United States Department of the Interior Bureau of Land Management
Environmental Assessment DOI-BLM-Eastern States-0020-2021-0002-EA
EOI ES3321 Part 1 (1835a), Covington County, Alabama
December 2020
U.S. Department of the Interior Bureau of Land Management Southeastern States District Office 273 Market St Flowood, MS 39232
TABLE OF CONTENTS TABLE OF CONTENTS ...... 1 1. Introduction ...... 3 Identifying Information ...... 3 Background ...... 3 Purpose and Need for Action ...... 4 Decision to be Made ...... 4 Conformance with the Land Use Plan ...... 5 Relationship to Statutes, Regulations and Other NEPA Documents ...... 5 2. Public Involvement ...... 6 Internal Scoping ...... 6 External Scoping ...... 6 3. Proposed Action and Alternatives ...... 6 Proposed Action (Alternative A) ...... 6 3.1.1. Project Components and General Schedule ...... 7 3.1.2. Design Features ...... 7 3.1.3. RFDS ...... 7 No Action Alternative (Alternative B)...... 8 Alternatives Considered but Eliminated from Detailed Analysis ...... 8 4. Issues ...... 8 Issues Analyzed in Detail ...... 8 Issues Analyzed in Brief ...... 9 4.2.1. Noise Resources ...... 9 4.2.2. Visual Resources ...... 9 4.2.3. Socioeconomics and Environmental Justice ...... 10 4.2.4. Transportation ...... 10 4.2.5. Prime and Unique Farmlands ...... 10 4.2.6. Induced Seismicity ...... 11 4.2.7. Sinkholes and Subsidence ...... 11 5. No Action Alternative and Baseline Conditions ...... 12 Impacts of the No Action Alternative for All Issues ...... 12 Baseline Conditions ...... 12 5.2.1. Past and Present Actions ...... 12 5.2.2. Reasonably Foreseeable Future Actions and Trends ...... 12 6. Affected Environment and Potential Environmental Impacts ...... 13 General Setting & Access to the Project Area ...... 13 6.1.1. EOI ES3321 Part 1 (1835a) ...... 13 6.1.2. Impacts Common To All Resources ...... 13 Land Use ...... 13 Cultural Resources and Native American Concerns ...... 15
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Minerals and Mineral Development ...... 17 Wastes ...... 19 Air Resources ...... 20 Soils ...... 23 Water Resources ...... 26 6.8.1. Surface Water Resources ...... 27 6.8.2. Ground Water Resources ...... 30 6.8.3. Floodplains ...... 32 Invasive/Exotic Species ...... 33 Vegetation ...... 35 Wildlife ...... 36 Special Status Species ...... 38 Migratory Birds of Conservation Concern ...... 42 Irreversible and Irretrievable Commitment of Resources ...... 44 Relationship Between Local Short-term Uses and Long-term Productivity ...... 44 7 Supporting Information ...... 45 7.1 List of Preparers ...... 45 7.2 Tribes, Individuals, Organizations, or Agencies Consulted ...... 45 7.3 References ...... 46 Appendix A. Maps ...... 51 Appendix B. Mitigation Measures ...... 57 Lease Stipulations ...... 57 Recommended Best Management Practices (BMPs) ...... 60 Lease Notices ...... 60 Appendix C. Summary of Anticipated Effects Across All Resources ...... 61 Appendix D. USFWS and Cultural Consultation Letters ...... 64 Appendix E. Reasonably Foreseeable Development Scenario ...... 71 Appendix F. National Ambient Air Quality Standards ...... 74 Appendix G. USFWS Birds of Conservation Concern (BCC) ...... 76 Appendix H. Acronyms and Abbreviations ...... 78 Appendix I. Soil Characteristics ...... 81 Appendix J. Air Resources Supplemental Data Tables ...... 88
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1. INTRODUCTION Identifying Information
Project Title: EOI ES3321 Part 1 (1835a), Covington County, Alabama
Legal Description: EOI ES3321 Part 1 (1835a), Covington County, AL: T. 3 N., R. 14 E. Sec. 11 NWNW; Sec. 14 NWNE (80.24 acres).
NEPA Document Number: DOI-BLM-Eastern States-0020-2021-0002-EA
Background The Eastern States State Office (ESSO) of the Bureau of Land Management (BLM) conducts quarterly competitive sales to lease available oil and gas parcels. Interested parties such as private individuals or companies may file Expressions of Interest (EOIs) to nominate parcels for competitive bid and leasing by the BLM. The ESSO publishes a Notice of Competitive Lease Sale, which lists lease parcels to be offered at the auction, at least 45 days before the auction is held. Lease stipulations applicable to each parcel are specified in the Sale Notice. Decisions as to which public lands and minerals are open for leasing and what leasing stipulations may be necessary are made during the land use planning process using available information. Constraints on leasing and any future development of split estate parcels are determined by BLM in consultation with the appropriate surface management agency or the private surface owner.
BLM will only lease subsurface mineral estate owned by the United States. The Southeastern States District Office (SSDO) manages the federal mineral estate underlying 11 states in the southeast. The SSDO prepares an analysis for EOIs consistent with the National Environmental Policy Act (NEPA), most commonly in the form of an Environmental Assessment (EA). NEPA documents for the nominated parcels are prepared in accordance with the BLM Washington Office Instruction Memorandum (IM) No. 2018-034 and are posted on the SSDO’s online NEPA register for a 15-day public comment period. Comments received from the public are reviewed and incorporated into the NEPA documents, as applicable.
After the SSDO completes the NEPA analysis and returns them to the ESSO, a list of available lease parcels and associated stipulations is made available to the public through a Notice of Competitive Lease Sale (NCLS). Lease sale notices are posted on the Eastern States BLM website at: https://www.blm.gov/programs/energy-and-minerals/oil-and-gas/leasing/regional- lease-sales/eastern-states. The BLM may defer or withhold additional parcels prior to the day of the lease sale. In such cases, BLM prepares an addendum to the sale notice.
A parcel comprising 80.24 acres of federal minerals underlying private surface in Covington County, Alabama was nominated to the ESSO and will be made available for lease at the March 2021 Competitive Oil and Gas Lease Sale. This EA documents the review of the nominated parcel under the administration of the SSDO, serves to verify conformance with the approved land use plan, and provides the rationale for the SSDO’s recommendation to offer or to defer this parcel for the March 2021 Lease Sale.
If the proposed parcel is not leased at the March 2021 Lease Sale, it will remain available to be leased for a period of up to two years to any qualified lessee at the minimum bid cost. Parcels obtained in this way may be re-parceled by combining or deleting other previously offered lands. Mineral estate that is not leased within a two-year period after an initial offering will no longer be available and must go through a competitive Lease Sale process again prior to being leased. The act of leasing does not authorize any development resulting in surface disturbance or occupancy within leased lands without further application by the lessee and approval by BLM in coordination with the surface owner. However, if the proposed lease is sold at the quarterly sale, the lease would provide the lessee exclusive rights to explore and develop oil and gas reserves on the lease.
In the future, BLM may receive Applications for Permit to Drill (APDs) for this leased parcel. If APDs are received, BLM conducts additional site-specific NEPA analysis before deciding whether to approve the APD, and what conditions of approval (COAs) should apply. Although there would be no surface disturbance from the action of leasing, this Environmental Assessment (EA) analyzes a Reasonably Foreseeable Development Scenario (RFDS) to address the anticipated environmental effects from potential future oil and gas development that are considered reasonably foreseeable, although unknown in specific detail at this time.
Purpose and Need for Action The purpose of the Proposed Action is to consider opportunities for private individuals or companies to explore and develop federal oil and gas resources through the competitive leasing process.
The need of the Proposed Action is to respond to the EOI nominated by outside parties in support of development of oil and natural gas resources that are essential to meeting the nation’s future needs for energy, while minimizing adverse effects to natural and cultural resources. It is the policy of the BLM as mandated by various laws, including the Mineral Leasing Act of 1920, as amended [(30 United States Code [USC] 181 et seq.), the Federal Land Policy and Management Act of 1976 (FLPMA) ( 43 USC 1701), and the Energy Policy Act of 2005 (42 USC 13201 et seq.) to make mineral resources available for development to meet national, regional, and local needs. The oil and gas leasing program managed by the BLM encourages the sustainable development of domestic oil and gas reserves which reduces the dependence of the United States on foreign sources of energy as part of its multiple-use and sustainable yield mandate.
Decision to be Made Based on the analysis contained in this EA, the BLM will decide whether to approve or deny the proposed EOI ES3321 Part 1 (1835a) and if so, under what terms and conditions. Under NEPA, the BLM must determine if there are any significant environmental impacts associated with the Proposed Action warranting further analysis in an environmental impact statement (EIS). The Southeastern States District Office (SSDO) District Manager is the decision maker who will determine if it is appropriate to sign a Finding of No Significant Impact (FONSI). The Eastern States State Director is the decision maker who will decide one of the following:
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• To approve EOI ES3321 Part 1 (1835a) with design features as submitted, • To analyze the effects of the Proposed Action in an EIS, or • To deny EOI ES3321 Part 1 (1835a).
Conformance with the Land Use Plan The Proposed Action is subject to and is in conformance (43 CFR 1610.5) with the following land use plan:
Land Use Plan: BLM Alabama and Mississippi Proposed Resource Management Plan and Final Environmental Impact Statement (AL/MS RMP and FEIS)
Date Approved: August 2008
Decision Language: “The purpose of the AL/MS RMP is to prepare a single land use plan for the two States so that the BLM will be able to respond to mineral leasing proposals.” The AL/MS RMP and FEIS allows for “…760,570 acres of BLM-administered, Federal Mineral Ownership to be open to oil and gas leasing” (page ES-1). The proposed parcel is within the decision area outlined in the approved AL/MS RMP and FEIS.
Authority: Although the RMP does not mandate decisions for federal minerals leasing, the BLM is obligated to follow the authority of the Mineral Leasing Act of 1920, as amended and supplemented (30 USC 181), and the FLPMA, as amended, and the associated regulations at 43 CFR Part 1600, which give the BLM responsibility for oil and gas leasing on approximately 564 million acres of BLM, national forest, and other federal surface lands, as well as state and private surface lands where subsurface mineral rights have been retained by the United States Government.
Relationship to Statutes, Regulations and Other NEPA Documents The Proposed Action does not conflict with any known state or local planning or zoning law, regulation, policy or ordinance. The BLM’s policy is to promote oil and gas development if it meets environmental and natural resources management and planning guidelines and regulation standards set forth by NEPA and other subsequent laws and policies of the United States, including, but not limited to the following:
• NEPA [42 U.S.C. 4321 et seq.] and the associated Council on Environmental Quality (CEQ) regulations at 43 CFR Parts 1500-1508 • Federal Onshore Oil & Gas Leasing Reform Act of 1987 [30 U.S.C. § 181 et seq.] • National Historic Preservation Act of 1966, as amended [54 U.S.C. § 300101 et seq.] • Clean Air Act [42 U.S.C. § 1857 et seq.], as amended and recodified [42 U.S.C. § 7401 et seq.] • Clean Water Act [33 U.S.C. § 1251 et seq.] • American Indian Religious Freedom Act of 1978 [42 U.S.C. 1996] • Paleontological Resources Preservation Act of 2009 [16 U.S.C. §470aaa et seq.]
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• Native American Graves Protection and Repatriation Act of 1990 [25 U.S.C. § 3001 et seq.] and 43 CFR § 10 • Executive Order (EO) 13007 – Indian Sacred Sites • Endangered Species Act [16 U.S.C. § 1531 et seq.], as amended • Bald and Golden Eagle Protection Act of 1940, as amended [16 U.S.C. § 668 et seq.] • Federal Onshore Oil and Gas Leasing Reform Act (FOOGLA) • Migratory Bird Treaty Act [16 U.S.C. § 703 et seq.] • Resource Conservation and Recovery Act (1976), as amended • Comprehensive Environmental Response Compensation and Liability Act of 1980 • Executive Order (EO) 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations
2. PUBLIC INVOLVEMENT The BLM invites public participation in the NEPA process. Consideration of the views and information provided by all interested persons promotes open communication and enables more informed decision-making. All agencies, organizations, and members of the public having a potential interest in the Proposed Action are encouraged to participate in the decision-making process. The BLM uses a scoping process to identify potential significant issues in preparation for impact analysis. The principal goals of scoping are to identify issues, concerns, and potential impacts that require detailed analysis. Scoping is both an internal and external process.
Internal Scoping Internal scoping was initiated on this project on October 8, 2020 with an interdisciplinary team meeting. The interdisciplinary team consists of a Planning and Environmental Coordinator, Planning and Environmental Specialist, Environmental Protection Specialist, Wildlife Biologist, Archaeologist, Geologist, and GIS specialist. The interdisciplinary team used various sources of information to prepare the EA, including existing data inventories, online resources, information collected onsite, and analysis from a previous project adjacent to the proposed lease parcel (EOI ES3321 (1835b) analyzed in DOI-BLM-Eastern States-0020-2020-0009-EA). Documentation of the physical site characteristics and site conditions relied on aerial imagery, United States Geologic Survey (USGS) topographic mapping, and reconnaissance site visits. No major issues of concern were identified during internal scoping.
External Scoping A project description was posted on the SSDO’s on-line NEPA register in ePlanning on October 14, 2020. The draft EA and draft FONSI were available for a 15-day public review and comment period beginning December 14, 2020 and ending December 30, 2020. Legal notices were placed in the printed and online versions of the Andalusia Star News to notify the public of the opportunity to comment on December 2, 2020.
3. PROPOSED ACTION AND ALTERNATIVES Proposed Action (Alternative A)
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3.1.1. Project Components and General Schedule The Proposed Action is to lease 80.24 acres of federal minerals underlying privately owned surface (split-estate) located in Covington County, Alabama (described in Section 1.1 and shown in Appendix A) for potential future oil and gas development. BLM is limited in its decision-making authority to the federal subsurface mineral resources. Decisions concerning surface disturbance and occupancy on the private surface and/or subsurface resources will be made by the private landowner and operator and will need to be in compliance with all local, state and federal laws including, but not limited to, the Endangered Species Act (ESA), National Historic Preservation Act (NHPA), and Clean Water Act. The proposed lease would provide the lessee exclusive rights to explore and develop oil and gas reserves on the lease, although it does not in itself authorize surface disturbing activities or obligate the lessee to drill a well on the parcel in the future. Should the proposed parcels be leased and a detailed plan for oil and gas development be identified, the BLM would conduct future site-specific environmental analysis prior to any ground-disturbing activities.
Before a lease owner or operator occupies or conducts any surface-disturbing activities related to development of this lease to access federal minerals, the BLM must first approve an APD as specified in Title 43 CFR 3162. In an APD, an applicant proposes to drill the well subject to the terms and conditions of the lease. Upon receipt of an APD, the BLM may request and conduct an onsite inspection with the applicant and preferably, the private landowner or surface management agency. The BLM also conducts additional site-specific NEPA analysis and the appropriate consultations under the ESA and NHPA prior to approving the APD. Although there would be no surface disturbance from the action of leasing, this EA analyzes an RFDS to address the potential environmental effects from potential future oil and gas development that are considered likely to occur but are unknown in specific detail at this point in time. For example, estimates are projected for the likely number of wells to be constructed; however, well locations may change at the APD stage. Potential surface impacts, as outlined in the RFDS, have been considered for analysis in this EA.
3.1.2. Design Features BLM issues oil and gas leases for an initial 10-year period. These leases continue thereafter if oil or gas is produced in paying quantities. If a lessee fails to produce oil and gas, does not make annual rental payments, does not comply with the terms and conditions of the lease, or relinquishes the lease, then ownership of the minerals reverts to the federal government.
3.1.3. RFDS EOI ES3321 Part 1 (1835a) contains 80.24 acres of federally-owned mineral estate underlying privately-owned surface. Reasonably foreseeable activities that could occur as a result of future oil and gas development associated with leasing this parcel includes surface disturbance associated with preparation for drilling, including construction of an access road, drilling pad, and reserve pit (Table 1). The total surface disturbance predicted under the RFDS for EOI ES3321 Part 1 (1835a) is approximately 9.86 acres, which includes projected surface disturbance associated with the well pad and pit (approximately 6.42 acres) and construction of access roads
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(approximately 3.44 acres) (Appendix E). The RFDS projects that one well would be drilled from one well pad on private surface to private minerals with a separate well drilled from a different well pad located on private surface and penetrating federal minerals. The extent of the impacts to mineral resources would be further determined once site-specific development information is available at the APD stage if federal minerals are to be penetrated.
Table 1. RFDS Disturbances (acres) for Alabama EOI ES3321 Part 1 (1835a). EOI Number State and EOI Access Well Pad Utility and/or Total County Acreage Road and Pit Pipeline ROW Disturbance EOI ES3321 AL, 80.24 3.44 6.42 0 –Use access 9.86 Part 1 (1835a) Covington acres road ROW County (0.95 mile)
No Action Alternative (Alternative B) Under the No Action Alternative, the BLM would not offer for competitive bid or lease the proposed 80.24 acres of federal mineral estate for potential future oil and gas development. Not leasing EOI ES3321 Part 1 (1835a) would not meet the purpose of and need for the Proposed Action. CEQ guidelines (40 CFR 1502) stipulate that the No Action Alternative should be analyzed to assess any environmental consequences that may occur if the Proposed Action is not implemented and to serve as a baseline for comparing impacts of the Proposed Action. Therefore, the No Action Alternative has been retained for analysis in this EA.
Alternatives Considered but Eliminated from Detailed Analysis No feasible alternative surface locations were identified for the proposed project that would result in less impacts than the proposed location. As a result, BLM did not consider any other alternatives aside from the Proposed Action and the No Action Alternative.
4. ISSUES The CEQ Regulations state that EAs should “briefly provide sufficient evidence and analysis” for determining whether to prepare an environmental impact statement (EIS) or a FONSI (40 CFR 1501.5) and that agencies should only briefly discuss issues other than significant ones (40 CFR 1500.4(e)). While many issues may arise during scoping, not all of the issues raised warrant analysis in an EA. Issues will be analyzed if: 1) an analysis of the issue is necessary to make a reasoned choice between alternatives, or 2) if the issue is associated with a significant impact, or where analysis is necessary to determine the significance of the impact. The following sections list the resources considered and the determination as to whether they require additional analysis.
Issues Analyzed in Detail Based on a review of the context and scale of the Proposed Action, the following issues are analyzed in detail in this EA (Section 6): Land Use, Cultural Resources and Native American Concerns, Minerals and Mineral Development, Wastes, Air Resources, Soils, Water Resources – Surface Water, Ground Water and Floodplains, and natural resources including; Invasive/Exotic Species, Vegetation and Wildlife, Special Status Species, and Migratory Birds of Concern.
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Issues Analyzed in Brief Based on a review of the context and scale of the Proposed Action, the following issues have been considered but eliminated from further analysis with justifications provided:
4.2.1. Noise Resources The extent to which individuals are affected by noise is controlled by several factors, including the duration and frequency of sound; the distance between the source and the receptor; the intervening natural or man-made barriers or structures; and the ambient environment. Typically, levels of noise are measured in units called decibels (dB). Construction equipment generates between 70 and 115 decibels (dB). Typical noise associated with oil and gas activities include the actual drilling, the pumps (that extract the oil), the engines, the compressor and the vehicle traffic to and from the site. Noise associated with oil and gas development typically continues non-stop for 30 days for each well that is constructed, but after this initial development period, the noise is expected to be reduced.
While the act of leasing federal minerals would not contribute to noise disturbances, subsequent exploration/development may. It is unknown at this time if development will occur on or off- lease. Noise generation from well operations would be associated with vehicle movements and the operation of production equipment. There could be short term noise impacts associated with construction, drilling, and/or completion of reasonably foreseeable oil and gas development activities where development occurs. Noise generating activities would lessen over time as production commences and the sites are visited periodically to haul produced fluids. Noise resources may be further analyzed at the APD stage when a site-specific development proposal is received.
4.2.2. Visual Resources Potential future development across all parcels is anticipated to occur on private property with no public access. The proposed lease parcel is located in a rural, forested area with few nearby residences. However, until a site-specific development proposal is received at the APD stage, it is unknown how development of the Proposed Action will definitively affect the viewshed in the area.
Visual impacts due to lease development may be short or long term, depending on when oil and gas activities are completed and reclaimed. Visual quality could be impacted through: increased visibility of constructed features such as roads, well pads, pipelines, and tank batteries; road degeneration from heavy trucks and vehicles following rain; dust and exhaust from construction, drilling, and production vehicles and equipment; vegetation removal; unreclaimed sites; and/or discarded equipment. Well pads, power lines, access roads, and associated production facilities and storage tanks have the greatest potential to alter visual conditions over the life of a well. Vegetation removal would present an obvious contrast in color with the surrounding vegetation and affect visual resources in the area for more than a decade. These impacts would be most obvious immediately after construction. Impacts would decrease as the disturbed surface began to blend in color, form, and texture, if interim or final
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reclamation occurs. Long-term visual impacts could persist as long as the well is producing, which typically is twenty to thirty years for wells within the Haynesville Frisco City Sandstone Formation. Long-term impacts may include vegetation removal, alteration of the landscape, and installation of equipment and facilities. Reclamation activities would result in some of the land being reverted to natural conditions over time, although any reclamation activity would be at the discretion of the private landowner.
4.2.3. Socioeconomics and Environmental Justice Based on United States Census Bureau data (2018), there is no evidence of socioeconomic disparity or environmental justice population presence in Covington County, Alabama. Less than a sixth of the population in Covington County is of minority status (15.5%). The percentage of persons in poverty in Covington County (19.9%) is 3–5% higher than the state of Alabama as a whole (16.8%).
4.2.4. Transportation The proposed EOI is located in a rural area with low vehicular traffic. No changes to existing travel routes or access points currently used by the public are anticipated if the Proposed Action is developed in the future. Access roads, totaling 0.95 mile with a 3.44-acre footprint, may be needed if the Proposed Action is fully developed in the future; however, this new road development will likely occur on private property, which cannot be used by the general public. Some existing roads, likely on private surface, may need to be upgraded to facilitate heavy equipment travel. Effects to traffic patterns on the nearby road system may vary depending on the location(s) of the future well(s) and the time of day the roads are used. Increases in vehicle traffic associated with potential future mineral development may result in periodic traffic-related inconveniences. Increases in the amount of traffic present on existing public roads would be most noticeable for a short duration during the construction and drilling phases of development and reduce to an undetectable level during the production phase when only a few vehicles would visit well pads intermittently. Any increase in truck traffic may also increase the risk of potential traffic-related accidents. Increases in vehicle traffic resulting from future mineral development could potentially increase vehicle-wildlife collisions in addition to potentially increasing noise, dust, and soil compaction. This issue will be further considered at the APD stage if new road development or existing road upgrades will alter the current traffic flow, travel routes or public access points.
