SUBLETTE COUNTY – Citizens at the Pinedale public meeting about the Normally Pressured Lance (NPL) draft environmental impact statement (DEIS) last Tuesday provided input on the DEIS as well as the commenting process itself.
The Bureau of Land Management’s (BLM) Pinedale Field Office (PFO) brought together the public, officials and specialists to ask and answer questions.
The BLM undertook its NPL scoping for Encana back in 2011 – the last time public comments were submitted.
Jonah Energy first purchased Linn Energy, and then Encana’s holdings, in and around the NPL project, replacing Encana as the sole operator proposing to drill up to 350 wells per year for 10 years for 3,500 total, from 24 well pads on about 141,000 acres.
The years-long process of the National Environmental Protection Act (NEPA) brought forth the NPL DEIS released on July 7.
With core sage-grouse habitat, smaller technological footprints and the Upper Green River Basin’s nonattainment probation for federal ozone standards, the public and Jonah have a great deal of reading to do with the 1,083-page DEIS, not to mention scoping and other NEPA documents.
The public meeting was more of an open house, with stations of enlarged maps and descriptions of DEIS alternatives, wildlife-use areas and migration routes, and cultural and historical sites.
PFO manager Caleb Hiner and High Desert District regional supervisor Timothy Wakefield mingled to offer answers and explanations. At times, citizens and officials talked across each other’s conversations to listen in on various topics.
The NPL draft EIS comment period is open through Aug. 21, with written and emailed comments being accepted and collated, and then responded to and available for public review afterward at the PFO, according to Hiner.
At the July 25 meeting, though, people came directly to the points of their concerns – whether pronghorn, greater sage grouse, air, water or historic landmarks – with various specialists posted around the conference room by the large maps.
Rock Springs Field Office assistant manager Doug Linn and Mark Snyder explained at the “wildlife” map how a marked pronghorn migration route cutting north and south through the NPL project’s western half is not officially designated.
Officially designating a big-game migration route, such as the Red Desert to Hoback mule deer corridor, is a Wyoming Game and Fish process that could bring more guidelines, they said.
As the map stands now, “it gives us the potential for ways to look at mitigation,” said Linn. The maps on display, he added, are “from the 40,000-foot level” based on the NPL project area.
Specific mitigations for impacts to pronghorn as well as sage-grouse, air, water and cultural resources, to name a few, will be designed as Jonah Energy files its applications for permits to drill (APDs).
The DEIS is more of an overview comparing the alternatives’ impacts, they said. Besides the proposed action, there is a “no action” alternative, Alternative A (considered the “wildlife alternative”) and the PFO’s “preferred” alternative (considered the “broader resource protection” alternative).
“The draft EIS doesn’t have site-specific actions,” Linn said. “You’re looking at a really big level here.”
APDs will bring analyses for site-specific impacts and mitigations that follow BLM field offices’ resource management plans (RMP), he said.
At another station, BLM historical specialist Scott Stadler talked about potential impacts to the Sublette Cutoff of the Lander Trail. He said no one even knew it was there until someone commented in a past NEPA process and now it is a real consideration for the NPL. The nearby North Sublette Meadow Spring for settlers’ livestock was a very important stopover marking the cutoff, he said.
“First, we would try to hide (a facility) so it can’t be seen from the trail,” he said. “And any (offsite) mitigation would have to be tied to the national historic trail somehow.”
He added, “Prehistoric artifacts are scattered throughout the NPL but we don’t have the data yet. As individual projects are applied for, we will survey more.”
“Forty-five days is a pretty short time to review a document of eight volumes that took almost eight years,” said citizen Dave Hohl, asking Hiner and Wakefield if the comment period might be extended.
Hohl had concerns about recharge rates for the project’s water sources.
Before sitting down to write out comments, Carmel Kail told Hiner and Wakefield, “I’m here to complain as much as to comment.”
She said she sent in comments about noise and sage grouse for the Jonah Infill environmental assessment and was “disappointed” with “two-liners” after spending a lot of time to write comments. She asked why commenters couldn’t get “real thought-out responses.”
Hiner and project manager Liz Dailey both said comments first go to a contractor who sorts them into categories, passes some back to her and writes comment responses.
“Is there a way to change that culture?” Kail asked. “This project can be a lot better but I don’t really feel anyone’s trying very hard.”
Hiner said comments are read quickly and people submitting them “have an instantaneous need for feedback.”
Wakefield and Hiner said comments should express new ideas or information – “something new and different we haven’t seen before.”
Form letters, whether 10 or 100, are counted as one comment and comments of support or protest are not counted at all, they said.
Numerous concerns were voiced about NPL emissions and maintaining good air and water quality.
Hiner also explained that the DEIS is one NEPA document that follows the record of decision to allow as many as 350 wells a year – but for the BLM, the “General Conformity” standard dictates the actual number of wells drilled per year based on the operator’s actual emissions. For the NPL, that is currently 160 wells per year, which can go up or down depending on Jonah Energy’s emissions, he said.
“(Jonah’s current) technology is such that 160 wells can be drilled,” Hiner said, with advanced emissions controls allowing more wells annually. “As technology increases and emissions decrease per well, more wells can be drilled (under General Conformity) and at the point of 350, they merge with the record of decision.”
Many questions arose about greater sage-grouse habitat, which now defines placement and pace of NPL development.
Jonah’s Paul Ulrich said the NPL proposed action would protect resources, adding he hopes for a final decision on the DEIS “well prior to the end of the year” so the company can start development and exploration in early 2018.
Then APDs will be filed, which, contrary to some offices, is a timely process with the PFO, he said. “The PFO is fantastic; they are very efficient and process them thoroughly and quickly.”
He was still evaluating the lengthy DEIS’ alternatives and analyses.
“I believe we can provide input for a sustainable, workable final decision,” Ulrich said. “Our hope is at the end of the day, (the BLM) decision more closely reflects our proposed action with appropriate measures for wildlife, water, air. Clearly we take this very seriously and we need to make sure all resources are protected.”
He added, “We are getting very positive feedback this evening. People are excited about it. I truly believe that people understand Jonah Energy is a leader in the industry for protecting the environment.”
The state’s greater sage-grouse core-area strategy provides high-level protections for that portion of the NPL and Jonah made “a strong and public commitment to follow science of winter protections and will continue to do so.”
As for noise impacts, “We’re reviewing the noise sections of the DEIS and clearly expect if we have significant noise impacts to sage-grouse … there are a lot of little things we can do – site placements, sneaking (a facility) behind a hill with other mitigations…”
The NPL draft EIS and other NEPA documents are at http://tinyurl.com/hloulms or the Pinedale Field Office.
Submit comments through Aug. 21 for the NPL DEIS to [email protected] or turn them in at the Pinedale Field Office, 1625 W. Pine, Pinedale, WY.