Specialist Report 7.0 Water Resources

Oil and Gas Leasing EIS on Lands Administered by the Dixie National Forest

Prepared For: US Forest Service Dixie National Forest 1789 N. Wedgewood Lane Cedar City, 84720

Prepared By:

8160 South Highland Drive Sandy, Utah 84093

October 2008

Table of Contents

7.1 Introduction ...... 1 7.2 Consideration of Available Science...... 1 7.3 Use of a GIS...... 1 7.4 Description of Affected Environment...... 2 7.4.1 Surface Water ...... 2 7.4.2 Groundwater...... 2 7.4.3 Water Quality...... 3 7.4.4 Water Uses...... 4 7.4.5 Pine Valley Ranger District...... 4 7.4.5.1 Surface Water...... 4 7.4.5.2 Groundwater...... 7 7.4.5.3 Water Quality...... 7 7.4.5.4 Water Uses...... 8 7.4.6 Cedar City Ranger District...... 8 7.4.6.2 Surface Water...... 8 7.4.6.3 Groundwater...... 10 7.4.6.4 Water Quality...... 10 7.4.6.5 Water Uses...... 11 7.4.7 Powell Ranger District ...... 11 7.4.7.2 Surface Water...... 11 7.4.7.3 Groundwater...... 12 7.4.7.4 Water Quality...... 12 7.4.7.5 Water Uses...... 12 7.4.8 Escalante Ranger District...... 14 7.4.8.2 Surface Water...... 14 7.4.8.3 Groundwater...... 14 7.4.8.4 Water Quality...... 14 7.4.8.5 Water Uses...... 15 7.5 Impact Analysis ...... 17 7.5.1 Connected Actions ...... 17 7.5.2 Issue Statement ...... 18 7.5.3 Indicators...... 18 7.5.4 Direct and Indirect Effects ...... 19 7.5.4.1 Impacts of Connected Actions By Leasing Option ...... 21 7.5.4.2 Impacts of Connected Actions Under SLT ...... 25 7.5.4.3 Impacts by Alternative ...... 34 7.5.5 Cumulative Effects ...... 39 7.5.5.2 Description of Cumulative Effects Area ...... 40 7.5.5.3 Past, Present, and Reasonably Foreseeable Actions ...... 40 7.5.5.4 Cumulative Effects...... 47 7.5.6 Summary ...... 49 7.6 Compliance with Other Laws and Regulations...... 49 7.7 Forest Plan Consistency Determination...... 49 7.8 Literature Cited...... 50

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page i List of Tables

Table 7.5-1 Summary of Terms used to Describe Effects in the Specialist Report...... 17 Table 7.5-2 Leasing Options Assigned Under Each Alternative...... 20 Table 7.5-3 Acreage of Resource Components under each Leasing Option by Alternative...... 34 Table 7.5-4 Potential Acreage of Surface Disturbance Versus Total Water Resource Component ...... 39 Table 7.5-5 Land Ownership Within Cumulative Effects Area ...... 40 Table 7.5-6 Forest Service Routes Impacting Watershed Resources...... 42

List of Figures

Figure 7.4-1 Water Resources of the Pine Valley Ranger District...... 6 Figure 7.4-2 Water Resources of the Cedar City Ranger District...... 9 Figure 7.4-3 Water Resources of the Powell Ranger District ...... 13 Figure 7.4-4 Water Resources on the Powell Ranger District ...... 16

List of Appendices

Appendix 7A Stipulation Forms Appendix 7B Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page ii

List of Acronyms & Abbreviations

BLM Bureau of Land Management CEQ Council on Environmental Quality CFR Code of Federal Regulations CSU Controlled Surface Use EIS Environmental Impact Statement EPA Environmental Protection Agency LRMP Land and Resource Management Plan NA Not Available NL No Lease NEPA National Environmental Policy Act NSO No Surface Occupancy RFDS Reasonable Foreseeable Development Scenario SLT Standard Lease Terms TDS Total Dissolved Solids TL Timing Limitation USFS US Forest Service

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7.0 Water Resources

7.1 Introduction This Specialist Report has been prepared in support of the Oil and Gas Leasing EIS on Lands administered by the Dixie National Forest, which is an environmental analysis to identify those lands with Federal mineral rights that should or should not be made available for oil and gas leasing. A more detailed description of the Purpose and Need is provided in Chapter 1 of the EIS and a description of the Proposed Action, Alternatives, and leasing options is available in Chapter 2

7.2 Consideration of Available Science The techniques and methodologies used in this analysis consider the best available science. The analysis includes a summary of the credible scientific evidence that is relevant to evaluating reasonably foreseeable impacts. In addition, the analysis also identifies the methods used and references the scientific sources relied on. When appropriate, the conclusions are based on a scientific analysis that shows a thorough review of relevant scientific information, a consideration of responsible opposing views, and the acknowledgment of incomplete or unavailable information, scientific uncertainty, and risk.

7.3 Use of a GIS Alternatives were developed by assigning the leasing options described in Chapter 2 of the EIS and summarized in Table 2.3-1 to resource components using geospatial data. Using a geographic information system (GIS), the spatial distribution of each resource component and associated leasing option were overlaid. The most restrictive leasing option (i.e., NL or NSO) assigned to a particular resource component supersedes any less restrictive options (i.e., CSU or SLT) assigned to other resource components that occur in the same area or site-specific location. For example, where NSO was assigned to an area of high erosion potential that coincides with the habitat of a sensitive wildlife species assigned CSU, the NSO option would be applied to the area common to both of these resources. As a result, multiple leasing options may apply to a resource component, depending upon its location, even if only a single leasing option was specified for that resource component under an alternative. A full range of leasing options was incorporated into the development of alternatives so that the different alternatives would insure that differing levels of protection were addressed for each specific resource component.

Leasing options were applied to geographical areas that represent the spatial distribution of a resource component. However, it is important to note that leasing options are applied to the resource component and not simply to specific geographic areas and if unmapped resource components were identified in the future they would be protected by the same leasing option. Furthermore, the geospatial data used in this analysis is the best GIS data available; however, it comes from multiple sources and was created at varying scales. As a result, it is not assumed that these data are 100 percent complete or that they meet the US National Mapping Accuracy Standard of the Office of Management and Budget. Unless otherwise stated, GIS data was provided by the Dixie National Forest.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 1 7.4 Description of Affected Environment

7.4.1 Surface Water Water resources in the Dixie National Forest occur within one of two geographic regions: the Colorado Plateau (primarily in the Virgin River and Escalante River watersheds); or the (primarily in the Sevier River watershed). The majority of the Powell and Cedar City Ranger Districts are located in the Great Basin, with only very small portions located in the Colorado Plateau. The Pine Valley and Escalante Ranger Districts are more evenly distributed between the Great Basin and the Colorado Plateau. Watershed boundaries for the main drainages (Hydrologic Unit Code 10) on the Dixie National Forest are given in Figures 7.4-1 through 7.4-4. According to Dixie National Forest Geographic Information System data, assuming that each stream on the Dixie National Forest has a 300-foot buffer (which is the narrowest buffer established for various stipulations in the EIS), there are slightly more than 411,000 acres of streams and on the Dixie National Forest. The buffer zone is defined as 300 feet on either side of the stream centerline. The Geographic Information System metadata defines streams as “linear water features” as derived from 1:24,000 US Forest Service Cartographic Features Files and validated by Forest Hydrologists. This category presumably includes perennial and intermittent streams.

Within the Colorado Plateau, several tributaries head in the Dixie National Forest: Beaver Dam Wash, Santa Clara River, Quail Creek, Ash Creek, North Fork Virgin River, and East Fork Virgin River, which all flow to the Virgin River prior to entering the Colorado; Kanab Creek and its tributary Johnson Wash; the Paria River; and the Escalante River. About 16 percent of the Virgin River watershed area is within Dixie National Forest boundaries and the USFS was one of the stakeholders in the recently completed Virgin River Watershed Management Plan (Washington County Water Conservancy District 2006).

Within the Great Basin, Dixie National Forest lands produce flows that are tributary to the Sevier River or that flow to internal playa-type basins within the Sevier River watershed. Shoal Creek, Pinto Creek, Coal Creek, and Parowan Creek all head in the Dixie National Forest, and flow to internal basins located outside of the Forest. Bear Creek, Panguitch Creek, Mammoth Creek, and East Fork Sevier River are tributary to the Sevier River. The Sevier River is noted as being the State’s largest river basin, and one of the Nation’s most highly utilized, with only a small percentage of initial flow reaching the terminal basin (Utah Department of Water Resources 1999). Much of the water that is ultimately consumed is generated on Dixie National Forest lands.

Throughout the Dixie National Forest, a wide range of elevation, topography, geology, and soil types results in diverse hydrologic regimes and water quality. Precipitation also varies widely across the Dixie National Forest, ranging from 10 inches annually in the lower elevations up to more than 40 inches on some of the higher peaks (USFS 1986). At the higher elevations, most precipitation falls as snow, providing the primary source of recharge to groundwater resources and supporting intermittent and perennial stream flows. Intense thunderstorms are common from July through September and produce heavy rains, which can cause flow and flash flooding in ephemeral streams.

7.4.2 Groundwater Groundwater contained in shallow or perched aquifers within the Dixie National Forest is associated with springs, which typically represent discharge of small, locally recharged areas. More extensive regional aquifers are found at depths from several hundred to a thousand feet below ground surface (USFS 1995a). Typical of high elevation lands, much of the Dixie National Forest serves as recharge areas for shallow and regional aquifers, eventually supplying groundwater to the lower

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 2 elevation, off-Forest lands. Groundwater recharge and flow patterns in the region are determined by geology. As described in more detail in a previous Dixie National Forest report (USFS 1995a), aquifers are associated with the Straight Cliffs, Wahweap, Kaiparowits, and Navajo Sandstone Formations, which are Mesozoic sedimentary formations found at depths underlying the High Plateau area of the Dixie National Forest. Of these, the Navajo is the most important regional aquifer. The overlying Tertiary sediments and igneous intrusives are noted (USFS 1995a) as formations with low primary, but high secondary permeability; these geologic units transmit infiltrated precipitation through fractures and solution channels to the underlying Mesozoic sandstones. Figure 7.4-2 shows Dixie National Forest-generated areas described as “lava fields over sensitive aquifers”. These areas are defined in the Geographic Information System metadata as sensitive aquifers defined originally in 1993 in support of oil and gas analysis, but modified dramatically in 2007. These lava fields are primarily associated with the Tertiary volcanics, which have high macro pore space and thus readily transmit infiltrating precipitation (including any surface contaminants). Where they overly a larger aquifer they can serve as a major source of the aquifer’s recharge.

Trans-basin groundwater outflow from the Sevier River Basin to the Colorado River Basin occurs within the Dixie National Forest from the Markagunt and Paunsaugunt Plateaus, with an estimated total annual of about 21,400 acre-feet (Utah Division of Water Resources 1999).

The Proposed Land and Resource Management Plan (2006a) has identified a priority to complete a groundwater resource inventory, including aquifer mapping. Currently, there are no EPA- designated Sole Source Aquifers in the Dixie National Forest (Environmental Protection Agency 2007). The State of Utah does not classify groundwater or specific aquifers as sole source except on an as-needed basis. None of the areas in the Dixie National Forest have been classified to date. However, as described in more detail below, there have been petitions to classify two aquifers in the Pine Valley Ranger District as Class I aquifers, under Utah’s Groundwater Protection Program, as described in more detail below.

7.4.3 Water Quality The Land and Resource Management Plan (LRMP) (USFS 1986) recognizes that sediment represents a general surface water quality concern throughout the Dixie National Forest. Many Forest streams have naturally high sediment concentrations due to erodible soils and exposed sedimentary bedrock. Management activities, including road construction, timber harvest and grazing in riparian areas, are noted in the Land Resource Management Plan as contributing to water quality degradation. In contrast, the chemical quality of most of the Dixie National Forest streams is good.

The Utah Division of Water Quality designates beneficial use classifications for surface waters within Utah, and protects those waters so as to maintain their designated uses (State of Utah 2007). Classes relevant to streams on the Dixie National Forest include: 1C - protected for domestic purposes with prior treatment; 2B - protected for secondary contact recreation such as boating, wading, or similar uses; 3A - protected for cold water species of game fish and other cold water aquatic life, including the necessary aquatic organisms in their food chain; 3C - protected for non- game fish and other aquatic life, including the necessary aquatic organisms in their food chain; 3D - protected for waterfowl, shore birds and other water-oriented wildlife not included in Classes 3A, 3B, or 3C, including the necessary aquatic organisms in their food chain; and 4 - protected for agricultural uses including irrigation of crops and stock watering. Numeric surface water quality criteria are applied to each of these beneficial use classes by regulation at Utah Annotated Code R317-2-14.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 3 Streams and lakes that the State considers impaired, and thus not able to meet their designated beneficial uses, are reported on the State’s 303(d) list, which is updated every other year. Listed water bodies are then scheduled for Total Maximum Daily Load development. Specific Dixie National Forest streams and reservoirs listed on the currently approved 2006 State’s 303(d) list are noted below in the individual Ranger District sections. Generally, however, most assessed water bodies in the Dixie National Forest are not considered impaired; the ones that are, are primarily listed due to phosphorous.

Groundwater quality varies depending upon the aquifer’s geologic properties and the water’s proximity to the recharge area. An assessment of available water quality data found that total dissolved solids (TDS) values within portions of their study area, including parts of the Upper Ash Creek and Navajo/Kayenta aquifers, some of which are on Dixie National Forest lands, ranged from 200 to 300 mg/l (Hansen, Allen & Luce, Inc. 2005). The State has also generally considered the Navajo Sandstone aquifer as being of excellent quality in this area (Utah Division of Water Resources 1993).

7.4.4 Water Uses Surface waters and groundwater produced within the Dixie National Forest are used for various consumptive and non-consumptive purposes, many of which occur outside of the Forest boundaries. In fact, water produced on the high elevation land associated with the Dixie National Forest makes up a large portion of the overall water yield in this part of the State (USFS 1986). Many local communities obtain culinary and agricultural water from sources located on the Dixie National Forest. Extensive water developments such as reservoirs, diversions, and ditches have been constructed on the Forest to support these and other uses. The primary consumptive uses of surface water include off-Forest irrigation and culinary water supply. On-Forest uses include domestic water supplies for campgrounds and livestock/wildlife watering, and non-consumptive in- stream flows for aquatic habitat maintenance and recreation. Documents from recent planning efforts (USFS 2006) state that “Given the numerous and increasing demands for consumptive water use both on and off the Forests, it is difficult to retain sufficient water in streams, lakes, springs, wetlands, and aquifers to fully support ecological uses…”

For most public water systems, the State requires that protection zones be designated through an assessment program for drinking water sources. Transient non-community systems (such as campgrounds) existing before 1993 that have a groundwater source do not have to establish protection zones. The Dixie National Forest relies upon these source protection plans to provide management direction and guidelines for municipal supply watersheds within Forest boundaries. The Dixie National Forest has identified numerous municipal watersheds within its boundaries whose on-forest portions total 53,403 acres. They are shown on Figures 7.4-1 through 7.4-4. The Geographic Information System metadata indicates that these watersheds were delineated for use in oil and gas analysis in 1993, and the data base has subsequently been updated.

7.4.5 Pine Valley Ranger District

7.4.5.1 Surface Water Most of the northern half of the Pine Valley Ranger District is located within the Sevier River Basin, which is part of the Great Basin. This area (Figure 7.4-1) includes the headwaters of Shoal Creek and its tributaries, and the headwaters of Pinto Creek and its tributaries. Shoal and Pinto creeks each flow into the Escalante Desert, where they infiltrate and/or evaporate. The southern half and most of the eastern end of this Ranger District are located primarily within the Santa Clara, Quail,

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 4 and Ash Creek watersheds. These watersheds are tributary to the Virgin River, which is in the lower Colorado River Basin.

Several of these streams have been gaged within the Dixie National Forest by the United States Geological Survey, including South Ash Creek, Leap Creek, and Leeds Creek, which are all tributary to Ash Creek, and the Santa Clara River. The United States Geological Survey (2007) provides this flow data, which is briefly summarized below.

South Ash Creek (draining about 11 square miles) was gaged from 1966 to 1998. Average annual flows ranged from 1.3 to 16 cubic feet per second, with the highest monthly average typically occurring in May. Leap Creek drains about 9 square miles at the gaged location near the Forest boundary. During the seven years of record (1994 to 2001), average annual flows ranged from 0.6 to 5.1 cubic feet per second. This stream seems to peak earlier in the year (generally in March) than other gaged streams in the Ranger District. Leeds Creek has been gaged since 1964 at a location near the Forest boundary; drainage area is about 15.5 square miles at the gage site. Peak flows typically occur in June, and average annual flows have ranged from 2.1 cubic feet per second in 2002 up to 26.5 in 2005. The Santa Clara River has been gaged for many years, beginning in 1959. At the gaging station located in Pine Valley, which drains 18.7 square miles, average annual flows have ranged from a low of 1.2 cubic feet per second in 2002 to a high of 40.9 in 2005. The Land and Resource Management Plan (USFS 1986) notes that the Santa Clara River is one of several Dixie National Forest streams where snowmelt runoff can cause extensive and/or prolonged flooding, particularly in downstream, off-Forest areas. Its peak typically occurs in May.

Though not gaged, estimates of average flow in the Shoal and Pinto Creek watersheds are 17,000 and 16,000 acre-feet per year, respectively (Utah Division of Water Resources 1995).

There are two main reservoirs in this Ranger District, both capturing water from Little Pine Creek, which is tributary to Shoal Creek watershed. Lower Enterprise Reservoir has a capacity of about 2,670 acre-feet and Upper Enterprise Reservoir has a capacity of 9,950 acre-feet (Utah Division of Water Resources 1995).

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Oil & Gas Leasing EIS on Lands Administered by the Dixie National Forest Legend Cities State Boundaries Other Land Administration Watersheds (HUC 10) FIGURE 7.4-1 Minor Roads (1) National Forest System Lands Bureau of Land Management Municipal Watersheds Pine Valley Highways Dixie National Forest National Park Service Ranger District Interstates Wilderness Areas Private

Water Resources Streams State of Utah NOTES Tribal (1) Not all roads are shown. Only some roads Major Streams & Rivers are depicted for orientation purposes. Horizontal Datum = NAD 83 25 February 2008 Coordinate System = Zone 12N 1:320,000 Water Bodies 7.4.5.2 Groundwater The Pine Valley and Bull Valley Mountains within the Pine Valley Ranger District serve to recharge regional aquifers. It has been estimated that most of the 48,100 acre-feet of annual recharge to the Beryl-Enterprise groundwater basin comes from Shoal and Pinto Creeks, whose watersheds are almost entirely within Pine Valley Ranger District boundaries (Utah Division of Water Resources 1995). A number of small springs are located in the higher elevation areas, discharging groundwater from numerous small, perched aquifers. The Land Resource Management Plan (USFS 1986) also notes that there are geothermal waters found at depth within portions of the Pine Valley Ranger District.

In 2005, the Washington County Water Conservancy District petitioned the Utah Board of Water Quality for aquifer classification on a portion of the Ash Creek Basin and a portion of the Quail and Santa Clara basins (Hansen, Allen & Luce, Inc. 2005). With aquifer classification, Washington County Water Conservancy District hoped to provide a means of reasonable protection of these groundwaters. While the requested class designation (Class IA - Pristine Groundwater where the TDS is below 500 mg/l (for the portions of the aquifers within Dixie National Forest boundaries) would not result in mandatory development prohibitions or use restrictions, it would provide an additional management tool in these areas. The aquifer has not yet been classified.

According to the petition, the Upper Ash Creek aquifer includes land in the Pine Valley Ranger District. Within the Ranger District, that aquifer is described as the Tertiary Pine Valley monzonite aquifer, comprised of fractured monzonite, volcanic ashflow, tuff, andesite, volcanic breccia, sandstone, conglomerate, and limestone with an estimated thickness of more than 2,000 feet.

The Extended Aquifer Zone that is associated with the Navajo/Kayenta aquifer addressed in the petition also includes land along the southern boundary of the Ranger District (the Navajo/Kayeta aquifer itself is outside of the Dixie National Forest boundaries). This zone is defined as “…the developable area (slope <30%) north of the exposed Navajo formation where the buried Navajo/Kayenta aquifer is estimated to remain unconfined… these formations are shallow enough in the Extended Aquifer Zone that infiltration of surface water may reach the Navajo Aquifer” (Hansen, Allen & Luce, Inc. 2005).

7.4.5.3 Water Quality There are no streams or lakes in the Pine Valley Ranger District currently listed as 303d impaired (Utah Division of Water Quality 2006). Newcastle Reservoir, just downstream of the Forest boundary, which impounds water from Pinto Creek and Little Pinto Creek, within the Pine Valley Ranger District, is listed as impaired for total phosphorous and dissolved oxygen.

Although not currently listed as impaired, the Santa Clara River has had problems with phosphorus exceedances as recently as 2004 (USFS 2004).

