BLM

Wyoming State Office – Rawlins Field Office

ENVIRONMENTAL ASSESSMENT for the 

Hanna Draw Coalbed Natural Gas 

Pilot Project 

Carbon County, Wyoming 

January 2007
MISSION STATEMENT 

It is the mission of the Bureau of Land Management to sustain the health, diversity, 

and productivity of the public lands for the use and enjoyment of present and 

future generations. 

BLM/WY/PL-07/009+1310 

WY-030-07-EA-083 
United States Department of the Interior 

BUREAU OF LAND MANAGEMENT

Rawlins Field Office 

P.O. Box 2407 (1300 North Third Street)

Rawlins, Wyoming 82301-2407

January 29, 2007 

In Reply Refer To:

1790 (030) 

Re: Environmental Assessment for the 

 Hanna Draw CBNG Pilot Project 

Dear Reader: 

This is to inform you of the availability of the Hanna Draw Coalbed Natural Gas (CBNG) Pilot 

Project (Project) Environmental Assessment (EA) at the Wyoming Bureau of Land 

Management’s (BLM) website: 

www.wy.blm.gov/rfo/nepa.htm 

In order to satisfy the requirements of the National Environmental Policy Act, this EA was 

prepared to analyze impacts associated with the construction, drilling, production, maintenance, 

and reclamation of coalbed natural gas wells north of Hanna, Wyoming. 

It is expected that this EA can be viewed at our website beginning January 29, 2007. This will 

begin the 30-day public review/comment period for the document. We will review all comments 

and will address substantive comments in the Decision Record. A substantive comment is one 

that would alter conclusions drawn from the analysis based on: 1) new information, 2) why or 

how the analysis is flawed, 3) evidence of flawed assumptions, 4) evidence of error in data 

presented, and 5) requests for clarification that bear on conclusions presented in the analysis. 

Your comments should be as specific as possible. Comments on the alternatives presented and 

on the adequacy of the impact analysis will be accepted by the BLM until February 28, 2007. 

Comments may be submitted via regular mail to: 

Travis Bargsten, Project Manager

Bureau of Land Management 

Rawlins Field Office 

P.0. Box 2407 

Rawlins, Wyoming 82301 
2 

or may be submitted electronically at the address shown below (please refer to the Hanna Draw 

CBNG Pilot Project): 

e-mail: rawlins_wymail@blm.gov 

Please note that comments, including names, e-mail addresses, and street addresses of 

respondents, will be available for public review and disclosure at the above address during 

regular business hours (7:45 a.m. to 4:30 p.m.) Monday through Friday, except holidays. 

Individual respondents may request confidentiality. If you wish to withhold your name, e-mail 

address, or street address from public review or from disclosure under the Freedom of 

Information Act, you must state this plainly at the beginning of your written comment. Such 

requests will be honored to the extent allowed by law. All submissions from organizations or 

businesses, and from individuals identifying themselves as representatives or officials of 

organizations or businesses, will be made available for public inspection in their entirety. 

The EA may also be reviewed at the following locations: 

Bureau of Land Management Bureau of Land Management 

Wyoming State Office Rawlins Field Office 

5353 Yellowstone Road 1300 N. Third Street 

Cheyenne, Wyoming 82009 Rawlins, Wyoming 82301 

If you require additional information regarding this project, please contact Travis Bargsten, 

Project Manger, at the Rawlins address or phone (307) 328-4387. 

Sincerely, 

 Field Manager 

Enclosure 
TABLE OF CONTENTS 

CHAPTER 1...............................................................................................................................1-1

Purpose and Need ...................................................................................................................1-1

1.1 Introduction......................................................................................................... 1-1 

1.2 Purpose and Need ............................................................................................ 1-1 

1.2.1 Purpose of and Need for the Proposed Development ................ 1-1 

1.2.2 Conformance with Great Divide Resource Area RMP ................ 1-2 

1.2.3 Relationship to Other Plans and Documents................................ 1-2 

CHAPTER 2...............................................................................................................................2-1

Proposed Action and Alternatives .........................................................................................2-1

2.1 Proposed Action ................................................................................................ 2-1 

2.1.1 Plan of Development ........................................................................ 2-5 

2.1.2 Preconstruction Planning and Site Layout .................................... 2-5 

2.1.3 Project Construction.......................................................................... 2-6 

2.1.3.1 Well Pad Design and Construction.................................... 2-6 

2.1.3.2 Access Road Construction ................................................. 2-6 

2.1.4 Drilling and Completion Operations................................................ 2-9 

2.1.5 Production Operations...................................................................... 2-9 

2.1.5.1 Well Production Facilities.................................................... 2-9 

2.1.5.2 Power Generation .............................................................. 2-10 

2.1.5.3 Gas and Water Pipelines .................................................. 2-10 

2.1.5.4 Central Compressor Facility ............................................. 2-14 

2.1.6 Workforce Requirements and Traffic Estimates......................... 2-14 

2.1.7 Water Supply and Disposal ........................................................... 2-18 

2.1.7.1 Water for Drilling................................................................. 2-18 

2.1.7.2 Disposal of Produced Water............................................. 2-19 

2.1.8 Applicant-Committed Resource Protection Measures .............. 2-20 

2.1.8.1 Paleontological Resources ............................................... 2-20 

2.1.8.2 Floodplains and Wetlands ................................................ 2-21 

2.1.8.3 Vegetation and Reclamation ............................................ 2-21 

2.1.8.4 Surface Reclamation Plans .............................................. 2-21 

2.1.8.5 Terrestrial Wildlife .............................................................. 2-21 

2.1.8.6 Special Status Terrestrial Wildlife.................................... 2-22 

2.1.8.7 Cultural Resources............................................................. 2-22 

2.1.8.8 Socioeconomics ................................................................. 2-23 

2.2 No Action Alternative ...................................................................................... 2-23 

2.3 Alternatives Considered but Not Analyzed in Detail.................................. 2-23 

2.3.1 Developing Existing Williams Wells.............................................. 2-23 

2.3.2 Underground Disposal of Production Water ............................... 2-23 

2.3.3 Use of Horizontal Production Wells.............................................. 2-24 

2.3.4 Discharge of Produced Water to Medicine Bow River .............. 2-24 

CHAPTER 3...............................................................................................................................3-1

Affected Environment..............................................................................................................3-1

3.1 Air Quality ........................................................................................................... 3-1 

3.2 Geology and Geological Hazards................................................................... 3-2 

3.2.1 Geology............................................................................................... 3-2 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment i 
TABLE OF CONTENTS

3.2.2 Mineral/Oil and Energy Resources................................................. 3-6 

3.2.3 Geologic Hazards.............................................................................. 3-6 

3.3 Paleontological Resources .............................................................................. 3-8 

3.4 Soils................................................................................................................... 3-10 

3.4.1 General Soil Characteristics .......................................................... 3-10 

3.4.2 Soil Characteristics by Landform .................................................. 3-10 

3.4.3 Prime Farmlands ............................................................................. 3-14 

3.5 Water Resources............................................................................................. 3-14 

3.5.1 Surface Water .................................................................................. 3-14 

3.5.1.1 Hydrology............................................................................. 3-14 

3.5.1.2 Existing Water Quality ....................................................... 3-15 

3.5.2 Groundwater .................................................................................... 3-18 

3.6 Floodplains ....................................................................................................... 3-19 

3.6.1 Functioning Conditions/PFC Evaluation of Hanna Draw, St. 

Mary’s Creek, and the Medicine Bow River ................................ 3-20 

3.7 Vegetation ........................................................................................................ 3-21 

3.7.1 Dominant Vegetation Communities and Land Types ................ 3-22 

3.7.1.1 Wyoming Sagebrush/Mixed Grass Community ............ 3-22 

3.7.1.2 Low Shrub/Mixed Grass Community .............................. 3-22 

3.7.1.3 Mixed Shrub Community................................................... 3-24 

3.7.1.4 Greasewood and Basin Big Sagebrush Drainages ...... 3-24 

3.7.1.5 Mixed Grass-like/Grass Meadow Community ............... 3-25 

3.7.1.6 Reclaimed Grass Community........................................... 3-25 

3.7.1.7 Rockoutcrop/Broken Land/Miscellaneous Land 

Types.................................................................................... 3-25 

3.7.2 Upland Vegetation Health Evaluation .......................................... 3-26 

3.7.3 Non-native Invasive (Weed) Species........................................... 3-26 

3.7.4 Wetlands and Riparian Areas........................................................ 3-28 

3.8 Terrestrial Wildlife ........................................................................................... 3-29 

3.8.1 Habitat............................................................................................... 3-29 

3.8.2 Big Game Species .......................................................................... 3-30 

3.8.3 Upland Game Birds, Waterfowl, and Other Waterbirds ............ 3-31 

3.8.4 Raptors.............................................................................................. 3-37 

3.8.5 Other Birds, Mammals, Amphibians, and Reptiles .................... 3-38 

3.9 Aquatic Biology................................................................................................ 3-38 

3.10 Special Status Species................................................................................... 3-40 

3.10.1 Plants ................................................................................................ 3-40 

3.10.1.1 Threatened and Endangered Species ............................ 3-40 

3.10.1.2 Sensitive Plant Species..................................................... 3-40 

3.10.1.3 Plant Species of Special Concern ................................... 3-42 

3.10.2 Terrestrial Animals .......................................................................... 3-42 

3.10.3 Aquatic Resources .......................................................................... 3-53 

3.10.3.1 Amphibians.......................................................................... 3-53 

3.11 Cultural Resources.......................................................................................... 3-53 

3.11.1 Overview of Prehistory and History .............................................. 3-53 

ii Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
TABLE OF CONTENTS 

3.11.2 Class I File Search Results............................................................ 3-54 

3.12 Range Resources and Other Land Uses .................................................... 3-55 

3.12.1 Range Resources............................................................................ 3-55 

3.12.2 Other Land Uses ............................................................................. 3-56 

3.13 Noise ................................................................................................................. 3-56 

3.14 Recreation ........................................................................................................ 3-57 

3.15 Visual Resources ............................................................................................ 3-58 

3.16 Socioeconomics .............................................................................................. 3-58 

3.16.1 Population and Demography......................................................... 3-59 

3.16.2 Economic Conditions ...................................................................... 3-59 

3.16.2.1 Employment and Income. ................................................. 3-59 

3.16.2.2 Local and State Government Revenues ........................ 3-61 

3.16.3 Housing............................................................................................. 3-62 

3.16.4 Emergency Services....................................................................... 3-62 

3.16.5 Attitudes and Opinions ................................................................... 3-63 

3.16.6 Environmental Justice .................................................................... 3-63 

3.17 Transportation and Access............................................................................ 3-64 

3.18 Health and Safety............................................................................................ 3-65 

CHAPTER 4...............................................................................................................................4-1

Environmental Consequences ...............................................................................................4-1

4.1 Air Quality ........................................................................................................... 4-1 

4.1.1 Proposed Action ................................................................................ 4-1 

4.1.2 No Action Alternative ........................................................................ 4-2 

4.1.3 Mitigation ............................................................................................ 4-3 

4.2 Geology and Geologic Hazards...................................................................... 4-3 

4.2.1 Proposed Action ................................................................................ 4-3 

4.2.2 No Action Alternative ........................................................................ 4-4 

4.2.3 Mitigation ............................................................................................ 4-4 

4.3 Paleontological Resources .............................................................................. 4-4 

4.3.1 The Proposed Action ........................................................................ 4-4 

4.3.2 The No Action Alternative ................................................................ 4-4 

4.3.3 Mitigation ............................................................................................ 4-5 

4.4 Soils..................................................................................................................... 4-5 

4.4.1 Proposed Action ................................................................................ 4-5 

4.4.1.1 Impacts to Soil Chemical, Physical, and Microbial 

Characteristics ....................................................................................... 4-5 

4.4.1.2 Impacts to Sensitive Soils................................................... 4-7 

4.4.2 No Action Alternative ........................................................................ 4-8 

4.4.3 Mitigation ............................................................................................ 4-8 

4.5 Water Resources............................................................................................... 4-8 

4.5.1 Surface Water .................................................................................... 4-8 

4.5.1.1 Proposed Action ................................................................... 4-8 

4.5.1.2 No Action Alternative ......................................................... 4-11 

4.5.1.3 Mitigation ............................................................................. 4-12 

4.5.2 Groundwater .................................................................................... 4-12 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment iii 
TABLE OF CONTENTS

4.5.2.1 Proposed Action ................................................................. 4-12 

4.5.2.2 No Action Alternative ......................................................... 4-13 

4.5.2.3 Mitigation ............................................................................. 4-13 

4.6 Floodplains ....................................................................................................... 4-13 

4.6.1 Proposed Action .............................................................................. 4-13 

4.6.2 No Action Alternative ...................................................................... 4-14 

4.6.3 Mitigation .......................................................................................... 4-14 

4.7 Vegetation, Wetlands, and Reclamation ..................................................... 4-14 

4.7.1 Proposed Action .............................................................................. 4-14 

4.7.2 No Action Alternative ...................................................................... 4-17 

4.7.3 Mitigation .......................................................................................... 4-18 

4.8 Terrestrial Wildlife ........................................................................................... 4-18 

4.8.1 Proposed Action .............................................................................. 4-18 

4.8.2 No Action Alternative ...................................................................... 4-30 

4.8.3 Mitigation .......................................................................................... 4-30 

4.9 Aquatic Resources.......................................................................................... 4-31 

4.9.1 Proposed Action .............................................................................. 4-31 

4.9.2 No Action Alternative ...................................................................... 4-31 

4.9.3 Mitigation .......................................................................................... 4-31 

4.10 Special Status Species................................................................................... 4-31 

4.10.1 Plants ................................................................................................ 4-32 

4.10.1.1 Proposed Action ................................................................. 4-32 

4.10.1.2 No Action Alternative ......................................................... 4-32 

4.10.1.3 Mitigation ............................................................................. 4-32 

4.10.2 Animals ............................................................................................. 4-32 

4.10.2.1 Surface Water Analysis..................................................... 4-32 

4.10.2.2 Species Analyses............................................................... 4-33 

4.10.2.3 Mitigation ............................................................................. 4-39 

4.10.3 Aquatic Species............................................................................... 4-39 

4.10.3.1 Proposed Action ................................................................. 4-39 

4.10.3.2 No Action Alternative ......................................................... 4-39 

4.10.3.3 Mitigation ............................................................................. 4-39 

4.11 Cultural Resources.......................................................................................... 4-40 

4.11.1 Proposed Action .............................................................................. 4-40 

4.11.2 No Action Alternative ...................................................................... 4-41 

4.11.3 Mitigation .......................................................................................... 4-41 

4.12 Range Resources and Other Land Uses .................................................... 4-41 

4.12.1 Proposed Action .............................................................................. 4-41 

4.12.1.1 Range Resources .............................................................. 4-41 

4.12.1.2 Other Land Uses ................................................................ 4-41 

4.12.2 No Action Alternative ...................................................................... 4-42 

4.12.2.1 Range Resources .............................................................. 4-42 

4.12.2.2 Other Land Uses ................................................................ 4-42 

4.12.3 Mitigation .......................................................................................... 4-42 

4.12.3.1 Range Resources .............................................................. 4-42 

iv Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
TABLE OF CONTENTS 

4.12.3.2 Other Land Uses ................................................................ 4-42 

4.13 Noise ................................................................................................................. 4-42 

4.13.1 Proposed Action .............................................................................. 4-42 

4.13.2 No Action Alternative ...................................................................... 4-43 

4.13.3 Mitigation .......................................................................................... 4-43 

4.14 Recreation ........................................................................................................ 4-43 

4.14.1 Proposed Action .............................................................................. 4-43 

4.14.2 No Action Alternative ...................................................................... 4-44 

4.14.3 Mitigation .......................................................................................... 4-44 

4.15 Visual Resources ............................................................................................ 4-44 

4.15.1 Proposed Action .............................................................................. 4-44 

4.15.2 No Action Alternative ...................................................................... 4-45 

4.15.3 Mitigation .......................................................................................... 4-45 

4.16 Socioeconomics .............................................................................................. 4-45 

4.16.1 Proposed Action .............................................................................. 4-45 

4.16.2 Population and Demography......................................................... 4-45 

4.16.3 Economic Conditions ...................................................................... 4-46 

4.16.3.1 Employment and Income .................................................. 4-46 

4.16.3.2 Effects on Other Economic Activities in the Vicinity 

of the Proposed Action ...................................................... 4-47 

4.16.3.3 Effects on Government Revenues .................................. 4-47 

4.16.4 Housing............................................................................................. 4-49 

4.16.5 Emergency Services....................................................................... 4-49 

4.16.6 Attitudes and Opinions ................................................................... 4-49 

4.16.7 Environmental Justice .................................................................... 4-50 

4.16.8 No Action Alternative ...................................................................... 4-50 

4.16.9 Mitigation .......................................................................................... 4-50 

4.17 Transportation and Access............................................................................ 4-50 

4.17.1 Proposed Action .............................................................................. 4-50 

4.17.2 No Action Alternative ...................................................................... 4-51 

4.17.3 Mitigation .......................................................................................... 4-51 

4.18 Health & Safety................................................................................................ 4-51 

4.18.1 Proposed Action .............................................................................. 4-51 

4.18.2 No Action Alternative ...................................................................... 4-52 

4.18.3 Mitigation .......................................................................................... 4-52 

4.19 Cumulative Impacts Assessment ................................................................. 4-52 

4.19.1 Past, Present, and Reasonably Foreseeable Future Actions .. 4-54 

4.19.2 Air Quality ......................................................................................... 4-55 

4.19.3 Geology and Geological Hazards................................................. 4-56 

4.19.4 Paleontological Resources ............................................................ 4-56 

4.19.5 Soils................................................................................................... 4-56 

4.19.6 Water Resources............................................................................. 4-56 

4.19.6.1 Surface Water..................................................................... 4-56 

4.19.6.2 Groundwater ....................................................................... 4-58 

4.19.7 Floodplains ....................................................................................... 4-58 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment v 
TABLE OF CONTENTS

4.19.8 Vegetation, Wetlands, and Reclamation ..................................... 4-58 

4.19.9 Terrestrial Wildlife............................................................................ 4-59 

4.19.10 Aquatic Biology ................................................................................ 4-62 

4.19.11 Special Status Species................................................................... 4-62 

4.19.11.1 Special Status Plant Species ....................................... 4-62 

4.19.11.2 Special Status Animal Species .................................... 4-62 

4.19.11.3 Special Status Aquatic Species ................................... 4-65 

4.19.12 Cultural Resources.......................................................................... 4-65 

4.19.13 Range Resources and other Land Uses ..................................... 4-65 

4.19.13.1 Range Resources .......................................................... 4-65 

4.19.13.2 Other Land Uses ............................................................ 4-65 

4.19.14 Noise ................................................................................................. 4-65 

4.19.15 Recreation ........................................................................................ 4-65 

4.19.16 Visual Resources ............................................................................ 4-66 

4.19.17 Socioeconomics .............................................................................. 4-66 

4.19.18 Transportation and Access ............................................................ 4-66 

4.19.19 Health and Safety............................................................................ 4-67 

CHAPTER 5...............................................................................................................................5-1

Consultation and Coordination ..............................................................................................5-1

5.1 Public Participation............................................................................................ 5-1 

5.2 Consultation and Coordination........................................................................ 5-2 

5.3 List of Preparers ................................................................................................ 5-2 

CHAPTER 6...............................................................................................................................6-1

References................................................................................................................................6-1

vi Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
LIST OF TABLES 

Table 2-1 Disturbance Areas ..............................................................................................2-2 

Table 2-2 Traffic Estimates...............................................................................................2-18 

Table 3-1 Regional Air Pollutant Background Concentrations and State and Federal 

Ambient Air Quality Standards............................................................................3-3 

Table 3-2 Summary of Geologic Formations in the Pilot Project Area................................3-4 

Table 3-3 Selected Soil Baseline Characteristics of Dominant Soil Map Units.................3-11 

Table 3-4 Hanna Draw Baseline Water Quality ................................................................3-17 

Table 3-5 Metals in Produced Water Samples .................................................................3-18 

Table 3-6 Isotopic Analysis of Hanna Formation Coal Seam Groundwater......................3-19 

Table 3-7 Designated or Prohibited Noxious Weeds Occurring or Potentially Occurring 

In the Project Area............................................................................................3-27 

Table 3-8 Special Status Plant Species............................................................................3-41 

Table 3-9 Special Status Animal Species Examined for the Hanna Draw Pilot Project....3-43 

Table 3-10 Previously Recorded Site Types and Eligibility Status .....................................3-55 

Table 3-11 Carbon County and Wyoming Population Trends ............................................3-59 

Table 3-12 Carbon County and Wyoming Employment by Industry1

 2003.........................3-60 

Table 3-13 2004 Annual Average Daily Traffic Counts.......................................................3-61 

Table 4-1 Vegetation Map Unit Impact Acreages and Reclamation Potentials ................4-16 

Table 4-2 Known Raptor Nests Located within Applicable Buffer Areas .................4-29 

Table 4-3 Estimated Total Property Tax Revenues from the Proposed Action ................4-48 

Table 4-4 Cumulative Effects Analysis Domains ..............................................................4-53 

Table 4-5 Hydrologic Units Associated with Pilot Project Area.........................................4-54 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment vii 
LIST OF FIGURES

Figure 1-1 Project Location Map..........................................................................................1-3 

Figure 2-1 Map of Proposed Hanna Draw Pilot Project.......................................................2-3 

Figure 2-2 Detailed Map of Proposed Hanna Draw Drilling Area ........................................2-4 

Figure 2-3 Typical Drill Site Layout......................................................................................2-7 

Figure 2-4 Typical Profile of New Road Construction..........................................................2-8 

Figure 2-5 Typical Well Bore .............................................................................................2-11 

Figure 2-6 Typical Well Site...............................................................................................2-12

Figure 2-7 Diagram of Typical Water Transfer Facility ......................................................2-15 

Figure 2-8 Typical Pipeline Construction ...........................................................................2-16 

Figure 2-9 Diagram of Typical Compressor Facility...........................................................2-17 

Figure 3-1 Bedrock Geology Hanna Draw Pilot Project.......................................................3-7 

Figure 3-2 Hydrologic Features of the Pilot Project Area...................................................3-16 

Figure 3-3 Vegetation of the Hanna Draw Pilot Project .....................................................3-23 

Figure 3-4 Pronghorn Seasonal Ranges ...........................................................................3-32 

Figure 3-5 Pronghorn and Mule Deer Seasonal Ranges in Proposed Drilling Area..........3-33 

Figure 3-6 Deer Seasonal Ranges ....................................................................................3-34 

Figure 3-7 Elk and Moose Distribution...............................................................................3-35 

Figure 3-8 Waterfowl and Water Birds...............................................................................3-36 

Figure 3-9 Known Raptor Nests ........................................................................................3-39 

Figure 3-10 Special Status Species Occurrences ...............................................................3-48 

Figure 3-11 Prairie Dog Colonies and Historic Black-footed Ferret Observations...............3-49 

Figure 3-12 Greater Sage-Grouse Lek Sites .......................................................................3-52 

Figure 4-1 Pronghorn Crucial Winter Range with 0.5-Mile Displacement Buffer...............4-23 

Figure 4-2 Raptor Nesting with Construction and Operational Buffers..............................4-28 

Figure 4-3 Cumulative Impact Assessment Areas Surface Water, Floodplains, and

Vegetation ........................................................................................................4-57 

viii Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
LIST OF APPENDICES 

Appendix A Master Surface Use Plan 

Appendix B Master Drilling Plan 

Appendix C List of Permitted Wells 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment ix 
LIST OF ACRONYMS AND ABBREVIATIONS

AADT Annual Average Daily Traffic 

ANC acid neutralizing capacity 

APC Anadarko Petroleum Corporation 

APCD Air Pollution Control Division 

APD Application for Permit to Drill 

APLIC Avian Power Line Interaction Committee 

AQRV Air Quality Related Values 

ARS Air Resource Specialists 

BA Biological Assessment 

BACT best available control technology 

bbl/day barrels per day 

BGEPA Bald and Golden Eagle Protection Act 

BLM Bureau of Land Management 

CBNG coalbed natural gas 

CCF central compressor facility 

CDPHE Colorado Department of Public Health and Environment 

CEQ Council on Environmental Quality 

cfs cubic feet per second 

CIAA cumulative impact assessment area 

CO carbon monoxide 

COA Conditions of Approval 

CR county road 

dBA decibels on the A-weighted scale 

EA environmental assessment 

EPA Environmental Protection Agency 

ESA Endangered Species Act 

FEMA Federal Emergency Management Agency 

FO Field Office 

FY fiscal year 

g/bhp-hr grams per brake horsepower hour 

gpm gallon per minute 

H3 tritium 

HAP hazardous air pollutant 

HDPE high-density polyethelene 

hp horse power 

HU Hydrologic Unit 

HUD Department of Housing and Urban Development 

I-80 Interstate 80 

IDT BLM interdisciplinary team 

IC internal combustion 

km kilometer 

kV kilovolt 

LOP life-of-project 

MBTA Migratory Bird Treaty Act 

MCF thousand cubic feet 

MDP Master Drilling Plan 

uS/cm micro siemens per centimeter 

μg/l micrograms per liter 

μg/m3 micrograms per cubic meter 

x Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
LIST OF ACRONYMS AND ABBREVIATIONS 

mg/l milligrams per liter 

MMCF million cubic feet 

MMCFD million cubic feet per day 

mph miles per hour 

MSUP Master Surface Use Plan 

NAAQS national ambient air quality standards 

NAICS North American Industry Classification System 

NEPA National Environmental Policy Act 

NHPA National Historic Preservation Act 

NOx nitrogen oxides 

NO2 nitrogen dioxide 

NRCS Natural Resources Conservation Service 

NRHP National Register of Historic Places 

NRWQC National Recommended Water Quality Criteria 

O3 ozone 

OHV off-highway vehicle 

OSHA Occupational Safety and Health Administration 

PA Physician’s Assistant 

Pb lead 

PFC Proper Functioning Condition 

PFWC Probable Fossil Yield Classification 

Pilot Project Hanna Draw Coalbed Natural Gas Pilot Project 

PM10 particulate matter less than 10 microns in diameter 

POD Plan of Development 

PSD Prevention of Significant Deterioration 

psi pounds per square inch 

RAM Ranching, Agricultural, Mining 

RCSC Rosebud Sales Coal Company 

RMP Resource Management Plan 

ROD Record of Decision 

ROS Recreation Opportunity Spectrum 

ROW right-of-way 

ROWs rights-of-way 

RV recreational vehicle 

SEO State Engineers Office 

SH State Highway 

SHPO State Historic Preservation Office 

SO2 sulfur dioxide 

TDS total dissolved solids 

TEG tri-ethylene glycol 

tpy tons per year 

TSP total suspended particulates 

USDOT U.S. Department of Transportation 

USEIA U.S. Energy Information Administration 

USFS U.S. Forest Service 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

VOCs volatile organic compounds 

VRM Visual Resource Management 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment xi 
LIST OF ACRONYMS AND ABBREVIATIONS

VSMOW Vienna Standard Mean Ocean Water 

WAQSR Wyoming Air Quality Standards and Regulations 

WES Western Economic Services, LLC 

WDAI Wyoming Department of Administration and Information 

WDEQ Wyoming Department of Environmental Quality 

WDEQ-AQD Wyoming Department of Environmental Quality, Air Quality Division 

WDOE Wyoming Department of Employment 

WDOR Wyoming Department of Revenue 

WES Western Economic Services 

WET Whole Effluent Toxicity 

WGFD Wyoming Game and Fish Department 

WIC Wyoming Interstate Company 

WMP Water Management Plan 

WNDDB Wyoming Natural Diversity Database 

WOGCC Wyoming Oil and Gas Conservation Commission 

WOS Wildlife Observation System 

WRCC Western Regional Climate Center 

WSA Wilderness Study Area 

WYDOT Wyoming Department of Transportation 

WyCRO Wyoming Cultural Records Office 

WYPDES Wyoming Pollutant Discharge Elimination System 

xii Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 1 

PURPOSE AND NEED 
CHAPTER 1: PURPOSE AND NEED 

CHAPTER 1 

PURPOSE AND NEED 

1.1 INTRODUCTION 

Anadarko Petroleum Corporation (APC) proposes to explore and potentially develop coalbed 

natural gas (CBNG) wells near Hanna Draw, which is located within the administrative 

boundaries of the Rawlins Field Office (FO) of the Bureau of Land Management (BLM). The 

proposed well sites for the Hanna Draw Coalbed Natural Gas Pilot Project (Pilot Project) are 

located in Township 23 North, Range 81 West, Section 2, in Carbon County, Wyoming. The 

project area is located approximately 10 miles northeast of Hanna, Wyoming (Figure 1-1) on 

BLM-administered federal surface and mineral estate. Access to the project area is provided by 

Carbon County Road 291 from Hanna. 