4.2.5. Prime and Unique Farmlands The Farmland Protection Policy Act discourages Federal activities that would convert farmland to nonagricultural purposes. Prime farmland is a designation assigned by U.S. Department of Agriculture in order to define land that has the best combination of physical and chemical characteristics for producing food, feed, forage, fiber, and oilseed crops and is also available for these land uses.
There are no prime farmlands in Section 11 of EOI ES3321 Part 1 (1835a). Section 14 of the parcel contains approximately 3.6% of prime farmlands (Appendix I, Table I.1.). These designated prime farmlands are not currently being used for agricultural purposes. However,
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BLM would encourage an alternate siting location at the APD stage (per 43 CFR 3101.1-2) if development were proposed on prime farmlands, in order to preserve the soil integrity of those lands for future use.
4.2.6. Induced Seismicity There would be no impacts to induced seismicity from issuing new oil and gas leases because leasing does not directly authorize oil and gas exploration and development activities. Earthquakes in the southeast are low probability, high impact events. The size of an earthquake can be expressed by either intensity or magnitude. Magnitude is based on an instrumental recording that is related to energy released by an earthquake and is a logarithmic measure of the earthquake’s size, while intensity describes the observed (felt) effects of an earthquake by people (Louisiana Geological Survey, 2001).
According to the USGS Earthquake Hazards Program, there have only been 17 earthquakes above 2.5 magnitude in south Alabama since 1920 (USGS, 2020a). The intensity of a 2.5 Mw or less earthquake is described as “usually not felt, but can be recorded by seismograph” (Michigan Tech, 2020). According to the USGS induced seismicity model, Covington County has a low (<1%) chance of experiencing seismic activity of sufficient intensity and duration that could cause slight damage to large infrastructure, including private homes other private property (USGS, 2020d). Hydraulic fracturing associated with the production of 2 wells would create a miniscule incremental increase in the induced seismic activity in Covington County, Alabama. Development of the proposed lease is not anticipated to contribute to felt induced seismic activity.
4.2.7. Sinkholes and Subsidence Sinkholes are common where the rock below the land surface is limestone, carbonate rock, salt beds, or rocks that can naturally be dissolved by groundwater circulating through them. The substrate underlying Covington County can be generally classified as evaporite rocks composed of salt, gypsum, and karst (USGS, 2020c). Humans have been documented to contribute to sinkholes by pumping groundwater. “If large amounts of groundwater are pumped from an area that is composed of a thick layer of fine-grained material, then the land can become more compacted once the water is removed” (USGS, 2020b). This process would result in soil settling that could contribute to surface infrastructure damage. The amount of water needed to hydraulically fracture a well depends on the geologic basin, the formation, and depth and type of well (vertical, horizontal, directional), and the proposed completion process. During the EOI phase, the water source to be used for activities that will occur during the APD phase (i.e., drilling, production, etc.), the quantity of water needed for such activities, and whether hydraulic fracturing will be necessary are unknown. BLM cannot reasonably foresee if groundwater will be used for future proposed wells that may contribute to sinkholes and/or soil settling. While sinkholes are prevalent in southern Alabama, the leasing stage would have no direct effect on sinkholes or subsidence in the area. Site-specific analysis for sinkholes and subsidence will be evaluated at the APD phase.
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5. NO ACTION ALTERNATIVE AND BASELINE CONDITIONS
Impacts of the No Action Alternative for All Issues Under the No Action Alternative, the proposed lease parcel would not be made available for lease. There would be no subsequent impacts from oil and/or gas construction, drilling, and production activities. The No Action Alternative would result in the continuation of the current land and resource uses in the proposed lease areas. Any impacts that are presently occurring to natural or cultural resources would continue under the No Action Alternative.
Baseline Conditions Past, present, and reasonably foreseeable future actions independent of the Proposed Action are considered to be baseline conditions of the No Action Alternative and Affected Environment of the Proposed Action. The baseline conditions include predictable future trends in the area (i.e., if the affected environment has a history of oil and gas development on private land developing private mineral estate and it is reasonable to foresee continued development in the future).
5.2.1. Past and Present Actions There are four inactive private wells, and three active, producing private wells within a two mile radius of EOI ES3321 Part 1 (1835a). There are several existing plugged oil wells and dry holes to the south and southeast of the parcel on the current landowner’s property (Appendix A, Figure A.1). This two-mile area surrounding EOI ES3321 Part 1 (1835a) is rural with little development and is entirely private land, so there is no information available regarding current activities that could be impacting resources in this area, including soil, vegetation, land use, and wildlife resources.
Approximately 50% of the area surrounding this parcel within a ten-mile radius has been cleared of forest for private purposes including several towns, including Andalusia, Alabama (population approximately 10,000 people), roads, timberlands, cattle operations and crop lands. Approximately ten miles west of the proposed EOI in Conecuh County, oil and gas activity seems to be prevalent with over 150 well pads located within a five-mile radius (as observed through aerial photographs). The Conecuh National Forest is approximately 4 miles south of the project area. Current projects planned on the Conecuh National Forest consist of wildlife habitat improvements, restoration and facility maintenance. The Schedule of Proposed Actions (SOPA) for the National Forests in Alabama, including the Conecuh National Forest, is available at https://www.fs.fed.us/sopa/forest-level.php?110801.
5.2.2. Reasonably Foreseeable Future Actions and Trends Offering the subject parcel for lease and the subsequent issuance of the lease, in and of itself, would not result in any changes to current conditions or reasonably foreseeable future trends. The analysis of the Proposed Action includes information regarding relevant impacts that could occur in the future associated with potential reasonably foreseeable oil and gas development, including potential reasonably foreseeable oil and gas development from another lease parcel,
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ES3321 (1835b). This serves as the basis for assessing possible changes to the current conditions or reasonably foreseeable future trends to better inform the decision-maker.
Further NEPA analysis at the APD stage, if necessary, will address reasonably foreseeable impacts of any proposed development at the site-specific level; however, this EA does discuss impacts from leasing on the current conditions or reasonably foreseeable future trends on a general level. A discussion of the current conditions and reasonably foreseeable future trends under each resource is offered in the Affected Environment section.
6. AFFECTED ENVIRONMENT AND POTENTIAL ENVIRONMENTAL IMPACTS General Setting & Access to the Project Area
6.1.1. EOI ES3321 Part 1 (1835a) EOI ES3321 Part 1 (1835a) consists of one parcel separated into 2 geographically independent tracts, totaling 80.24 acres, on privately owned surface located in central Covington County in southern Alabama (Appendix A, Figure A.1). The parcel is located approximately 8.5 miles southwest of the town of Andalusia, Alabama. A reconnaissance site visit occurred on October 18, 2019.
This tract consists entirely of a pine mixed hardwood forest. Dominant tree species include water oak (Quercus aquatica), sweetgum (Liquidambar styraciflua), loblolly pine (Pinus taeda), wax myrtle (Myrica cerifera), laurel oak (Q. laurifolia), and Chinese tallow (Triadica sebifera). This parcel is used as a hunting property and has many dirt trails and roads running through it.
6.1.2. Impacts Common To All Resources There would be no impacts to any resources as a result of leasing parcel ES3321 Part 1 (1835a) because there would not be any surface disturbance or otherwise activity in the human environment during the administrative process of leasing the parcel. Any impacts that would happen to the human environment would take place if potential future oil and gas development occurs and would be further analyzed at the APD stage.
Land Use How would future potential development on the nominated lease parcel impact current land use?
Affected Environment ES3321 Part 1 (1835a) is located within a pine mixed hardwood forest. Multiple trails and dirt roads run through the tracts. This parcel is used as hunting property for white tailed deer (Odocoileus virginianus), turkey (Meleagris gallopavo), and Eastern cottontail rabbit (Sylvilagus floridanus).
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A two-mile radius was used as the analysis area for land use because drilling technology in this area will not allow for drilling any farther than 2 miles. Further, this area exhibits a similar land use pattern on the landscape. The area within the two-mile radius of EOI ES3321 Part1 (1835a) exhibits typical land use patterns found in the Southeastern Plains ecoregion (Griffith, et al., 2001); this complex use pattern consists of a mostly forested (pine) landscape containing frequent, scattered, open farmland and pastureland on dissected, irregular plains and gently rolling hills. Hay, cattle, dairy, and poultry production are the primary commodities. Forested woodland occupies slopes along drainages with cleared fields for agriculture and pastureland occupying flatter, more level terrain. Within this two-mile radius, approximately 6,641 acres are evergreen forest, 1,738 acres are woody wetlands, 1,469 acres are mixed forest, 614 acres are hay and pasture fields, 531 acres are shrubland, 416 acres are crop fields, 369 acres are herbaceous forest, 312 acres are developed open space, 137 acres are open water, 127 acres are deciduous forest, 32 acres are developed land reflecting low development, 30 acres are herbaceous wetlands, and a remaining 3 acres of barren land and land with medium development (Land Use Data 2020, Crop Land Data 2020).
Brooklyn Road (County Road 42) is approximately 0.25 mile north of the portion of EOI ES3321 Part 1 (1835a) in Section 11. Loango Road (County Road 7) intersects with Brooklyn Road approximately 0.80 mile northwest of the portion of the EOI in Section 11. All other roads within the analysis area are private dirt and gravel roads.
There are currently 24 active federal oil and gas leases within Covington County; however, there are no active wells producing federal minerals. There are three active wells and four inactive wells on private estate producing private minerals within the analysis area. There is an existing, active Federal lease parcel for oil and gas resources adjacent to EOI ES3321 Part 1 (1835a), called EOI ES3321 (1835b), for which the lease was sold in June 2020 (Appendix A, Figure A.2).
The area surrounding both EOI ES3321 Part 1 (1835a) and EOI ES3321 (1835b) within a two- mile radius is largely rural with minimal development. Development activities occurring in this area include some rural residences, logging associated development on private land, some agriculture, and oil and gas activity separate from the leases for ES3321 Part 1 (1835a) and ES3321 (1835b). There is also an active well, a plugged well and a dry hole to the southeast of both parcels on private property (Appendix A., Figure A.2).
Over time, the activity from EOI ES3321 (1835b) may contribute to changes in existing land uses. EOI ES3321 (1835b) is estimated to create 6.65 acres of development-related surface disturbance. This development activity would impact 0.005% of the land within the two-mile radius of EOIs ES3321(1835b) and ES3321 Part 1 (1835a). The presence of existing oil wells and dry holes suggest that oil and gas operations have been a historical land usage within a two- mile radius of EOIs ES3321 Part 1 (1835a) and ES3321 (1835b).
Effects of Alternative A (Proposed Action) The RFDS developed for EOI ES3321 Part 1 (1835a) predicts that approximately 9.86 acres of land will experience surface disturbance. If development occurs, immediate impacts anticipated
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to land use at the site would involve the conversion of 9.86 acres of pine mixed hardwood forest to gravel access roads and well pads during the construction and production phase of the operation (drilling, fracturing, production, etc.). The site would remain impacted for the life of the well, approximately 20-30 years.
After the construction phase, interim reclamation or natural vegetative succession could occur on up to approximately 30 percent of the initial surface disturbance (2.94 acres). This would minimize long-term effects but would occur at the private landowner’s discretion. The extent of impacts beyond five years would be dependent upon decisions made by the landowner for reclamation activities and are unknown at this time. However, it is estimated that 6.92 acres will remain used for well pads and associated infrastructure for the life of the well if interim reclamation is completed. Any changes to land use for the life of the well as a result of reasonably foreseeable oil and gas development are consistent with existing land use activities in the analysis area. These changes would be addressed further at the APD stage.
Further, this potential future development is consistent with ongoing uses of the land in the general vicinity of the proposed lease parcel. As noted earlier, there is an approved Federal lease, ES3321 (1835b), adjacent to the proposed EOI ES3321 Part 1 (1835a). Considering the reasonably foreseeable development scenarios for EOIs ES3321 Part 1 (1835a) and ES3321 (1835b), an estimated 16.51 acres may be impacted by oil and gas development activities in the future, including 9.86 acres of surface disturbance for EOI ES3321 Part 1 (1835a) and 6.65 acres of surface disturbance for EOI ES3321 (1835b). Impacts to land conversion would be anticipated to persist on the landscape for the life of the wells, which could last more and 30 years if development activities are staggered, and would impact 0.13 percent of the area within the lease parcels and the surrounding 2 miles. There is also an active oil well and plugged oil well that remain visible on the landscape and a dry hole that is not visible on the landscape within a half a mile to the southeast of the portion of EOI ES3321 Part 1 (1835a) in Section 14 on private property (Appendix A., Figure A.2).
There would be a small reasonably foreseeable impact to land use if EOI ES3321 Part 1 (1835a) were developed in the future. Since the area already demonstrates a history of oil and gas leasing activity, the proposed action is historically in line with the general land use of the area. Since the area within EOIs ES3321 Part 1 (1835a) and ES3321 (1835b) is comprised of private land in a rural setting, and do not cross any roads or populated areas, no impacts to public health and safety are anticipated to result from any change in land use imposed by the Proposed Action.
Cultural Resources and Native American Concerns How would potential future development on the nominated parcels impact cultural resources and Native American concerns?
Affected Environment The NHPA, as amended, and its implementing regulations require that federal agencies consider the effects of their undertakings on “historic properties.” The term “historic properties” refers to cultural properties, both prehistoric and historic, that are eligible for listing in the National
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Register of Historic Places (NRHP). Traditional sacred places and traditional use areas of tribes are also considered cultural historic properties that may be eligible for the NRHP, because of their association with cultural practices and beliefs rooted in history and their importance in maintaining the cultural identity of ongoing American Indian communities. Federal agencies consider the effects of their management activities on historic properties by first determining the area of potential effect (APE; the proposed lease area and the surrounding two miles). The APE was selected because this is the potential outer limit of where reasonably foreseeable future development of the lease could occur. Then, federal agencies conduct literature searches and field surveys to locate cultural properties. Additionally, they consult with Native American Indian Tribes and other interested parties to determine whether Traditional Cultural Properties (TCPs) are within the APE.
All of the property within the APE is private and, thus, limited survey information exists; however, potential effects to cultural resources from reasonably foreseeable actions could occur if future development of EOI ES3321 Part 1 (1835a) is conducted without proper surveys and consultations under the NHPA or state requirements. Although there are no known sites within the area of potential effect that are eligible for the NRHP, future surveys may discover eligible listings within the area of potential effect. The scale and extent of future resource discovery cannot be predicted due to a lack of survey information on private property. If recommended surveys are completed during the APD stage, survey information would allow for the preservation of the historical record for lands within the APE.
There are no known instances of damage to cultural resources in the APE that may contribute to environmental trends of cultural resource damage. However, it is possible that there is ongoing illegal activity, primarily including archeological vandalism and theft, that is known to occur on certain sites or site types unless such sites are protected. The degree of impacts to properties discovered during surveys performed before accessing federal minerals should be slight as inventory, assessment, protection, and avoidance measures would be implemented as required by the NHPA at the APD stage.
Federally recognized Native American tribes have been contacted about this proposed undertaking (see Section 7.2). Known sites of Native American religious activities have not been identified within the APE but may still be present. Literature reviews indicate that the lease parcel has not been surveyed nor does it have recorded historic or cultural resources. However, there are two recorded sites within the APE for the parcel. Additionally, the proposed lease parcel may have undiscovered sites that would qualify as historic properties (36 CFR 61). A professionally conducted survey for historic properties would add information on human utilization of this area.
There is an existing lease parcel, EOI ES3321 (1835b), within the APE that was analyzed in a previous EA, DOI-BLM-Eastern States-0020-2020-0009-EA. There are no known cultural resources within EOI ES3321 (1835b); however, there may be undiscovered resources present that could be impacted from future potential development. The type of impacts to cultural resources from the development of the existing lease for ES3321 (1835b) would be identical to the Proposed Action, although development of both EOI ES3321 (1835b) and EOI ES3321 Part
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1 (1835a) could increase the degree of these impacts to cultural resources within the surrounding 2 miles of both parcels. Impacts from both projects are discussed below in the Proposed Action.
Effects of Alternative A (Proposed Action) Most lands in Alabama have not been surveyed for cultural resources. Cultural survey information is especially deficient on private lands. All the surface lands within EOIs ES3321 Part 1 (1835a) and ES3321 (1835b) are private. These lands have no documented surveys for cultural resources or places listed or proposed to be listed on the NRHP. The closest known cultural resources to EOIs ES3321 Part 1 (1835a) and ES3321 (1835b) in Covington County occur within the 2-mile radius of the parcels.
There may be undiscovered resources present within the APE that could be impacted from future potential development of either or both parcels. As a result, BLM would recommend conducting cultural resource surveys prior to undertaking ground-disturbing activities. If sites are located and recorded before ground disturbance begins, these impacts may be avoided through consultation with the State Historic Preservation Office (SHPO). If site characteristics are known during the APD stage, SHPO may make recommendations, depending on the nature of the site, for surveys to be performed, for well-associated development to be moved to another location, or other mitigation meant to preserve cultural resources. If this mitigation is not followed, development of the proposed lease could irreparably damage cultural sites and diminish the accuracy of the historical record. The degree of impacts is unknown at this time and would depend on the types of sites present near where development occurs. This issue may be further evaluated at the APD stage.
Mitigation Measures As required by the NHPA, the American Indian Religious Freedom Act, the Native American Graves Protection and Repatriation Act, and Executive Order 13007, a stipulation regarding cultural resources and Native American religious concerns applies to the lease parcels (Appendix B). The stipulation states that the BLM would not approve any ground disturbing activities that may affect historic properties and/or resources until it completes its obligations under applicable requirements of the NHPA and other authorities. On June 4, 2020, the Louisiana SHPO recommended a Phase I cultural resource survey for the proposed project area at the APD stage. In addition, if unknown burials are discovered during development activities associated with these leases, activities must cease immediately, applicable law on unknown burials will be followed and, if necessary, consultation with the appropriate Tribe/group of federally recognized Native Americans would take place.
Minerals and Mineral Development How would potential future development on the nominated parcels impact minerals and mineral development?
Affected Environment The target formation for EOI ES3321 Part 1 (1835a) is the Haynesville Frisco City Sandstone formation at depths above 11,800 feet. The secondary objective would be to reach the
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Smackover Limestone formation at depths above 12,500 feet. The targeted commodity in both formations is oil and associated natural gas. The oil and gas occurrence potential is high within the proposed lease parcel with a moderate degree of certainty for the Haynesville Frisco City Sandstone formation and a low degree of certainty for the Smackover Limestone formation. The oil and gas development potential is moderate for the Haynesville Frisco City Sandstone formation and low for the Smackover Limestone formation.
The analysis area for minerals development is Covington County, which provides a sense of the historical development in the area. There are solid mineral prospects near EOI ES3321 Part 1 (1835a). Over one hundred iron prospects are located within three miles to the northeast of this parcel and there are two clay prospects in Covington County, but they are not near the proposed lease parcel. Additionally, there are currently 24 active federal oil and gas leases within Covington County; however, there are no active wells producing federal minerals. Of these active federal leases, there is one adjacent to the proposed lease parcel called EOI ES3321 (1835b). For EOI ES3321 (1835b), the RFDS projected that one well would be drilled from one well pad on private surface to private minerals and a second well would drilled from a separate pad on private surface penetrating federal minerals. For each well, a 30-foot-wide access road would likely be constructed consisting of a 16-foot-wide travel surface with a 7-foot buffer on each side. The previously leased parcel, EOI ES3321 (1835b), would have similar impacts to mineral resources as the Proposed Action, EOI ES3321 Part 1 (1835a), although development of both parcels would increase the degree of these impacts within Covington County, Alabama.
Effects of Alternative A (Proposed Action) For EOI ES3321 Part 1 (1835a), the RFDS projects that one well would be drilled from one well pad on private surface to penetrate private minerals and a second, separate well drilled from a separate pad on private surface penetrating federal minerals. For each well, a 30-foot-wide access road would likely be constructed consisting of a 16-foot-wide travel surface with a 7-foot buffer on each side. Additional information regarding predicted surface disturbances based on the RFDS can be found in Section 3.1.3. If productive, oil and gas handling and production facilities will be constructed on the existing pad.
Subsequent exploration and oil and gas development for EOIs ES3321 (1835b), ES3321 Part 1 (1835a), or other existing, active leases in Covington County, Alabama, could impact the production horizons and reservoir pressures. If production wells are established, the resources allotted to the wells would eventually be depleted. Some well stimulation may be necessary for wells in the Haynesville Frisco City Sandstone formation. However, low-, high-low, or high- volume hydraulic stimulation (fracking) is not used for wells in the Smackover Limestone formation. One hundred barrels of 15% hydrochloric acid would be used to clean perforations and overcome formation damage. Wells would be vertically drilled or slightly deviated.
The extent of the impacts to fluid mineral resources would be further determined once site- specific development information is available at the APD stage if federal minerals are to be penetrated. Although solid mineral resources are present in Covington County, there are none that overlap the proposed lease parcel. As a result, there should be no impacts to solid mineral resources as a result of potential future exploration or development.
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Wastes What kinds of wastes could be produced from potential development on the nominated lease parcels and how could it impact the environment?
Affected Environment The Resource Conservation and Recovery Act (RCRA) of 1976 (42 USC 6901) established a comprehensive program for managing hazardous wastes from the time they are produced until their disposal. On January 6, 1988, the United States Environmental Protection Agency (EPA) determined that oil and gas exploration, development, and production wastes would not be regulated as hazardous wastes under the RCRA. The Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of 1980 (42 USC 9601), deals with the release (spillage, leaking dumping, accumulation, etc.), or threat of release of hazardous substances into the environment. Despite many oil and gas constituent wastes being exempt from hazardous waste regulations, certain RCRA exempt contaminants could be subject to regulations as a hazardous substance under CERCLA.
Wastes were analyzed within a two-mile radius of EOI ES3321 Part 1 (1835a), where development and, therefore, production and storage of wastes could occur. This area is rural, private property. Within the analysis area, there is another existing lease, EOI ES3321 (1835b), for which impacts were analyzed in the EA, DOI-BLM-Eastern States-0020-2020-0009-EA. EOI ES3321 (1835b) would have similar waste production to the Proposed Action, EOI ES3321 Part 1 (1835a), although development of both parcels would increase the degree of these impacts within the analysis area. BLM has not received a development proposal for EOI ES3321 (1835b) at this time. Impacts from both projects are discussed below in the Proposed Action and would adhere to the same mitigation measures.
