an integrated pest management program is applicable, coordination has been undertaken with the state and local management program (if existing). A copy of the pest management plan will be submitted for each project. • A pesticide use proposal (PUP) will be obtained for the project, by the proponent if applicable. 4.1.2.2 RESIDUAL IMPACTS The mitigation measures will reduce but not eliminate the potential for spread or introduction of weed species in the project area.

4.1.3 PALEONTOLOGY

Direct impacts to paleontology would be the destruction of fossils during the construction of the pipeline, access road, and on any expansion of the well pad and monitoring of ground disturbing activities is required. Additional analysis of these impacts are included in the Gasco Final EIS section 4.7 (Bureau of Land Management Vernal Field Office, 2012a).

Mitigation considerations for the pipelines and well pads must include an assessment of the construction disturbance. For example, removal or penetration of surface alluvium or soils that had been protecting the fossils could result in accelerated erosion. The construction process itself could create easier access to fossils resulting in a greater looting potential. On-site monitoring and spot

checking would be necessary during construction activities to record and protect fossils in place or to remove significant specimens for archiving and preserving in a museum.

Scientifically important fossils may be present at the Federal 42-29-9-19, 31-29-9-19 and 43-30-9- 19 host well pads.

4.1.3.1 MITIGATION MEASURES

• A BLM permitted paleontologist should be present for monitoring of excavation activities at the proposed Federal 42-29-9-19 and 31-29-9-19 well pad expansion projects, including related surface disturbing activities requiring infrastructure development.

4.1.3.2 RESIDUAL IMPACTS The mitigation measures will reduce but not eliminate the potential for damage or destruction to paleontological resources in the project area.

4.1.4 PLANTS: THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

4.1.4.1 UINTA BASIN HOOKLESS CACTUS (SCLEROCACTUS WETLANDICUS) The proposed action will occur mostly on previously disturbed areas. Although there are 78 individual cacti within 300 feet of the existing disturbance, no direct physical damage will occur to Uinta Basin hookless cactus individuals as a result of the Proposed Action. Adherence to additional conservation measures will minimize impacts to Uinta Basin hookless cactus individuals as a result of the Proposed Action. The surface pipeline that will be upgraded is within an existing ROW, and all construction work related to pipeline replacement and maintenance will be done from the existing roads and well pads so that no new surface disturbance will occur. Additional analysis of these impacts are included in the Gasco Final EIS section 4.12.1 (Bureau of Land Management Vernal Field Office, 2012a).

Surveys follow the most currently accepted protocols between USFWS and BLM (see section 3.1.4.1 above and BLM and USFWS 2012). In addition, the Gasco Final EIS allows for up to 5% surface disturbance in Level 2 core conservation areas (p. 23). The proposed action will contribute approximately 0.5 acres of disturbance to the Middle Green core conservation area, which is less than 0.1% of the total area, and is in accordance with the Gasco EIS (see Gasco EIS final biological opinion).

Possible dispersed direct and indirect negative impacts which may result from implementation of the Proposed Action include: loss of suitable habitat, habitat modification by invasive weed species which may compete with individuals, accidental spray or drift of herbicides used during invasive plant control, and the deposition of fugitive dust from construction activities and vehicle traffic on unpaved roads. Due to these indirect negative impacts the Proposed Action warrants a “may affect, is not likely to adversely affect” determination for Uinta Basin hookless cactus. For a summary of Endangered Species Act Section 7 consultation, refer to Chapter 5.

4.1.4.2 MITIGATION MEASURES This project involves drilling new wells on existing well pads, and includes 0.5 acres of disturbance from well pad expansion (see Table 2-2). Some areas that were previously disturbed will be 28

redisturbed for this project. Because of the close proximity of the existing wells to Sclerocactus wetlandicus individuals, the applicant has committed to the standard Sclerocactus mitigation measures (see Appendix L, page L-6, from the Vernal Record of Decision and Approved RMP) as well as the following project-specific measures:

• Drilling on these well pads will be closed loop to limit the amount of re-disturbance and well pad expansion that will occur. • As a result of recommendations made by the BLM botanist during onsites, corner #2 on the 31-29-9-19 location will be moved to the edge of existing disturbance to minimize impacts to suitable Uinta Basin hookless cactus habitat. • A BLM-approved botanist will be on site during any construction and drilling operations to make sure activities do not impact plants. The BLM-approved botanist will install silt fencing at the edge of the proposed disturbance to prevent impacts to Sclerocactus wetlandicus individuals and will remove them at the end of construction. • Any construction work associated with this proposed project will happen outside of flowering season (usually April through May) as determined by the BLM Authorized Officer. • Any backfill/spoils/topsoils will be stockpiled as far away from existing plants as possible (for example, on the side of the well pad that is furthest from existing plants). • Water only (no chemicals, reclaimed production water, or oil field brine) will be used for project-related dust abatement from March through August, when Sclerocactus species are most vulnerable to dust-related impacts. • Where the pipeline is within 50 feet of individual Sclerocactus plants or populations, the pipeline will either be hand-laid or laid by vehicles from the existing road and secured in place to prevent movement toward plants. • After construction is completed, the BLM-approved botanist will provide a report to the BLM summarizing the methods and results of the avoidance measures. Alternatively, the BLM botanist will complete a compliance check and report. • Sclerocactus spot checks will be conducted and approved for all planned disturbance areas on an annual basis the year following the 100% Sclerocactus clearance survey for this project. Results of spot checks may require additional pre-construction plant surveys as directed by the BLM and in coordination with the USFWS. If the proposed action or parts thereof have not occurred within four years of the original survey, coordination with the USFWS will be required and 100% clearance re-survey may be necessary prior to ground disturbing activities. Spot check surveys for 31-29-9-19 expire May 10, 2018, and 100% clearance surveys expire July 28, 2018. Spot check surveys will be required for 42-29-9-19 if construction commences after May 10, 2018, and 100% clearance surveys expire May 10, 2021. • Additional mitigation for project impacts in lieu of the 3-year Sclerocactus monitoring requirement (for plants within 300 feet of disturbance) includes contribution to the Sclerocactus mitigation fund, with the amount determined during section 7 consultation with the USFWS, concluded July 1, 2014. This monetary amount must be paid by Gasco to the Sclerocactus Mitigation Fund-BLM within 90 days upon receipt of concurrence, or before construction of the Project begins. The payment should be made to; Sclerocactus Mitigation Fund-BLM, Michelle Olson, Manager, Impact-Directed Environmental Accounts, National Fish and Wildlife Foundation, 1133 Fifteenth Street NW, Suite 1100, Washington, DC 20005.

4.1.4.3 RESIDUAL IMPACTS The mitigation measures will reduce but not eliminate the potential for impacts to cactus and its habitat in the project area.

4.1.5 WILDLIFE: MIGRATORY BIRDS (INCLUDING RAPTORS)

Implementation of the Proposed Action Alternative would directly impact approximately 0.5 acres of suitable nesting and/or foraging habitat for migratory bird species. These impacts would be short term and would occur during project activities and until reclamation efforts are in accordance with the Reclamation Plan. Other potential impacts to migratory bird species could include: increased direct impacts (including poaching and collisions with vehicles), direct loss or degradation of potential nesting and foraging habitats, and indirect disturbance from human activity (including harassment, displacement, and noise). If activities occur in the spring during the nesting season for most migratory birds, impacts would be greater than if development occurred late summer through late winter. Impacts during the spring could include nest abandonment, reproductive failure, displacement, and destruction of nests. Additional analysis of these impacts are included in the Gasco Final EIS section 4.12.1 (Bureau of Land Management Vernal Field Office, 2012a).

4.1.5.1 MITIGATION MEASURES None identified.

4.1.5.2 RESIDUAL IMPACTS Residual impacts are as previously described.

4.1.6 WILDLIFE: NON-USFWS DESIGNATED

4.1.6.1 SPECIAL STATUS FISH The analysis for the three special status fish species excluding USFWS designated species is the same as the analysis for threatened, endangered or candidate animal species; therefore, the same mitigation measures apply. It is not anticipated that the proposed action would result in the listing of any fish species. Additional analysis of these impacts are included in the Gasco Final EIS section 4.12.1 (Bureau of Land Management Vernal Field Office, 2012a).

4.1.6.2 MITIGATION MEASURES None identified, although special status fish species may benefit from the mitigation measures identified for the Colorado River fish species.

4.1.6.3 RESIDUAL IMPACTS Residual impacts are as previously described.

4.1.7 WILDLIFE: THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

4.1.7.1 COLORADO RIVER FISH SPECIES The proposed action would result in 16 acre-feet of depletion from the Upper Colorado River Drainage System. Water depletions, along with a number of other factors, have resulted in such drastic reductions in the populations of the Colorado pikeminnow, humpback chub, bonytail, and razorback sucker that the Service has listed these species as endangered and has implemented programs to prevent them from becoming extinct.

Water depletions reduce the ability of the river to create and maintain the primary constituent elements that define critical habitats. Food supply, predation, and competition are important elements of the biological environment. Food supply is a function of nutrient supply and productivity, which could be limited by reduction of high spring flows brought about by water depletions. Predation and competition from nonnative fish species have been identified as factors in the decline of the endangered fishes. Water depletions contribute to alterations in flow regimes that favor nonnative fishes.

The potential exists for water intake structures placed in the Upper Colorado River Drainage System (flowing rivers and streams) to result in mortality to eggs, larvae, young-of-the-year, and juvenile life stages. BLM and their applicants would minimize this potential by following the conservation measures listed below. Key habitat components for foraging or cover may be removed or altered due to equipment, including decreased water quantity for aquatic species from dewatering during low flow periods.

The proposed action would result in a water depletion based on removal of water from the Upper Colorado River Drainage System for construction and drilling operations. Therefore, the proposed action will have a “may affect, likely to adversely affect” determination for the endangered Colorado pikeminnow, humpback chub, bonytail, and razorback sucker. The proposed project falls within the scope of the Gasco Natural Gas Field Development EIS. Additional analysis of these impacts are included in the Gasco Final EIS section 4.12.1 (Bureau of Land Management Vernal Field Office, 2012a). Therefore, Section 7 consultation has already been completed for this project.