The Pilot Project would entail the construction, drilling, completion, and production of up to a 

maximum of 15 CBNG wells in the project area and the construction, utilization, and 

maintenance of appurtenant access roads, pipelines, and production facilities. The Pilot Project 

would be production tested for a period of 12 to 18 months. If economically viable, the total lifeof-project (LOP) is estimated at 10 to 20 years. 

If the Pilot Project wells produce marketable quantities of gas, APC would complete construction 

of a CBNG interconnect pipeline. If this Pilot Project demonstrates CBNG production in the 

project area is economically feasible, then additional development of this resource may be 

proposed. Any additional development would require further environmental analysis under the 

National Environmental Policy Act (NEPA). 

APC drilled one test well in the Pilot Project area (Hanna Draw Federal 2-2), along with 

construction of an access road and water disposal pipeline. NEPA analysis for the test well and 

associated road and pipeline was completed by BLM (2005a). The purpose of the test well is to 

provide data that will be used to refine the Pilot Project. The well also will provide produced 

water for additional testing, particularly Whole Effluent Toxicity (WET) tests. 

1.2 PURPOSE AND NEED 

1.2.1 Purpose of and Need for the Proposed Development 

Exploration and development of federal mineral resources by private entities is an integral part 

of the BLM's national energy policy. BLM is authorized to lease the federal lands for oil and gas 

development under authority of the Mineral Leasing Act of 1920, as amended; the Mining and 

Minerals Policy Act of 1970; the Federal Land Policy and Management Act of 1976; the National 

Materials and Minerals Policy, Research and Development Act of 1980; and the Federal 

Onshore Oil and Gas Leasing Reform Act of 1987. 

The purpose of the Proposed Action is to determine whether, given current technology, the 

coalbeds in the project area can be economically developed. If it is determined that such 

resources were suitable for commercial extraction, additional oil and gas resources would be 

evaluated and developed. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 1-1 
CHAPTER 1: PURPOSE AND NEED 

1.2.2 Conformance with Great Divide Resource Area RMP 

The BLM's Great Divide Resource Management Plan (RMP) and Record of Decision (ROD) 

(BLM 1987, 1988, 1990) directs the management of BLM-administered lands within the project 

area. The objective for management of oil and gas resources as stated in the RMP is to provide 

for leasing, exploration, and development of oil and gas while protecting other resource values. 

The ROD found that public lands in the resource area are suitable for oil and gas leasing and 

development, subject to certain stipulations. The BLM has determined that impacts from CBNG 

exploration and development are similar in scope to those for oil and gas development and that 

the RMP provides for exploration and testing to determine the viability of CBNG development. 

1.2.3 Relationship to Other Plans and Documents 

The proposed project is in conformance with the State of Wyoming Land Use Plan (Wyoming 

State Land Use Commission 1979) and the Carbon County Land Use Plan (Pederson Planning 

Consultants 1997, 1998) and would comply with relevant federal, state, and local laws and 

regulations. The development of this project would not affect the achievement of the Wyoming 

Standards for Healthy Rangelands, produced in August 1977 and updated in May 2003 (BLM 

2003a). 

1-2 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 

CHAPTER 2 

PROPOSED ACTION AND ALTERNATIVES 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

CHAPTER 2 

PROPOSED ACTION AND ALTERNATIVES 

Two alternatives are currently proposed for the Hanna Draw Environmental Assessment (EA). 

The Proposed Action would encompass up to 15 CBNG exploration wells and associated 

facilities. The No Action Alternative would result in denial of the Proposed Action. Under the No 

Action Alternative, no pilot testing of CBNG production would occur, as described for the 

Proposed Action. Other project alternatives that were considered but eliminated from detailed 

analysis are discussed further in Section 2.3. 

2.1 PROPOSED ACTION 

APC is proposing to construct and operate a pilot CBNG project in Carbon County, Wyoming, 

approximately 10 miles northeast of Hanna (Figures 2-1 and 2-2). The Proposed Action would 

involve the development of up to 15 wells and associated facilities on federal lands and the 

construction and operation of a CBNG interconnect pipeline. The project’s Master Surface Use 

Plan (MSUP) and Master Drilling Plan (MDP) are presented in Appendix A and B, respectively. 

Therefore, this EA analyzes the maximum potential surface disturbance from drilling up to15 

CBNG producing well sites, associated roads and facilities, and an interconnect pipeline. 

Table 2-1 provides a summary of surface disturbance areas for the project. 

The BLM has received all 15 Applications for Permit to Drill (APDs) for the project; however, the 

rights-of-way (ROWs) for the interconnect pipeline and power line have not yet been submitted 

by APC. This EA, then, considers the site-specific impacts from the Proposed Action, but is 

limited in assessing the impacts associated with the interconnect pipeline and power line. If 

impacts not analyzed in this EA would be necessary (such as access road construction) for 

installation and use of the interconnect pipeline and power line, these will be identified upon the 

BLM’s receipt of the ROWs, and additional NEPA analysis would be completed, as necessary, 

prior to authorization. 

Project area access is from the town of Hanna along Carbon County Road 291 (i.e., Hanna 

Draw Road). The exploration project would consist of drilling, casing, completing, and 

producing up to 15 wells on public lands administered by the BLM. All wells would be located to 

minimize potential environmental impacts, where feasible. 

Ancillary facilities would include access roads, buried utility lines, buried gas and water 

gathering lines, an above ground electric power distribution line, associated substation, central 

compressor facility (CCF), and a CBNG interconnect pipeline. A previous action was authorized 

(Hanna Draw Federal 2-2) that resulted in the construction of a pipeline from Section 2 to the 

existing reservoir in Section 13. An additional pipeline is being considered under this Proposed 

Action to construct and operate a return pipeline from this existing reservoir back to Section 2. 

Production water would be discharged to an existing reservoir located in Section 13, in 

accordance with an existing Wyoming Pollutant Discharge Elimination System (WYPDES) 

permit approved by the Wyoming Department of Environmental Quality (WDEQ). The expected 

volume of produced water proposed for discharge would be no more than 40,000 barrels per 

day (bbl/day), or approximately 2.6 cubic feet per second (cfs). Produced water quality would be 

monitored in accordance with state and federal regulations. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 2-1 
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CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

Table 2-1 Disturbance Areas 

Short-term Project Disturbance1 (acres) Long-term Proj

Length/ 

Feature Dimensions BLM Private State Total BLM Priva

New Roads 3 2.11 Miles 11.5 11.5 7.7 Drill Pads 4 200 ft. x 300 ft. 21.0 21.0 11.0 Facility Area 700 ft. x 700 ft. 11.1 11.1 11.Return Pipeline5 2.46 Miles 3.0 6.0 9.0 0.0 0.0 Interconnect Pipeline6 26.5 Miles 150.3 142.5 13.1 305.9 0.0 0.0 Gathering Pipelines5 4.6 Miles 9.2 3.7 12.9 0.0 0.0 Power Line 7 7.6 Miles 13.5 10.5 3.7 27.7 <.1 <0.Total Areas 208.5 173.8 16.8 399.1 18.7 11.1 Short-term Disturbance: Maximum initial project disturbance prior to interim reclamation. 2 Long-term Disturbance: Project disturbance after interim reclamation; LOP disturbance. 

3 Road disturbance width = 60-foot (short-term, including gathering lines constructed along new roads); road disturbance width = 

4 15 drill pads; half of drill pad assumed to be reclaimed in the interim.

 5 Return Pipeline and Gathering Pipeline (where constructed along existing roads) short-term disturbance width = 30 feet. 

6 Short-term Interconnect Pipeline disturbance width = 100 feet. 

7 Power line short-term disturbance width = 30 feet. 

2-2 Hanna Draw Coalbed Natural Gas Pilot Project Environm


CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

One existing road provides the primary access to the proposed drilling area. Field development 

of 15 CBNG wells would require the construction/reconstruction of a maximum of 5 miles of 

access roads with an adjacent electric distribution line and produced gas/water gathering lines 

(i.e., facilities corridors). An estimated 4 miles of new road would be constructed on lands 

administered by the BLM and 1 mile of road/facilities corridors would be built on private lands. 

Each well would require gas and water gathering lines for transportation to the CCF and an 

electric distribution line for its power source. Natural gas gathering lines (made of up to 2- to 

12-inch-diameter, high-density polyethylene [HDPE]) from exploration wells would be connected 

into the CCF for gas metering and subsequent venting or flaring. Water would be metered and 

discharged via a pipeline. Gas and water lines would be installed adjacent to and overlapping 

with the access road ROWs, wherever possible. Electric power would be brought into the field 

on overhead lines. Within the field, power lines would be buried directly adjacent to access road 

ROWs. 

It would require an estimated 7 to 10 days to drill, log, and case each well utilizing a 

conventional rotary drilling rig and associated equipment. It would require an additional 

2 to 5 days to run a bond log, perforate, and set a pump with a completion rig. Road 

construction would occur prior to well drilling and testing. 

The LOP for the proposed Hanna Draw Pilot Project would be approximately 10 to 20 years. 

Each well would be production tested for a period of 12 to 18 months. Production testing would 

evaluate the feasibility of CBNG production from the Pilot Project. Based upon this analysis, 

APC would determine whether full-field development would be economically viable. If the Pilot 

Project production wells produce marketable quantities of gas, APC could deliver the gas via an 

interconnect pipeline throughout a productive life of approximately 10 to 20 years. In the event 

APC would pursue additional CBNG drilling and/or alternate water disposal methods, additional 

consideration under NEPA and associated regulations would be required. 

2.1.1 Plan of Development 

APC would follow the procedures outlined below for activities proposed on BLM-administered 

lands or minerals within the project area. Project development also must be reviewed and 

approved, as required, by other associated agencies. 

2.1.2 Preconstruction Planning and Site Layout 

Considering CBNG production requirements, the locations of proposed project facilities have 

been sited to avoid or minimize, to the degree possible, disturbances to sensitive resources. 

APC has submitted federal APDs and ROW applications along with the preliminary MSUP 

(Appendix A), MDP (Appendix B), associated Water Management Plan (WMP), and a project 

map to the Rawlins FO depicting the specific location of the proposed activities. These mapped 

activities would encompass individual drill sites, pipeline corridors, power line ROW, access 

roads, and other facilities. The applications include site-specific plans describing the proposed 

development (surface use plans with construction details for roads and drill pads, drilling plans 

with casing/cementing program, a water management plan, and site-specific reclamation plans. 

Approval of planned operations would be obtained in accordance with the applicable regulations 

and Onshore Oil and Gas Order No.1 (Approval of Operations on Onshore Federal and Indian 

Oil and Gas Leases). Stormwater discharges during construction would be managed in 

accordance with a stormwater permit issued by WDEQ. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 2-5 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

The following discussion of general construction techniques would apply to the Hanna Draw 

Pilot Project. More detailed plans can be reviewed in Appendices A and B. These construction 

techniques would apply to drill sites, pipelines, power line, and access roads within the project 

area. 

2.1.3 Project Construction 

2.1.3.1 Well Pad Design and Construction 

A graded well pad would be constructed at each drill location using cut and fill construction 

techniques. Figure 2-3 shows the layout for a typical drill site. Each well pad would extend 

approximately 200 feet x 300 feet, covering an estimated 1.4 acres, not including stockpiles and 

the cut and fill slopes. 

A temporary reserve pit about 75 feet wide x 95 feet long x 8 feet deep would be excavated at 

each drill location. These reserve pits would be reclaimed after well completion operations end. 

Topsoil would be removed and stockpiled before the pit is excavated. APC estimates the 

reserve pit would be open for 6 to 12 months to allow fluids to evaporate. During this time, the 

pit would be fenced on all sides with three-strand, barbed wire fencing to prevent access from 

livestock. 

2.1.3.2 Access Road Construction 

The primary access road to the project area would be County Road 291 (Hanna Draw Road). 

Access is provided by Jefferson Road on the north end of Hanna, Wyoming. Jefferson Road 

becomes Hanna Draw Road about 1 mile north of Hanna. Hanna Draw Road is an existing 

road that is graded and graveled. Access to drill locations from the existing network of roads 

would be provided by new and upgraded crowned, ditched, and surfaced roads. The access 

road would be upgraded from the point where it crosses into T24N, R81W, S35 to the southern 

edge of the project area in T23N, R81W, S2. 

APC proposes to construct new access roads to the well locations in accordance with BLM 

standards (Manual 9113), applicable regulations, and private landowner direction for access 

(see MSUP in Appendix A). Figure 2-4 illustrates a typical profile for new road construction with 

adjacent gas and water gathering lines buried in a single trench along the access road ROW. 

Roads associated with the proposed interconnect pipeline would be temporary and would be 

described in detail under the ROW application submitted to the BLM for approval prior to 

construction and use. No new access roads are being considered under this EA, since the 

ROW has not yet been submitted, and APC has not identified if roads would be necessary for 

the construction and operation of the pipeline. Although disturbance and associated impacts 

from construction within the pipeline ROW are considered in this EA, the construction of new 

access roads is not, and any use required for pipeline construction outside of the ROW and not 

considered by the BLM to be “casual use” would require consideration by the BLM and would 

likely require additional consideration under NEPA. 

APC would close and reclaim roads when they are no longer required for production operations, 

unless otherwise directed by the BLM or the affected surface owner. 

2-6 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 


CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

The proposed facilities have been staked by APC and inspected by an interdisciplinary team 

(IDT) from the BLM to verify consistency with the Rawlins FO’s Great Divide RMP, best 

management practices, and stipulations contained in the oil and gas leases. This pre-field 

planning and BLM onsite inspections, prior to the final facility siting and any surface disturbance, 

aided in identifying sensitive areas, modifying site locations, if applicable, and minimizing 

potential environmental effects. 

Culverts would be installed on ephemeral channel crossings, as described in the MSUP (see 

Appendix A). Rip-rap would be added at the outlet of each culvert to minimize erosion. Topsoil 

would be conserved before channel crossing construction occurs. Additional culverts would be 

placed as the need arises or as directed by the BLM’s Authorized Officer (see Appendix A). 

2.1.4 Drilling and Completion Operations 

A conventional drilling rig would be used to drill the CBNG wells. Additional equipment and 

materials needed for drilling operations would be trucked to the drill location. The well control 

system would be designed to meet the conditions likely to be encountered and would conform to 

BLM and State of Wyoming requirements. Figure 2-5 depicts a typical well bore diagram for a 

vertical well drilling operation. Detailed drilling plans are included in Appendix B. 

A mobile completion rig similar to the drill rig would be transported to the well site and used to 

complete each well. Completion operations are expected to average 2 to 5 days per well. In 

accordance with the applicable permits, natural gas may be vented or flared. Formation water 

may be temporarily contained in the reserve pit during drilling and well completion activities. 

2.1.5 Production Operations 

APC would operate all wells, pipelines, and associated ancillary production facilities in a safe 

manner, as set forth in standard industry operating guidelines and procedures. Routine 

maintenance of producing wells would be necessary to maximize performance and detect 

potential difficulties with production operations. Each well location would be visited 

approximately every other day to ensure that operations are proceeding in an efficient and safe 

manner. The visits would include checking separators, gauges, valves, fittings, tanks, 

generators, and pumps. The equipment onsite also would be routinely maintained, as 

necessary. Additionally, all roads and well locations would be regularly inspected and 

maintained to minimize erosion and assure safe operating conditions. 

2.1.5.1 Well Production Facilities 

Producing wells would be equipped with the appropriate wellhead facilities and would be shut in 

until pipelines and other production facilities are constructed. A weatherproof covering would be 

installed over the wellhead facilities. A downhole pump would be used to produce water from 

the cased and perforated pay intervals. Natural gas and produced water would be collected and 

transported from the wellhead via buried pipelines. Gas and water would be measured as 

specified in the MSUP (Appendix A). 

The long-term surface disturbance at the location of each producing well would encompass 

approximately 0.7 acre (half of short-term disturbance), including cut and fill slopes. Typically, 

only the production facilities at the well site would be fenced or otherwise removed from existing 

uses. A loop road or a small, graveled pad area would provide a safe turnaround area for 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 2-9 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

vehicles. The perimeter of the pad area would be fenced if adjacent cut and fill slopes represent 

a safety hazard for vehicles. A typical gas production well site is shown in Figure 2-6. 

2.1.5.2 Power Generation 

Electricity to power pumps to initiate and maintain production, would be obtained from an 

electric distribution line constructed for the Pilot Project or from natural gas or propane-fired 

generators, based on cost comparisons. APC may construct an overhead electric distribution 

line from T23N, R81W, S33 to the CCF in T24N, R81W, S35. A small substation also would be 

constructed within the CCF to step-down the line voltage to a usable level. From the substation, 

an underground distribution system would provide power to wells and associated facilities. 

Utility lines would be installed directly adjacent to access road ROWs to minimize surface 

disturbance. Optionally, internal combustion (IC) engines fired by either natural gas or propane 

would be used to run generators in order to provide power to the project. For a temporary 

generator (operating less than 6 months), a Chapter 6, Section 2 waiver authorizing operation 

for a best available control technology (BACT) compliant generator would be obtained. If the 

unit operates longer than 6 months, a Chapter 6, Section 2 permit would be obtained prior to 

installing such unit. All utility lines within the test field would be buried. Anticipated noise levels 

associated with these generators, if warranted, are expected to approach 61 decibels, Aweighted (dBA), each at 50 feet. 

2.1.5.3 Gas and Water Pipelines 

Construction and installation of gathering lines for gas and water would occur at the same time 

as access road construction or immediately after drilling has been completed. Construction and 

installation of the proposed CBNG interconnect pipeline to the Wyoming Interstate Company 

(WIC) 36-inch block valve would occur after project viability has been determined. All produced 

water used to test the integrity of the gas interconnect pipeline (142,800 gallons) would be 

disposed of in accordance with an approved WYPDES permit. 

Three types of buried pipelines would be constructed as part of the proposed Hanna Draw Pilot 

Project: 

1. A gas-gathering pipeline system (low pressure) would be constructed from the wellheads 

to the CCF. This system would use HDPE pipe, starting with 4-inch-diameter pipe at the 

wellhead, graduating up to 10- to 20-inch-diameter pipe at the inlet to the CCF. 

2. Produced water-gathering pipeline systems (low pressure) would be constructed from 

the wellheads to the centralized facilities and from the centralized facilities to the 

reservoir outfall. This network of water lines would use 4- to 12-inch-diameter pipe 

made of HDPE. 

3. A CBNG interconnect pipeline (high pressure) would be constructed from the CCF to an 

existing transmission pipeline. The pipe would be constructed of 8- to 12-inch-diameter 

steel. 

2-10 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 


CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

The ROWs for the gathering systems would follow access roads. Trenches would be excavated 

to install the flow lines and electrical lines and then backfilled. Gas-gathering and produced 

water-gathering pipelines would be laid together in the same trench when practical. Trenches 

excavated for well gathering lines and electrical lines would result in temporary construction 

corridors 30 feet wide, which would be reclaimed as soon as practical after construction is 

completed. An additional area, estimated to be 10 feet wide, would be used to transport 

machinery, personnel, and equipment along the corridor to install flow lines and electrical lines, 

wherever the gathering system would not follow an access road. This corridor would be used to 

allow working room for the machinery, personnel, and equipment during the installation process. 

Gathering line segments in the project area would total about 5 miles, with 4 miles located on 

BLM-administered lands and 1 mile located on private land. An additional 12-inch HDPE water 

transfer line may be required and, if needed, would be installed adjacent to the existing road. 

Up to four water transfer pumping stations may be used during production operations to transfer 

produced water from the gas wells to the water handling facilities. The transfer pumping 

stations would be needed in areas where differences in elevation would require supplemental 

pumping to transfer the produced water. If transfer pumping stations were required, they would 

be placed within existing footprints of project-related facilities, and no additional short-term 

surface disturbance would occur. Each pumping station would contain up to two 17,000-gallon 

water tanks, an inlet separation vessel, and a small centrifugal water pump. A small pump shed 

would be constructed to enclose the pump. Each pumping station would consist of a pad of 

approximately 125 feet x 125 feet that would disturb an estimated 0.4 acre, including cut and fill 

slopes. An approximate 3.5-foot berm would be constructed around the perimeter of the water 

tanks, excluding the pump shed, at each pumping station to contain any potential spills on the 

pad. The pump shed would be excluded from the berm area in order to minimize the potential 

for electrical or safety hazards that could occur if water entered the pump shed and caused 

electrical outages. The berm would be constructed to contain the water from the largest tank, 

plus 10%, and maintain a freeboard of 1 foot. A berm that is about 40 feet x 25 feet, with a water 

height of 2.5 feet could contain 2,500 cubic feet of water, equivalent to the 2,250 cubic feet of 

water contained in a 17,000-gallon tank, with additional capacity (10%). A typical water transfer 

facility is shown in Figure 2-7. 

The CBNG interconnect pipeline would extend from T24N, R81W, S35 to the WIC block valve in 

T21N, R83W, S19 (Figure 2-1). Up to two 8- to 12-inch steel pipes would be buried a minimum 

of 42 inches deep. The construction ROW for the gas interconnect pipeline would be an 

estimated 100 feet wide, with the operational ROW totaling 50 feet. This corridor would allow 

working room for the machinery, personnel, and equipment during the construction and 

installation process. Figure 2-8 depicts a typical construction profile for the proposed CBNG 

interconnect pipeline construction. Roads associated with the interconnect pipeline, unless 

located entirely within the pipeline disturbance/ROW width of 90 feet, would need to be 

considered under additional NEPA analysis prior to authorization and construction. 

The interconnect pipeline would be constructed using open-cut construction methods for upland 

areas and dry-ditch construction or boring methods for water body crossings. The disturbed 

area would be kept to a minimum. In order to minimize surface disturbance, the operator would 

use wheel trenchers (ditchers) or ditch witches, where possible, to construct pipeline trenches 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 2-13 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

associated with this project. Trenches that would be open for the installation of pipelines would 

have plugs placed no more than 1,000 feet apart to allow livestock and wildlife to cross or 

escape the trench, if warranted. Plug placement would be determined in consultation with BLM 

or the applicable landowners. ROWs located in the same corridor would overlap each other to 

the maximum extent possible, while maintaining sound construction and installation practices. 

Where ROW corridors are located along a road, working space for installation of facilities would 

be along the road. Pipeline corridors would be reclaimed as soon as practical after construction 

of the pipeline is complete. 

2.1.5.4 Central Compressor Facility 

Produced natural gas under wellhead pressure would move through the low-pressure 

gas-gathering system to the CCF, located in T24N, R81W, S35 (Figure 2-2). Typical pressure in 

the lines for a gathering system of the type proposed for this project is less than 100 pounds per 

square inch (psi). Gas arriving at the CCF would be compressed from the pressure in the 

gathering line to facilitate delivery and introduction of the gas into a CBNG interconnect pipeline. 

Compression of the gas at a field CCF would increase the pressure to an estimated 800 to 

1,500 psi. 

The CCF would be sited to allow for the installation of two compressors for the proposed Hanna 

Draw Pilot Project. The compressors would be sized to handle 4.5 million cubic feet per day 

(MMCFD) from 15 to 25 psi suction pressure to 800 to 1,500 psi discharge pressure. The 

compressors would be driven by natural gas-fired IC engines designed to meet applicable 

requirements established by the Wyoming Department of Environmental Quality, Air Quality 

Division (WDEQ-AQD). Prior to construction and operation, a construction permit application 

package would be completed and an air quality permit obtained pursuant to requirements set 

out under Wyoming Air Quality Standards and Regulations (WAQSR), Chapter 6, Section 2. 

BACT would be applied for nitrogen oxides (NOx), carbon monoxide (CO), and hazardous air 

pollutants (HAP), specifically formaldehyde. Additional equipment at each CCF would include a 

tri-ethylene glycol (TEG) dehydration system, which would dry the gas to meet all pipeline 

quality specifications of the market pipeline. The compressors would be contained in an 

enclosed building. Anticipated noise levels associated with each of these engines would be 

approximately 77 dBA at 50 feet. The CCF would require approximately 11 acres of 

disturbance and would be located as shown on Figure 2-2. All CCF engines would be housed 

within structures designed in accordance with applicable regulations. A typical CCF is shown in 

Figure 2-9. 

In the event that the wells prove to be economically viable, a CBNG interconnect pipeline would 

be required to move the gas to an existing system, as discussed in Section 2.1.5.3. 

2.1.6 Workforce Requirements and Traffic Estimates 

Estimated traffic requirements for drilling, completion, and well development are shown on 

Table 2-2. The "Trip Type" column lists the various service and supply vehicles that would 

travel to and from the well sites and ancillary facilities. The "Round-Trip Frequency" column lists 

the number of trips, both external (to and from the Hanna Draw Pilot Project area) and internal 

(within the Hanna Draw Pilot Project area). The figures provided on Table 2-2 should be 

2-14 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 



CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

Table 2-2 Traffic Estimates 

Trip Type Round Trip Frequency 

Drilling (2 rigs, 2 crews/rig) External (to/from project area) Internal (within project area) 

Rig supervisor 4/day same 

Rig crews 9 to 16/day same 

Engineers1 2/week 1/day/rig 

Mechanics 4/week same 

Supply delivery 1/week 2-4/day 

Water truck2 1/month 2 round trups/day 

Fuel Trucks 2 round trips/well same 

Mud trucks 1/week 2/day 

Rig move3 8 trucks/well 8 trucks/well 

Drill bit/tool delivery 1 every 2 weeks same 

Completion 

Smeal rig/crew 1/day same 

Cement crew 2 trips/well same 

Consultant 1/day same 

Well loggers 3 trips/well same 

Gathering systems 8/day same 

Power systems 2/day same 

Compressor stations 2/day same 

Other field development 3/day same 

Testing and operations 2/day same 

1

 Engineers travel to the project area weekly and stay in a trailer in the project area during the week. 2

 Water trucks would deliver water to rigs from a location within the project area. 

3

It would require four trucks to move each rig to the project area. Upon completion of drilling in the 

 project area, each rig would move to the next area. 

considered general estimates, based on an active drilling program. The level of drilling and 

production activity may vary over time in response to weather and other factors. 

2.1.7 Water Supply and Disposal 

2.1.7.1 Water for Drilling 

Water for use in well drilling would be obtained from existing gas wells completed in the coal 

seams of the Hanna Formation. Approximately 30,000 gallons of water would be needed to drill 

each well. The actual volume of water used in drilling operations would depend on the depth of 

the well and any losses that might occur during drilling. Associated drilling activities also would 

require almost 70,000 gallons of water per well for preparation of cement or stimulation of the 

well (55,440 gallons) and dust control (14,000 gallons). In all, nearly 100,000 gallons (about 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 2-18 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

0.3 acre-feet) of water per well would be used. Dust abatement measures would comply with all 

applicable Wyoming Oil and Gas Conservation Commission (WOGCC) requirements. Only 

water suitable for livestock use would be used for dust abatement. 