No hazardous or solid waste disposal sites are located within the analysis area. Should the parcel be leased and federal minerals developed in the future, generation and temporary storage of waste materials (solid and liquid) could occur where development occurs within a two-mile radius of EOI ES3321 (1835b). The Alabama Department of Environmental Management (ADEM) is responsible for the proper handling, transport and disposal of produced waste materials in Alabama. Operators and the BLM ensure hazardous and non-hazardous substances are properly managed through the preparation of a Spill Prevention, Control, and Countermeasure (SPCC) plan during the APD phase, which would include appropriate permits for storage, transfer and disposal from ADEM.
Effects of Alternative A (Proposed Action) Subsequent oil or gas exploration and/or development of either EOI ES3321 (1835b), EOI ES3321 Part 1 (1835a), or both, could result in the introduction of hazardous and non-hazardous substances to the area. Oil and gas development activities typically generate the following wastes: (1) discharge of drilling fluids and cuttings into the reserve pits, (2) wastes generated from used lubrication oils, hydraulic fluids, and other fluids used during production of oil and gas, some of which may be characteristic or listed hazardous waste, and (3) service company
DOI-BLM-Eastern States-0020-2021-0002-EA 19 wastes from exploration and production activities as well as containment of some general trash. The drilling fluids, drill cuttings, and produced waters are classified as a RCRA exempt waste, and potential drilling that could occur would not introduce hazardous substances into the environment if they are managed and disposed of properly under federal, state, and local waste management regulations and guidelines. Properly used, stored, and disposed of hazardous and non-hazardous substances greatly decreases the potential for any impact on any environmental resources. Operators and the BLM ensure hazardous and non-hazardous substances are properly managed through the preparation of a Spill Prevention, Control, and Countermeasure (SPCC) plan during the APD phase.
If either or both leases, EOI ES3321 (1835b) along with ES3321 Part 1 (1835a), are developed, operators and private landowners will be required to adhere to all laws and regulations regarding the proper disposal of wastes for the entire life of the well. Impacts are not anticipated if future development occurs, due to measures discussed in the Mitigation Measures section below. If these mitigation measures are not followed, a development proposal received at the APD stage would not be approved. The area surrounding the lease parcels within a two-mile radius consists of private property, so information is not available regarding planned present or future development projects, although impacts from wastes are not anticipated.
Mitigation Measures The Onshore Oil and Gas Orders (Onshore Orders) (U.S. Department of Interior 1993) and the Code of Federal Regulation implementing and supplementing the oil and gas regulations found at 43 CFR 3160 for conducting oil and gas operations for federal leases. Implementing all regulations outlined in the Onshore Orders and the SPCC plan created during the APD stage will minimize potential health, safety and environmental impacts from storage, handling and disposal of wastes. The Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development (the Gold Book) (U.S. Department of Interior and U.S. Department of Agriculture 2007) also provides useful information regarding requirements and recommendations for conducting environmentally responsible oil and gas operations on federal lands and split estate. Requirements and recommendations offered in the Gold Book should also be followed at the APD stage to reduce potential impacts from handling, storage and disposal of wastes.
Air Resources How would future potential development on the nominated lease parcels impact air quality and greenhouse gases?
Affected Environment The National Ambient Air Quality Standards (NAAQS) are established by the U.S. Environmental Protection Agency (EPA) has nationwide standards for air quality (Appendix F); Alabama does not have any separate state ambient air quality standards. The Alabama Department of Environmental Management (DEM) administers, regulates, and enforces state air pollutant and GHG emissions via issuance of permits and regulations, while the EPA issues regulations regarding air pollutant and GHG emissions. DEM is the delegated authority in
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Alabama to implement and enforce the EPA New Source Performance Standards for VOC and GHGs. There are no national or state ambient air quality standards for GHGs.
Impacts to air quality and generation of greenhouse gas emissions were analyzed using the total emissions generated by oil and gas production of Federal minerals in the State of Alabama and in the region, including the other 10 states in which Federal mineral resources are managed by the SSDO: Arkansas, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, and Virginia.
The proposed action will be located in Covington County, Alabama, which meets all NAAQS for carbon monoxide (CO), lead, nitrogen dioxide (NO2), ozone, coarse and fine particulate matter (PM10 and PM2.5), and sulfur dioxide (SO2) (EPA 2020a). Ozone is not directly emitted by oil and natural gas production activities; rather, it is formed from a photochemical atmospheric reaction between oxygen, volatile organic compounds (VOC), and NO2. VOC emissions are regulated to control ozone formation, so VOC emissions are included in this analysis instead of ozone.
According to the U.S. Energy Information Administration (EIA) and BLM, there are 6,340 oil and natural gas wells in Alabama (EIA 2018), including 29 within the Federal mineral estate: mineral rights owned by the Federal government, with the surface owner being a private party (split estate) or the Federal government (BLM 2020). The Affected Environment analysis considered active producing wells to form a reasonable conclusion on potential impacts. There is no guarantee that wells that have not been developed will become active producing wells; therefore, this analysis focused on current emissions from actual producing wells. Since EOI ES3321 (1835b) does not have an active producing well or any planned development of a well pad at this time, it is not producing any emissions, and therefore is not creating any impacts to air quality or greenhouse gas emissions.
From 2014 to 2018, the total number of oil and natural gas wells in Alabama has reduced from 6,758 to 6,340 (6% decrease), statewide oil production has decreased from 9,831,000 barrels to 5,884,000 barrels (40% decrease), statewide natural gas production has decreased from 182,147,000 mcf to 139,477,000 mcf (23% decrease) (EIA 2018), and air pollutant emissions have similarly decreased, with a reduction range that varies from 8,831 tons of VOC to 184 tons of PM2.5, (48% to 76% reduction, respectively) (EPA 2020c).
Total oil production was 5,883,000 barrels (247,086,000 gallons) and total natural gas production was 139,477,000 thousand cubic feet (mcf) from a total of 6,340 producible wells for Alabama in 2018 (EIA 2018). Thus, the average production from an Alabama well is 927.9 barrels (38,970 gallons) of oil and 22,000 mcf of natural gas. For additional discussion of oil and natural gas production, see Tables 3 and 4 in Appendix J.
Effects of Alternative A (Proposed Action) BLM has developed a RFDS projection based on technical analyses and general assumptions of future development to assess the impacts from the proposed action. The RFDS projection for this project includes the following assumptions:
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1) Two wells will be constructed, each on a separate well pad; 2) One of these wells will be located on privately-owned surface overlying subsurface Federal mineral estate; 3) The wells will be drilled for oil and associated natural gas; 4) Vertical drilling will be used to access the targeted formations; and 5) The well on Federal mineral estate will be required to implement Best Management Practices specified by BLM.
Since the RFDS projects that only one well will be drilled into Federal mineral ownership, (FMO), that well is subject to this analysis. Any other wells drilled from private land into private mineral ownership are not subject to BLM requirements because private mineral development on private land is outside the BLM’s jurisdiction.
The proposed action will generate air pollution, including GHGs, that will be emitted into the atmosphere, impacting air quality and climate change. Additionally, the RFDS for the proposed action indicates that the well will generate oil and natural gas, which will eventually be combusted to provide heat or power. Since BLM will not have any data on oil or natural gas yields from the Proposed Action until a well is drilled and begins producing, expected production was calculated using the total oil and natural gas production divided by the total number of producible wells. For additional discussion of GHG emission and oil and gas production totals, see Tables 1 to 4 in Appendix J.
Since the Proposed Action could potentially result in the drilling of one oil and natural gas well that would eventually produce oil and natural gas, the GHG impacts from the Proposed Action have to be considered within the context of emissions from oil and natural gas production within Alabama and the SSDO. For additional information on total projected emission by state within SSDO’s jurisdiction, see Tables 6 and 7 in Appendix J.
Based on an RFDS of 1 well, the Proposed Action represents a miniscule increase in both the air pollutant and GHG emissions for all oil and natural gas production within the entire state of Alabama (0.02% increase) and for all oil and natural gas production on FMO managed by the BLM within the SSDO (0.8% increase). Since the potential emissions increases are so slight compared to current emissions from oil and natural gas production in Alabama, the air quality and GHG impacts will be correspondingly small. Thus, the addition of one additional oil and natural gas well will not offset the significant decrease in number of wells, production, or air emissions within Alabama from oil and natural gas production.
Recommended Best Management Practices The BLM holds regulatory jurisdiction over certain aspects of oil and natural gas production, as provided by the Federal Land Policy and Management Act of 1976, Mineral Leasing Act of 1920, NEPA, and the BLM Application for Permit to Drill program. To fulfill its statutory requirements, BLM has developed BMPs: state-of-the-art mitigation measures that ensure the Proposed Action is implemented in an environmentally responsible manner and consistent with our Multiple-Use and Sustained Yield Mission. BLM applies BMPs to specific oil and natural
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gas production projects on a site-by-site basis to reduce impacts to air quality through reduction of air pollutant and GHG emissions. Typical BMPs include:
• Prohibiting open burning of garbage or refuse at well sites or other facilities to reduce CO, CO2, PM, and VOC emissions; • Requiring fuel-burning equipment to meet Federal standards, including the use of selective catalytic reducers and ultra-low sulfur diesel fuel, to reduce NO2 and SO2 emissions; • Requesting the use of alternative fuels in drill rigs, including natural gas-fired engines or electric motors, to reduce CO2, NO2, PM, and SO2 emissions; • Requiring all engines to be maintained in good working order, to reduce CO2, NO2, PM, and SO2 emissions; • Venting natural gas emissions from stock tanks and natural gas dehydrators to a flare or similar control device to reduce CH4 and VOC emissions by 95 percent or greater; and • As applicable, requiring adherence to BLM regulations (43 CFR, Subpart 3179) concerning the venting and flaring of natural gas on Federal leases, to reduce CH4 and VOC emissions.
Soils How would potential future development on the nominated parcels effect soils and soil erosion?
Affected Environment EOI ES3321 Part 1 (1835a) Soil characteristics within EOI ES3321 Part 1 (1835a) are summarized in Appendix I., Table I.1 (Soil Survey Staff, 2020). Most soils within the EOI are expected to be slightly fragile, although most soil types within the EOI have not been rated for fragility. Soils within the portion of the EOI in Section 11 all have a low risk for compactiblity when wet. Soils within the portion of the EOI in Section 14 predominantly (83.9 percent) have a medium compactiblity rating when wet, with the remaining portion given a low rating. Soil textures are predominantly loamy fine sand, loam, and sandy loam, which makes them highly susceptible to wind erosion (as measured by the Wind Erodibility Group, Table I.1.) and have a low potential for water erosion caused by runoff and detachment (as measured by the K Value, Table I.1.). EOI ES3321 Part1 (1835a) lies within the Teel Creek subwatershed (HUC:031403010503). Although soil types vary across the subwatershed and with landscape position, soil textures throughout the Teel Creek subwatershed are largely similar to the proposed lease area, with textures of loamy sand, fine sandy loam, loam and sandy loam being predominant. Soils within the Teel Creek watershed are estimated to have similar fragility, compactibility, and susceptibility to wind and water erosion as those in the proposed lease area and area within existing leases described in Appendix I., Table I.1 because of the shared similarities in texture and disturbance regime.
Planned Actions Within the Teel Creek subwatershed, there are 3 other active, existing oil and gas leases including EOI ES3321 (1835b) leased in June 2020 (120.38 acres) and EOIs 1516 and 1517
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leased in December 2012 (totaling 201.47 acres). After lease, EOIs 1516 and 1517 were given lease numbers ALES-057845 and ALES-057966, respectively. ALES-057845 and ALES-057966 are entirely within the Teel Creek subwatershed, while EOI ES3321 Part 1 (1835a) is approximately 90 percent within the Teel Creek subwatershed and 10 percent within the Fall Creek subwatershed (HUC: 031403010503) (Appendix A, Figure A.6). Although these parcels have not yet been developed, it has been determined that reasonably foreseeable development of EOI ES3321 (1835b) would involve 6.65 acres of surface disturbance, including 2 wells, 2 well pads and 3.44 miles of access roads, and reasonably foreseeable development of ALES-057845 and ALES-057966 would involve 16.42 acres of surface development, including 4 wells from 4 separate pads and 4.33 miles of access roads.
Soil characteristics within these 3 leases are summarized in Appendix I., Table I.1. EOI ES3321 (1835b) contains soils with loamy fine sand, sandy loam and loamy sand textures. These soils are expected to be slightly fragile, although most soil types within the EOI have not been rated for fragility. Most soils within the EOI have a low risk of compactiblity when wet (87 percent of EOI acreage) with the remaining portion of soils in the EOI having a medium to high risk. All soils have a high risk of impacts from wind erosion (as measured by the Wind Erodibility Group, Table I.1.) and a low potential for water erosion caused by runoff and detachment (as measured by the K Value, Table I.1.). Soil characteristics within the Fall Creek subwatershed are similar to those described above for the Teel Creek subwatershed. The two subwatersheds in which EOI ES3321 (1835b) lies, are estimated to have similar fragility, compactibility, and susceptibility to wind and water erosion as those in the proposed lease area and area within existing leases described in Appendix I., Table I.1. (Soil Survey Staff, 2020).
Soils within ALES-057845 and ALES-057966 contain soils with textures of loamy fine sand, sandy loam, loamy sand, and loam. Soils within the EOI have largely not been rated for fragility, although 27.6 percent of soils in the EOI are moderately fragile and 9.6 percent of soils in the EOI are slightly fragile. Most soils in ALES-057845 and ALES-057966 (61.9 percent) have a medium risk of compactiblity when wet, with the remaining soils (38.1 percent) having a low risk for compactiblity. Similar to EOI ES3321 Part 1 (1835a) and EOI ES3321 (1835b), soils within ALES-057845 and ALES-057966 have a high risk of wind erosion and a low potential for water erosion caused by runoff and detachment. These EOIs lie entirely within the Teel Creek subwatershed discussed previously.
Analysis Area Because the Proposed Action and reasonably foreseeable planned actions span 2 subwatersheds, the Teel Creek and Fall Creek subwatersheds were used as the analysis area for soil resource issues, which provides coverage of where potential future development could occur and allows for analysis of how soil resources may impact water resources. Soils have an effect on the surface and ground water quality within a subwatershed and impacts to soils are consequential to water resources. The Teel Creek and Fall Creek subwatersheds comprise and 42,635.78 and 37,104.74 acres respectively, totaling 79,740.52 acres.
Current Condition
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Soil characteristics within EOIs ES3321 (1835b), ALES-057845 and ALES-057966 are predominantly not highly vulnerable to degradation from compaction or erosion. However, subsequent exploration and/or development may produce short and long-term impacts by physically clearing vegetation from the site, removing topsoil and exposing the substratum soil, mixing of horizons, compaction, and loss of topsoil productivity. Additionally, activities would be expected reduce soil structure and integrity, increase runoff and overland flow, and create some sedimentation in streams. Activities that could cause these types of impacts include construction and operation on well sites, access roads, gas pipelines and facilities. Vehicle traffic–related wind erosion would be limited to access routes without a surface that has been paved or dressed in a material to prevent soil movement. Impacts indirectly creating impacts such as runoff, erosion, and compaction and would be limited to the watersheds in which each lease parcel lies, which are further described in Section 6.8– Water Resources.
Notwithstanding, soil erosion potential is low due to the lack of fragile soils and adequate availability of slopes less than 10 percent to conduct development activities within all parcels and the surrounding subwatersheds. Initial development of active, existing leases is anticipated to create a total of 23.07 acres in surface disturbance for the construction of well pads, access roads, and reserve pits, which represents 0.03 percent of the Teel Creek and Fall Creek subwatersheds in the short term.
Although most soils within the EOI parcels have a low to moderate susceptibility to compaction when wet, development activities could cause some level of compaction, which causes increased soil density and hardness, reduced pore space, and provides poor aeration and drainage to support plant growth. However, unless construction activities are performed in areas that are highly susceptible to compaction when soils are wet, compaction related to development of the lease parcels is not anticipated to inhibit future reclamation success. If interim reclamation occurs, up to 30 percent of the initial 23.07-acre disturbance could be revegetated after construction activities are complete. This would reduce the disturbance footprint by 6.92 acres and reduce potential for impacts to the site by wind and water erosion. If interim reclamation occurs, 16.15 acres within the Teel Creek and Fall Creek subwatersheds (0.02 percent of the subwatershed acreage) would remain impacted in the long term, approximately 30 years.
Contamination of soil from future drilling, and production wastes mixed into soil or spilled on the soil surface could cause a long-term reduction in site productivity. Contaminants spilled on soil have the potential to pollute and/or change the soil chemistry (see also Section 6.4- Wastes). These potential impacts can be reduced or avoided through proper design, construction, maintenance, and implementation as described in the Gold Book.
Effects of Alternative A (Proposed Action) While the act of leasing federal minerals would not affect soils, subsequent exploration and development of proposed EOI ES3321 Part 1 (1835a) would create the same short and long-term impacts to soil resources necessary for the development of EOI ES3321 (1835b), ALES-057845 and ALES-057966, described in the Affected Environment. This is because the proposed lease parcel displays similar slope, fragility, susceptibility to compaction, and potential for soil erosion caused by wind and water as the existing leases, EOIs ES3321 (1835b), ALES-057845 and
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ALES-057966. Future potential development of EOI ES3321 Part 1 (1835a) would involve disturbance of 9.86 acres for 2 wells from 2 separate well pads and 0.95 mile of access roads. Development of this lease could increase the total initial surface disturbance in the Teel Creek and Fall Creek subwatersheds to 32.93 acres (9.86 acres for EOI ES3321 Part 1 (1835a) plus 23.07 acres for EOIs ES3321(1835b), ALES-057845 and ALES-057966). This area represents only 0.04 percent of the Teel Creek and Fall Creek subwatersheds. The Proposed Action would increase oil and gas development in this area by 0.01 percent above the No Action Alternative described in the Affected Environment.
If interim reclamation activities occur after construction is complete, approximately 2.96 acres of the initial 9.86-acre disturbance would have reduced susceptibility and increased resilience to impacts from wind and water erosion in the long-term. Any impact to soils would be remedied upon final reclamation of the well pad and associated infrastructure, after approximately 30 years when the well has ceased production. However, reclamation activities are performed at the discretion of the private landowner. Further analysis of impacts to soil resources will be performed at the APD stage when a site-specific development proposal has been received and site-specific impacts to soil resources can be better evaluated. Based on the proposal received, BLM may request modifications to the siting location and/or construction techniques to limit impacts to soil and water resources.
Mitigation Measures If federal minerals are proposed for future development, an APD would be required and the BLM would conduct additional site-specific analysis of potential impacts to soils. The Gold Book provides recommendations for construction techniques that would minimize impacts that could be caused by soil erosion including the recommendation for the operator to stockpile topsoil from the surface of well pads to be used for future surface reclamation. The Gold Book also recommends that during the life of the development, all disturbed areas not needed for active support of production operations should undergo “interim” reclamation in order to minimize the environmental impacts of development on other resources used. Upon abandonment of wells and/or when access roads are no longer in service, final reclamation would ideally be implemented. Reclamation activities will be decided upon by the private landowner.
Water Resources How would future potential development on the nominated lease parcels impact water resources? The Alabama Oil & Gas Board (AOGB) (https://www.gsa.state.al.us/), regulates oil and gas operations in the state of Alabama. The AOGB has the responsibility to gather oil and gas production data, permit new wells, establish pool rules and oil and gas allowables, issue discharge permits, enforce rules and regulations of the division, monitor underground injection wells, and ensure that abandoned wells are properly plugged and the land is responsibly restored. The ADEM administers the major environmental protection laws and all Water Quality Act regulations pertaining to surface and groundwater (except sewage not present in a combined waste stream).
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6.8.1. Surface Water Resources Affected Environment EOI ES3321 Part 1 (1835a) As described in Section 6.7 – Soil Resources and shown in Appendix A, Figure A.6, EOI ES3321 Part 1 (1835a) falls entirely within the Teel Creek subwatershed (HUC:031403010503; 42,635.78 acres; EPA, 2020).
There is a 4.04-acre freshwater pond approximately 0.03 mile from the western boundary of the portion of the parcel in Section 11, which interrupts a first order tributary to Teel Creek. The only mapped wetland habitat in Section 11 includes approximately 0.45 acre of freshwater forested/shrub wetland in the southwestern corner of the parcel (Appendix A., Figure A.5.). This wetland is only a portion of a larger, 2.76-acre total freshwater forested/shrub wetland which also enters an adjacent EOI parcel with an existing lease, EOI ES3321 (1835b). Wetland features comprise approximately 1.1 percent of this 40.12-acre parcel section.
Within the portion of EOI ES3321 Part 1 (1835a) occurring in Section 14, there is an 8.6 acre freshwater forested/shrub wetland in the northern half of the parcel, which continues outside of the parcel boundaries to the north and west (Appendix A, Figure A.5.). There are also approximately 2.14 acres of a freshwater wetland/shrub wetland in the southeastern corner of the parcel in Section 14, which is adjacent to the Conecuh River and extends outside the parcel boundary to the east and to the southeast. The southern half of the parcel in Section 14 includes approximately 0.29 miles or 5.98 acres of the Conecuh River. Wetland/riverine features comprise approximately 42 percent of this 40.12-acre parcel section.
Planned Actions Within the Teel Creek subwatershed, there are 3 other active, existing leases present including EOI ES3321 (1835b), ALES-057845, and ALES-057966. EOI ES3321 (1835b) contains approximately 2.07 acres of freshwater forested/shrub wetlands that extend from the southern boundary of EOI ES3321 Part 1 (1835a) into the western portion of the parcel. This wetland is linked to an approximately 1.07 acre freshwater pond in the southwest portion of the parcel which is fed by 0.09 miles or 0.31 acres of a riverine, first order stream running along the western edge of EOI ES3321 (1835b). There are no wetlands on the eastern half of the parcel, except a small inclusion of 0.05 acres of freshwater forested/shrub wetlands along the southeast edge of the parcel, which extends outside the parcel boundary to the southeast. There are no wetlands or water bodies within the portion of the parcel that overlaps into the Fall Creek subwatershed (Appendix A, Figures A.5 and A.6). Wetland features comprise approximately 3 percent of this 120.38-acre parcel.