Based on Dixie National Forest GIS data showing areas deemed unstable or subject to high erosion, portions of the watersheds in this Ranger District may be susceptible to sediment-related water quality problems. These areas are primarily along the eastern and southeastern parts of the Ranger District (in the Ash and Quail watersheds), and the parts of the southern Ranger District, within tributaries to Santa Clara River and Beaver Dam Wash.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 7 7.4.5.4 Water Uses The majority of the stream reaches in this Ranger District have beneficial use designations of 2B, 3A, and 4 (State of Utah 2007). In addition to those three classes, the headwaters of Quail Creek are also designated as drinking waters under Class 1C. Both Upper and Lower Enterprise Reservoirs are designated as Class 2B, 3A, and 4 waters. In addition, Lower Enterprise is used for flood control, and Upper Enterprise uses also include municipal and industrial (Utah Division of Water Resources 1995).

Groundwater (with very limited exceptions) and surface water in the Virgin River watershed is considered completely appropriated (Utah Division of Water Resources July 2006).

There are numerous municipal watersheds have been designated on the Pine Valley Ranger District, as shown on Figure 7.4-1. They are: Central, Enterprise, Leeds, New Harmony, Pine Valley, Pintura, Sawyer Springs, and St. George. The area of Forest land they cover, combined, is approximately 27,799 acres. The Utah Division of Water Resources’ most recent Municipal and Industrial Report for the Kanab Creek/Virgin River Basin (July 2006) describes community and non- community water systems in the basin, at least some of which have their source on Dixie National Forest land in the Pine Valley Ranger District. Among these, Pine Valley Irrigation Company (which supplies culinary water to 100 residential connections) is listed as having a total diversion of 79 acre-feet in 2002, predominantly from spring sources, but supplemented by wells, all apparently on- Forest. Their water rights are for substantially more than this volume. Others who likely receive at least a portion of their water from the Pine Valley Ranger District are New Harmony (82 acre-feet diverted in 2004 (Utah Division of Water Resources July 2006)), St. George, and Enterprise. The Municipal and Industrial Report for 1997 (Utah Division of Water Resources, July 1998) apparently pre-dates the Pine Valley Irrigation Company system, and the New Harmony system used 108 acre-feet that year.

7.4.6 Cedar City Ranger District

7.4.6.2 Surface Water The majority of the Cedar City Ranger District is within the Sevier River Basin, contributing flows to the main stem of the Sevier River (Figure 7.4-2). The upper Sevier River and its tributaries (including Asay, Mammoth, Panguitch, and Bear Creeks) flow generally northeast off the Markagunt Plateau to the main stem. The form the northwestern edge of the Ranger District and include several streams than drain towards Parowan Valley and Little Salt , which is a closed subbasin of the Sevier River Basin. The headwaters of Coal Creek are also located in the Cedar City Ranger District; Coal Creek terminates in Cedar Valley. The extreme southwestern portion of the Ranger District includes the headwaters of some first order drainages within the North Fork Virgin River, and the extreme southwest portion includes the headwaters of the East Fork Virgin River. As noted above, the Virgin River is part of the Colorado River Basin.

Stream flows in Cedar City Ranger District are typically snowmelt derived with high spring flows during spring snowmelt and low base flows in the summer and fall. Peak stream flow typically occurs in late spring to early summer as a result of melting snow packs; however, high flows can also be produced by localized heavy thunderstorms (USFS 2006). This is especially true for Center Creek and Ashdown Creek. While flows in Center Creek and Ashdown Creek increase during spring snowmelt, monsoonal rains can often cause peak flows to occur in summer months. The Land Resource Management Plan (USFS 1986) notes that snowmelt runoff can cause more extensive and/or prolonged flooding in Panguitch and Mammoth Creeks than occurs in some of the other streams in this Ranger District.

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k r Original data was compiled from multiple source o F data and may not meet the U.S. National Mapping t s a Accuracy Standard of the Office of Management Zion E and Budget. For specific dates and/or additional National Park digital information, contact the Forest Supervisor, Dixie National Forest, Cedar City, Utah. This map Miles has no warranties to its contents or accuracy. 0 2 4 6 8

Oil & Gas Leasing EIS on Lands Administered by the Dixie National Forest Legend FIGURE 7.4-2 Cities National Forest System Lands Other Land Administration Municipal Watersheds Minor Roads (1) Dixie National Forest Bureau of Land Management Sensitive Aquifers Cedar City Highways Wilderness Areas National Park Service Watersheds (HUC 10) Ranger District Interstates Private Water Resources Streams State of Utah Major Streams & Rivers Tribal Horizontal Datum = NAD 83 NOTES 1:320,000 25 February 2008 Water Bodies (1) Not all roads are shown. Only some roads Coordinate System = Zone 12N are depicted for orientation purposes. Several of these streams have been gaged within the Dixie National Forest by the United States Geological Survey and the flow conditions are briefly described below. Mammoth Creek has been gaged for many years, beginning in 1964. The data shows widely ranging seasonal variation, from an average low monthly flow of 11 cubic feet per second in February, to a high monthly average of 181 in May; the yearly average for this 105 square mile drainage ranged from 8 cubic feet per second in 2002 to 159 cubic feet per second in 2005. Panguitch Creek typically peaks in June, and during twenty years of record, annual average flow ranged from 14 cubic feet per second to 45 cubic feet per second. Stream gaging on Asay Creek, during four years in the 1950s, recorded average annual flows ranging from 20 to 61 cubic feet per second.

The two largest lakes in the Dixie National Forest are found in this Ranger District: Panguitch Lake and Navajo Lake. Navajo Lake is a natural lake formed by a lava flow that cut off the natural surface drainage, and its eastern end has been diked. Red Creek Reservoir is another small impoundment located in the northwestern part of the Ranger District.

7.4.6.3 Groundwater The Markagunt Plateau, in the vicinity of Navajo Lakes supports groundwater not only within the Sevier Basin in which watershed it is located, but also to the Virgin River Basin to the south, via transbasin outflow (Utah Division of Water Resources 1993). According to a previous Dixie National Forest report (USFS 1995a), bedrock solution channels in the Navajo Lakes areas provide a conduit for infiltrated precipitation to be conveyed to either the Sevier or Virgin River watersheds and emerge as springs. Duck Creek, Lower Asay, and Cascade Springs are the three largest of these.

58,585 acres in this Ranger District are on these lava fields where they are overlying a sensitive aquifer, as shown on Figure 7.4-2). As noted above, these are described as areas of high groundwater recharge associated with the Tertiary volcanics that have high macro pore space and thus readily receive precipitation.

The upper Markagunt Plateau also contains springs that are closely tied to the precipitation regime as a function of their recharge area with a moderate storage capacity (USFS 1995a). The Dixie National Forest report also notes that alluvial deposits associated with the larger creeks draining the Markagunt (including Asay, Mammoth, and Bear Valley Creeks) are of sufficient thickness and extent to contain alluvial groundwater. Further, the Land and Resource Management Plan (USFS 1986) notes that there are geothermal waters within portions of the Cedar City Ranger District, particularly in the Navajo Lake area.

7.4.6.4 Water Quality Dixie National Forest water quality monitoring indicates that Bowery Creek, Bear Creek, and Threemile Creek are above the state water quality standard for phosphorous (USFS 2004). Water quality is also declining in Panguitch Lake and Navajo Lake (USFS 1995b). High phosphorous in Bear Creek may be due to its igneous geology; however, high phosphorous in Bowery Creek and especially Threemile Creek appears associated with sediment influxes accompanying high flow events. Panguitch Lake is one of the few water resources on the Dixie National Forest where human-caused water quality degradation has become a chronic problem. Nutrient levels have often exceeded state water quality standards and accelerated eutrophication has been documented, those these conditions have improved in recent years. The State’s Total Maximum Daily Load study for Panguitch Lake was approved by the Environmental Protection Agency in 2004; that document set goals and strategies for total phosphorus reductions.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 10 Streams that may be susceptible to sediment related water quality problems include Coal Creek, Stout Canyon (a small tributary to East Fork Virgin River), and Parowan Creek, as well as numerous other small headwater areas, based upon Geographic Information Service mapping of unstable and high erosion areas.

Noted sediment influxes in Threemile Creek are likely a result of the reduction of riparian vegetation as a result of grazing and dispersed recreational use (USFS 2004). In addition, the loss of riparian vegetation in Threemile Creek and in Bear Creek has led to a decrease in shade levels and a concomitant increase in stream temperatures above State limits. Grazing impacts in Bear Creek has resulted in a widening of the stream channel; which also increases stream temperatures.

Several watersheds in the Cedar City Ranger District have very low baseline amounts of fine sediment due to well vegetated watersheds overlying extrusive igneous rock, sandstone, and limestone. These watersheds include: Mammoth Creek, Panguitch Creek, and Ash Creek (USFS 1995a). Streams from less vegetated watersheds overlying shale and siltstone, such as tributaries to the North and East Forks of the Virgin River, and streams near the Hurricane Cliffs (Summit Creek and Coal Creek) have higher sediment concentrations (USFS 1995a). In Little Creek, percent fine sediment in the stream channel is greater than 25 percent; which may be a result of drought, which has decreased flows and the sediment transport capacity of the stream (USFS 2004).

According to the 2006 303(d) list, there are no streams in this Ranger District currently listed as impaired (Utah Division of Water Quality 2006). Navajo Lake is currently listed as impaired for dissolved oxygen. Red Creek and Yankee Meadow Reservoirs, which drain toward Parowan Valley, are also listed: Red Creek for dissolved oxygen and Yankee Meadow for dissolved oxygen and pH. Panguitch Lake has been removed from the list due to development and approval of the TMDL.

7.4.6.5 Water Uses All of the stream reaches in the Cedar City Ranger District have beneficial use designations of 2B, 3A, and 4 (State of Utah 2007). In addition to those three classes, Duck Creek and stream reaches that are tributary to the North Fork Virgin River are also designated as drinking waters under Class 1C. Both Panguitch and Navajo Lakes are also designated for 2B, 3A, and 4 uses.

Groundwater (with very limited exceptions) and surface water in the Virgin River watershed is considered completely appropriated (Utah Division of Water Resources July 2006)

Four municipal watersheds, shown on Figure 7.4-2, with a total acreage of about 12,867 acres have been designated on the Cedar City Ranger District to protect spring sources that supply municipal culinary water to Brian Head, Panguitch, Summit, and Parowan.

7.4.7 Powell Ranger District

7.4.7.2 Surface Water The Powell Ranger District is almost entirely within the Sevier River Basin. The western portion is comprised of many small tributaries to the main stem of the Sevier, many of which are intermittent or ephemeral (Figure 7.4-3). These include Smith Canyon, Sanford Creek, Sand Wash, Limekiln Creek, Red Canyon, and Hildale Canyon. The eastern portion is located in the East Sevier watershed and includes its headwaters as well as numerous smaller tributary streams such as Cottonwood Creek, East and West Forks Hunt Creek, and Blubber Creek. A very small part of the

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 11 this Ranger District drains south into the Upper Colorado River Basin via tributaries to Paria River, Johnson Wash, and Kanab Creek. The Paria River drains directly to the Colorado River, as does Kanab Creek. Johnson Wash is tributary to Kanab Creek.

Tropic Reservoir is the largest lake in this Ranger District, collecting primarily snowmelt runoff from the headwaters of the East Sevier River. Its capacity is approximately 3,600 acre-feet (Utah Division of Water Quality 2007).

Most of the stream reaches, with the exception of the East Fork Sevier River, are small first-order streams and have not been gaged. The East Fork Sevier River was gaged between 1962 and 1995 at a site near Ruby’s Inn upstream of Johns Valley, where the drainage area is about 72 square miles. According to that data, flows typically peak in May or June (United States Geological Survey 2007). Annual averages ranged from 6 cubic feet per second in 1977 to 45 cubic feet per second in 1980. The Land Resource Management Plan (USFS 1986) notes that snowmelt runoff can cause more extensive and/or prolonged flooding on this river than occurs in some of the other streams in this Ranger District.

7.4.7.3 Groundwater As described in the introduction section, the High Plateaus area, of which the Powell Ranger District is part, provides recharge to several water-bearing regional geologic units comprised of Mesozoic sandstones that are found at depth and overlain by Tertiary igneous extrusives. This Ranger District also provides recharge to alluvial aquifers associated with the off-Forest Sevier and East Fork Sevier River valleys.

Though topographically within the Sevier Basin, the Paunsaugunt Plateau also provides groundwater to the Kanab Creek Basin to the south, via transbasin outflow (Utah Division of Water Resources 1993).

7.4.7.4 Water Quality According to the 2006 303(d) list, some streams in this Ranger District are currently listed as impaired (Utah Division of Water Quality 2006). Included in this most recent list are the tributaries to the Paria River (which are listed for TDS).

Based upon Geographic Information System mapping for the Dixie National Forest, there is a substantial area in the southern half of this Ranger District that is considered as unstable or as a high erosion area; streams crossing this area may be more susceptible to sediment-related water quality problems than areas not so mapped.

7.4.7.5 Water Uses All of the stream reaches within the Sevier Basin portion of the Powell Ranger District have beneficial use designations of 2B, 3A, and 4, as does the portion of the Ranger District within the Johnson Wash and Kanab Creek watersheds (State of Utah 2007). The small portion of the Ranger District within the Paria River watershed is designated as 2B, 3C, and 4.

Groundwater and surface water in the Kanab Creek and Johnson Wash watersheds are considered completely appropriated (Utah Division of Water Resources July 2006).

.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 12 R

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Alton r M NOTES C National Mapping Accuracy Standard i r (1) Not all roads are shown. ll e of the Office of Management and Bud- C e Only some roads are depic- r e k get. For specific dates and/or additional e ted for orientation purposes. k digital information, contact the Forest (2) Grand Staircase-Escalante Supervisor, Dixie National Forest, Cedar National Monument Managed Miles City, Utah. This map has no warranties by the Bureau of Land Mana- 0 2 4 6 8 to its contents or accuracy. gement. A single municipal watershed (6,471 acres within the ranger district) has been designated on the northeast corner of the Powell Ranger District, to protect municipal culinary water for Antimony (a very small portion of Antimony’s municipal watershed is located on the Escalante Ranger District). This watershed is shown on Figure 7.4-3.

7.4.8 Escalante Ranger District

7.4.8.2 Surface Water The majority of streams on the Escalante Ranger District drain into the Escalante River, which is in the Upper Colorado River Basin. Tributary streams that head in this Ranger District include Deer Creek, Boulder Creek, Birch Creek, Upper Valley Creek, and Pine Creek (Figure 7.4-4). In addition, some areas in the southwest corner of the Ranger District drain into the Paria River drainage, and some streams on the northwestern side of the Ranger District drain into the East Fork Sevier River While some of these stream reaches have been gaged at various times, most have fairly short periods of record. Pine Creek is an exception, as it has been gaged essentially continuously since 1951 (United States Geological Survey 2007). Pine Creek flow typically peaks in May and is at its lowest during the winter months. Annual averages vary widely, and have ranged from 0.77 cubic feet per second in 1955 to 13.4 cubic feet per second in 2005.

There are numerous small lakes and reservoirs in this Ranger District, including Jacob’s Valley and Roundy Reservoirs. Jacobs Valley Reservoir was constructed in 1911 and has a capacity of 1,967 acre-feet (Utah Division of Water Resources 2000). It is located in the Pine Creek watershed. Also in the Pine Creek Basin, Roundy Reservoir is much smaller, with a capacity of 150 acre-feet (Utah Division of Water Resources 2000).

7.4.8.3 Groundwater As described in the introduction section, the High Plateaus area, of which the Escalante Ranger District is part, provides recharge for several water-bearing regional geologic units comprised of Mesozoic sandstones that are found at depth and overlain by Tertiary igneous extrusives. Outcrops of the Straight Cliffs Aquifer (which includes the Straight Cliffs, Wahweap, and Kaiparowits Formations) occur in the Paunsagaunt Plateau within the Escalante District. A 1995 Forest Service report (USFS 1995a) notes that the Aquarius Plateau, including the Escalante Ranger District lands overlies highly transmissive igneous rock, which results in a large percentage of precipitation leaving the Plateau as groundwater in bedrock aquifers. There is essentially no alluvial groundwater found in this Ranger District.

7.4.8.4 Water Quality Water quality monitoring by the Dixie National Forest in portions of the Escalante River drainage indicates that phosphorous is above State limits in both the East and West Forks of Boulder Creek (USFS 2004). From the few samples taken it is difficult to establish a link to the source; however, igneous geology in the area could lead to high background phosphorous levels (USFS 2004). In addition, many of the more western streams draining into the Escalante River drainage have higher sediment concentrations due to less vegetated watersheds overlying shale and siltstone (USFS 1995a).

According to the 2006 303(d) list, some streams in this Ranger District are currently listed as impaired (Utah Division of Water Quality 2006). Included in this most recent list are some reaches of the Escalante River and its tributaries, which are listed for temperature downstream of the Forest boundary. The Escalante River Watershed Water Quality Management Plan (Millennium Science

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 14 and Engineering, Inc. 2005) is awaiting Environmental Protection Agency approval; that document assessed reaches of Birch Creek and North Creek, including stretches within the Dixie National Forest, as potential contributors to the downstream temperature problem.

7.4.8.5 Water Uses The stream reaches within the Sevier River watershed and the majority of the Escalante River portions of the Escalante Ranger District have beneficial use designations of 2B, 3A, and 4 (State of Utah 2007). The small portion of the very southeast corner of the Ranger District within Alvey Creek that is tributary to the Escalante River, and the Paria River watershed in the southwest portion is designated as 2B, 3C, and 4. Jacob’s Valley Reservoir is protected under 2B, 3C, 3D, and 4 classes of beneficial use.

Three municipal watersheds (with a total on-forest acreage of about 6,266 acres) have been designated on the Escalante Ranger District, to protect spring sources that supply municipal culinary water to Antimony (only a very small portion of the total is located in this Ranger District), Escalante and Boulder (Figure 7.1-4).

Boulder Creek provides water for a run-of-river hydropower electric generation plant, as a non- consumptive use (though this water is used consumptively for irrigation downstream of the power plant).

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 15 Fremont River Ranger District K Pole Can yon Antimony k (Administered by Fishlake National Forest) Antimony Cree ek le Cre Hood A

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S e C C P k C er k r W e B e D e r L e a o e Ranger District e k r e u k e k D S l C C d a e r y ek e e Cre n e w k Co Nor e r th r C d reek k C s k i e C Cre r ing C r Spr P lue e F B r k r ee i e e Cr n e od k e wo e e on D k ott e k C ep C C r Li ree e ttle k e Cot k tonw ood Boulder Cr eek Tw L itch k Powell ell C o S ree e s k t a R e C ock C Ran r re n ree ch e d k C C Ranger ree k k C h Box Death-Hollow W t r hite C r e reek o e ek Birch Creek Wilderness k District re N ct C spe k Pro r H o o F r s t P e H 12 C s i (! n r a e a e e l l k E C C r r e e e e k Oil & Gas Leasing EIS on Lands Administered k by the Dixie National Forest Cen Sweetwat ter er Creek Cre B ek ir So ch ut C FIGURE 7.4-4 h re Cr e C ee k la k Escalante y C re k e Cree Ranger District k Corn Dry Creek Water Resources k ree (!12 y C Horizontal Datum = NAD 83 err Ch Coordinate System = Zone 12N 1:320,000 25 February 2008 ek Clay Cre Escalante A llen C Pine Lake reek Legend Left H and Allen Cities Watersheds (HUC 10) Creek Minor Roads (1) Municipal Watersheds

ek Highways Other Land Administration re 12 C (! y Bureau of Land Management le Streams al V er Major Streams & Rivers GSENM (2) pp Bryce U Canyon Water Bodies National Park Service eek w Cr National Willo Grand Staircase- National Forest System Lands Private Park Escalante National Monument Dixie National Forest State of Utah Tropic Wilderness Areas Tribal Canaan Creek Glen Canyon Fishlake National Forest National Original data was compiled from multiple source NOTES data and may not meet the U.S. National Mapping R(1e) Ncort ealla rotaiodsn ar eA shroewan. Accuracy Standard of the Office of Management Only some roads are depic- and Budget. For specific dates and/or additional ted for orientation purposes. 12 (2) Grand Staircase-Escalante (! digital information, contact the Forest Supervisor, National Monument. Managed Miles Dixie National Forest, Cedar City, Utah. This map by the Bureau of Land Mana- 0 2 4 6 8 has no warranties to its contents or accuracy. gement. Cannonville Henrieville 7.5 Impact Analysis This section describes the changes to the human environment that could occur as a result of implementing the Alternatives outlined in Chapter 2. Changes to the human environment are described using the terms “effect” and “impact,” which are synonymous under NEPA. Effects may be direct, indirect, or cumulative in nature.

• Direct effects occur at the same time and place as the action. • Indirect effects are reasonable foreseeable effects that occur later in time or are removed in distance from the action. • Cumulative effects are those impacts to the environment that result from the incremental impacts of an alternative when added to other past, present, and reasonably foreseeable future actions.

In this Specialist Report, the direct and indirect effects of an action are discussed in combination for the affected resource components in Section 7.5.4. Cumulative effects are described by alternative in Section 7.5 .5. For water, three resource components were identified for analysis: (1) streams and lakes; (2) lava fields over sensitive aquifers; and (3) municipal watersheds. These resource components were defined above in Section 7.4.1, 7.4.2, and 7.4.4, respectively.