2.1.7.2 Disposal of Produced Water 

As part of the proposed Hanna Draw Pilot Project, up to 40,000 barrels (1,680,000 gallons) of 

produced water per day from the production operations would be discharged directly into the 

existing reservoir located in Section 13 (Figure 2-2). Approval for the discharge of produced 

water is under the jurisdiction of BLM from the point of origin to the point of discharge as 

described in Onshore Order No. 7, Disposal of Produced Water. Discharge of produced water 

downstream from the point of discharge is under the jurisdiction of the WDEQ, in accordance 

with permits issued through the WYPDES program. APC recently renewed the existing 

WYPDES permit (# WY0044164) for discharge to the reservoir, which was set to expire on 

November 27, 2006. The renewed permit became effective on November 28, 2006 and will 

expire November 30, 2011. APC would conduct monitoring activities to ensure that discharge 

quality meets the limits in the WYPDES permit issued by the WDEQ. 

On May 2, 2006, APC submitted a WYPDES renewal application to the WDEQ for discharge of 

produced water to the existing reservoir in Section 13. The BLM provided public comment to 

the WDEQ in a letter dated November 20, 2006. The BLM’s primary issues brought forward 

included concerns about reservoir containment of produced water (preventing seepage from the 

reservoir below the dam faces), dam engineering and safety, wildlife protection, groundwater 

protection, and sampling methodology. On November 28, 2006, the WYPDES permit was 

renewed. A copy of this permit is available from the WDEQ and was provided in the WMP by 

APC. 

Produced water from the Pilot Project would be conveyed from the CCF to the existing reservoir 

via a pipeline located along the existing road ROW. The maximum storage in the reservoir 

(approximately 500 acre-feet at an elevation of 6,915 feet) would not be exceeded, in 

accordance with APC’s State Engineer’s Office (SEO) permit for use of this reservoir. Above 

and elevation of 6,915 feet the reservoir includes an additional 5 feet of freeboard (255 acre-feet 

of storage to accommodate precipitation and runoff from the 25-year storm event). 

As noted in the WMP, APC would inspect two monitoring locations (downstream of each dam 

face) on a weekly basis during operations to ensure there is no reservoir seepage. Before 

utilizing the reservoir, APC would reinforce the dam faces with an erosion control device to help 

prevent any erosion due to wave action. In addition, APC would inspect the dams quarterly or 

after major storm events for the first year of operation. If the reservoir level needed to be 

lowered, water haul trucks could be utilized. Finally, APC would reclaim the reservoir when no 

longer used for disposal of produced water in accordance with specifications in the MSUP. 

If needed, APC would construct a second water pipeline from the pilot drilling area to the 

reservoir. This additional line also would parallel the existing road to minimize impacts. 

A portion of the produced water would infiltrate and evaporate. However, since the produced 

water would be added to the reservoir at a constant rate, it may be necessary for APC to reduce 

the discharge of produced water to the existing reservoir if storage capacity becomes a limiting 

factor. 

2-19 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

2.1.8 Applicant-Committed Resource Protection Measures 

APC is required to comply with a number of federal, state, county, and local regulations and 

standards for project development and operation. Additionally, APC has developed a list of 

measures to minimize impacts from project construction and operation, as detailed in the MSUP 

in Appendix A. A few additional resource-specific measures have been identified to help 

minimize potential impacts from the proposed Hanna Draw Pilot Project. APC has voluntarily 

committed to incorporate the following environmental protection measures into the Proposed 

Action. These measures and procedures are referred to as “Committed Protection Measures” 

throughout this document. The resource impact analyses completed for this EA have included 

these measures, which would prevent or minimize anticipated impacts, as discussed. Additional 

measures developed to “mitigate” potential impacts to specific resources from implementation of 

the Proposed Action, if warranted, are presented for the applicable resource discipline in 

Chapter 4.0 of this EA. 

These protection measures and procedures would be applied to actions under the jurisdiction of 

the BLM. An exception to a protection measure or design feature may be approved on public 

land on a case-by-case basis when deemed appropriate by the BLM only after a thorough, 

site-specific analysis had concluded the resource or land use the measure was intended to 

protect is not present or would not be significantly affected in the absence of the protection 

measures. BLM also conducted on-site inspections of various elements of the Proposed Action 

(primarily drill pads and roads). During these inspections BLM reviewed surveyed locations of 

project elements and evaluated site-specific features such as sensitive plant species, wildlife 

habitat, erodible soils, steep slopes, drainages, riparian areas, floodplains, wetlands and other 

features that could be impacted by the Proposed Action. The BLM considered alternative 

locations to avoid or minimize the potential surface impacts of the Proposed Action. As a result 

of these inspections, changes were made to several project elements to avoid sensitive 

environmental resources. 

Many of these protection measures align with the BLM’s standard Conditions of Approval 

(COAs) that can be applied to coalbed natural gas projects. Additionally, many of these 

protection measures and other more detailed protection measures may be found in the MSUP in 

Appendix A, MDP in Appendix B, and WMP prepared for the project. A number of the resourcespecific measures (e.g., soil erosion measures) would apply to other resource disciplines (e.g., 

water quality). 

The following committed protection measures are outlined and summarized by project phase, 

project component, or resource type. 

2.1.8.1 Paleontological Resources 

1. If paleontological resources were uncovered during ground-disturbing activities, APC 

would suspend all operations that may further disturb such materials and immediately 

contact the BLM, who would arrange for a determination of significance and, if 

necessary, would recommend a recovery or avoidance plan. Mitigation of 

paleontological resources would be on a case-by-case basis, and APC would incur 

costs associated with BLM-required mitigations. Surface-disturbing activities would not 

resume until a Notice to Proceed is issued by the BLM. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 2-20 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

2.1.8.2 Floodplains and Wetlands 

1. Span the existing vegetated wetlands of the Mixed Grass-like/Grass Meadow 

Community along the proposed electric distribution line ROW. Avoid disturbance to 

other vegetated wetlands and open water features, where practicable. 

2.1.8.3 Vegetation and Reclamation 

1. One general seed mixture to be planted during reclamation may be insufficient to 

address the varying characteristics of the disturbed sites to be revegetated. In 

consultation with the BLM, APC would develop a limited array of seed mixtures to 

address varying site characteristics, such as soil chemical and physical parameters and 

existing vegetation community types. 

2.1.8.4 Surface Reclamation Plans 

1. On any disturbed sites where compaction could interfere with successful revegetation, 

disk, rip, or otherwise treat the affected areas to relieve the negative affects of this 

condition prior to initiating revegetation activities. 

2. Fill and compact “rat and mouse holes” (i.e., subgrade excavations for the conduct of 

drilling operations) from the bottom to the top immediately upon release of the drilling rig 

from the location. 

2.1.8.5 Terrestrial Wildlife 

1. In the event that water quality is determined to be potentially detrimental to wildlife (e.g., 

oil deposition), identify applicable mitigation measures to minimize impacts in the short 

and long term. If netting is necessary over open reserve pits to eliminate any hazard to 

migratory birds or other wildlife, as outlined in the MSUP, APC and the BLM would 

develop an appropriate monitoring program for netted areas. Monitoring frequency 

would depend on 1) pit location, 2) evaluated water quality, 3) estimated water residence 

time, and 4) frequency of well maintenance schedule. APC would be responsible for 

monitoring activities as part of project implementation. APC also would be responsible 

for notifying the BLM if a wildlife injury or fatality were found at one of the reserve pits. 

2. Tiering from the BLM’s Great Divide RMP (BLM 1988), prohibit construction, drilling, and 

other activities potentially disruptive to nesting raptors within 1 mile of active ferruginous 

hawk and golden eagle nests and within 0.75 mile of all other active raptor nests 

between February 1 and July 31. Controlled Surface Use restrictions would apply within 

1,200 feet of an active ferruginous hawk, and an 825-foot buffer would be required for all 

other active raptor nests during project operation. An exception would be approved only 

after a thorough, site-specific analysis by the BLM or designated representative 

concluded that a negative impact would not occur. 

3. If project development were to occur during breeding season (February 1 through 

July 31), complete a raptor survey prior to the initiation of construction to ensure that well 

sites are located a sufficient distance from potential conflict areas and ensure that active 

nest sites are not disturbed from development of applicable project components (e.g., 

access road, pipeline construction, and power line construction). These survey results 

2-21 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

are applicable for that breeding season, and if project construction were delayed into the 

following season, additional surveys for the specific construction areas may be required. 

4. Coordinate with PacifiCorp (i.e., Pacific Power) in the design and construction of the 

proposed three-phase 34.5-kV overhead electric distribution line to the Hanna Draw Pilot 

Project area. Electric lines would be constructed in accordance with the standards for 

raptor (i.e., bird of prey) protection in accordance with the Avian Power Line Interaction 

Committee’s Suggested Practices for Avian Protection of Power Lines: The State of the 

Art in 2006 (APLIC 2006). PacifiCorp also maintains an ongoing Avian Protection Plan 

and Bird Management Policy for electric distribution lines in rural areas. This measure 

would minimize the potential for bird electrocution risks. 

2.1.8.6 Special Status Terrestrial Wildlife 

1. If required, restrict construction, drilling, and other activities within a 2-mile radius of 

active greater sage-grouse leks during the breeding, egg-laying, and incubation period 

(March 1 through July 15). Exceptions may be granted if the activity would occur in 

unsuitable nesting habitat. 

2. Prohibit construction, drilling and other potentially disruptive activities in mountain plover 

habitat from April 10 through July 10. An exception would be approved only after a 

thorough site-specific review concluded a negative impact would not occur. 

2.1.8.7 Cultural Resources 

1. APC shall be responsible for informing all personnel associated with this project that 

those persons shall be subject to prosecution for damaging, altering, excavating, or 

removing any archaeological or historical objects or sites. If archaeological or historical 

materials are discovered, APC shall immediately suspend all operations that may further 

disturb or damage such materials. The BLM Authorized Officer shall immediately be 

contacted and informed of the discovery of such materials. Operations shall not resume 

until written authorization to proceed is issued by the BLM Authorized Officer. 

Within 5 working days, the BLM Authorized Officer would evaluate the discovery of such 

materials, and APC would be informed of the mitigations and/or actions necessary to 

prevent the loss of significant cultural values. 

APC shall be responsible for the cost of any mitigation required by the BLM Authorized 

Officer. The BLM Authorized Officer provides technical and procedural guidelines for 

the conduct of mitigation. Upon verification from the BLM Authorized Officer that the 

required mitigation(s) have been completed, APC would be allowed to resume 

operations. 

Avoidance is the preferred method for mitigating effects to a property that is considered 

eligible for, or is already listed on, the National Register of Historic Places (NRHP). If 

avoidance is not possible, NRHP-eligible sites are to be afforded protection by the 

preparation and implementation of a cultural resources mitigation plan that would be 

developed through consultation with APC, BLM, and SHPO. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 2-22 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

2.1.8.8 Socioeconomics 

1. Implement hiring policies to encourage the use of local or regional workers who would 

not have to relocate to the area. 

2.2 NO ACTION ALTERNATIVE 

In accordance with NEPA Section 1502.14(d), an impact analysis must include the No Action 

Alternative. Under the No Action Alternative, the proposed Hanna Draw Pilot Project would not 

proceed, as described in Section 2.1. No exploratory drilling is proposed for private lands as 

part of the Hanna Draw Pilot Project; therefore, no additional CBNG drilling would occur under 

this alternative. Similarly, no construction or operation of ancillary facilities (e.g., gas and water 

gathering and transmission lines, power line, access roads) would occur. 

2.3 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL 

Several alternatives to the Proposed Action were examined. The following section describes 

the alternatives previously considered but subsequently eliminated from detailed analysis and 

the rationale for their elimination. 

2.3.1 Developing Existing Williams Wells 

In 2002, Williams Production RMT Company (Williams) proposed to test the viability of the 

coalbed resources by drilling CBNG wells in T23N, R81W, S13 and T24N, R81W, S35 

(Figure 2-1 of this EA). BLM analyzed the potential impacts from this proposal in the 

Environmental Assessment for the Hanna Draw Coalbed Methane Exploration Project (BLM 

2002a). Although these wells were drilled, APC, which has acquired Williams’ interests, has 

determined, based on its examination of the geology and reservoir data that the Williams 

eight-well Pilot Project in Section 13 (T23N R81W) was located in an area of poor reservoir 

quality (i.e., low gas content and saturation) and had insufficient well density. Data from other 

wells in the project area indicate that reservoir quality improves to the north, which is where 

APC has proposed its Pilot Project. In addition, it would be difficult to drill additional wells 

around the Williams’ wells in Section 35 (T24N R81W) because of terrain features. Based on 

the data gathered to date, it would not be economical to develop the resources in this area; 

therefore, this alternative was eliminated from further analysis. 

2.3.2 Underground Disposal of Production Water 

APC also considered the potential for underground injection of produced water associated with 

the Hanna Draw Pilot Project. This alternative is not considered to be a viable project 

alternative for the Pilot Project. Subsurface injection of fluids must meet specific criteria, 

including water quality thresholds and potential changes to groundwater chemistry, suitable 

underground strata, sufficient space for anticipated fluid volume, and economic viability. 

Available subsurface data suggest that suitable porous and permeable strata of significant 

regional extent are not present at reasonable depths for water disposal in the project area. In 

addition, the volume of produced water would require a large number of injection wells, which 

would reduce the viability of the Pilot Project. For these reasons this alternative was eliminated 

from further analysis. If the Pilot Project were to prove that a full-field development may be 

practicable, the feasibility of underground injection would be examined further. 

2-23 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

2.3.3 Use of Horizontal Production Wells 

APC considered the use of horizontal drilling but it was excluded for the following reasons: 

1. Horizontal drilling in coal seams at these depths is an unproven technology 

2. Areas with multiple coal seams such as the Hanna coal, or areas where a coal seam has 

shale breaks imbedded in the coals would require multiple laterals to reach all reserves. 

Additionally, any barrier that represents limited vertical permeability would require an 

additional lateral to reach reserves. 

3. Unknown risks associated with hole stability 

4. Increased produced water volumes and potential subsequent treatment 

5. Insufficient water handling capacities with the current infrastructure 

6. Unknown kv/kh (ratio of horizontal to vertical permeability) 

7. Increased risk of mechanical failure because of wellbore complexity 

8. Significantly increased costs 

2.3.4 Discharge of Produced Water to Medicine Bow River 

Originally, APC’s Proposed Action entailed the discharge of approximately 100,000 bbl/day of 

produced water to the Medicine Bow River, a tributary to the North Platte River. Hydrological 

evaluation of a U.S. Geological Survey (USGS) gaging station located immediately downstream 

of the Hanna Draw Pilot Project area on the Medicine Bow River indicated that the proposed 

discharge would, throughout much of the year, contribute a substantial amount of flow to the 

river (i.e., on 10 days, in an average year, the effluent would contribute at least 50% of instream 

flows). 

The Medicine Bow River is classified as a 2AB watercourse (i.e., protected for drinking water 

and game fisheries). The BLM subsequently conducted fish population sampling in this portion 

of the river, in coordination with the Wyoming Game and Fish Department (WGFD). The 

sampling found no sensitive/protected fish taxa, but there are several species of warm- and 

cold-water fishes present, including brown trout. 

The BLM requested that WET tests be conducted on waters representative of the produced 

water effluent from the target formations. These tests would assess the potential for toxicity to 

aquatic life as a result of discharging produced water. 

In September 2004, APC selected the #14-35 well, a test well approximately 0.5 mile to the 

north of the project area and completed to a depth of 4,648 feet (the project target formations 

range from 4,050 feet to 5,850 feet) as the source for waters to conduct WET tests. 

Additionally, water quality analyses were conducted on the #14-35 well and six other wells 

located approximately 2 miles to the south of the project area (the completion depths of these 

six wells ranges from 3,600 feet to 4,100 feet, a mean depth of 3,884 feet; over 1,000 feet 

shallower than the midpoint of the project’s target formations). 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 2-24 
CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES 

WET tests conducted on the #14-35 waters for Daphnia magna (an aquatic invertebrate) and 

Pimephales promelas (fathead minnow) resulted in 100% mortality at 100% effluent 

concentration. Both of these species are present in the Medicine Bow River. Tests at varying 

concentrations of effluent and laboratory standard (distilled water) indicated an expected lethal 

concentration for 50% of the population (LC50) at approximately 62% effluent to 38% laboratory 

standard. The #14-35 water was moderately toxic to aquatic life. Subsequent modeling by a 

third-party consultant indicated that the primary toxicants of concern are ammonia (NH3+) and 

salinity. Once the WET test results were received by the Rawlins FO, the FO requested the 

assistance of a BLM Toxicologist (NSTC-Denver). 

As a result of additional BLM review of the issues and circumstances, the BLM determined there 

is concern regarding potential effects of the discharge. Hydrological analysis by the Rawlins FO 

Hydrologist using mean daily flows has shown that the LC50 concentration would be exceeded 5 

days in an average year within this reach of the river, even when assuming complete mixing of 

the effluent in the receiving water. 

A possibility exists that the #14-35 water used for the WET tests is unrepresentative of the 

target formations, but until the blended effluent from the project can be sampled (after drilling), 

this is difficult to determine. 

APC subsequently revised the Proposed Action, eliminating effluent discharge to the Medicine 

Bow River for the Pilot Project. 

2-25 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 3 

AFFECTED ENVIRONMENT 
CHAPTER 3: AFFECTED ENVIRONMENT

CHAPTER 3 

Affected Environment 

Chapter 3 of this EA presents the baseline environmental conditions within the area to be 

potentially affected by APC’s proposed Pilot Project. The baseline conditions discussed in the 

chapter include air quality, geology, geologic hazards, paleontology, soils, water resources, 

floodplains and wetlands, vegetation, terrestrial wildlife, aquatic species, special status species, 

cultural resources, land use, noise, recreation, visual resources, socioeconomics, 

transportation/access, and health and safety. 

3.1 AIR QUALITY 

The Hanna Draw Pilot Project is located in a semiarid, steppe (dry and cold), midcontinental 

climate regime typified by dry windy conditions, limited rainfall, and long cold winters. The 

average annual temperature is approximately 42°F (Western Regional Climate Center [WRCC] 

2000a, 2000b), and monthly mean temperatures range from a low of 11°F in January to a high 

of 83°F in July. The average annual precipitation is approximately 10 inches, with the majority 

falling from April to October; 30% occurs from thunderstorms during the summer months of 

June through August (Martner 1986). The average annual snowfall is approximately 39 inches, 

with January being the month of greatest accumulation (WRCC 2000a, 2000b). Snow 

accumulation patterns are determined by the effects of topography and vegetation on 

windblown snow and have a marked effect on vegetation, wildlife, hydrology, and human 

activities. Annual pan evaporation rate is an estimated 60 inches, while reservoir evaporation, 

representing anticipated conditions is approximately 42 inches. 

The Hanna Draw Pilot Project is located in a region of Wyoming known as the wind corridor, 

where cold wind from the west and southwest is channeled eastward across the Continental 

Divide (Martner 1981). Annual wind speeds average 4.5 to 21.5 miles per hour (mph) and are 

greater during the afternoon and in the winter. The wind corridor has some of the strongest and 

most persistent winds in the U.S. (Martner 1986). 

Air quality in the region is generally good (BLM 1995a, 1995b). Management for air quality 

includes the prevention of deterioration of air quality beyond applicable local, state, or federal 

standards; the enhancement of air resources of high quality where practicable; and the 

preservation of scenic values that may be impaired by the release of total suspended 

particulates (TSP) or other contaminants into the air that would affect visibility (BLM 1988). 

The Hanna Draw Pilot Project is located in the Hanna Basin and is part of the Laramie Air Basin 

(BLM 1987), which includes much of south-central Wyoming. The basin is bordered by the 

Wyoming-Colorado state line to the south, the Laramie Mountains to the east, the Granite 

Mountains to the North, and the Great Divide Basin to the west. Air transport from the west and 

southwest dominates in level terrain areas, and dispersion results from unstable conditions 

induced by surface heating during the day. Stable conditions may be expected at night as the 

earth cools. In areas with significant terrain features such as the Medicine Bow, Shirley, and 

Green Mountains, transport is more complex. Typical mountain-valley coupling effects are 

evident in these areas, along with significant diurnal variations in local winds (BLM 1987). 

The Hanna Draw Pilot Project is in an area designated a Prevention of Significant Deterioration 

(PSD) Class II area under the WDEQ/AQD Implementation Plan (BLM 1987). PSD Class II 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-1 
CHAPTER 3: AFFECTED ENVIRONMENT

areas are those that may be developed, and the release of limited concentrations of certain 

pollutants over Class II PSD increments is permitted so long as national ambient air quality 

standards (NAAQS) are maintained and emissions are within the PSD Class II increment 

(WDEQ 2002). The nearest PSD Class I area (an area where little air quality deterioration is 

allowed) is the Savage Run Wilderness, located approximately 50 miles south-southeast of the 

project area. Although the Savage Run Wilderness has not been designated Class I by 

Congress and thus legally does not have to be managed as a Class I area, it has the legal 

requirement to be managed as a Class I area under the Wyoming Air Quality Standards and 

Regulations Chapter 6, Section 4(c) (Dailey 2004). Other Class I areas in the region include the 

Bridger Wilderness in Wyoming and the Mount Zirkel Wilderness in Colorado. 

The Clean Air Act mandates that NAAQS, established by the Environmental Protection Agency 

(EPA), must be maintained nationwide. NAAQS include standards for six "criteria" pollutants 

including: ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), particulate matter less 

than 10 microns in diameter (PM10), sulfur dioxide (SO2), and lead (Pb). Carbon County, 

Wyoming, is in an attainment area for all NAAQS "criteria" pollutants. 

Visibility in the region is very good (generally greater than 70 miles), and particulates (i.e., fine 

particles carried by the wind from natural or manmade sources) are considered to be the main 

source of visibility degradation (BLM 1998). Climatic factors such as prevailing winds, 

atmospheric stability, and mixing heights affect air quality by influencing the ability of air to 

disperse or dilute particulates and other pollutants. Unstable conditions caused by vertical 

movement of air heated near the ground during the day combined with moderate to high wind 

speeds provide conditions conducive to dispersing and diluting particulates and other pollutants 

and maintaining air quality (BLM 1987). These conditions occur more than 70% of the time 

throughout most of the region in which the Hanna Draw Pilot Project would be located. A 

summary of some regional criteria pollutant background levels is presented in Table 3-1. 

3.2 GEOLOGY AND GEOLOGICAL HAZARDS 

3.2.1 Geology 

The proposed Pilot Project is located within the Hanna Basin. Hanna Basin is a one of the 

deepest structural basins in Wyoming formed during the Laramide Orogeny, a period of intense 

folding, faulting, deformation, and deposition from the Late Cretaceous to early Tertiary Periods 

(Richter 1981). It is flanked to the north by the Shirley and Seminoe Mountains, east by the 

Carbon Basin, south by the Medicine Bow Uplift and Elk Mountain, and west by the Rawlins 

Uplift (Wilson et al. 2001). 

Structural relief within the Hanna Basin exceeds 30,000 feet (Hansen 1986; Blackstone 1989). 

The basin is an asymmetrical synclinal feature with shallow dipping sedimentary rocks along the 

southern and western margins and steeper south-dipping rocks on the northern margin near the 

Shirley Mountain Thrust fault, which forms the northern boundary. The structural axis of the 

basin trends west-northwest to east-southeast along the northern portion of the basin. 

Figure 3-1 shows the bedrock geology of the proposed Pilot Project area, and Table 3-2 is a 

generalized stratigraphic section of the bedrock units. The overall sedimentary rock thickness 

within the basin exceeds 35,000 feet in the deeper portion of the basin (see Table 3-2). 

3-2 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 3: AFFECTED ENVIRONMENT

Table 3-1 Regional Air Pollutant Background Concentrations and State and 

Federal Ambient Air Quality Standards 

Pollutant/Averaging 

Time 

Measured 

Background 

Concentration 

(μg/m3

)

State and 

National 

Ambient Air 

Quality 

Standards 

 (μg/m3)

PSD Class I 

Increment 

 (μg/m3)

PSD Class II 

Increment 

 (μg/m3) 

Carbon Monoxide (CO) 1 

1-hour 2,299 40,000 None None 

8-hour 1,148 10,000 None None 

Nitrogen Dioxide (NO2) 2 

Annual 3.4 100 2.5 25 

Ozone (O3)

3 

1-hour 169 235 None None 

8-hour 147 157 None None 

Particulate Matter (PM10) 4 

24-hour 47 150 8 30 

Annual 16 50 4 17 

Particulate Matter (PM2.5) 4 

24-hour 15 65 None None 

Annual 5 15 None None 

Sulfur Dioxide (SO2) 5 

3-hour 29 1,300 25 512 

24-hour 18 260 5 91 

Annual 5 80 2 20 

Source: BLM 2004a 

*Effective February 27, 2001 the U.S. Supreme Court upheld the EPA's position on the proposed national 8­

hour ozone and PM2.5 standards. The WDEQ-AQD will not enforce the standards until EPA issues an 

implementation rule. Therefore no demonstration of compliance with these standards is required at this time. 

(WDEQ 2002). 

1

Colorado Department of Public Health and Environment-Air Pollution Control Division (CDPHE-APCD) 1996 

in BLM 2004a: Data collected at Rifle and Mack, Colorado in conjunction with proposed oil shale 

development during early 1980s. 

2

Background data collected at Green River Basin Visibility Study site, Green River, Wyoming, during period 

January-December 2001 (ARS 2002). 

3

Background data collected at Green River Basin Visibility Study site, Green River, Wyoming, during period 

June 10, 1998 through December 31, 2001 (ARS 2002). 

4

Background data collected by WDEQ-AQD at Emerson Building, Cheyenne, Wyoming, Year 2002. 

5

CDPHE-APCD 1996 in BLM 2004a: Data collected at the Craig Power Plant site and at Colorado oil shale 

areas from 1980 to 1984. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-3 
CHAPTER 3: AFFECTED ENVIRONMENT

Table 3-2 Summary of Geologic Formations in the Pilot Project Area 

Stratigraphic Units in the Hanna Basin 

Stratigraphic Unit 

Approximate 

Thickness (feet) 

Crops out in 

Pilot Project 

Area 

Probable Fossil 

Yield 

Classifications1 

Medicine Bow Formation 6,000 Yes 4 

Fox Hills Sandstone 6,000 Yes 

Lewis Shale 2,100 Yes 2 

Mesaverde Group 2,600 Yes 4 

Steele Shale 3,000 No 

Niobrara Formation 1,200 No 

Frontier Formation 800 No 

Mowry Shale 200 No 

Muddy Sandstone 60 No 

Thermopolis Shale 80 No 

Cloverly Formation 20 No 

Morrison Formation 375 No 

Sundance Formation No 

Nugget Sandstone No 

Jelm and Chugwater Fromations 700 No 

No 

No 

400 No 

300 No 

Madison Limestone 500 No 

Flathead Standstone 65 No 

granitic and metemorphic basement No 

Formation 

Hanna 

PALEOCENE 

Period/EPOCH 

Tertiary (part)

EOCENE 

MISSISSIPPIAN 

CAMBRIAN 

PRECAMBRIAN 

Goose Egg Formation 

TRIASSIC 

PERMIAN 

PENNSYLVANIAN Casper Formation 

19,000 Yes 4

300 

400 

LATE 

EARLY 

JURASSIC 

Ferris Formation 

Cretaceous 

Modified from Willson et al. 2001 

 See text for explanation 

3-4 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 

1
CHAPTER 3: AFFECTED ENVIRONMENT

Sedimentary rocks exposed within the Proposed Action area of the Hanna Basin are shown in 

Figure 3-1 and range from Tertiary rocks of the Hanna Draw Formation (Tha) to Late 

Cretaceous (Medicine Bow Fm). The exposed bedrock units within the proposed interconnect 

pipeline corridor are shown on Figures 3-1 and Table 3-2 and are discussed below from 

youngest to oldest. 