There are two riverine features within ALES-057845 and ALES-057966. The first is a first order stream beginning in the northwest portion of ALES-057845 and flowing south within the western half of the parcel for approximately 0.53 miles. The second feature is a first order stream beginning in the northern portion of ALES-057966 and flowing south into ALES-057845 for the entire length of both parcels. This eastern stream segment is approximately 0.52 miles. The southern portion of ALES-057845 and the southwestern most corner of ALES-057966 contain
DOI-BLM-Eastern States-0020-2021-0002-EA 27 approximately 28.3 acres of freshwater forested/shrub wetland, which comprises 14 percent of the total lease acreage in the Teel Creek subwatershed (201.47 acres). Analysis Area Because the Proposed Action and reasonably foreseeable planned actions span 2 subwatersheds, the Teel Creek and Fall Creek subwatersheds were used as the analysis area for surface water resource issues. The Teel Creek and Fall Creek subwatersheds comprise and 42,635.78 and 37,104.74 acres respectively, totaling 79,740.52 acres.
Current Condition Riverine features, freshwater emergent wetlands, freshwater forested/shrub wetlands and freshwater ponds are prevalent throughout the Teel Creek and Fall Creek subwatersheds. All streams within these watersheds, including Teel Creek and Fall Creek, ultimately flow into the Conecuh River. The Conecuh River is undammed below Gantt and Point A Reservoirs near Andalusia, Alabama (and upstream of the Fall and Teel Creek subwatersheds). The Conecuh River is largely used for fishing and various other types of recreational activities (Outdoor Alabama 2020).
There are no water bodies listed on the Alabama 303(d) list of impaired water bodies in either subwatershed. Although there is no past or current oil and gas development related to Federal leases within these subwatersheds, it has been determined that reasonably foreseeable development of EOI ES3321 (1835b) would involve 6.65 acres of surface disturbance, including 2 wells, 2 well pads and 3.44 miles of access roads, and reasonably foreseeable development of ALES-057845 and ALES-057966 would involve 16.42 acres of surface development, including 4 wells from 4 separate pads and 4.33 miles of access roads.
The Conecuh National Forest is located in the southern third of the Teel Creek Subwatershed, although this area includes approximately 30 percent private inholdings within the forest boundary. The Fall Creek subwatershed is entirely private. Energy development and construction activities, forestry, agriculture, and the conversion of land to developed landscapes within the Teel Creek and Fall Creek subwatersheds could collectively result in the removal of vegetation, long-term reduction in overall vegetation cover, and disturbance of soils. This would increase overland flow, result in accelerated soil erosion, and decrease the ability of watersheds to buffer high flows and filter water, sediment, and nutrients. Soil mobilized by wind and water erosion would be transported downslope and to nearby water bodies, which would increase sediment and nutrient loads to streams, rivers, lakes, and reservoirs and thereby degrade water quality. Increases in overland flow also would directly increase the amount of water transported to streams and rivers, which could lead to increased downcutting, widening, and overall degradation of stream channels. Impacts to surface water from the development of existing leases would be limited to the respective watershed where development occurs and would cease after final reclamation is completed. Impacts are expected to be minimal if all state and federal requirements are met including those outlined in the Onshore Orders and in the Gold Book.
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Effects of Alternative A (Proposed Action) Impacts from subsequent potential exploration and development of EOI ES3321 Part 1 (1835a) the lease parcel are similar to the impacts of existing leases in the Teel Creek and Fall Creek subwatersheds. Future potential development of EOI ES3321 Part 1 (1835a) would involve disturbance of 9.86 acres for 2 wells from 2 separate well pads and 0.95 mile of access roads. Development of this lease could increase the total initial surface disturbance in the Teel Creek and Fall Creek subwatersheds to 32.93 acres when added to the potential development of existing leases in the subwatersheds (9.86 acres for EOI ES3321 Part 1 (1835a) plus 23.07 acres for EOIs ES3321(1835b), ALES-057845 and ALES-057966). This area represents 0.04 percent of the Teel Creek and Fall Creek subwatersheds. The Proposed Action would increase oil and gas development in this area by 0.01 percent above the No Action Alternative described in the Affected Environment.
Sedimentation and pollution of streams or wetlands can occur down-gradient from such activity sites (USDA 2010). Surface disturbance from the construction of well pads, access roads, pipelines, and utility corridors can result in degradation of surface water quality from non-point source pollution, increased soil losses, and increased erosion.
Potential impacts to surface water that may occur from construction of well pads, access roads, fracturing ponds, pipelines, utility lines and production include:
• Increased surface runoff and off-site sedimentation brought about by soil disturbance; • Increased water quality impairment of surface waters; • Channel morphology changes due to road and pipeline crossings; and • Possible contamination of surface waters by spills.
The magnitude of these impacts to water resources would depend on the proximity of the disturbance to the drainage channel, slope, aspect and gradient, degree and area of soil disturbance, amount of local precipitation, soil character (see Section 6.5- Soils), and duration and time before implementation mitigation or clean up measures can be put into place. Mitigation measures will further reduce the adverse short- and long-term impacts to surface water resources by increasing the distance of development from water bodies.
Minor long-term adverse impacts to watersheds could occur from water discharge from roads, road ditches, and well pads, but would decrease once all well pads and road surfacing material has been removed and reclamation of well pads, access roads, pipelines, and powerlines have taken place. Interim reclamation of the portion of the well pad not needed for production operation, re-vegetating the portion of the pad needed for production operations, and re- vegetating road ditches would reduce this long-term impact. Short-term adverse impacts to the watershed from future access roads that are not surfaced with impervious materials would occur and would likely decrease in time if reclamation efforts are conducted by the private landowners. Spills of materials used to drill/complete the wells and or produced formation fluids could result in contamination of the soil and may potentially impact surface and groundwater resources in the long term if not detected and addressed.
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Mitigation Measures In order to protect the water quality of watersheds and natural stream substrate and morphology and to avoid potential impacts to aquatic species and their habitat, it is recommended that no surface occupancy or disturbance, including discharges, occur within 250 feet of a river, stream, wetland spring, headwaters, wet meadows, wet pine savannas, pond, tributary, lake, coastal slough, sand bars, vernal pools on granite outcrops, calcareous seepage marshes, brackish marshes, saltmarsh or small, marshy calcareous streams. If the slope exceeds 10 percent, the buffer should be extended to 600 feet to provide adequate protection for aquatic habitats and associated resources. Onshore Orders No. 7 and the Gold Book both provide requirements and recommendations regarding erosion control measures and techniques and well pad and pit placement and design to avoid waterbody contamination. If potential future development were to occur on near the identified wetland/riverine features, coordination with the U.S. Army Corp of Engineers would be required to determine if a permit would be required under Section 404 of the Clean Water Act and potential mitigation needs/requirements.
6.8.2. Ground Water Resources Affected Environment The primary source of groundwater for the proposed EOI ES3321 Part 1 (1835a) and all existing leases in the Teel Creek and Fall Creek subwatersheds comes from the Pliocene-Miocene Aquifer in Alabama, an important water source in southwest Alabama and the Florida panhandle. This aquifer is composed of nonmarine, fine to coarse sands and gravel beds. Wells in this area of southern Alabama produce suitable drinking water and commonly yield up to 1,000 gallons per minute. Well depths range within the aquifer depending on the formation and depths vary between 20 feet and 1,010 feet below sea level (Geological Survey of Alabama 2018).
The Pliocene-Miocene Aquifer is considered to be highly vulnerable to contamination from the surface due to the permeability of the underlying sediments. The soils are highly permeable, which allows rapid infiltration of water. Areas near where large amounts of groundwater are pumped are more vulnerable to contamination, not only because of the permeable nature of the sediments and the slope of the land surface, but because of depressions created in the potentiometric surface by large withdrawals of water from the aquifers. These depressions act as funnels to direct ground water flow toward pumping centers and increase the rate at which a potential contaminant could migrate into the ground water system. Other areas of high vulnerability are regions characterized by flat terrain, which decreases the rate of surface runoff, and highly permeable soils, which increase the rate of infiltration from the surface. Many of these areas are farmed intensively and the potential exists for contamination of ground water by agricultural chemicals (Geological Survey of Alabama 2000). Impacts from development of the Proposed Action on groundwater resources for existing leases are the same as those discussed for the Proposed Action.
Effects of Alternative A (Proposed Action) While the act of leasing federal minerals would produce no impacts to groundwater resources, subsequent potential exploration and development of EOI ES3321 Part 1 (1835a) or the existing
DOI-BLM-Eastern States-0020-2021-0002-EA 30 lease parcels could produce impacts. The physical effects of mineral extraction include erosion, compaction, sedimentation, and potential groundwater contamination. Surface disturbance from the construction of well pads, access roads, pipelines, and utility corridors can result in degradation of groundwater quality from non-point source pollution, increased soil losses, and increased erosion. Nonetheless, impacts to the quality of groundwater from future development, should they occur, would likely be limited to near a well bore location due to inferred groundwater flow conditions near the parcels.
Contamination of groundwater could occur without adequate cementing and casing of a well bore. Failure of the cement or casing surrounding the wellbore also is a possible risk to water supplies. Complying with BLM Onshore Orders and state regulations regarding casing and cementing, testing casings and cement prior to continuing to drill or introducing additional fluids, and continual monitoring during drilling, would allow producers and regulators to check the integrity of casing and cement jobs and greatly reduce the chance of aquifer contamination.
Petroleum products and other chemicals used in the drilling and/or completion process could result in groundwater contamination through a variety of operational sources including but not limited to pipeline and well casing failure, well (gas and water) construction, and spills. Similarly, improper construction and management of reserve and evaporation pits could degrade groundwater quality through leakage and leaching.
Nonetheless, the potential for negative impacts to groundwater caused from completion activities are not likely. Authorization of the proposed projects would require full compliance with local, state, and federal directives and stipulations that relate to surface and groundwater protection. The BLM would deny any APD whose proposed drilling and/or completion process was deemed to not be protective of usable water zones as required by 43 CFR 3162.5- 2(d) (Control of wells).
Typically, when groundwater is used as a source of drilling/completion water, impacts to the aquifer would be minimal due to the size of the aquifers impacted and recharge potential across the entire aquifer. The time it takes to recharge depends greatly on rainfall events, surface soil materials, drought conditions, and frequency of pumping that has already occurred and will continue to occur into the future. The amount of water actually used for drilling/completion activities is highly dependent on a number of factors including: length of well bore, closed-loop or reserve pit drilling system, type of mud, whether hydraulic fracturing would be used during stimulation, whether recycled water would be used, dust abatement needs, and type and extent of construction, to name a few. The impacts of water use on water quality and quantity could be analyzed when site-specific details are known at the APD phase. Regardless, any proposed drilling/completion activities would need to comply with Onshore Order 2, 3, 7, and 43 CFR 3160 (Onshore Oil and Gas Operations) regulations, and not result in a violation of a federal and/or state law.
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Mitigation Measures and Residual Impacts The implementation of regulations as outlined in Onshore Orders No. 7, 2, 3 and CFR 3160 would minimize impacts to groundwater. Complying with BLM Onshore Orders and state regulations regarding casing and cementing, including testing casings and cement prior to continuing to drill or introducing additional fluids, continual monitoring during drilling, and allowing producers and regulators to check the integrity of casing and cement jobs would greatly reduce the chance of aquifer contamination.
6.8.3. Floodplains Affected Environment Executive Order 11988 requires Federal agencies to avoid to the extent possible, both the long and short-term adverse impacts associated with the occupancy and modification of floodplains, and to avoid direct and indirect support of floodplain development, wherever there is a practicable alternative. The BLM implements this executive order by encouraging operators to avoid locating infrastructure in floodplains or wetlands when possible during site-specific planning. When areas cannot be avoided, the BLM may require BMPs and mitigation measures to minimize, compensate for or avoid impacts and restore the pre-disturbance condition after occupancy.
Floodplains are important for attenuating flood flows, stabilizing sediment and flood debris, groundwater recharge, nutrient buffering as well as providing valuable habitat for aquatic and terrestrial plants and animals. Floodplains in intermittent stream systems also play a vital role in capturing and storing sediment, attenuating flood flows and providing habitat for wildlife (FEMA 2020a).
The portion of EOI ES3321 Part 1 (1835a) located in Section 11 does not contain any lands designated as a 100-year floodplain by the Federal Emergency Management Agency (FEMA). Conversely, the portion of EOI ES3321 Part 1 (1835a) within Section 14 entirely lies within the 100-year flood zone of the Conecuh River (Appendix A, Figures A.3. and A.4.).
The existing, active leases within the Teel Creek subwatershed, including EOI ES3321 (1835b), ALES-057845 and EOI ALES-057966 do not sit within the 100 year floodplain area (Appendix A, Figure A.4). Subsequent potential exploration and development of these leased parcels is not anticipated to cause any impacts to floodplains.
Effects of Alternative A (Proposed Action) Subsequent potential exploration and development of the Proposed Action could produce impacts of floodplains if development is proposed within Section 14 of EOI ES3321 Part 1 (1835a). Impacts would include potential changes to the hydrology of stream systems. Any development that occurs within the floodplain is likely to reduce the effectiveness of the floodplain to attenuate flood flows by removing vegetation that reduces streamflow velocities, increasing compaction of soils, reducing infiltration and reducing the cross sectional area of the floodplain available to convey flood flows. Increased peak flows during flood events and increased sedimentation downstream are other possible impacts from subsequent potential exploration and development.
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As noted above, Section 11 does not sit with a 100 year floodplain area, nor does the immediately adjacent already leased parcel, EOI ES3321 1835(b), so impacts from the exploration and/or development of the portion of EOI ES3321 Part 1 (1835a) in Section 11, EOI ES3321 (1835b), ALES-057845 and EOI ALES-057966 are not anticipated to cause impacts to the hydrology of stream systems or wetlands within floodplains.
EOI ES3321 Part 1 (1835a) in Section 14, however, is entirely located within the 100-year floodplain (Appendix A, Figure A.4). Mitigation measures discussed below would avoid impacts to floodplains from any potential exploration or development of Section 14. Further analysis of floodplains will be conducted at the APD stage, when a site-specific development proposal has been received.
Mitigation Measures In order to avoid impacts to floodplains, a lease notice has been added to EOI ES3321 Part 1 (1835a) which states, “the EOI lies within a 100-year floodplain; additional mitigation and/or permits may be necessary for development. Whether or not development occurs within the lease parcel boundaries will be analyzed and decided upon by the Authorized Officer at the Application for Permit (APD) stage with no guarantees given that development could occur on said lease parcel” (Appendix B).
Invasive/Exotic Species How would future potential development as a result of the proposed project potentially increase invasive species?
Affected Environment There are a number of non-native species that are considered invasive in Alabama. Alabama’s 10 Worst Invasive Weeds – a publication of the Alabama Invasive Plant Council (ALIPC 2003) is summarized in Table 2 below. One invasive species on this list, Chinese tallow (Triadica sebifera), was confirmed present on EOI ES3321 Part 1 (1835a). The table below notes if the nominated parcel contains suitable habitat for additional species.
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Table 2. Alabama’s 10 Worst Invasive Weeds. COMMON NAME SCIENTIFIC NAME HABITAT SUITABILITY ON PARCEL Kudzu Pueraria montana Suitable habitat on the parcel Chinese tallow Triadica sebifera Present in Section 11 Cogongrass Imperata cylindrica Suitable habitat on the parcel Chinese privet Ligustrum sinense Suitable habitat on the parcel Tropical soda apple Solanum viaria No suitable habitat on the parcel Japanese climbing fern Lygodium japonicum Suitable habitat on the parcel Invasive roses Rosa spp. Suitable habitat on the parcel Eurasian water milfoil Myriophyllum spicatum No suitable habitat on the parcel Hydrilla Hydrilla verticillata Suitable habitat in Section 14 Alligatorweed Alternanthera philoxeroides Suitable habitat in Section 14
There is an existing oil and gas nomination (EOI ES3321 [1835b]), which was sold for lease during the lease sale held in June 2020, located immediately adjacent to the 40 acre portion of EOI ES 3321 Part 1 (1835a) in Section 11 (Appendix A, Figure A.2). Chinese tallow was observed on this 120.38-acre parcel during the site visit conducted on October 18, 2019. No additional invasive species were observed. The RFDS for EOI ES3321 (1835b) predicts that 6.65 acres will be disturbed for one well pad and access road on the parcel or within a 2-mile radius, which will change the existing level of disturbance in that area.
The majority of the land within a 10-mile radius of the proposed parcel is private property so information is not available regarding the presence of invasive species for this area excluding the 200.62 acres that were surveyed for EOI ES3321 Part 1 (1835a) and EOI ES3321 (1835b). Based on aerial photography, the majority of this area appears to be forested with some acreage cleared for agricultural activities. There is some federal land however within the 10-mile radius surrounding these EOIs. The proclamation boundary for the Conecuh National Forest (NF) is located approximately four miles south of the parcel. Current projects planned on the Conecuh NF include habitat restoration, tree stand thinning, and maintenance/modification of facilities and roads. Twenty-four invasive species have been documented to occur on Conecuh NF and include all of the species listed in Table 2 except for tropical soda apple, Eurasian water milfoil, and hydrilla (U.S. Department of Agriculture 2004). The type of impacts to invasive species from the development of the existing lease for ES3321 (1835b), as analyzed in the EA DOI-BLM- Eastern States-0020-2020-0009-EA, and the current projects planned on the Conecuh NF would be identical to the Proposed Action, although development of EOI ES3321 Part 1 (1835a) and planned projects on the Conecuh NF would increase the degree of these impacts within a 10 mile radius of the proposed lease parcel. Impacts from all of these projects are discussed below in the Proposed Action.
Effects of Alternative A (Proposed Action) The RFDS projects that approximately 16.6 acres of surface disturbance could occur from future oil and gas activities associated with EOIs ES 3321 Part 1 (1835a) and ES3321 (1835b) (9.86 and 6.65 acres, respectively) on the parcels or within a 2-mile radius. The exact amount of acreage that would be disturbed for projects currently planned on the Conecuh is unknown at this time. Surface disturbances can often encourage the introduction of invasive species into an area
although the probability of this happening cannot be predicted using existing information. Noxious weed seeds can be carried to and from the project areas by construction equipment, the drilling rig and transport vehicles. Noxious weeds can have a disastrous impact on biodiversity and natural ecosystems. Noxious weeds affect native plant species by out-competing native vegetation for light, water and soil nutrients. Noxious weeds in the United States cause $137 billion in estimated losses to producers annually (Fuller and Mangold 2017). These losses are attributed to: 1) decreased quality of agricultural products due to high levels of competition from noxious weeds, 2) decreased quantity of agricultural products due to noxious weed infestations, and 3) costs to control and/or prevent the spread of noxious weeds.
Forest conversion activities on and surrounding the proposed EOI parcel and within a 2 to 10 mile radius for timber harvest, agricultural activities and human development have likely increased the presence of invasive species in the past and will continue to do so if precautionary measures, such as the recommended BMPs below, are not implemented during development activities. If the recommended BMPs are implemented, effects due to invasive species on the potential future development sites are not anticipated.
Recommended Best Management Practices BMPs are recommended for the proposed project to prevent the introduction or spread of noxious weeds, including the use of weed-free hay, mulch and straw. The BMPs recommend that native seeding mixtures be used during reclamation activities. It is also recommended that post- construction monitoring for cogongrass (Imperata cylindrica) and other invasive plant species be conducted to ensure early detection and control. If invasive species are found, the proper control techniques should be used to either eradicate the species from the area or minimize its spread to other areas. If cogongrass is found on site, equipment should be washed before exiting the site to prevent the spread of this highly invasive species to other locations.
Vegetation How would potential future development on the nominated lease parcel impact vegetation?
Affected Environment EOI ES3321 Part 1 (1835a) and adjacent EOI ES3321 (1835b) consist entirely of an oak-pine forest. Dominant tree species include: water oak, sweetgum, loblolly pine, wax myrtle, laurel oak, and Chinese tallow. The majority of the land surrounding these EOIs within a 10-mile radius is private land so information regarding vegetation in this area is not available, however there is some federal land approximately four miles south in the Conecuh NF. Based on aerial photography, the majority of the area is forested with some acreage cleared for agricultural activities. According to the Final Environmental Impact Statement for the Revised Land and Resource Plan, National Forests of Alabama (FEIS RLRP), there are nine major habitat groups found on the nearby Conecuh NF including the oak-pine forest habitat that can be found on both EOIs. The type of impacts to vegetation from the development of the existing lease for ES3321 (1835b), as analyzed in the EA DOI-BLM-Eastern States-0020-2020-0009-EA, and the current projects planned on the Conecuh NF would be identical to the Proposed Action, although
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development of EOI ES3321 Part 1 (1835a) and planned projects on the Conecuh NF would increase the degree of these impacts in the area. Impacts from all of these projects are discussed below in the Proposed Action.
Effects of Alternative A (Proposed Action) Reasonably foreseeable oil and gas development could result in short and long-term impacts to vegetation on ES3321 Part 1 (1835a) and within the surrounding 10-mile area. A RFDS predicts that 9.86 acres will be cleared for development of the proposed lease parcel, with approximately half of the disturbance acreage located on the EOI parcel itself for one pad and the remaining acreage disturbed for a second well pad somewhere within a 2-mile radius of the EOI, in a location not yet determined. A RFDS predicts that an additional 6.65 acres of vegetation will be cleared in the future for ES3321 (1835b) for one well pad located adjacent to EOI ES3321 Part 1 (1835a) within a 2-mile radius. Some acreage of vegetation will also be cleared for planned projects on the Conecuh NF and potential future development of other active, existing leases within the 10 mile radius. Some of the acreage cleared could be reclaimed and revegetated over time, however it is unlikely that the site will be reclaimed back to the original condition and vegetation type and will be dependent upon decisions made by the private landowners and the Conecuh NF.
Short-term impacts to vegetation from future development would primarily result from removal of vegetation for construction of a total of three well pads for the two EOIs and associated infrastructure within a 2 mile radius of EOI ES3321 Part 1 (1835a). Long-term vegetation loss could include those portions of the well pads needed for production operations for the life of the wells and access roads. Impacts could potentially be remediated during the reclamation process or through natural succession; however, the standard of reclamation or likelihood of natural succession taking place is at the discretion of the private landowners. Therefore, the BLM cannot predict whether vegetation will be returned to their existing conditions and ecological trajectory.
