The letters are still being opened, read and initialed by Big Piney District Ranger Greg Clark. A fat folder holds the originals of every letter he’s read and had scanned. However, electronic comments are being shuttled to a Colorado consultant and won’t be printed out.
Looking through the letters, many hand-written, there’s an overall sense of concern, urgency and even anger emanating from those who commented on the proposal by Plains Exploratory and Production (PXP) to gain permission to drill its three exploratory – and as many as 136 – natural gas wells in the Hoback Rim/ Noble Basin project area.
The Bridger-Teton National Forest (BTNF) administers this land on the edge of the coveted Wyoming Range and over a potentially huge gas field. Because it falls in the Big Piney District, Clark’s signature is the only one required to approve or alter the proposal.
The recent “scoping” invited comment as to what the public and agencies feel should be addressed in the new Environmental Impact Statement (EIS) for PXP’s proposal. The comment deadline was Feb. 7.
“They are still coming in every day,” Clark said Monday. “Most of them if not all of them will be exactly the same.”
How many have come in?
“I don’t know,” he said, fatigue evident in his voice. “I read every one of them but I don’t count them.”
How many support PXP’s drilling project?
“Not many,” Clark said. “There’s not many of support.”
In fact, there were only three in the folder on Monday.
“Wyoming has a long tradition of resource development in an environmentally responsible manner, beyond the tourism use of the federal lands,” writes Vic Chevillon of Nevada. “I urge you to expedite the required permits to allow the development.”
Wildlife has value
Everyone knows where Gov. Dave Freudenthal stands – protect the Wyoming Range.
Wyoming Game and Fish Department (G&F) Deputy Director John Emmerich states emphatically that BTNF must follow its own Forest Plan and the Bureau of Land Management’s Pinedale Resource Management Plan (RMP), and undertake detailed analyses of impacts on wildlife populations in the Rim/Noble Basin project area.
“If this is not possible (to adhere to RMP standards for surface-disturbing activities) throughout the life of the field, development of the field should be reconsidered prior to its initial implementation,” says Emmerich.
BTNF also must analyze impacts on “species of great conservation need” and “sensitive” and “threatened” species that include (but aren’t limited to) wolverines, Canada lynx, several bats and owls, merlin and river otter.
“It is very important with the proposal that cumulative analysis be very comprehensive, both in terms of what is already planned for this general area and the projected life of project-impacts that would be likely if this first stage of development were implemented,” Emmerich says.
Sportsmen and outfitters voice opposition to drilling in the Wyoming Range, including the Wyoming and Sublette County Outfitters and Guides Associations.
“We support gas development and are proud that Wyoming is contributing to our Nation’s oil and gas needs,” says WYOGA board member Dustin Child. “We feel that the Hoback Basin and other places in the Wyoming Range should not be developed at this time. … (Drilling) will undermine outfitters, guides and other local businesses that rely on the income of tourists and hunters coming here to enjoy the wildlife, scenery and solitude the Wyoming Range has to offer.”
The Jackson Hole Chamber of Commerce and citizens ask BTNF to consider impacts on tourism focusing on wildlife and public land use (as well as socioeconomic impacts on nearby residents and towns).
Water and air concerns
These two elements are commented upon in nearly every letter, with calls for complete analyses.
Grand Teton National Park Superintendent Mary Gibson Scott expresses concern about “the degradation of visibility within the local an regional area” and calls for a “larger geographic scale/cumulative effects analysis on air quality.”
She also states concern for acid-sensitive lakes, saying “direct, indirect and cumulative impacts to acid-sensitive lakes from nitrogen and sulfur deposition should be included in the analysis.”
Bringing a well into productivity takes about 550 million gallons of water, says William Conley of Bondurant, and “extracting that volume of water from this drought-prone area will only exacerbate problems that exist for homeowners, such as myself, and ranchers.”
Rancher J.J. Healy, based near Daniel, writes that “none of the Forest Plan’s objectives, guidelines or standards support authorizing the massive removal of water this project proposes, nor do they encourage the water quality degradation that will occur from new road construction and pipeline installation.”
The draft EIS should include a complete study to “provide data on aquifer structure, connectivity, recharge areas and water volumes in various aquifer zones” and “thoroughly discuss the risks from potential groundwater contamination,” Healy says.
No new roads (in roadless area)
There are repeated comments about negative effects of new roads in an inventoried BTNF roadless area (such as illegal hunting and increased fire danger). Sublette ranchers who summer cattle in the project area worry that new roads and drilling could affect their permits.
Hoback Stock Association president Kevin Campbell writes “neither a letter of opposition nor endorsement of the project” on behalf of its permittees with the concern that a maintained road between two grazing units “will create a thoroughfare for cattle to traffic back and forth” which isn’t allowed in allotment management.
Steve Robertson, Bondurant rancher and permittee, voices his personal opposition to new roads and says, “It is possible the effects of the proposed development could put some or all of the affected (grazing) permittees out of the cattle business. It should also be noted under such a scenario there is no compensation for losses.”
He recites “an old Indian proverb that said something to the effect, ‘even a frog has the wisdom not to use up all the water in the pond in which he lives.’”
Slow down, suspend or stop
Solutions are plenty, with one – “slow down and look before you leap” – covering most of them.
They range from writing buy-out/trade-out alternatives into the EIS, awaiting the outcome of Sen. John Barrasso’s Wyoming Range protection legislation, authorizing phased development or telling “Plains Exploitation to just screw off.”
State Rep. Keith Gingery advocates (as do many) suspending the EIS process “to ensure that proper baseline analyses are prepared” or extending the draft EIS deadline to later this year.
“The Forest Service is fully empowered to require the highest level of comprehensive study and review,” Healy says. “”It should not be pressured by (PXP) to streamline this draft EIS.”
Signs of pressure
What could happen next would take a crystal ball, with signs in the outside world of mounting agency pressure for quicker-than-slower decisions on forest drilling.
While Sen. Barrasso’s Wyoming Range legislation has people crossing their fingers, there is no guarantee as to its outcome.
“If we do wait it won’t be solely because of that,” Clark said, adding that every decision can be delayed for a further outcome.
“If you wait, you never get anywhere.”
BTNF recently announced its “supplemental analysis” on the fate of 44,720 suspended/leased acres in the Big Piney District to “analyze and disclose new information relevant to oil and gas” on those leases. The draft EIS is expected in May.
Now, Stanley Energy wants to drill 181 wells from 50-acre well pads very close to PXP’s project site. Other energy companies no doubt wait in the wings.
New rule streamlines
On Feb. 9, the agency announced a new rule, in response to the Executive Order to expedite energy production, “which permits it to respond quickly to applications for oil-and-gas exploration on (forest) land already under federal leases.”
It categorically excludes land under lease that has already undergone environmental analysis under National Environmental Policy Act guidelines.
“The additional analysis previously required by a new oil-and-gas exploration and development application took a minimum of six months,” the release says.
Under this new rule an application can be processed “much faster unless there are extraordinary circumstances such as the presence of threatened or endangered species or their designated habitat, wilderness areas, inventoried roadless areas, wetlands and archeological or historic sites.”
“…It allows for streamlining the application process for permits to drill and other energy-related permits in an environmentally sound manner,” according to the Forest Service.
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