Hanna Draw Formation 

The Hanna Draw Formation sediments are fluvial deltaic in origin consisting of interbedded, 

siltstone, claystone, and carbonaceous shale’s with massive cross-bedded sandstones. This 

formation is synorgenic in nature, as the Hanna Basin was in-filled during rapid subsidence 

relative to adjacent Laramide orogenic uplifts (Wilson et al. 2001). The overall stratigraphic 

thickness of the formation is about 11,000 feet thick (Wilson et al. 2001). There are 32 known 

coalbeds of 5 feet or more within the Hanna Draw Fm. Coal thicknesses within the Tha are 

typically 5- to 10-feet thick but can be as thick as 60 feet and are the target of CBNG exploration 

within the basin (Glass and Roberts 1980). The formation contains moderate folds and minor 

faulting particularly along the southern portion of the basin (see Figure 3-1). 

Ferris Fm 

The Ferris Formation (TKf) also is comprised of synorogenic fluvial deltaic sedimentary rocks 

deposited across Cretaceous/Tertiary time boundary. It is similar in stratigraphic thickness and 

lithology to that of the overlaying Tha. The TKf consists of siltstone, shale, and claystone with 

massive cross-bedded fluvial coarse-grained to conglomeritic sandstone (Glass and Roberts 

1980). The combined thickness of the Tha and TKf is on the order of 19,000 feet (see 

Table 3-2). The TKf contains 28 mineable coalbeds (Glass and Roberts 1980). Ferris 

Formation exposure occurs along the southern portion of the proposed Pilot Project area (see 

Table 3-2). 

Medicine Bow Formation and Fox Hills Sandstone 

The Late Cretaceous Medicine Bow Formation (Kmb) and Fox Hills Sandstone (Kfs) at its base 

have a combined thickness of approximately 6,000 feet. These units are exposed along the 

southern margin of the project area (see Table 3-2). The basal portion (Kfs) consists of massive 

to cross-bedded sandstones interbedded with coal seams. Above the Kfs, the Kmb consists of 

finer grained materials predominantly dark-colored shale and fine grained sandstones. The 

upper portion of the Kmb contains massive friable sandstone interbedded with dark colored 

shale (Glass and Roberts 1980). 

Lewis Shale 

The Lewis Shale (Kls) underlies the Kfs and consists of 2,100 feet of marine shale. It is 

interbedded with thin shaly sands and nearshore marine sandstones, including the 

150-foot-thick Dad sandstone (HydroGeo 2004). 

Mesa Verde Group 

The oldest sedimentary rocks within the proposed Pilot Project area are the Cretaceous Mesa 

Verde Group (Kmv). This Kmv consists of four formations including white-colored sandstones 

of the Almond Formation; sandstone, shale, and coal of the Pine Ridge Formation; brown fluvial 

sandstones of the Allen Ridge Formation; and shale, bentonite, and sandstones of the Haystack 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-5 
CHAPTER 3: AFFECTED ENVIRONMENT

Mountain Formation. The combined stratigraphic thickness of the Kmv is about 2,600 feet 

(Wilson et al. 2001). 

Surficial Geology 

The Pilot Project surficial geology is shown on Figure 3-1. Within the proposed project area, 

quaternary alluvial and colluvial deposits (Qa) are located in the Medicine Bow River valley and 

the drainage west of the town of Hanna. Other colluvial deposits are present localized to 

drainages, but not at a reasonable scale for viewing. Gravel terrace and pediment deposits (Qt) 

are present northwest of the Pilot Project area. 

3.2.2 Mineral/Oil and Energy Resources 

The primary energy resource within the Hanna Basin is coal, with an estimated reserve of 

23 billion tons of coal deposits. Both underground and surface mining of coal has been 

conducted within the basin since the 1860s, targeting subituminous to bituminous coals largely 

within the Tha and KTf formations (Glass and Roberts 1980). Underground mining of coal in 

Hanna Basin is no longer economically viable, and surface mining along the southern margin of 

the basin is currently under reclamation. 

Numerous oil and gas exploration wells have been drilled across the Hanna Basin, some to 

depths of over 16,000 feet seeking natural gas potential. To date, no viable conventional oil or 

gas production has been discovered in the basin. However, because of the underlying coal, 

Hanna Basin contains potential for CBNG production. 

There are no known economic mineral or base metal deposits within the Hanna Basin. Other 

industrial rock and minerals gravel deposits in the Qa and bentonite are unproven and likely 

sub-economic across the proposed Pilot Project area. 

3.2.3 Geologic Hazards 

Potential geologic hazards within the proposed project area include earthquakes, landslides, 

flash flooding, and subsidence from former mining activities. 

Seismicity 

The most recent earthquake greater than a magnitude 3 on the Richter Scale occurred on the 

western margin of the Hanna Basin in August 1998, likely recurrent motion on an existing fault 

(see Figure 3-1). A magnitude 4 earthquake is minor with noticeable shaking if indoors, but 

barely perceptible when outdoors. The overall seismic risk within the Hanna Basin is very low. 

Landslides and Flooding 

Landslides are possible in the form of slumps and flows along hill slopes, particularly during or 

after periods of high precipitation along slopes with bentonitic soil and little vegetation. Small 

landslides and slumps are present to the west of the project area on steeper slopes closer to 

Hanna Draw. 

Precipitation within the area is generally 12 inches per year or less and occurs largely from 

thunderstorm events. There is a potential for flooding along the dry washes and ephemeral and 

3-6 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 

CHAPTER 3: AFFECTED ENVIRONMENT

perennial streams in the project area. Flooding in ephemeral drainages is generally in response 

to high-intensity (large quantity of precipitation in a short time) localized storms. Such storms 

cause most of the floodwater damage, surface erosion, gulley formation, sediment deposition in 

arid and semi-arid environments (Branson et al. 1981). Curtis and Grimes (2004) indicates 

there are, on average, 35 to 40 days with thunderstorms in the area. 

Subsidence 

The proposed CBNG interconnect pipeline ROW avoids several historic coal mining areas, but 

does not cross reclaimed areas where subsidence risk may be greatest. Ground subsidence 

from the proposed withdrawal of produced water also has been examined, given its potential 

impact from CBNG development. However, there appears to be minimal risk for subsidence 

related to historic coal mining. Withdrawal of groundwater has been associated with subsidence 

in several areas including the San Joaquin Valley California, Las Vegas, New Orleans, Houston, 

and Mexico City. In these areas groundwater has been removed from unconsolidated sand and 

gravel aquifers, causing previously saturated zones to compress, resulting in ground 

subsidence of as much as 29 feet. The geologic strata underlying the Pilot Project is 

consolidated rock with porosities much lower than unconsolidated sand and gravel, and 

therefore, much less likely to be compressed following dewatering. In fact, estimates of ground 

subsidence associated with CBNG production for the Wyodak coal in the Powder River Basin, 

predict subsidence of less than 0.5 inch (Case et al. 2002). Furthermore, coal seams from 

which produced water would be withdrawn for the Pilot Project are much deeper than those in 

the Powder River Basin and any subsidence is expected to be attenuated because of the 

increased depth. Therefore, the potential for ground subsidence from the proposed project is 

not considered to be an issue and not carried forward in the analysis for the proposed Hanna 

Draw Pilot Project. 

3.3 PALEONTOLOGICAL RESOURCES 

BLM employs the Probable Fossil Yield Classification (PFYC) developed by the U.S. Forest 

Service (USFS) as the basis for describing the potential presence of paleontologic resources 

within surface geologic formations. This classification system is then used to determine the 

need for additional considerations for proposed surface disturbing activities. The classifications 

are described as follows: 

Class 1. Igneous and metamorphic geologic units (excluding tuffs) that are not likely to 

contain recognizable fossil remains. 

Class 2. Sedimentary geologic units that are not likely to contain vertebrate fossils or 

scientifically significant nonvertebrate fossils. 

Class 3. Fossiliferous sedimentary geologic units where fossil content varies in 

significance, abundance, and predictable occurrence. 

Class 4. Class 4 geologic units are Class 5 units that have lowered risk of 

human-caused impacts or lowered risk of natural degradation. Proposed grounddisturbing activities would require assessment to determine whether significant 

paleontological resources occur in the area of a Proposed Action and whether the action 

would impact the resources. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-8 
CHAPTER 3: AFFECTED ENVIRONMENT

Class 5. Highly fossiliferous geologic units that regularly and predictably produce 

vertebrate fossils or scientifically significant nonvertebrate fossils and that are a high risk 

of natural degradation or human-caused impacts. 

Six sedimentary formations are exposed at or near the ground surface in the Hanna Draw Pilot 

Project area, including the proposed interconnect pipeline ROW. These include, from youngest 

to oldest: 1) unnamed deposits of late Holocene age, including unconsolidated aeolian sands, 

stream gravels, alluvium, and colluvium; 2) Hanna Formation of Paleocene and possibly early 

Eocene age; 3) Ferris Formation of late Cretaceous and Paleocene age; 4) Medicine Bow 

Formation of Late Cretaceous age, 5) the Lewis Shale of Late Cretaceous age, and 

6) Mesaverde Group of Cretaceous age. The Holocene deposits are widespread across the 

Pilot Project area, while the Hanna Formation, as shown on Figure 3-1 (USGS 1994) underlies 

Section 2 of the project area, the compressor station site in Section 35, and roughly the 

northeast half of the interconnect pipeline ROW. The remaining formations (i.e., Ferris, 

Medicine Bow, Lewis Shale, and Mesaverde Group) outcrop over varying lengths of the 

southeastern half of the interconnect pipeline ROW. 

The Holocene deposits are derived from local erosional sources and are too young to contain 

significant fossil resources. However, the Hanna, Ferris, and Medicine Bow Formations and 

Mesaverde Group are known to produce vertebrate fossils of scientific significance in areas 

adjacent to the Pilot Project as summarized in the following paragraphs. The Lewis Shale is 

known to contain invertebrate fossils and occasionally vertebrate fossils but underlies a small 

portion of the pipeline corridor. 

High deposition rates in the Hanna Basin led to the deposition of thick sequences of sediments 

that form the Hanna Formation, which yields abundant vertebrate and invertebrate fossils and 

plants of Paleocene age (Higgins 2003; Gill et al. 1970; Ryan 1977; Lillegraven 1995; Eberle 

and Lillegraven 1998a). Plants from the formation include microfossil (pollen) and megafossil 

(leaf and stem imprints and petrified and carbonized wood) remains. More recently, field parties 

have documented fossil vertebrates including a wide variety of mammals, reptiles, and fish of 

Paleocene age. In addition, a specimen of early horse, Hyracotherium, was discovered from 

near the top of the unit that suggests the top of the Hanna Formation is earliest Eocene in age 

(Eberle and Lillegraven 1998a, 1998b). 

The Ferris Formation has produced scientifically significant fossils ranging in age from Late 

Cretaceous to Early Paleocene age, including the remains of 59 species of early Paleocene 

mammals (Eberle and Lillegraven 1998a, 1998b; Eberle 1996). The vertebrate fauna of the 

Ferris Formation is of particular importance because it spans the Cretaceous-Tertiary boundary 

and provides critical information on the diversification of mammals at the beginning of the 

Cenozoic Era. In addition, the formation preserves fossil leaves and shells of freshwater 

invertebrates and trace fossils. 

The Medicine Bow Formation yields fossils of terrestrial vertebrates and plants and marine and 

freshwater invertebrates. Plants known from this formation also include microfossil (pollen) and 

megafossil (leaf and stem imprints, and petrified and carbonized wood) remains. Well-preserved 

fossil leaf floras have been described from the formation by Dorf (1942). Invertebrate fossils 

include marine foraminifera and brackish water gastropods and bivalves, represented by at least 

21 species (Gill et al. 1970; Fox 1971). Dinosaur bone fragments have long been known from 

the lower part of the formation (Bowen 1918; Lull 1933; Breithaupt 1985, 1994), and the 

formation has also produced the remains of a small number of mammals of Late Cretaceous 

age (Lillegraven 1993, 1995; Secord 1998). 

3-9 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 3: AFFECTED ENVIRONMENT

Due to the presence of significant fossil resources within the Hanna, Ferris, Medicine Bow, and 

Mesaverde Group formations in areas near or adjacent to the Pilot Project, these formations 

meet the criteria for PFYC Class 4 (see Table 3-2). Class 4 may require further assessment of 

existing data prior to authorizing land use actions involving surface disturbance. 

3.4 SOILS 

Unpublished soil maps, map unit descriptions, pedon descriptions, and soil interpretations for 

the project area were provided by the Natural Resources Conservation Service (NRCS) (Cox 

2004) to aid in developing this section. In addition, an interpretations table was developed 

depicting ratings for the majority of the map units occurring within the project area with respect 

to runoff potentials, water and wind erosion hazards, and the presence of elevated salt and 

sodium levels. 

The following information was developed based on the maps and data collected from these 

sources pertaining to the dominant soil map units found across the proposed project area. Soil 

chemical and physical characteristics related to impact assessment, mitigation planning, and 

potential revegetation success are emphasized. Table 3-3 provides an overview of the specific 

soil baseline characteristics of the dominant soil map units for the project area. 

3.4.1 General Soil Characteristics 

The soils of this project area are somewhat variable in terms of both physical and chemical 

characteristics, as a function of parent material, topography, and differential rates of mineral 

weathering. Soils range from shallow to very deep with shallow soils common to dissected 

uplifts, cuestas, and various upland topographic positions. Deeper soils are most common on 

alluvial fans and fan skirts, floodplains, drainages, pediment surfaces, and rolling uplands. 

Surficial textures are loamy with coarse fragments in the form of channers included in steeper 

and dissected upland soil profiles. Heavy clay textures are not common. The soils are typically 

alkaline with pH values ranging from 6.6 to 9.0. Saline and/or sodic profiles are comparatively 

rare across the project area as a whole, but are locally common as noted below. Available 

water capacities range from very low to high depending upon soil depth and texture, with 

effective rooting depths following a similar pattern. Water erosion hazards range from slight to 

severe with moderate to severe ratings most common. Wind erosion hazards are typically 

moderate or moderate to severe. 

3.4.2 Soil Characteristics by Landform 

The following discussion presents a more detailed discussion of the dominant soil map units 

overlying the landforms that characterize this project area. Moderately steep to steep cuestas, 

dissected uplifts, and rolling uplands are common landforms across the proposed drilling area in 

Section 2 and along the interconnect pipeline and power line ROWs, with slopes ranging from 6 

to 50%. Parent materials include local alluvium and residuum derived from sandstone and 

shale materials. These soils are typically shallow, although moderately deep soils also may 

occur. Available water capacities range from very low to low. Effective rooting depths range 

from 5 to 20 inches over weathered and unweathered bedrock. These soils are characterized by 

slight to severe and moderate to severe water and wind erosion hazards, respectively. Seeding 

efforts would be constrained by shallow soil depths and soil alkalinity. Map unit range sites 

include the Very Shallow, Shallow, Shallow Loamy, Loamy, and Shale types. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-10 
CHAPTER 3: AFFECTED ENVIRONMENT

Table 3-3 Selected Soil Baseline Characteristics of Dominant Soil Map Units 

Map 

Unit # 

Topographic 

Position 

Slope 

(%) Depth (pH) 

Surficial 

Texture(s) 1 Runoff Potential Water Erosion Hazard Wind Erosion Hazard Available Water Capacity 

235 dissected uplifts 6-40 shallow (7.5-9.0) l, cl rapid severe moderate very low 252 

moderately steep to steep cuestas 

10-50 shallow (6.6-9.0) l, cl, chsl rapid severe moderate very low 

253 

rolling uplands, cuesta slopes 

6-40 

shallow to 

moderately 

deep 

(6.6-9.0) 

l, sl, cl, scl medium to slow slight to moderate moderate to severe very low to low 

254 

nearly level to gently sloping uplands 

0-6 

shallow to 

moderately 

deep 

(6.6-9.0) 

sl, l, cl slow to medium slight to moderate moderate to severe low 

257 

floodplains, major drainages 

0-3 very deep (7.9-9.0) l, sl, cl, sil slow moderate moderate to severe High 

258 

alluvial flats and fans skirts 

0-12 

very deep 

to 

moderately 

deep 

(6.6-9.0) 

sl, scl slow slight Severe low to high 

263 alluvial fans 3-15 

very deep 

to 

moderately 

deep 

(6.6-8.4) 

sl slow to medium slight to moderate Severe very low to moderate 

401 steep to very steep sandstone exposures and thin soils rapid severe not rated not rated 

1252 

steep dissected uplands 

10-50 shallow (6.6-9.0) chsl vchsl, l, cl medium to rapid moderate to severe slight to moderate very low to moderate 

3-11 Hanna Draw Coalbed Natural Gas Pilot Project E
CHAPTER 3: AFFECTED ENVIRONMENT

Table 3-3 Selected Soil Baseline Characteristics of Dominant Soil Map Units 

Map 

Unit # 

Topographic 

Position 

Slope 

(%) Depth (pH) 

Surficial 

Texture(s) 1 Runoff Potential Water Erosion Hazard Wind Erosion Hazard Available Water Capacity 

1255 

sloping to steep uplands 

10-40 Shallow (6.6-9.0) sl, chsl, xchl slow to rapid moderate to severe moderate to severe very low to low 

1256 

alluvial fans, pediments, dissected relict surfaces 

2-15 very deep (8.0-9.0) sl - scl slow to medium slight to moderate severe moderate to high 

1260 rolling uplands 2-20 deep (7.4-8.6) sl moderate to high slight to severe moderate moderate to high 2530 sloping uplands 2-10 

shallow to 

moderately 

deep 

(6.6-9.0) 

l, cl, sl, scl slow to medium slight to moderate slight to moderate low to high 

1l = loam; sl = sandy loam; cl = clay loam; sil = silt loam; scl = sandy clay loam; chsl = channery sandy loam; vchsl = ver

xchl = extremely channery loam. 

2Project Facility Occurrence: DA = Drilling Area (Section 2), PL = Power Line, FA = Sec. 35 Compressor Facility, ROW = P

3-12 Hanna Draw Coalbed Natural Gas Pilot Project E
CHAPTER 3: AFFECTED ENVIRONMENT

Sloping to steeply dissected uplands also support shallow soil profiles forming in shallow 

alluvium and residuum derived from interbedded sandstone and shale as well as from tilted 

sandstone beds. Slopes range from 10 to 50%. Available water capacities are very low to 

moderate. The effective rooting depth ranges from 5 to 20 inches over weathered bedrock. 

Water erosion hazards range from moderate to severe and wind erosion hazards range from 

slight to severe. Overlying the “breaks” along the Medicine Bow River and certain southern 

portions of the proposed interconnect pipeline ROW, these soil map units are included in the 

Very Shallow, Shallow Sandy, and Shale range sites. Seeding efforts would be constrained by 

shallow soil depths and alkalinity. 

Shallow to moderately deep soils developing in shale residuum and alluvium over residuum 

derived from interbedded sandstone and shale overlie nearly level to sloping (0 to 10%) 

uplands. These soils occur in association with the proposed drilling area and the southern 

terminus of the interconnect pipeline ROW. Saline profiles are common to the exploration site. 

Available water capacities range from low to high. Effective rooting depths typically range from 

10 to 20 inches, constrained by unweathered bedrock, but may extend to 40 inches or more 

with the deepest soils. A slight to moderate water erosion hazard and a slight to severe wind 

erosion hazard characterize these soils. Seeding efforts would be constrained, on a soil seriesspecific basis, by depth to bedrock, alkalinity, and soil salinity. Range sites to which these soils 

have been assigned include the Impervious Clay and Loamy types. 

Sloping to steeply dissected uplands also support shallow soil profiles forming in shallow 

alluvium and residuum derived from interbedded sandstone and shale as well as from tilted 

sandstone beds. Slopes range from 10 to 50%. Available water capacities are very low to 

moderate. The effective rooting depth ranges from 5 to 20 inches over weathered bedrock. 

Water erosion hazards range from moderate to severe and wind erosion hazards range from 

slight to severe. Overlying the “breaks” along the Medicine Bow River and certain southern 

portions of the pipeline ROW, these soil map units are included in the Very Shallow, Shallow 

Sandy, and Shale range sites. Seeding efforts would be constrained by shallow soil depths and 

alkalinity. Shallow to moderately deep soils developing in shale residuum and alluvium over 

residuum derived from interbedded sandstone and shale overlie nearly level to sloping 

(0 to 10%) uplands. These soils occur in association with the proposed drilling area and the 

southern terminus of the interconnect pipeline ROW. Saline profiles are common to the 

exploration site. Available water capacities range from low to high. Effective rooting depths 

typically range from 10 to 20 inches, constrained by unweathered bedrock, but may extend to 

40 inches or more with the deepest soils. A slight to moderate water erosion hazard and a 

slight to severe wind erosion hazard characterize these soils. Seeding efforts would be 

constrained, on a soil series-specific basis, by depth to bedrock, alkalinity, and soil salinity. 

Range sites to which these soils have been assigned include the Impervious Clay and Loamy 

types. 

Floodplains, drainages, alluvial flats and skirts, and relict surfaces have given rise to moderately 

deep to very deep soils on slopes typically ranging from 0 to 15% with lesser slopes 

predominating. These soil units occur in and along Hanna Draw and in the larger drainages 

crossing the interconnect pipeline ROW. Parent materials consist of sandstone alluvium and 

alluvium from interbedded sandstones, siltstones, and shales. The available water capacity 

ranges from low to high with higher values the norm. Effective rooting depth is typically 

60 inches or more, although lesser depths do occur. The water and wind erosion hazards for 

these soils are slight to moderate and moderate to severe, respectively. Seeding activities may 

be somewhat constrained on portions of this unit due to soil pH. Range sites that these soils 

3-13 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 3: AFFECTED ENVIRONMENT

have been assigned to include the Saline Lowland, Loamy, Shallow Sandy, and Sandy 

classifications. 

Steep to very steep sandstone exposures with thin soil inclusions occur in association with the 

“breaks” topography bordering Hanna Draw and the Medicine Bow River. This unit also occurs 

in isolated areas along the southern portion of the interconnect pipeline ROW. This unit is 

typically about 70% sandstone ledges and associated barren shales with about 30% very 

shallow to shallow soil inclusions. Runoff is rapid and the erosion hazard is severe where soils 

occur. No other descriptive or interpretive information was available for this soil unit. 

3.4.3 Prime Farmlands 

No prime farmland soil units, or soils, occur in Carbon County, Wyoming (Cox 2004). 

3.5 WATER RESOURCES 

3.5.1 Surface Water 

The project area is located within the drainage of the Medicine Bow River, in the North Platte 

River Basin (Figure 3-2). The Medicine Bow River is a prominent perennial drainage flowing in 

a westerly direction north of the project area, eventually discharging into Seminoe Reservoir. 

Runoff from the project area ultimately reaches this river via ephemeral and intermittent 

drainages, including Hanna Draw. Since the proposed Hanna Draw Pilot Project would not 

affect the Medicine Bow River or points downstream, these surface water resources are not 

discussed in detail as part of this baseline summary. 

3.5.1.1 Hydrology 

Surface Water Resources 

The project area is located south of the Medicine Bow River. No perennial water sources occur 

in the immediate project area. Hanna Draw is an intermittent creek entering the Medicine Bow 

west of the project area. Hanna Draw was evaluated by the USGS from 1975 to 1981 at 

Station 06634990. During this period, the creek typically was dry from October through 

January, with a maximum monthly average in March at 2.7 cfs. Peak flows of 79 and 80 cfs 

occurred in 1979 and 1980, respectively, in response to spring rain or snow events. Hanna 

Draw is the receiving water for any runoff than may flow in a westerly direction from the project 

area. 

Missouri John Spring is located near the project area, in T23, R80, S30. This spring is 

intermittent and only flows in wetter years. The spring is located on the south side of the ridge 

draining towards the town of Hanna and does not flow towards or from the project area. Barrel 

Springs is located south of the project area in T23, R80, S27. This spring is located 

downstream of a reclaimed coal mine area and drains to the northwest into Hanna Draw. Both 

springs are located between 3 and 4 miles from Section 2 where the proposed project wells 

would be located. 

Two playas with surface ponds exist in the project area. Runoff from the eastern portion of the 

project area may reach these playas. One playa is located in T23, R81, S12 and has an 

excavated depression in the bottom used seasonally by local ranchers for livestock watering. A 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-14 
CHAPTER 3: AFFECTED ENVIRONMENT

farm pond is located in a small playa (T23, R81, S12) downgradient of the existing reservoir 

located in Section 13. 

The proposed CBNG interconnect pipeline also would cross several drainages that are 

hydrologically distinct from the Medicine Bow River. The initial 7 miles of the pipeline would run 

along Hanna Draw, which is a tributary to the Medicine Bow River. Farther south, the proposed 

pipeline ROW crosses the Big Ditch drainage and Saint Mary’s Creek. Both of these streams 

are intermittent tributaries (Class 4A and Class 3B, respectively) of the North Platte River 

(WDEQ 2001). The Big Ditch is maintained for drainage from area coal mines with a Class 4A 

classification indicating that aquatic life is not a designated use for this stream. 

Existing Reservoir 

The permitted reservoir located in T23N, R81W, E1⁄2 S13 (see Figure 3-2) is dry and has, to 

date, only contained small amounts of produced water and surface water accumulated from 

runoff. It has been constructed at the hydrologic divide between Hanna Draw to the west and 

Pine Draw to the east, and it has a storage capacity of 500 acre-feet. The reservoir is permitted 

by WDEQ as a closed basin, playa, or reservoir with no flow into any waters of the state. The 

reservoir is permitted per SEO Permit #11084, assigned to APC as of April 13, 2004. The 

reservoir is expected to accommodate water storage needs for the produced water 

management program. APC is currently projecting that the initial, maximum daily flow into the 

reservoir would be approximately 40,000 BBL/day, or 2.6 cfs. At this rate of water production, 

the reservoir would take approximately 97 days to fill (excluding evaporation and infiltration). 

The reservoir would be an on-channel reservoir within a class 3 receiving stream, which is 

eventually tributary to a class 2AB perennial water of the state. Authorized uses include aquatic 

life other than fish, recreation, agriculture (livestock watering), wildlife, industry, and scenic 

value. WYPDES permit No. WY0044164 was issued to operator Barrett Resources for this 

reservoir on August 23, 2001. This permit was renewed by WDEQ effective November 28, 

2006 and valid through November 30, 2011. With exception of discharge due to natural 

overtopping during a 50-year/24-hour storm event or greater, the permit does not authorize 

discharge of water from the reservoir. 

The reservoir is designed for 500 acre-feet of storage with 5 feet of freeboard. Reservoir 

storage including the 5 feet of freeboard is 755 acre-feet, which is more than sufficient to 

contain the annual precipitation expected for the area (approximately 36 acre-feet) and the 

estimated runoff from the 25-year storm event (13.2 acre-feet) (BLM 2002a). APC would 

manage delivery of produced water to the reservoir to ensure that the design storage of 500 

acre-feet is not exceeded. 