4.1.7.2 MITIGATION MEASURES

• The best method to avoid entrainment is to pump from an off-channel location – one that does not connect to the river during high spring flows. An infiltration gallery constructed in a BLM and Service approved location is best. • If the pump head is located in the river channel where larval fish are known to occur, the following measures apply: o Do not situate the pump in a low-flow or no-flow area as these habitats tend to concentrate larval fishes; o Limit the amount of pumping, to the greatest extent possible, during that period of the year when larval fish may be present (April 1 to August 31); and o Limit the amount of pumping, to the greatest extent possible, during the pre-dawn hours as larval drift studies indicate that this is a period of greatest daily activity. o Screen all pump intakes with 3/32 inch mesh material. o Approach velocities for intake structures will follow the National Marine Fisheries Service’s document “Fish Screening Criteria for Anadromous Salmonids”. For projects with an in-stream intake that operate in stream reaches where larval fish may be present, the approach velocity will not exceed 0.33 feet per second (ft/s). 31

• Report any fish impinged on the intake screen to the Service (801.975.3330) and the Utah Division of Wildlife Resources: Northeastern Region 318 North Vernal Ave, Vernal, UT 84078 Phone: (435) 781-9453

4.1.7.3 RESIDUAL IMPACTS The mitigation measures will reduce but not eliminate the potential for impacts to fish and their habitat from the project.

4.1.8 MONITORING AND/OR COMPLIANCE

Compliance inspections will occur by Vernal Field Office Natural Resource Managers in accordance with the Inspection and Enforcement Documentation and Strategy Development Handbook (H- 3160-5).

Additionally, the BLM annually reports APD-related water depletions from the Upper Colorado River Drainage System to the USFWS.

4.2 ALTERNATIVE B – NO ACTION

The following are the impacts expected from the implementation of the No Action Alternative to the resources of concern.

4.2.1 AIR QUALITY AND GREENHOUSE GAS EMMISIONS

Under the No Action Alternative, effects on ambient air quality would continue at present levels from three host wells and other existing oil and gas development in the region as well as other emission producing sources.

4.2.2 INVASIVE PLANTS/NOXIOUS WEEDS, SOILS, AND VEGETATION

Under the No Action Alternative, effects on weed introduction and spread would continue at present levels from the three host wells and other existing oil and gas development in the region. Current land use trends in the area would continue, including increased industrial development, increased off-highway vehicles (OHV) traffic, and increased recreation use for hunting, fishing, bird watching, and sightseeing.

4.2.3 PALEONTOLOGY

Under the no action alternative, fossil resources in the project area would remain the same as they currently are.

4.2.4 PLANTS: THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

4.2.4.1 UINTA BASIN HOOKLESS CACTUS (SCLEROCACTUS WETLANDICUS) 32

Under the No Action Alternative, effects on cactus and cactus habitat would continue at present levels from the three host wells and other existing oil and gas development in the region. Current land use trends in the area would continue, including increased industrial development, increased off-highway vehicles (OHV) traffic, and increased recreation use for hunting, fishing, bird watching, and sightseeing.

4.2.5 WILDLIFE: MIGRATORY BIRDS (INCLUDING RAPTORS)

Under the No Action Alternative, effects on migratory birds, raptors, and their habitat would continue at present levels from the three host wells and other existing oil and gas development in the region. Current land use trends in the area would continue, including increased industrial development, increased off-highway vehicles (OHV) traffic, and increased recreation use for hunting, fishing, bird watching, and sightseeing.

4.2.6 WILDLIFE: NON-USFWS DESIGNATED

4.2.6.1 SPECIAL STATUS FISH The analysis for the three special status fish species excluding USFWS designated species is the same as the analysis for the Colorado River fish species. It is not anticipated that the No Action Alternative would result in the listing of any fish species.

4.2.7 WILDLIFE: THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

4.2.7.1 COLORADO RIVER FISH SPECIES Under the No Action Alternative, effects Colorado River fish would continue at present levels from the three host wells and other existing oil and gas development in the region. Current land use trends in the area would continue, including increased industrial development, increased off- highway vehicles (OHV) traffic, and increased recreation use for hunting, fishing, bird watching, and sightseeing.

4.2.8 MONITORING AND/OR COMPLIANCE

No monitoring would be necessary under the No Action Alternative.

4.3 CUMULATIVE IMPACTS

“Cumulative impacts” are those impacts resulting from the incremental impact of an action when added to other past, present, or reasonably foreseeable actions regardless of what agency or person undertakes such other actions.

4.3.1 AIR QUALITY AND GREENHOUSE GAS EMMISIONS

4.3.1.1 AMBIENT AIR QUALITY The cumulative impact area for air quality is the Uinta Basin, plus all regional Class I areas and other environmentally sensitive areas (e.g., national parks and monuments, wilderness areas, etc.) near the Uinta Basin. The Air Resource Management Strategy (ARMS) Modeling Project is a cumulative assessment of potential future air quality impacts associated with predicted oil and gas activity in the Uinta Basin (AECOM Environment, 2014). Consequently, past, present and reasonably foreseeable wells in the Uinta Basin are a part of the cumulative actions considered in this analysis. The ARMS is incorporated by reference and summarized below.

The ARMS Modeling Project predicted the following impacts to air quality and air quality related values for the 2010 typical year and four 2021 future year scenarios: 2021 on-the-books (OTB); 2021 Scenario 1 (NOx controls); 2021 Scenario 2 (VOC controls); and 2021 Scenario 3 (NOx and VOC controls).

• Ozone o The highest modeled ozone occurs in the Uinta Basin study area regardless of model scenario, and all scenarios predict exceedances of the ozone NAAQS and state AAQS in the Uinta Basin. o In the Uinta Basin, the ozone concentrations are highest during the winter period. In Class I and Class II areas outside the Uinta Basin study area, ozone concentrations are highest during the summer period. o During non-winter months in the Uinta Basin the model predicts that ozone may exceed the NAAQS and state AAQS (Ambient Air Quality Standards); however, model-adjusted results from the MATS tool (which accounts for model performance biases) indicate that non-winter ozone concentrations are below the NAAQS and state AAQS for all monitors and areas analyzed. Also, the 2021 scenarios have minimal effect on model-predicted ozone concentrations during non-winter months. o 2021 Scenario 2 tends to have the lowest 8-hour ozone concentration relative to all other 2021 scenarios (4th highest daily maximum is 3 ppb lower compared to the 2021 OTB Scenario). When comparing Scenario 2 to the OTB Scenario, a potential reduction in ozone concentrations occurs in the vicinity of the Ouray site (where the concentrations are already largest). There is no predicted ozone disbenefit associated with Scenario 2 mitigation measures (i.e., there is no area with predicted ozone increases relative to the OTB Scenario). This supports the assessment that peak ozone impacts are in VOC-limited areas. o 2021 Scenarios 1 and 3 are predicted to have higher ozone impacts than either the 2010 Typical year and the 2021 OTB Scenario. Both scenarios predict a relatively large increase

in ozone concentrations within the vicinity of Ouray indicating potential ozone disbenefits associated with NOx control mitigation measures. • NO2, CO, SO2, PM2.5, and PM10 o There are seven monitoring stations within the 4- km domain with daily PM2.5 concentrations that exceed the NAAQS and state AAQS in the baseline emissions inventory. o All modeled NO2, CO, SO2, PM2.5, and PM10 values are well below the NAAQS and state AAQS in the Uinta Basin. o The model-predicted PM2.5 and PM10 concentrations may underestimate future impacts due to a negative model bias throughout the year in the 4-km domain with the largest bias occurring in summer (AECOM and STI 2014). o Results from the MATS tool (which accounts for model performance biases) indicate that PM2.5 concentrations may exceed the NAAQS and state AAQS for select monitors and assessment areas in the 2010 Typical year. All 2021 scenarios predict that only one of these monitoring station would continue to exceed the NAAQS and state AAQS. o No monitoring stations within the 4-km domain exceed the annual PM2.5 NAAQS and state AAQS during the 2010 typical or 2021 Scenarios. o Two unmonitored areas within the Uinta Basin exceed the annual PM2.5 NAAQS and state AAQS during the 2010 typical year, and impacts in these areas tend to increase under 2021 Scenarios 1 and 2. Under 2021 Scenario 3, the annual PM2.5 impacts decrease in the Uinta Basin due to combustion control measures. o The 2021 scenarios generally have lower NO2, CO, SO2, PM2.5, and PM10 concentrations than the 2010 Typical Year scenario, except for within the Uinta Basin. o Under the 2021 scenarios, all assessment areas are within the PSD (Prevention of Significant Deterioration) increments for annual NO2, 3-hour SO2, annual SO2, and annual PM10. o Under the 2021 scenarios, most assessment areas exceed the 24-hour PM2.5 PSD increment. • Visibility o Visibility conditions in Class I and sensitive Class II areas generally show improvement in the 2021 Scenarios relative to the 2010 Typical Year. o There also are no substantial differences in the 20th percentile best and worst visibility days between the 2021 Scenarios. • Deposition and Acid Neutralizing Capacity o Results generally show a decrease in deposition for the 2021 Scenarios relative to the 2010 Typical Year. o The differences in estimated deposition between the 2021 Scenarios are generally very small. o Acid Neutralizing Capacity change at all seven sensitive lakes exceeds the 10 percent limit of acceptable change for all model scenarios.

It is anticipated that the impact to ambient air quality and air quality related values associated with the Proposed Action Alternative would be indistinguishable from and dwarfed by the model and emission inventory scope and margin of error. The No Action alternative would not result in an accumulation of impacts.

4.3.1.2 GREENHOUSE GASES

The cumulative impact area and past, present, and reasonably foreseeable development for GHG is the same as Air Quality. The Proposed Action Alternative could contribute to cumulative GHG emissions. The primary sources of emissions include the following:

• Fossil fuel combustion for construction and operation of oil and gas facilities – vehicles driving to and from production sites, engines that drive drill rigs, etc. These produce CO2 in quantities that vary depending on the age, types, and conditions of the equipment as well as the targeted formation, locations of wells with respect to processing facilities and pipelines, and other site-specific factors. • Fugitive CH4 – CH4 that escapes from wells (both gas and oil), oil storage, and various types of processing equipment. This is a major source of global CH4 emissions. These emissions have been estimated for various aspects of the energy sector, and starting in 2011, producers are required under 40 C.F.R. §98, to estimate and report their CH4 emissions to the EPA. • Combustion of produced oil and gas – it is expected that operations will produce marketable quantities of oil and/or gas. Combustion of the oil and/or gas would release CO2 into the atmosphere. Fossil fuel combustion is the largest source of global CO2.