Because site-specific project details and reclamation plans are unknown at the leasing phase, it is possible that all 16.51 acres of predicted disturbance associated with lease development for both EOIs and additional acreage cleared for projects on the NF, will be lost to native vegetation for the long-term. Future site-specific analysis would be conducted at the APD stage.
Wildlife How would potential future development on the nominated lease parcel impact wildlife?
Affected Environment Wildlife species diversity and abundance is likely high on ES3321 Part 1 (1835a), adjacent EOI ES3321 (1835b), and within a 10-mile radius, including lands in the Conecuh NF. Game species are particularly anticipated to thrive due to the primarily mature oak-pine forest, the Conecuh River located in Section 14 and oxbow to the River in Section 11 and unfragmented forest within the Conecuh NF. This surrounding area within a 10-mile radius is predominantly privately owned with some federal acreage on the Conecuh NF and appears to be primarily forested with
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some water bodies present. Species likely present on the parcel and within the 10-mile radius include forest passerines, white-tailed deer (Odocoileus virginianus), bobwhite quail (Colinus virginianus), small rodents, and small to medium-sized omnivores and carnivores. The type of impacts to wildlife from the development of the existing lease for ES3321 (1835b), as analyzed in DOI-BLM-Eastern States-0020-2020-0009-EA, and the current projects planned on the Conecuh NF would be identical to the Proposed Action, although development of EOI ES3321 Part 1 (1835a) and planned projects on the Conecuh NF would increase the degree of these impacts in the area. Impacts from all of these projects are discussed below in the Proposed Action.
Effects of Alternative A (Proposed Action) Reasonably foreseeable oil and gas development could result in short and long-term impacts to wildlife due to the proposed project. The RFDS predicts that 9.86 and 6.65 acres of vegetation which can be used as wildlife habitat will be cleared for EOI ES3321 Part 1 (1835a) and adjacent EOI ES3321 (1835b) respectively. Additional acreage will be cleared for planned projects on the Conecuh NF. Some of this acreage could be reclaimed and revegetated over time, however it is possible that the site will not be reclaimed back to the original condition and vegetation type. Reclamation activities and success will be dependent upon decisions made by the private landowners or the USFS.
Negative impacts to wildlife could result from decreased habitat availability, increased habitat fragmentation, dust, noise, or other disturbance during development. The aquatic habitat stipulation would reduce impacts to wildlife habitat by requiring a 250 foot radius from water bodies in Sections 11 and 1. Reclamation and restoration efforts for surface disturbance could provide for the integrity of other resources; however, these efforts may not always provide the same habitat values (e.g., structure, composition, cover, etc.) that were previously present. Short- term negative impacts to wildlife would occur during the construction and production phase of the operation (i.e., drilling, fracturing, production, etc.) due to noise and habitat destruction. In general, most wildlife species would become habituated to the new facilities. For other wildlife species with a low tolerance to human activities, operations on the well pads would cause displacement from the area due to ongoing disturbances such as vehicle traffic, noise and equipment maintenance. As a result, species diversity and relative abundance of individual species may change at the well sites, including for game species. The EOI parcels appear to be primarily a hunting property. If game species at the sites decline during the construction phase and potentially after construction, hunting opportunities may decrease as well, particularly if reclamation activities do not occur.
Long-term impacts to wildlife populations and habitat would likely vary. Negative effects can be correlated to the distance of new surface disturbance to pre-existing development and disturbances. For example, well-pad installation near roads and powerlines would have a lesser effect on wildlife populations than if the well pad were to be installed in an area devoid of pre- existing development. Wildlife use of the sites after the well is put into production would vary depending on vegetation and succession stage. Once put into production, the well pad would likely be reduced in size and the reserve pit would be graded and seeded. Wildlife use of the sites in the long-term is dependent on the adequacy of restoration. Because site-specific project details
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and reclamation plans are unknown at the leasing phase and currently unknown for planned USFS projects, it is possible that all 16.51 acres of predicted disturbance associated with lease development for both EOIs and additional acreage for USFS projects, will be lost as wildlife habitat for the long-term. Future site-specific analysis would be conducted at the APD stage. The Proposed Action, even in combination with other reasonably foreseeable development, would not be expected to significantly alter current habitat or modify existing wildlife patterns. Effects to species at the population level would not be expected.
Mitigation Measures Measures should be taken to prevent, minimize, or mitigate impacts to fish and wildlife animal species from exploration and development activities. Prior to authorization of an APD, activities would be evaluated on a case-by-case basis, and the project would be subject to recommended mitigation measures. Suggested mitigation could potentially include rapid re-vegetation, noise restrictions, project relocation, or pre-disturbance wildlife species surveying. These mitigation techniques could have a high potential to minimize negative impacts caused by the proposed action.
Special Status Species How would future potential development on the nominated lease parcel impact threatened, endangered, and candidate species?
Affected Environment Section 7 of the ESA requires that federal agencies prevent or modify any projects authorized, funded, or carried out by the agencies that are “likely to jeopardize the continued existence of any endangered species or threatened species, or result in the destruction or adverse modification of critical habitat of such species.” Information regarding this project was entered into the U.S. Fish and Wildlife Service (USFWS) Information for Planning and Consultation database (IPaC). Table 3 provides the species list generated for ES3321 Part 1 (1835a) through IPaC. The table also notes the presence of suitable habitat on the parcel. Details regarding species habitat, habits, threats and other information was obtained from the Nature Serve website (www.natureserve.org), USFWS ECOS (https://ecos.fws.gov), and published literature.
No special status plant species are documented to be present on EOI ES3321 Part 1 (1835a), although suitable habitat may be present, as described in Table 3.
Table 3. IPaC species list for EOI ES3321 Part 1 (1835a). Species Federal Suitable Habitat Presence Status Red-cockaded Woodpecker Endangered No suitable habitat present (Picoides borealis) Wood Stork (Mycteria americana) Threatened Potential suitable habitat present Choctaw Bean (Villosa Endangered Suitable habitat present in Sec. 14 choctawensis) and Critical Habitat
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Fuzzy Pigtoe (Pleurobema Threatened Suitable habitat present in Sec. 14 strodeanum) and Critical Habitat Narrow Pigtoe (Fusconaia Threatened Suitable habitat present in Sec. 14 escambia) and Critical Habitat Orangenacre Mucket (Lampsilis Threatened Suitable habitat present in Sec. 14 perovalis) Round Ebonyshell (Fusconaia Endangered Suitable habitat present in Sec. 14 rotulata) and Critical Habitat Southern Clubshell (Pleurobema Endangered Suitable habitat present in Sec. 14 decisum) Southern Kidneyshell Endangered Suitable habitat present in Sec. 14 (Ptychobranchus jonesi) and Critical Habitat Southern Sandshell (Hamiota Threatened Suitable habitat present in Sec. 14 australis) and Critical Habitat Critical Habitat for Tapered Pigtoe Critical Suitable habitat present in Sec. 14 (Fusconaia burkei) Habitat Only Atlantic Sturgeon (Gulf Threatened Potential suitable habitat present subspecies) (Acipenser oxyrinchus in Sec. 14 desotoi) and Critical Habitat Gray Bat (Myotis grisescens) Endangered Potential suitable foraging habitat present Eastern Indigo Snake Threatened Suitable habitat present (Drymarchon corais couperi) Gopher Tortoise (Gopherus Candidate Suitable habitat present polyphemus)
Red-Cockaded Woodpecker (Picoides borealis) (Endangered) EOI ES3321 Part 1 (1835a) and ES3321 (1835b) do not contain a pine component of the appropriate size class for cavity trees or spacing for foraging with a high pine basal area and therefore, does not contain suitable habitat for the red-cockaded woodpecker (RCW). RCWs can be found on the Conecuh NF.
Wood Stork (Mycteria americana) (Threatened) There is potentially suitable habitat for the wood stork along the oxbow located along the western boundary of the southern portion of Section 11 and within the Conecuh River in Section 14 (see Maps, Appendix A). There is also potentially suitable habitat for this species on EOI ES3321 (1835b) located adjacent to the proposed EOI in Section 11. The wood stork has not been documented on the Conecuh NF.
Mussel Species and Critical Habitat Suitable habitat for the Choctaw bean, fuzzy pigtoe, narrow pigtoe, orangenacre mucket, round ebonyshell, southern clubshell, southern kidneyshell, southern sandshell, tapered pigtoe and
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critical habitat species can be found in Sec.14 of the proposed EOI. Several mussel species have the potential to be found on the Conecuh NF.
Atlantic Sturgeon (Gulf subspecies) (Acipenser oxyrinchus) (Threatened) and Critical Habitat Potentially suitable habitat for the Atlantic sturgeon is present in Sec. 14. Suitable habitat is not available on EOI ES3321 (1835b). This species has not been documented on the Conecuh NF.
Gray Bat (Myotis grisescens) (Endangered) There is potential for gray bat foraging and resting habitat on the nominated parcel and on EOI ES3321 (1835b). This species has not been documented on the Conecuh NF.
Eastern Indigo Snake (Drymarchon corais couperi) (Threatened) Potential suitable habitat for the eastern indigo snake exists on EOI ES3321 Part 1 (1835a). There is also suitable habitat for this species on EOI ES331 (1835b), which contains 120.38 acres adjacent to the proposed parcel in Section 11. This species has not been documented on the Conecuh NF.
Gopher Tortoise (Gopherus polyphemus) (Candidate) No gopher tortoise individuals or burrows were observed on the parcels for EOI ES3321 Part 1 (1835a) or EOI ES3321 (1835b) during the site visit. The parcels contain an open midstory and understory in some areas and therefore suitable or potentially suitable habitat for this species is present for both EOIs and on the Conecuh NF.
The types of impacts to wood storks, eastern indigo snakes, and gopher tortoises from the development of the existing lease for ES3321 (1835b), as analyzed in the EA DOI-BLM-Eastern States-0020-2020-0009-EA, would be identical to the Proposed Action, although development of EOI ES3321 Part 1 (1835a) would increase the intensity of these impacts (within the analysis area). Planned projects on the Conecuh NF could potentially have additional impacts on the gopher tortoise. Impacts from all projects are discussed below in the Proposed Action.
Effects of Alternative A (Proposed Action) Reasonably foreseeable oil and gas development could result in short and long-term impacts to some species on the proposed parcel. There is no suitable habitat for the RCW on EOI ES3321 Part 1 (1835a). As a result, there will be no effect on this species from potential future oil and/or gas development. However, there is potentially suitable habitat for the gopher tortoise, wood stork, gray bat and eastern indigo snake in Section 11 and 14. Mussel species and critical habitat and the Atlantic sturgeon and critical habitat in are present in Section 14. There is also suitable or potentially suitable habitat for the wood stork, Eastern indigo snake, and gopher tortoise on EOI ES3321 (1835b). There is suitable habitat for the RCW, gopher tortoise, and several mussel species on the Conecuh NF.
Reasonably foreseeable oil and gas development, in combination with planned projects on the Conecuh NF, could result in short and long-term impacts to federally listed species, including displacement due to habitat loss, noise, and disturbance which could cause individuals to move
DOI-BLM-Eastern States-0020-2021-0002-EA 40 to less suitable surrounding areas. This could affect overall health and reproductive success of individuals. Future site-specific analysis would be conducted at the APD stage. Appropriate enforcement of pertinent laws and policies by applicable agencies, plus adherence to the stipulations listed below, would reduce impacts, and implementation of reclamation activities could help restore habitat conditions.
To protect the gopher tortoise, wood stork, gray bat and eastern indigo snake, stipulations are attached to the leases for EOI ES3321 Part 1 (1835a) and ES3321 (1835b) and are described in the Mitigation Measures section below and Appendix B. To protect federally listed aquatic species including nine mussels and the Atlantic sturgeon, a freshwater aquatic habitat stipulation has also been attached to this lease. This stipulation requires that no disturbance occur within 250 feet of any wetlands or the Conecuh River in Section 14 and the southwest portion of Section 11. As a result of these stipulations, BLM has determined that the proposed project may affect, but is not likely to adversely affect the gopher tortoise, wood stork, gray bat, eastern indigo snake, nine mussel species and their critical habitats and the Atlantic sturgeon and its critical habitat.
Informal Consultation Informal consultation with USFWS was initiated on November 18, 2019 stating that the proposed EOIs “may affect, but is not likely to adversely affect” the gopher tortoise, wood stork, gray bat, eastern indigo snake, nine mussel species and their critical habitat and the Atlantic sturgeon and its critical habitat. Since the gopher tortoise is a candidate species, USFWS could not concur with the SSDO determination since candidate species are not afforded protection under the ESA. A signed letter from USFWS of concurrence with BLM determinations for these species was received on December 5, 2019 (Appendix D).
Mitigation Measures Additional consultation with USFWS will be conducted at the APD stage if it is determined that the project has the potential to affect federally listed species.
An endangered species stipulation is attached to the lease which states that BLM may recommend modifications to exploration and development proposals to further its conservation and management objective to avoid BLM-approved activity that will contribute to a need to list such a species or their habitat. BLM may require modifications to or disapprove a proposed activity that is likely to result in jeopardy to the continued existence of a proposed or listed threatened or endangered species or result in the destruction or adverse modification of a designated or proposed critical habitat. BLM will not approve any ground-disturbing activity that may affect any such species or critical habitat until it completes its obligations under applicable requirements of the ESA as amended, 16 U.S.C. ' 1531 et seq., including Section 7 consultation (Appendix B).
A stipulation is also attached to the proposed lease to protect habitat for the gopher tortoise and eastern indigo snake which states that BLM-approved surveys will be recommended in all suitable gopher tortoise habitat (in which the eastern indigo snake relies) including Covington County, Alabama, if surface disturbance is scheduled to occur (Appendix B). If the gopher
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tortoise or eastern indigo snake or burrows are observed, additional coordination will occur with USFWS to minimize impacts and eliminate the possibility of take.
A stipulation is also attached to the leases for the wood stork which recommends that construction activities not occur within 250 feet of wetlands that serve as roosting and foraging habitat for the wood stork (Appendix B).
A gray bat stipulation is attached to this lease which states that no surface occupancy will be permitted within 0.5 miles of a gray bat maternal or hibernacula cave site (Appendix B).
A freshwater aquatic habitat stipulation is attached to this lease which states that no surface occupancy or disturbance, including discharges, are permitted within 250 feet of a river, oxbow, floodplain or other water body (Appendix B). As a result, there will be no surface occupancy within 250 feet of the wetlands or the Conecuh River in Section 14 and the southwest portion of Section 11.
These stipulation mitigation techniques would have a high potential to minimize negative impacts that could potentially be caused by the proposed action.
Migratory Birds of Conservation Concern How would potential future development on the nominated lease parcel impact migratory bird species of conservation concern?
Affected Environment The Migratory Bird Treaty Act of 1918 (MBTA), as amended, makes it unlawful to ”pursue, hunt, take, capture, kill, attempt to take, capture or kill, or possess any migratory bird or any part, nest, or egg of any such bird”, unless expressly permitted by Federal regulations (16 U.S.C. 703(a)). EO 13186, Responsibilities of Federal Agencies to Protect Migratory Birds, directs Federal agencies to integrate conservation principles, measures, and practices into authorized activities and avoid or minimize, to the extent practicable, adverse impacts on migratory bird resources. USFWS and the BLM signed a Memorandum of Understanding (MOU) in 2010, to promote the conservation and strategic management of migratory birds on BLM managed public lands and federal mineral split estate lands.
Because of the vast number of migratory bird species, BLM focuses on species identified by USFWS as Birds of Conservation Concern (BCC) (USFWS 2008). Appendix H lists the BCC found in the Southeastern Coastal Plain where ES3321 Part 1 (1835a), ES3321 (1835b) and the Conecuh NF are located. There is suitable habitat on the proposed lease parcels and on the Conecuh NF for some BCC on this list. The IPaC list of migratory birds for this EOI includes the lesser yellowlegs (Tringa flavipes), prairie warbler (Dendroica discolor), and rusty blackbird (Euphagus carolinua). The type of impacts to migratory birds from the development of the existing lease for EOI ES3321 (1835b), as analyzed in the EA DOI-BLM-Eastern States-0020- 2020-0009-EA, and from planned projects occurring on Conecuh NF would be similar to the Proposed Action, although development of EOI ES3321 Part 1 (1835a) and disturbance on the
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Conecuh NF would increase the degree of these impacts within a 10-mile radius of the proposed lease parcel. Impacts from all projects are discussed below in the Proposed Action.
Effects of Alternative A (Proposed Action) The Proposed Action and predicted activities associated with both EOIs and planned projects on the Conecuh NF would contribute a minor amount of potential vegetation loss from reasonably foreseeable development. Under the RFDS, approximately 9.86 and 6.65 acres of surface disturbance could occur from future oil and gas activities associated with ES3321 Part 1 (1835a) and ES3321 (1835b) respectively. Exact acreage disturbance caused by projects planned on the Conecuh NF are unknown at this time. Surface disturbance from the development of well pads, access roads, pipelines, utility lines and other forest conversion activities can result in an impact to migratory birds and their habitat. The loss of vegetation would also affect migratory birds using that habitat, although many species would likely relocate during construction from future development activities. Reclamation activities would help restore vegetation conditions. Future site-specific analysis would be conducted at the APD stage. The Proposed Action would not be expected to significantly compound current patterns of habitat fragmentation, degradation, or wildlife patterns.
Onshore Oil and Gas Order 7 requires that produced water pits “shall be fenced or enclosed to prevent access by livestock, wildlife, and unauthorized personnel”. Additionally, the Order requires deterrents to exclude birds from open fluid pits. At the APD stage, design features, applicant committed BMPs, conservation actions, and COAs may be applied to provide migratory bird protections.
Recommended Best Management Practices and Mitigation Per the MOU between BLM and USFWS, entitled, “To Promote the Conservation of Migratory Birds,” the following temporal and spatial conservation measures are recommended to be implemented as part of the COAs with an APD:
1. Avoid any take of migratory birds and/or minimize the loss, destruction, or degradation of migratory bird habitat while completing the proposed project or action. 2. If the proposed project or action includes a reasonable likelihood that take of migratory birds will occur, then complete actions that could take migratory birds outside of their nesting season. This includes clearing or cutting of vegetation, grubbing, etc. The primary nesting season for migratory birds varies greatly between species and geographic location, but generally extends from early April to mid-July. However, the maximum time period for the migratory bird nesting season can extend from early February through late August. Strive to complete all disruptive activities outside the peak of migratory bird nesting season to the greatest extent possible. 3. If no migratory birds are found nesting in the proposed project or action areas immediately prior to the time when construction and associated activities are to occur, then the project activity may proceed as planned.
Onshore Oil and Gas Order 7 requires that produced water pits “shall be fenced or enclosed to prevent access by livestock, wildlife, and unauthorized personnel”. Additionally, the Order
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requires deterrents to exclude birds from open fluid pits. These mitigation techniques would have a high potential to minimize negative impacts that could potentially be caused by the proposed action.
Irreversible and Irretrievable Commitment of Resources NEPA Section 102(2)C requires a discussion of any irreversible or irretrievable commitments of resources that would be involved in the proposal should it be implemented. An irreversible commitment of a resource is one that cannot be reversed (e.g., the extinction of a species or disturbance to protected cultural resources). An irretrievable commitment of a resource is one in which the resource or its use is lost for a period of time (e.g., extraction of any solid mineral ore or fluid mineral).
Reasonably foreseeable oil and gas development associated with the Proposed Action would result in a minor amount of surface disturbing activities that could result in irreversible or irretrievable commitments of resources. These surface disturbing activities would result in alterations to soil, removal of vegetation cover and wildlife habitat, and possible damage to cultural resources if proper surveys and consultations are not conducted under the NHPA. Increases in sediment and nonpoint source pollution that result from these activities could result in degradation of water quality within the watershed and habitat for aquatic-dependent species. Use of BMPs, COAs and stipulations as described in the EA are designed to reduce the magnitude of these impacts by preventing habitat degradation. Development of oil and gas wells would represent an irretrievable commitment of nonrenewable fossil fuels.
Relationship Between Local Short-term Uses and Long-term Productivity NEPA requires an analysis of the relationship between a project’s short-term impacts on the environment and of the effects that these impacts may have on the maintenance and enhancement of the long-term productivity of the affected environment. Impacts that narrow the range of beneficial uses of the environment are of particular concern. This refers to the possibility that choosing one development option reduces future flexibility in pursuing other options, or that giving over a parcel of land or other resource to a certain use eliminates the possibility of other uses being performed at the site.
The Proposed Action would take place within a relatively rural area with minimal development. No unique habitat or ecosystems would be lost due to this action. Implementation of the Proposed Action or No Action Alternative may result in future oil and gas development, which results in surface disturbing and other disruptive activities that remove vegetation, increase soil erosion and compaction, create visual intrusions and landscape alterations, increase noise, and degrade wildlife habitat. Although proposed management actions, BMPs, surface use restrictions, and lease stipulations are intended to minimize the effect of short-term uses, some impact on long-term productivity of resources could occur.
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7 SUPPORTING INFORMATION 7.1 List of Preparers Name Title Area of Responsibility Date Signed Geology and Minerals, Induced Jason Leist Fluid Geologist Seismicity, Sinkholes and 11/19/2020 Subsidence Special Status Species, Migratory Birds of Conservation Concern, Alison McCartney Wildlife Biologist Wildlife, Vegetation, 11/16/2020 Invasive/Exotic Species Cultural Resources, Native American Religious Concerns, John Sullivan Archaeologist 11/30/2020 Socioeconomics and Environmental Justice Catherine GIS Specialist Maps, Data Accuracy 9/21/2020 Karlovich Planning & NEPA Compliance, Land Use Joe Edmonds Environmental Water Resources- Floodplains Specialist NEPA Compliance, Prime and Planning & Unique Farmlands, Soil Resources, Heather Stewart Environmental 12/1/2020 Water Resources – Surface Water, Coordinator Ground Water, Transportation Environmental Waste, Visual Resources, Noise Tracy Mullins 11/18/2020 Protection Specialist Resources Assistant District John Gant Massey NEPA Compliance 12/03/2020 Manager, Resources
7.2 Tribes, Individuals, Organizations, or Agencies Consulted The BLM conducted and completed required informal consultation with the USFWS in compliance with the ESA Section 7 (16 USC 1531 et seq.). Consultation was completed for a larger area that included EOI ES3321 Part 1 (1835a) and EOI ES3321 (1835b), which satisfied the consultation requirements for the proposed action as well as the proposed action of a past EA, DOI-BLM-Eastern States-0020-2020-0009-EA. The BLM initiated informal consultation with USFWS on November 18, 2019. A concurrence letter was received on December 5, 2019 (Appendix D, Figures D.1 and D.2).