3.5.1.2 Existing Water Quality 

In 2003 and 2004, APC collected water quality data from Hanna Draw and three additional 

tributaries to the Medicine Bow River upstream of the project area (i.e., Little Medicine Bow 

River, Difficulty Creek, Troublesome Creek). In addition, limited USGS water quality data are 

available for Hanna Draw. Table 3-4 shows the water quality data available for intermittent flow 

in Hanna Draw. The load of dissolved solids is considerably higher than in the Medicine Bow 

River, a pattern commonly recorded for smaller regional streams. These data were likely 

collected during coal mine discharges from the upstream Rosebud Coal Mine. 

3-15 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 

CHAPTER 3: AFFECTED ENVIRONMENT

Associated water quality in regional playa lakes has not been evaluated, but may be expected 

to be elevated in salinity and ionic components relative to surface water streams, as these 

components would be expected to concentrate as a result of ongoing water evaporation. 

Table 3-4 Hanna Draw Baseline Water Quality 

Conductivity 

μS/cm1 

Calcium 

mg/L2 

Magnesium 

mg/L 

Sodium 

mg/L 

Chloride 

mg/L 

TDS 3 

mg/L 

USGS Monitoring Station 06634990 

Period of 

Record 1975 - 1981 

No. 

Observations 

33 32 32 32 32 32 

Average 2239 207 140 175 21 1840 

Minimum 615 60 24 27 4 415 

Maximum 3800 310 240 300 160 3050 

Anadarko Station HDC (Hanna Draw at culvert near mouth) 

Period of Record November 2003 - July 2004 (dry in July 2004) 

No. Observations 8 8 8 8 8 8 

Average 2382 195 105 143 37 1749 

Minimum 464 50 15 23 5 309 

Maximum 4530 293 205 320 121 3500 1

μS/cm = micro siemens per centimeter 2

mg/L = milligram/liter 3 TDS = total dissolved solids 

Coal Mine and Operation 

Upstream of the project area in Hanna Draw is an area of extensive coal mining belonging to 

the Rosebud Coal Sales Company (RCSC). This mining operation has been operational since 

1964, and most locations have since been reclaimed. The mine is currently in the reclamation 

phase, and covers 4,000 acres, once containing 11 pits. The mine employed a technique of 

area strip mining with overburden removal using draglines and scrapers. There is evidence that 

soil health may be affected in some areas of reclamation (Stahl et al. 2003). Discharges 

occurred to Hanna Draw under a WDEQ NPDES permit, principally during the early 1980s. 

Hanna Draw Coalbed Natural Gas Project 

Williams Production RMT Company undertook a CBNG project located south of the current 

project area where 25 wells were authorized, of which 8 wells were installed. The existing road 

infrastructure was built to access these sites, and the permitted reservoir in Section 13 was 

constructed to store the anticipated produced waters. Reclamation of these sites has not been 

finalized. 

Metals with Potential for Bioaccumulation 

The wildlife section discusses those constituents known to bioaccumulate in the terrestrial food 

chain, including mercury, boron, selenium, cadmium and chromium. None of the values 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-17 
CHAPTER 3: AFFECTED ENVIRONMENT

measured in existing wells (Table 3-5) indicate these constituents may be of issue, but not all of 

these constituents were measured in the existing monitoring wells. Water quality in the Williams 

Table 3-5 Metals in Produced Water Samples 

Well ID 2-2 14-35 HD-14 

(2001) 

HD-14 

(2004) HD-1 HD-18 Chronic 

NRWQC2 

Arsenic ND(1) 1 7.7 ND(.1) 7.7 1.1 ND(1) 150 

Boron --- --- 370 --- 110 170 --- 

Cadmium --- 2.3 ND(.1) --- --- 6.2 3 

Chromium --- ND(1) ND(1) --- 8 --- 230 3 

Mercury --- ND(.06) ND(.1) --- ND(.1) --- 0.77 

Selenium ND(5) ND(5) ND(5) ND(?) 7 --- 5 

Units = μg/l 

1

 ND( ) = non detect (detection limit) 

2

 NRWQC = National Recommended Water Quality Criteria

 3 NRWQC at a hardness of 400 

wells may not be representative of water quality in the producing wells, although the water is 

expected to be similar as it originates in the same formation. 

3.5.2 Groundwater 

Groundwater within the project area is present under unconfined conditions in alluvium-filled 

drainages, primarily in the Medicine Bow River valley north of the proposed pilot project area. 

Alluvium within the Medicine Bow alluvium may approach 100 feet thick and contain significant 

water storage. This perennial drainage likely functions as a groundwater recharge and 

discharge boundary. Other shallow groundwater systems generally discharge to local 

drainages and ultimately the Medicine Bow River (Richter 1981). Deeper groundwater is present 

in the Hanna and Ferris Formations within the basin (Lowry et al. 1983; Richter 1981). The 

deeper groundwater exists under semi-confined and confined conditions with potentiometric 

surfaces from aboveground surface to several hundred feet below ground level across the basin 

(Daddow 1986). The range of potentiometric surfaces is largely due to complex interbedded 

nature and structural orientation of the bedrock units. Groundwater is present within fluvial 

sandstones, conglomerates, and fractured coalbeds, which are interbedded with lowpermeablity shales and claystones. Because of the interbedded nature of these formations, 

little vertical migration of groundwater is thought to occur. 

Groundwater recharge occurs along the margins of the basin in the form of infiltration of rain 

and snowmelt into more permeable horizons, the outer edges of the basin, and/or where 

drainages cross aquiferous rocks (Richter 1981). Infiltrated water flows in the direction of the 

bedrock dip or toward the center of the basin. Locally, groundwater flow is likely affected by 

faulting and joint sets, which increase permeability through an increase in fracture density 

(Freeze and Cherry 1979). 

Aquifer characteristics are poorly known across the basin. Aquifer permeability and potential 

water yield tend to be related to rock characteristics and degree of fracturing (Richter 1981). A 

3-18 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 3: AFFECTED ENVIRONMENT

table of permitted wells in close proximity is provided in Appendix C. The majority of these wells 

are related to exploration, monitoring, or dewatering of CBNG or reclamation and monitoring of 

coal mines. Wells with available groundwater information show a range of static water levels 

from artesian (above ground surface) to over 700 feet below ground surface. Most static water 

levels fall between 100 and 300 feet below ground surface. Water yield information for the 

permitted wells is limited, but yields generally range from 2 to 650 gallons per minute (gpm) 

within the proposed Pilot Project area. 

Two water samples (from test Well 14-35 and from Hanna Draw Well 18) have been dated 

using deuterium, tritium (H3), and oxygen 18/16 isotope ratios (tests conducted for APC in 2004 

by the Illinois State Geological Survey laboratories). The results of the analyses are presented 

in Table 3-6. The lack of tritium in groundwater samples from the Pilot Project area is indicative 

of water that has not been in contact with the atmosphere since at least the early 1950s when 

large amounts of tritium were released during atmospheric testing of nuclear devices. The 

isotopic ratios for deuterium and oxygen-18 suggest that the groundwater in the area was 

isolated from the atmosphere during a time of lower mean atmospheric temperatures 

(approximately 10 degrees cooler than present). Temperatures this much lower than present 

are associated with the Pleistocene Epoch, suggesting that the groundwater in the coal seams 

has an age on the order of thousands of years. This age indicates that the groundwater system 

in the target formation moves slowly and is not likely connected closely to surface waters. 

Table 3-6 Isotopic Analysis of Hanna Formation Coal Seam 

 Groundwater 

Well 

Tritium 

Content 

(TU) 

δ 18 O 

VSMOW 

(0/00) 

δ 18 D VSMOW

 (0/00) 

Hanna Draw 18 <0.50 -19.52 -15.3 

Hanna Draw 14-35 <0.50 -18.66 -14.49 

Notes: 

TU - Tritium Unit. One TU is defined as one tritium atom per 1,018 hydrogen atoms. 

VSMOW = Vienna Standard Mean Ocean Water, an international standard used for 

oxygen and hydrogen isotopic analysis. 

(0.00) is per mil or per thousand. 

3.6 FLOODPLAINS 

Low-lying areas adjacent to perennial streams, dry washes, and ephemeral streams in the 

vicinity of the Pilot Project may be subject to periodic flooding. Flood Insurance Rate Maps or 

Flood Hazard Boundary Maps have been developed for portions of the proposed Pilot Project 

area by FEMA. The areas where floodplain mapping has been published by FEMA are along 

the southern portions of the proposed interconnect pipeline ROW where two stream crossings 

(Big Ditch and Saint Mary’s Creek) have been mapped as Zone A (approximate extent of the 

100-year floodplain where flood elevations and flood hazard factors have not been determined). 

Floodplain mapping is not available for the northern portion of the project area, which includes 

Hanna Draw and the Medicine Bow River. Therefore, flood-prone areas adjacent to these 

streams are classified as Zone D (areas of undetermined, but possible, flood hazard). 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-19 
CHAPTER 3: AFFECTED ENVIRONMENT

The Medicine Bow River is located to the north of the Pilot Project and is the only perennial 

stream in the project area. The river flows to the west in a narrow topographic valley where 

flooding is restricted to low-lying areas immediately adjacent to the river channel. Hanna Draw 

is an intermittent tributary to the Medicine Bow River, which flows to the north parallel to a 

portion of the interconnect pipeline. Smaller floodplains occur along Hanna Draw and other 

creeks and washes throughout the Pilot Project area. Flooding in ephemeral drainages is 

generally in response to high-intensity, localized storms. Such storms cause most of the 

floodwater damage, surface erosion, arroyo formation, and sediment deposition in arid and 

semi-arid environments (Branson et al. 1981). Martner (1986) indicated an average of 

40 thunderstorms per year in the vicinity. 

The constructed ditch in the St. Mary’s Creek drainage consists of a narrow, incised channel 

(R4SBJ) with vegetated wetlands (PEM1J) occurring on the low benches to either side. The 

wetlands are dominated by seaside buttercup, Baltic rush, silverweed, and creeping bentgrass. 

Open water features of the project area include small, intermittent drainages, Hanna Draw, and 

its tributaries. The small, intermittent drainages consist of narrow drainages, typically 1- to 

6-foot-high, incised banks. Bed widths generally range from 1 to 3 feet. The beds and banks of 

these drainages range from barely discernable under low flow conditions to strongly developed 

in areas draining larger watersheds. These drainages are subject to intermittent (R4SBJ) or 

seasonal (R4SBC) flooding. Typically, these drainages do not support a fringe of vegetated 

wetlands but transition directly into upland vegetation communities. 

Hanna Draw is the major drainage (to the Medicine Bow River) of the northern project area. 

This drainage is typically incised with extensive terraces and benches located along the channel 

proper. Channel banks typically range from 1 to 4 feet high (discounting terrace and bench 

formations), while bed widths are in the 1- to 3-foot range. Beds and bank features are strongly 

developed, overall. The channel is subject to intermittent flooding (R4SBJ). As noted above, 

vegetated wetlands associated with this drainage and its tributaries are highly variable. 

The Mixed Grass-like/Grass Meadow Community is a wetland community delineated as a 

defined vegetation type. Therefore, it is described below and included as one of the vegetation 

types associated with the proposed project. 

3.6.1 Functioning Conditions/PFC Evaluation of Hanna Draw, St. Mary’s Creek, 

and the Medicine Bow River 

Riparian conditions on public lands along Hanna Draw, St. Mary’s Creek, and the Medicine Bow 

River have been evaluated by the BLM using the following Proper Functioning Condition 

Assessment Process. 

Evaluation Method: 

The primary method used in evaluating this standard is through a qualitative assessment 

procedure called Proper Functioning Condition (PFC). This process evaluates physical 

functioning of riparian/wetland areas through consideration of hydrology, vegetation, and 

soil/landform attributes. A properly functioning riparian/wetland area will provide the following 

elements: 

• Dissipate stream energy associated with high-water flows, thereby reducing erosion and 

improving water quality. 

3-20 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 3: AFFECTED ENVIRONMENT

• Filter sediment, capture bedload, and aid floodplain development. 

• Improve floodwater retention and groundwater recharge. 

• Develop root masses that stabilize streambanks against cutting action (Technical 

Reference 1737-15 1998). 

Overall, most locations along Hanna Draw and St. Mary’s Creek were rated by the respective 

PFC multidisciplinary teams to be “Functioning at Risk” with either a static or downward trend. 

Hanna Draw does rate Proper Functioning Condition at the upper end, where there are less 

impacts from the past mineral exploration. Further downstream, inadequate previous 

reclamation changed the hydrologic nature of the channel causing accelerated vertical and 

lateral adjustments to the channel (approaching the non-functional rating). In addition, permit 

long grazing duration also has contributed to the instability of the system by wet season 

trampling effects. Permit long grazing duration on Hanna Draw, St. Mary’s Creek, and other 

riparian areas also has resulted in reduced vegetation vigor, changes in species composition, 

and changes in overall plant density in some locations. In some cases, these riparian areas are 

drying and losing their riparian vegetative component. The Medicine Bow River near the mouth 

of Hanna Draw was rated “Functioning at Risk” primarily due to vegetation composition and 

associated effects (i.e., weeds). No lentic systems within the Hanna Draw area on public lands 

have been rated. 

When riparian areas are not PFC, the BLM has to make changes to improve riparian condition. 

Livestock grazing duration is addressed through pasture rotation, fencing, and water 

developments. Stream stabilization generally improves as vegetation improves; however, past 

impacts from mineral development also may need to be addressed. 

3.7 VEGETATION 

Project maps based on aerial photos were used to develop a preliminary list of dominant 

vegetation types potentially present across the project area. Following map analysis, the 

vegetation reconnaissance survey was completed from July 12 through July 15, 2004. The 

project area was traversed by two biologists in a vehicle along the roads identified during the 

project map review. Pedestrian surveys also were completed where the proposed project area 

deviated from established roads. Aerial photo interpretation was used in 2005 for portions of 

Section 35. Vegetation was mapped within the entire Section 2 proposed drilling area, the 

proposed compressor facility area, and to a distance of 600 feet on either side of the utility ROW 

centerlines. As the reconnaissance survey proceeded, notes were taken on the project maps 

concerning the dominant vegetation present, vegetation continuums, topography, physiography, 

erosion, and significant features such as rock outcrops, drainages, wetlands, and open water 

bodies. In addition, plant cover values were estimated at representative sample sites to further 

characterize the vegetation types encountered and to gain information on vegetation community 

productivity. The acreage inaccessible by road was viewed through binoculars and the 

vegetation types present estimated based on a comparison of surficial characteristics with the 

areas traversed elsewhere on the project area. Preliminary map unit boundaries were then 

drawn on the field maps. 

Areas of weed invasions, wetlands, and open water features were noted, and GPS coordinates 

were taken. Similarly, areas qualifying as potential habitat for threatened, endangered, and 

sensitive plant species were identified and GPS coordinates noted for future identification. 

Weed infestation and sensitive plant habitat identification surveys were conducted to a distance 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-21 
CHAPTER 3: AFFECTED ENVIRONMENT

of 100 feet on either site of the center points/lines of proposed well sites, access roads, utility 

corridor ROWs, and within the proposed CCF disturbance area in Section 35. 

The data collected in the field were compiled, the dominant vegetation communities were 

identified, and the final vegetation community boundaries were mapped. Vegetation 

communities too small to delineate at final map scale were treated as community inclusions in 

the following discussion. Figure 3-3 depicts the vegetation communities identified and 

described onsite as well as weed concentrations and the locations of potential threatened, 

endangered, and sensitive plant species habitat. 

3.7.1 Dominant Vegetation Communities and Land Types 

3.7.1.1 Wyoming Sagebrush/Mixed Grass Community 

This vegetation community occurs across all project components and is the dominant 

community along the majority of the proposed CBNG interconnect pipeline ROW. Slopes 

typically range from nearly level to moderately sloping, although steeper slopes occur. 

Concave-convex landforms are common and all aspects are represented. The soils supporting 

this community appear to be of a higher productivity than the soils common to the Low 

Shrub/Mixed Grass Community discussed below. 

Wyoming sagebrush (Artemisia tridentata var. wyomingensis) dominates this community with an 

understory composed of a variety of grass species including Sandberg bluegrass (Poa 

secunda), threadleaved sedge (Carex filifolia), green needlegrass (Stipa viridula), Indian 

ricegrass (Achnatherum hymenoides), and western wheatgrass (Pascopyrum smithii ). Hood’s 

phlox (Phlox hoodii) is a commonly occurring forb. Douglas rabbitbrush (Chrysothamnus 

viscidiflorus) also is present as a community inclusion in site-specific areas. Sandberg 

bluegrass is the most common grass species though other species dominate on a site-specific 

basis. Needle-and-thread (Stipa comata) tend to dominate on more sandy soils to the general 

exclusion of most other grass species. Plant cover typically ranges from 30 to >60% with higher 

values the norm. 

Pedestalling and sheetwash were commonly observed across this unit. Vegetation community 

transition zones are narrow to moderately broad with the broadest observed where soil 

characteristics permit a transition to the Low Shrub/Mixed Grass Community. Included in this 

delineation are small, localized areas of the Low Shrub/Mixed Grass Community, as well as 

disturbed areas adjacent to and paralleling County Road 291. Transitioning with both the 

Wyoming Sagebrush/Mixed Grass and Greasewood/Basin Big Sagebrush units, the disturbed 

areas consist primarily of a native and introduced grass/forb community dominated by such 

species as western wheatgrass (Pascopyrum smithii), Sandberg bluegrass, and kochia (Bassia 

sieversiana). Isolated rock outcrops also were observed. 

3.7.1.2 Low Shrub/Mixed Grass Community 

A dominant community in the area of Section 2, this unit also occurs sporadically along the 

proposed interconnect pipeline and distribution line ROWs on upland ridge tops and hillocks, 

dissected side-slopes and similar upland sites. It is not associated with the higher elevations 

and landforms normally occupied by the Mixed Shrub Community. Slopes typically range from 

nearly level to moderately sloping, although more gentle slopes are most common. All aspects 

are represented and the physiography is dominated by convex landforms, although concave 

and concave-convex landforms also occur. Some soils may be saline. This community is 

3-22 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 

CHAPTER 3: AFFECTED ENVIRONMENT

dominated by Gardner saltbush (Atriplex gardneri) and birdfsfoot sagebrush (Artemisia 

pedatifida) with shadscale (spiny) saltbush (Atripex confertifolia) occasionally occurring as a 

sub- or co-dominant. Winterfat (Krascheninnikovia lanata) also was noted as a common 

community inclusion. Dominant understory species include Sandberg bluegrass and 

threadleaved sedge. Plant cover is somewhat low compared to the Wyoming Sagebrush/Mixed 

Grass Community ranging from 20 to 40% with values around 35% most common. 

Soil pedestalling was commonly found in this unit and sheet wash leading, in part, to a gravel 

pavement also was noted. Transition zones associated with this unit are comparatively narrow, 

although they broaden in some instances, as noted above, where bordering the Wyoming 

Sagebrush/Mixed Grass Community. 

Included in this unit are minor drainages supporting greasewood and/or basin big sagebrush, as 

well as isolated meadows dominated by native or introduced grass species. Wyoming 

sagebrush also occurs as an inclusion on isolated rocky slopes and knolls. 

3.7.1.3 Mixed Shrub Community 

This vegetatively diverse unit occurs locally near the proposed CCF and on the smooth slopes 

and broken topography associated with Dana Ridge. Slopes are nearly level to moderately 

sloping at the CCF site and moderately steep to steep along Dana Ridge. The topography is 

typically concave-convex and all aspects are represented. 

Dominant species near the proposed CCF include Wyoming big sagebrush, rubber rabbitbrush 

(Chrysothamnus nauseosis), Gardner saltbush, and Douglas rabbitbrush. Antelope bitterbrush 

(Purshia tridentata), white squaw currant (Ribes cereum), and mountain mahogany 

(Cercocarpus montanus) dominate this community along Dana Ridge. Herbaceous understory 

species vary. Plant cover is highly variable ranging from 20 to >50%. 

Transition zones to adjacent communities are narrow to moderately broad. Both pedestalling 

and sheet wash were noted leading to the formation of a gravel pavement, particularly on more 

steeply sloping sites. 

Isolated rock outcrops at higher elevations and a few deeply incised greasewood/basin big 

sagebrush drainages at lower elevations are included in this unit. 

3.7.1.4 Greasewood and Basin Big Sagebrush Drainages 

This mapping unit has become established along the major and many of the minor drainages of 

the project area. It crosses and, in some cases, parallels the interconnect pipeline, road, and 

power line ROWs. Slopes are nearly level to very gently sloping across concave topographies. 

All aspects are represented. Soil alkalinity and/or salinity levels are presumed to be higher than 

those of the surrounding vegetation communities dominated by Wyoming sagebrush. 

Vegetation characteristics associated with this unit vary. Both greasewood and basin big 

sagebrush dominate this delineation along Hanna Draw. Conversely, the smaller drainages 

located in the project area exhibit vegetation communities dominated by either greasewood or 

basin big sagebrush with varying levels of the sub-dominant species present. Greasewood flats 

also are included in this unit where basin big sagebrush contributes only a minor cover 

percentage. Plant cover values are typically high as is normal for this type unit given soil 

moisture regime considerations and range from 60 to >90%. Understory plant cover is limited, 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-24 
CHAPTER 3: AFFECTED ENVIRONMENT

with Sandberg bluegrass occurring at some sample sites. Crested wheatgrass also was noted 

in one drainage. 

Sheet wash was observed in some drainages, but severe pedestalling was typically lacking. 

Transition zones to other vegetation communities characteristically range from abrupt to 

moderately broad, depending upon side-slope angles, though wider zones do occur in 

association with greasewood flats. 

Included in this unit, on a site-specific basis, are minor drainage channels and their associated 

narrow grass/forb terraces along with limited wetland fringe communities. 

3.7.1.5 Mixed Grass-like/Grass Meadow Community 

Sufficiently large to depict on the vegetation community map, this wetland community (PEMC) is 

discussed in this section as a defined vegetation type. This community is located in the 

southern portion of Hanna Draw within the project area along the proposed interconnect pipeline 

and power line ROWs (see Figure 3-3). Slopes are primarily nearly level across a concave 

topography. A northerly aspect predominates. 

Herbaceous species dominate this diverse community, with Nebraska sedge (Carex 

nebrascensis), Baltic rush (Juncus balticus), meadow barley (Hordeum brachyantherum), and 

silverweed (Potentilla anserina) commonly occurring. A variety of other species, including 

common plantain (Plantago major), spikerush (Eleocharis sp.) and creeping bentgrass (Agrostis 

stolonifera) also are present. Plant cover values are high, typically ranging from 95 to 98%. 

The soil surface was observed to be stable. Transition zones to adjacent communities are 

typically abrupt to very narrow given the hydrologic constraints associated with this type of 

vegetation community. 

A narrow to moderately wide band of the Greasewood/Basin Big Sagebrush community exists 

as a border between this community and adjacent communities. 

3.7.1.6 Reclaimed Grass Community 

This vegetation unit includes disturbances associated with past mining activities where 

reclamation techniques have been employed and is limited in extent across the project area. 

Slopes are nearly level to very gently sloping with a concave-convex topography. 

Crested wheatgrass (Agropyron cristatum var. desertorum) along with western wheatgrass 

dominate this community. Indian ricegrass and Lewis flax (Linum lewisii) are notable 

community inclusions in some areas. Plant cover typically ranges from 25 to 40%, with values 

approximating 30% most common. 

Minor pedestalling was noted on an otherwise stable soil surface. Transition zones to adjacent 

communities were abrupt to narrow. 

3.7.1.7 Rockoutcrop/Broken Land/Miscellaneous Land Types 

Occurring intermittently across the project area, this unit is characterized by sandstone rock 

outcrops, surface rock exposures, and weathered geologic formations typified by little to no soil, 

high surficial coarse fragments, and comparatively sparse vegetation. Slopes are moderately 

3-25 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 3: AFFECTED ENVIRONMENT

steep to very steep on all aspects. The Wyoming Sagebrush/Mixed Grass Community may 

occur as an inclusion in this land type. 

3.7.2 Upland Vegetation Health Evaluation 

The upland vegetation southwest of the Pilot Project was determined to not meet Rangeland 

Health Standard 3 on public lands. Reclamation with introduced species and a predominance 

of herbaceous rather than a mix of shrub/herbaceous components was identified by the 

assessment team. In addition, Basin big sagebrush and Wyoming big sagebrush communities 

in the area are comprised of mature to decadent dense stands of sagebrush with little to no 

diversity in types. This holds true for the entire area from the Pilot Project as well as along the 

proposed interconnect pipeline and power line routes. Loss of sheep grazing in the area, and 

permit long grazing has favored shrub dominance. As grazing distribution and duration is 

addressed, herbaceous communities will improve. In addition, many of these areas have been 

identified for vegetative diversification to improve age and cover class variability thereby 

improving habitat for wildlife species dependent on sagebrush communities. 

3.7.3 Non-native Invasive (Weed) Species 

Of the 25 noxious weeds listed in Table 3-7, 24 plant species are either designated or prohibited 

noxious weeds in the State of Wyoming. Any large populations (infestations) of these weeds 

observed during the July 2004 vegetation surveys were noted and GPS coordinates taken. The 

locations of these weed populations identified during the field review are depicted on Figure 3-3. 

Lesser noxious weed levels also were noted. Halogeton (Halogeton glomeratus) is declared a 

noxious weed in Carbon County with larger populations of this weed also noted in the field for 

inclusion in this document. 

Weed infestations were limited within the project area, confined primarily to roadside 

disturbances and along wetter drainages such as Hanna Draw. Weed populations also were 

noted along the borders of some disturbed areas that were previously revegetated. Weed 

populations were not typically found within healthy, undisturbed, upland native vegetation 

communities upslope from drainages. Weed populations established along roadsides and 

drainages commonly took a linear form following disturbance configurations and runoff/natural 

drainage flow patterns. 

State-declared noxious weed species found as larger populations in the field included whitetop 

(Cardaria draba), Canada thistle (Cirsium/Breea arvense), and Dalmation toadflax (Linarea 

dalmatica). Whitetop was the most common weed species encountered during the field 

surveys. This species was found along roadsides in Section 2 and County Road 291, as well as 

similar disturbed areas, in drainages, and across drainage terraces and benches. Whitetop also 

was found, although to a limited degree, along the banks of the Medicine Bow River. It is one of 

the few weed species that appears to be successful in invading established, native shrub 

communities, although this seems to occur only in association with enhanced soil moisture 

regimes such as along drainages. Whitetop was not commonly observed in drier upland sites. 

Whitetop populations along roadsides, as may be expected, assumed a narrow, linear form and 

may reach 300 feet in length, although lesser lengths are generally the norm. Populations 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-26 
CHAPTER 3: AFFECTED ENVIRONMENT

Table 3-7 Designated or Prohibited Noxious Weeds Occurring or Potentially 

Occurring In the Project Area 

Common Name Scientific Name Common Name Scientific Name 

Field bindweed Convolvulus 

arvensis Common burdock Actium minus 

Saltcedar Tamarix sp. Dyers woad Isatis tinctoria 

Leafy spurge Euphorbia esula Houndstongue Cynoglossum officinale 

Perennial sowthistle Sonchus arvensis Purple loosestrife Lythrum salicaria 

Quackgrass Agropyron repens Skeletonleaf bursage Franseria discolor 

Hoary cress or 

whitetop 

Cardaria draba and 

C. pubescens 

Common tansy Tanacetum vulgare 

Perennial 

pepperweed or giant 

whitetop 

Lepidium latifolium Spotted knapweed Centaurea maculosa 

Russian knapweed Acroptilon repens Plumeless thistle Carduus acanthoides 

Diffuse knapweed Centaurea diffusa Canada thistle Cirsium/Breea arvense 

Yelowtoadflax Linaria vulgaris Scotch thistle Onopordum acanthium 

Dalmation toadflax Linaria dalmatica Musk thistle Carduus nutans 

Common St 

Johnswort 

Hypericum 

perforatum Halogeton Halogeton glomeratus 

Ox-eye daisy 

Leucanthemum 

vulgare 

present on drainage terraces and banks, as well as drier drainages, may range from small 

isolated patches to infestations up to 200 feet long. This species can serve as a notable 

community component in some isolated areas. 