The BLM’s Colorado Plateau Rapid Ecoregional Assessment (REA) (Bureau of Land Management, 2012d) provides an estimate of where climate change may occur in the Colorado Plateau. This project area is in an area predicted to be subject to moderately low change (See REA Figure 6-14A). In particular the REA states that the pinyon-juniper and sagebrush vegetation communities in the Uinta Basin are predicted to experience moderately low exposure to climate change. However, the direction of such climate change is not known.

Since climate change and global warming are global phenomena, for purposes of this NEPA analysis, the analysis presented above about the direct and indirect effects of GHG emissions from the Proposed Action is also an analysis of the cumulative effects of the Proposed Action. The BLM has determined that this analysis “adequately addresses the cumulative impacts for climate change from the Proposed Action, and therefore a separate cumulative effects analysis for GHG emissions is not needed. The No Action Alternative would not contribute to an accumulative of impacts.

4.3.2 INVASIVE PLANTS/NOXIOUS WEEDS, SOILS, AND VEGETATION

The cumulative impacts for these resources are the same as, and incorporated by reference to, the cumulative impacts analyzed in Section 4.18.3 of the Gasco EIS and include the introduction or spread of noxious weeds and cumulative soil erosion. The cumulative impacts for this project were included in the Gasco EIS analysis. The Proposed Action would add 0.5 acres of new surface disturbance. The No Action Alternative would not contribute to cumulative impacts.

4.3.3 PALEONTOLOGY

The cumulative impacts for these resources are the same as, and incorporated by reference to, the cumulative impacts analyzed in Section 4.18.3 of the Gasco EIS. The cumulative impacts for this project were included in the Gasco EIS analysis. The cumulative impact region includes numerous known fossil localities with particular emphasis on the very high fossiliferous zone contained within the Uintah B/Myton Member (Murphy et al., 2009 PFYC 5). The discovery of surface 36

fossils in this area indicates the potential for important subsurface paleontological resources potentially impacted during ground disturbing activities, cumulatively related to the past, present and future oil field development. Cumulative impacts include damage or destruction of surface or buried paleontological resources from surface disturbing activities. The Proposed Action would add 0.5 acres of new surface disturbance. The No Action Alternative would not contribute to cumulative impacts.

4.3.4 PLANTS: THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

4.3.4.1 UINTA BASIN HOOKLESS CACTUS (SCLEROCACTUS WETLANDICUS) The area delineated by the USFWS as potential habitat for Uinta Basin hookless cactus covers approximately 540,030 acres on BLM, Ute tribal, state of Utah, and privately held lands. Within the CIAA, there are eight active approved field development NEPA documents, Newfield Production Company’s Castle Peak and Eightmile Flat Oil and Gas Expansion EIS (40,475 acres of 64,000 acre project in CIAA), EOG Resources, Inc. North Chapita Natural Gas Well Development Project EA (7,785 acres of the 10,920 acre project area is in the CIAA), Enduring Resources, LLC’s West Bonanza Area Natural Gas Well Development Project EA (263 acres of the 24,813 acre project area is in the CIAA), Gasco Production Company’s Natural Gas Field Development EIS (102,389 acres of the 236,165 acre project area is in the CIAA), Kerr-McGee Oil & Gas Onshore LP’s Greater Natural Buttes Project EIS (88,882 acres of the 162,911 acre project area is in the CIAA), QEP Energy Company’s Greater Deadman Bench Oil and Gas Producing Region EIS (10,585 acres of the 98,785 acre project area is in the CIAA), EOG Resources, Inc. Chapita Wells-Stagecoach EIS (18,489 acres of the 31,872 acre project area is in the CIAA), and Bill Barrett Corporation’s West Tavaputs Plateau Natural Gas Full Field Development Plan EIS (26,045 acres of the 137,930 acre project area is in the CIAA). In total approximately 24,208 acres of surface disturbance was authorized across the analysis areas of these documents. If the disturbance is relatively uniform throughout these project areas, then approximately 10,339 acres of surface disturbance has occurred or will occur within the CIAA (1.9% of the CIAA). Within the CIAA, numerous oil and natural gas wells do not tier to these NEPA documents. As of 6/25/2012, there are 548 abandoned oil and gas locations outside of the scope of the field development documents.

Using the assumption contained within the Greater Uinta Basin Cumulative Impacts Technical Support Document, 2,791 acres of the CIAA were disturbed some point in the past and are in various stages of reclamation (0.5% of the CIAA). There are currently 4,415 well pads that serve as platforms for actively producing wells not permitted under these documents. Using the above assumption, this has resulted in 18,254 acres of surface disturbance (3.4% of the CIAA). Finally, 380 wells are currently proposed that do not tier to these documents that will result in 1,638 acres of surface disturbance (0.3% of the CIAA). Currently proposed field developments, if all approved as proposed (either the estimated disturbance presented in the agency preferred alternative, in the applicant proposed alternative if the agency preferred alternative has not been selected, or an estimate of 5- acres of disturbance per well if an estimate is not yet available) would result in 25,472 acres of surface disturbance throughout the entirety of the project areas. If it assumed that disturbance would be relatively uniform throughout, then there will be about 11,232 acres of disturbance with the CIAA due the projects (2.1% of the CIAA). Thus, in total 44,254 acres (8.2% of the CIAA) have been or will be disturbed within the CIAA due to energy development activities. Within the CIAA, there are also approximately 1,903 miles of roads. Cumulative impacts include habitat disturbance and fragmentation through surface disturbing activities, dust impacts to flowering plants, and

pollinator habitat disturbance and pollinator displacement. The Proposed Action would add 0.5 acres of surface disturbance. The No Action Alternative would not contribute to cumulative impacts.

Due to inclusions of areas of unsuitable habitat within the potential habitat area, the total acreage of suitable habitat is less than 540,030 acres. However, a complete survey of suitable habitat has not been performed and thus the amount of suitable habitat has not been quantified. Impacts to the species from past, current, and reasonably foreseeable actions may be greater or smaller than those described for the total area depending upon the exact distribution of actions relative to suitable habitat.

4.3.5 WILDLIFE: MIGRATORY BIRDS (INCLUDING RAPTORS)

The CIAA is the Vernal RMP area. Cumulative impacts are incorporated by reference to section 4.18.3 of the Gasco EIS. Cumulative impacts include decreased available cover, carrying capacity, foraging opportunities, breeding habitat, and habitat productivity for migratory birds and mountain plover. In general, the severity of the cumulative effects would depend on factors such as the sensitivity of the species affected, seasonal intensity of use, type of project activity, and physical parameters (e.g., topography, forage quality, cover availability, visibility, and noise presence). The Proposed Action would add 0.5 acres of new surface disturbance. The No Action Alternative would not contribute to cumulative impacts.

4.3.6 WILDLIFE: NON-USFWS DESIGNATED AND THREATENED, ENDANGERED, PROPOSED, OR CANDIDATE

4.3.6.1 SPECIAL STATUS FISH AND COLORADO RIVER FISH SPECIES The CIAA for this resource is the Colorado River system. Cumulative impacts are incorporated by reference to Section 4.18.3.11 of the Gasco EIS. Cumulative impacts in this area include oil and gas exploration and development, irrigation, urban development, recreational activities, and activities associated with the Upper Colorado River Endangered Fish Recovery Program. Cumulative impacts such as decreased water quality and quantity, decreased habitat quality, habitat fragmentation, and mortality result from decreased stream flow, erosion, improperly placed culverts, elevated salinity, and contamination. Decreased stream-flows reduce or eliminate both the extent and quality of suitable habitat by increasing stream temperatures, and subsequently by reducing dissolved oxygen levels. Such impacts may be more pronounced during periods of natural cyclic flow reductions (fall and winter or periods of drought). A loss of stream flow can also reduce a stream’s ability to transport sediment downstream. The Proposed Action would add 0.5 acres of surface disturbance with its associated impacts, and about 16 acre-feet of water depletion. The No Action Alternative would not contribute to cumulative impacts.

5.0 CONSULTATION AND COORDINATION

5.1 INTRODUCTION

The issue identification section of Chapter 1 identifies those issues analyzed in detail in Chapter 4. The issues were identified through the public and agency involvement process described below.

5.2 PERSONS, GROUPS, AND AGENCIES CONSULTED

Table 5-1 lists the persons, groups, and agencies that were coordinated with or consulted during the preparation of this project. The table also summarizes the conclusions of those processes.

Table 5-1: Coordination And Consultation Name Purpose & Authorities for Findings & Conclusions Consultation or Coordination Utah State Historic Preservation National Historic Preservation Consultation with the Utah State Historic Office Action Section 106 Preservation Office was previously conducted through Utah state antiquities project number U- 07-GB-0032bs.

No cultural resources were identified within the project area, therefore the BLM has made a “no historic properties affected” determination pursuant to 36CFR800(d)(1). Concurrence was received, documentation of this can be found in the individual well/APD files. U.S. Fish and Wildlife Service Endangered Species Act Section Water depletion will occur for the proposed 7 project; however, the proposed project wells have been analyzed under the USFWS’s Conclusion of Reinitiation of Section 7 Consultation for Water Depletion in the Upper Colorado River Basin on Bureau of Land Management land administered by the Vernal Field Office Biological Assessment, 2011 (FWS/R6 ES/UT 06-F-0215- R001).

Sclerocactus wetlandicus (Uinta Basin hookless cactus) was also consulted on through the EIS. However, that consultation did not include mitigation measures for plants that would be directly impacted by development and deferred mitigation to project-specific consultation The BLM’s determination is that this action “may affect, but is not likely to adversely affect” S. wetlandicus. Consultation was initiated for this project on June 9, 2014 and completed with a letter from USFWS concurring with BLM’s determination on July 1, 2014.

Table 5-1: Coordination And Consultation Name Purpose & Authorities for Findings & Conclusions Consultation or Coordination Additionally, On May 10, 2017, BLM botanists conducted clearance, spot check, and meander surveys as per standard protocols and as per the EA and USFWS consultation requirements. Once again USFWS concurred with BLM’s determination on May 16, 2017.