The BLM also conducted and completed the required consultation with the Alabama SHPO and Native American tribes for a larger area that included EOI ES3321 Part 1 (1835a) and EOI ES3321 (1835b). This effort satisfied the consultation requirements for the proposed action as well as the proposed action of a past EA, DOI-BLM-Eastern States-0020-2020-0009-EA. Consultation with the SHPO and coordination with the tribes occurred on February 7, 2019.
The Alabama SHPO and the following tribes were contacted to notify them of the Proposed Action and to request comments or concerns:
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Alabama-Coushatta Tribe of Texas Kialagee Tribal Town Alabama Quassarte Mississippi Band of Choctaw Choctaw Nation Thlopthlocco Tribal Town Coushatta Indian Tribe Tunica-Biloxi Tribe of Louisiana Jena Band of Choctaw Muscogee (Creek) Nation Seminole Nation of Oklahoma Seminole Tribe of Florida Poarch Creek Tribe
The BLM received a concurrence letter from the Alabama SHPO on March 6, 2019. Native American tribal responses were received on March 6, 2019. One tribe responded by saying the project sites are outside of their area of interest and another tribe responded by saying that they are not aware of any sites within the proposed parcels. Cultural-related correspondence may be found in Appendix D, Figures D.3 through.D.7.
7.3 References AirNow 2020. Air Quality Indices. Accessed November 19, 2020. Available at: https://www.airnow.gov/index.cfm?action=airnow.local_city&mapcenter=0&cityid=3
Alabama Department of Environmental Quality. 2000. Alabama Nonpoint Source Management Program (Version 010614). Alabama Department of Environmental Quality, Montgomery, Alabama. 117 pp.
Alabama Forestry Commission. 2007. Alabama’s Best Management Practices for Forestry Manual. [online] URL, Available at: http://www.forestry.alabama.gov/Publications/BMPs/2007_BMP_Manual.pdf
Alabama Invasive Plant Council (ALIPC). 2003. Alabama’s 10 Worst Invasive Weeds. Southeast Exotic Pest Plant Council (SE-EPPC). Available at: https://www.se-eppc.org/pubs/alabama.pdf
Council on Environmental Quality (CEQ). 1997. Environmental Justice: Guidance under the National Environmental Policy Act. Available at: https://www.energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/G-CEQ- EJGuidance.pdf
Cropland data. 2020. ArcGIS Online. Available at: https://goto.arcgisonline.com/landscape11/USA_Cropland
Encyclopedia of Alabama. Climate and weather patterns. Available at http://www.encyclopediaofalabama.org/article/h-1283
Federal Emergency Management Agency (FEMA). 2020a. Benefits of Natural Floodplains. Available online Accessed October 2020.Available at https://www.fema.gov/floodplain- management/wildlife-conservation/benefits-natural
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Federal Emergency Management Agency (FEMA). 2020b. National Flood Hazard Layer Viewer. Available online. Accessed October 2020. Available at: https://hazards- fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5 529aa9cd
Fuller, K.B. and J. Mangold. 2017. The Cost of Noxious Weeds: What You Can Do About Them. Big Sky Small Acres. Spring Summer 2017. Page 8-9.
Geological Survey of Alabama. 2000, Hydrogeology and Vulnerability to Contamination of Major Aquifers in Alabama: Area 13. Alabama Geological Survey. Available at https://www.gsa.state.al.us/Home/DownloadPubDocument/?path=Circulars&fileName= C199A.pdf. Accessed November 2020.
Geological Survey of Alabama. 2018, Assessment of groundwater resources in Alabama, 2010- 16: Alabama Geological Survey Bulletin 186, 426 p., plus separately bound volume of 105 plates.
Griffith, G.E., J.M. Omernik, J.A. Comstock, G. Martin, A. Goddard, and V.J. Hulcher. 2001. Ecoregions of Alabama. U.S. Environmental Protection Agency, National Health and Environmental Effects Research Laboratory, Corvallis, OR. Available at http://www.ag.auburn.edu/auxiliary/BC/PAGESL1/AgFactsAL/AgFactsALPages_L2/Ge ography/Geography_Texsts/ALeco4pgsz.pdf
Land Use Data. 2020. ArcGIS Online. Available at: https://goto.arcgisonline.com/landscape10/USA_NLCD_Land_Cover
Louisiana Geological Survey. June 2001. Earthquakes in Louisiana. Public Information Series No. 7. Available at https://www.lsu.edu/lgs/publications/products/Free_publications/La-earthquakes.pdf. Accessed July 8, 2020.
Michigan Tech. 2020. Earthquake Magnitude Scale. Available at http://www.geo.mtu.edu/UPSeis/magnitude.html. Accessed July 8, 2020.
NatureServe. 2018. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. NatureServe, Arlington, Virginia. Available at: http://explorer.natureserve.org.
Outdoor Alabama.2020. Conecuh River. Available at https://www.outdooralabama.com/rivers- and-mobile-delta/conecuh-river. Accessed November 2020.
Presidential Documents. 2001. Executive Order No. 13186, Responsibilities of Federal Agencies to Protect Migratory Birds. Federal Register, Vol. 66(11), pg. 3853-3856.
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Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture. Web Soil Survey. Available online at the following link: http://websoilsurvey.sc.egov.usda.gov/. Accessed October 23, 2020 and November 10, 2020.
Title 36, Code of Federal Regulations (CFR) Part 61. Title 36, Chapter I – Department of the Interior, Part 61 – Procedures for State, Tribal, and Local Government Historic Preservation Programs. Available at: http://www.ecfr.gov/cgi-bin/text- idx?SID=6dc7484527f272d5230e0106d4d6de57&mc=true&tpl=/ecfrbrowse/Title36/36c fr61_main_02.tpl
Title 40 Code of Federal Regulations (CFR) Parts 1500-1508 (1978, as amended). Title 40, Chapter V – Council on Environmental Quality, Parts 1500-1508. Available at: http://www.ecfr.gov/cgi-bin/text- idx?SID=c224960d3b75f2df1d20dc0885baf6c9&mc=true&tpl=/ecfrbrowse/Title40/40cfr 1500_main_02.tpl
Title 43, Code of Federal Regulations (CFR) 3162 (1983). Title 43, Subtitle B, Chapter II, Subchapter C, Part 3160 - Onshore Oil and Gas Operations. U.S. Census Bureau. 2018. State and County Quick Facts, Choctaw and Covington County, Alabama. Accessed May 2020. Available at: https://www.census.gov/quickfacts/fact/table/choctawcountyalabama,al,US/PST045217
U.S. Code (16 USC §§ 703-712). Migratory Bird Treaty Act of 1918 (MBTA).
U.S. Code. (16 USC § 470 et seq.). National Historic Preservation Act of 1966.
U.S. Code (16 USC § 1531 et seq.). Endangered Species Act of 1973.
U.S. Code. (30 USC §181 et seq.). Mineral Leasing Act of 1920.
U.S. Code. (33 USC §1251 et seq.). Clean Water Act of 1972.
U.S. Code. (42 USC § 4321). National Environmental Policy Act (NEPA) of 1969, as amended.
U.S. Code. (42 USC § 6901 et seq.). The Resource Conservation and Recovery Act (RCRA). 1976.
U.S. Code. (42 USC § 7401). The Clean Air Act of 1970.
U.S. Code. (42 USC § 9601 et seq.). The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (Superfund). 1980. U.S. Code. (42 USC § 13201 et seq.). The Energy Policy Act (EPA). 2005.
U.S. Code. (43 USC § 1701 et seq.). Federal Land Policy and Management Act of 1976. Public
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Law 94-579.
U.S. Department of Agriculture. U.S. Forest Service. 2004. Final Environmental Impact Statement for the Revised Land and Resource Management Plan. National Forests of Alabama.
----- August 2010. Lands Available for Oil and Gas Leasing Environmental Assessment. Available online. Accessed July 2018. Available at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5210291.pdf
U.S. Department of Interior and U.S. Department of Agriculture. 2007. Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development. BLM/WO/ST- 06/021+3071/REV 07. Bureau of Land Management. Denver Colorado. 84 pp.
U.S. Department of the Interior, Bureau of Land Management (BLM). 1993. Onshore Oil and Gas Operations; Federal and Indian Oil and Gas Leases. Federal Register. Vol. 58(172). 22 pp.
----- 2008. Alabama and Mississippi Proposed Resource Management Plan and Final Environmental Impact Statement. Bureau of Land Management. August 2008.
----- 2008. BLM National Environmental Policy Act Handbook H-1790-1. Bureau of Land Management. 184 pgs.
----- 2009. Departmental Manual Part 516 National Environmental Policy Act of 1969, Environmental Quality. Chapter 6. Managing the NEPA Process. Department of the Interior. 12 pgs.
----- 2020. Oil and natural gas Statistics: Tables 1-16. Accessed February, 2020. https://www.blm.gov/programs/energy-and-minerals/oil-and-gas/oil-and-gas-statistics
U.S. Energy Information Administration (EIA). 2018. The Distribution of U.S. Oil and Natural Gas Wells by Production Rate, Appendix C. Accessed February, 2020. U.S. Department of Energy, Washington, DC. https://www.eia.gov/
U.S. Environmental Protection Agency (EPA). 2011. Our Nation’s Air: Status and Trends Through 2010. Available at: http://www.epa.gov/airtrends/2011
----- 2016. What Climate Change Means for Alabama. https://19january2017snapshot.epa.gov/sites/production/files/2016- 09/documents/climate-change-al.pdf
----- 2020a. Alabama Nonattainment / Maintenance Status for Each County by Year for All Criterial Pollutants. Accessed November, 2020. https://www3.epa.gov/airquality/greenbook/anayo_al.html
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----- 2020b. Inventory of U.S. Greenhouse Gas Emissions and Sinks. 1990-2017. www.epa.gov/sites/production/files/2019-04/documents/us-ghg-inventory-2019-main- text.pdf
----- 2020c. 2017 National Emissions Inventory (NEI) Data. Accessed November, 2020. www.epa.gov/air-emissions-inventories/2017-national-emissions-inventory-nei-data
----- 2020. WATERS GeoViewer. https://epa.maps.arcgis.com/apps/webappviewer/index.html?id=ada349b90c26496ea52aa b66a092593b Accessed August 22, 2020.
----- 2020. Greenhouse Gas Equivalencies Calculator. Accessed February, 2020. https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator
U.S. Fish and Wildlife Service. 2003. Red-cockaded Woodpecker (Picoides borealis) Recovery Plan: Second Revision. U.S. Fish and Wildlife Service, Atlanta, Georgia, USA.
------2008. Birds of Conservation Concern. Available online. Accessed May 2018. Available at: https://www.fws.gov/migratorybirds/pdf/grants/BirdsofConservationConcern2008.pdf
------2011. Endangered and threatened wildlife and plants; 12-month finding on a petition to list the Gopher Tortoise as threatened in the eastern portion of its range. Federal Register 76(144):45130-45162.
------Environmental Conservation Online System (ECOS). Accessed October 2019. Available at: https://ecos.fws.gov/ec
U.S. Geological Survey. 2020a. Earthquake catalog. Available at https://earthquake.usgs.gov/earthquakes/search/. Accessed October 15, 2020.
U.S. Geological Survey. 2020b. Groundwater Questions and Answers. Available at https://www.usgs.gov/special-topic/water-science-school/science/water-science- questions-answers?qt-science_center_objects=0#qt-science_center_objects. Accessed July 8, 2020.
U.S. Geological Survey. 2020c. Land Subsidence in the United States, USGS Fact Sheet-165-00. https://water.usgs.gov/ogw/pubs/fs00165/. Accessed July 9, 2020.
U.S. Geological Survey. 2020d. Short-term Induced Seismicity Models. Available at https://earthquake.usgs.gov/hazards/induced/. Accessed October 15, 2020.
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APPENDIX A. MAPS Figure A.1. Aerial map of EOI ES3321 Part 1 (1835a). The southeastern portion of the EOI in Section 14 crosses the Conecuh River.
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Figure A.2. Aerial map showing EOI ES3321 Part 1 (1835a) in relation to an existing Federal lease, EOI ES3321 (1835b).
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Figure A.3. Map showing approximate location of EOI ES3321 Part 1 (1835s) in Sections 11 and 14, marked by orange dots, on the Federal Emergency Management Agency (FEMA) National Flood Hazard Layer Viewer. The reader can see that Section 11, the northern section, is within an area of minimal flood hazard, but Section 14 is within a Zone A Flood Hazard Zone(FEMA 2020b).
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Figure A.4. A map from the Environmental Protection Agency (EPA)’s WATERS GeoViewer. The map shows that while Section 11, the northern section, of the parcel is outside of the 100 year floodplain area, Section 14, the southern section, is directly in the middle of the Conecuh River 100 year floodplain.
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Figure A.5. A map of the wetlands within the parcel. The aquatic habitat NSO stipulation in Appendix B requires development to be 250 feet from wetlands and the Conecuh River.
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Figure A.6. Map showing the EOIs and active Federal oil and gas leases in the Teel Creek subwatershed. Existing private well locations are also shown.
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APPENDIX B. MITIGATION MEASURES Lease Stipulations
Cultural Resources and Tribal Consultation Stipulation: This lease may be found to contain historic properties and/or resources protected under the NHPA, American Indian Religious Freedom Act, Native American Graves Protection and Repatriation Act, E.O. 13007, or other statutes and executive orders. The BLM will not approve any ground disturbing activities that may affect any such properties or resources until it completes its obligations under applicable requirements of the NHPA, NEPA and other authorities. These obligations may include a cultural resources survey, depending on the type of APD under the scenarios discussed in Permanent Instruction Memorandum (PIM) 2018-014. Any survey must be conducted by a professional archaeologist approved by the SHPO. The operator will contact the BLM if new Historic Properties, including, but not limited to, archaeological material such as flint or stone tools, pottery, fire hearths, human remains, historic glass, ceramics, metal, or building foundations are exposed during the course of the drilling and production operations approved under the APD. If these are discovered during development activities associated with this lease, these activities must cease immediately, applicable law on unknown burials will be followed and, if necessary, consultation with the appropriate tribe/group of federally recognized Native Americans and the SHPO will take place. The BLM may require modification to exploration or development proposals to protect such properties or disapprove any activity that is likely to result in adverse effects that cannot be successfully avoided or minimized.
Minerals and Mineral Development Stipulation: Operations will not be approved which, in the opinion of the authorized officer, would unreasonably interfere with the orderly development and/or production from a valid existing mineral lease issued prior to this one for the same lands.
Endangered Species Stipulation: The lease area may now or hereafter contain plants, animals, or their habitats determined to be threatened, endangered, sensitive or other special status species. BLM may recommend modifications to exploration and development proposals to further its conservation and management objective to avoid BLM-approved activity that will contribute to a need to list such a species or their habitat. BLM may require modifications to or disapprove proposed activity that is likely to result in jeopardy to the continued existence of a proposed or listed threatened or endangered species or result in the destruction or adverse modification of a designated or proposed critical habitat. BLM will not approve any ground-disturbing activity that may affect any such species or critical habitat until it completes its obligations under applicable requirements of the Endangered Species Act as amended, 16 U.S.C. ' 1531 et seq., including completion of any required procedure for conference or consultation.
Exception: None
Modification: None
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Waiver: None
Eastern Indigo Snake and Gopher Tortoise Stipulation (Controlled Surface Use [CSU]): The BLM recommends USFWS-approved surveys in all suitable habitat for the threatened eastern indigo snake, whose habitat is dependent on the closely associated candidate gopher tortoise. This association is especially pronounced in Alabama, where eastern indigo snakes are largely restricted to sandhill habitats occupied by gopher tortoises. Therefore, surveys are recommended, in consultation with the USFWS, where the gopher tortoise is listed, including Covington County, Alabama. The eastern indigo snake frequents several habitat types, including pine flatwoods, scrubby flatwoods, high pine, dry prairie, tropical hardwood hammocks, edges of freshwater marshes, agricultural fields, coastal dunes, and human-altered habitats. Further, no surface disturbance is recommended within 600 feet of a gopher tortoise burrow.
Suitable habitat includes areas with deep, well-drained and excessively well-drained sandy soils, especially the following USDA¬NRCS soil series and with an open understory with grass and forb groundcover open areas. Suitable soils include Alaga, Bigbee, Eustis, Lakeland, Waldley or Troup, McLaurin, Benndale, Heidel, Bama, Smithdale, Ruston, Lucedale, Lucy, Shuguta, Baxterville, Malbis, Poarch, Saucier, Susquehanna, Boswell, Lorman, Freestone, Freest, Prentis, Savannah, Basin, and Petal.
Objective: To protect habitat for the gopher tortoise and other commensal species, including the eastern indigo snake and gopher frog.
Exception: Exceptions may be granted if the proponent agrees to implement measures developed in consultation with USFWS and coordination with state agencies.
Modification: This stipulation may be modified if suitable gopher tortoise habitat does not exist on the stipulated area and that area does not provide forage habitat for adjacent tortoise populations. Survey requirements may be modified if current tortoise surveys of the tract are approved by BLM and USFWS.
Waiver: This stipulation may be waived if suitable gopher tortoise habitat does not exist on the tract and the tract does not provide forage habitat for gopher tortoises in adjacent areas.
Wood Stork Stipulation: Construction activities is not recommended within 250 feet of wetlands that serve as roosting and foraging habitat for the federally threatened wood stork.
Objective: To minimize harassment of wood storks during foraging.
Exception: An exception may be granted if the operator agrees to implement measures developed in consultation with the FWS and in coordination with state agencies.
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Modification: None
Waiver: This stipulation may be waived if no wetlands exist on the tract.
Gray bat Stipulation (NSO): No surface occupancy or disturbance is permitted within 0.5 miles of an Indiana or gray bat summer roost or gray bat wintering cave hibernacula.
Objective: To prevent fatal disturbance during summer nursery roosting or winter hibernation.
Exception: An exception may be granted if the operator agrees to implement measures developed in coordination with USFWS and appropriate state agencies. Formal consultation with USFWS may be required if determined necessary to protect species and associated habitat.
Modification: This stipulation may be modified if the project does not adversely impact Indiana or gray bat summer roost or gray bat wintering cave hibernacula with concurrence from Fish and Wildlife Service and the appropriate state agencies.
Waiver: This stipulation may be waived if the lease is not within 0.5 miles of an Indiana or gray bat summer roost or gray bat wintering cave hibernacula.
Freshwater Aquatic Habitat
Stipulation (NSO): No surface occupancy or disturbance, including discharges, are permitted within 250 feet of a river, stream, wetland spring, headwaters, wet meadows, wet pine savannas, pond, tributary, lake, coastal slough, sand bars, vernal pools on granite outcrops, calcareous seepage marshes, brackish marshes, saltmarsh or small, marshy calcareous streams.
Objective: To protect water quality of watersheds and natural stream substrate and morphology and to avoid potential impacts to federal and state-listed aquatic species.
Exception: An exception may be granted if the operator agrees to 1) span creeks and floodplains by attaching pipelines to bridges or 2) directionally drill under creeks, rivers, and other waters supporting listed species, 3) implement other measures developed in consultation with USFWS and coordination with state agencies.
Modification: The radius may be reduced if the adjacent waterway has been surveyed for 100 yards upstream and 300 yards downstream of the site, and results document the lack of suitable/occupied habitat for special status species within the mixing zone downstream of the project, as determined by BLM and USFWS.
Waiver: The stipulation may be waived if it is determined that the lease area has no hydrological connection to habitat of sensitive aquatic species.
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Recommended Best Management Practices (BMPs)
Invasive and Non-Native Species BMP: Use of native or non-invasive plants in seeding mixtures is encouraged to stabilize disturbed areas and during restoration activities. Construction sites should ideally be surveyed for invasive species prior to ground disturbance. If invasive species are found, the proper control measures should be used to either eradicate the species from the area or minimize its spread to other areas. If cogongrass (Imperata cylindrica) is found on site, equipment should be washed before exiting the site to prevent the spread of this highly invasive species to other locations. Post-construction monitoring for cogongrass and other invasive plant species should be conducted to ensure early detection control. In the case of split-estate lands, final seed mixtures will be determined by the private landowner. Objective: To discourage the spread of invasive, non-native plants.
Pesticide Application BMP: Any ground application of herbicides or other pesticides, sterilants, or adjuvants within 150 feet of listed species or habitat will require site-specific control measures developed in coordination or formal consultation with FWS. No aerial application of herbicides or pesticides will be permitted.
Objective: To protect the water quality of watersheds and natural stream substrate and morphology supporting special status species and their host species.
Soils BMP: Appropriate sediment and erosion control BMPs are recommended to be implemented as defined in the following documents: (1) Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development (DOI 2007) and (2) Alabama’s Best Management Practices for Forestry (Alabama Forestry Commission 2007), which can be found at: http://www.forestry.alabama.gov/Publications/BMPs/2007_BMP_Manual.pdf
Objective: To limit on-site and off-site impacts of erosion and sedimentation across resources.
Lease Notices
Prime and Unique Farmlands BLM may propose an alternate siting location at the APD stage if development were proposed on prime or unique farmlands, in order to preserve the soil integrity of those lands for present or future agricultural purpose, per 43 CFR 3101.1-2.
Floodplains The EOI lies within a 100-year floodplain; additional mitigation and/or permits may be necessary for development. Whether or not development occurs within the lease parcel boundaries will be analyzed and decided upon by the Authorized Officer at the Application for Permit (APD) stage with no guarantees given that development could occur on said lease parcel.
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APPENDIX C. SUMMARY OF ANTICIPATED EFFECTS ACROSS ALL RESOURCES
Impact Analysis Total IAA No Action Resource Area (IAA) Acreage Alternative Proposed Action No immediate impacts from leasing. Minor, short- and EOI ES3321 Part No impacts. long-term changes to land use from reasonably 1 (1835a) and Current land and foreseeable development activities due to conversion of Land Use 12,423 acres the surrounding resource uses undeveloped areas to areas that support potential future 2 mile radius would continue. oil and gas development.
Current land and EOI ES3321 Part resource uses No direct impacts from leasing. Future surveys or Cultural Resources 1 (1835a) and would continue. consultation under the National Historic Preservation and Native American 12,423 acres Potential impacts Act (NHPA) may be required at the APD stage to Interests the surrounding from “relic ensure that no impacts to cultural resources or Native 2 mile radius hunting”, American interests occur. bulldozing, etc. Covington County includes 668,200 acres.
