Wyoming Governor Relays ‘Significant Concerns’ With Little Mountain Natural Gas Project

CHEYENNE, Wyo. - Pointing to the area's importance to the quality of life of residents in Sweetwater County and all of Wyoming, Gov. Dave Freudenthal expressed significant concerns about a proposal to drill two exploratory natural gas wells south of Rock Springs.

In comments on the scoping of Devon Energy’s Baxter Natural Gas Exploratory Proposal in the Little Mountain area south of Rock Springs, the Governor expressed concerns about the project’s impact on recreation, critical wildlife habitat, sensitive species, existing land management plans and air and water quality.

“That such a remarkable area is so near to Rock Springs and Green River, not to mention Flaming Gorge Reservoir, makes it a uniquely important place to residents of Sweetwater County, as well as to the rest of the state and the region,” Freudenthal said.

Although this initial proposal reflects just two exploratory wells, Freudenthal said “the pressure to expand from two wells seems inevitable.” According to the Wyoming State Geological Survey, the field will likely be characterized by closely spaced wells at 10- or even 5-acre spacing.

The potential impact on the habitat of two sensitive species, the greater sage-grouse and the pygmy rabbit, could have serious implications on future land use decisions, Freudenthal wrote.

“Every action that could potentially affect sage-grouse in this state, including the Baxter Proposal, is going to be viewed under the microscope of the Endangered Species Act. I want to be sure that we do not put our future ability to make land use decisions at risk,” he said.

Since 1990, the area has benefitted from $1.44 million in ecosystem restoration projects funded by both private entities and state and federal agencies, including the BLM. The Wyoming Game and Fish Department has spent at least $351,000, Freudenthal said.

“Since wildfires have burned approximately 80,000 acres in the Little Mountain ecosystem within the last seven years, we are still at a critical moment in terms of preventing invasive plant species such as cheat grass from taking hold and spreading,” he added.

Freudenthal said he does not want the Baxter Project “to trigger the full industrialization of an irreplaceable recreational area and fragile ecosystem.”

The governor’s comments follow.

February 11, 2008

Jeromy Caldwell
Devon Drilling Proposal
Bureau of Land Management
Rock Springs Field Office
280 Highway 191 North
Rock Springs, Wyoming 82901

Dear Jeromy,

Thank you for the opportunity to comment on the scoping of Devon Energy’s Baxter Natural Gas Exploratory Proposal. Because of the wildlife and recreational issues related to the two exploratory wells - one at Section 28, T13N R106W, and the other at Section 4, T14N, R105W - I have significant concerns about the Baxter Proposal and any potential expansion of that proposal.

As Devon states in their project brochure, their aim is to “test the feasibility of natural gas production and determine the extent of recoverable hydrocarbons underlying the company’s leases within the Project Area.” Considering the Baxter shale formation and its similarity to the Vermillion Basin, the pressure to expand from two wells seems inevitable, especially since Devon owns the bulk of the leases in the general area. If these wells are successful, the Wyoming State Geological Survey has advised me that “a gas resource play and associated field(s) will result on the southwestern flank of the Rock Springs Uplift that will be characterized by closely spaced wells at 10- or even 5-acre spacing.” I do not want the Baxter Project to trigger the full industrialization of an irreplaceable recreational area and fragile ecosystem.

If my hesitation about the Baxter Proposal were limited to the possibility of it serving as a beachhead for a large production unit, then perhaps a combination of aggressive stipulations and mitigation measures could partly address my concerns. According to the Wyoming Game and Fish Department, however, even these two proposed wells present serious problems. Game and Fish has already detailed their comments, so rather than revisit them I will highlight and expand on a few striking points:

Recreation and Big-Game Hunting
The Little Mountain area is one of the premiere hunting grounds in Wyoming for trophy bull elk and buck deer. That such a remarkable area is so near to Rock Springs and Green River, not to mention Flaming Gorge Reservoir, makes it a uniquely important place to residents of Sweetwater County, as well as to the rest of the state and the region. As Game and Fish Department has observed, one of the wells in the Baxter Proposal is within delineated crucial winter range for the South Rock Springs mule deer herd, and the other proposed well abuts crucial range for both the South Rock Springs mule deer and South Rock Springs elk herd units.