Tribes Government to Government Tribal consultations were conducted under the Consultation Policy Gasco EIS. No Traditional Cultural Properties are identified within the area of potential effect. The proposed project will not hinder access to or use of Native American religious sites.

5.3 SUMMARY OF PUBLIC PARTICIPATION

The public was notified of this project by its being posted on the BLM’s NEPA Register 1/4/2017. Issues were identified by the BLM Interdisciplinary Team as documented in the Interdisciplinary Team Checklist, which is attached to this document as Appendix A. Issues were also identified through a public comment period and subsequent appeals of the predecessor to this document, Gasco 16 Wells DOI-BLM-UT-G010-2013-0132-EA. A public comment period will be held for this EA.

5.4 LIST OF PREPARERS

The specialists listed in the following table(s) assisted in the preparation of this EA.

Table 5-2 BLM Preparers

Name Title Responsible for the Following Section(s) of this Document

Chris Yeager Natural Resource Project Lead Specialist -Chapters 1&2; 3&4 Air Quality & Greenhouse Gas Emissions, Invasive Plants/Noxious Weeds, Soils & Vegetation

Daniel Emmett Wildlife Biologist Wildlife: Migratory Birds(including raptors), Wildlife: Non-USFWS Designated, Threatened, Endangered, Proposed or Candidate

Table 5-2 BLM Preparers

Name Title Responsible for the Following Section(s) of this Document

Jessi Brunson Botanist Plants: Threatened, Endangered, Proposed, or Candidate

Joseph Islas Geologist/Paleontologist Paleontology

Stephanie Howard NEPA Coordinator Quality Assurance

6.0 REFERENCES, GLOSSARY, AND ACRONYMS

6.1 INTRODUCTION

The following sections list the references cited within this document, the terms used and their definitions, and the acronyms used and their meanings.

6.2 BIBLIOGRAPHY

Bibliography

AECOM Environment. (2013). Utah State BLM Emissions Inventory Technical Support Document.

AECOM Environment. (2014). Utah Air Resource Management Strategy Modeling Project Impact Assessment Report.

Alpine Geophysics LLC. (2015). Final Technical Report Far-Field Modeling for the Newfield Exploration Corporation Monument Butte Oil and Gas Development Project Environmental Impact Statement.

Alpine Geophysics LLC and Buys and Associates Environmental Consultants. (2010). Ozone Impact Assessment for GASCO Energy Inc. Uinta Basin Natural Gas Development Project Environmental Impact Statement.

Beatty & Wozniak on behalf of Badlands Production Co. (2016, December 1). Letter RE: Gasco Energy Inc. Uinta Basin Gas Development Project.

Beatty & Wozniak on behalf of Badlands Production Co. (2017, June 1). Letter RE: November 8 2016 BLM correspondance.

Beatty & Wozniak on behalf of Badlands Production Co. (2017, July 26). Letter Re; Gasco Energy Inc. Uinta Basin Gas Development Project - Adaptive Management.

Belknap, J. (2016). Cryptobiotic Soils: Holding the Place in Place. Retrieved from https://geochange.er.usgs.gov/sw/impacts/biology/crypto/

Boden, T. A., Marland, G., & Andres, R. J. (2013). Global, regional, and national fossil fuel CO2 emissions. U. S. Department of Energy, Carbon Dioxide Information Analysis Center. Oak Ridge TN: Oak Ridge National Laboratory. doi:10.3334/CDIAC/00001_V2013

Brunson, J. (2017). Special Status Plant Species Report.

Bureau of Indian Affairs. (2010). Notice of Intent to Prepare an Environmental Impact Statement for Oil and Gas Development Activities on the Uintah and Ouray Indian Reservation, Utah.

Bureau of Land Management. (2012d). Colorado Plateau Rapid Ecoregional Assessment Report.

Bureau of Land Management. (2012e). Greater Natural Buttes Final Environmental Impact Statement.

Bureau of Land Management Utah State Office. (2012). Greater Natural Buttes Air Quality Technical Support Document.

Bureau of Land Management Utah State Office. (2014). Decision SDR UT 14-03 Vernal Field Office Decision Affirmed, Stay Petition Denied as Moot.

Bureau of Land Management Vernal Field Office. (2008). Enduring Resources LLC Big Pack Environmental Assessment.

Bureau of Land Management Vernal Field Office. (2008a). Little Canyon Project Area Natural Gas Development Environmental Assessment.

Bureau of Land Management Vernal Field Office. (2008c). Enduring Resources' Southam Canyon Environmental Assessment.

Bureau of Land Management Vernal Field Office. (2008d). Record of Decision and Approved Resource Management Plan.

Bureau of Land Management Vernal Field Office. (2009 unpublished data). XTO Energy's Hill Creek Unit Infill Development Environmental Assessment and Biological Assessment.

Bureau of Land Management Vernal Field Office. (2012a). Gasco Energy Inc Uinta Basin Natural Gas Development Project Final Environmental Impact Statement.

Bureau of Land Management Vernal Field Office. (2012b). Greater Uinta Basin Oil and Gas Cumulative Impacts Technical Support Document.

Bureau of Land Management Vernal Field Office. (2012c). Record of Decision for the Gasco Energy Inc. Uinta Basin Natural Gas Development Project.

Bureau of Land Management Vernal Field Office. (2013). XTO Energy's River Bend Unit Infill Development Environmental Assessment and Biological Assessment.

Bureau of Land Management Vernal Field Office. (2014). Gasco Production Company Proposes to Drill 16 Gas Wells from Three Existing Well Pads.

Bureau of Land Management Vernal Field Office. (2016). Monument Butte Oil and Gas Development Project in Uintah and Duchesne Counties, Utah Final Environmental Impact Statement.

Bureau of Land Management Vernal Field Office. (February 8, 2017). DOI-BLM-UT-G010-2014-0004- EIS (Greater Chapita Wells Natural Gas Infill Project. Retrieved from https://eplanning.blm.gov/epl-front- office/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite&pr ojectId=37362&dctmId=0b0003e880614243

Bureau of Land Managment Vernal Field Office. (2016a). Notice of Intent to Prepare an Environmental Impact Statement for the Crescent Point Energy Utah Federal-Tribal Well Development Project, Duchesne and Uintah Counties, Utah.

Environmental Protection Agency. (2012, August 16). 40 CFR Parts 60 and 63 Oil and Natural Gas Sector: New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants Reviews; Final Rule.

EPA. (2016, September 12). Environmental Protection Agency Particulate Matter (PM) Basics. Retrieved August 23, 2017, from U. S. Environmental Protection Agency: https://www.epa.gov/pm-pollution/particulate-matter-pm-basics

EPA. (2017, July 7). Energy and the Environment - Greenhouse Gases Equivalencies Calculator - Calculations and References. Retrieved August 23, 2017, from U. S. Environmental Protection Agency: https://www.epa.gov/energy/greenhouse-gases-equivalencies-calculator- calculations-and-references

EPA. (2017a, April 30). Greenhouse Gas Reporting Program (GHGRP). Retrieved August 25, 2017, from U. S. Environmental Protection Agency: https://www.epa.gov/ghgreporting

EPA. (2017b, April 14). Sources of Greenhouse Gas Emissions. Retrieved August 24, 2017, from U. S. Environmental Protection Agency: https://www.epa.gov/ghgemissions/sources- greenhouse-gas-emissions

EPA. (2017c, April 13). Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2015 - Executive Summary. Retrieved August 24, 2017, from U. S. Enviromental Protection Agency: https://www.epa.gov/sites/production/files/2017- 02/documents/2017_executive_summary.pdf

EPA. (2017d, February 14). Understanding global warming potentials. Retrieved August 24, 2017, from U. S. Environmental Protection Agency: https://www.epa.gov/ghgemissions/understanding-global-warming-potentials

Hansen, J., Sato, M., Ruedy, R., Lo, K., Lea, D. W., & Medina-Elizade, M. (2006, September 26). Global Temperature Change. PNAS, 103(39). Retrieved August 24, 2017, from Proceedings of the National Academy of Sciences of the Untied States of America: http://www.pnas.org/content/103/39/14288.full

Herring, D. (2007). Research Features - Earth's Temperature Tracker. Retrieved August 25, 2017, from National Aeronautics and Space Administration - Goddard Institute for Space Studies: https://www.giss.nasa.gov/research/features/200711_temptracker/

IPCC. (2007). Climate Change 2007: Mitigation of Climate Change. (B. Metz, O. R. Davidson, P. R. Bosch, R. Dave, & L. A. Meyer, Eds.) Retrieved August 25, 2017, from Intergovernmental Panel on Climate Change: http://www.ipcc.ch/publications_and_data/publications_ipcc_fourth_assessment_report_w g3_report_mitigation_of_climate_change.htm

J.R. Parrish, F. H. (2002). Utah Partners in Flight Avian Conservation Strategy Version 2.0 . UDWR Publication Number 02-27.

Memorandum Decision and Order, 2:13-cv-01060-EJF (United States District Court for the District of Utah, Central Division October 03, 2016).

Natural Resources Conservation Service. (2003). Web Soil Survey.

Purdue University. (Accessed September 7, 2017). Noise Sources and their Effects. Retrieved from https://www.chem.purdue.edu/chemsafety/Training/PPETrain/dblevels.htm

Second Amended Complaint for Declaratory and Injunctive Relief, 2:13-cv-01060-EJF (United States District Court District of Utah, Central Division November 11, 2014).

Southern Utah Wilderness Alliance. (2014). SUWA vs VFO In the Matter of the Gasco Production Company Proposes to Drill 16 Gas Wells from Three Existing Well Pads EA.

Texas Commission on Environmental Quality. (2016, October 10). Introduction to Air Quality Modeling: Ozone Modeling Procedure. Retrieved from https://www.tceq.texas.gov/airquality/airmod/overview/am_proc.html

Third Amended Complaint for Declaratory and Injunctive Relief, 2:13-cv-01060-EJF (United States District Court District of Utah, Central Division November 11, 2014).