The amount of No impacts. Covington fluid mineral Would result in No direct impacts from leasing. Use and depletion of Mineral Resources resources the continuation of the resource would occur from reasonably foreseeable County, AL available for the current land development. development is and resource uses. unknown until exploration activities are performed. EOI ES3321 Part No impacts. No adverse impacts from leasing. Wastes would be Wastes 12,423 acres. 1 (1835a) and Current land and generated from reasonably foreseeable development,
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Impact Analysis Total IAA No Action Resource Area (IAA) Acreage Alternative Proposed Action the surrounding resource uses with a potential for short and long-term adverse 2 mile radius would continue. impacts if wastes are not properly handled, stored, and disposed. Standard operating procedures (SOPs), best management practices (BMPs), and conditions of approval (COAs) at the APD stage would minimize risk from spills. No direct impacts from leasing. Short and long term Impacts are Potential increases impacts from production and combustion of natural gas Leased Federal discussed in terms in air pollutants if resources from one well, emissions from construction Mineral Estate of the number of Air Resources existing, active oil equipment and fugitive dust if development occurs The acreage in wells producing and gas leases are proposed lease may contribute to the installation and Alabama. Federal minerals developed. production of new wells, which would cause a small in the state increase in greenhouse gas (GHG) emissions. No impacts. No direct impacts from leasing. Potential for minor Teel Creek and Current land and adverse impacts to soils from future reasonably Soils Fall Creek 79,740.52 acres resource uses foreseeable development associated with clearing, subwatersheds would continue. filling, and grading activities. Potential for adverse impacts to water resources from future reasonably No direct impacts from leasing. Potential for minor Water Resources – foreseeable Teel Creek and adverse impacts to water resources from future Surface and development of Fall Creek 79,740.52 acres reasonably foreseeable development. SOPs, BMPs, and Groundwater, existing leases in subwatersheds COAs at the APD stage would minimize risk to Floodplains the subwatersheds. groundwater and surface water from spills. SOPs, BMPs, and COAs at the APD stage would minimize risk to groundwater and
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Impact Analysis Total IAA No Action Resource Area (IAA) Acreage Alternative Proposed Action surface water from spills. No direct impacts from leasing since there would be no surface disturbing activities.
Potential for minor adverse impacts to wildlife and vegetation associated with reasonably foreseeable Natural Resources development associated with clearing for well pad and (Wildlife and road construction due to habitat loss and modification. EOI ES3321 Part No impacts. Vegetation, 1(1835a) and the Approximately Current land and Invasives/Exotics, No adverse impacts to threatened or endangered 207,398 acres resource uses Special Status surrounding 10 species, or habitat suitable for these species, are would continue. Species, Migratory miles anticipated. Other wildlife species, including migratory Birds) birds, would experience loss of habitat and potentially direct disturbance impacts from reasonably foreseeable future development. These impacts are not expected to cause population level impacts to any species, including migratory birds.
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APPENDIX D. USFWS AND CULTURAL CONSULTATION LETTERS Figure D.1. Page 1 of the consultation response letter from the U.S. Fish and Wildlife Service on December 5, 2019, which reiterates BLM’s determinations for each species.
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Figure D.2. Page 2 of the consultation response letter from the U.S. Fish and Wildlife Service on December 5, 2019, which concurs with BLM’s determinations for each species.
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Figure D.3. Consultation response letter from the Alabama Historical Commission, Deputy State Historic Preservation Officer on March 6, 2019.
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Figure D.4. Page 1 of the consultation response email from the Choctaw Nation of Oklahoma on March 6, 2019.
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Figure D.5. Page 2 of the consultation response email from the Choctaw Nation of Oklahoma on March 6, 2019.
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Figure D.6. Page 1 of the consultation response email from the Jenna Band of Choctaw Indians, Tribal Historic Preservation Officer on March 8, 2019.
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Figure D.7. Page 2 of the consultation response email from the Jenna Band of Choctaw Indians, Tribal Historic Preservation Officer on March 8, 2019.
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APPENDIX E. REASONABLY FORESEEABLE DEVELOPMENT SCENARIO REASONABLY FORESEEABLE DEVELOPMENT SCENARIO Case File Number: EOI ES3321 Part 1 (1835a) Project Number: DOI-BLM-Eastern States-0020-2021-0002-EA (March 2021 Oil and Gas Lease Sale) Acres: 80.24 acres Location: St. Stephens Meridian, T3N, R14E, Sec. 11, NWNW; Sec. 14, NWNE, Covington County, Alabama. I. Reasonably Foreseeable Development A. Geology a. Haynesville Frisco City Sandstone: The first commercial production of hydrocarbons from the Jurassic Haynesville Formation in southwestern Alabama was from the Frisco City field, which currently produces 57.8- degree oil on the API gravity scale. There is 160-acre well spacing from a depth of approximately 12,000 ft. Perforations are in the Frisco City sand interval, in the lower part of the Haynesville Formation. The hydrocarbon trap in the Frisco City field is a combination structural-stratigraphic trap. The Frisco City sand reservoir is located on a faulted anticline. The stratigraphic trap is produced by a permeability barrier near the crest of the structure and termination against a basement high. The lower part of the Haynesville Formation in this area is comprised of (in ascending order) the Buckner Anhydrite Member, the Frisco City sand, and interbedded shale and anhydrite (Mann, et al., 1989) b. Smackover Limestone: The Upper Jurassic Smackover Formation is found in an arcuate belt in the subsurface from south Texas to panhandle Florida. The Smackover is not exposed at the surface, except at an age-equivalent strata outcrop in northeastern Mexico. The Smackover is the most prolific hydrocarbon-producing formation in Alabama (Kopask-Merkel, et al., 1993).
B. Mineral Commodity a. Mineral commodity is oil with associated natural gas.
C. Oil and Gas Occurrence Potential a. The potential for occurrence of hydrocarbon deposits is high with a moderate degree of certainty for Haynesville Frisco City Sandstone and low for the Smackover Limestone.
D. Oil and Gas Development Potential a. The potential for oil and gas development is moderate for Haynesville Frisco City Sandstone and low for the Smackover Limestone. Market conditions directly affect potential for drilling and field development.
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E. Typical Drilling Scenario a. The leasing of this acreage does not guarantee that wells will be drilled through federal minerals. Several drilling scenarios are possible: wells could be developed on federally leased tracts, wells could be developed on private tracts and require federal agreements, or no wells could be drilled. Should development occur it will mostly likely be vertical or deviated drilling. Once the well pad has been constructed, the drilling rig moves onto location. The rig size is dependent on the depth of the target formation and the total measured depth of the well. Depending on target formation and depth, surface casing will be set to protect the USDW (Underground Source of Drinking Water), intermediate casing, and production casing. Surface casing will always be set. Once the drilling rig has finished, a completion rig moves on location. Different completions methods are used depending on formation being produced. The primary and secondary objectives in this case are generally not hydraulically fractured. Matrix acidizing is typically used to stimulate production in these formations. After the well completion is finished and the proper production equipment has been installed, the well will be put into production status.
F. RFD Baseline Scenario Assumptions and Discussion a. Primary Objective horizon is likely Haynesville Frisco City Sandstone with the Smackover Limestone as the secondary objective. Commodity is oil and associated natural gas. b. Federal acreage will be incorporated into a state determined drilling unit. Drilling and production units for the Haynesville Frisco City Sandstone and Smackover Limestone are 160 acres. It is projected that 2 wells will be drilled from 2 pads, with 1 occurring on-lease. Development of the resources underlying the southeastern section of EOI ES3321 Part 1 (1835a) will take place off-lease if within 250 feet of a wetland or the Conecuh River, per the Aquatic Habitat No Surface Occupancy stipulation. In the targeted formations in Alabama, horizontal drilling is unlikely.
G. Surface Disturbance Due to Oil and Gas Activity a. Access Roads: 3.44 acres (5000’ X 30’) b. Well Pads & Pits: 6.42 acres (2 X 400’ X 350’) c. Utility and/or Pipeline R.O.W: 0 – Use access road ROW. d. Total Disturbances: 9.86 acres
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References
IHS Market Energy Products
Mann, S D, Mink, R M, Bearden, B L, and Schneeflock, Jr, R D. Frisco City sand: New Jurassic reservoir in southwest Alabama. United States: N. p., 1989. Web.
Kopaska-Merkel, D. C., D. R. Hall, S. D. Mann, and B. H. Tew, "Reservoir Characterization of the Smackover Formation in Southwest Alabama," Report No. DOE/BC/14425-7, Final report of work performed under Contract No. FG22- 89BC14425, Prepared for the U.S. Department of Energy by the Geological Survey of Alabama, Tuscaloosa, AL, February 1993.
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APPENDIX F. NATIONAL AMBIENT AIR QUALITY STANDARDS Table F.1. National Ambient Air Quality Standards Primary Standards Secondary Standards Pollutant Level Averaging Time Level Averaging Time Carbon 9 ppm 8-hour (1) None None 3 Monoxide (10 mg/m ) Carbon 35 ppm 1-hour (1) None None 3 Monoxide (40 mg/m ) 3 Lead 0.15 µg/m Rolling 3-Month Same as Same as (2) Average Primary Primary 3 Lead 1.5 µg/m Quarterly Average Same as Same as Primary Primary Nitrogen 53 ppb (3) Annual Same as Same as
Dioxide (Arithmetic Average) Primary Primary Nitrogen 100 ppb 1-hour (4) None None
Dioxide Particulate 150 µg/m3 24-hour (5) Same as Same as Matter Primary Primary (PM10) Particulate 15.0 µg/m3 Annual (6) Same as Same as Matter (Arithmetic Average) Primary Primary (PM2.5) Particulate 35 µg/m3 24-hour (7) Same as Same as Matter Primary Primary (PM2.5) (8) Ozone 0.075 ppm 8-hour Same as Same as (2008 std) Primary Primary (9) Ozone 0.08 ppm 8-hour Same as Same as (1997 std) Primary Primary (10) Ozone 0.12 ppm 1-hour Same as Same as Primary Primary Sulfur 0.03 ppm Annual 0.5 ppm 3-hour (1)
Dioxide (Arithmetic Average) Sulfur 0.14 ppm 24-hour (1) 0.5 ppm 3-hour (1)
Dioxide Note: (1) Not to be exceeded more than once per year. (2) Final rule signed October 15, 2008. (3) The official level of the annual NO2 standard is 0.053 ppm, equal to 53 ppb, which is shown here for the purpose of clearer comparison to the 1-hour standard.
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(4) To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1- hour average at each monitor within an area must not exceed 0.100 ppm (effective January 22, 2010). (5) Not to be exceeded more than once per year on average over 3 years. (6) To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from single or multiple community-oriented monitors must not exceed 15.0 µg/m3. (7) To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor within an area must not exceed 35 µg/m3 (effective December 17, 2006). (8) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.075 ppm. (effective May 27, 2008). (9) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm. (b) The 1997 standard—and the implementation rules for that standard—will remain in place for implementation purposes as EPA undertakes rulemaking to address the transition from the 1997 ozone standard to the 2008 ozone standard. (c) EPA is in the process of reconsidering these standards (set in March 2008). (10) EPA revoked the 1-hour ozone standard in all areas, although some areas have continuing obligations under that standard ("anti-backsliding"). (b) The standard is attained when the expected number of days per calendar year with maximum hourly average concentrations above 0.12 ppm is < 1.
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APPENDIX G. USFWS BIRDS OF CONSERVATION CONCERN (BCC) Table G.1. List of BCC found in the Southeastern Coastal Plain Region (EOI ES3321 Part 1 (1835a)). Suitable Habitat Common Name Scientific Name Located on Parcel Red-throated loon Gavia stellata No Black-capped petrel (nb) Pterodroma hasitata No Audubon’s shearwater No Puffinus Iherminieri (nb) American bittern (nb) Botaurus lentiginosus No Least bittern Ixobrychus exilis No Roseate spoonbill (nb) Platalea ajaja No Swallow-tailed kite Elanoides forficatus No Bald eagle (b) Haliaeetus leucocephalus No American kestrel (paulus No Falco sparverius ssp.) Peregrine falcon (b) Falco peregrinus No Coturnicops No Yellow rail (nb) noveboracensis Black rail Laterallus jamaicensis No Limpkin Aramus guarauna No Snowy plover (c) Charadrius alexandrinus No Wilson’s plover Charadrius wilsonia No American oystercatcher Haematopus palliatus No Solitary sandpiper (nb) Tringa solitaria No Upland sandpiper (nb) Bartramia longicauda No Whimbrel (nb) Numenius phaeopus No Long-billed curlew (nb) Limosa haemastica No Marbled godwit (nb) Limosa fedoa No Red knot (rufa ssp.)(a)(nb) Calidris canutus No Semipalmated sandpiper No Calidris pusilla (Eastern)(nb) Buff-breasted sandpiper No Tryngites subruficollis (nb) Short-billed dowitcher No Limnodromus griseus (nb) Least tern (c) Sternula antillarum No Gull-billed tern Gelochelidon nilotica No Sandwich tern Thalasseus sandvicensis No Black skimmer Rhynchops niger No Common ground-dove Columbina passerine Yes Chuck-will’s-widow Caprimulgus carolinensis Yes Whip-poor-will Caprimulgus vociferous Yes
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Suitable Habitat Common Name Scientific Name Located on Parcel Melanerpes Yes Red-headed woodpecker erythrocephalus Loggerhead Shrike Lanius ludovicianus Potential Brown-headed nuthatch Sitta pusilla Yes Bewick’s wren (bewickii Yes Thryomanes bewickii spp.) Sedge wren Cistothorus platensis No Brown-headed nuthatch Sitta pusilla Yes Wood thrush Hylocichla mustelina Yes Blue-winged warbler Vermivora cyanoptera Yes Black-throated green Yes Dendroica virens warbler Prairie warbler Dendroica discolor Yes Cerulean warbler Dendroica cerulean Yes Prothonotary warbler Protonotaria citrea No Swainson’s warbler Limnothlypis swainsonii Yes Kentucky warbler Oporornis formosus Yes Bachman’s sparrow Peucaea aestivalis No Henslow’s sparrow (nb) Ammodramus henslowii No LeConte’s sparrow (nb) Ammodramus leconteii No Nelson’s sharp-tailed No Ammodramus nelson sparrow (nb) Saltmarsh sharp-tailed No Ammodramus caudacutus sparrow (nb) Seaside sparrow (c) Ammodramus maritimus No Painted bunting Passerina ciris Potential Rusty blackbird (nb) Euphagus carolinus No Note: (a) - ESA candidate, (b) - ESA delisted, (c) - non-listed subspecies or population of threatened or endangered species, (nb) - non-breeding in this Bird Conservation Region. Source: U.S. Fish and Wildlife Service. 2008. Birds of Conservation Concern 2008. United States Department of Interior, Fish and Wildlife Service, Division of Migratory Bird Management, Arlington, Virginia. 85 pp. [Online version available at http://www.fws.gov/migratorybirds/]
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APPENDIX H. ACRONYMS AND ABBREVIATIONS
APD Application for Permit to Drill APLIC Avian Power Line Interaction Committee AQI Air Quality Index BCC Birds of Conservation Concern BLM Bureau of Land Management BMP Best Management Practices CEQ Council on Environmental Quality CERCLA Comprehensive Environmental Response Compensation and Liability Act CFR Code of Federal Regulations CH4 Methane CO Carbon Monoxide CO2 Carbon Dioxide COA Condition of Approval CSU Controlled Surface Use °F Fahrenheit ddbh Diameter at breast height DOI (U.S.) Department of the Interior EA Environmental Assessment EIS Environmental Impact Statement EO Executive Order EOI Expression of Interest ESA Endangered Species Act Et al. Latin phrase et alia meaning “and others” Et seq Latin phrase et sequentes meaning “and the following” FLPMA Federal Land Policy and Management Act FONSI Finding of No Significant Impact GHG Greenhouse Gas GIS Geographic Information System H2S Hydrogen Sulfide
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HFC Hydrofluorocarbon HV High-Volume IM Internal Memo MBTA Migratory Bird Treaty Act MDWFP Mississippi Department of Wildlife, Fisheries, and Parks Mgal/d Million gallons per day MLA Mineral Leasing Act MNHP Mississippi Natural Heritage Program MOGB Mississippi Oil and Gas Board MOU Memorandum of Understanding MS Mississippi NAAQS National Ambient Air Quality Standards Nb Non-breeding NEPA National Environmental Policy Act NHPA National Historic Preservation Act N2O Nitrous Oxide NOx Nitrogen Oxides (generic for air pollutants – NO and NO2) NO Nitrogen Oxide NO2 Nitrogen Dioxide NRHP National Register of Historic Places NSO No Surface Occupancy NWR National Wildlife Refuge O3 Ozone Pb Lead PFC Perfluorocarbon PL Public Law PM2.5 Particulate Matter PM10 Particulate Matter PPB Parts per Billion PPM Parts per Million PSD Prevention of Significant Determination RCRA Resource Conservation Recovery Act
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RFDS Reasonably Foreseeable Development Scenario ROW Right of Way SEC Section
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APPENDIX I. SOIL CHARACTERISTICS Table I.1. Summary of soil characteristics within EOI ES3321 Part 1 (1835a) in Section 11 and in Section 14 (Soil Survey Staff, 2020). A summary of soil characteristics for past related action, EOI ES3321 (1835b) and ALES-057845 and ALES-057966, are also included in this table for context. EOI Soil Map Unit Percent Surface Fragile Soil Wind K Factor, Prime Number Name of EOI Texture Soil Index Compactibility Erodibility Whole Farmland rating* Risk rating** Group*** Soil**** EOI Blanton loamy 59.8% Loamy Not Rated Low 2 .15 Not prime ES3321 fine sand, 0 to 5 Fine Sand farmland Part 1 percent slopes (1835a), Section 11 Blanton loamy 4.6% Loamy Not Rated Low 2 .15 Not prime fine sand, 5 to Fine Sand farmland 12 percent slopes Troup loamy 35.6% Loamy Slightly Low 2 .05 Not prime sand, 0 to 5 Sand Fragile farmland percent slopes EOI Bigbee loamy 2.0% Loamy Not Rated Low 2 .05 Not prime ES3321 sand, 0 to 5 Sand farmland Part 1 percent slopes, (1835a), rarely flooded Section 14 Kalmia loamy 3.6% Loamy Not Rated Low 2 .20 All areas are fine sand, 0 to 2 Fine Sand prime farmland percent slopes, rarely flooded
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EOI Soil Map Unit Percent Surface Fragile Soil Wind K Factor, Prime Number Name of EOI Texture Soil Index Compactibility Erodibility Whole Farmland rating* Risk rating** Group*** Soil**** Rains-Bethera 83.9% Loam/ Not Rated Medium 5 .24 Not prime complex, 0 to 2 Sandy farmland percent slopes, Loam frequently flooded Water, >40 acres 10.5% Not Not Not Applicable Not Not Not prime Applicable Applicable Applicable Applicable farmland EOI Blanton loamy 66.8% Loamy Not Rated Low 2 0.15 Not prime ES3321 fine sand, 0 to 5 Fine Sand farmland (1835b) percent slopes Blanton loamy 7.2% Loamy Not Rated Low 2 0.15 Not prime fine sand, 5 to Fine Sand farmland 12 percent slopes Chrysler sandy 8.0% Sandy Not Rated High 3 0.20 All areas are loam, 0 to 2 Loam prime farmland percent slopes, rarely flooded Lynchburg 3.1% Sandy Not Rated Medium 3 0.15 Not prime sandy loam, 0 to Loam farmland 2 percent slopes Troup loamy 13.0% Loamy Slightly Low 2 0.05 Not prime sand, 0 to 5 Sand Fragile farmland percent slopes Water, >40 acres 2.0% Not Not Not Applicable Not Not Not prime Applicable Applicable Applicable Applicable farmland
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EOI Soil Map Unit Percent Surface Fragile Soil Wind K Factor, Prime Number Name of EOI Texture Soil Index Compactibility Erodibility Whole Farmland rating* Risk rating** Group*** Soil**** ALES- Blanton loamy 21.4% Loamy Not Rated Low 2 0.15 Not prime 057845 fine sand, 0 to 5 Fine Sand farmland and percent slopes ALES- 057966 Blanton loamy 16.8% Loamy Not Rated Low 2 0.15 Not prime fine sand, 5 to Fine Sand farmland 12 percent slopes Cowarts-Dothan 9.6% Loamy Slightly Medium 2 0.15 Not prime complex, 5 to 10 Sand/ Fragile farmland percent slopes Sandy Loam Dothan and 27.6% Sandy Moderately Medium 3 0.17 All areas are Malbis sandy Loam Fragile prime farmland loams, 1 to 5 percent slopes Lynchburg 6.6% Sandy Not Rated Medium 3 0.15 Not prime sandy loam, 0 to Loam farmland 2 percent slopes Muckalee, Bibb, 18.1% Sandy Not Rated Medium 3 0.10 Not prime and Osier soils, Loam/ farmland 0 to 2 percent Loam slopes, frequently flooded
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*Soils can be rated based on their susceptibility to degradation in the "Fragile Soil Index" interpretation. Fragile soils are those that are most vulnerable to degradation. In other words, they can be easily degraded—they have a low resistance to degradation processes. They tend to be highly susceptible to erosion and can have a low capacity to recover after degradation has occurred (low resilience). Fragile soils are generally characterized by a low content of organic matter, low aggregate stability, and weak soil structure. They are generally located on sloping ground, have sparse plant cover, and tend to be in arid or semiarid regions. The index can be used for conservation and watershed planning to assist in identifying soils and areas highly vulnerable to degradation.
Soils are placed into interpretive classes based on their index rating, which ranges from 0 to 1. An index rating of 1 is the most fragile, while a rating of zero is the least fragile. Interpretative classes are as follows:
Not Fragile (index rating less than or equal to 0.009). These soils have a very high potential to resist degradation and be highly resilient. They are highly structured with an organic matter content greater than 5.7 percent, are nearly level, are deep or very deep, have greater than 85 percent vegetative cover, and are in a climate that is wet or very wet.
Slightly Fragile (index rating less than 0.009 and less than or equal to 0.209). These soils have a high potential to resist degradation and be resilient. They are: — Poorly structured to weakly structured soils that have an extremely low to moderate content of organic matter, are very deep, have high vegetative cover, occur on nearly level ground, and are in wet or very wet climates; — Highly structured soils that have a very high content of organic matter, are very shallow to moderately deep, have high vegetative cover, occur on nearly level ground, and are in wet or very wet climates; — Highly structured soils that have a very high content of organic matter, are very deep, have low to moderately high vegetative cover, occur on nearly level ground, and are in wet or very wet climates; — Highly structured soils that have a very high content of organic matter, are very deep, have high vegetative cover; are on slopes greater than 3 percent, and are in wet or very wet climates; or — Highly structured soils that have a very high content of organic matter, are very deep, have high vegetative cover; occur on nearly level ground, and in semi-dry to mildly wet climates.