NEPA requires that effects in an EIS be discussed in terms of context and intensity. In this Specialist Report, context refers to the location, type, or size of the area to be affected relative to each resource component. Intensity refers to the severity or level of magnitude of impact. In this Specialist Report, the intensity of effects are defined as Major, Moderate, Minor, or Negligible. In addition, the duration of effects can be temporary, short-term, or long-term. These terms are described more specifically in Table 7.5-1.

Table 7.5-1 Summary of Terms used to Describe Effects in the Specialist Report Attribute of Effect Description Quality Beneficial An improvement of current conditions. Adverse A degradation of current conditions. Magnitude Negligible No measurable change in current conditions. (Intensity) Minor A small, but measurable change in current conditions. Moderate A moderate, measurable change in current conditions. Major A big, easily measurable change in current conditions. Duration Temporary Short-lived (i.e., during construction). Short-term 10 years or less. Long-term More than 10 years.

Impacts were assessed in light of the best available scientific information, including papers, reports, literature reviews, review citations, peer reviews, science consistency reviews, results of ground- based observations, etc.

7.5.1 Connected Actions The Alternatives described in Chapter 2 do not authorize surface disturbance. Therefore, environmental impacts in this Specialist Report are analyzed as connected actions. Connected actions are defined by the Council on Environmental Quality (CEQ 1508.25) as actions that: 1) automatically trigger other actions which may require environmental impact statements; 2) cannot or

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 17 will not proceed unless other actions are taken previously or simultaneously, and; 3) are interdependent parts of a larger action and depend on the larger action for their justification. Forest Service regulations (36 CFR 228.102(c)(4)) require the Forest Service to consider the subsequent actions that would be authorized by a lease as connected actions. Connected actions are the basis of the environmental analysis from which leasing decisions would be made. In this Specialist Report, connected actions are the predicted disturbance from oil and gas leasing activity, which is discussed in Chapter 2 of the EIS.

7.5.2 Issue Statement Post-leasing activities could impact flow and water quality of surface streams and groundwater, sensitive aquifers, developed water systems, floodplains, wetlands, and riparian areas.

This Specialist Report addresses flow, water quality, sensitive aquifers, and developed water systems. A separate Specialist Reports addresses floodplains, wetlands, and riparian areas.

KEY FACTORS Drilling and completion activities are regulated by the State of Utah and include Best Management Practices such as casing and dry hole plugging designs intended to protect groundwater resources. Unexpected failure of these mitigation measures could lead to potential impacts to groundwater.

Construction and operation of oil and gas facilities such as power lines, drill pads, drill rigs, roads, and production facilities could increase the potential for surface and mass-erosion, which could contaminate surface water. Water from exploration and production facilities could become contaminated with chemical pollutants used at the facilities and flow from the disturbed areas to adjacent surface waters. Streams, lakes, and reservoirs are particularly vulnerable to pollution and increased sediment loads. Culinary and irrigation water sources are of special concern.

Diversion of water from surface water sources for drilling and production could reduce flows. Production of water in conjunction with oil and gas production could decrease underground sources of surface waters. Either of these outcomes could reduce support of Beneficial Uses protected under the Clean Water Act, and could impact public and private water rights downstream.

7.5.3 Indicators In this Specialist Report, effects will be described using indicators developed for each resource. Using the environmental conditions described in Section 7.1 as a baseline, indicators are used to predict or measure change in a resource related to effects of the Alternatives. Some indicators are quantitative and measure effects based on numerical thresholds, while other indicators involve a narrative to qualitatively describe any changes relevant to baseline conditions.

MEASUREMENT INDICATORS • Utah State Beneficial Use Classification • Narrative description of potential sources of pollutants, the types of pollutants, and the effects to surface waters and groundwater • Potential for effects to numerical water quality standards and groundwater classifications • Potential to increase sediment in surface streams • Relative potential for increasing miles of roads within municipal watersheds and lava fields over sensitive aquifers • Narrative description of potential effects to surface water flow and groundwater availability • Potential to reduce flow of developed water sources including their recharge areas and well or spring collection galleries

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 18 • Acres of disturbance as compared to available • Narrative description of water rights potentially impacted

7.5.4 Direct and Indirect Effects Under Alternative B, C, D, E it is assumed that activities described under the Reasonable Foreseeable Development Scenario (RFDS) would occur. Activities described under the RFDS include 60 to 120 acres (depending on Ranger District) of overland travel associated with seismic surveys, 80 to 330 acres (depending on Ranger District) of land clearing surface disturbance associated with road and pad building for exploration wells, and 254 acres of land clearing surface disturbance for a production field. The locations of these activities are not yet known.

As will be discussed throughout this section, surface water resources could be affected by any land disturbing activity and/or spills of polluting substances. Sediments are one result of land disturbing activity, and if they enter streams, they could have effects on water quality and channel stability, which in turn could affect fisheries and downstream users. If spills of polluting substances and chemicals were to reach streams, the level of significance of these events would depend on the composition and amount of contaminant entering the stream as well as the conditions of the stream.

Impacts to water associated with overland travel (seismic activities) result from the fact that runoff rates and erosion can increase when soils are compacted. The crushing of vegetation associated with overland travel could reduce this effect because the vegetation would still intercept precipitation and could also provide a protective cover for the soil. These impacts would likely range from negligible to minor and would be short term.

Impacts to water associated with land clearing result from the fact that runoff rates and erosion are typically increased when vegetation is removed and soil is exposed and possibly compacted. In the case of exploration disturbances, this type of impact would be short term, because reclamation activities would return the ground surface and the vegetative cover to a stable condition. Reclamation sufficient to provide erosion protection can be expected to take one to three growing seasons. Prior to reclamation, the level of impact to surface water resources could vary from negligible to major depending upon the site-specific circumstances associated with the exploration location (i.e. how close to surface water the disturbance is, what the ground slope is where the disturbance occurs, and the erosion characteristics of the disturbance). In the case of a production field, impacts to water associated with land clearing would be of the same type as for exploration, but could be increased in scale because of a greater percentage of land cleared within a given watershed, and increase over time because the production field operations would last for a greater time. However, in both exploration and production instances, increases in runoff rates may not result in realized increases in stream runoff or sedimentation because of sediment and runoff control best management practices that would retain runoff. To help ensure that this is the case, Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements include requirement E that dictates site drainage including berming and ditching criteria.

Some types of potential impacts to water do not have anything to do directly with overland travel or land clearing. Instead, they have to do with the potential pollutants that may be inadvertently released during overland travel or during the construction or use of the cleared land. For example, these types of impacts would include leaking fuels from vehicles or equipment; spilling fuels or chemicals during exploration or production, or improperly managing storm water runoff such that it contacts pollutants stored on drill sites and storage yards, etc. These types of impacts to water resources would likely be short term, and could be minor to major. This subject, as well as other

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 19 details for impacts to water resources is discussed in greater detail throughout the following subsections.

Table 7.5-2 lists the leasing options assigned to each water resource component under each alternative. Descriptions of leasing options (and associated impacts on water) are described in Section 7.5.4.1. Each assigned leasing option would either allow or restrict certain oil and gas activities (described under the RFDS) whenever the applicable resource component occurs on the Dixie National Forest.

Table 7.5-2 Leasing Options Assigned Under Each Alternative Resource A B C D E Lava Fields over Sensitive NL NSO NSO NSO SLT Aquifers (58,585 acres) Streams and Lakes (including NSO a 300-foot buffer NL 500 ft buffer NSO CSU SLT (410,550 acres), NL 300 ft buffer 300 ft buffer except for 300 ft buffer Alternative B which includes a 500-foot buffer (662,835 acres) Municipal Watershed NL NL NSO CSU SLT (53,403 acres)

As will be seen throughout the following sections, impact analysis of the Reasonably Foreseeable Development Scenario is difficult for these three water resource components and difficult for water resources in general. First, without knowing exactly where a specific action might occur, there is uncertainty saying what the level of impact to water resources might be – it could range from minor to major depending upon many factors such as proximity to water, soil type, geology, season, etc. Second, assuming that all of the environmental protection measures that the Dixie National Forest would have at its disposal (including at the least, the Dixie National Forest Conditions of Approval, and Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements), even under SLT, are met, as well as all of the other requirements of the various Clean Water Act laws, and assuming that spills or failures of environmental protection measures rarely occur, impacts to water resources could most likely be considered to be negligible or minor, however there is uncertainty in this prediction. There is at least some un-definable probability that spills or failures in environmental protection measures could occur, with consequent impacts to water resources ranging from negligible to major. The history of oil and gas activities throughout the county indicates that even though improvements have been made in procedures, chemicals used, and environmental protection, unforeseen spills, ruptures, and leaks, can occur and result in impacts to water. The recent track record of oil and gas companies may be quite good, but it is not perfect – nor can it be expected to be perfect in the future. In part, limiting the period in which construction activities could occur, by avoiding wet weather periods as required by Condition of Approval No. 20.D, would help to reduce the chance that an accidental event would result in a water quality impact. Last, the level or potential for impacts to water resources is not so much tied to acreages, but often more tied to proximity of the activities to water sources; while the former is available conceptually in this impact analysis, the latter is not available because specific site locations for future oil and gas activities are not known.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 20 7.5.4.1 Impacts of Connected Actions By Leasing Option This section describes the leasing options that would be applied to the identified water resource components in various combinations under the various alternatives. Timing Limitations are described here, though that leasing option is not applicable to water resources, because that option does have the affect of being in place for some areas of the identified water resource components due to overlap with other resources and their leasing options. Also see Appendix 7A for stipulation forms for NSO and CSU, by relevant resource component. Leasing options would dictate the conditions under which impacts from connected actions (described under the RFDS) may occur. Impacts from connected actions under each leasing option are discussed in this section; impacts under SLT are described more extensively in Section 7.5.4.2. Impacts to water considering leasing action overlaps (i.e. overlaps with more restrictive leasing options assigned to other resources) are discussed in Section 10.5.4.3 (Impacts by Alternative).

NOT AVAILABLE (NA) NA applies to lands that are not administratively available for leasing and includes Wilderness Areas and Brian Head Ski Resort. No oil and gas leasing would occur in these areas. Further, there would be no effects to wetlands, stream channels, floodplains, or riparian areas occurring within these areas. This leasing option does not apply directly to any of the water resource components under any alternative.

NO LEASE (NL) NL applies to lands where no new leases would be authorized. No disturbances associated with oil and gas leasing would occur on lands with an NL stipulation. Where NL applies to lava fields over sensitive aquifers, the intent is to prevent the direct effects associated with pollutants that may escape and mix with groundwater, thereby potentially degrading these aquifers over the long term; aquifer cleanup would be difficult and costly. Where NL applies to streams and lakes, again the intent is to prevent the direct effects associated with pollutants (including sediment) entering these surface water features and the associated indirect effects on aquatic habitat and human uses. Last, where NL applies to municipal watersheds, the intent is to provide the maximum level of protection possible to these water sources that are used for community water supplies. This is needed because any sediment production and/or release of potentially polluting materials to municipal water supplies could be considered significant due to the fact that these areas are managed for culinary water production.

Under Alternative A, NL would apply to lava fields over sensitive aquifers, streams and lakes, and municipal watersheds. Specifically, since there would be no new leases on lava fields over sensitive aquifers, streams or lakes, or municipal watersheds, none of these water resource components could be directly impacted under the NL option. In addition, NL would also apply to other resource components on adjacent lands, so there would be no new leases available anywhere on the Dixie National Forest, thus there would be no new potential to impact water resources either due to direct disturbances or actions on the water resources component lands or due disturbances or actions on adjacent lands that might cause impacts to water resource components.

Under Alternative B, there would be an NL option on municipal watersheds and an NL option for within 300 feet of streams and lakes. Regarding municipal watersheds, under the NL option, there would be no potential for impacts from leasing activities.

Regarding a 300-foot buffer with NL for streams under Alternative B, this would reduce the likelihood of impacts when compared to options where activities could occur closer to streams. Because there would be no culverts or in-stream activities associated with road building or pipeline

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 21 installation, sediment loading and channel instability potential would be greatly reduced. Any increased erosion from construction outside of the buffer would have a greater chance of settling out prior to entering the channel, and thus have a lesser chance of affecting the stream. Similarly, the potential for a spill to enter a stream, either due to a leak in production facilities, or a vehicle accident, would be reduced. Again, the 300-foot buffer would allow some distance for trapping or containing spilled or leaked materials prior to their reaching a stream either via surface flow or infiltration. However, a large or unattended release would still have the potential to enter a stream, depending upon the circumstances. In general, with proper implementation of BMPs applicable to road and well pad construction, the impacts would likely range from negligible to moderate and be short term for exploration activities and long term for production facilities. As described in more detail elsewhere in this report, the further a disturbance or activity is away from a stream, the lower the likelihood that a water quality impact would occur. Thus, a 300-foot buffer with no disturbances or activities in it is more protective than no buffer or a narrower buffer. As shown on the maps, there is a vast network of streams across the Dixie National Forest; even though many of those streams are small, eliminating these areas from potential disturbances greatly reduces the potential area of direct effect.

NO SURFACE OCCUPANCY (NSO) With the exception of seismic activities, NSO would prohibit occupancy or use of the land for oil and gas activities (e.g. construction of well pads, central tank batteries, access roads, pipelines, power lines, and other linear structures). This stipulation is intended to prevent the most likely sources of pollutants and water-related impacts – those related to surface occupancy – from occurring, while still allowing certain uses, which have some, but more minimal potential for impact.

NSO would apply directly to lava fields over sensitive aquifers under Alternatives B, C, and D. As noted above, this stipulation would not allow those areas to be used or surface-occupied by well pads, roads, pipelines or similar features; however it would allow for directional drilling into the NSO area from outside its boundaries and would allow for seismic activities. As noted and discussed further elsewhere in this report, roads represent one of the greatest potentials for sediment impacts and other water quality impacts due to spills; therefore eliminating this potential impact for lava fields over sensitive aquifers by having an NSO stipulation greatly reduces the impact potential as a whole for this resource component. It would also greatly reduce the potential for most other spills not related to roads to occur or reach these areas.

The intent of applying NSO to lava fields over sensitive aquifers is to prevent the direct effects associated with road building sediments and pollutants that may escape and mix with groundwater, thereby potentially degrading these aquifers over the long term; aquifer cleanup would be difficult and costly. In most cases, sediments, and even small amounts of pollutants, would not present a risk of contamination to groundwater. However, lava fields over sensitive aquifers are unique in that they have extremely high permeability and macro pore spaces. The pore spaces are large enough that any pollutants, including sediment, can rapidly enter the aquifer. Although an oil play is unlikely to occur near lava fields, there is a potential for impacts to groundwater if directional drilling were to occur beneath lava fields over sensitive aquifers. In general, if there is a risk of groundwater contamination, wells would be cased to prevent contamination of groundwater. However, if wells were improperly cased or sealed, leaking of contaminants into the aquifer could occur. The potential for this is very small since proper casing of wells is well regulated. If contamination were to occur, the impacts would be long term and would range from moderate to major. Although some roads currently cross lava field over sensitive aquifers and travel access is allowed, the potential for a spill to occur in large enough proportions from existing approved access is much less than the potential scale of spills from commercial oil and gas drilling or production activities.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 22 There would also be an NSO stipulation for municipal watersheds under Alternative C, again meaning that these areas could not be used or surface-occupied, but directional drilling could again occur under these areas. As described above for lava fields over sensitive aquifers, this stipulation would essentially eliminate the greatest potential for impact – roads. It would also greatly reduce the potential for non-road-related spills. Further, directional drilling would not be likely to impact municipal watersheds. In sum, application of an NSO stipulation for municipal watersheds essentially affords the same protections as NL. This means that, for this resource component, there is only the slightest theoretical difference in the potential for impact, and very little real impact difference between NSO and NL.

As mentioned above, and as shown on the maps, there is a vast network of streams across the Dixie National Forest; even though many of those streams are small, eliminating these areas from potential disturbances greatly reduces the potential area of direct effect; the NSO stipulation as applied to Alternative B for streams and lakes would do just that. For Alternative C, however, that may not be the case. This brings up a finer point of difference between these two alternatives in regard to the NSO stipulation for streams and lakes.

The NSO stipulation as applied to the streams and lakes resource component would be slightly different for Alternatives B and C. For Alternative B, the NL option applies to a 300-foot buffer on either side of a perennial of intermittent stream channel and an NSO applies to a 500-foot buffer, meaning that there would be no surface disturbance anywhere within the 500-foot buffer on either side of a perennial or intermittent stream channel, but within the 200 feet in between the 300-foot distance and the 500-foot distance, there could be directional drilling. As described above for 300- foot NL buffer, this greatly reduces the chance for in-stream water quality impacts. The application of these combined NSO and NL options for a 500-foot buffer is essentially as protective as NL over the entire buffer, but less protective of stream water quality than NSO applied to a larger area. For example, the streams located in a municipal watershed would be better protected than streams outside of the municipal watershed because in the former case, there would essentially be a NSO buffer zone comprised of the entire watershed, and not just the 500 feet adjacent to a stream.

Under NSO as applied to Alternative C for a 300-foot buffer along streams, roads and pipelines and similar linear features would be allowed as perpendicular features. This means that, for example, a culvert could be installed to cross a stream, but a road could not be constructed alongside the stream within that 300-foot distance. The intent of this type of NSO is to open up more land to access, while still providing some protection to water resources. This reduces, but does not eliminate, the amount of disturbed area that could be in close proximity to a stream. However, in some areas and circumstances, even small amounts of resulting sediment production could be considered significant. As a result, the impacts of stream crossings could range from minor to moderate and could be short and long term. As described elsewhere in this report, roads are one of the greatest potential impacts to stream water quality due to sediments and to accidental spills. This application of NSO would be less protective than the NSO under Alternative B for streams.

CONTROLLED SURFACE USE (CSU) CSU provides for controlled but generally allowed surface use on all or portions of a lease. Operations would be held to special operational constraints that may otherwise exceed the mitigation provided by SLT, regulations, and operating orders. Under Alternative D, a CSU leasing option would be applied within municipal watersheds and to the 300-foot buffer around waterbodies located outside of a municipal watershed. The CSU applied to the 300-foot buffer would allow surface use or occupancy that does not involve blading or other mechanical disturbance of the soil surface. Platforms or other stabilizing structures would need to be used if facilities such as well pads or portions of roads need to extend into these areas. The exception would be for

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 23 perpendicular stream crossing as explained above for NSO with Road Crossings. The intent of this CSU is to allow operators some flexibility in the location of facilities, while preventing the impacts to water resources associated with surface disturbance and erosion. Given the level of restrictions, this CSU would provide similar protection to water resources as NSO. However, as facilities may be placed in increased proximity to water, there would be an increased potential for spills. As described in Section 7.5.4.2, the impacts of a spill would range from negligible to major, and generally be long term.

A separate CSU leasing option would be applied to municipal watersheds under Alternative D. The CSU would allow surface use and occupancy, with the caveat the proposed activities would be delayed until the Dixie National Forest finds the lessee has sustained its burden of proof and that the proposed activities do not create a foreseeable and substantial risk of pollution to the municipal watershed. This CSU is intended to decrease the risk of pollution described in Section 7.5.4.2 by adding additional oversight. As risks are inherent to all types of oil and gas activity, some potential still exists. However, it is anticipated that the additional oversight should decrease the impacts described in Section 7.5.4.2 to negligible to moderate. Impacts could be short or long term.

TIMING LIMITATIONS (TL) TLs are seasonal restrictions that prohibit surface use during specified time periods to protect identified resource values. This leasing option does not apply to the operation and maintenance of production facilities unless the findings of analysis demonstrate the continued need for such mitigation and that less stringent, project-specific mitigation measures would be in-sufficient. TLs are not directly applicable to water resource components, but they have been applied to numerous other resource components (where they have varying specific meanings and timeframes), and thus can affect some areas of water resource components due to overlap with those TL-affected resources.

STANDARD LEASE TERMS (SLT) Under SLT (BLM 2006), existing laws and regulations would be applied to oil and gas activities. Anywhere within the leasehold is available for placement of a road and drill site. At a minimum and according to the standard surface use requirements attached to any lease, SLT would allow operations to be moved up to 200 meters (656 feet) and be delayed for up to 60 days if the authorizing officer deems it necessary to protect a resource. These allowances could be used to avoid certain areas close to water or sensitive land that would be susceptible to water impacts.

In general, SLT provides an adequate level of protection to most resources due to the well- developed operating procedures set forth by the BLM and the USFS. Agencies would ultimately have a central role in determining where oil and gas activities may occur under SLT, and due to the mandates inherent in their missions to protect natural resources, will not allow oil and gas activities to adversely impact resources despite the absence of more restrictive leasing options in place to protect them. Following standard operating procedures, well sites are selected in level areas, off narrow ridges, and set back from steep slopes. Well locations constructed on steep slopes cost more to construct, maintain, and reclaim and [are known to] result in greater resource impacts (BLM and USFS 2006).

Under Alternative E, SLT would be applied on all water resources components (lava fields over sensitive aquifers, streams and lakes, and municipal watersheds) including within Inventoried Roadless Areas if a less conservative Roadless Area Conservation Rule were to be adopted. This would increase the likelihood of occurrence for all of the impact types discussed elsewhere in this report. However, the terms within the Dixie National Forest Conditions of Approval, and Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements, as well as other resource protection measures, and the need to comply with the

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 24 Clean Water Act would serve to reduce the chance for impacts, and their occurrence would most likely be due to some accident or unanticipated event. However, because there would be some potential for accidents or unanticipated events to occur, SLT is less protective than NSO or NL.