U.S. Energy Information Administration . (2016). Carbon Dioxide Emissions Coefficients. Retrieved from https://www.eia.gov/environment/emissions/co2_vol_mass.php

U.S. Fish and Wildlife Service. (1994). Final Rule: Determination of Critical Habitat for the Colorado River Endangered Fishes: Razorback Sucker, Colorado Squawfish, Humpback Chub, and Bonytail Chub.

UDOGM. (2017a, February). Department of Natural Resources, Utah Division of Oil, Gas and Mining, Summary Production Report by Well, February, 2017. Retrieved from Utah Division of Oil, Gas and Mining: https://oilgas.ogm.utah.gov/oilgasweb/publications/monthly-rpts-by- well.xhtml

Uintah County. (2011). General Plan.

URSC. (2010). Climate change supplementary information report, Montana, North Dakota and South Dakota Bureau of Land Management. Denver Co. URS Corporation, Denver CO.

Utah Department of Environmental Quality. (Accessed September 12, 2017). Uinta Basin Ozone Studies.

Utah Department of Environmental Quality. (Accessed September 7, 2017). Monitoring - Uinta Basin. Retrieved from https://deq.utah.gov/locations/U/uintahbasin/ozone/strategies/monitoring.htm

Utah Division of Oil, Gas, and Mining. (Accessed September 8, 2017). Well Counts. Retrieved from https://oilgas.ogm.utah.gov/oilgasweb/statistics/well-counts.xhtml

Western Regional Air Partnership. (2015). Welcome to the WRAP. Retrieved from https://www.wrapair2.org/

WRI. (n.d.). Understanding the IPCC Reports - Infographic: the Global Carbon Budget. Retrieved August 25, 2017, from World Resources Institute: http://www.wri.org/ipcc-infographics.

6.3 GLOSSARY OF TERMS

ALLOTMENT: An area of land where one or more individuals graze their livestock.

ANIMAL UNIT MONTH: The amount of dry forage required by one animal unit for one month based on a forage allowance of 26 pounds per day.

AUTHORIZED OFFICER: The decision maker who has the delegated authority to for that decision.

BEST MANAGEMENT PRACTICES: A suite of techniques that guide, or may be applied to, management actions to aid in achieving desired outcomes.

CONDITIONS OF APPROVAL: Conditions or requirements under which a decision is made.

ENVIRONMENTAL ASSESSMENT: A concise public document that analyzes the environmental impacts of a proposed action and provides sufficient evidence to determine the level of significance of the impacts.

ENVIRONMENTAL IMPACT STATEMENT: A detailed written statement of environmental effects of a major federal action significantly affecting the quality of the human environment.

FORAGE: Vegetation eaten by animals, especially grazing and browsing animals.

FRAGMENTATION (HABITAT): The break-up of a large land area (such as a forest) into smaller patches isolated by areas converted to a different land type.

IMPACT: A modification of the existing environment caused by an action (such as construction or operation of facilities).

INTERDISCIPLINARY TEAM: Representatives of various disciplines designated as members of a team which was created to prepare an environmental document.

INVASIVE PLANTS: Plants that are not part of (if exotic), or are a minor component of (if native), the original plant community or communities that have the potential to become a dominant or co- dominant species on the site if their future establishment and growth is not actively controlled by management interventions.

MINIMIZE: To reduce the adverse impact of an operation to the lowest practical level.

MITIGATION: Steps taken to: 1) avoid an impact; 2) minimize an impact; 3) rectify an impact; 4) reduce or eliminate an impact over time; or, 5) compensate for an impact.

MONITORING: The process of collecting and assessing data/information necessary to evaluate the effectiveness of a decision or its conditions of approval.

MULTIPLE USE: The management of the public lands and their various resource values so that they are utilized in the combination that will best meet the present and future needs of the American people.

NO ACTION ALTERNATIVE: The most likely condition to exist in the future if current management direction were to continue unchanged.

NOXIOUS WEEDS: A plant species designated by Federal of State law as generally possessing one or more of the following characteristics: aggressive and difficult to manage; parasitic; a carrier or host of serious insects or disease; or nonnative, new, or not common to the United States.

OFF-HIGHWAY VEHICLE: Any motorized vehicle capable of or designed for travel on or immediately over land.

PERIOD OF USE: The time of livestock grazing on a range area based on type of vegetation or stage of vegetative growth.

PERMIT: A revocable authorization to use public land for a specified purpose for a specified period of time.

PLAN OF DEVELOPMENT: A plan developed by a project applicant that specifies the techniques and measures to be used during construction and operation of the project

PROJECT AREA: The area of land potentially affected by a proposed project.

PROPERLY FUNCTIONING CONDITION: A measurement that indicates an area’s ability to produce desired natural resources in a sustained way.

RANGELAND HEALTH: The degree to which the integrity of the soil, the vegetation, the water, and air as well as the ecological processes of the rangeland ecosystem is balanced and sustained.

REVEGETATION: Re-establishing desirable plants on areas where desirable plants are absent or of inadequate density, by management alone (natural revegetation) or by seeding or transplanting (artificial revegetation).

SCOPING: The process of identifying the issues, management concerns, preliminary alternatives, and other components of an environmental document.

SIGNIFICANCE: A determination of the degree or magnitude of importance of an effect, whether beneficial or adverse.

TIMING LIMITATION: A constraint that prohibits specified activities during specified time periods to protect identified resource values.

UTILIZATION: The proportion or degree of current year's forage production that is consumed or destroyed by animals (including insects).

VALID EXISTING RIGHTS: Rights that existed before a change in law, policy, or plan that would not be altered by that change.

6.4 LIST OF ACRONYMS

The below table contains a list of acronyms and their meanings that are frequently used by the BLM and which may have been used in the writing of this document.

TABLE 6-1: ACRONYMS

Acronym Meaning ACEC Area of Critical Environmental Concern ACEPM Applicant-Committed Environmental Protection Measure AO Authorized Officer APD Application for Permit to Drill APE Area of Potential Effect AUM Animal Unit Month BCC Birds of Conservation Concern BLM Bureau of Land Management BMP Best Management Practice CEQ Council of Environmental Quality CFR Code of Federal Regulations CIAA Cumulative Impact Analysis Area CO Carbon Monoxide COA Condition of Approval CWA Clean Water Act DAQ Division of Air Quality DR Decision Record EA Environmental Assessment EIS Environmental Impact Statement EPA Environmental Protection Agency ESA Endangered Species Act FLPMA Federal Land Policy and Management Act FO Field Office FONSI Finding of No Significant Impact GIS Geographic Information System HAP Hazardous Air Pollutants IDT Interdisciplinary Team MBTA Migratory Bird Treaty Act NAAQS National and Utah Ambient Air Quality Standards NEPA National Environmental Policy Act NI Not Impacted NP Not Present

Acronym Meaning NRCS Natural Resource Conservation Service NRHP National Register of Historic Places NSO No Surface Occupancy OHV Off-highway Vehicle Onsite Onsite Inspections per Onshore Order #1 OSHA Occupational Safety and Health Act PAC Protected Activity Center PIF Partners in Flight PUP Pesticide Use Proposal RCRA Resource Conservation and Recovery Act of 1976 RFD Reasonable Foreseeable Development RMP Resource Management Plan ROD Record of Decision ROW Right-of-way SARA Superfund Amendments and Reauthorization Act SDR State Director Review SHPO State Historic Preservation Office SITLA School and Institutional Trust Lands Administration SMA Surface Management Agency SPCC Spill Prevention, Control and Countermeasure SRMA Special Recreation Management Area SUPO Surface Use Plan of Operations TDS Total Dissolved Solids TSS Total Suspended Solids UDOGM Utah Division of Oil, Gas and Mining UDWaR Utah Division of Water Rights UDWR Utah Division of Wildlife Resources USACE United States Army Corps of Engineers USDI U.S. Department of the Interior USFS U.S. Forest Service USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey VRM Visual Resource Management

Acronym Meaning WSA Wilderness Study Area

APPENDICIES

APPENDIX A: INTERDISCIPLINARY TEAM CHECKLIST

INTERDISCIPLINARY TEAM CHECKLIST

RESOURCES AND ISSUES CONSIDERED (INCLUDES SUPPLEMENTAL AUTHORITIES APPENDIX 1 H-1790-1)

Project Title: Badlands Proposes to Drill 16 Gas Wells from Three Existing Well Pads

NEPA Log Number: DOI-BLM-UT-G010-2017-0008-EA

File/Serial Number: UTU-037246, UTU-76034 and UTU-76262

Project Leader: Chris Yeager

DETERMINATION OF STAFF: (Choose one of the following abbreviated options for the left column)

NP = not present in the area impacted by the proposed or alternative actions

NI = present, but not affected to a degree that detailed analysis is required

PI = present with potential for relevant impact that need to be analyzed in detail in the EA

NC = (DNAs only) actions and impacts not changed from those disclosed in the existing NEPA documents cited in Section D of the DNA form. The Rationale column may include NI and NP discussions.