Existing Investments and Conflicts with the Rock Springs RMP
Private entities and state and federal agencies (including the BLM) have invested approximately $1.44 million in ecosystem restoration projects on Little Mountain since 1990. The Wyoming Game and Fish Department has spent at least $351,000. Since wildfires have burned approximately 80,000 acres in the Little Mountain ecosystem within the last seven years, we are still at a critical moment in terms of preventing invasive plant species such as cheat grass from taking hold and spreading.

It also appears that the Baxter Proposal, according to the Game and Fish Department, is “out of compliance with the habitat resource protections” incorporated in the Rock Springs BLM office’s 1997 RMP. Indeed, it seems “it would be virtually impossible for the BLM to allow practical fluid minerals development (road transportation and pipeline systems) in any of these areas and remain in compliance with the existing RMP.”

Wyoming’s Comprehensive Wildlife Conservation Strategy
The Little Mountain ecosystem (Pine Mountain, the Red Creek Basin, Mellor Mountain, Little Mountain and the Sugarloaf Basin) is home to at least 37 terrestrial species identified in the Wyoming Comprehensive Wildlife Conservation Strategy as “species of greatest conservation need.” One of these species, the greater sage-grouse, is being considered for Endangered Species Act (ESA) listing and another, the pygmy rabbit, has been petitioned for listing.

Our state-wide efforts to preclude listing of the sage-grouse include substantial financial investments and a groundbreaking cooperative agreement with the U.S. Fish and Wildlife Service. Every action that could potentially affect sage-grouse in this state, including the Baxter Proposal, is going to be viewed under the microscope of the Endangered Species Act. I want to be sure that we do not put our future ability to make land use decisions at risk.

To heighten the stakes further, the Little Mountain ecosystem supports aquatic species of greatest conservation need, most notably the Colorado River cutthroat trout, and has been identified as “the number one aquatic habitat priority area for the Green River Region” in the Wyoming Game and Fish Department’s Strategic Habitat Plan.

Water and Air Quality Considerations
The Department of Environmental Quality is submitting separate comments, but I would nevertheless like to underscore a few items related to water and air quality. First, water handling and disposal methods must be accounted for, and possible impacts to surface water quality should be assessed in light of extensive energy development in the general area. Second, a baseline assessment of air quality ought to be established prior to any activity. The likely push to expand from two wells to a larger unit will mean that the U.S. Environmental Protection Agency’s new and more strict ozone standards may come into play.

General Comments
There are additional issues that will have to be accounted for in future documentation relative to any proposed development. These include:

-Invasive weed control. As noted above, recent wildfires have elevated this issue to a level of significant concern.
-The potential for soil erosion.
-Plans for surface reclamation.
-Air quality, including dust mitigation.
-Socioeconomic impacts.
-Availability of water for drilling and completion operations.
-Transportation planning and possible effects on other recreational activities in the area.
-Effects from new infrastructure (liquid gathering lines, pipelines, transmission lines, etc.).
-Energy demands and transmission associated with exploratory and developmental operations.
-Cumulative impacts resulting from the fact that this proposal is in close proximity to several intense energy developments.

Any energy development, whether limited or broad, in the Little Mountain area is going to stir up a perfect storm of wildlife, environmental, recreational, and social issues. The Baxter Proposal has already evoked strong reactions from locals, including blue collar workers, hunters and the Association of Churches. Their opposition reflects Little Mountain’s importance to the quality of life of those who live nearby, and a firm understanding, rooted in personal experience, that these two wells could harbinger large-scale development. It is clear that these two exploratory wells will require an Environmental Impact Statement (EIS), and I urge the BLM to carefully weigh whether the impacts associated with energy activity around Little Mountain would be manageable.

Warm regards,

Dave Freudenthal
Governor

Source: Wyoming Governor

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