7.5.4.2 Impacts of Connected Actions Under SLT The impacts of connected actions under the RFDS are discussed in this section, assuming no restrictions or stipulations on oil and gas activities other than those listed on BLM form 3100-11 (SLT, BLM 2006), the Gold Book (BLM and USFS 2007), and the “Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements” (Appendix 7B). They are also discussed in this section as separate from leasing options. Leasing options would dictate the conditions under which the following impacts from connected actions may occur, and are discussed in relation to the connected action impacts (Impacts by Alternative).

SEDIMENT-RELATED WATER QUALITY IMPACTS In general, surface disturbances that include vegetation removal, soil compaction, earthwork, and natural drainage pattern alteration often result in increased upland erosion. Some of the eroded material has the potential to enter streams, raising sediment concentrations and turbidity and altering bed substrate. These types of direct surface disturbances can also increase localized runoff, which too may result in erosion and sedimentation. If erosion, sedimentation, and/or increased runoff occur over a great enough area, over a long enough time period, or in close proximity to streams, water quality can be adversely impacted. Generally speaking, the direct ground-disturbing activities associated with exploration or well field development activities (well pad construction, road construction or improvement, and drainage control features such as culverts or ditches) would increase the potential for sediment-related, adverse water quality impacts. This potential is discussed in more detail in the following paragraphs.

Both the quantity of the eroded material itself and the percentage of the material that makes its way to a stream are wholly dependent upon very site-specific factors including: soil characteristics, ground slope, distance between the disturbance and the stream, and vegetation characteristics of the area between the disturbance and the stream, among others. For example, in certain areas, site conditions might tend toward producing minor surface erosion from sheet flow, which typically would produce small-sized sediment particles. If this were combined with either a long, low- gradient distance (or a shorter distance with a stringer wetland) between the source and the stream, these particles would likely be deposited before reaching the channel and thus would not impact water quality. In other areas, site conditions could produce gullies or mass earth movements with a direct connection to a stream system, thus adversely impacting water quality by adding large amounts of sediment with varying particle sizes to a stream. Generally speaking, activities on steeper slopes would be more likely to erode, transport sediment to a stream, and take longer to reclaim, all combining to have a greater potential impact to surface water resources.

Once sediment has reached a stream, the distance and timing of its downstream progression is highly dependent upon factors such as particle size, flow patterns, stream velocity, bed substrate, and channel morphology, among others. For example, fine sediments derived from shales and clays are likely to remain suspended in all but the slowest-moving water, temporarily causing increased turbidity and sediment concentration, but not necessarily destabilizing the stream channel, which could lead to longer term adverse water quality impacts. Particle sizes added en masse to a stream might initially be deposited rather than transported, with finer sizes being gradually winnowed away over time, or the deposit might move downstream as a slug of sediment as a result of a single large storm event. A stream with a high percentage of pools might serve as a reservoir for sediments, temporarily mitigating the water quality impact, but over the long term altering the channel morphology. As these few examples show, the variations in sediment transport

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 25 are endless and thus difficult to predict, especially for general types of disturbances in unknown locations.

Introduction of sediments into a stream can also have side effects, including plugging culverts, initiating channel instability, raising water temperature, and increasing salt load, among others.

Localized runoff that can cause adverse sediment-related water quality impacts is similarly site- specific. Construction activities in areas with steep slopes and less permeable soils often result in increased runoff from uplands. On a local level, and/or where the impacted acreage represents a higher percentage of the watershed area, the increased runoff volumes could trigger gully development and/or accelerated stream bank erosion in receiving streams. It could also exacerbate instability in previously existing deteriorated or vulnerable streams. Both would have adverse water quality impacts due to sediments. Construction activities in other areas (those with flatter gradients, more permeable soils, or lower natural drainage density, for example) might only negligibly increase local runoff, with consequent negligible sediment impacts. Additionally, SLT would allow activities within riparian areas. If surface disturbance eliminates the ability of the riparian area to act as buffer, eroded materials could be more likely to enter streams, water velocity could increase, and bank instability could result.

The type of construction activity also dictates the potential for localized increased runoff. Well pads are typically bermed and thus do not release the increased runoff off-site. Roads with their attendant diversion ditches and culverts often alter natural drainage patterns, concentrate flows and redistribute runoff, often increasing it on a local level. Inadvertent releases of produced water would also function as locally increased runoff on a very short-term basis, with a similar potential for sediment-related impacts (as well as other water quality impacts depending upon its constituents, described later in this section).

For all of these reasons given above, it is only possible to estimate adverse sediment-related water quality impacts from the connected actions on surface water in this Specialist Report in a general manner. Although they would most likely be temporary or short-term in duration, their magnitude could range from negligible to major, depending upon the location of the activity, the effectiveness of the environmental protections measures (including, but not limited to, the Dixie National Forest Conditions of Approval, the Gold Book (BLM and USFS 2007), and Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements), and the occurrence of accidental releases. Therefore, this issue would need to be assessed more thoroughly during the NEPA process for specific proposals. However, two main points can be made: (1) in general, the closer a ground disturbance is to a stream system, the more potential it has to contribute sediments to that stream reach and to downstream reaches via sediment transport, thus adversely affecting water quality; and (2) roads are known to be one of the greatest contributors of sediment on national forests.

While these direct ground-disturbing activities are not normally considered to have the potential to affect groundwater quality by introduction of sediments, there are some unique areas on the Dixie National Forest in which this potential could occur. These areas are where lava flows outcrop. These outcrops are highly permeable and essentially provide a direct pathway between the ground surface and groundwater. Road construction or pad development in these locations would likely require importing fill material, which could erode and be conveyed into the subsurface of the lava flows adversely affecting the permeability and geochemistry of the flow paths in the basalt lava rock. This impact would be site-specific, minor and long-term, depending upon the exact circumstance. In some areas of the Cedar Ranger District, these lava fields overlie sensitive aquifers and these areas have been singled out as a resource component.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 26

In addition to the location of the activity, the type of activity also affects the potential for adverse sediment-related water quality impacts, as described above. For the types of activities considered as connected actions in this Specialist Report, the following comparisons can be made. Assuming equivalent site baseline conditions, seismic exploration has the least potential for adverse sediment-related water quality impacts, followed in approximate order of increasing sediment- related impacts by well pads, central production and substation facilities, power lines, pipelines, and last (and thus greatest potential for adverse sediment-related water quality impacts), access roads.

One measure by which roads and their potential to cause sediment-related water quality impacts can be assessed is road density. For wildlife uses on the Dixie National Forest, a density of 2 miles of road per square mile is considered dense and problematic from a wildlife standpoint. Using a similar measure to qualitatively assess road-related impacts to water resources, it can be said that a developed well field may likely exceed that density, and thus be more likely to cross some threshold of sediment potential than an exploration program under SLT, whereby exploration is more likely to be spread out. For lack another measure, the same density (two miles/square mile) applied to forest watersheds shows that a number already approach or exceed this density. Construction of new roads in these watersheds may result in a tipping point type effect, with resultant greater levels of channel erosion/instability that might otherwise be expected. In part, the Dixie National Forest Dixie Oil and Gas Construction and Operating Standards and Well Site Design Requirements include: requirements to use existing roads where feasible (operating standard No. 3); siting guidance for new roads (operating standard No. 4) to reduce water impact potential; and instructions on stream crossings such as use of perpendicular alignments.

Drill pads would be expected to be much less likely to contribute sediment. Normally, they would be sloped toward a reserve pit located near the cut/slope, trapping most sediment on site. However, erosion could still occur on the fill slopes below the drill pad, contributing to sediment which may or may not reach streams.

Fugitive dust from vehicles, roads, and other bare soil areas can be deposited on stream or lake surfaces, thus adding fine particles which could become suspended in the water column. This could increase turbidity. While a reasonable potential, this impact is not likely to be substantial, even where the sources are near to the water resource.

The likelihood that these ground-disturbing activities would cause direct or indirect adverse sediment-related water quality impacts is greatest during and immediately after construction. Over the short term, erosion would tend to naturally stabilize in most instances. Exploration activities themselves would also occur within a limited time frame, and successful reclamation would also reduce the potential for longer-term adverse sediment-related surface water quality impacts.

The environmental protection measures that would apply to the various types of activities have been designed to reduce the potential for adverse sediment-related water quality impacts. Section 2.6 in the EIS describes these to include: the BLM’s Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development; the Forest Service Region 4 Oil and Gas Roading Guidelines; Dixie National Forest Best Management Practices in place at the time of lease approval; the Dixie National Forest Conditions of Approval, the Gold Book (BLM and USFS 2007), and Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements. For example, Condition of Approval No. 7 requires operators to implement erosion control measures and No 36A requires that water be controlled to reduce erosion and sedimentation. In general, the actual acreage of disturbance associated with any given well pad is relatively small, compared to the natural setting, and acreage associated with linear features such

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 27 as roads and pipelines would be dispersed. This would also tend to reduce the potential for adverse sediment-related water quality impacts. Assuming that these environmental protection measures are properly implemented, that disturbance is distributed over multiple watersheds or sub-watersheds, and that individual project NEPA analysis is done correctly, adverse sediment- related water quality impacts would likely be negligible or minor for the majority of leases, at least as a result of the normal course of events. If the above assumptions are not met, impacts could be greater.

Also see measurement indicators 2 and 4 below.

OTHER WATER QUALITY IMPACTS In addition to adverse water quality impacts related to sediment, contamination of surface water or groundwater could potentially occur due to inadvertent releases of pollutants from activities such as:

• Spilling fuels, lubricants, or liquid hydrocarbon product from mobile equipment; • Spilling or releasing drilling fluids, including chemical products used during drilling or stimulation of production zones; • Improperly casing or plugging wells; and • Mis-handling produced water.

Fuels and lubricants would be used in all aspects of exploration and production. They are used in vehicles of all types and in equipment such as pumps, drill rigs, compressors, and the like. Further, a developed oil field would be producing liquid oil, transporting it by pipeline and storing it temporarily at the well field, and conveying it by trucks from the production field out of the Forest to market. While these hydrocarbons would not intentionally be released in such a way as to enter streams or groundwater, accidental releases could occur. The releases could be from field maintenance of vehicles or equipment; on-site fueling; transfer to and from storage facilities; and vehicle or equipment accidents. Secondary containment at tank batteries reduces the impact of the release. The use of catch basins at all points where lines are open or valves are in place, as required at production facilities by Condition of Approval No. 2, would also reduce the impact of those types of releases. Further, Condition of Approval No 20 requires lines crossing streams to be double-cased and buried at least eight feet below the surface, and would provide a measure of protection to surface waters. Depending upon the quantity of the release and its proximity to a stream, failure of secondary containment could adversely impact surface water quality. The degree of impact to surface water could vary from negligible up to major, but in most cases it would be short-term. If the release were to occur over a lava field overlying groundwater, and in particular a lava field overlying a sensitive aquifer, it could adversely impact groundwater quality. While the degree of impact would vary depending upon the quantity released, the impact could be long-term if not immediately mitigated.

Drilling fluids, including chemical additives, which can contain toxic substances, would be used during exploration well drilling. During production field development these fluids would be used both for drilling production wells and a produced water disposal (injection) well. Normally these fluids would be contained in lined reserve pits on site, and properly disposed off site after drilling is complete. The Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements include, as requirement F, several criteria for reserve pits to ensure that they function properly. However, their inadvertent failure and release of fluids, or an operator’s failure to follow protocol for off-site disposal, could result in short-term surface water quality impacts, the degree of which would depend upon the quantity released and the proximity of the release to a stream. The inadvertent release of these fluids on a lava field could have a longer-term impact on groundwater if it could not be immediately mitigated. Similarly, transporting any of these

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 28 chemicals to the drill sites could result in accidental releases, which could impact either surface water or groundwater, again depending upon quantity and proximity, potentially affecting any of the three resource components to a degree ranging from negligible to major. Condition of Approval No. 3 dictates how many chemical containers can be stored on site at any one time, and could limit the potential for an accidental release due to improper handling.

While drilling and completion activities must use casing and dry hole plugging designs that are intended to protect groundwater resources, their unexpected failure could lead to potential impacts to groundwater quality. This could also occur due to failure to isolate usable groundwater from other water-bearing zones with naturally poor quality water, potentially degrading a higher quality groundwater by introducing lower quality water. Such problems would be difficult to discover, particularly in plugged and abandoned wells or in production wells where there are no operational symptoms of the problem. This type of impact, if it occurred, would likely be long-term and range from moderate to major.

Water is produced as a natural byproduct of both exploration and production wells, but mostly during production. Due to the geologic occurrences that are the focus of oil and gas drilling, this produced water often contains high concentrations of TDS. Because of its quality, the produced water typically cannot be discharged to surface waters, particularly within the Colorado River Basin where the Colorado River Salinity Control Forum has placed salt load limits on any water discharges. Thus, the produced water is normally temporarily held in storage tanks at the production facilities and then either disposed on site through a permitted underground injection well to a deep formation, or is trucked off site for disposal. As required by the Dixie National Forest Condition of Approval No. 5, all vessels that are part of a production facility, and that contain production fluids of any type must be diked to provide secondary containment; this would minimize releases to surface waters due to an accidental release of such fluids. Off-site disposal of produced water can also involve temporary storage in tanks and re-injection in a permitted well but can also take place in permitted, lined evaporation ponds. This EIS has assumed that one injection well and no large evaporation ponds would be utilized. Routine handling of produced water would not result in impact. Any release of production water would be accidental, however it could impact water quality depending upon the quantity released and its proximity to surface waters. Again, this type of direct impact could range from negligible to major, and would most likely be temporary for streams.

There is also the concern that the reinjected produced water could migrate into groundwater associated with other formations and degrade its quality. While the configuration hydrogeologic characteristics may differ, a study done by the USGS (Steiger 2007) found no evidence that this has occurred in the Altamont-Bluebell oil and gas field in the Uintah Basin.

The environmental protection measures that would apply to the various types of activities have been designed to reduce the potential for adverse water quality impacts. Section 2.6 in the EIS describes these to include: the BLM’s Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development; the Forest Service Region 4 Oil and Gas Roading Guidelines; Dixie National Forest Best Management Practices (Best Management Practices) in place at the time of lease approval; the Dixie National Forest Conditions of Approval, the Gold Book (BLM and USFS 2007), and Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements. Assuming that these environmental protection measures are properly implemented, adverse water quality impacts would likely be short-term and negligible to minor for the majority of leases, at least as a result of the normal course of events. If the above assumptions are not met, impacts could be greater.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 29 As noted above, recent history indicates that the track record of the oil and gas industry is good, but not perfect, and it cannot be expected to be perfect. For the purposes of this document, it can probably be assumed that under SLT, at least one if not more, of the following could occur

• a hydrochloric acid spill as a result of hauling or use as a fracturing fluid; • a hydrocarbon spill, due to a truck overturn or a line rupture, or similar event; • a magnesium chloride (or other dust suppressant) release due to either a truck or tank spill or to over-application during dust control; • overflow of a reserve pit containing produced water; and/or • leak or other failure of an improperly placed, designed, or maintained reserve pit liner, resulting a release of drilling fluids.

If one or more of these events -- or similar events -- occurred, it may or may not result in an impact to water resources depending upon the volume, location, proximity to waters, etc. However, it can be stated that the likelihood is greater under SLT than other leasing options with more restrictive environmental protection measures. Further, if one of these events occurred, requirements for reporting, including but not limited to those in Condition of Approval No. 35E, would help to mitigate impact to water resources.

Also see measurement indicators 2 and 3 below.

IMPACTS TO WATER USAGE DUE TO WATER QUALITY IMPACTS Introduction of sediment, fuels, lubricants, product oil, drilling fluids, or produced water to surface and/or groundwater systems that alter water quality, as described above, could also affect down-gradient water users. The primary human users of Dixie National Forest water resources are downstream irrigators, and culinary users both on-forest and downstream. Livestock, wildlife, and aquatic life also depend on Dixie National Forest surface water. Such water uses are often driven by the natural water quality and the reliability of the source. Water quality in the State of Utah is protected based upon its defined Beneficial Use classification, and in turn, this classification provides an indication of the types of uses a given stream segment may have (Utah Annotated Code R317-2-13).

For example, some streams on the Dixie National Forest are Beneficial Use Class 4, which means that they are protected for agricultural uses including irrigation of crops and stock watering. Class 4 streams have a TDS water quality standard for irrigation of 1,200 mg/L. If an accidental release of briny production water were to enter this stream, it would represent a violation of the water quality standard and could also temporarily affect an irrigator’s ability to use this water source. If sediment- induced water quality impacts were to occur on this stream, there would not be a standards violation (there are no applicable sediment standards for Class 4 waters), but there could be an impact to an irrigator if channel instability resulted in a physical impact to the diversion structures.

Some streams on the Dixie National Forest are Beneficial Use Class 3, which means that they are protected for fish and other aquatic life. Many metals have water quality standards for Class 3 streams, some of which could be introduced in advertent chemical spills. This might only have short-term impacts on water quality, but could have a longer-term impact on aquatic life if concentrations were high long enough to adversely impact aquatic species populations. Sediment impacts, which are not limited by water quality standards, could have long-term or short-term impacts on aquatic life and upon humans who use those streams for fishing (see the wildlife and recreation technical reports).

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 30 Degradation of municipal or culinary water supplies could occur if their source-water were impacted. Beneficial Use Class 1 streams are those that are protected for such domestic purposes; however within the Dixie National Forest, all such streams are in subclass 1C, which presumes that prior treatment is needed. There are numerous municipal watersheds throughout the Dixie National Forest. Since potential usage impacts to those features due to water quality impacts is not common to all action alternatives, the discussion on that subject occurs in a later part of this Specialist Report.

In regard to groundwater supplies, there are not many currently used wells on the Dixie National Forest. However, there is at least some potential that fresh water aquifers could be affected by drilling, if proper procedures were not followed or if accidents occur. These effects could be due to: cross-contamination between aquifers; altered flow patterns as a result of withdrawal and reinjection of water into the wells; and contamination from drilling fluids and other materials. Exploration activities would be less likely to result in this occurrence than production wells because they would be plugged sooner. Natural gas wells would be less likely to result in cross contamination-related impacts than oil wells, due to the nature of the produced material and due to the more likely proximity of saline groundwater. Further, as noted above, a USGS study (Steiger 2007) found no evidence that migration of reinjected produced water has contaminated other aquifers in the Altamont-Bluebell oil and gas field in the Uintah Basin.

For the same reasons that there is uncertainty in determining location and level of impact to water quality in general, impacts to any given water use or users are also uncertain at this level of analysis. The environmental protection measures (including, for example, the Dixie National Forest Conditions of Approval, the Gold Book (BLM and USFS 2007), and Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements) that would apply to the various types of activities have been designed to reduce the potential for adverse water quality impacts, and would thus reduce the potential for impact to water users. However, the site-specific NEPA analysis that would occur for any given future exploration or development proposal would need to fully analyze this potential effect.

Also see measurement indicators 1, 3, and 9 below.

IMPACTS TO WATER QUANTITY During exploration and production, water is primarily used to facilitate drilling and control dust. Water for either of these uses cannot be withdrawn from a nearby stream or from a groundwater source without approval of the State Engineers Office. Further, Condition of Approval No. 36B prohibits use or taking of water off Forest lands without prior approval. Exploration activities generally require a limited amount of water for a limited time period, and the operator purchases water from an existing legitimate water right holder. It could be purchased from an off-site source such as a city well, or from a water right holder who temporarily defers their use of the stream for irrigation or stock watering. Therefore, there would be no net change in diversion of water from surface water or groundwater sources due to exploration water needs.

Larger quantities of water are needed during well field development than during exploration, due to a larger number of wells and a greater road network. For these longer-term road uses, a measure such as magnesium chloride application to roads for dust control is often used to reduce the need for frequent water application. It is likely that well field development and production activities would similarly purchase water from existing water holders, as described above for exploration. There is essentially no surface water and very little groundwater available for appropriation in any of the basins within the Dixie National Forest, so operators would likely purchase water that has already

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 31 been appropriated, thus it is assumed that there would be no net change in diversion of water from surface water or groundwater sources.

During production, water is often removed from the wells in conjunction with the oil and gas (more so with gas than oil). Such produced water would be re-injected on site into the same formation from which it was obtained, or would be trucked off site for disposal by injection or evaporation. Produced water is typically poor quality and obtained from great depth; thus is not generally considered to be usable groundwater or to support wetlands, stream base flow, aquatic, wildlife, or human uses.

Therefore, the effects to the quantity of water resources, including quantities associated with the three identified components, would be expected to be negligible.

Also see measurement indicators 6 and 7 below.

MEASUREMENT INDICATORS Measurement Indicator #1: Utah State Beneficial Use Classification. Beneficial Use classifications are set by State law at Utah Annotated Code R317-2-13; they dictate the water quality standards of a given stream or stream segment. An activity or an activity-caused impact would not change the Beneficial Use class of a given stream – these classes are not subject to change simply because of either a potential water quality impact or an existing water quality impact. Activities that would degrade water quality such that the existing beneficial uses could not be accommodated cannot, by law, be permitted; inadvertent impacts must be mitigated or the activity must cease if beneficial uses are not accommodated. This indicator would thus not be impacted by any post-leasing activity under any alternative and is not discussed further under the various alternatives in Section 7.5.4.3.

