Can you spell ‘mitigation’?

BLM proposes 3rd-quarter lease sale

Wyoming Bureau

of Land Management’s third-quarter

lease sale notice of May 16 proposes putting

212 oil and gas parcels of 322,234.35 acres

on the auction block in September.

In western and southwestern Wyoming,

many of these parcels – if developed – could

have a range of impacts on national historic

trails, archeological and cultural sites, crucial

big-game winter ranges and nesting sites for

greater sage-grouse, raptors, burrowing owls,

bald eagles and ferruginous hawks.

The BLM’s environmental assessment’s

comment period opened with its release

and runs through June 15. To see associated

documents and maps or to comment, go to

In Sublette County and adjoining Lincoln

County, the Pinedale Field Office’s resource

management plan and Pinedale Anticline

2008 Record of Decision can impose some

restrictions on almost every parcel proposed

for sale in the Upper Green River Basin.

In the EA, the BLM makes the argument

that these stipulations themselves might do

more long-term harm than good to the resources

they are designed to protect.

“While multiple, overlapping timing

stipulations can provide benefit to wildlife

resources by preventing sustained disruptive

activity, the Pinedale RMP also notes,

‘(W)hen areas with greater sage-grouse nesting

restrictions overlap areas with big game

crucial winter range restrictions, the oil and

gas operator would potentially be restricted

to a 3-and-a-half-month construction, drilling

and well completion season.’

“This short drilling and development window

in areas such as the Pinedale Anticline

has led to accelerated operations, which result

in congested traffic on primary access

roads and a potential overload on local service

and emergency resources. It also causes

a yearly bust-and-boom cycle for the local

communities as crews move in during the

open development window, then leave when

the seasonal restrictions are invoked. This situation

can be exacerbated when lease development

is further reduced by other seasonal

restrictions, including those for raptors.”

By the numbers

Of all 212 parcels, 62 contain mule deer

crucial winter range including six in Rock

Springs, 14 in Kemmerer and 11 in Pinedale

resources areas.

In this area, six parcels in Rock Springs,

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Can you spell ‘mitigation’?

BLM proposes 3rd-quarter lease sale

By Joy Ufford, [email protected]

13 in Kemmerer and six in Pinedale are in

mule deer crucial winter range – and also

within greater sage-grouse priority habitat

management area. “Deferring the offering

of one parcel (Lease 177) at the request of

(Wyoming Game and Fish) will benefit big

game in the short-term.”

“During initial coordination with (Game

and Fish) and during preparation of this

EA, the BLM and Game and Fish discussed

proposed lease sale parcels located in areas

with the Wyoming-designated Red Desert

to Hoback Mule Deer Corridor. This initial

coordination resulted in the deferral of parcel

177. Parcels 173, 174, 176, and 178-180

are located within the Red Desert to Hoback


As for sage-grouse, “The lands within

the PHMA parcels are assumed to provide

nesting, wintering and/or breeding habitat

for greater sage-grouse as described in the

EA. ... All potential impacts are expected to

be within the range analyzed in the RMPs

as revised or amended, which was found to

be acceptable by the U.S. Fish and Wildlife

Service. All parcels will be offered with the

stipulations specified within the underlying


Also, 41 southwestern parcels contain

pronghorn antelope crucial winter range, including

22 in Kemmerer and 10 in Pinedale.

Both pronghorn and mule deer critical winter

ranges are found in three Rock Springs parcels,

12 in Kemmerer and all 10 in Pinedale.

An additional 40 parcels in the larger High

Desert District, whole or in part intersect elk

crucial winter range.

Sublette County lease parcels 173 through

184 are described as “crucial” winter range

and either on a designated big-game corridor

route or one being studied by Game and


Although the Sublette mule deer herd’s

2018 decline hit the Pinedale Anticline’s

low threshold to require additional wildlife

mitigation, this EA does not contain further

plans, even with studies showing mule deer

avoid development and abandon traditional

ranges, it says.

“Recent data suggests that … mule deer

are not habituating even as large parts of the

field are being reclaimed. To date, the Pinedale

Field Office has not recommended any

changes through the adaptive management

process for this project. Additional study and

coordination with Game and Fish and local

partners are continuing.”

However, these parcels fall less than 90

percent within the designated corridor and

Game and Fish did not request their deferral

but recommended that a “special lease

notice” be attached to the parcels; BLM has

since attached special lease notices to them,

the EA says.

“Thirty-seven parcels are located within

the Wyoming Range herd unit. Of these,

parcels 185, 186, 188-191 and 197-200 are

entirely or partially within the Moxa Arch

project area. If development is proposed, activity

levels or impacts to surface resources

including big game are not expected to increase


The EA also notes, “Parcels 182 and 183

are about 5 miles east of the Normally-Pressured

Lance Natural Gas Project EIS area.”

History matters

With historic travelers also blazing trails

and roads through Sublette, Lincoln and

Sweetwater counties, regional parcels on

offer could impact the California-Oregon-

Mormon and Pony Express trails as well as

the Sublette Trail and the Opal Wagon Road.

These leases contain visual and distance

stipulations for the trails and associated landmarks

such as Emigrant Springs, Johnston

Scout Rock, gravesites and trail markers.

The EA says, “Anticipated impacts to

these resources are mitigated through controlled

surface use stipulations that restrict

or prohibit surface use or disturbance where

required by the underlying RMP, unless a

satisfactory plan to mitigate the potential

impacts are developed. Otherwise impacts

to setting are mitigated through (different

processes) that “will determine affects (sic)

to setting where it contributes to a national

historic trail, and could require additional


“Parcels 208 and 213, located in the Pinedale

Field Office, have multiple National

Register eligible sites and a wagon road.

This parcel was previously subjected to sitespecific

tribal consultation under National

Historic Preservation Act. This consultation

resulted in no new mitigation identified by

the consulting Native American tribes.

“Other parcels in the Pinedale Field Office

have one National Register site and numerous

cultural sites. All parcels are subject

to (No Surface Occupancy) and controlled

surface use to protect these resources. ... Parcels

190, 191, 194-198, 201, 203, 205, 217-

221 and 223 would have a CSU, a NSO or

both applied to protect the Oregon/California

National Historic Trail and/or gravesites

and landmarks.”

Low-impact sale

“The BLM cannot reasonably determine

at the leasing stage whether or not a nominated

parcel will actually be leased, or if

leased, whether or not the lease would be

explored or developed or at what intensity

development may occur,” the EA states.

Also, “As of April 2018, less than 50 percent

of all leases issued are explored.”

Wyoming BLM will not determine actual

consequences or mitigation until an

application is submitted for development.

Parcels offered are subject to stipulations

and lease notices and the BLM might “require

additional mitigation such as seasonal

restrictions, directional drilling and liquids

gathering systems at the development stage

to further reduce impacts associated with oil

and gas development.”


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