Canada thistle populations were found at one site in Hanna Draw along County Road 291 and 

where the proposed CBNG interconnect pipeline crosses Big Ditch. These populations occurred 

under more mesic soil moisture regime conditions. Dalmation toadflax was observed at one site 

along the proposed transmission corridor near County Road 291. 

Populations of two additional noxious weed species are currently known to exist within or 

adjacent to the project area but were not observed within the survey area at the time of the July 

2004 fieldwork. Leafy spurge (Euphorbia esula) has been observed along the banks of the 

Medicine Bow River and upslope to within 200 yards of the southern riverbank in Sections 34 

and 35 to the north of the proposed project access road. Similarly, Russian knapweed 

(Acroptilon repens) has been noted along the proposed access road to Section 2 and also along 

the Medicine Bow River to the north of the proposed disturbances located in Sections 34 

and 35. 

Halogeton occurs along numerous roadside disturbances, notably in Section 2. Populations of 

this Carbon County–designated noxious weed species were typically limited to road shoulders 

3-27 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 3: AFFECTED ENVIRONMENT

and adjacent disturbed soils. This species was not observed to have escaped to any degree 

into adjacent, mature, native vegetation community types. 

With respect to invasive weed species not listed as noxious, Russian thistle (Salsola iberica) 

also was observed to inhabit roadside disturbances. However, this species was less common 

than halogeton in this respect. Cheatgrass (Bromus tectorum) is present in the project area and 

is found sporadically on disturbed areas in upland situations. It may occasionally occur in the 

understory of more mature shrub communities but is not typically a dominant species. This 

species is not usually supported by soils exhibiting wetter moisture regimes or found associated 

with wetland conditions. Curley-cup gumweed (Grindelia squarrosa) also is present in upland 

range communities and along roadside disturbances forming a notable community component 

in some areas. Drought resistant, this species increases under droughty conditions. 

Babysbreath (Gypsophila paniculata) is known to occur onsite along county road disturbances 

in or adjacent to the project area. 

3.7.4 Wetlands and Riparian Areas 

Vegetated wetlands occur across the project area primarily in connection with intermittent 

drainages (including Hanna Draw). Two vegetated wetlands also were found associated with 

constructed stock ponds, while several small wetlands have developed adjacent to and within a 

constructed diversion ditch in the St. Mary’s Creek drainage. 

Vegetated wetlands that have formed in intermittent drainages (PEM1C, PEM1D, PEM1E, 

PEM1J) occur in the drainage bottoms or across the adjacent benches and terraces where such 

have formed. Typical vegetated wetlands associated with Hanna Draw are dominated by a 

variety of species including Nebraska sedge (Carex nebrascensis), Baltic rush (Juncus 

balticus), meadow barley (Hordeum brachyantherum), and silverweed (Potentilla anserina) as 

noted previously for the Mixed Grass-like/Grass Meadow Community. Other species occurring 

with regularity include common plantain (Plantago major), spikerush (Eleocharis sp.), and 

creeping bentgrass (Argostis stolonifera) in soils with more variable soil moisture regimes. 

Where soils trend toward higher alkalinities and/or salinities, small-flowered sumpweed (Iva 

axillaris) has become established. 

One stock pond, fed by a small drainage, is characterized by a central flooded zone (PEM1F) 

supporting a near mono-typic stand of cattails (Typha latifolia). This zone transitions to a variety 

of soil moisture regimes supporting a border dominated by spikerush, Nebraska sedge, 

creeping bentgrass, foxtail barley, meadow barley, and Baltic rush, depending upon soil 

moisture regime. A second stock pond-associated wetland was found upslope from the stock 

pond proper within the associated drainage. Exhibiting a somewhat drier soil moisture regime, 

this vegetated wetland occurs in a mosaic with upland plant communities. Dominant species 

include creeping bentgrass, foxtail barley, Baltic rush, inland saltgrass, alkali muhly 

(Muhlenbergia asperfolia), and sedge (Carex) species. The soils of this wetland appear to be 

saline. 

A number of vegetated wetlands have developed along and adjacent to the crossing at St. 

Mary’s Creek. Vegetated wetlands established in old creek oxbows (PEM1U) appear to be 

remnant communities and are drying. Species inhabiting these oxbows include Baltic rush and 

small-flowered sumpweed. The soils appear to be saline in nature. Wetlands of the adjacent 

channels (PEM1J, PEM1Y) vary according to soil moisture regime characteristics, but are 

wetter than the oxbows located upslope. These wetlands support wetland plant communities 

somewhat similar to those of the oxbows but at notably higher cover rates, or a more 

salt-tolerant grouping where saturated, saline soils predominate. In the latter case, red saltwort 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-28 
CHAPTER 3: AFFECTED ENVIRONMENT

(Salicornia rubra), small-flowered sumpweed, foxtail barley, alkali muhly, and Baltic rush 

dominate. 

3.8 TERRESTRIAL WILDLIFE 

3.8.1 Habitat 

The terrestrial wildlife resources commonly associated with the Hanna Draw Pilot Project area 

encompass a variety species commensurate with the native and reclaimed habitats, relative 

carrying capacities of these habitats, and the degree of existing disturbance from past coal 

mining and petroleum exploration and development. It should be noted that many reclaimed 

habitats may not return to their original state due to weed invasion, erosion, etc. Reclaimed 

habitats that are degraded from original conditions are often not suitable for wildlife use due to 

the change in species/forage composition. 

Section 3.7 summarizes the dominant vegetation recorded within the project area, including 

general terrain, physiography, erosion, significant topographic features such as rock outcrops 

and drainages, and noxious weeds. Pertaining to wildlife, the dominant plant community in the 

immediate project area of Section 2 is the Wyoming Sagebrush/Mixed Grass Community. This 

habitat type supports a variety of terrestrial wildlife species, including common species such as 

mule deer, pronghorn, bobcat, coyote, prairie dogs, raptors, upland game birds, and greater 

sage-grouse. Sagebrush is a critical year-round food and habitat component for sage-grouse, 

as well as high-value winter forage for mule deer and pronghorn antelope. Other special status 

terrestrial wildlife species are discussed in Section 3.10.2. 

The localized areas of the Low Shrub/Mixed Grass Community, Greasewood/Basin Big 

Sagebrush Community, and small grassland meadows provide greater habitat diversity and a 

mosaic of upland habitats for area wildlife. Increased species’ diversity would be particularly 

apparent along the narrow drainages containing basin wildrye, basin big sagebrush, and 

greasewood with isolated rock outcrops, transitioning into the upland sagebrush benches and 

ridges. 

Section 3.6 summarizes the vegetated wetlands and open water features occurring within the 

Hanna Draw Pilot Project area. Wet meadows, wetland areas, and the mesic interface with the 

upland communities provide a greater habitat diversity for terrestrial vertebrate and invertebrate 

species than the surrounding upland habitats. Available water is one of the most valuable 

habitat features for regional wildlife species. In the arid west, these riparian areas consist of a 

relatively small proportion of the landscape, but are used by wildlife at some portion of their life 

history to a much greater degree than other, more predominate habitats. In addition to food, 

water and shelter, these habitats are often utilized as travel corridors (dispersal and migration) 

within the landscape. As discussed in Sections 3.5, 3.6, and 3.7, these features within the 

project area include small, intermittent drainages, such as Hanna Draw and its tributaries, and 

the perennial Medicine Bow River. Typically, the intermittent or ephemeral drainages do not 

support a fringe of vegetated wetlands but transition directly into upland vegetation 

communities, whereas, the Medicine Bow River’s adjacent shoreline supports vegetated 

wetlands that are seasonally flooded. 

The predominant plant community along the proposed CBNG interconnect pipeline corridor and 

electric distribution line ROW is the Wyoming Sagebrush/Mixed Grass Community interspersed 

with areas of the Low Shrub/Mixed Grass Community along upland ridges and side-slopes. The 

Greasewood and Basin Big Sagebrush Drainages also intersect and parallel these proposed 

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CHAPTER 3: AFFECTED ENVIRONMENT

alignments, as shown on Figure 3-3. Small, isolated wetlands associated with the Mixed 

Grass-like/Grass Meadow Community occur along these ROWs (see Sections 3.6 and 3.7.1.5). 

The reclaimed grasslands in the previously mined areas along the proposed pipeline corridor 

would provide a lower habitat diversity to area wildlife than the upland shrub/grass communities; 

however, it appears that these reclaimed areas are recovering well, albeit they are more 

homogenous. 

The following information is a summary of terrestrial wildlife resources either documented or 

anticipated to occur in and near the proposed project. This area encompasses the proposed 

drilling sites, CCF, access roads, gas gathering lines, water disposal lines, the interconnect 

pipeline, and ancillary electric distribution line corridor. 

3.8.2 Big Game Species 

Big game species documented to occur in the Hanna Draw Pilot Project region primarily include 

pronghorn and mule deer, although isolated occurrences of white-tailed deer and moose have 

been reported along the Medicine Bow River and other regional riparian corridors and 

tributaries. Elk are not known to occur in the immediate project area, but do occupy suitable 

habitats north and south of the project region. Specific big game seasonal ranges are integral 

to these animals’ survival and movement patterns. The primary seasonal range addressed in 

this analysis is crucial winter range for both pronghorn and mule deer, although other seasonal 

range information also has been provided, when available. 

Figure 3-4 depicts seasonal ranges for pronghorn in and near the project region; Figure 3-5 

provides a detailed overview of pronghorn seasonal ranges relative to the proposed drilling area 

in Section 2 and the immediate surrounding area. Although pronghorn typically occupy a large 

extent of the upland grasslands and sagebrush steppe, designated crucial winter/yearlong 

range for pronghorn encompasses a portion of Section 2 in the proposed drilling area, the 

farthest northern portion (approximately 2 miles) of the proposed interconnect pipeline and 

electric distribution line ROWs, and the southern terminus (about 1 mile) of the interconnect 

pipeline. 

The majority of the proposed CBNG interconnect pipeline would cross pronghorn 

winter/yearlong range (WNDDB 2004). Pronghorn in this area belong to the Medicine Bow 

Herd, Herd Unit #525. 

Figure 3-6 shows the seasonal ranges for mule deer and white-tailed deer and isolated 

occurrences of white-tailed deer outside of its winter range for the project region, including the 

proposed interconnect pipeline. Figure 3-5 provides more detailed information for mule deer 

seasonal ranges for the immediate project area. As shown, a portion of the proposed drilling 

area in Section 2 intersects with mule deer winter/yearlong range, in addition to the proposed 

CCF located to the north in Section 35, a majority of the electric distribution line and 

approximately 8 miles of the proposed interconnect pipeline ROW on its northern end. Mule 

deer crucial winter/yearlong range extends immediately north of the Medicine Bow River. The 

only project component that intersects with mule deer crucial winter/yearlong range is 3 miles of 

the pipeline route near its southern terminus. Mule deer occur in much of the upland habitats 

and along the riparian corridor along the Medicine Bow River. Browse for foraging and thermal 

protection in the winter are key to mule deer use and survival. East of Hanna Draw, mule deer 

are part of the Shirley Mountain Herd, Herd Unit #540; west of Hanna Draw, it is the Platte River 

Herd, Herd Unit #541. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-30 
CHAPTER 3: AFFECTED ENVIRONMENT

Crucial range can describe any particular seasonal range or habitat component often the 

determining factor in a population's ability to maintain itself at a certain level over the long term 

(Wyoming Chapter of the Wildlife Society 1990). Crucial winter/yearlong range is defined as 

suitable habitat that has is used by a population or portion of a population of animals on a 

year-round basis, but during the winter months (commonly between December 1 and April 30), 

there is a “significant influx” of additional animals into the area from other seasonal ranges 

(Wyoming Chapter of the Wildlife Society 1990; WGFD 2004a). Crucial winter range (in this 

instance for big game species), is commonly referred to as a “limiting factor” for big game 

populations, in that their populations can be limited by the amount, quality, and lack of 

disturbance factors on these critical areas. 

Overall, the herd health for both pronghorn and mule deer is considered to be good, and 

populations are stable or increasing in specific areas. However, vegetative conditions in certain 

portions of these two big game species’ winter ranges are not optimal because of extended 

drought and older decadent shrub conditions (Lanka 2005). Animal densities vary throughout 

these ranges. 

Two other big game species have are known to occur near the project region, as shown in 

Figure 3-7. Elk occur north and south of the project area, and designated elk winter/yearlong 

range extends from near the southern terminus of the proposed interconnect pipeline east. No 

project components intersect with this elk range; however, the Shirley Mountain Herd Unit #16 

occurs north of Highway 30. Winter range for moose also occurs south of the project region, but 

individuals are not expected to occur in the immediate project area, based on this species’ 

habitat associations with dense riparian willow corridors and mature wetlands. 

3.8.3 Upland Game Birds, Waterfowl, and Other Waterbirds 

The project area occurs in the Small and Upland Management Area #22. The predominant 

upland game bird species in the project area is the greater sage-grouse. Sage-grouse are 

classified as a BLM sensitive species and are discussed in Section 3.10.2. Chukar partridge 

and gray (Hungarian) partridge may occur in low numbers; however, both chukar and gray 

partridge populations fluctuate depending on climatic and vegetative conditions. As range 

conditions improve with increased precipitation, their populations expand. In comparison, the 

effects from the continuing drought in the western U.S. continue to shrink these game bird 

distributions (Rothwell 2004). Therefore, if present, it is assumed that population numbers are 

low. 

Waterfowl and other waterbirds would primarily be associated with the Medicine Bow River 

corridor, adjacent wetlands, Seminoe Reservoir, isolated playas, and livestock ponds (BLM 

2001a, 2002a). Figure 3-8 depicts the general areas where waterfowl have been recorded in 

and near the Proposed Action. Other water birds (e.g., wading birds and shorebirds), also have 

been documented, but these occurrences are sporadic throughout the region. Common 

waterfowl species would include the mallard, Canada goose, American coot, green-winged teal, 

blue-winged teal, northern pintail, northern shoveler, American wigeon, ring-necked duck, and 

gadwall (BLM 2002a; WNDDB 2004). WGFD conducts aerial surveys for nesting Canada 

geese in the project area. These breeding surveys are the only waterfowl surveys flown along 

this reach of the Medicine Bow River and occur in April; however, they are not conducted every 

year for the project area (Roberts 2004). 

3-31 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 





CHAPTER 3: AFFECTED ENVIRONMENT

Representative waterbirds (also associated with available water resources), would include the 

Clark’s grebe, great blue heron, snowy egret, black-crowned night heron, American white 

pelican, killdeer, American avocet, white faced ibis (a BLM sensitive species), and spotted 

sandpiper (BLM 2002a; WNDDB 2004). As shown in Figure 3-8, reported bird occurrences of 

water-dependent species are scattered throughout the region. Lentic waters (i.e., nonflowing 

wetlands, ponds, reservoirs, playas) are more important to migratory birds, as compared to lotic 

waters (i.e., flowing streams, Medicine Bow River) (Roberts 2004). However, it is assumed that 

waterfowl and water birds would capitalize on any available surface water in the region. 

3.8.4 Raptors 

A number of raptor (i.e., birds of prey) species breed and winter in the project region, as 

depicted on Figure 3-9, which provides data on known raptor nest sites. Numerous nest sites 

for golden eagles, ferruginous hawks, and prairie falcons occur throughout the area (Oakleaf 

2004). Wintering and migrating bald eagles may forage along the Medicine Bow River and 

adjacent uplands downstream to Seminoe Reservoir. Bald eagles are discussed further in 

Section 3.10.2. Breeding buteos (i.e., hawk species) include the ferruginous hawk, (a BLM 

sensitive species), red-tailed hawk, and Swainson’s hawk. Falcons known to breed in the area 

include the prairie falcon and American kestrel (WNDDB 2004). Accipters (forest-dwelling 

hawks) are not as common in the open sagebrush-dominated habitats of the project area, 

although foraging or migrating individuals may move through the region, including the 

sharp-shinned hawk, Cooper’s hawk, and an occasional goshawk. Owl species that would 

occur in the project area include the great horned owl, burrowing owl, (a BLM sensitive species), 

barn owl, long-eared owl, and short-eared owl along the wet meadows and adjacent wetlands in 

the region. Other raptors include breeding northern harriers and turkey vultures and wintering 

rough-legged hawks (WNDDB 2004; BLM 2001a, 2002a). 

Breeding raptors may nest on or in a variety of substrates, including cliff faces, rock outcrops, 

both deciduous and conifer trees, ground burrows, and manmade structures (e.g., windmills, 

artificial nest structures). The relative open nature of the project region increases the habitat 

value of vertical structures (both natural and manmade) that provide nest sites, roosts, and 

foraging perches. Breeding raptors typically defend specific home territories, which vary in size, 

depending on the bird species. Within this territory, a breeding pair may occupy or tend one or 

more nest sites. Many raptor species alternate among nest sites within their breeding territories 

from year to year. The species-specific information shown in Figure 3-9 may represent 

alternate nest sites within an individual territory, and nests that may be unoccupied or inactive 

one year may become active in subsequent years. 

All raptors are protected under the Migratory Bird Treaty Act (MBTA), both eagle species are 

protected under the Bald and Golden Eagle Protection Act (BGEPA), and the bald eagle is 

protected under the Endangered Species Act (ESA), which is discussed in detail in 

Section 3.10.2. In accordance with these Acts, any “take” of active nest sites (containing eggs 

or young), injury or death to individual birds, or harassment of breeding birds resulting in nest 

abandonment (BGEPA and ESA only) would be a federal violation. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-37 
CHAPTER 3: AFFECTED ENVIRONMENT

3.8.5 Other Birds, Mammals, Amphibians, and Reptiles 

The habitat diversity found among the upland sagebrush steppe, mixed shrublands, reclaimed 

grasslands, rocky outcrops and cliffs, wetlands, and area streams corridor supports a wide 

variety of other terrestrial wildlife species. These nongame terrestrial wildlife species reflect the 

mosaic of habitats and habitat interfaces. 

Other representative mammal species that occur in the project region include the coyote, 

mountain lion, bobcat, badger, long-tailed weasel, striped skunk, raccoon, black-tailed 

jackrabbit, desert cottontail, white-tailed prairie dog, and a variety of small mammals including 

the thirteen-lined ground squirrel, northern pocket gopher, least chipmunk, deer mouse, and 

bushy-tailed woodrat (BLM 2002a). Although these representative predator and prey species 

characterize mammalian presence in the region, certain species, such as the white-tailed prairie 

dog and ground squirrel species are considered to be a key prey species for a wide variety of 

predators. Prairie dog colonies generally concentrate use by predators (e.g., ferruginous hawk, 

red-tailed hawk, bald eagle, golden eagle, coyote, black-footed ferret, potentially the swift fox (a 

BLM sensitive species), and other associated species (burrowing obligates), such as mountain 

plover, burrowing owl, and rattlesnake species. Prairie dogs are discussed further in 

Section 3.10.2 for special status species. 

Representative bird species not already mentioned for the project region include the Say’s 

phoebe, western kingbird, horned lark, black-billed magpie, common raven, vesper sparrow, 

mountain bluebird, lark bunting, red-winged blackbird, common grackle, and Brewer’s blackbird 

(BLM 2002a; WNDDB 2004). 

Area amphibian and reptile species would be range among the different habitat types. 

Amphibians are limited to aquatic habitats, but primarily along the Medicine Bow River and its 

tributaries that support perennial or more regular intermittent sources. Representative 

amphibians include the tiger salamander, northern leopard frog, and chorus frog. Reptiles 

would include eastern short-horned lizard and northern sagebrush lizard, and rattlesnakes and 

bull snakes tend to be wide ranging and may be found throughout the upland and riparian 

habitats. Garter snakes tend to be more prevalent in the riparian areas (BLM 2001a, 2002a). 

3.9 AQUATIC BIOLOGY 

The aquatic habitats within and downstream of the project area are detailed in Section 3.5.1. 

The existing constructed reservoir located in Section 13 (see Figure 3-2) is currently dry and, 

therefore, does not support aquatic resources. 

Although the existing reservoir is generally dry, during wet periods (primarily during the spring 

season), standing water from snowmelt and rains may result in an ephemeral aquatic 

community present. This community consists of species adapted to opportunistic exploitation of 

ephemeral aquatic resources, including planktonic species, aquatic insects, and frogs. The 

ephemeral water supply serves as a resource permitting development of larval and juvenile 

stages of many of these species. The existing reservoir would not contain any resident or 

permanent aquatic community. 

3-38 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 

CHAPTER 3: AFFECTED ENVIRONMENT

3.10 SPECIAL STATUS SPECIES 

3.10.1 Plants 

Three threatened and one endangered plant species are known to occur in the general project 

region, while seven species classified as BLM “sensitive,” also occur (BLM no date). In addition, 

two species of special concern in the State of Wyoming have been previously identified for the 

project region (Handley 2004). Table 3-8 presents selected information, including habitat 

characteristics, for each of these special status plant species. The locations of habitats 

marginally suitable or suitable for supporting species potentially present on site are depicted on 

Figure 3-3. 

3.10.1.1 Threatened and Endangered Species 

The three threatened plant species include the Ute ladies’-tresses orchid (Spiranthes diluvialis), 

Colorado butterfly plant (Guara neomexicana ssp. coloradensis), and the desert yellowhead 

(Yermo xanthocephalus). The Ute ladies’-tresses orchid and the Colorado butterfly plant both 

occur in association with wetlands at comparatively lower elevations. Desert yellowhead is 

considered endemic to Fremont County and occurs on barren outcrops of white silty clays of the 

Split Rock Geologic Formation at a known elevation of 6,700 feet. The designated Critical 

Habitat for this species occurs only in Fremont County. The endangered blowout (Hayden’s) 

penstemon (Penstemon haydenii) grows on actively shifting sand dunes and blowouts created 

by wind action out of sandy substrates. This species is associated with the Ferris/Seminoe 

Mountain region in Wyoming. 

Marginally suitable habitat was found for the Ute ladies’-tresses orchid and the Colorado 

butterfly plant within Hanna Draw in the Mixed Grass-like/Grass Meadow Community. However, 

the potential presence is questionable, given the lack of a typical sub-irrigated meadow 

landform surrounded by a mixed grass prairie community with which this species is typically 

associated. The remaining wetlands observed during the field survey failed to qualify as habitat 

due to a drier soil moisture regime or a propensity to flood, high soil salinity, and/or dense 

vegetation. No habitat suitable for supporting blowout penstemon or desert yellowhead was 

observed during the vegetation field surveys completed for this project. 

3.10.1.2 Sensitive Plant Species 

Seven plant species occurring within the region of the Hanna Draw Pilot Project area are 

considered “sensitive” by the BLM. These species occur in a wide variety of habitat types from 

wetlands, to sparsely vegetated shale or sandy-clay slopes, to granite boulders, cliffs, and 

limestone ridges. These species occur across a wide range of elevations from 4,300 to 

9,600 feet. The majority of these species, however, occur within a range of from 5,000 to 

7,500 feet. Two species, Laramie columbine (Aquilegia laramiensis) and Cedar rim thistle 

(Cirsium aridum), are considered endemic to counties other than Carbon County. 

Habitat considered marginally suitable or suitable for supporting one BLM sensitive plant 

species, persistent sepal yellowcress (Rorippa calycina), was observed within the project area 

during the field surveys completed. Suitable habitat for this species consists of riverbanks and 

lake shorelines exhibiting muddy or sandy soils. Historically, it has been found to exist on both 

the North Platte and Medicine Bow River arms of Seminoe Reservoir (Dutcher 2004). This 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-40 
CHAPTER 3: AFFECTED ENVIRONMENT

Table 3-8 Special Status Plant Species 

Species Name Organization Listing 1 Status 2 Elevation Range (feet) Habitat Characteristics/Comments 

Colorado butterfly plant Guara neomexicana ssp. coloradensis 

USFWS T 5,700 - 6,400 Subirrigated alluvial soils of drainage bottoms surround

by mixed prairie 

Blowout penstemon Penstemon haydenii USFWS E NI Actively shifting sand dunes, blowout depressions; know

from Ferris/Seminoe Mountains region 

Ute ladies’-tresses orchid Spiranthes diluvialis USFWS T 5,100 - 5,200 Moist streambanks, wet meadows, and abandoned stre

channels 

Desert yellowhead Yermo xanthocephalus USFWS T 6,700 Barren outcrops of white silty clay of Split Rock Formation; endemic to Fremont Co. Laramie columbine Aquilegia laramiensis BLM S 6,400 - 8000 Crevices of granite boulders and cliffs; endemic to Albany and Converse counties Nelsons milkvetch Astragalus nelsonianus BLM S 5,200 – 7,600 Alkaline clay flats, shale bluffs and gullies, pebbly slopes, volcanic cinders in sparse vegetation Cedar rim thistle Cirsium aridum BLM S 6,700 - 7,200 

Barren, chalky hills, gravelly slopes and fine-textured, sandy/shaley draws; endemic to Fremont and Sublette Counties 

Webber’s scarlet-gilia Ipomopsis aggregata ssp. weberi 

BLM S 8,500 - 9,600 Openings in coniferous forests and scrub oak woodland

Gibbons beardtongue Penstemon gibbensii Yellowcress 

BLM S 5,500 - 7,700 Sparsely vegetated shale or sandy-clay slopes 

Persistent sepal yellowcress Rorippa calycina BLM S 4,300 – 6,800 Riverbanks and shorelines, usually on sandy soils near high waterline; more common near Seminoe Reservoir Laramie false sagebrush Sphaeromeria simplex BLM S 7,500 – 8,600 Cushion plant communities on rocky limestone ridges a

gentle slopes 

Bedstraw milkweed Asclepias subverticillata WNDDB SC ~ 6,800 Roadsides and other disturbed sites; last observed in Wyoming in 1947 Ward’s goldenweed Oonopsis wardii WNDDB SC 5,460 – 7,200 Selenium – rich, shale – clay slopes, barren plains and disturbed roadsides; areas of low vegetation cover 

1USFWS = U.S. Fish and Wildlife Service; BLM = Bureau of Land Management; WNDDB = Wyoming Natural Diversity Databa2T = Threatened plant species; E = Endangered plant species; S = Sensitive plant species; SC = Wyoming Species of Concer3NI = No information Sources: BLM (no date); Fertig 1994; Handley 2004; WNDDB 2004 

3-41 Hanna Draw Coalbed Natural Gas Pilot Project E
CHAPTER 3: AFFECTED ENVIRONMENT

species was not observed during the surveys completed in 2004. This species is not present 

within the boundaries of the project area. Other project area wetlands failed to qualify as habitat 

for this species due to the lack of shoreline landforms exhibiting a muddy or sandy substratum 

near the high water line. 

The breaks located south of the Medicine Bow River include exposed clay-shale slopes and 

associated toeslope positions paralleling County Road 291 in Hanna Draw. This habitat was 

initially considered as potentially marginally suitable for the Nelson’s milkvetch (Astragalus 

nelsonianus) and Gibbon’s beardtongue (Penstemon gibbensii). Selected habitats areas were 

searched for the presence of plants of the Astragalus and Penstemon genera. None was found 

and it was concluded that are not present in the areas searched. Additionally, a review of the 

habitat features was conducted by the BLM. The agency concluded that these species would 

not likely occur in this area. 