Moderately Fragile (index rating greater than 0.209 and less than or equal to 0.409). These soils have a moderate potential to resist degradation and be moderately resilient. They are: — Highly structured soils that have a very high content of organic matter, are very shallow, have high vegetative cover, occur in nearly level to moderately sloping areas, and are in semi-dry climates; — Poorly structured soils that have an extremely low content of organic matter, are deep, have low vegetative cover, occur in nearly level areas, and are in wet or very wet climates;
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— Poorly structured soils that have an extremely low content of organic matter, occur on gentle to very steep slopes, have high vegetative cover, and are in wet or very wet climates; — Weakly structured soils that have a very low content of organic matter, are deep, occur in nearly level to gently sloping areas, have high vegetative cover, and are in semi-dry climates; or — Weakly structured soils that have a very low content of organic matter, are very shallow to very deep, occur in nearly level to strongly sloping areas, have high vegetative cover, and are in mildly wet climates.
Fragile (index rating greater than 0.409 and less than or equal to 0.609). These soils have a low potential to resist degradation and low resilience. They are: — Well-structured soils that have a low content of organic matter, are shallow to very deep, have moderate to moderately high vegetative cover, occur on steep slopes, and are in dry climates; — Well structured soils that have a low content of organic matter, are shallow to very deep, have a low vegetative cover, occur in nearly level to gently sloping areas, and are in dry climates; — Well structured soils that have a low content of organic matter, are deep, have low vegetative cover, occur on nearly level to very steep slopes, and are in a semidry climate; — Moderately structured soils that have a very low content of organic matter, are deep, have moderately high vegetative cover, occur on moderately steep to very steep slopes, and are in semi-dry climates; or — Weakly structured soils that have a low content of organic matter, occur on moderately steep to very steep slopes, have low vegetative cover, and are in wet or very wet climates.
Very Fragile (index rating greater than 0.609 and less than or equal to 0.809). These soils have a very low potential to resist degradation and very low resilience. They are: — Weakly structured soils that have an extremely low content of organic matter, are deep, have low vegetative cover, occur on nearly level to very steep slopes, and are in dry climates; — Weakly structured soils that have an extremely low content of organic matter, are shallow to very deep, have low vegetative cover, occur on nearly level to very steep slopes, and are in very dry climates; or — Poorly structured soils that have an extremely low content of organic matter, are very shallow, have no vegetative cover, occur on steep slopes, and are in mildly wet to wet climates.
Extremely Fragile (index rating greater than 0.809 and less than or equal to 1.0). These soils can have no potential to resist degradation and no resilience. They are: — Poorly structured soils that have an extremely low content of organic matter, are very shallow, have low vegetative cover, occur on very steep slopes, and are in dry or very dry climates; — Weakly structured soils that have a very low content of organic matter, are nearly level to very deep, have low vegetative cover, occur on very steep slopes, and are in dry climates; or — Very shallow soils on steep slopes.
The interpretive rating is based on soils that occur in the dominant land use for the map unit component and may not represent soils that occur in site-specific land uses.
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**This interpretation is designed to predict the potential for soil compaction from operation of ground-based equipment for forest harvesting and site preparation activities when soils are moist. Soils are rated based on their susceptibility to compaction from the operation of ground-based equipment for planting, harvesting, and site preparation activities. Soil compaction is the process in which soil particles are pressed together more closely than in the original state. Typically, the soil must be moist to be compacted because the mineral grains must slide together.
Interpretative ratings are based on soil properties in the upper 12 inches of the profile. Factors considered are soil texture, soil organic matter content, soil structure, rock fragment content, and the existing bulk density. Each of these properties contributes to a soil’s ability to resist compaction. Organic matter in the soil provides resistance to compaction and the resilience to overcome the effects with time. Soil structure adds strength through discrete aggregates; it is the aggregates that are deformed or destroyed by the forces of compaction, thus strong soil structure lowers the susceptibility to compaction. Similarly, rock fragments in the soil can bridge and provide a framework to resist compaction. Finally, if a soil is already dense, further compaction is more difficult.
The ratings are both verbal and numerical. Rating class terms indicate the soil compaction potential.
Definitions of the ratings: Low - The potential for compaction is insignificant. The soil is able to support standard equipment with minimal compaction. The soil is moisture insensitive, exhibiting only small changes in density with changing moisture content. Medium - The potential for compaction is significant. The growth rate of seedlings may be reduced following compaction. After the initial compaction (i.e., the first equipment pass), the soil is able to support standard equipment with only minimal increases in soil density. The soil is intermediate between moisture insensitive and moisture sensitive. High - The potential for compaction is very significant. The growth rate of seedlings will be reduced following compaction. After initial compaction, the soil is still able to support standard equipment but will continue to compact with each subsequent pass of the equipment. The soil is moisture sensitive, exhibiting large changes in density with changing moisture content.
*** A wind erodibility group (WEG) consists of soils that have similar properties affecting their susceptibility to wind erosion in cultivated areas. The soils assigned to group 1 are the most susceptible to wind erosion, and those assigned to group 8 are the least susceptible.
**** The K Factor is an index which quantifies the relative susceptibility of the soil to sheet and rill erosion. K factor values range from 0.02 for the least erodible soils to 0.64 for the most erodible.
Soil properties affecting K Factor include texture, organic matter content, structure, and saturated hydraulic conductivity. Soils high in clay have low K values because they resist detachment. Coarse textured soils (such as sandy soils) have low K values because of low runoff. Medium textured soils (such as fine sandy loams) have moderate K values because they are moderately
DOI-BLM-Eastern States-0020-2021-0002-EA 86 susceptible to detachment and runoff. Soils having high silt content are the most erodible of all soils as they are easily detached; tend to crust, and produce high rates of runoff.
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APPENDIX J. AIR RESOURCES SUPPLEMENTAL DATA TABLES Purpose for Proposed Action In support of the Proposed Action detailed within Expression of Interest (EOI) ES3321, Part 1 (1835a), this supplementary analysis has been prepared to provide additional air quality and greenhouse gas (GHG) analyses to determine if a more robust National Environmental Protection Act (NEPA) analysis and documentation is required.
Environmental Impacts of the Proposed Action Air pollution is emitted from the following oil and natural gas production activities: • Fossil fuel combustion for construction and operation of oil and natural gas wells and support facilities. This includes vehicles driving to and from production sites, engines that drive drill rigs, natural gas-fired compressors, etc. These produce CO, NO2, PM2.5, PM10, SO2, and VOC and the GHGs carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) in quantities that vary depending on the age, types, and conditions of the equipment as well as the targeted formation, locations of wells with respect to processing facilities and pipelines, and other site-specific factors. • Fugitive emissions of CH4 and VOC escape from oil and natural gas wells, gathering pipelines, valves, connectors, pneumatic controllers, pressure relief devices, and vents, oil and produced water storage tanks, and various types of processing equipment. Well completions and workovers are also a major source of CH4 and VOC emissions. Major producers are required by Title 40 of the Code of Federal Regulations (40 CFR), Part 98, to estimate and report their CH4 emissions to the U.S. EPA. 40 CFR, Part 60, Subpart OOOOa applies to oil and natural gas well drilling and production activities and fugitive CH4 and VOC emissions from associated equipment. These regulations are enforced by the Alabama DEM. • It is expected that drilling will produce marketable quantities of oil and/or natural gas. Most of these products will be combusted to provide energy, releasing CH4, CO, CO2, NO2, N2O, PM2.5, PM10, SO2, and VOC into the atmosphere. Fossil fuel combustion is the largest source of GHG emissions in the U.S. (EPA 2020b).
Since lead is not emitted from oil and natural gas production activities, it is not included in this analysis. Estimates of air pollution emissions from the proposed action are included in Table 1.
Table 1. Estimated Air Pollution Emissions from Proposed Action State Oil & State Air Natural Gas Producible Emissions factor RFDS # Projected Pollutant Total (tons) Wells (ton/well) of Wells Emissions (tons) CO 6,344 6,340 1.001 1 1.00 NO2 3,751 6,340 0.592 1 0.59 PM10 61 6,340 0.010 1 0.01 PM2.5 59 6,340 0.009 1 0.01 SO2 5,547 6,340 0.875 1 0.88
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VOC 9,582 6,340 1.511 1 1.51 The emissions factors in Table 1 were calculated for each air pollutant by dividing the total air pollution emitted for oil and natural gas production in Alabama (EPA 2020b) by the total number of producible wells in 2018 reported to the EIA (EIA 2018). These emissions factors were then multiplied by the RFDS projected number of wells to estimate the air pollution emissions from the proposed action.
GHGs are air pollutants that impact the climate, i.e. the long-term weather patterns for an area. Climate is described statistically (e.g., mean and variability) via surface variables such as temperature, precipitation, and wind over the past 30 years. Climate change refers to any significant change in these surface variables lasting for an extended period. Climate change may result from both natural and human-caused actions. In 2013, the Intergovernmental Panel on Climate Change (IPCC) concluded that “warming of the climate system is unequivocal” and “most of the observed increase in global average temperatures since the mid-20th century is very likely due to the observed increase in (human-caused) GHG concentrations” (IPCC 2013).
GHG emissions are reported in metric tons (MT) of carbon dioxide equivalents (CO2e), in which emissions of each individual GHGs are converted into CO2e by multiplying the GHG by its global warming potential (GWP). The GWP is a ratio of the radiative adsorption of a GHG relative to an equal amount of CO2. For example, CH4 has a GWP of 25, so it is 25 times more effective at absorbing radiation than CO2, and 1 MT of CH4 is equal to 25 MT of CO2e. N2O has a GWP of 298 (EPA 2020b). Since the other GHGs (i.e., fluorinated gases) are not emitted by oil and natural gas production activities, they are not included in this analysis.
GHG emissions were calculated using the 2014 statewide GHG emissions from oil and gas production on the FMO, as reported in the U.S. Geological Survey (USGS) Scientific Investigations Report (SIR): Federal Lands Greenhouse Gas Emissions and Sequestration in the United States – Estimates for 2005-2014 (USGS 2018). The total GHG emissions from the FMO in Alabama were divided by the number of FMO State Producible Wells in 2014, to derive a per well GHG emission factor. This factor was multiplied by the RFDS to estimate the GHG emissions associated with the Proposed Action, as provided in Table 2.
Table 2. Estimated GHG Emissions from Proposed Action GHG Emissions FMO State Producible GHG Factor RFDS # GHG Emissions 2014 (mt CO2e) Wells (2014) (mt CO2e/well) of Wells (mt CO2e) 12,858 30 428.6 1 428.6
Total oil production was 5,883,000 barrels (247,086,000 gallons) and total natural gas production was 139,477,000 thousand cubic feet (mcf) from a total of 6,340 producible wells for Alabama in 2018 (EIA 2018). Thus, the average production from an Alabama well is 927.9 barrels (38,970 gallons) of oil and 22,000 mcf of natural gas.
The average oil and natural gas production amounts were multiplied by air pollutant and GHG emissions factors developed by EPA to determine the emissions from combustion of the oil and natural gas. The calculations for combustion emissions are provided in Tables 3 and 4. Since
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crude oil and natural gas require further refinement and processing and are transported to customers via an extensive national pipeline network, combustion emissions may or may not occur in Alabama.
Total estimated emissions from the combustion of oil and natural gas from the Proposed Action, as listed in Tables 3 and 4, are as follows:
• CO 1.02 tons • NO2 2.17 tons • PM10 0.18 tons • PM2.5 0.18 tons • SO2 0.16 tons • VOC 0.09 tons • CO2e 1,607 mt
Table 3. Estimated Air Pollution Emissions from Oil and Natural Gas Combustion Air Average Oil Emissions Factor RFDS # Projected Combustion Pollutant Production (barrels) (lbs./barrel)* of Wells Emissions (tons) CO 927.9 0.210 1 0.10 NO2 927.9 2.310 1 1.07 PM10 927.9 0.218 1 0.10 PM2.5 927.9 0.218 1 0.10 SO2 927.9 0.330 1 0.15 VOC 927.9 0.067 1 0.03 Air Average Natural Gas Emissions Factor RFDS # Projected Combustion Pollutant Production (mcf) (lbs./mcf)** of Wells Emissions (tons) CO 22,000 0.084 1 0.92 NO2 22,000 0.100 1 1.10 PM10 22,000 0.0076 1 0.08 PM2.5 22,000 0.0076 1 0.08 SO2 22,000 0.0006 1 0.01 VOC 22,000 0.0055 1 0.06 *Emissions factor source: AP-42 Compilation of Air Pollutant Emissions Factors, Chapter 1, Section 3 https://www3.epa.gov/ttn/chief/ap42/ch01/index.html **Emissions factor source: AP-42 Compilation of Air Pollutant Emissions Factors, Chapter 1, Section 4 https://www3.epa.gov/ttn/chief/ap42/ch01/index.html
Table 4. Estimated GHG Emissions from Oil and Natural Gas Combustion Air Average Oil Emissions Factor RFDS # Projected Combustion Pollutant Production (barrels) (mt/barrel)* of Wells Emissions (mt) CO2e 927.9 0.43 1 399 Air Average Natural Gas Emissions Factor RFDS # Projected Combustion Pollutant Production (mcf) (mt/mcf)* of Wells Emissions (mt) CO2e 22,000 0.0549 1 1,208
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*Emissions factor source: EPA GHG Equivalencies Calculator https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator
EPA established the Prevention of Significant Deterioration (PSD) program to ensure that new or modified sources of air pollution do not cause or contribute to a NAAQS violation, allowing Covington County to retain its NAAQS attainment designations. Air pollution from the proposed action are well below the applicability thresholds for PSD for air pollutants, as provided in 40 CFR, Part 52.21(b)(1)(i)(b); estimated emissions are less than 1% of the PSD applicability threshold of 250 tons per year for each air pollutant, (GHGs are not used to determine PSD applicability). Since air pollutant emissions from the proposed action will not cause Covington County to be reclassified as a non-attainment area for any of the NAAQS, a general or transportation conformity analysis is not required.
GHGs increase the radiative adsorption of our atmosphere, warming surface temperatures. From 1890 to 2019, global mean surface temperatures have increased 1.3ºC (2.3ºF), and observations show that the average surface temperature changes are greater in the Northern Hemisphere than elsewhere on the planet. Collected data indicates that northern latitudes (above 23.6° N) have exhibited temperature increases of 1.9ºC (3.2°F) since 1890, with nearly a 1.5°C (2.7°F) increase since 1970. For the conterminous U.S., the rates of change will vary, but overall increases in both temperature and precipitation have been documented and are expected to continue (Goddard Institute for Space Studies 2020).
U.S. EPA has identified the following changes for Alabama due to a warmer climate (EPA 2016):
• Sea level rise and retreating shores; • Increased power of potential tropical storms and hurricanes; • Increased risk of flooding in low lying areas due to increased rainfall and sea level rise; • Droughts can affect the amount of electricity available from hydroelectric dams, such as Alabama Power and the Tennessee Valley Authority; • Change in the composition tree type in forests; and • Decrease in air quality due to the increase in formation of ground-level ozone, a pollutant that causes lung and heart problems and harms plants.
Statewide air pollutant emissions were obtained from the 2017 National Emissions Inventory (EPA 2020c). For GHGs, the GHG emission factor from Table 1 was multiplied by the number of oil and natural gas wells within Alabama in 2018 to estimate the GHG emissions from the proposed action; the statewide GHG emissions calculations for oil and natural gas production are provided in Table 5.
Table 5. Alabama Statewide GHG Emissions from Oil and Natural Gas Production GHG Factor (mt CO2e/well)* # of Wells GHG Emissions (mt CO2e) 428.6 6,340 2,717,324 *From Table 2
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The estimated statewide emissions for Alabama in 2018 from oil and natural gas production are as follows:
• CO 6,344 tons • NO2 3,751 tons • PM10 61 tons • PM2.5 59 tons • SO2 5,547 tons • VOC 9,582 tons • CO2e 2,717,324 mt • BLM SSDO manages oil and natural gas production on FMO in the following states: Alabama, Arkansas, Kentucky, Louisiana, Mississippi, Tennessee, and Virginia. According to the USGS SIR, Tennessee does not have any GHG emissions from oil and/or natural gas production; since no data is available, air pollutant and GHG emissions for Tennessee were not calculated. (EIA 2018). The estimated emissions from all oil and natural gas production activities within the SSDO FMO are calculated in Tables 6 and 7.
Table 6. Estimated Air Pollution Emissions from SSDO FMO Oil and Natural Gas Production State Oil & State Air Natural Gas Producible Emissions factor FMO # Projected Pollutant Total (tons) Wells (ton/well) of Wells Emissions (tons) Alabama CO 6,344 6,340 1.001 29 29.0 NO2 3,751 6,340 0.592 29 17.2 PM10 61 6,340 0.010 29 0.3 PM2.5 59 6,340 0.009 29 0.3 SO2 5,547 6,340 0.875 29 25.4 VOC 9,582 6,340 1.511 29 43.8 Arkansas CO 6,795 11,378 0.597 219 130.7 NO2 7,256 11,378 0.638 219 139.7 PM10 109 11,378 0.010 219 2.2 PM2.5 109 11,378 0.01 219 2.2 SO2 209 11,378 0.018 219 3.9 VOC 8,983 11,378 0.790 219 173 Kentucky CO 18,968 20,013 0.948 159 150.7 NO2 13,048 20,013 0.652 159 103.7 PM10 192 20,013 0.010 159 1.6 PM2.5 192 20,013 0.01 159 1.6 SO2 102 20,013 0.005 159 0.8
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State Oil & State Air Natural Gas Producible Emissions factor FMO # Projected Pollutant Total (tons) Wells (ton/well) of Wells Emissions (tons) VOC 37,697 20,013 1.884 159 299.6 Louisiana CO 28,112 35,644 0.789 473 373.2 NO2 20,889 35,644 0.586 473 277.2 PM10 498 35,644 0.014 473 6.6 PM2.5 494 35,644 0.014 473 6.6 SO2 1,266 35,644 0.036 473 17 VOC 57,958 35,644 1.626 473 769.1 Mississippi CO 4,368 3,276 1.333 128 170.6 NO2 2,107 3,276 0.643 128 82.3 PM10 45 3,276 0.014 128 1.8 PM2.5 45 3,276 0.014 128 1.8 SO2 1,616 3,276 0.493 128 63.1 VOC 10,060 3,276 3.071 128 393.1 Virginia CO 4,950 8,137 0.608 18 10.9 NO2 3,485 8,137 0.428 18 7.7 PM10 75 8,137 0.009 18 0.2 PM2.5 75 8,137 0.009 18 0.2 SO2 69 8,137 0.009 18 0.2 VOC 8,656 8,137 1.064 18 19.2 Total CO 1,026 865 NO2 1,026 628 PM10 1,026 13 PM2.5 1,026 13 SO2 1,026 110 VOC 1,026 1,698
Table 7. Estimated Air Pollution Emissions from SSDO FMO Oil and Natural Gas Production 2014 FMO State FMO State GHGs Producible GHG Factor Producible Wells GHG Emissions State (mt CO2e) Wells (2014) (mt CO2e/well) (2018) (mt CO2e) Alabama 12,858 30 428.6 29 12,429 Arkansas 118,116 223 529.7 219 116,004 Kentucky 30,100 161 187.0 159 29,733 Louisiana 158,210 482 328.2 473 155,239 Mississippi 22,470 128 175.5 128 22,464
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2014 FMO State FMO State GHGs Producible GHG Factor Producible Wells GHG Emissions State (mt CO2e) Wells (2014) (mt CO2e/well) (2018) (mt CO2e) Virginia 8,100 20 405.0 18 7,290 Total 349,854 1,044 1,026 343,159
Preparer Andrew D. Shroads, QEP, Senior Air Quality Specialist, SC&A, Inc.
Literature Cited State Oil and Gas Board of Alabama. 2018. Administrative Code. Accessed May, 2020. https://www.gsa.state.al.us/Scripts/OGB/rules/goldbook.pdf
Goddard Institute for Space Studies. 2020. Analysis Graphs and Plots. Annual Mean Temperature Change for Three Latitude Bands – Northern Extratropics. Accessed February, 2020. https://data.giss.nasa.gov/gistemp/graphs_v4/
Intergovernmental Panel on Climate Control. 2001. Third Assessment Report: Climate Change 2001. http://www.ipcc.ch/publications_and_data/publications_and_data_reports.shtml
Intergovernmental Panel on Climate Control. 2013. Fifth Assessment Report: Climate Change 2013. http://www.ipcc.ch/publications_and_data/publications_and_data_reports.shtml
National Academy of Sciences. 2008. Understanding and Responding to Climate Change: Highlights of National Academies Reports (2008 Edition). Washington, D.C., U.S.A. 28p.
U.S. Energy Information Administration (EIA). 2018. The Distribution of U.S. Oil and Natural Gas Wells by Production Rate, Appendix C. Accessed February, 2020. U.S. Department of Energy, Washington, DC. https://www.eia.gov/
U.S. Environmental Protection Agency (EPA). 1995. AP-42 Compilation of Air Pollutant Emissions Factors, Fifth Edition, Volume I, Chapter 1: External Combustion Sources. Updated 1999. Accessed February, 2020. https://www3.epa.gov/ttn/chief/ap42/ch01/index.html
----- 2016. What Climate Change Means for Alabama. https://19january2017snapshot.epa.gov/sites/production/files/2016- 09/documents/climate-change-al.pdf
----- 2018. 2014 National Emissions Inventory (NEI) Data. Accessed February, 2020. https://www.epa.gov/air-emissions-inventories/2014-national-emissions-inventory-nei- data
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----- 2019. Inventory of U.S. Greenhouse Gas Emissions and Sinks. 1990-2017. https://www.epa.gov/sites/production/files/2019-04/documents/us-ghg-inventory-2019- main-text.pdf
----- 2020. Greenhouse Gas Equivalencies Calculator. Accessed February, 2020. https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator
U.S. Geological Survey (USGS). 2018. Scientific Investigations Report (SIR). Federal Lands Greenhouse Gas Emissions and Sequestration in the United States --- Estimates for 2005- 14. Accessed June 2019.
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