Measurement Indicator #2: Narrative description of potential sources of pollutants, the types of pollutants, and the effects to surface waters and groundwater. The potential sources of pollutants, the types of pollutants, and the general effects to surface waters and groundwater were described above. All action alternatives would have at least some potential for some adverse effect on water quality. As noted above, whether these pollutants adversely affected water quality and by how much and for how long is uncertain to determine because specific activity locations are not known and these impacts would vary by site location and conditions. Thus, future project-specific NEPA analyses would need to be relied upon for further analysis of this measurement indicator. However, the impacts would be negligible to minor as long as the existing environmental protection requirements, such as those outline in the Dixie National Forest Conditions of Approval, the Gold Book (BLM and USFS 2007), and Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements, are properly implemented and no accidents occur. There may be slightly more or less potential for pollutants to impact water quality, depending upon the alternative, and these differing potentials are described qualitatively in Section 7.5.4.3.

Measurement Indicator #3: Potential for effects to numerical water quality standards and groundwater classifications. Numerical surface water quality standards are set by State law at Utah Annotated Code R317-2-14, based upon which Beneficial Use Class they have been assigned. There are no classified groundwaters to date within the Dixie National Forest. However, similar to measurement indicator #1, activities do not change these water quality standards or classifications; instead, the activity must meet the existing standard or it is not allowed. While there may be impacts to water quality, described under measurement indicators 2 and 4, there would not be impacts to the standards or

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 32 classifications due to any post-leasing activity under any alterative. Thus this indicator is not discussed further under the various alternatives in 7.5.4.3.

Measurement Indicator 4: Potential to increase sediment in surface streams. As noted above, all action alternatives would have at least some potential to increase sediment in surface streams. The means by which this could occur was also described. Whether this increase would actually occur, its magnitude, and its duration would depend upon many factors and in part requires knowing the site-specific locations of the activities. Thus, the project-specific NEPA analyses would need to be relied upon for further analysis of this measurement indicator. However, the impacts could be kept as negligible to minor as long as environmental protection measures are properly implemented. Generally speaking, there may be slightly more or less potential for increased sediments in streams, depending upon the alternative, and these differing potentials are described qualitatively in Section 7.5.4.3.

Measurement Indicator #5: Relative potential for increasing miles of roads within municipal watersheds and lava fields over sensitive aquifers. Under SLT, road construction would be allowed in municipal watershed and lava fields over sensitive aquifers. As a result, total miles of new roads predicted by the RFDS to occur on any ranger district (13.3 miles of new road on the Pine Valley Ranger District, 19.9 miles on the Cedar City Ranger District, and 23.2 miles on both the Powell and Cedar City Ranger Districts) could occur within a municipal watershed. Lava fields over a sensitive aquifer only occur on the Cedar City Ranger District and the total amount of new roads that could occur would be 19.9 miles

Measurement Indicator #6: Narrative description of potential effects to surface water flow and groundwater availability. The potential for connected actions related to oil and gas leasing to affect surface water flow and ground water availability was described above. That potential was determined to be negligible for both surface water and groundwater, and would be the same for all action alternatives. (This indicator addresses the effects on quantity of water only; any rendering of a water quality effect on the ability to use a quantity of water is addressed by other indicators). Thus, this indicator is not discussed further in following sections.

Measurement Indicator #7: Potential to reduce flow of developed water sources including their recharge areas and well or spring collection galleries. The potential to reduce flow in general would be negligible as described for measurement indicator #6, thus it would similarly be negligible in regard to flow of developed water sources. Even though there is not a specific stipulation that would prevent direct interference with spring collection galleries, it is presumed that Best Management Practices and NEPA-specific requirements would prevent that occurrence, thus it is similarly assumed that there would be negligible potential to impact those features. This indicator is not discussed further in the following sections, because impacts are assumed to be the same for all action alternatives.

Measurement Indicator #8: Acres of disturbance as compared to available. Under SLT, disturbance of up to 396.9 acres could occur on the Pine Valley Ranger District, 622.9 acres on the Cedar City Ranger District, and 705.9 acres on the Powell and Escalante Ranger Districts. Acreage of disturbance would be the same under all action alternatives; however the acreage available differs by alternative due to the leasing options that would apply. Therefore, this indicator is discussed under each alternative in Section 7.5.4.3. However, it is not the only indicator for all cases. For example, while perhaps only a very small percentage of a stream might be directly disturbed by a road crossing, a vehicle accident and spill could occur on this crossing, with an impact to water quality entirely un-related to the acreage involved in the road disturbance. As

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 33 described throughout this Specialist Report, proximity to a stream channel is more important than acreage when describing impacts to surface water resources.

Measurement Indicator #9: Narrative description of water rights potentially impacted. This subject was discussed above, and was determined to represent a negligible impact. It is not discussed further in the following sections.

7.5.4.3 Impacts by Alternative The degree to which connected action impacts (Sections 7.5.4.1 and 7.5.4.2) would differ by alternative are discussed in this section. Alternatives involve leasing options, which would restrict the locations and the nature of oil and gas impacts that are allowed. Because areas for different resource components overlap, leasing options assigned to each resource component would also overlap and the most restrictive leasing option would take precedence. (Resource components were defined above in Sections 7.4.1, 7.4.2, and 7.4.4.

Table 7.5-3 shows the acres of each resource component under each leasing option by alternative. Table 7.5.3 incorporates the amount of overlap with more restrictive leasing options (assigned to other resources) in addition to the leasing option assigned directly to each resource component. There are two columns under Alternatives C, D, and E. The first column under each of these alternatives (C, D, and E) incorporates the acres within all Inventoried Roadless Areas assigned an NSO stipulation as mandated by the current Roadless Area Conservation Rule. The second column under Alternatives C, D, and E represents the same acres with less restrictive stipulations, assuming a less restrictive rule is adopted. The following resource components fall within Inventoried Roadless Areas: (lava fields over sensitive aquifers (32%), streams and lakes (35%), and municipal watersheds (23%)). While in general, the total acreage given for each resource component should be the same for each alternative, Table 7.5-3 has a number of discrepancies in this regard. This is due to the fact that limitations with the GIS database applied over an extremely large area result in an inability to accurately calculate acreages that match exactly between alternatives.

Table 7.5-3 Acreage of Resource Components under each Leasing Option by Alternative. Alternative Leasing Resource C* D E Option A B NSO/NSO** NSO/CSU** NSO/SLT** NA 0 0 0 0 0 0 0 Lava Fields NL 58,585 41,990 225 225 0 0 0 0 over NSO 0 16,596 58,565 58,565 58,790 58,790 18,821 0 Sensitive TL 0 0 0 0 0 0 0 0 Aquifers CSU 0 0 0 0 0 0 0 0 SLT 0 0 0 0 0 0 39,969 58,790 Streams and NA 37,325 22,939 22,939 22,940 22,940 22,939 22,939 Lakes NL 410,550 543,172 5,614 5,614 0 0 0 0 (including a NSO 0 82,338 382,265* 382,265* 167,404 27,370 142,117 0 300-foot TL 0 0 0 0 121,641 199,110 0 0 buffer, CSU 0 0 0 0 98,836 161,400 0 0 except for Alternative B which includes a SLT 0 0 0 0 0 0 245,762 387,879 500-foot buffer)*** Municipal NA 7,587 7,588 7,588 7,587 7,587 7,587 7,587 Watershed NL 53,403 45,816 5,449 5,449 0 0 0 0 NSO 0 0 40,366 40,366 23,548 5,940 12,480 0

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 34 Alternative Leasing Resource C* D E Option A B NSO/NSO** NSO/CSU** NSO/SLT** TL 0 0 0 0 10,954 22,491 0 0

CSU 0 0 0 0 11,314 17,386 0 0 SLT 0 0 0 0 0 33,337 45,816 *NSO acreage for streams and lakes under Alternative C actually includes two types of NSO stipulations as will be described later in the report. **The two leasing options listed under Alternatives C, D, and E represent the dual analysis for lands within Inventoried Roadless Areas if 1) the more restrictive rule (2001) remains in effect, or 2) if a less restrictive rule is adopted (see Chapter 2 and Specialist Report 2.0). ***The total acreage associated with Streams and Lakes under Alternative B is larger than under the other alternatives because the buffer width is greater.

A more detailed table that separates the acreage by resource component and Ranger District will be available in Appendix B of the EIS. In this section, impacts are generally discussed at the forest- wide level and not by Ranger District. This is done to avoid repetition and facilitate the comparison of impacts across alternatives. However, any pronounced differences in the impacts to a resource component between Ranger Districts will be highlighted and discussed.

ALTERNATIVE A Under this alternative, there would be no new leases made available, thus there would be no connected actions associated with well disturbances, pipelines, roads, etc. related to oil and gas. There could be other unrelated actions on the Dixie National Forest, but these are not considered connected actions for this Specialist Report so they are not discussed in this section (they may be discussed as a cumulative effect, if relevant).

Thus, 100 percent of the 58,585 acres of lava fields over sensitive aquifers on the Dixie National Forest would not be affected under Alternative A. All of these are on the Cedar Ranger District. Further, 100 percent of the 53,403 acres of municipal watersheds, and all of the 410,550 acres of streams and lakes (assuming a 300-foot corridor width to derive area based upon stream length) on the Dixie National Forest would not be affected under Alternative A.

None of the effects described above in Section 7.5.4.2 would occur under Alternative A. Measurement indicators would not change, thus they are not discussed individually for this alternative.

ALTERNATIVE B Under Alternative B, there would be NA, NL, or NSO options applied to all three of the identified water resource components. This means that there would essentially be no potential for the types of effects described above in Section 7.5.4.2 to occur within municipal watersheds. Further, there would be no potential for increasing miles of roads within municipal watersheds and lava fields over sensitive aquifers. Impacts to the 28 percent of lava field over sensitive aquifers available under NSO would be the same as described for NSO in Section 7.5.4.1. There would be a markedly reduced potential for the general effects described in Section 7.5.4.2 to occur, indirectly, within the 500-foot buffer for streams and lakes, than Alternatives D and E. This is due to the fact that, as noted above, the greater the distance between the stream and the activity, the lesser the chance for the majority of the described general impacts to occur. However, there would still be some potential for streams to be impacted in the general ways described in Section 7.5.4.2 due to activities outside the buffer.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 35 In addition, there is some potential for those general affects to occur to water resources outside of the defined components. Those three components represent aspects of water resources that are keyed upon in the Specialist Report, but in fact, water resources occur across the forest. For surface water resources, upland watershed areas, ephemeral channels, or headwater catchments areas are not included the streams resource component, but could be impacted by the types of general effects described above. In part, because this restricts the potential areas wherein oil and gas exploration can occur, it might have the consequence of forcing disturbances to be located within a smaller area and perhaps resulting in a greater likelihood that a higher proportion of a small subwatershed could be disturbed, even if the identified water resource components were not directly subject to the activity. For example, while exploration activity in general might not be likely to greatly increase road density over some threshold value (such as the 2 miles/square mile), if enough land is excluded from exploration, the remaining available land might result in a concentration of activity and thus by default increase road density in that area. Groundwater occurs in other areas than just the identified lava fields over sensitive aquifer component, and would have at least some potential for impact, depending upon specific circumstances.

However, the environmental protection measures that would apply to the various types of activities would reduce the likelihood of their occurrence assuming that they are properly implemented. That, combined with the leasing options that would be in place under this alternative, the likelihood of occurrence would be even further reduced because the areas over which the impact could occur would be limited. For example, the types of specific events listed in Section 7.5.4.2 as being assumed that one or more could occur under SLT (hydrochloric acid spills, hydrocarbon spills, magnesium chloride releases, reserve pit overflows, failure of reserve pit liner), are less likely to occur under this Alternative and much less likely to affect water resources, should they occur. As the data in Table 7.5-3 shows, under this alternative, 72 percent of the lava fields over sensitive aquifers (which all occur in the Cedar Ranger District) would be NL, and the remainder 28 percent would be NSO. Under this alternative, 6 percent of streams and lakes along with a 500-foot buffer would be NA, 82 percent would be subject to the NL option, and 12 percent would have an NSO stipulation. Regarding municipal watersheds, most (86 percent) would be NL and the remainder (14 percent) would be NA.

ALTERNATIVE C WITH NSO IN IDENTIFIED ROADLESS AREAS Under Alternative C, there would be the potential for all of the same impacts as described in Section 7.5.4.2 and as described under Alternative B. However, there would be more land associated with the three resource components available for lease with this Alternative than there would be under Alternative B. Even so, those lands would only be available for lease with an NSO stipulation, so the potential for direct effects would still be reduced when compared with Alternatives D and E. As described under Alternative B, there would be the potential to impact water resources other than those associated with the three identified resource components. However, the types of specific events listed in Section 7.5.4.2 as being assumed that one or more could occur under SLT (hydrochloric acid spills, hydrocarbon spills, magnesium chloride releases, reserve pit overflows, failure of reserve pit liner), are less likely to occur under this Alternative and substantially less likely to affect water resources, should they occur.

As the data in Table 7.5-3 show, under Alternative C with NSO in Identified Roadless Areas, almost all of the lava fields over sensitive aquifers (which all occur in the Cedar Ranger District) would be NSO; only 0.4 percent would be NL. Regarding municipal watersheds, most (76 percent) would be NSO, 14 percent would be NA, and 10 percent would be NL. As the majority of lava fields over sensitive aquifers and municipal watersheds would be available under NSO, the impacts to these resources would be the same as described for NSO in Section 7.5.4.1. There would be no potential for increasing miles of roads within municipal watersheds and lava fields over sensitive aquifers.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 36

For this alternative, 6 percent of streams and lakes along with a 300-foot buffer would be NA, 1 percent would be NL, and the remainder (93 percent) would have an NSO stipulation within a 300- foot buffer. However, as described above in Section 7.5.4.2, two NSO leasing options would apply. Approximately 69 percent would be under a general NSO leasing option that would not allow use or occupancy, with the exception of seismic exploration. Approximately 24 percent would be under the NSO developed to allow for perpendicular stream crossings. As a result of the different NSO leasing options under Alternative C, direct impacts to water resources would be limited to seismic exploration over 69 percent of the 300-foot buffer, with a small amount of road, culvert, and bridge construction allowed in 24 percent of the 300-foot buffer. The impacts of seismic exploration would be as described for SLT in Section 7.5.4.2. Road-stream crossings would also have impacts as described in Section 7.5.4.2 including the introduction of sediment, increased bank erosion, and alteration of local hydrological conditions; however, most of these would be avoided by following the existing BMPs described. Also, impacts of road stream crossings would be less severe than described in Section 7.5.4.2, as only small amounts of these water and watershed resources would be affected at each crossing (there would be approximately 600 linear feet of road within the buffer at each crossing, or about 0.5 acres). As a result, impacts would range from negligible to moderate and would be short to long term.

Direct disturbance under this alternative would be primarily seismic exploration, with up to 60 acres on the Pine Valley Ranger District and 120 acres on the Cedar City, Powell, and Escalante Ranger Districts. In addition, approximately 0.5 acres (600 linear feet) of roads would be constructed at each stream crossing. As the number of possible stream crossings is unknown, a conservative estimate is to assume that disturbance could be up to the maximum estimated for road construction on each ranger district. This would be up to 53.5 acres for the Pine Valley Ranger District, 160.5 acres for Cedar City, and 214.0 acres for the Powell and Escalante Ranger Districts. As a result, total acres disturbed would be 113.5 acres for the Pine Valley Ranger District, 280.5 acres for the Cedar City Ranger District, and 334.0 acres for the Powell and Escalante Ranger Districts. This represents less than one percent of the total acreage of the different resource components on the individual ranger districts.

ALTERNATIVE C WITH NSO IN IDENTIFIED ROADLESS AREAS Under this dual analysis scenario, Alternative C would have NSO applied in Inventoried Roadless Areas, just like it would under the other Alternative C scenario described above, even if the 2001 Roadless Conservation Rule was not in effect. Therefore, refer to the discussion above; there is no difference.

ALTERNATIVE D WITH NSO IN IDENTIFIED ROADLESS AREAS All of the effects described above in Section 7.5.4.2 would have the potential to occur under Alternative D with NSO in Identified Roadless Areas. When compared with Alternative C with NSO in Identified Roadless Areas, this alternative is almost the same in regard to lava fields over sensitive aquifers available for lease, except that all of these acres would be available only under the NSO stipulation, rather than the 0.4 percent that would be NL under Alternative C. Further, the relative potential for increasing miles of roads within lava fields over sensitive aquifers is the same as under Alternative C.

Regarding streams and lakes with a 300-foot buffer, 6 percent would be NA, 41 percent would be NSO (the standard application of NSO due to other resources, so perpendicular crossings would not be allowed), and the remainder (54 percent) would have TL or CSU stipulations within a 300- foot buffer. Although the TL stipulation is considered to be more restrictive than CSU, it’s implications to water resources are not very meaningful and would not provide protection beyond what is provided by CSU. As described in Section 7.5.4.1, the CSU applied to the 300-foot buffer

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 37 around all waterbodies is similar to the NSO applied under Alternative C (NSO with Stream Crossings). As a result, the impacts to water resources (including Measurement Indicators) would be the same as described for Alternative C. For municipal watersheds, the disturbance allowed would essentially be the same as SLT. However, the level of impacts expected to occur from the types of impacts to water quality described in Section 7.5.4.2 would be reduced due to increased oversight and regulation. As a result, impacts due to short-term sediment impacts and temporary impacts from accidental releases of fuels or chemical spills would be negligible to moderate, and short-term (as compared to negligible to major under SLT). However, given the amount of disturbance allowed under CSU, there would still be a greater potential to impact municipal watersheds than under Alternative B and C.

ALTERNATIVE D WITH CSU IN IDENTIFIED ROADLESS AREAS The same types of impacts as described for Alternative D with NSO in IRAs would have the potential to occur under this alternative and the impacts (including Measurement Indicators) would be the same as described for Alternative D with NSO in IRAs. The difference between this Alternative and Alternative D with NSO in IRAs is simply a matter of the amount of acres of streams, lakes, springs, wetlands, floodplains, riparian areas, and municipal watersheds where surface occupancy would be allowed. Under this alternative, a greater number of acres would have a CSU leasing option and thus would be more prone to impact than equivalent areas where NSO would apply.

Based upon Table 7.5-2 numbers, streams and lakes with a 300-foot buffer, almost 6 percent would be NA (the same as Alternative D with NSO in IRAs), almost 7 percent would be NSO, and the remainder (88 percent) would have TL or CSU stipulations within a 300-foot buffer. The TL stipulations would not provide protection beyond that provided by CSU. Regarding municipal watersheds, 14 percent would be NA (the same as the other Alternative D), 75 percent would be TL or CSU, and 11 percent would have an NSO stipulation.

ALTERNATIVE E WITH NSO IN IDENTIFIED ROADLESS AREAS Under this alternative, all of the identified resource components would be available for lease with SLT, with the exception of those that are NA, or are associated with identified roadless areas, which would be available under the NSO stipulation. All of the impacts discussed under 7.5.4.2 above would have the potential to occur. This would include the types of specific events listed in Section 7.5.4.2 as being assumed that one or more could occur under SLT (hydrochloric acid spills, hydrocarbon spills, magnesium chloride releases, reserve pit overflows, failure of reserve pit liner). Further, the relative potential for increasing miles of roads within lava fields over sensitive aquifers or municipal watersheds would be greater than under any of the other alternatives.

For lava fields overlying sensitive aquifers, some surface occupancy would be allowed, where it wouldn’t be under Alternatives B to D. While 32 percent of these areas would be available only with an NSO stipulation, 68 percent of lava fields overlying sensitive aquifers could have surface occupancy with SLTs. While these terms, which include the Dixie National Forest Conditions of Approval, the Gold Book (BLM and USFS 2007), and Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements, along with other environmental protections that would be required would still help to reduce the potential impacts, there would be more potential for them to occur on these areas than under the other action alternatives.

For streams and lakes, the same percentage would remain NA as for Alternatives C and D (almost 6 percent). About 35 percent would be available with an NSO stipulation (because they would occur within Identified Roadless Areas), and the remaining 59 percent would be available with SLTs.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 38

For municipal watersheds, 14 percent would be NA (the same as for Alternatives B, C, and D); 23 percent would be available with an NSO stipulation (less than the amount under Alternative D with NSO in Identified Roadless Areas, and less than under Alternatives B or C; and 63 percent would be available under standard lease terms.

Unlike the other alternatives previously described (A to D), this alternative would potentially result in surface disturbance on some land associated with the three identified water resources components. Under the highly unlikely scenario whereby the entire disturbance in a Ranger District was to occur on water resource components, the percentage that would be disturbed is shown in Table 7.5-4. As shown, it is less than one percent for all Ranger Districts.