No habitat was observed to be present for the remaining two species. Webber’s scarlet gilia 

(Ipomopsis aggregata ssp. weberi) occurs in association with coniferous forests and scrub oak 

woodlands at elevations ranging from 8,500 to 9,600 feet; well above the elevations associated 

with this project. Similarly, Laramie false sagebrush (Sphaeromeria simplex) grows in 

conjunction with cushion plant communities on limestone ridges and slopes at 7,500 to 

8,600 feet; conditions not observed across the areas proposed to be disturbed. 

3.10.1.3 Plant Species of Special Concern 

Two species of special concern to the State of Wyoming have been recorded previously within 

the project region and could potentially occur within project boundaries if suitable habitat were 

present. These species include bedstraw milkweed (Asclepias subverticillata) and Ward’s 

goldenweed (Oonopsis wardii). Suitable bedstraw milkweed habitat consists of roadsides and 

other disturbed sites at an elevation of about 6,800 feet. Found previously in the Hanna Draw 

area, the last recorded siting of this species in Wyoming was in 1947 (Dutcher 2004). Given 

that suitable habitat consists of disturbed roadsides and it has not been recorded in such 

accessible sites for 57 years, it is assumed that this species does not exist in the project area. It 

may also be noted that this species was not observed in any disturbed area during the 

vegetation field survey completed for this project. 

Ward’s goldenweed typically inhabits selenium-rich shale-clay slopes, barren plains, and 

disturbed roadsides in areas of low vegetation cover at elevations ranging from 5,460 to 

7,200 feet. It has been previously recorded near the project area to the north of the Medicine 

Bow River (Dutcher 2004). Soils known to be selenium rich occur to the north of the Medicine 

Bow River in Carbon County. Selenium-rich soils are not present to the south of the river within 

the project area and it is therefore assumed that habitat suitable for Ward’s goldenweed is not 

present within the acreage proposed to be disturbed. 

3.10.2 Terrestrial Animals 

The BLM identified 21 special status animal species for the Hanna Draw Pilot Project, including 

2 federally listed and 19 BLM sensitive species. These animal species potentially present in or 

near the project area are reflected in Table 3-9, which summarizes the species, their associated 

status, habitats, potential to occur in the project area, and which species are analyzed in greater 

detail. Figure 3-10 depicts occurrences for some of these species, as discussed below for each 

special status animal. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-42 
CHAPTER 3: AFFECTED ENVIRONMENT

Table 3-9 Special Status Animal Species Examined for the Hanna Draw Pilot Project 

Common 

Name 

Scientific 

Name Status1 Habitat Association and Distribution Potential to Occur i

Bald eagle Haliaeetus leucocephalus FT2 

Typically breeds along reservoirs, lakes, and rivers, often using upland habitats for foraging. Winters near open water and in semideserts and grasslands, often associated with prairie dog colonies. 

Moderate. No documented winter roosts in or near projindividuals may move foragMedicine Bow River, in activcolonies, and in upland areawould be rare and sporadic

Black-footed ferret 

Mustela nigripes FE 

A prairie dog obligate, tied directly to prairie dog colonies. Minimum size of white-tailed prairie dog colony for suitable habitat to support ferrets is 200 acres (complex w/in 4.3 miles). 

Low. Project area in USFWblock clearance; no presencwould be required. If presethe black-footed ferret woulexperimental/nonessential p

American peregrine falcon 

Falco peregrinus BLM 

Typically breeds along high ridges and cliffs in foothills and mountainous areas. Eyries often located 400 feet or greater on cliff faces, overlooking rivers, lakes, wetlands, and wet meadows. 

Low. No peregrine falcon ndocumented. Habitat in proMedicine Bow River is modforaging. Cliffs in vicinity of corridor are limited for poten

Ferruginous hawk Buteo regalis BLM 

Occurs in open, semi-arid basin-prairies, foothills, badlands, and grasslands. Nest sites include trees, ledges, rock outcrops, and the ground on knolls or hills. Tree nests often occur on the pinyon-juniper woodland interface with sagebrush basins. 

High. Habitat is suitable for nesting and foraging. A numactive nest sites occur in su

Northern goshawk 

Accipiter gentilis BLM 

Generally found in woodlands and forests, although individuals will forage in open, dry uplands. Migrants often observed in uplands. 

Low. Habitat in the immedinot suitable for nesting birdsindividuals may forage in th

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CHAPTER 3: AFFECTED ENVIRONMENT

Table 3-9 Special Status Animal Species Examined for the Hanna Draw Pilot Project 

Common 

Name 

Scientific 

Name Status1 Habitat Association and Distribution Potential to Occur i

Burrowing owl Athene cunicularia BLM 

Typically nests in open, grasslands, shrublands, and some woodland communities. Often occupies burrows of prairie dogs, ground squirrels, foxes, and badgers. 

Moderate. Pairs may breed project area, particularly in Individual birds also may foProposed Action. 

Long-billed curlew 

Numenius americanus BLM 

During migration found along coasts, islands, prairies, rivers, ponds, wet meadows, and marshes. Nests in moist meadows or dry prairies; upland feeder on nesting and wintering grounds. 

Moderate. Known to occur iindividual birds may occur aRiver and adjacent uplands

White-faced ibis Plegadis chihi BLM Marshes, wet meadows. Low. Breeding areas may e

Bow River; some migration exist in small wetland/stock 

Greater sage-grouse 

Centrocercus urophasianus BLM 

A sagebrush obligate with lek sites typically located along ridges, open areas, and plateaus. Nesting habitat includes sagebrush with adequate canopy cover and shrub density. Brooding habitat includes wet meadows and mesic areas adjacent to riparian streams. Winter range requires adequate sagebrush cover and linkage corridors. 

Documented. Greater sageproject vicinity, and documethroughout the project areaare known to occur in the imor are intersected by the proGrouse nesting would occu

Sage thrasher Oreoscoptes montanus BLM 

Breeds in sagebrush shrublands and occasionally in other shrublands or cholla grasslands. During migration and winter, occupies open agricultural areas, pastures, grasslands, shrublands, open riparian areas, and pinyon-juniper woodlands. 

High. Likely occurs in or nebased on habitat associatioforaging. 

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Table 3-9 Special Status Animal Species Examined for the Hanna Draw Pilot Project 

Common 

Name 

Scientific 

Name Status1 Habitat Association and Distribution Potential to Occur i

Brewer’s sparrow 

Spizella breweri BLM 

Breeds and forages primarily in sagebrush communities, but occasionally in other shrubland types. During migration, occupies woody, brushy, and weedy riparian, agricultural, and urban areas. 

Sage sparrow Amphispiza belli BLM Breeds in sagebrush shrublands; also occupies grasslands and other shrubland 

communities during migration. 

High. Likely occurs in or nebased on habitat associatioforaging. 

Baird’s sparrrow 

Ammodramus bairdii BLM Breeds in grasslands and dry prairie. Forages and nests on the ground. 

Low. May occur in or near based on habitat associatioforaging. Distribution infers in immediate project area. 

Loggerhead shrike 

Lanius ludovicianus BLM 

Typically inhabits grasslands, semi-desert shrublands, agricultural areas, and riparian zones. Nests usually in isolated trees or large shrubs. 

Moderate. This species cousuitable shrubland and ripaproject area. 

Mountain plover 

Charadrius montanus BLM 

Inhabits flat, shortgrass prairie often with surface disturbance, livestock grazing, and prairie dog colonies. 

Moderate. Potentially suitaand near the project area. 

White-tailed prairie dog 

Cynomys ludovicianus BLM 

Forms colonies of varying size in shortgrass or mixed-grass prairie, digging complex burrow systems. 

Documented. Colonies occproject area. 

Wyoming pocket gopher 

Thomomys clusius BLM Meadows with loose soil. Low. Generally, wet meado

not present in project area. 

Pygmy rabbit Brachylagus idahoensis BLM Basin-prairie and riparian shrub. 

Low-Moderate. Areas of sasoils sufficient to support buwithin the project area; howhave been attempted within boundaries. 

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Table 3-9 Special Status Animal Species Examined for the Hanna Draw Pilot Project 

Common 

Name 

Scientific 

Name Status1 Habitat Association and Distribution Potential to Occur i

Swift fox Vulpes velox BLM 

Typically occupies short-, mid-, and mixed-grass prairies with flat to gently rolling topography. Den sites provide good visual coverage of surrounding area and may coincide with prairie dog colonies. 

Low. Although habitats are for this mammal species anoccurrences have been recrecords are rare and incidenlow. 

Townsend’s big-eared bat 

Corynorhinus townsendii BLM 

Inhabits dry, coniferous forests, juniper woodlands, deciduous forests, basins, desert shrublands, and grasslands. Roosts are critical to this species, typically requiring underground caverns (e.g., caves and abandoned mines) with stable temperatures and air supply. Roosting in rock outcrops and buildings would be individually dispersed. 

Low. This bat species requunderground features and tparticularly for hibernacula acolonies. No communal roohabitat in underground featudocumented in the project awould be expected to be low area lacks breeding habitathabitat potentially exists. 

Spotted bat Euderma maculatum BLM Cliffs over perennial water, basin prairie shrub. Low. Generally large cliffs 

project area; however, foragpotentially exists within the 

Sources: Fitzgerald et al. 1994; WGFD 2004b; WyGISC 2002; WNDDB 2004; Oakleaf 2004; Terres 1991; Andrews and Righ2002a. 1Status: 

FE = Federally listed as endangered 

FT = Federally listed as threatened BLM = BLM Sensitive Species 

2The bald eagle is proposed for delisting; the final decision is pending. 

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The bald eagle sporadically occurs in the Hanna Draw Pilot Project area. Bald eagles actively 

nest and roost along the North Platte River over 30 miles north and south (or upstream) of the 

project area (BLM 2002a). Optimum nesting habitat includes proximity to open water that 

provides an adequate food source, large nest trees with sturdy branches at sufficient height, 

and stand heterogeneity. Bald eagles often use the same nest each year (Grubb 1976; 

Anderson and Bruce 1980). Wintering bald eagles may gather in large aggregations and share 

communal roosts, diurnal perches, and feeding areas. The major habitat components on 

wintering grounds include a food source and suitable trees for diurnal perching and night 

roosting, with eagles commonly using riparian drainages, open water areas, and conifers or 

riparian woodlands for foraging, roosting, and thermal protection. Thermal cover is a crucial 

component of bald eagle winter night roosts and relates to energy conservation during extreme 

low temperatures. Food availability is likely the single most important factor influencing winter 

eagle distribution and abundance (Steenhof 1976). Perches are an essential element in bald 

eagles’ selection of foraging areas (Stalmaster and Newman 1979). Perch sites must be in 

open view of potential food sources and are generally within 160 feet of water (Vian 1971). The 

bald eagle commonly forages on fish, waterfowl, and carrion; however, bald eagles also will 

forage in upland habitats for terrestrial prey species. Scavenging along reservoir shorelines and 

rivers corridors for stranded fish or crippled waterfowl is a main food source during the winter 

(Winternitz 1998). No known nest sites or communal winter roosts are known to occur in the 

vicinity of the project, specifically along this reach of the Medicine Bow River (BLM 2002a; 

WNDDB 2004); however, migrating, foraging, and wintering eagles may occur in the region, 

particularly near Seminoe Reservoir, approximately 10 to 20 miles west of the project area. 

Historically, the black-footed ferret was documented in Hanna Basin in 1968 and 1979 

(Figure 3-11). One of those sitings (i.e., ferret skull) was documented in the immediate area of 

proposed drilling in Section 2 (WNDDB 2004). More recently, two observations of released 

ferrets (i.e., part of the experimental population) were recorded 13 miles north and 20 miles 

northeast of the project area (BLM 2002a). Presently, no ferrets are known to occur in or near 

the project area. The black-footed ferret is closely associated with active prairie dog colonies, 

their primary prey species. Although white-tailed prairie dogs occur the project area, as 

discussed below, the project area is included in the U.S. Fish and Wildlife Service’s (USFWS’) 

black-footed ferret block clearance where no documentation of ferret presence or absence is 

currently required. A portion of the area also is included in the black-footed ferret 

“experimentalreintroduction area.” It is not likely that reintroduced ferrets occur in the area, 

since a sylvatic plague epizootic in the mid-1990s severely impacted the prairie dog colonies 

extending from 

Hanna Draw to the Shirley Basin/Medicine Bow reintroduction area (Oakleaf 2004). However, it 

is likely these prairie dog populations continue to recover and provide a suitable prey base for 

area predators. Therefore, the project area may be considered suitable for future ferret 

reintroductions. If present in the future, the black-footed ferret would be considered to be part of 

the USFWS’ “experimental/nonessential population.” 

The American peregrine falcon and northern goshawk are not known to nest in the vicinity of the 

project area. Individual falcons may periodically forage along the Medicine Bow River and any 

associated riparian habitats, and goshawks may forage in the upland habitats in and near the 

project (BLM 2001a, 2002a). Individual migrants also may occur in the region, but occurrences 

would be expected to be low. 

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The ferruginous hawk nests throughout the project area (see Figure 3-9) (WNDDB 2004; BLM 

2004b). Many habitats are optimal to support these breeding and foraging birds, as inferred by 

the number of known nest sites for this region. Many of those nests clustered in close proximity 

are likely alternative nest sites for the same breeding pair, as some species of birds often 

alternate nest sites year to year. 

Few burrowing owl nests are shown on Figure 3-9; however, a number of records exist for the 

project area (Oakleaf 2004; WNDDB 2004). Also, habitat for this raptor that nests in 

underground burrows is suitable for both nesting and foraging. Nesting pairs may occur in and 

near the project area, especially in active or inactive prairie dog colonies. 

The long-billed curlew is known to occur in the project vicinity (BLM 2002a; TRC Mariah 2003). 

This species is more closely associated with wet meadows and riparian corridors; therefore, 

individual birds may forage and nest along the Medicine Bow River and the adjacent upland 

grasslands. 

The white-faced ibis may use stock ponds or isolated areas where water ponds in the spring as 

migration stopover areas. Breeding habitat may exist on the adjacent Medicine Bow River. The 

potential habitat in the project area is very limited, and occurrences of this species is expected 

be sporadic or non-existent. 

Sage-grouse across the western U.S. are receiving a greater scrutiny from federal, state, and 

local regulatory and management agencies. This increased interest is based on the continued 

decline of sage-grouse populations in the western U.S. and Canada, caused by a number of 

factors, predominantly habitat loss and fragmentation. Because this species is a sagebrush 

obligate, the greater sage-grouse requires large expanses of sagebrush-dominated lands. 

Regulatory and management agencies also recognize sage-grouse as “indicator species” of the 

overall health of not only the range but also the other commonly associated wildlife and plant 

species. 

Greater sage-grouse are documented in and near the project area. Lek sites (i.e., breeding 

areas) are typically situated on broad ridgetops, grassy swales, disturbed sites (e.g., burns), and 

dry lake beds. The leks commonly occur in openings of sagebrush rangelands, containing less 

herbaceous and shrub cover than the surrounding area (Schroeder et al. 1999). Lek sites are 

generally used from year to year, although some lek locations may shift slightly to adjacent 

areas. Figure 3-12 depicts documented lek sites recorded for the area in and near the 

Proposed Action (WNDDB 2004; BLM 2004b; Guenzel 2004). No known leks intersect directly 

with the proposed project components, although leks and satellite leks can change with 

changing habitat conditions, degree of human-related disturbances, and precipitation levels. A 

2-mile buffer surrounding each lek also is shown relative to specific project component 

locations. 

Nesting habitat generally occurs in relatively thick vegetative cover, usually dominated by big 

sagebrush, with both vertical and horizontal strata. Nests are placed on the ground under a 

shrub, typically but not always sagebrush, and most nest sites are located within 3.9 miles of the 

lek. However, research on the greater sage-grouse showed that females moved from 0.2 mile 

up to 12.4 miles from a lek to nest, with the mean being 2.5 miles. In Colorado, up to 80% of 

greater sage-grouse hens were documented nesting within this 2.5-mile average (Apa 2003). 

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Holloran’s (2005) recent studies from the Wyoming Pinedale Anticline show that female grouse 

will move even greater distances in areas near disturbance (e.g., surface, noise, human 

presence). Hens nest in the project area, although specific nest sites have not been mapped. 

Brooding habitats typically occur in and near wet meadows and riparian areas; therefore, 

sage-grouse broods likely occur along the Medicine Bow River corridor and adjacent tributaries 

that provide wet and mesic habitats. No designated sage-grouse wintering habitat occurs in the 

vicinity of the drilling area (BLM 2002a), although some wintering areas likely occur along the 

proposed interconnect pipeline ROW. The Rawlins FO has not yet mapped sage-grouse 

wintering areas; however, these habitat types generally occur in areas of taller, denser 

sagebrush stands (e.g., basin big sage) 

Five BLM sensitive passerines or songbirds were identified for the proposed project, including 

the sage thrasher, Brewer’s sparrow, sage sparrow, Baird’s sparrow, and loggerhead shrike. 

The sage thrasher, Brewer’s sparrow, and sage sparrow are closely associated with sagebrush 

communities, particularly during the breeding season. Figure 3-10 depicts some occurrence 

information for these species. The Baird’s sparrow is found in grasslands, commonly nesting on 

the ground (Terres 1991). All four of these bird species have been documented in the project 

region (BLM 2002a) and may occur within suitable habitats in and near the area of the 

Proposed Action. The loggerhead shrike typically occurs in more open grasslands and 

sagebrush steppe with scattered shrubs and small trees. It likely occurs in the region, 

particularly the greasewood and grassland communities. 

The mountain plover is closely associated with shortgrass prairie, disturbed areas, and prairie 

dog colonies. This bird species returns to Wyoming to breed between March and August. 

Potentially suitable habitat occurs in and near the project area, particularly in active prairie dog 

colonies. Potentially suitable plover habitat and two breeding plovers were documented in the 

project area in 2001 and 2003 (TRC Mariah 2003). Other observations also have been 

recorded (WNDDB 2004). 

The white-tailed prairie dog occurs in the project region. They provide a prey base for a wide 

diversity of predators, including a number of special status species (e.g., bald eagle, ferruginous 

hawk, swift fox). However, local prairie dog populations were severely impacted by sylvatic 

plague in the mid-1990s, extending between Hanna Draw and the Shirley Basin/Medicine Bow 

black-footed reintroduction area, as discussed for the ferret above (Oakleaf 2004). White-tailed 

prairie dog colonies are typically dispersed within open, grasslands and desert grass 

communities. Figure 3-11 depicts historic prairie dog locations recorded by the WGFD through 

2004 (WGFD 2004b). Additional active colonies may be present beyond those previously 

mapped, particularly as this species recovers from the plague. 

The five remaining mammal species that are classified as BLM sensitive, the swift fox, pygmy 

rabbit, Wyoming pocket gopher, spotted bat, and Townsend’s big-eared bat were identified for 

the proposed project area. Habitat for the pygmy rabbit may exist on the project area. The 

pygmy rabbit selects sagebrush stands with soils deep enough to support its burrows (it is the 

only rabbit species, not including hares, that digs a burrow complex). Limited surveys have 

been undertaken by the Rawlins FO, and the project area has not yet been surveyed. Thus, the 

possibility exists that pygmy rabbit habitat could be located within the project area. The 

Wyoming pocket gopher requires wet meadow areas with correspondingly loose soils for its 

burrows. These areas are quite limited within the project area, and thus probability of its 

occurrence is considered low. Habitats in and near the project area would be considered to be 

suitable to support swift fox. Records of this mammal species do exist for the area (Oakleaf 

2004). The swift fox often will utilize prairie dog burrows for its den sites. The Townsend’s big 

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CHAPTER 3: AFFECTED ENVIRONMENT

eared bat requires underground features (e.g., mines, caves) for its maternity colonies and 

stable temperature regimes, which are critical for this bat species’ survival. No known winter 

hibernacula, maternity colonies, or bachelor roosts have been documented in or near the project 

area, and the potential for a feature of this nature would be low. Individual bats may day-roost 

under appropriate vegetative cover, in rocky crevices, and in buildings, but roosting would be 

anticipated to be sporadic and dispersed through the area. Foraging habitat within the 

basin-prairie shrub ecosystem is present on the project area. The spotted bat utilizes rock 

crevices on cliff faces for its maternity roosts, and the habitat within the project area lacks this 

feature. Foraging habitat within the basin-prairie shrub ecosystem is present on the project 

area. 

3.10.3 Aquatic Resources 

3.10.3.1 Amphibians 

Three amphibian species are listed as BLM sensitive, including the northern leopard frog (Rana 

pipiens), Great Basin spadefoot (Spea intermontana), and boreal toad (Bufo boreas boreas). 

The boreal toad is a species characteristic of elevation exceeding 7,000 feet with conifer 

vegetation. No suitable habitat for this species is present in the project area. The Great Basin 

spadefoot is primarily a terrestrial species, associated with water only during spring 

reproduction. This species reproduces in temporary or permanent pools, ponds, stock tanks, 

and irrigation ditches. Few such aquatic features are present in the project area and this species 

is not expected to reproduce in aquatic features in the project area such as the constructed 

reservoir as it seldom contains any water. The northern leopard frog inhabits backwaters with 

emergent vegetation, and suitable habitat is therefore limited along the Medicine Bow River. 

3.11 CULTURAL RESOURCES 

3.11.1 Overview of Prehistory and History 

This brief overview is taken from the work of Mulloy (1958); Frison (1991); and BLM (2002a). 

The earliest known peoples to have occupied the Northwestern Plains appear to have entered 

the region over 11,000 years ago. These Paleoindian period cultures were expert big game 

hunters who focused on now-extinct species such as the mammoth, bison, and camel. 

Paleoindian sites are rare in the study due primarily to poor preservation conditions and thus are 

usually limited to isolated lithic artifacts. As a result of significant climatic changes as well as 

other environmental factors the megafauna eventually died out, which forced a behavioral shift 

to more diverse subsistence strategies that focused on smaller game species and increased 

reliance on a variety of plant resources. This period is known as the Plains Archaic, which is 

subdivided into Early, Middle, and Late stages as characterized by a range of distinctive 

projectile point styles. The Plains Archaic persisted for some 6,000 years until the Late 

Prehistoric period about 2,000 years ago, which is marked by the technological change from 

dart projectiles to the bow and arrow and by the appearance of ceramics. Throughout the 

Plains Archaic and Late Prehistoric periods, the present project area was occupied by small 

bands of hunter-gatherers whose movements were dictated primarily by seasonal change. 

Thus it is the open camps and lithic scatters of these two periods that make up the majority of 

prehistoric sites that have been documented in the area. Sites of the subsequent Protohistoric 

period, which represents the time when Euroamerican influences were beginning to impact the 

region, are not known to occur in the project area. 

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The first known historic land use of the area was related to fur trapping and trading as 

represented by the Ashley-Smith Expedition, which entered what is now Carbon County in 1825 

(Seiersen 1981). Subsequently, and prior to the 1880s, cattle ranching became a major 

enterprise that claimed vast tracts of land. However, a prolonged period of severe drought and 

harsh winters ultimately bankrupted many of these ranchers. Large-scale sheep ranching 

followed in the late 1800s. To serve the livestock industry and other enterprises, the Union 

Pacific Railroad was built into Carbon County in 1868. Given this history, abandoned livestock 

camps and other ranching-related materials and facilities are the most common historic site 

types found in the project area. 

3.11.2 Class I File Search Results 

A file search of the Hanna Draw Project area was conducted through the online database of the 

Wyoming Cultural Records Office (WyCRO) and directly from the files of the BLM Rawlins FO. 

The Class I study encompasses over 84 sections and includes the entirety of the original Hanna 

Draw Exploration POD, Williams EA study area (BLM 2002a; Stainbrook 2004); a proposed 

project-related power line (Buenger 2004a); and the route of a proposed 8-inch pipeline 

(Buenger 2004b) for which the BLM has required a 2-mile-wide cultural resources study 

corridor. The results revealed a total of 163 archaeological sites, both prehistoric and historics 

(Table 3-10). The majority of these sites consists of prehistoric sites (n=124). Of the remaining 

sites, 33 are historical in age, 3 exhibit both prehistoric and historical components, and the ages 

of 3 are unknown or not reported. 

Regarding site significance, 105 sites have been assessed as not eligible for the NRHP and as 

such will not be discussed further. Of the remainder, 15 sites are NRHP-eligible and 43 remain 

unevaluated. Of those sites that are NRHP-eligible, 8 are deemed so by the Wyoming State 

Historic Preservation Office (SHPO). These sites include prehistoric stone circle sites 

48CR730, 48CR731, and 48CR732 and prehistoric camp sites 48CR135, 48CR776, 48CR816, 

and 48CR7074. Of particular note is the spatially extensive 48CR135, which was initially 

recorded in 1976 and has subsequently been re-recorded and evaluated in conjunction with 

various gas field projects (Buenger 2004a, 2004b). The eighth officially eligible site is the old 

Lincoln Highway (48CR1191), several segments that are reported to occur in the vicinity of the 

study area, especially near the southern end, and are variously assessed as contributing or 

non-contributing portions of the larger site. Six sites bear field-eligible recommendations and 

include prehistoric sites 48CR84, 48CR533, 48CR962, 48CR1375, 48CR7259, and 48CR7263. 

A seventh field eligible site, 48CR4430, is identified as a burial, but the recorder failed to report 

the age and/or cultural affiliation. 

The file search also revealed that 64 cultural resource surveys were previously conducted in the 

project area. A total of 35 surveys were completed prior to 1990, and 29 were conducted in 

1990 or after, the most recent being five Class III inventories conducted by Western 

Archaeological Services, Inc. for the APC Hanna Draw Pilot Project, which is the subject of this 

current EA (Buenger 2004a, 2004b; Stainbrook 2004; Gries 2005a, 2005b). Virtually all of the 

previous cultural resource studies are related to gas field development and some coal mining. 

A few are associated with proposed seismic line installations. 

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Table 3-10 Previously Recorded Site Types and Eligibility Status 

Site Type 

NRHP Status 

Total 

Field 

Not 

Eligible 

Field 

Eligible 

Officially 

Eligible 

Officially 

Not 

Eligible 

Not 

Evaluated 

Prehistoric Camp/Hearths 36 4 3 2 25 70 

Prehistoric Lithic 

Scatter/Artifacts 

30 0 1 0 10 41 

Prehistoric Stone Circles 4 0 3 0 3 10 

Prehistoric Hunting Blind 0 1 0 0 2 3 

Historic Stock Camps 6 0 0 0 1 7 

Historic Cairns/Rock Piles 13 0 0 1 0 14 

Historic Bridge 2 0 0 0 1 3 

Historic Debris/Trash 7 0 0 1 0 8 

Other Historic Sites 1 1 1 0 1 4 

Burial, Unknown Age 0 1 0 0 0 1 

Rock Alignment, Unk. Age 2 0 0 0 0 2 

Total Number of Sites: 163 

3.12 RANGE RESOURCES AND OTHER LAND USES 

The proposed Hanna Draw Pilot Project would be constructed on land within the Hanna Basin of 

Wyoming. The drilling area is located on federal land managed by the BLM (T23N R81W, S2); 

the facility area is located on private land (T24N, R81W, S35). In addition, the proposed 

25.3-mile-long interconnect pipeline route would cross portions of 14 public land sections, 

17 sections of private land, and 1 Wyoming state section. Most of the private land is owned by 

Q Creek Land and Livestock, LLC; Union Pacific Land and Resources Company owns the north 

half of the project site and portions of the pipeline route; Peterson Livestock owns the remainder 

of the pipeline route near the southwest terminus. The mixed ownership reflects the location in 

the “checkerboard” land paralleling the Union Pacific Railroad route. 

3.12.1 Range Resources 

Undisturbed portions of the proposed project site and surrounding lands are used primarily for 

livestock grazing. The majority of the project area is within the 66,583-acre Dana Block North 

federal grazing allotment, number 00822 (BLM 2004c). The entire allotment is approved for 

4,962 AUMs for both cattle and sheep between March 1 and November 10 (BLM 2004c). 