Determination Resource/Issue Rationale for Determination Signature Date Air Quality & Emissions from construction, drilling, and PI Greenhouse Gas production equipment could adversely Chris Yeager 6/8/17 Emissions affect air quality. None Present as per GIS layer review and NP BLM Natural Areas Chris Yeager 6/8/17 RMP/ROD Review Cultural: No cultural resources eligible for inclusion David NI Archaeological into the NRHP were identified within the 6/30/17 Christensen Resources APE of the proposed project. No Traditional Cultural Properties are Cultural: Native identified within the APE. The proposed David NP American Religious 6/30/17 project will not hinder access to or use of Christensen Concerns Native American religious sites. Designated Areas: None Present as per GIS layer review and NP Areas of Critical Chris Yeager 6/8/17 RMP/ROD Review Environmental Concern Designated Areas: None Present as per GIS layer review and NP Chris Yeager 6/8/17 Wild and Scenic Rivers RMP/ROD Review Designated Areas: None Present as per GIS layer review and NP Chris Yeager 6/8/17 Wilderness Study Areas RMP/ROD Review No minority or economically disadvantaged communities or NI Environmental Justice populations would be disproportionately Chris Yeager 6/8/17 adversely affected by the proposed action or alternatives. Farmlands No prime or unique farmlands as NP Chris Yeager 6/8/17 (prime/unique) designated by the NRCS exist in the

Interdisciplinary Team Checklist Page 1

Determination Resource/Issue Rationale for Determination Signature Date proposed project area. Therefore this resource in not present. No fuel management activities planned for Fuels/Fire the project area. The proposed project NI Chris Yeager 6/8/17 Management would not conflict with fire management activities. The 2008 Vernal Field Office Record of Decision and Approved Resource Management Plan lists oil, gas, Gilsonite, oil shale, tar sands, coal and phosphate as valuable leasable minerals in the VFO area. It also identifies locatable minerals such as gold, copper and uranium and mineral materials such as stone and aggregate. Spatial analysis of the proposed Production of natural gas or oil would deplete reserves, but the proposed project allows for the recovery of natural gas and oil per 43 CFR 3162.1(a), under the existing Federal lease. Compliance with “Onshore Oil and Gas Order No. 2, Drilling Operations” would assure that the project would not adversely affect gilsonite, oil Geology/Minerals/Ener shale, or tar sand deposits. Due to the NI Joseph Islas 5/30/2017 gy Production state-of-the-art drilling and well completion techniques, the possibility of adverse degradation of tar sand or oil shale deposits by the proposed action would be negligible. Well completion must be accomplished in compliance with “Onshore Oil and Gas Order No. 2, Drilling Operations.” These guidelines specify the following: … proposed casing and cementing programs shall be conducted as approved to protect and/or isolate all usable water zones, potentially productive zones, lost circulation zones, abnormally pressured zones, and any prospectively valuable deposits of minerals. Any isolating medium other than cement shall receive approval prior to use.3 Approximately 0.5 acres of new soil disturbance would occur during construction until reclamation is successful. Soils would be re-contoured and reseeded during reclamation. Invasive There would be approximately 0.5 acres of PI Plants/Noxious Weeds, initial vegetation disturbance/removal. Chris Yeager 6/8/17 Soils & Vegetation Proposed disturbance would provide suitable habitat for the establishment and spread of non-native plant species. Operator would control invasive species along roads, pipeline corridors, and on well pads, as discussed in Chapter 2.

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Determination Resource/Issue Rationale for Determination Signature Date The proposed area is located within the Vernal Field Office Resource Management Plan area which allows for oil and gas development with associated road and pipeline rights-of-way. Due to the location of the wells pads and the different oil & gas leases being tapped, the well pads will be required to be under ROW. Also, the pipelines and roads are currently in place NI Lands/Access Chris Yeager 6/8/17 & will change from lease authorizations to ROWs as well. Letters were mailed to all ROW holders adjacent to the project area on July 1, 2013. To date one response has been received from Uintah County. No existing land uses would be changed or modified by the implementation of the proposed action; therefore there would be no adverse effect. Lands with Wilderness None Present as per 2008 Vernal RMP NI Chris Yeager 6/8/17 Characteristics (LWC) ROD and GIS layer review The proposed project is located within the Wetlands cattle grazing allotments. Some surface disturbance would occur and would remove forage from livestock use. Disturbed surface would have interim and final reclamation that would return forage to livestock in the future. Rangeland Health monitoring was conducted on Livestock Grazing and NI Wetlands in 2008, and all representative Tracy Hart 12/12/16 Rangeland Health areas were shown to be meeting standards. Cheatgrass is present and canopy cover varies with annual precipitation. There are no inventoried stock watering sites and/or other rangeland improvements that would be impacted within the immediate vicinity of the project. Evaluation of paleontological sensitivity of all geological formations along proposed access roads, pipeline right-of-ways and well sites is requested by the Department of the Interior and the Bureau of Land Management, by the mandates outlined in NEPA, FLPMA, OPLM and the BLM Paleontology Resources Management Manual and Handbook. PI Paleontology Spatial analysis of the Badlands proposed Joseph Islas 10/5/2017 well pad expansion within T9S R19E, Section 29, SENE, NWNE, indicates potential conflicts with paleontological resources. A licensed and permitted Paleontologist is recommended onsite during excavation activities within these areas. New fossil discoveries should facilitate the cessation of all excavation activities, followed by immediate

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Determination Resource/Issue Rationale for Determination Signature Date notification of the VFO officer for mitigation procedures. The following UT BLM sensitive plant species are present or expected in the same or an adjacent subwatershed as the proposed project: Yucca sterilis. • Sandy soils in the vicinity of the proposed project may provide Plants: NI potential habitat for Yucca Jessi Brunson 6/11/17 BLM Sensitive sterilis. However, no populations are present in the project vicinity. Given the exclusively clonal nature of the species, the potential for future establishment is negligible. The following federally listed, proposed, or candidate plant species are present or expected in the same or an adjacent subwatershed as the proposed project: clay reed-mustard (Schoenocrambe argillacea), Pariette cactus (Sclerocactus brevispinus), and Uinta Basin hookless cactus (Sclerocactus wetlandicus). • As the contact zone between the Green River and Uinta Plants: Formations is not present in the Threatened, vicinity of the proposed project PI Jessi Brunson 6/11/17 Endangered, Proposed, there is no potential habitat for or Candidate clay reed-mustard. • As currently understood, Pariette cactus is restricted to the Pariette and Castle Peak drainages and the surrounding benches. Therefore, the proposed project is located outside of the potential range for the species. • The proposed project is located within occupied habitat for Uinta Basin hookless cactus. No riparian sites are inventoried at or in Plants: the vicinity of the project area. Based on NP Chris Yeager 6/8/17 Wetland/Riparian visits to the area and confirmed by Field Office data from GIS information. The proposed project occurs within the Extensive Recreation Management Area (ERMA). Recreation opportunities within the area include but are not limited to hunting, off road vehicle use, hiking, fishing, and floating the nearby Green NI Recreation River. Rene Arce 6/8/17 The topography between the river and the well sites creates a viewing angle which would completely block the view of any drilling rigs and production equipment associated with the project. This topography would also greatly reduce any

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Determination Resource/Issue Rationale for Determination Signature Date noise from the wellsite to the Green River due to attenuation over distance. In addition a sound meter was utilized to read the noise production of the current producing wellsite. The average decibel reading was less than 50 decibels. No lasting impacts to recreation would be anticipated by the implementation of the proposed action. The proposed action is out of line of sight of the river. See Appendix B for photographs from the location, and Appendix C for a more detailed discussion of the viewshed, soundscape, and topography. No impact to the social or economic status of the county or nearby communities NI Socio-Economics would occur from this project due to its Chris Yeager 3/14/17 size in relation to ongoing development throughout the basin. The proposed project occurs within Visual Resource Management Objective Class IV. The objective of Class IV is to provide for management activities that require major modifications to the existing character of the landscape. The level of change to the landscape can be high. The management activities may dominate the view and may be the major focus of viewer attention. NI Visual Resources Rene Arce 6/8/17 However, every attempt should be made to minimize the impact of these activities through careful location, minimal disturbance, and repetition of the basic visual elements of form, line, color, and texture. The proposed project would meet VRM Class IV objectives. The proposed action is out of line of sight or greater than 0.5 mile from the river. Hazardous materials above reportable quantities will not be produced by drilling or completing proposed well(s) or constructing the pipelines/facilities. The term “hazardous materials” as used here means: (1) any substance, pollutant, or containment listed as hazardous under the Comprehensive Environmental Response, Wastes Compensation, and Liability Act (CERCLA) NI Chris Yeager 6/8/17 (hazardous/solid) of 1980, as amended 42 U.S.C 9601 et seq., and the regulations issued under CERCLA; and (2) any hazardous waste as defined in RCRA of 1976, as amended. In addition, no extremely hazardous substance, as defined in 40 CFR 355, in threshold planning quantities, would be used, produced, stored, transported, or disposed of while producing any well.

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Determination Resource/Issue Rationale for Determination Signature Date Trash and other waste would be contained in appropriate containers and then disposed in approved locations. A review of the Field Office GIS layer files Water: and site visit indicates that there are no NI Peter Kauss 6/2/2017 Floodplains HUD inventoried flood plains or streams located in the project area. Compliance with “Onshore Oil and Gas Order No. 2 drilling operations, assures that the project will not adversely affect groundwater quality. Water: NI Spatial analysis of the Badlands proposed Joseph Islas 10/5/2017 Groundwater Quality well pad expansion and drilling within T9S R19E, Section 29, SENE, NWNE, indicates no potential interaction with ground water or transient source protection zones. The proposed construction of the well locations and development of the access roads would alter the topography of the area to a small degree and change surface Water: water flow patterns. It is not expected that NI Hydrologic Conditions surface water or stormwater would be Peter Kauss 6/2/2017 (stormwater) created to the level of concern for Clean Water Act Section 402 (stormwater) review. In addition federal law has exempted energy development from stormwater requirements. The only potential for the proposed project to negatively impact water quality would be increased potential for chemical spills or increased disturbance to surface soils which could cause soil erosion. This would not be expected to occur in a way that would be negative to surface waters. The site is in an upland area and more than 0.25 linear miles from perennial waters. The Green River is on Utah’s 2016 Final Integrated Report regarding 303(d) listing of Impaired Waters as “Insufficient Data” (Utah Department of Environmental Quality Water Quality, 2016) (See Water: Assessment Unit Name “Green River-3”). NI Peter Kauss 6/2/2017 Surface Water Quality Due to topography, the 43-30-9-19 well pad is 0.6 mile upstream from the nearest 100-year floodplain (Sheep Wash), and any spills or sedimentation would have to travel 3.9 miles downstream from the well pad to reach the Green River. Similarly the 31-29-9-19 well pad is 0.4 mile upstream from the Eightmile Flat 100-year floodplain, however due to topography any spills or sedimentation would have to travel 2.8 miles downstream to reach the Green River. Finally, the 42-29-9-19 well pad is 0.9 mile upstream from the Eightmile Flat 100-year floodplain, and due to topography any spills or Interdisciplinary Team Checklist Page 6

Determination Resource/Issue Rationale for Determination Signature Date sedimentation would have to travel 3.4 miles downstream to reach the Green River. Waters of the U.S. are not present per Water: NI USGS topographic map and GIS data Peter Kauss 6/2/17 Waters of the U.S. review. No herd areas or herd management areas NP Wild Horses are present in the project area per BLM Chris Yeager 6/8/17 GIS database. Wildlife: Migratory birds are present. No known PI Migratory Birds Dan Emmett 6/01/17 raptor nests exist within project area. (including raptors) Water would be used for this proposed Wildlife: PI project so sensitive fish species need to be Dan Emmett 6/01/17 Non-USFWS Designated analyzed. Water would be used for this proposed Wildlife: project so T&E fish species need to be Threatened, analyzed. Project is not within sage grouse PI Dan Emmett 6/01/17 Endangered, Proposed habitat. or Candidate Is the proposed project in sage grouse GHMA or PHMA? Yes No None Present as per Vernal Field Office NP Woodlands/Forestry Chris Yeager 6/8/17 RMP/ROD and GIS database

FINAL REVIEW:

Reviewer Title Signature Date Comments

Environmental Coordinator

Authorized Officer

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APPENDIX B: PHOTOGRAPHS

All of the following photos are screenshots of Google Earth aerial photo imagery, with North at the top of the photo unless otherwise noted in the photo’s explanatory text.