Table 7.5-4 Potential Acreage of Surface Disturbance Versus Total Water Resource Component

Ranger District Potential Surface Combined Water Resource % of Combined Water Disturbance (acres) Components Acreage Resource Components (Baseline Amount) Potentially Disturbed Pine Valley 397 166,581 0.24 Cedar 623 154,843 0.40 Powell 706 102,549 0.69 Escalante 706 99,041 0.71

ALTERNATIVE E WITH SLT IN IDENTIFIED ROADLESS AREAS Under this alternative, the identified resource components would all be available for lease with SLTs, except where they are NA (the same percentages as under Alternatives C, D, and the other Alternative E). This means that all of the potential impacts discussed under 7.5.4.2 above would have the potential to occur on all of the lava fields over sensitive aquifers, 94 percent of streams and lakes, and 86 percent of municipal watersheds. However as has been discussed, the likelihood would be reduced by the terms and other environmental protection measures that would be placed. This ability to move disturbances would not marginally affect impacts to lava fields over sensitive aquifers or municipal watersheds. All told, this alternative would have the greatest potential to impact water resources components. In part, this would be due to the fact that, as noted above, recent history indicates that the track record of the oil and gas industry is good -- but not perfect -- and it cannot be expected to be perfect.

As with Alternative E with NSO in IRAs, this Alternative E would potentially result in surface disturbance on some land associated with the three identified water resources components. Because the acres of predicted disturbance are the same for all alternatives, Table 7.5-4 also applies to this alternative.

7.5.5 Cumulative Effects Cumulative effects are the total effect, including direct and indirect effects, on a given resource resulting from the incremental impact of past, present, and reasonably foreseeable future actions. They can result from individually minor, but collectively significant actions taken over a period of time. Cumulative effects may arise from single or multiple actions and the effects may be additive or interactive. The net adverse effect of interactive actions may be less than the sum of the individual effects (countervailing) or the actions may interact to create a net adverse cumulative effect that is greater than the sum of the individual effects (synergistic). The magnitude and extent of the effect on a resource depends on whether the cumulative effects exceed the ability of a resource to function at a desired level (CEQ 1997).

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 39 7.5.5.2 Description of Cumulative Effects Area The Cumulative Effects Area (CEA) that applies to this technical report is shown on Figure 8.5-1 in the Watershed Specialist Report (SR #8). It is defined as all 6th level HUC subwatersheds occurring on the Dixie National Forest that are within the following boundaries: north of the Virgin River, east of the Union Pacific rail line located west of the Utah-Nevada border, south and east of US Highway 56 and Desert Mount Road, east of Interstate 15 north of Cedar City, and south and west of US Highway 12 on the Fremont River Ranger District. No data exists for one of the subwatersheds on the west side of the Pine Valley Ranger District and a buffer was created by extending a boundary west from the nearest subwatershed (Nephi Draw HUC 160300061301) along an existing dirt road to its intersection with the Union Pacific rail line at Brown, Nevada. These boundaries were placed on the 6th level subwatersheds due to the presence of several subwatersheds that covered only very small portions of the Dixie National Forest, but extended long distances from the Dixie National Forest boundary. The portions of these watersheds eliminated are likely beyond the extent of any cumulative effects. The CEA is approximately 3,528,829 acres (Table 7.5-5).

RATIONALE The 6th level HUC subwatershed was chosen to incorporate any impacts of oil and gas activity that could be transmitted downstream of the Dixie National Forest boundary and, in combination with off-Forest activities, result in larger impacts. Impacts to water resources from oil and gas activity are not expected to be of a magnitude large enough to be transmitted beyond the 6th level HUC subwatershed and a larger CEA does not appear justified. Also, the subwatershed boundaries that were limited by the roadways were eliminated due to the distance they extended beyond the Forest boundary and impacts are not likely to extend out beyond the boundaries created. Further, assuming that all available environmental protection measures are applied correctly and that accidental events do not occur, the predicted water resources impacts should be confined to within the Dixie National Forest boundaries. Table 7.5-5 Land Ownership Within Cumulative Effects Area Area Percent of Land Ownership (acres) Total CEA Bureau of Land Management (BLM) 1,000,286 28% National Park Service (NPS) 40,357 1% Private 560,755 16% State Lands* 174,904 5% US Forest Service (USFS) 1,667,043 47% USFS Wilderness Area 82,573 2 Water 2,907 <1 Total 3,528,829 100 *Includes: State Park (Nevada): 2,025 acres State Parks and Recreation: 8,994 acres State Trust Land: 156,955 State Wildlife Reserve/Management Area: 6,931

7.5.5.3 Past, Present, and Reasonably Foreseeable Actions As defined by land area, about one-half of this CEA is National Forest land and about one-half is other lands (predominantly private and BLM). However, in regard to water resources (as measured both by quantity and by importance), National Forest lands dominate the CEA. Their position within the higher elevation, greater precipitation zone of the CEA means that Dixie National Forest lands

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 40 capture, store, and release water that supports not only their proximate ecosystems, but many off- Forest ecosystems and human uses as well. For example, the 15 municipal water systems on the Dixie National Forest serve as the only (or predominant) source of culinary water for the 28 municipalities within the CEA. Thus, degradation of a water source on the Dixie National Forest may literally have a greater impact to a community outside the Forests’ boundaries than degradation of a stream adjacent to -- or within -- the community itself. Similarly, the defined lava fields over sensitive aquifers water resource component is located only within the Cedar City Ranger District boundaries; while severe contamination of that recharge area could negatively impact off-Forest, down-gradient valley wells, off-Forest activities do not have the potential to affect these lava fields over sensitive aquifers. As noted in the Forest Plan (USFS 2006a) “it will be a continuing challenge to retain sufficient water for healthy watersheds, streams, aquatic species, wildlife, and vegetation, while also providing water for the needs of local communities and traditional rural activities.” Therefore, past, present, and reasonably foreseeable actions within the Dixie National Forest have a proportionally greater focus in this cumulative effects section than off-forest actions.

In addition, the potential for impacts to water resources as a result of connected actions associated with oil and gas leasing is related more to degrading water quality than to reducing water quantity. In earlier sections of this Specialist Report, potential water quality degradation was attributed to two types of occurrences related to oil and gas leasing or production: sedimentation due to surface disturbances and vegetation removal, soil compaction, and drainage pattern alteration; and isolated introduction of pollutants such as hydrocarbons or chemicals due to accidental spills. Only the former is realistically relevant to cumulative effects analysis; while the latter may represent an impact that could be locally significant, it would be limited in duration and unlikely to exacerbate or be exacerbated by other similar simultaneous impacts that would result in a cumulative effect. For this reason, past, present, and reasonably foreseeable actions that can result in erosion and sedimentation, and thus contribute to increased sediment yields in a given watershed, represent the bulk of actions discussed in this section.

In-stream sedimentation can result from various sources, activities, and land uses. Upland erosion due to generally poor watershed condition (such as due to forest fires, poorly managed timber cutting, or overgrazing) can introduce sediments via overland flow or storm runoff, as well as from mass movements due to slope destabilization. Direct surface disturbances related to industrial or construction activities (such as roads, well pads, mines, or subdivisions) often result in ground compaction and drainage pattern alteration, which in turn increase flow velocities and sediment transport capacities. Stream alterations (such as culverts, road realignments, or irrigation diversion structures) can affect a channel’s stability and result in in-channel erosion that transports sediments downstream. Agriculture can also degrade water quality by introducing sediments through poor tillage practices and ill-managed irrigation systems.

Compared to historic conditions (late 1800s and early 1900s), watershed conditions have improved on many parts of the Dixie National Forest and on lands now managed by the BLM. However, recent past and present management activities have continued to impact watershed conditions. In general, any major surface disturbing activity has the potential to result in cumulative impacts to watershed resources. However, USFS (2006a) identified the following management activities as the key threats to watershed resources, which in turn, relate to water quality: road systems in riparian and wetland areas; livestock grazing; dispersed recreation -- notably off-road vehicle use; water diversions and dams; uncharacteristic fire; timber harvest (including the associated road building); and minerals activity (including oil and gas exploration and development). These activities also occur on off-Forest lands, notably on both private and BLM-managed lands, but less so on State lands within the CEA as those are predominantly associated with State Parks. In

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 41 addition, activities that occur predominantly on private lands and that can threaten water resources include agriculture and expanding municipalities.

The potential types of impacts from these activities are many, but ones most relevant to sediment- related water quality are: erosion of stream channels, concentrated runoff, and increased sediment loads. While these impacts continue to occur within the CEA (both on- and off-Forest), many of the activities listed have decreased or become better managed in recent years as the importance of watershed processes in overall ecosystem health has become increasingly recognized. As part of the Dixie National Forest’s management efforts, strategies have been implemented to ensure that activities do not result in negative impacts to channel substrate (including fine sediments), dimensions, or stability (USFS 2006a).

Discussions on the past and present levels of these types of activities are listed below, along with the general water-quality-related impacts that have resulted and the expected level of future activity. The Watersheds Specialist Report lists many more specific current and future projects by name, and these represent types of projects that may have water impacts as well.

ROADS

The construction of roads in close proximity to streams has occurred in the past, and is still occurring in the present, within the CEA. Roads can channel surface water runoff directly into streams, water that would normally travel slowly or diffusely through the watershed. Roads can also alter channel morphology due to culvert placement and straightening. The result is that sediment inputs to streams are high in some areas, which can further destabilize channels and in- turn increase sediments. Overall, as described in Section 7.5.4.2, roads represent one of the greatest sources of impacts to water quality

Table 7.5-6 shows the miles of Dixie National Forest Service routes that are impacting, or that have the potential to impact, watersheds and/or water resources.

Table 7.5-6 Forest Service Routes Impacting Watershed Resources

Miles of Forest Service Routes Route Impacts Pine Valley Cedar City Powell Escalante Route presents a high risk to soil 206.5 44.9 65.5 189.1 and water resources Route presents a moderate risk to 135.7 329.3 360.6 362.3 soil and water resources Route impacts stream channels, floodplains, 385.1 346.9 152.8 478.0 wetlands, or riparian areas Route crosses 111.3 210.6 164.3 276.4 riparian areas Route is in riparian areas 67.00 146.0 105.1 48.00 (within banks or high water mark)

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 42 Route is within ½- mile of a riparian 185.2 174.6 416.3 515.8 area Route is within a 2.2 stream channel Routes with 640.5 591.7 682.7 604.3 stream crossing Routes within 2.6 0.7 wetlands Routes within 200 700.7 670.1 815.8 710.2 feet of streams Source: Dixie National Forest Route Analysis Database

Such details on road/stream relationships are not readily available for the non-Forest portions of the CEA, however a simple measure of road density can provide some indication the potential for roads as a whole to impact streams. This is based upon the assumption that the greater the network density of roads in a watershed area (all else being the same), the greater the likelihood of channel alteration, sedimentation, spill contamination, etc. Throughout the CEA, there are numerous HUC 6 watershed areas with a road density of 2 miles/square mile or greater: notably these include off- Forest lands to the north of the Pine Valley Ranger District; much of the southern 2/3 of the Cedar City Ranger District; and a significant part of the Escalante Ranger District. In general, the Dixie National Forest has a higher road density than the surrounding non-Forest lands in the CEA. Soil type, slope steepness, geology and other aspects of a watershed, as well as road surface, gradient, and other aspects of a road design, also relate to potential impact as well as road density itself.

In recent years, many roads and trails within the Dixie National Forest have been relocated away from streams or have been obliterated. The Duck Creek – Swains Access Management Project is a recent example of a project designed to lessen the impact of roads on riparian areas (USFS 2006a). This project is closing or decommissioning unneeded roads, which will potentially decrease the adverse affects to water resources. Further, in recent years, the USFS has placed more focus on proper road placement, design, and maintenance, all with an eye towards reducing impacts to water resources.

However, similar efforts to relocate or obliterate roads outside the Dixie National Forest boundary have not occurred, with one exception possibly being within the Grand Staircase-Escalante National Monument, where the BLM plans to implement road closure projects in the future, as funding permits. While off-Forest roads are also currently likely better-managed and subject to more thought toward environmental considerations prior to construction than in the past, their numbers are increasing; more roads are constructed than are obliterated. This generally means than, in the CEA, there is an increasing network of roads and a generally increasing road density. One exception would be within the St. George BLM District, there are three wilderness study areas (Cougar Canyon, Red Mountain, and Cottonwood Creek) that are at least partially within the CEA (BLM 1999b). These areas would not be likely to see new road construction.

Ongoing road maintenance, repair, construction, and reconstruction occur in various locations throughout the CEA. For example, Bryce Canyon National Park’s Tropic Canyon highway rehabilitation project involves repairing a bridge damaged by flood events. In addition, a 50-foot bridge will be constructed across Ash Creek north of Pintura as part of a road project, and will involve a significant amount of fill material to construct the bridge abutments. These types of projects often involve at least some ground disturbance, with consequent erosion; usually they are subject to sediment control practices that are intended to minimize off-site impacts. When such impacts occur, they are usually short term and decrease following construction. These types of

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 43 projects can also correct poor drainage and actually improve water quality. An example of this would be the Cottonwood Wash Road (located within the Grand Staircase-Escalante National Monument and within the boundaries of the CEA), which is restricted by the BLM’s management plan to maintenance for stabilization to prevent erosion and sediment loading in drainages (BLM 1999).

Within the CEA the impacts of roads are likely to slightly decrease in the future due to the increased awareness of the importance of maintaining stream stability quality and water quality.

OIL AND GAS AND MINERALS ACTIVITY Within the Dixie National Forest, the Upper Valley Field consists of 33 wells in the southeast corner of the Escalante Ranger District. It was developed in 1964 and production is projected to continue into the future. This field was discussed in the Reasonably Foreseeable Development Scenarios Report upon which this EIS is based.

Regarding oil and gas leases on BLM lands within the CEA, there are 122 separate authorized leases and 14 pending leases, with a combined total lease area of 101,682 acres. While these leases occur throughout the CEA, they tend to occur in clusters. Some of the larger clusters are to the south and north of the Cedar City Ranger District, in between the Cedar City and Powell Ranger Districts, and off the southeast corner of the Escalante District (an extension of the Upper Valley Field). Only the Upper Valley Field is currently active. While the lease acreage is not reflective of potential surface disturbance area, it may be likely that the larger lease areas and the lease clusters may eventually have a greater area of surface disturbance than a smaller, isolated lease. Further, it can be assumed that similar types of impacts as were described for on-Forest leases could occur on these leases as well.

The UNEV Pipeline project is a petroleum pipeline project planned for the near future. It would cross the CEA in a generally northeast/southwest direction, passing through the Pine Valley Ranger District as wells as lands to the north and south of that district. Located within the Kern River pipeline corridor, it could be likely to generate some sediment, at least during the construction phase.

Mining activities, as with any type of surface disturbance, can also generate sediments due to erosion and drainage alteration. Within the CEA, there are currently 25 separate minerals activities, more than half of which are on BLM land surrounding the Pine Valley Ranger District. Activities include mining claims and active mines, with the target material that includes sandstone, limestone, silica, rhyolite, alabaster, travertine, iron, gold, and silver. As current mining is a regulated activity by the land management agency, and/or by the Utah Division of Oil, Gas and Mining, it can be assumed that erosion and sediment, as well as other potential impacts to water quality, are regulated to at least some degree.

The largest planned mining activity in the near future is a proposed coal mine about 3 miles south of the town of Alton, between the Cedar City and Powell Ranger Districts. The project, which is only in the planning stage, is being called the Coal Hollow project and is proposed by Alton Coal Development, LLC. This proposed surface coal mining project involves federal (BLM) and private lands, with the bulk of the coal resource on federal lands. Preliminary plans would mine the coal from private lands first (about 570 acres) and then expand onto adjacent federal lands (about 1,430 acres). The estimated total surface disturbance from coal mining will entail about 2,000 acres including haul roads and surface facilities, over about 20 years of mining. Coal mines are regulated to ensure that excessive erosion does not occur, that stream water quality standards are met, and

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 44 that the land is ultimately reclaimed, however there is likelihood of some sediment loading in the streams within the affected watersheds.

FIRE Wildfire can occur over entire watersheds or over significant portions of them, and result in impacts to water quality. In particular, the types of large, severe wildfires that are more common now than historically as a result of fire suppression can cause increase overland flow and erosion, as well as large mass movements such as debris flows. Wildfire can occur anywhere in the CEA, although on public lands such as the Dixie National Forest and on BLM-managed land, it is likely to cover a greater area and thus have a greater potential for impact.

Historically, fire played a major role in ecosystem processes on the Dixie National Forest. Historical fire levels within the entire CEA likely averaged 3 percent per year, with up to 6 percent burning in active years (USFS 2006a). However, 150 years of fire suppression has created large mosaics of dense fuel loads in many watersheds within the CEA, which has increased the frequency of large, severe fires in recent years. The Sanford Fire that occurred on the Dixie National Forest in 2002 has resulted in changes to channel morphology and riparian vegetation in the Cottonwood Creek, Deep Creek, and Deer Creek watersheds (USFS 2004). The frequency of large, severe fires is expected to increase in the future due to the limited acres than can be treated to reduce fuel loads.

In addition, the use of prescribed fire and mechanical fuel treatments are also anticipated to increase over the next 5 to 10 years. Most of the prescribed fires are small and are low to moderate intensity, so they normally do not cause the same levels of sediment impacts as do large overdue wildfires. Further, an increase in the number of prescribed fires and mechanical fuel treatments should ultimately lead to a decrease in the number of large, catastrophic fires.

LIVESTOCK GRAZING Overgrazing can directly affect riparian areas and upland watershed condition in various ways, which in turn can increase sediment transport in streams. As an example, the result of over- utilization of riparian ecosystems is a reduction in plant cover and increased soil compaction. These two processes can result in a decrease in natural surface water infiltration, a concomitant increase in surface water runoff, and changes in stream channel morphology (USFS 1995). The result can be increased sediment loads and channel instability.

Much of the CEA experienced intense overgrazing in the late 1800s and early 1900s prior to active management. Although impacts continue to occur, grazing practices have improved considerably in recent years. The level of grazing occurring on the Dixie National Forest has been relatively constant over the past 5 years (USFS 2006a), with moderate impacts on watershed resources, particularly riparian areas. Grazing on the Dixie National Forest is expected to continue at current levels; however, correct application of revised criteria for grazing should result in fewer undesirable impacts to riparian areas (USFS 1996). On the Grand Staircase-Escalante National Monument, grazing is currently being managed with consideration given to ensuring that water quality standards are being met (BLM 1999). Grazing also occurs on BLM-managed land around and to the south of Antimony (in between the Escalante and Powell Ranger Districts); since at least 1988, grazing levels have been considerably less than the permitted uses (BLM 2007). The Kanab BLM- managed land in between the Cedar City and Powell Ranger Districts, as well as all areas that are south of these two Ranger Districts, and within Kane County has experienced significantly decreased livestock grazing from its peak in the early part of the last century, with present levels anticipated to continue (BLM 2007b). Grazing levels within the St. George BLM District are not known, though it is likely to occur over much of the district with the exception of the Red Cliffs Desert Reserve (BLM 1999b).

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 45 OTHER ACTIVITIES THAT CAN AFFECT WATER QUALITY Vegetation conditions in some watersheds have been appreciably altered from their natural range of conditions. This is a result of several factors such as fire suppression and exclusion, wildlife and livestock grazing, development and urbanization, and timber harvest. Consequently, there is an elevated risk of soil loss, which in turn can increase sediment yields and destabilize streams. Some of these factors are discussed briefly below.

While dispersed recreation activities, particularly camping and OHV use that is concentrated near streams, can interrupt flow patterns and increase sediment delivery to stream channels. It is anticipated that the proposed Dixie National Forest Motorized Travel Management Project will largely eliminate off-trail or cross-country motorized travel, which may reduce the potential for these types of impacts. In general, impacts to water resources from dispersed recreation are likely to remain stable or slightly increase (USFS 2006a). Within the Grand Staircase-Escalante National Monument, OHV use limited to designated routes (BLM 1999), while much of the BLM’s Richfield District is open to cross-country motorized travel (BLM 2007). The Kanab BLM-managed land in between the Cedar City and Powell ranger Districts, as well as all areas that are south of these two Ranger Districts, and within Kane County is currently open to cross-country motorized travel; however, once a new management plan is approved, it would limit motorized use to existing routes (BLM 2007b).

Timber harvest can also impact water resources, due to upland watershed effects such as ground compaction, increased runoff, increased erosion, and slope destabilization; sedimentation in streams is a well-known consequence of logging, particularly as practiced in the past. Timber harvest on the Dixie National Forest has generally decreased in recent years, with greater emphasis on salvage logging due to the amount of timber killed by spruce beetle epidemics and the passage of the Healthy Forests Initiative. No commercial timber harvesting is authorized within the Grand Staircase Escalante National Monument, though fuelwood (green or dead and down) harvesting, post cutting, and Christmas tree cutting would be allowed by permit only within designated areas (BLM 1999) (one of these designated areas, Rock Springs Bench, is within the CEA). Similar forest products uses occur on the BLM’s Richfield District (BLM 2007), Kanab District (BLM 2007b), and St. George District (BLM 1999b). While these may also occur within the Cedar City BLM District, there are also numerous thinning and fuels treatment projects planned for the future. All of these types of more-dispersed uses are not likely to have a large effect on stream sedimentation.

Within private lands of the CEA, agriculture is the dominant land use (over about 502,000 acres) outside of the municipalities (about 58,000 acres). As municipalities grow, some agricultural land is being converted to subdivisions; this is expected to continue into the future. While agriculture can increase sediment loads and salinity in streams, construction activities and increased runoff rates due to development likely represent greater impacts to water quality, at least on a per-area basis.