Appendix B Page 1

PHOTO 1: EXISTING WELL PADS IN RELATION TO THE GREEN RIVER

Photo 1 shows the three well pads proposed for expansion in relationship to each other and the Green River.

Appendix B Page 2

PHOTO 2: 31-29-9-19 WELL PAD

Photo 2 shows the existing 31-29-9-19 well pad.

Appendix B Page 3

PHOTO 3: 42-29-9-19 WELL PAD

Photo 3 is a BLM 360° landscape photo of the existing wellsite 42-29-9-19. Note the ridge in the center of the photo foreground, which falls between the well pad and the Green River. The center of this photo is facing southeast.

Appendix B Page 4

PHOTO 4: VIEW OF THE GREEN RIVER FROM A RIDGETOP NEAR 42-29-9-19

Photo 4 is a BLM photo taken from the top of the ridge seen in the center of Photo 3 looking southeast toward the Green River.

Appendix B Page 5

PHOTO 5: VIEW OF 42-29-9-19 FROM A NEARBY RIDGETOP

Photo 5 is a BLM photo taken from the top of the ridge seen in the center of Photo 3 looking northwest toward the existing 42-29-9-19 well pad (in the center of the phot indicated by two trucks parked near to a tank.

Appendix B Page 6

PHOTOS 6 AND 7: 42-29-9-19

Photos 6 and 7 are of the existing 42-29-9-19 well pad. Photo 6 is a close-up of the well pad. Photo 7 shows the well pad in relation to the River. Appendix B Page 7

PHOTO 8: 43-30-9-19

Photo 8 shows the existing 43-30-9-19 well pad.

Appendix B Page 8

APPENDIX C: RESPONSES TO THE DISTRICT COURT’S QUESTIONS

This NEPA document has been revised in response to the District Court’s ruling for the Gasco 16 well EA. In particular, the Court asked for additional information regarding the below three questions (Memorandum Decision and Order, 2016).

QUESTION 1: AIR QUALITY IMPACTS – WHY DID THE BLM USE DATA FROM CANYONLANDS NATIONAL PARK INSTEAD OF THE UINTA BASIN?

The Canyonlands data used in the Gasco CMAQ ozone impact assessment was monitoring data. Monitoring data is used to judge the accuracy of the CMAQ ozone model’s forecasts. In traditional CMAQ ozone models, the region being modeled has enough monitors nearby with a sufficiently long monitoring history (at least 3 years4) to judge the adequacy of the model. For the Gasco EIS’s CMAQ model, which was revised in 2010, the Canyonlands National Park monitor data was the closest (approximately 150 km away) rural monitor with a sufficiently long data record to truth the model’s forecasts (Alpine Geophysics LLC and Buys and Associates Environmental Consultants, 2010)(Section 5.0). The Uinta Basin ozone monitors began recording data of a sufficient quality for attainment determinations in 2009 (Utah Department of Environmental Quality, Accessed September 7, 2017). The BLM admits that without local data the model’s estimated ozone levels cannot be validated, however the comparative levels between among modeled scenarios is reliable and useful for determining the change in impacts between modeled scenarios (Alpine Geophysics LLC and Buys and Associates Environmental Consultants, 2010).

Recognizing the limitations of the Gasco EIS CMAQ model, the BLM updated the ozone cumulative analysis in DOI-BLM-UT-G010_2013-0132-EA to incorporate data from the Greater Natural Buttes ozone model (Bureau of Land Management Utah State Office, 2012) and the Greater Natural Buttes Final EIS (Bureau of Land Management, 2012e)(page 22). The Greater Natural Buttes model conducted in 2012, was able to use local monitoring data for its model assessment (Section ES-7). However it also was limited because of the lack of monitored data in the model’s base year (2006), which made it impossible to assess the accuracy of the model’s performance in the base year (Section 5.2.5) (Bureau of Land Management Utah State Office, 2012).

Please note that this Badlands EA incorporates the results of the 2014 Air Resource Management Strategy (ARMS) model (AECOM Environment, 2014), which is the latest ozone model for the Uinta Basin. This is also the first Uinta Basin ozone model for which monitoring data exists for the modeled base year, so the BLM could make a performance evaluation determination (Section 1.3).

The BLM has been incorporating newer models into their analyses rather than revising old models for several reasons.

• First, ozone is a regional issue, not a project specific issue, because oil and gas operations emit ozone precursors, not ozone itself. The emitted ozone precursors must be influenced

4 The data record from the monitor should be “sufficiently long…for attainment designation” (page 31), or at least three years because the ozone NAAQS is a 3 year rolling average. Appendix C Page 1

by environmental factors before they will form ozone. Ozone models by design are cumulative regional models that forecast probable ozone trends under various emission management scenarios. The BLM’s project-specific models, due to limitations in available monitoring data as previously noted, compared one modeled alternative’s impacts against another’s to determine the degree of impact each alternative may have on ozone formation. This alternative comparison data is still sufficient for analysis and decision making purposes related to the degree of impact expected from the implementation of each alternative considered in the Gasco and Greater Natural Buttes EISs compared to the other alternatives. • Second, because the ARMS model was a true regional model (not project specific) with a base year that coincided with area monitoring data, and because the BLM owns the ARMS model platform, the BLM can, and has, rerun the ARMS model to pull out specific projects impacts on the Uinta Basin’s ambient air quality (Alpine Geophysics LLC, 2015) (Section 3.1). These project specific increments are proving to be small. The BLM did this for the 5,750 wells Monument Butte Project in 2015. The BLM ran the Monument Butte model for calendar year 2010, to coincide with the ARMS 2010 base year (Alpine Geophysics LLC, 2015) (Section 2.1.1). The modeling determined that the Monument Butte proposed action contributed, at most, 2% of the total ozone impact (Bureau of Land Management Vernal Field Office, 2016) (Section 4.2.1.1.5). The Gasco project, with its 1,298 authorized wells, is likely to result in a much lower total ozone impact. • Third, CAMx models have been found to more reliably replicate the Uinta Basin’s wintertime ozone formation and timing, among other advantages (AECOM Environment, 2014) (Section 1.2) than the CMAQ model used for the Gasco project, although the accuracy issue was not known at the time the Gasco model was run. • Fourth, the Gasco and Greater Natural Buttes models were set up and run by contractors. Although the BLM approved the protocols prior to the run, and has the results of the runs, the BLM does not actually own either model. Re-creating the contractor’s models would be time-consuming, problematic if not impossible, and expensive. • Fifth, since the running of the Gasco and Greater Natural Buttes models, the EPA has promulgated New Source Performance Standards for the oil and gas industry (40 CFR 60 OOOO) that reduce emissions beyond those forecast by the Gasco and Greater Natural Buttes models, making the model estimates conservative. • Sixth, the Gasco and Greater Natural Buttes models did not model ozone concentrations during the winter months because of model limitations at the time and due to lack of corresponding monitoring data. The ARMS model does include winter ozone model results.

QUESTION 2: NOISE IMPACTS TO RECREATION ON THE GREEN RIVER – WHY WAS THERE NO ANALYSIS OF NOISE IMPACTS?

In this EA, following careful consideration and an additional onsite, BLM specialists have determined that the wells will not impact the recreationists on the Green River.

Due to a 300 foot cliff immediately on the west side of the river, recreationists would have to look backward over their left shoulder up a meandering, unnamed draw (where the cliff is reduced to 200 feet) to even attempt to see the well pad. See the below Google Earth Screenshot 1 showing the existing well pad in relation to the river and the unnamed draw. In this screenshot, the river is Appendix C Page 2

flowing from right to left, and the view is to the northwest. The unnamed draw is in the bottom- center of the screenshot, and the mouth of the draw is the largest green area in the screenshot. A small yellow pin at the top-center of the screenshot identifies the well pad.

Google Earth Screenshot 1: Existing well pad in relation to the Green River and the Unnamed Draw.

Construction Noise Impacts: As described in the Gasco Final EIS (Bureau of Land Management Vernal Field Office, 2012a), construction equipment decibels average 81-88 dBA at 50 feet (Table 4- 82). Construction noise for this well pad would be limited to existing pad expansion, so would be short term (assumed to be one week or less) and would occur only during daylight hours. Due to the 60 foot ridge near the well pad, and the 200 foot cliff near the river, and considering the approximately 0.4 mile distance between the river and the well pad5, construction noise would attenuate to 47-54 dBA (Table 4-82) or less at the river. For comparison, 50 DBA is approximately the noise level of a quiet suburb (Purdue University, Accessed September 7, 2017).

Drilling Noise Impacts: A drilling rig’s dBA are anticipated to be 81-88 dBA at 50 feet, similar to other construction engines described in the Gasco EIS. Drilling noise for this well pad is assumed to occur for at least one week and for up to one month on a 24-hour per day basis. Considering the approximately 0.4 mile distance between the river and the well pad, drilling noise would attenuate to 47-54 dBA (Table 4-82) or less at the river. For comparison, 50 DBA is approximately the noise level of a quiet suburb (Purdue University, Accessed September 7, 2017).

5 The Gasco ROD contains a Condition of Approval that no new well pads be located within line of sight up to 0.5 mile from the centerline of the Green River. This is an existing well pad that is out of line of sight of the river. Appendix C Page 3

Production Noise Impacts: A decibel reading was taken at the existing well pad. The average decibel reading of the producing well was less than 50 dBA. Due to topography and attenuation, production noises would not be perceivable to river recreationists.