Aside from specific land management practices or activities, water quality can also be affected by geology. A specific mention of this is given the Kanab BLM RMP-EIS (2007b), which states that, generally, as water moves downstream and is diverted and used, water quality deteriorates due to natural sedimentation from highly erosive substrates and anthropogenic non-point sources, and increased salinity levels. This likely applies to many other areas within the CEA, as well.

One measure of how land uses, specific activities, and perhaps natural pollutant sources affect water quality is the State of Utah’s 303(d) list. As described in Section 7.4.3 above, streams and lakes that the State considers impaired, and thus not able to meet their designated beneficial uses,

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 46 are reported on this list, which is updated every other year. Within the CEA, there are several stream reaches on the current (2006) list:

• Escalante River and some tributaries from Boulder Creek confluence to Birch Creek confluence (temperature); • Paria River from start of gorge to headwaters, and Paria River and tributaries from the Arizona-Utah state line to Cottonwood Creek confluence (TDS); • Virgin River and tributaries from Santa Clara River confluence to Quail Creek Diversion, excluding Quail and Leeks Creeks (TDS); • Sevier River and tributaries from Long Canal to Mammoth Creek confluence and Sevier River and east side tributaries from Horse Valley Bridge diversion upstream to Long Canal and Sevier River and tributaries from Circleville Irrigation Diversion to Horse Valley Diversion (total phosphorus and sediment); and • East Fork Sevier River and tributaries from Sevier River to Antimony Creek confluence excluding Otter Creek and tributaries (total phosphorus and temperature).

Most relevant to this discussion of cumulative impacts is 303(d)-listed segments that are impaired due to sediment concentrations, because that is the parameter which is most likely to be exacerbated by oil and gas activities. As indicated in the above list, certain reaches of the Sevier River and selected tributaries are the only streams currently impaired for sediments within the CEA. This area is located within the east side of the Cedar City Ranger District, the west side of the Powell District, and the land between the two.

7.5.5.4 Cumulative Effects

ALTERNATIVE A Under Alternative A, no new oil and gas activity would occur and there would be no cumulative effects.

ALTERNATIVE B The potential for cumulative effects to streams and lakes would be reduced under Alternative B by the application of a NL option to a 300-foot buffer and a NSO stipulation to a 500-foot buffer around these resources. Seismic exploration could occur in the buffered areas between the 300-foot and 500-foot zones, but it is not expected to produce disturbance sufficient to contribute to cumulative effects. However, adverse cumulative effects could occur from the construction of roads, exploratory well pads, and particularly a production field in upland areas if these facilities are constructed in areas that have been impacted by past wildfires or in areas that may be impacted by future timber harvest or vegetation management. Areas that may be susceptible to these types of cumulative effects are the Cottonwood, Deep, and Deer creek watersheds (Powell Ranger District) that were impacted by the Sanford Fire in 2002; the area to be affected by the Clayton Salvage Project (Escalante Ranger District); the Antimony Creek watershed that will be affected by the Pockets Vegetation Management Project (Escalante Ranger District), and; the area to be affected by the Midway-Deer Valley Scenery Enhancement and Vegetation Treatment Program (Cedar City Ranger District). Further, adverse cumulative effects could occur from the construction of roads, exploratory well pads, and particularly a production field in upland areas if these facilities are constructed in areas that have an already high drainage density, such as in the southern 2/3 of the Cedar City Ranger District and a significant part of the Escalante Ranger District. Through the application of the BMPs in Appendix C and BLM and USFS (2007), the cumulative impacts would remain in the range of minor to moderate. Impacts would be short term for exploration activities and long term for production facilities.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 47 Other management activities such as livestock grazing, dispersed recreation, and water developments are not expected to be of a magnitude sufficient to result in cumulative effects to water resources when combined with the effects of oil and gas activity in upland areas, except perhaps in those watershed areas which drain to the portions of the Sevier River and tributaries that are listed for sediment impairment on the State’s 303(d) list. Overall, due to the restrictions on locating oil and gas activity, the level of cumulative impact is probably minimal.

ALTERNATIVE C The NSO stipulation applied to a 300-foot buffer around streams and lakes in this Alternative would limit the likelihood of oil and gas activity directly contributing to cumulative effects, though less so than under Alternative B because of a narrower buffer, and the fact that perpendicular stream crossings could be allowed within these buffers (as noted, the definition of NSO for streams and lakes is different for Alternative C than for Alternative B). Road crossings could result in detrimental cumulative effects in areas with already high road densities, as well as in areas degraded by any of the management activities described. If the crossing is properly designed, constructed, and maintained the amount of sediment introduced should be negligible. However, given the surface disturbance required for the construction of a stream crossing (i.e., bridge construction and culvert placement) and the presence of a road in close proximity to the stream, the potential exists for the introduction of measurable amounts of sediment. Further, if the area impacted by road and bridge construction is subjected to future heavy grazing or is open to dispersed recreational use, the impacted area may be slow to re-vegetate following reclamation (for an exploratory well) or post- construction stabilization (for a production field). Increases in sediment delivery and bank erosion can result in adverse impacts to stream channels and water quality as described in Section 4.7.4.6. Given the BMPs listed, these impacts would be relatively minor and short term for roads associated with exploratory wells.

For a production field, the impacts may range from minor to moderate and be long term due to the length of time that roads would be present. For example, the longer the roads are present the greater the likelihood of an event such as a severe fire occurring in the area, exacerbating erosion problems.

In general, due to the narrower, and less restrictive, buffers under Alternative C, the potential for cumulative impact is greater than under Alternative B.

ALTERNATIVE D WITH NSO IN IDENTIFIED ROADLESS AREAS NSO applied to IRAs would prevent disturbance on 41 percent of wetlands, stream channels, floodplains, and riparian areas on the Dixie National Forest. As a result, there would be no cumulative effects resulting from disturbance directly related to oil and gas activity in these areas. Direct disturbance to these resources not within IRAs and would consist of seismic exploration and the potential for spills due to the possibility of having oil gas facilities in increased proximity to these resources. Mechanical disturbance would be prohibited, which eliminates the potential for sediment related impacts in areas that have high road densities (these areas are described in Section 7.5.5.3) or have been degraded by grazing, dispersed recreation, or fire. As a result, the impacts would be minor and short-term as described for Alternative C.

ALTERNATIVE D WITH CSU IN IDENTIFIED ROADLESS AREAS Under this alternative, 13 percent of the buffered areas created for the protection of water and watershed resources would be off limits to oil and gas development (six percent would not be available for leasing and seven percent would be under NSO). The remainder of these areas would be available for leasing under CSU. Overall, potential cumulative effects under this alternative would be similar as described for Alternative D with NSO in IRAs; however, given the lesser amount

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 48 of water resource components that would be under NSO, the potential for cumulative effects would be greatly increased.

ALTERNATIVE E WITH NSO IN IDENTIFIED ROADLESS AREAS Direct disturbance to water resources could occur in areas not within IRAs and would consist of seismic exploration, construction and reconstruction of roads, exploratory well pads and associated facilities, and production wells with their associated facilities. The construction and reconstruction of roads presents the greatest potential for cumulative impacts to water resources if construction occurs in areas that have high road densities (these areas are described in Section 7.5.5.3) or have been degraded by grazing, dispersed recreation, or fire. Furthermore, areas developed for oil and gas have an increased probability of being subjected to additional future degradation. For example, Dwire and Kaufman (2003) indicate that riparian areas are more susceptible to long-term degradation by wildfire if impacted by past human disturbance. Overall, these processes would produce cumulative effects to water quality primarily by increasing the potential for erosion and sediment deposition. Taken together, impacts may range from minor to major depending upon the location and amount of oil and gas activity. For example, a single exploratory well or a small amount of roads within a degraded area may only have minor cumulative impacts, but a production field or multiple wells with their associated roads would have major impacts. Impacts would be both short term and long term.

ALTERNATIVE E WITH SLT IN IDENTIFIED ROADLESS AREAS The cumulative effects under this alternative would be the same as described for Alternative E with NSO in IRAs.

7.5.6 Summary Impacts to water resources are most likely to occur due to erosion and sedimentation, though these can be greatly reduced if all BMPs are successfully implemented. However, there is also some chance of a chemical or fuel spill that could cause at least a short term impact to water quality.

7.6 Compliance with Other Laws and Regulations There is nothing inherent within the Proposed Action or Alternatives that would not be in compliance with other laws and regulations.

7.7 Forest Plan Consistency Determination In regard to water resources, there does not appear to be an inconsistency with the Forest Plan and the proposed actions.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 49 7.8 Literature Cited

Bureau of Land Management (BLM) 1999. FEIS for the Management Plan for the Grand Staircase–Escalante National Monument.

Bureau of Land Management (BLM) 1999b. Resource Management Plan for the St. George District.

Bureau of Land Management (BLM). 2006. Offer to lease and lease for oil and gas. Form 3100- 11.

Bureau of Land Management (BLM) 2007. Draft Resource Management Plan and EIS. Richfield District.

Bureau of Land Management (BLM) 2007b. Draft Resource Management Plan and EIS. Kanab District.

Bureau of Land Management and US Forest Service (BLM and USFS). 2007. Surface operating standards and guidelines for oil and gas exploration and development – the gold book. BLM/WO/ST-06/021+3071/REV 07. BLM. Denver, Colorado.

Environmental Protection Agency. 2007. Online listing of designated sole-source aquifers at: http://www.epa.gov/safewater/sourcewater/pubs/qrg_ssamap_reg8.pdf.

Hansen, Allen & Luce, Inc. 2005. Washington Water Conservancy District Petition for Classification of the Navajo/Kayenta and Upper Ash Creek Aquifers. July.

Millennium Science and Engineering, Inc. 2005. Escalante River Watershed Water Quality Management Plan. Prepared for Utah Department of Environmental Quality, Division of Water Quality.

State of Utah. 2007. Utah Administrative Code R317-2. Standards of Quality for Waters of the State. As in effect as of April 1, 2007. Accessed online on 5/4/07 at http://www.rules.utah.gov/publicat/code/r317/r317-002.htm#T8

Steiger, Judy I. 2007. Effects of Saline-Wastewater Injection on Water Quality in the Altamont- Bluebell Oil and Gas Field, Duchesne County, Utah, 1990-2005. U.S. Department of the Interior, U.S. Geological Survey Scientific Investigations Report 2007-5192.

US Department of Agriculture. Forest Service. 1986. Land and Resource Management Plan for the Dixie National Forest. Ogden, Utah .

1995a. Water resource background report. Dixie National Forest Oil and Gas Leasing EIS. Dixie National Forest. July.

1995b. Draft Environmental Impact Statement. Oil and Gas Leasing on Lands Administered by Dixie National Forest. June.

2004. Water – 2004 Dixie National Forest Monitoring Report.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 50

2006. Proposed Land Management Plan for the Dixie and Fishlake National Forests. Cedar City, Utah.

United States Geological Survey. 2007. National Water Information System : Web Interface. Accessed in May 2007 at http://waterdata.usgs.gov/ut/nwis.

USFS. See US Department of Agriculture. Forest Service.

Utah Division of Water Quality. 2006. Utah’s 2006 Integrated Report, Volume 2, 303(d) List of Waters. April 1, 2006.

____ 2007. Information accessed at: http://www.waterquality.utah.gov/watersheds/lakes/TROPICRS.pdf

Utah Division of Water Resources. July 2006. Municipal and Industrial Water Supply and Uses in the Kanab Creek/Virgin River Basin Data Collected for Calendar Year 2002). From: http://www.water.utah.gov/m&i/PDF/KanabVirgin/FinalKCVRM&I1-6-06.pdf

____ 2000. Utah State Water. Plan West Colorado Basin. August.

____ 1999. Utah State Water Plan. Sevier River Basin. June.

____ 1998 (Revised December 2000). Municipal and Industrial Water Supply and Uses in the Kanab Creek/Virgin River Basin Data Collected for Calendar Year 1997). From: http://www.water.utah.gov/m&i/PDF/KanabVirgin/KANVIR.pdf . July.

____ 1995. Utah State Water Plan. Cedar/Beaver Basin. April.

____ 1993. Utah State Water Plan. Kanab Creek/Virgin River Basin. August.

Washington County Water Conservancy District. 2006. Virgin River Watershed Management Plan. From: http://wcwcd.state.ut.us/Plan,%20Studies/Watershed%20Mgmt/VRWMP-all.pdf February.

Dixie Oil and Gas EIS Specialist Report: Water Resources DixieOG_EIS_TR_Water_ No 7_v19_Final.doc JBR Environmental Consultants, Inc. Page 51 Appendix 7A – Stipulation Forms

NO SURFACE OCCUPANCY STIPULATION Lava Fields Over Sensitive Aquifers Alternatives B, C, and D

No surface occupancy or use is allowed on the lands described below (legal subdivision or other description).

Lava fields over sensitive aquifers shown in Figure 7.4-2. This prohibition includes all surface disturbing activities such as roads, well pads, and other facilities.

For the purpose of:

Preventing any damage to water flow or quality of these sensitive aquifers.

A request for a waiver, exception, or modification (WEM) to the above lease stipulation may be requested along with the submission of a Surface Use Plan of Operations (36 CFR 228.104). Any changes to this stipulation will be made in accordance with the land use plan and/or the regulatory provisions for such changes. (For guidance on the use of this stipulation, see BLM Manual 1624 and 3101 or FS Manual 1950 and 2820). R4-FS-2820-14 (8/92)

NO SURFACE OCCUPANCY STIPULATION Streams, Lakes, Springs, Wetlands, and Riparian Areas – 500-foot Buffer Alternative B

No surface occupancy or use is allowed on the lands described below (legal subdivision or other description).

A 500-foot buffer zone from the high water point of any perennial streams, lakes, springs, wetlands, and riparian areas. 100-year floodplains are not included in this stipulation. This prohibition includes all surface disturbing activities such as roads, well pads, and other facilities. Some but not all of these features are mapped, so the actual areas of no surface occupancy would be determined based on actual ground conditions.

For the purpose of: Minimizing the contributions of sediments to watercourses, and minimizing the potential for spills or leaks to contribute pollutants to streams or other water features. This stipulation provides restrictions greater than in 36 CFR 228.108(j) under Standard Lease Terms due to the specific prohibition of surface occupancy within the buffer zone.

A request for a waiver, exception, or modification (WEM) to the above lease stipulation may be requested along with the submission of a Surface Use Plan of Operations (36 CFR 228.104). Any changes to this stipulation will be made in accordance with the land use plan and/or the regulatory provisions for such changes. (For guidance on the use of this stipulation, see BLM Manual 1624 and 3101 or FS Manual 1950 and 2820). R4-FS-2820-14 (8/92)

NO SURFACE OCCUPANCY STIPULATION Streams, Lakes, Springs, Wetlands, and Riparian Areas – 300-foot Buffer Alternative C

No surface occupancy or use is allowed on the lands described below (legal subdivision or other description). All areas within 300-foot buffer of the high water point of all perennial streams, lakes, springs, wetlands, and riparian areas. 100-year floodplains are not included in this stipulation. This stipulation applies to all surface disturbing activities, such as roads, pads, powerlines, and pipelines, but allows for perpendicular or near-perpendicular crossings such a needed for linear features like roads, pipelines, and powerlines as long as they are designed to minimize effects.

For the purpose of: Reducing the contributions of sediments to watercourses, and minimizing the potential for spills or leaks to contribute pollutants to streams or other water features. This stipulation provides restrictions greater than in 36 CFR 228.108(j) under Standard Lease Terms due to the specific prohibition of surface occupancy within the buffer zone.

A request for a waiver, exception, or modification (WEM) to the above lease stipulation may be requested along with the submission of a Surface Use Plan of Operations (36 CFR 228.104). Any changes to this stipulation will be made in accordance with the land use plan and/or the regulatory provisions for such changes. (For guidance on the use of this stipulation, see BLM Manual 1624 and 3101 or FS Manual 1950 and 2820). R4-FS-2820-14 (8/92)

NO SURFACE OCCUPANCY STIPULATION Municipal Watersheds Alternative C

No surface occupancy or use is allowed on the lands described below (legal subdivision or other description). Municipal watersheds shown in Figures 7.4-1, 7.4-2, 7.4-3, and 7.4-4. This prohibition includes all surface disturbing activities such as roads, well pads, and other facilities.

For the purpose of: Preventing any effects to water flow and quality of municipal watersheds and associated water sources.

A request for a waiver, exception, or modification (WEM) to the above lease stipulation may be requested along with the submission of a Surface Use Plan of Operations (36 CFR 228.104). Any changes to this stipulation will be made in accordance with the land use plan and/or the regulatory provisions for such changes. (For guidance on the use of this stipulation, see BLM Manual 1624 and 3101 or FS Manual 1950 and 2820). R4-FS-2820-14 (8/92)

CONTROLLED SURFACE USE STIPULATION

Streams, Lakes, Springs, Wetlands, and Riparian Areas – 300-foot Buffer Alternative D

Surface occupancy or use is subject to the following special operating constraints.

Special measures may be required within 300 feet of the high waterline of perennial streams, lakes, springs, wetlands, and riparian areas to minimize soil disturbance.

Platforms or other stabilizing structures may need to be installed to avoid blading and minimize soil disturbance for the establishment of well pads, roads, and other facilities. In general, the manner in which development activities would be permitted would be more restricted than Standard Lease Terms permit. This stipulation is not intended to prohibit perpendicular or near perpendicular stream crossings for linear facilities such as roads, power lines, and pipelines which are adequately designed to minimize effects.

On the lands described below:

Within 300 feet of the high waterline of perennial streams, lakes, springs, wetlands, and riparian areas that occur across the Dixie National Forest as shown in Figures 7.4-1, 7.4-2, 7.4-3, and 7.4-4, and as found on the ground during evaluations of proposed activities.

For the purpose of:

This stipulation provides greater protections than under Standard Lease Terms. This stipulation would minimize soil disturbance within the buffer zone.

Any changes to this stipulation will be made in accordance with the land use plan and/or the regulatory provisions for such changes. (For guidance on the use of this stipulation, see BLM Manual 1624 and 3101 or FS Manual 1950 and 2820).

CONTROLLED SURFACE USE STIPULATION

Municipal Watersheds Alternative D

Surface occupancy or use is subject to the following special operating constraints.

No surface disturbing operations would be permitted unless the Dixie National Forest finds that the leasee has sustained its burden of proof that the proposed activities do not create a foreseeable and substantial risk of pollution or disruption to the municipal watershed. No operation will be approved unless the operator can demonstrate that they have taken all reasonable measures to minimize surface use. Special conventions beyond normal operating procedures may be required in these areas.

On the lands described below:

Municipal Watersheds as designated at the time of lease issuance.

For the purpose of:

Protecting drinking water sources from contaminants. To protect drinking water sources from physical disruption.

Any changes to this stipulation will be made in accordance with the land use plan and/or the regulatory provisions for such changes. (For guidance on the use of this stipulation, see BLM Manual 1624 and 3101 or FS Manual 1950 and 2820).

Appendix 7B - Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements

Dixie National Forest Oil and Gas Construction and Operating Standards and Well Site Design Requirements

I. INTRODUCTION

The following operating standards and well site design requirements would be required by the Dixie National Forest for oil and gas facilities and operations to assure consistency with management objectives for the Forest. These operating standards should not be confused with stipulations contained in the applicable Federal oil and gas lease(s) which specify requirements regarding surface occupancy and timing within the specific areas in the lease. Operating standards must be consistent with the rights and restrictions established in the applicable lease(s) and are applicable to all drilling and production operations, unless otherwise approved by the responsible officer based on site-specific conditions.

These operating standards supplement the general requirements of the Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development (Gold Book) and Best Management Practices in place by the responsible agencies at the time of approval, and the Forest Service, Region 4 Oil and Gas Roading Guidelines. Copies will be made available to operators at first notification of proposed operations.

Authority to require such standards is provided by the Mineral Leasing Act of 1920, as amended, Federal Regulations at 36 CFR 228.106-108 (Submission, Review, and Requirements of Surface Use Plans of Operations) and 43 CFR 3162.3 (BLM procedures for approval of post-lease applications for operations).

II. PURPOSE

These operating standards have been developed to help operators meet agency and Forest requirement when planning operations and preparing their Surface Use Plan of Operations and to assure overall consistency with Forest Service management objectives/direction. They have been developed based on experience with oil and gas operations on National Forest System lands as needed to prevent or mitigate effects and conflicts with other uses.

III. PROCESS

Approvals of proposed operations on lease are subject to the application, review, and approval provisions specified in Onshore Oil and Gas Order No. 1, other Onshore Oil and Gas Orders, and all applicable laws and regulations. Surface disturbing proposals must be evaluated under the requirements of the National Environmental Policy Act of 1969 and the Energy Policy Act of 2005. Operators are encouraged to obtain these operating standards from the Forest Service early in the planning and approval process and to incorporate them into their Surface Use Plans of Operations to help streamline the NEPA analysis and approval process. If not incorporated into the initial SUPO, the Forest Service will work with the operator to revise the SUPO to include them or may otherwise require them as Conditions of Approval (COA).

Other standards or mitigations may be required based on site-specific evaluations of proposed activities. They may be modified if needed to address site-specific conditions.

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Operators are required to comply with all other applicable laws and regulations.

IV. OPERATING STANDARDS

These standards apply to the lease holder, contractors, and their sub-contractors. The term “operator” as used herein, includes the lease holder and/or company authorized to conduct operations on the lease or their contractors, subcontractors, and all employees or agents thereof.

1. The operator shall submit for review and approval, a detailed construction and maintenance plan for all exploration and production facilities and roads to be constructed or improved (reconstructed) for operations. Unless otherwise approved by the responsible Forest Service officer, pad designs must be consistent with requirements contained in the Dixie National Forest Well Site Requirements (Attachment 1). A road-use permit (or specific approval as part of the Surface Use Plan of Operations) must be obtained from the Forest Service for commercial use, improvement, and maintenance of National Forest System roads under authority of the National Forest Roads and Trails Act. Road designs must be generally consistent with the Forest Service guidelines provided in the Oil and Gas Roading Guidelines, R- 4.

2. The designs for roads, pads, and other facilities are subject to approval by the Forest Service. The designs must be approved and signed by a qualified licensed engineer. Any modifications to approved plans are subject to Forest Service review and approval.

3. Existing roads will be used to the extent possible as long as the existing alignment can be used or improved to the required standard. Additional roads or rerouting of existing road segments, if needed, shall be minimized and approved by the Forest Service prior to construction. Roads or road segments replaced and/or abandoned by construction of new roads or rerouting must be reclaimed by the operator. Road locations and designs must be generally consistent with the Forest Service guidelines provided in the Oil and Gas Roading Guidelines, R-4.

4. Locate and design roads and drainage structures to prevent slope failure and minimize impacts on water quality. To the maximum extent feasible, locate facilities, including service and refueling areas, on benches upslope from streams, lakes, ponds, riparian areas, and floodplains.

5. A pre-construction meeting including the responsible company representative(s), contractors, and the Forest Service must be conducted at the project work site prior to commencement of operations. Earthwork must be construction staked prior to this meeting. Approval of the designs and earthwork staking by responsible Forest Service official is required prior to beginning earthwork.

6. A Spill Prevention Control and Countermeasures (SPCC) Plan consistent with the current EPA Region VIII Oil and Hazardous Substances Regional Contingency Plan must be filed with the Forest Service and approved by the authorized officer prior to conducting any construction and operations on National Forest System lands. The plan must address the potential for spills to occur from haulage of materials and supplies to the construction/operations site(s) as well as drilling and production

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facilities. Material Safety Data Sheets (MSDS) for all potentially hazardous substances used for operations used for operations must be available on-site. Operators must be trained in MSDS protocols.

7. All surface disturbing activities, including reclamation, must be supervised by a qualified on-site responsible designated company representative(s) familiar with the approved plans as well as terms and conditions of approval. The designated representative(s) must be available for contact within the vicinity of the project area or by telephone at all times that operations are in progress. The name and contact telephone number of the designated company representative(s) must be filed with the responsible Forest Service official. A copy of all approved permits with specifications relative to operations in the project area must be available for inspection at the project site.

8. Topsoil must be salvaged from the area to be disturbed, stored, and protected from erosion and contamination until redistributed over recontoured areas for reclamation. The depth of topsoil to be salvaged must be determined though testing and approved by the Forest Service. Methods of topsoil handling and storage must be approved in project plans and specifications and/or appropriate project permits.

9. All vegetation removed by operations must be stored, used for reclamation, or disposed of as approved in project permits or as specified by the Forest Service. The operator must reimburse the Forest Service for the fair market value of all merchantable timber removed or damaged during operations. Prior to vegetation disturbance/removal all noxious weeds must be removed from the site and handled by approved methods needed to prevent spread of seeds.

10. Where determined appropriate by the responsible Forest Service officer, the operator may be required to bury pipelines and powerlines in or adjacent to roads to reduce surface disturbance and visibility. Designs must provide sufficient depth of cover and signs to indicate the type of pipeline(s), location, and depth to prevent damage from road maintenance and other surface disturbing activities in conformance with applicable Federal and State regulations.

11. Where feasible and appropriate, the operator will be required to centralize production facilities, use telemetry to monitor wells, and delay non-essential maintenance activities in important wildlife habitat during critical seasons of use to reduce the number of vehicle trips to the sites and activity that could disturb or stress wildlife.

12. Where needed to protect wildlife, the operator will be required to construct fences and/or nets on reserve pits or use other approved methods to prevent wildlife use or entrapment.

13. Stream crossings will be planned and constructed to minimize disturbance of the riparian and aquatic habitats by locating crossings at the most advantageous location and by crossing at or near the perpendicular. Structures must be designed to allow fish passage as needed to maintain habitat. Measures must be taken to minimize disruption of stream substrate. When no longer needed for operations, crossings must be removed and the stream and banks restored to pre-disturbance conditions/stream hydraulics. Sediment control measures must be used to minimize sediment introduction during all operations. Timing restrictions (construction and

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reclamation) may be needed to protect fisheries as coordinated with the Utah Division of Wildlife Resources and through permitting with the Utah Division of Water Rights, Stream Alteration Program.

14. Unless otherwise specified by the responsible Forest Service officer, new oil and gas access roads shall be closed to the public. Operators must construct and maintain gates to Forest Service design standards at intersections of project access roads with National Forest System roads or other highways to prevent unauthorized traffic from entering. A locking system will be required to allow a Forest Service lock in addition to the operator’s lock.

15. Off-road vehicle travel is prohibited unless specifically approved in project permits.

16. Roads used for drilling and production operations which remain open to public traffic must be properly signed to warn the public of project traffic and associated hazards. Signs must be consistent with the Manual on Uniform Traffic Control Devises, Federal Highway Administration.

17. Vehicle operators must obey posted speed restrictions. If speed restrictions are not posted, the operator and contractors must observe safe speeds commensurate with weather and road conditions.

18. Watering and/or application of appropriate dust suppressants shall be used if dust becomes a concern for visibility and sediment transport. Suppressants and application procedures are subject to approval by the responsible Forest Service officer.

19. Unless otherwise approved by the responsible Forest Service officer, all production pads will be fenced to prevent entry by the public and livestock. Designs and specifications are subject to Forest Service approval.

20. Sediment control structures will be used to catch sediment at the base of fill slopes on exploration and production pads. If silt fences are used, they must be constructed with adequate support and maintained to assure that they function at all times, including the winter season and spring runoff.

21. Establishment of staging areas or camp areas outside of the area permitted for surface disturbing operations for project personnel (operator or contractors) on National Forest System lands is subject to Forest Service approval.

22. All permanent survey markers within the area to be disturbed, including section corners, benchmarks, geodetic survey monuments, etc. must be located and flagged for protection prior to any surface disturbance activities. Disturbance or relocation of monuments requires the approval of the agency responsible for their use and preservation.

23. Water needed for operations must be obtained in accordance with State water law. The location and design of diversions on National Forest System lands are subject to review and approval of the responsible Forest Service official.

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24. The operator and all contractors shall take measures needed for the prevention of fires started as a result of their operations and to suppress fires that are started as a result of their operations. Fire suppression equipment must be available to all personnel in the project area consisting of shovels, axes, and other appropriate hand tools. At least one properly rated fire extinguisher must be available in each vehicle and around all machinery such that they are readily assessable for suppression of fires. During times of severe fire danger when fire restrictions are implemented by order of the responsible Forest Service officer, all operations must be conducted in conformance with the order. The operator may be required to submit and implement a Fire Prevention/Suppression Plan for review/approval by the responsible Forest Service official.

25. All vehicles and other gasoline/diesel-powered equipment must be equipped with properly functioning spark arresters and mufflers. Spark arresters must meet Forest Service specifications in accordance with USDA Forest Service Spark Arrester Guide.

26. The operator will be held responsible for damage and suppression costs for fires started as a result of operations. Fires must be immediately suppressed to prevent spreading and must be reported to the responsible Forest Service officer.

27. The operator must maintain structures, facilities, improvements, and equipment in a safe and neat manner and in accordance with approved permits. The operator must take appropriate measures in accordance with applicable Federal and State laws and regulations to protect the public from hazardous or conditions resulting from the operations. Such measures must include, but are not limited to, posting signs, building fences, or otherwise identifying the potentially hazardous site or condition.

28. All accidents or mishaps resulting in resource/property damage and/or serious personal injury must be reported to the responsible Forest Service officer as soon as possible.

29. The operator may be required to locate pads and facilities in areas where they can be effectively screened from view from sensitive areas. Production facilities must be located and designed to minimize visibility from sensitive viewing areas. Painting of facilities with a non-reflective paint in the color that would best blend with the background will be required. The color will be determined by the operator with approval of the responsible Forest Service officer.

30. The operator must comply with all applicable laws and regulations pertaining to the storage, use, and disposal of hazardous substances and solid or liquid waste. All fluids, chemicals, and solid wastes must be properly contained on-site. Reserve pits, catchment ponds, and bermed areas must be constructed to prevent seepage into the ground or adjacent areas. A minimum of 2-feet of freeboard must be maintained in all reserve pits and ponds at all times to prevent overflow and spillage into adjacent areas.

31. Chemical containers should not be stored on bare ground or exposed to the sun or moisture. Containers and labels are subject to degradation and punctured drums could leak contents onto the ground. Chemical containers should be maintained in good condition and placed within secondary containment in case of a spill or puncture.

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Secondary containment facilities must be of sufficient size to contain all appropriate fluids, including diesel or other fuels.

32. Sanitary facilities must be available to operators and contractors in the project area and properly used and maintained to prevent pollution. The installation of sanitary facilities, other than self-contained chemical toilets is subject to State and Forest Service approval.

33. Unless other methods are specifically approved, all solid wastes, contaminated soil materials, drill cuttings, petroleum products, and other fluids must be properly contained on-site. Disposal of associated waste materials must be at a facility licensed by the State to accept such materials.

34. Harassment of wildlife is prohibited. Pets must be properly restrained to prevent harassment of wildlife, livestock, government officials, and the public.

35. Move-in and move-out of heavy construction and drilling equipment will not be allowed during the opening weekends of the general big-game hunts or holiday weekends (including the observed holiday) from noon the previous day until midnight on Sunday or the observed holiday. Use and maintenance of National Forest System roads is regulated under authority of the National Forest Roads and Trails Act and the National Forest Management Act.

36. Vegetation seeding methods and seed mixes (species and amounts) used for interim and final reclamation must be approved by the Forest Service. Reclamation and revegetation plans and standards for success must be approved in project plans or permits. All vegetation materials, seeds, soil amendments, and sediment control materials must be certified that no noxious weed seed or noxious weeds are present. The operator is responsible for control and eradication of noxious weeds in project area, and the control and eradication of any invasive plant species not present at the site prior to operations, until such time as reclamation standards are met and the company is relieved of further reclamation responsibilities.

37. Vehicles and equipment shall be free of mud, soil, plant materials, and other debris which could contain noxious weed seeds prior to coming onto the Forest. This is needed to avoid transporting noxious weeds, or invasive species to sites on the Forest.

38. The operator shall follow Forest guidelines designed to prevent the introduction and spread of aquatic nuisance species (Dixie and Dixie National Forest Supplement, Forest Handbook 2509.16, chapter 1.

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Dixie National Forest Well Site Requirements

V. WELL SITE DESIGN REQUIREMENTS

A. General Requirements

The operator should propose locating the well site in cooperation with Forest Service personnel on the most nearly level location obtainable that would accommodate the intended use. However, potential well site locations should not be evaluated on the basis of site conditions alone. Access to the well site for road and possible future pipeline locations must also be considered in determining the most suitable location. What may be gained on a good location could be lost from an adverse access route. Plan the well site from the long-term standpoint, assuming a discovery could be made. Future pipeline locations are to be proposed by the operator as a part of his proposal on each well site.

Adjust the well site layout to conform to the best topographic situation. Avoid disturbance of drainages and locate reserve pits away from water courses. Deep vertical cuts and long fill slopes should be avoided. The cut and fill volumes should be balanced, excluding the topsoil and subsoil needed to backfill the reserve pit.

A contour map shall be developed for all well pad locations as an aid in the design of pad settings to the existing topography. This will allow the operator to plan the construction of facilities and the surface manager to evaluate impacts and calculate the bond more expeditiously and accurately. Maps should be prepared to a scale of 1 inch equals 20 feet horizontally and a contour interval of 2 feet vertically, or as otherwise directed by the responsible Forest Service officer.

Once this information is compiled, finished site elevations, cut and fill slopes and their respective catch points, drainage, balanced earth work, adequate storage area locations and other necessary construction features shall be determined and included with the drawings/specifications. Submittals shall include a well site plan (see Drawing No. 1), details of berms, diversion ditches, pits, catchments and other appurtenances and design features. Provide data to support drainage structure design.

B. Clearing

The site must first be cleared of all brush and trees. All merchantable timber must be purchased by the operator prior to cutting, at the appraised price determined by the Forest Service. Grasses and small shrubs need not be removed; however appropriate measure will be required to prevent the spread of noxious weeds and nuisance species prior to starting excavations if they occur on the site. Trees and brush will be disposed of by removal from the Forest, by burning, chipping, or other approved methods needed to prevent the spread of insects. Tree trunks less than 8 inches in diameter and slash can be stockpiled at an approved location to be spread over reclaimed areas. Burning permits will be required and are issued by the Forest Service. Burning would only be permitted if the fire danger is low to moderate.

C. Topsoil Removal and Storage

Surface soil material (topsoil), if present, will be stripped from all areas where surface

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disturbance is necessary and stockpiled. All topsoil will be removed in a separate layer, avoiding mixing with other excavated materials, and stored in a stockpile to prevent loss from erosion or contamination, and from which topsoil may be easily recovered. The depth of surface soil material to be removed and stockpiled will be specified by the Forest Service but will generally include the A Horizon. The topsoil and subsoil stock piles must be located to prevent contamination from the blooie line, flare line, and other operations. Stockpiles shall be contained by silt fencing, ditches and traps or other containment measures to prevent erosion, contamination and loss. If topsoil stockpiles are to remain for more than a single season, seeding with an approved seed mix will be required to minimize loss from erosion and preserve fertility and biological activity.

D. Site Grading

Cut and fill slopes will be such that stability can be maintained for the life of operations. Cut and fill slopes will be constructed as follows (exceptions can be made depending on the type and competency of material encountered):

Height of Slope Slope

0 – 5 feet 3:1 6 – 10 feet 2:1 over 10 feet 1.5:1

All fills will be free of vegetation and will be compacted in lifts no greater than 12 inches in thickness to a minimum of 90 percent Proctor dry density sufficient to prevent excessive settlement.

The drill site or pad surface will be surfaced with crushed gravel to a depth sufficient to support anticipated loads throughout the life of the well. Usually a depth of 12 inches of gravel is required.

E. Site Drainage

Diversion ditches having the minimum dimensions of 3 feet horizontal to 1 foot vertical (3:1 ditch) will be constructed around the site to divert existing drainages and surface runoff from flowing onto the site. Hydraulic design for ditches is required to determine capacity. The ditch(s) will be located at the top or base of the cut slope (to be determined based on site- specific conditions) and around the toe of the fill slopes (see Drawing No. 1 – Construction Requirements for Typical Well Sites). Straw dykes, catch basins, energy dissipaters or other approved structures will be constructed in the ditch outflow to trap any sediment and dissipate erosive flows. Provide data to support drainage structure designs. A culvert might be necessary where the access road enters the site.

A berm will be constructed around the perimeter of the site to contain all precipitation, spills, and other fluids from leaving the site. The berm will be a minimum of 18 inches high, 12 inches wide at the top, and have 1.5:1 side slopes. Berms will be compacted for stability and to reduce permeability as needed to contain fluids. The site surface will be graded at a minimum of 1 percent to drain to the reserve pit. Use silt fencing, ditches and traps or other containment at toe of fill slopes to prevent erosion and contamination.

The drainage pattern to be constructed will need to be designed for each site, depending on

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site-specific conditions.

F. Construction and Maintenance of Reserve Pits

Reserve pits will be constructed of sufficient size and capacity for the necessary fluids for drilling and to contain any runoff from the drill site. The pad will be graded to empty into the reserve pit or alternative pit or buried tank. Winter operations may require larger pits/tanks due to snow accumulations and runoff. Pits will not be constructed within intermittent or perennial drainage channels. If the operator has concerns that drainage from the pad could contaminate reserve pit muds, the pad can be constructed to drain into alternative lined pits or buried containment tanks.

It is preferred that pits be constructed in undisturbed materials and below the natural ground level to minimize the risk of failure. Where conditions exist that require pits to be constructed of embankment materials, the following criteria are required:

1. The area on which the embankment is to be placed will be cleared of all materials including vegetation, topsoil, and unconsolidated soils and gravels.

2. A foundation keyway will be designed and constructed into native materials to dimensions based on site-specific conditions to provide adequate anchoring and sealing of the embankment.

3. The embankment will be constructed using impermeable materials on slopes of 3:1 into the pit and 2:1 outside the pit. The embankment will have a minimum of 10-foot top width. The materials will be compacted to 95 percent Proctor density.

The following are requirements for construction and maintenance of all reserve pits:

4. Pits must be constructed to contain fluids without leaks throughout the life of operations. If pit liners other than clay coatings are used they must be constructed of sufficiently durable and watertight materials to prevent leakage. Compacted bedding material consisting of sand, clay, or other grout may be required to prevent rocks from puncturing the liner and to seal cracks.

5. A minimum of 2-foot freeboard will be maintained in the pit at all times during the drilling operations or if the pit is left unreclaimed over the winter.

6. If wildlife concerns exist, netting or some other approved method will be used to prevent wildlife use of the pit.

G. Site Reclamation for Nonproductive Wells

Reclamation of the entire site will be required and will commence immediately after drilling, testing, and well plugging/abandonment are complete. The site will be restored to as nearly as practical to its original condition (approximate original contour). Cut and fill slopes will be reduced and graded to conform to the adjacent terrain.

Reserve pits must be allowed to dry before they are backfilled. Fluids that will not dry must be removed from the Forest. All polluting substances or contaminated materials, such as

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oil, oil-saturated soils and gravels will be removed and disposed of at a State licensed facility licensed to receive these materials. Exceptions to allow for reserve pit solidification may be made if the operator can demonstrate to the responsible Forest Service officer that this method would be effective based on site-specific conditions.

Drainages will be reestablished and temporary measures will be required to prevent erosion on the site until all reclamation and revegetation standards established for the site are met.

In general, the well identification standpipe will be set such that it can be buried by at least two feet of soil. A final determination will be made on a case-by-case basis.

After final grading and before replacement of topsoil, the entire surface of the site shall be scarified to eliminate slippage surfaces and promote root penetration. Topsoil will be spread over the site to achieve approximate uniform stable thickness consistent with the established contours.

The site will be seeded and/or planted with a seed mix as approved in the SUPO or as otherwise approved by the responsible Forest Service officer. Nutrients and soil amendments will be applied to the disturbed surface soil needed to meet the revegetation standards.

A temporary fence will be constructed around the site until reclamation standards have been met. The fence design is subject to Forest Service approval will be designed to prevent entry by livestock or wildlife as needed for the specific area. The fence must be maintained such that it is functional at all times as intended to prevent livestock use and unauthorized access by the public. The operator is responsible for damages to the reclaimed condition of the site due to unauthorized access until final reclamation standards are met and the fence is removed. The operator will be responsible for eradicating noxious weeds and nuisance species each season until the final revegetation standards have been met. Once all reclamation standards have been met, the operator is responsible for removal of the fence, gate, and associated structures and materials.

H. Site Reclamation for Producing Wells

Interim and final reclamation for producing wells will be accomplished for portions of the site not required for the continued operation of the associated facilities. All disturbed surfaces will be treated to prevent erosion and to compliment the esthetics of the area. A new site plan will be required encompassing the facilities required for operation and interim reclamation measures. Generally, the following measures will be required:

1. The reserve pit will be reclaimed as previously discussed. 2. All polluting substances and contaminated materials, including contaminated soil and gravels will be disposed of as previously discussed. 3. All cut and fill slopes and other disturbed areas not needed for production operations will be contoured to match the surrounding area, topsoiled, and revegetated as previously discussed. 4. The berm will be reestablished on the production pad where removed to accomplish the reclamation discussed in the previous item.

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5. The pad perimeter and reclaimed area will be fenced. Once reclamation standards have been met for the reclaimed portion of the original pad the fence will be relocated onto the perimeter of the production pad. 6. Measures such as painting facilities an appropriate color, and other practical measures will be used to decrease visibility of the site as viewed from sensitive areas such as roads, highways, and recreation areas. Noise suppression devices and submersible pumps (if feasible) may be required as needed to meet scenic, wildlife, and recreation objectives for the area.

I. Site Maintenance

The site will require periodic maintenance to ensure that drainages remain functional and that surfaces are properly treated to reduce erosion, contamination, fugitive dust, invasion by undesirable plant species, and impacts to the adjacent areas.

All garbage, debris, and foreign materials shall be contained on site in a cage or other enclosure then will be removed to an established/licensed landfill or other recognized facility.

J. Site Reclamation for Production Wells

When production pads and production facilities are no longer needed, the facilities must be removed and final reclamation measures completed as previously prescribed for nonproductive wells. Abandoned or unneeded facilities will be removed/reclaimed within two years. In place abandonment of any facilities such as powerlines, pipelines, etc. will require approval of the Forest Service. If approved, appropriate measures to stabilize and decontaminate them will be required.

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