Construction and Production Visibility Impacts: Construction equipment is usually less than 20 feet high. A producing well’s tank is typically 20 to 30 feet high. Construction and production facilities would be located behind and below the 60 foot ridge near the well pad, and the 200 foot cliff near the river, so it would not be visible from the river.

Drilling Visibility Impacts: A drilling rig is 150 feet tall or less, and is fully lighted at night for safety purposes. However, as illustrated in Sketch 16, even a 150 foot fully lighted drilling rig would not be visible to river recreationists due to topography. Starting at the river at the mouth of the draw, the topography rises 200 feet over a distance (run) of 258 feet. The topography then rises an additional 90 feet over a 1,769 foot run, where it crests at a ridgetop. The well pad is located an additional 615 feet run beyond, and 60 feet below the ridgetop.

Sketch 1: Areas visible from the Green River

There is about 485 feet of river-width that is in-line with the unnamed draw. As shown in the sketch, even if a recreationist is located somewhere within those 485 feet of river width, and is looking over their left shoulder up the unnamed draw, their viewing angle is so restricted by the 200 foot cliff on the west side of the river that a drilling rig would not be visible. Google Earth Screenshot 2 is a picture of the view up the unnamed draw from the level of the Green River.

6 All distances in this sketch were estimated using GIS measuring tools and USGS topographic maps. Appendix C Page 4

Google Earth Screenshot 2: View up the Unnamed Draw from the level of the Green River.

QUESTION 3: CUMULATIVE IMPACTS ON OZONE POLLUTION – WHY DID THE BLM NOT USE THE UINTA BASIN TECHNICAL SUPPORT DOCUMENT (TSD) FOR THE ESTIMATES OF REASONABLY FORESEEABLE WELL DEVELOPMENT?

Reason 1: The TSD was prepared by the BLM to estimate oil and gas cumulative surface disturbance.

Detailed Explanation: As stated on page 2 of the Greater Uinta Basin TSD: “Data presented in this document account for the use of pad drilling to more accurately estimate levels of surface disturbance… Its scope is limited to those projects within the [cumulative impact area], which are determined to be reasonably foreseeable in the context of the BLM NEPA Handbook… This document deals exclusively with cumulative surface disturbance resulting from past, present, and reasonably foreseeable oil and gas development projects and oil and gas related infrastructure…” (Bureau of Land Management Vernal Field Office, 2012b)(Section 1.2). The TSD did not estimate when those wells would be drilled, and it did not estimate what emissions sources are associated with those wells. In contrast, emission inventories account for emissions in one or more particular years, usually including the baseline year (typically a year in the past for which both monitoring and emission inventory data is available) and a future emission year (to determine the ozone trend response to predicted growth and regulation) (Texas Commission on Environmental Quality, 2016). To get a reasonable emissions accounting, the number of emitting sources operating in those particular years must be known or estimated. The BLM notes that these projects were included in the 2013 ARMS emission inventory for the 2021 future year scenarios, but to do so the BLM had to Appendix C Page 1

make gross assumptions regarding project drilling timing and associated emissions (AECOM Environment, 2013).

Reason 2: The BLM elected to use publically available emission data compiled by regulatory agencies and their partners, and project that data into the future using air-modeling contractor recommended, and subject-matter-expert-reviewed protocols.

Detailed Explanation: A comprehensive emission inventory includes point sources, area sources, and on-road and non-road mobile sources as well as fugitive dust, ammonia, biogenic, fire, and emissions outside the U.S, such as Mexico, Canada, and offshore sources. Given the predominance of oil and gas activities in the Basin, special care was taken to develop a comprehensive oil and gas emissions inventory (AECOM Environment, 2013) (Section 1.2). For example, the ARMS project incorporated several data sources including WRAP emissions inventory products and Preliminary Reasonable Progress cases, Utah Division of Air Quality emission inventories, and other State and Federal emission inventory products (AECOM Environment, 2013)(Section 2.0). Both the Gasco model and the Greater Natural Buttes model relied on five different WRAP inventories (Alpine Geophysics LLC and Buys and Associates Environmental Consultants, 2010) (Section 3.1) (Bureau of Land Management Utah State Office, 2012) (Section ES-1). WRAP’s stated purpose is to understand current and evolving regional air quality issues in the West. WRAP’s stated mission is to develop, maintain, and share databases, support technical analyses, and provide access to data and results from various information sources to produce consistent, comparable, and complete air quality results for use by individual WRAP member jurisdictions and agencies (Western Regional Air Partnership, 2015) . These data sources are appropriate for use in an air model emission inventory because they were developed specifically for future use in air quality modeling efforts.

To account for future development, the emission inventory is “grown” or projected into the future according to protocols that the BLM’s air Resource Technical Advisory Group (RTAG) reviewed and approved. In the Greater Natural Buttes model, four scenarios were modeled, three of which were future year scenarios (Bureau of Land Management Utah State Office, 2012) (Section 1.3). In both the Gasco and ARMS models, five scenarios were modeled, four of which were future year scenarios (Alpine Geophysics LLC and Buys and Associates Environmental Consultants, 2010) (Section 2.0) (AECOM Environment, 2014) (Section 1.3). In the Monument Butte model, only one future year scenario was modeled because it was re-using the ARMS model (Alpine Geophysics LLC, 2015) (Section 2.1.1). As a specific example of how the inventory is “grown”, for the Greater Natural Buttes model the BLM first developed the 2006 baseline scenario from the WRAP III emissions inventory. The baseline scenario accounted for 6,663 existing wells in five counties (Table 3-11). The BLM then developed the 2018 projected baseline scenario by “growing” the WRAP inventories to 2018, supplemented by oil and gas development in the Uinta Basin (Section 3.1). This growth accounted for 17,227 wells in five counties7 (Table 3-11). The BLM then developed the 2017 proposed action scenario by adding the proposed action’s 3,675 wells to the 2018 projected baseline (Section 1.3). Finally, the BLM developed the 2026 optimal recovery alternative by adding the maximum recovery alternative’s 13,446 wells to the 2018 projected baseline (Section 1.3) (Bureau of Land Management Utah State Office, 2012). It is noted that these projects, totaling

7 Regarding the Greater Natural Buttes 2018 projected baseline, the prediction of 17,227 wells in five counties is conservative. As of September 8, 2017, UDOGM reports that the entire state of Utah contains 13,872 total wells that are capable of production (Utah Division of Oil, Gas, and Mining, Accessed September 8, 2017). Appendix C Page 2

21,236 wells, were included in the 2013 ARMS emission inventory for the 2021 future year scenarios (AECOM Environment, 2013).

Reason 3: The TSD was an August 2011 best estimate of reasonably foreseeable future wells that projected the drilling of 25,721 wells over an indefinite future. As of September 2017, the BLM’s best estimate of reasonably foreseeable future wells has decreased from that estimate by more than 11,000 wells.

Detailed Explanation: The TSD was an August 2011 snapshot of the reasonably foreseeable future number of wells (Bureau of Land Management Vernal Field Office, 2012b) (Page 1 Header). If this document were revised today, its projected number of wells would be much lower due to the drop in gas and oil prices that resulted in an economic “bust” in late 2014. For example, Table 4-1 states that the foreseeable BLM wells totaled 25,721. However, the operator or proponent has since dropped several of the pending NEPA projects listed on page 11 that were included in that number. These dropped projects include:

• Enduring Resource’s Big Pack EA (664 wells) (Bureau of Land Management Vernal Field Office, 2008), • XTO’s Little Canyon EA (510 wells) (Bureau of Land Management Vernal Field Office, 2008a), • Enduring Resource’s Southam Canyon EA (249 wells) (Bureau of Land Management Vernal Field Office, 2008c), • XTO’s Hill Creek Unit EA (137 wells) (Bureau of Land Management Vernal Field Office, 2009 unpublished data), and • Uintah and Ouray Tribal Oil and Gas EIS (4,899 wells) (Bureau of Indian Affairs, 2010).

In addition, the number of wells in the following projects have been reduced since that time:

• XTO River Bend EA 2013 Decision Record permitted 200 wells, instead of the 484 Proposed Action wells included in the TSD (Bureau of Land Management Vernal Field Office, 2013). • Gasco Final EIS Record of Decision permitted 1,298 wells, instead of the 1,491 Proposed Action wells included in the TSD (Bureau of Land Management Vernal Field Office, 2012c). • Greater Chapita Wells EIS Proposed Action includes 2,808 wells, instead of the 7,000 wells included in the TSD (Bureau of Land Management Vernal Field Office, February 8, 2017).

One project has increased its numbers over those accounted for in the model:

• EOG’s 22 well North Alger EA was acquired by Koch and the new NEPA decision contains 124 natural gas wells (none of which have been drilled to date) (Bureau of Land Management, 2013).

Only two new large development proposals have been reviewed or received by the BLM VFO since 2011.

• In 2015 the BLM completed the Koch Wild Horse Bench EA, 135 wells (none of which have been drilled to date) (Bureau of Land Management, 2015a).

Appendix C Page 3

• In 2016, the BLM published a Notice of Intent for the Crescent Point Federal-Tribal EIS, a project that proposed up to 3,925 new wells (Bureau of Land Managment Vernal Field Office, 2016a). After the scoping period closed the company put the project on hold and notified the BLM that they would be significantly reducing their proposed number of wells. In June 2017 the company told the BLM and the BIA that they were seriously considering dropping the project altogether. Although the company has not yet communicated to the BLM the final decision to drop the project, the project remains in an indefinite hold.

In all, there has been a total reduction of 9,787 foreseeable wells (46% of the ARMS model’s 2021 wells), with 3,925 additions of which only 237 (the Koch wells) are available for drilling but not implemented by the proponent. As a result of these reductions in foreseeable wells, the TSD now overestimates the future numbers of wells in the Greater Uinta Basin area.

Conclusion: Due to the above considerations, the BLM will continue to use emissions inventories as the basis for our project-specific air quality emission inventories and air quality cumulative impact analysis.

Appendix C Page 4

APPENDIX D: MAPS

Appendix D Page 1

Appendix D Page 2

Appendix D Page 3