Project ancillary lines (transmission and pipeline) cross two other allotments. The Quealey 

Block Allotment, (No. 00820) is southwest of the Pilot Project and includes 54,262 total acres, of 

which 23,681 acres are public (3,848 public AUMs for cattle and sheep). Near the southwest 

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end of the proposed interconnect pipeline, the allotment is Pass Creek Ridge (No. 00827), 

which includes 59,996 acres, with 26,308 acres being public (3,597 AUMs for cattle). 

The Dana Block North Allotment has two permittees, Q Creek Land and Livestock, LLC and 

Victor Anderson (incommon use). Peterson Livestock and Wallis Livestock Company 

(incommon use) are the permittees in the Pass Creek Ridge Allotment, and Q Creek Land and 

Livestock, LLC is the only permittee in the Quealey Block allotment. 

3.12.2 Other Land Uses 

Remnants of an inactive petroleum exploration project occur immediately south of the proposed 

site, and there are coal mines several miles to the south. These features, together with limited 

recreational activity in the area and on Seminoe Reservoir located 10 miles to the west (see 

Section 3.14), are the only non-agricultural uses identified in the area. 

Carbon County has adopted a Land Use Plan and Zoning Resolution (Carbon County 1998, 

2004). The Land Use Plan has three main purposes: 1) to “... serve as a general guide to future 

land and resource management in the unincorporated areas of ...” the county, with a regional 

vision for the future development pattern; 2) “... to articulate the County’s position concerning 

land uses on federal and State lands”; and 3) “... to provide ... municipalities ... with the 

County’s vision concerning future land uses ... in the unincorporated areas of the County” 

(Carbon County 1998). 

The Land Use Plan articulates the county’s concern for the long-term support of commercial 

agriculture, primarily ranching, both because of the economic value and because of the myriad 

of other benefits it provides to the county, including wildlife habitat, extensive vistas, open 

space, and other associated values. It also recognizes and encourages development of mineral 

resources in concert with continued agricultural use when the two can coexist to their mutual 

benefit. In the context of these considerations, the plan recommends that all lands that have 

suitability for agriculture, both public and private, should be used for future agricultural use. 

Carbon County zoning regulations apply only to private lands. But the county has designated 

zone districts for public lands, as well, providing the county’s perspective on the appropriate use 

patterns for the entire county. The project area is in the Ranching, Agricultural, Mining (RAM) 

Zone district (Rowen 2005). Principally permitted uses in the RAM district include commercial 

agriculture and oil, gas, and mineral exploration, development, and production, among several 

other uses (Carbon County 2004). 

3.13 NOISE 

Noise levels in the vicinity of the proposed Hanna Draw Pilot Project area have not been 

measured. Based on studies from other areas, it is expected that noise levels would be quite 

low, influenced mainly by wind, insects, birds, and animals. The background noise in the area 

without these influences is likely in the range of 40 to 45 dBA (EPA 1971). When the wind is 

blowing, the noise levels are substantially higher. 

There are no consistent sources of man-made noise in the vicinity. Occasional traffic on County 

Road (CR) 291 and occasional aircraft overflights are the only such sources. 

No noise sensitive receptors have been identified in the vicinity of the proposed project area. 

The nearest locations of regular human activity are several miles distant from the site. 

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3.14 RECREATION 

Recreation opportunities in the vicinity of the Hanna Draw Pilot Project site are limited. There 

are no developed recreation sites nearby; the closest are community facilities in Hanna, nearly 

10 miles south, and the Seminoe Reservoir-Bow Arm Public Access Area boat ramp, 12 miles 

to the west. Seminoe Reservoir is a popular recreation resource, but the highest activity is 

focused at Seminoe State Park on the west side of the reservoir. CR 291 provides access to the 

Bow Arm boat ramp, but it is relatively lightly used because the only facility, other than the ramp 

itself, is an outhouse. 

Hunting is the most popular among a small variety of dispersed recreation activities in the area. 

Other dispersed activities include sightseeing, wildlife viewing, fishing, and limited off-highway 

vehicle (OHV) use. Comprehensive data on recreation usage in the immediate vicinity of the 

project area are not available, but large game hunting in the fall seasons is likely the largest 

generator of recreation activity. Over 10,500 hunter days were recorded in 2004 for the hunt 

areas encompassing the project area (WGFD 2005a, 2005b). Over 90% of the hunter days 

were devoted to antelope (pronghorn), deer, and elk. The deer and elk hunting and, to a lesser 

extent, the antelope hunting tend to be located in the more mountainous sections of the hunt 

areas several miles north of the project area (Guenzel 2004). Hunting success varies with the 

game population; deer and elk harvests in the project area hunt areas in 2004 were fairly 

consistent with those over the preceding decade, while the antelope harvest was the largest 

since 1995 (WGFD 2005a). There is also a smaller amount of hunting in the general area for 

birds, such as sage-grouse, and small game, such as cottontail rabbits. 

Although the Medicine Bow River runs adjacent to the project area, it is not heavily fished in this 

area (Gunzel 2004). Presumably, this is because there are better fishing opportunities 

elsewhere in the region, including several world-class fisheries (BLM 2004c). 

OHV use is limited to existing roads and vehicle routes, other than at the Dune Ponds open 

area west of the reservoir (BLM 2004c). 

Classification under the Recreation Opportunity Spectrum (ROS) would likely include most of 

the project vicinity as Roaded Natural with a network of roads and two-tracks traversing an 

otherwise mostly natural setting (BLM 2004c). Previous disturbance of the Hanna Draw Project 

site and the section immediately to the south would probably cause them to be classified as 

Rural. 

There are no designate wilderness areas near the project area; the nearest Wilderness Study 

Area (WSA), the Bennett Mountain WSA, is located approximately 15 miles northwest of the 

project site. There are no designated or eligible Wild and Scenic Rivers near the project area 

(BLM 2002b). 

Although access to the Hanna Draw Project area is generally good via improved and maintained 

county roads (CR 291 and CR 121/270), there are no specific attractions to draw large numbers 

of recreationists to the project vicinity. The checkerboard ownership pattern also may 

discourage use by limiting access to public lands. Additional information on recreation 

resources in the region can be found in the Rawlins Resource Management Plan DEIS (BLM 

2004c). 

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3.15 VISUAL RESOURCES 

The visual landscape in the vicinity of the proposed Hanna Draw Project is typical of the Hanna 

Basin sub-basin of the Wyoming Basin physiographic province. Terrain is predominantly rolling, 

dissected by small drainages and punctuated by occasional buttes and rock outcrops. The 

grand scale of the landscape tends to veil the severity of the topography, which is quite steep in 

some places. The varied terrain defines relatively small viewsheds from valley perspectives, 

although the viewsheds from higher elevations are expansive, stretching for many miles when 

the air is clear. 

Colors are generally medium greens and gray-greens in the spring and as long into the summer 

as precipitation will support growth. As the summer wears on, the colors trend to paler 

gray-greens, beiges, and golds. Background soil colors are mostly beige, buff, and soft brown. 

Vegetation is dominated by low shrubs, including sagebrush, saltbush, and a mixture of grasses 

and forbs. There is virtually no vertical plant growth higher than 2 to 3 feet. The visual effect 

tends to be a tufted mat, soft textured with subtle variations in color from differing vegetation. 

Cultural modifications to the natural landscape primarily include roads, two-tracks, and utility 

lines. There are a few relatively small, aboveground power lines in the general area. There are 

also buried pipelines, which are noticeable primarily because of the linear changes in vegetation 

they produce. 

The BLM has inventoried the area using its Visual Resource Management (VRM) classification 

system (BLM 2004c). The system provides for classification of the landscape into four 

management categories based on scenic quality, visual sensitivity, and distance from viewers 

(BLM 2004c). Each VRM class has an associated management objective. VRM Class I is the 

most restrictive, intended for areas that should be preserved in a natural state, such as 

Wilderness Study Areas; Class IV is the least restrictive, it will accommodate activities that 

require major changes to the landscape. 

The Hanna Draw Pilot Project site, the power line corridor, and most of the interconnect pipeline 

corridor are designated VRM Class IV. The management objective indicates, “... management 

activities may dominate the view and may be the major focus of viewer attention. Every attempt 

should be made to minimize the impact of these activities through careful location, minimal 

disturbance, and repetition of the basic visual elements of form, line, color, and texture.” 

Approximately 5 miles of the southwest end of the interconnect pipeline corridor is designated 

VRM Class III. Class III areas are intended to partially retain the natural character of the 

landscape; the management objective indicates, “... activities may attract the attention of the 

casual observer, but should not dominate the view changes should repeat the basic elements 

found in the predominant natural features of the characteristic landscape” (BLM 2004c). 

3.16 SOCIOECONOMICS 

The Socioeconomics discussion addresses social and economic values in the vicinity of the 

project area, including population, employment, economic effects, and selected community 

resources such as housing, emergency services, and potentially affected government revenue 

resources. The geographic area of interest is Carbon County, including Hanna, the nearest 

town; Rawlins, the county seat and its largest city; and the towns of Medicine Bow, Elk 

Mountain, Saratoga, and Sinclair. 

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3.16.1 Population and Demography 

The Carbon County population boomed in the late 1970s and early 1980s, but has been 

consistently in decline since then (Table 3-11). The growth was spurred by energy development, 

but coal production, in particular, first became less labor intensive and subsequently production 

declined and the mines began to close. The loss of jobs led to a decline in population. The 

county population dropped by almost 30% from 1980 to 2000; it has continued to slide, but at a 

much slower rate since the 2000 census. 

Like the county as a whole, communities near the project area have declined only slightly since 

2000. The most recent available estimates (for July 2004) indicate populations for Hanna at 

866, Medicine Bow at 267, Elk Mountain at 190, Saratoga at 1,710, Sinclair at 408, and Rock 

River (Albany County) at 223. These communities together are down an estimated 1.6% from 

their 2000 census population levels. Rawlins, the county’s largest city, had an estimated 

8,633 people in 2004, down 4.1% from its adjusted census population of 9,006 (U.S. Census 

Bureau 2005). 

Table 3-11 Carbon County and Wyoming Population Trends 

Census Estimates 

1970 1980 1990 2000 7/1/01 7/1/02 7/1/03 7/1/04 

Carbon 

County 13,354 21,896 16,659 15,639 15,263 15,387 15,360 15,271 

Wyoming 332,416 469,557 453,588 459,260 494,118 499,192 502,111 506,529 

Source: Western Economic Services (WES) 2005 

Carbon County has a somewhat different ethnicity pattern than the state as a whole, according 

to the 2000 census (U.S. Bureau of the Census 2000). Both the county and the state are 

predominantly white, 90.1% for Carbon County and 92.1% for Wyoming, but the percentages of 

non-whites differ. Carbon County had lower percentages of Native Americans and African 

Americans, but a slightly higher percentage of Asians. The most notable difference is that 

Carbon County’s Hispanic or Latino population was at 13.5% compared to just 6.4% for the 

state as a whole (U.S. Bureau of the Census 2000). The smaller communities near the project 

area are all predominantly white, ranging from 95.4% in Saratoga to 97.8% in Medicine Bow; 

Hanna was 95.5% white in 2000 (U.S. Bureau of the Census 2000). Hispanics or Latinos were 

the largest identified ethnic group in each of the small communities. Not surprisingly, Rawlins, 

Carbon County’s largest city, had the largest population of self-identified non-whites; 21% were 

classified as Hispanic or Latino of any race. Other racial and ethnic groups were all quite small. 

3.16.2 Economic Conditions 

3.16.2.1 Employment and Income. 

Carbon County was named for the area’s coalbeds. As recently as a decade ago, the county’s 

economy was heavily based on natural resources. The county’s mining sector once had over 

3,000 workers and produced between 3 million and 5 million tons of coal per year from 1988 to 

1998. The entire sector, which includes oil and gas workers, was down from 661 workers in 

1993 to just 173 workers by 2003 (Table 3-12). (Although similar, the category definitions 

changed between 1993 and 2003 so the numbers may not be exactly comparable.) Coal 

production had dropped to less than 276,000 tons in 2003. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-59 
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Table 3-12 Carbon County and Wyoming Employment by Industry1 2003 

Industry Carbon County Wyoming 

Employment Percent Employment Percent 

Farm Employment 529 5.5% 12,192 3.6% 

Nonfarm Private Employment 

Forestry, Fishing & Related 

Activities 153 1.6% 3,155 0.9% 

Mining 173 1.8% 20,881 6.1% 

Construction 698 7.3% 27,544 8.0% 

Manufacturing 469 4.9% 10,940 3.2% 

Wholesale Trade 159 1.7% 8,000 2.3% 

Retail Trade 1,135 11.8% 39,577 11.6% 

Transportation, Warehousing & 

Utilities 564 5.9% 14,070 4.1% 

Information 91 0.9% 4,802 1.4% 

Financial Activities 556 5.8% 23,367 6.8% 

Professional & Business Services ND2 --­ 27,350 8.0% 

Educational & Health Services 571 5.9% 28,086 8.2% 

Leisure & Hospitality 1,192 12.4% 37,075 10.8% 

Other Services, except Public 

Admin. 523 5.4% 18,217 5.3% 

Private Sector Subtotal 7,383 76.9% 275,256 80.4% 

Government & Gov’t Enterprises 

Federal, Civilian 217 2.3% 7,482 2.2% 

Military 85 0.9% 6,349 1.9% 

State Government 626 6.5% 14,570 4.3% 

Local Government 1,291 13.4% 38,706 11.3% 

Public Sector Subtotal 2,219 23.1% 67,107 19.6% 

Total 9,602 100.0% 342,363 100.0% 

Source: WDAI 2005a 1

2002 North American Industry Classification System (NAICS) Sectors 2

ND = Data not disclosed to comply with confidentiality standards; estimates are included in totals. 

Basic economic sectors (i.e., those that bring outside revenues into the county) still include oil 

and gas production and processing, coal mining, electric power generation, agriculture (primarily 

ranching and logging), some manufacturing, transportation, and portions of the retail and 

service sectors that serve travelers, tourists, and recreationists. However, the balance has 

shifted. As illustrated in Table 3-13, the economic sectors that exceed state average 

employment levels by more than 1.0% (on a comparative percentage basis) are now farming, 

manufacturing, transportation and related services, leisure and hospitality services, and state 

and local government. A large portion of the first three categories and at least some of the fourth 

would be considered basic industries. 

Total Carbon County employment, defined as the total number of full- and part-time jobs, 

increased 2.8% over the last decade, from 9,344 in 1993 to 9,602 in 2003. The type of 

employment shifted somewhat, however, with wage and salary employment losing 231 jobs and 

proprietors employment increasing by 489, all but 18 of which were non-farm proprietors 

(Wyoming Department of Administration and Information [WDAI] 2005a). Despite some gains in 

oil and gas development, the mining sector suffered the largest percentage loss of jobs over the 

decade at 74%; the construction sector was the largest gainer with a 72% increase in 

employment, some of which may have been in support of oil and gas drilling (WDAI 2005a). 

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Carbon County unemployment rates over the past decade have ranged from a high of 6.2% in 

1993 to a low of 4.2% in 2000. The rate was 4.6% in 2004, representing 356 people seeking 

employment (Wyoming Department of Employment [WDOE] 2005). Unemployment rates in the 

county have consistently been higher than the statewide rate in recent years by from 0.1% to as 

much as 1.2%. The statewide rate was 3.9% in 2004 (WDOE 2005). 

Total personal income for Carbon County grew from $305.4 million in 1993 to $422.1 million in 

2003, representing a 3.0% average annual rate of increase (WDAI 2005a). The growth rate 

lagged substantially behind the average of 5.5% per year for Wyoming as a whole. Per capita 

personal income is perhaps a more telling comparison. Wyoming statewide per capita personal 

income grew at 4.6% per year from $19,976 in 1993 to $32,433 in 2003. Starting form a slightly 

lower average of $18,757 in 1993 (93.9% of the state average), Carbon County’s per capita 

personal income grew at 3.7% per year to $27,479 in 2003, which was 84.7% of the state level 

(WDAI 2005a). 

The Department of Housing and Urban Development (HUD) estimated 2005 median family 

income at $50,600 for Carbon County and $55,250 for Wyoming as a whole (WES 2005). Using 

different methods, the Census Bureau estimated that 12.2% of Carbon County’s population was 

living below the poverty level in 2003, compared with an estimated 10.8% of the state 

population for the same year (U.S. Bureau of the Census 2005). 

Carbon County natural gas production has fluctuated between 94 million cubic feet (MMCF) and 

98 MMCF over the past 5 years, with 2004 production at 97.2 MMCF (WOGCC 2001-2005). 

Carbon County oil production has ranged from just under 1.6 million barrels to nearly 1.8 million 

barrels over the same time period, with 2004 production at the 1.8-million barrels level (WOGCC 

2001-2005). There were a total of 1,120 producing oil and gas wells in Carbon County in 2004, 

producing 6.7% of all gas produced in Wyoming and 2.7% of all oil. There were 293 approved 

drilling permits in the county in 2004, the most of any of the past 5 years. If oil and gas prices 

remain at current levels and drilling efforts are successful, it could be expected that drilling will 

grow and production will increase. 

Table 3-13 2004 Annual Average Daily Traffic Counts1 

Route Location 

AADT 

Cars Trucks Total 

I-80 WY 72 Interchange 2,710 3,200 5,910 

U.S. 30/287 Hanna Vicinity 540 120 660 

WY 72 Between I-80 and 

U.S. 30/287 110 40 150 

Source: Wyoming Department of Transportation (WYDOT) 2005 1

Annual Average Daily Traffic (AADT)

3.16.2.2 Local and State Government Revenues 

In addition to the jobs provided by oil and gas, the communities receive tax revenues from oil 

and gas severance taxes and from sales and use taxes generated by purchases in the oil fields 

and spending by workers for goods. Oil and gas producers pay ad valorem taxes on equipment 

and production. They also pay royalties on production from state and federal leases at 16.67% 

and 12.5%, respectively. Half of the federal lease payments are returned to the state. In 

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CHAPTER 3: AFFECTED ENVIRONMENT

Wyoming, the state’s share is distributed to a variety of accounts, including the university, the 

school foundation fund, the highway fund, the legislative royalty impact account, and cities, 

towns and counties. 

The severance tax rate for oil and gas is 6.0%, of which 0.25% is distributed to counties and 

0.75% is distributed to cities and towns, based on population. The remaining 5.0% is committed 

to various state funds and accounts. The Oil and Gas Conservation mill levy is now 0.02%, 

down from the 0.06% as recently as 2004 (WOGCC 2005). 

Carbon County’s assessed valuation totaled $559.9 million for fiscal year (FY) 2004, 82% of 

which was “state assessed” property, including oil and gas production. Approximately 

$366.1 million, or 65% of the total, was attributed to the taxable value of natural gas (Wyoming 

Department of Revenue [WDOR] 2005). The average mill levy in Carbon County is 63.493 mills 

for 2004, which yielded a total of $35.5 million in revenue (WDOR 2005). 

Sales and use tax collections in Carbon County totaled approximately $4.4 million for FY 2004. 

Sales and use taxes in the county include a 4% state tax, a 1% general purpose option tax, and 

a 1% special purpose option tax for a total of 6%. In addition, the county levies a 2% lodging tax 

for a total of 8% on lodging (WDAI 2005b). 

3.16.3 Housing 

The exploratory nature and scale of the proposed Hanna Draw Pilot Project is such that most 

workers would either be local hires or would be in the area for a relatively short time while the 

wells were drilled and completed. Under these circumstances, there would be little or no 

demand for permanent housing facilities. Rather, there would be a need for temporary housing, 

including motel rooms, mobile home and recreational vehicle (RV) spaces, and possibly 

short-term rental apartments. 

The most recent Wyoming housing surveys indicated that the rental housing vacancy rate in 

Carbon County was 7.6%, more than double the statewide average and higher than most 

housing planners would consider necessary to accommodate normal flux in a rental market 

(WES 2005). The survey also found a 32% vacancy rate for mobile home lots for rent (not 

including RV sites), which represents 102 lots available to rent (WES 2005). 

There are numerous temporary lodging facilities in communities near the project area. Hanna 

has 1 motel; Elk Mountain has 1 hotel with adjacent RV spaces and a guest cabin facility; 

Medicine Bow has 1 hotel and 1 motel with a combined 60 units, and Saratoga has 9 motels 

and lodges and 2 RV/campground facilities. Rawlins has 23 motels and bed & breakfast 

facilities and 4 RV/campground facilities. 

3.16.4 Emergency Services 

Memorial Hospital of Carbon County in Rawlins is the nearest full service medical facility to the 

proposed project site. The 35-bed facility provides CT Scan, mobile MRI, ultrasonography, 

mammography, intensive care, an OB unit, nuclear medicine, a fully equipped laboratory, 

children's clinic, extended care facility and a physician-staffed emergency room. Emergency 

medical air transportation links the hospital to Casper, Cheyenne, Denver and Salt Lake City 

(Memorial Hospital 2005). 

Memorial Hospital also provides a clinic in Hanna. The clinic is staffed by a Physician’s 

Assistant (PA) 5 days per week augmented by one or more physicians once per week (Lessard 

3-62 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 3: AFFECTED ENVIRONMENT

2005). Other medical services, such as dental care and mental health services are available in 

Rawlins. 

Fire protection in the project area is provided by the all-volunteer fire department based in 

Hanna, with back-up and support from the Carbon County Fire Department. The Hanna 

department has a staff of approximately 15, most of whom are also EMT certified. Staff are 

hazardous materials certified and qualified to provide rescue services. Equipment based at 

Hanna includes both city- and county-owned pumpers and wildland fire equipment, including a 

water truck, all-wheel drive trucks and “dip tanks” (Lessard 2005). The Hanna volunteer 

organization owns its ambulance and provides first responder service and emergency transport 

to the nearest emergency hospital, usually in Rawllins. 

Law enforcement services in the Hanna Draw Pilot Project vicinity are provided by the Carbon 

County Sheriff’s Department, which has a deputy stationed in Hanna and one in Medicine Bow. 

The Town of Hanna has a town Marshall with three officers providing 24-hour service and 

emergency dispatch service (Lessard 2005). 

3.16.5 Attitudes and Opinions 

The last formal survey of Carbon County residents’ attitudes and opinions regarding land use, 

oil and gas development, natural resource conservation and use, and other topics was 

conducted in 1996 as part of the process to develop the county’s Land Use Plan (Carbon 

County 1998). Although the survey was conducted several years prior to the current interest in 

development of coalbed natural gas, it provides some background on community priorities. The 

top priority expressed by county residents was to conserve water resources and there was a 

related concern for the continuing availability of water to support future development. Many 

county residents expressed concerns about governmental regulation of land use, apparently in 

reference primarily to federal agency activities. Residents also were concerned about both the 

continuing viability of existing natural resource based economic activities (including oil and gas 

and ranching, among others) and the need to conserve wildlife habitat in the county (Carbon 

County 1998). 

Specifically regarding oil and gas development, results from the Rawlins area indicated 

conservation of water, land, and wildlife resources was of greater importance than increased oil 

and gas production, while residents of smaller outlying communities, including Medicine Bow, 

expressed a greater desire for increased oil and gas production (Carbon County 1998). In 

contrast, nearly half of the survey respondents favored more leasing of federal lands for oil and 

gas exploration and production (Carbon County 1998). Regarding management of federal lands, 

more than two-thirds of respondents wanted more federal lands in the county designated for 

conservation of fish and wildlife habitat and surface and groundwater resources and nearly as 

many wanted more land designated for public recreation (Carbon County 1998). 

3.16.6 Environmental Justice 

Executive Order No. 12898, “Federal Action to Address Environmental Justice in Minority 

Populations and Low-Income Populations” (59 FR 7629), is “intended to promote 

nondiscrimination in Federal programs substantially affecting human health and the 

environment, and to provide minority communities and low-income communities access to 

public information on, and an opportunity for participation in, matters relating to human health 

and the environment.” It requires each federal agency to achieve environmental justice as part 

of its mission by identifying and addressing, as appropriate, disproportionately high and adverse 

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CHAPTER 3: AFFECTED ENVIRONMENT

human health or environmental effects, including social and economic effects, of its programs, 

policies, and activities on minority and low-income populations. 

Environmental justice concerns are usually directly associated with impacts on the natural and 

physical environment, but these impacts are likely to be interrelated with social and economic 

impacts as well. 

EPA guidelines (Council on Environmental Quality [CEQ] 1997) for evaluating potential adverse 

environmental effects of projects require specific identification of minority populations when 

either: 1) a minority population exceeds 50% of the population of the affected area or 2) a 

minority population represents a meaningfully greater increment of the affected population than 

of the population of some other appropriate geographic unit, such as the State of Wyoming, as a 

whole. While the Hispanic/Latino population of Rawlins is notably higher than for the state as a 

whole (also resulting in higher levels on average for the county) the percentages of 

Hispanic/Latinos in all of the smaller communities in the project vicinity are below the state 

average, sometimes by a large margin (see Section 3.16.1 above). Percentages of families and 

individuals below the poverty level are higher in Carbon County and most of the communities in 

the vicinity of the project area than in the state as a whole. 

3.17 TRANSPORTATION AND ACCESS 

The primary access to the Hanna Draw Pilot Project vicinity is Interstate 80 (I-80) approximately 

20 miles south of the project area. I-80 runs east and west to Cheyenne, Salt Lake City, and 

points beyond. I-80 is a 4-lane, interstate standard freeway in good to excellent condition. 

U.S. 30/287 also runs east and west approximately 10 miles south of the project area, and just 

south of the Town of Hanna, looping off of I-80 from Walcott to Laramie. U.S. 30/287 is a 

2-lane, paved highway in fair to good condition. State Highway (SH) 72, also a paved, 2-lane 

highway, connects I-80 at exit 255 to Hanna across U.S. 30/287. 

CR 291, also known as the Hanna Leo Road, provides access from Hanna north to the project 

area. CR 291 is a well maintained, gravel surface, all-weather road. CR 291 continues north 

from the project area across the Medicine Bow River and on to Alcova. CR 270 intersects 

CR 291 just north of the river and travels easterly to the Medicine Bow. 

Traffic levels on all roads are well below their capacities. Traffic volume counts for the paved 

state and federal highways are illustrated in Table 3-13. Traffic counts are not available for the 

county roads. 

Current plans for road improvements in the project vicinity include widening and reconstruction 

of WY 72 between U.S. 30/287 and I-80. Preliminary engineering for this project is scheduled 

for FY 2005 (WYDOT 2004). 

In addition to the improved roads in the project vicinity, there are a number of unimproved 

and/or seldom maintained two-track routes in various directions across the range. Portions of 

the proposed interconnect pipeline route can be accessed by two-tracks. Conditions on these 

routes vary widely, depending on terrain, soil conditions, and whether they have a use that 

requires regular access and thus warrants maintenance by a user. The existing access road 

through the project site from CR 291 has been improved with a gravel surface in the past, but is 

currently in poor to fair condition from minimal maintenance. 

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The Union Pacific Railroad mainline runs through Hanna; it carried approximately 75, 100-car 

trains per day in the mid-to-late 1990s (Carbon County 1998). Several spur tracks off the 

mainline serve larger industrial customers, including coal mines. In addition there are several 

major east-west natural gas pipelines crossing the area south of Hanna. 

3.18 HEALTH AND SAFETY 

Due to the relatively remote nature of the Hanna Draw Pilot Project area, there is a low level of 

concern regarding health and safety impacts to the human population under existing conditions. 

Activities examined as part of the Proposed Action primarily include occupational hazards 

associated with oil and gas exploration and operations and risks associated with vehicular travel 

on improved and unimproved county and BLM roads. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 3-65 
CHAPTER 4 

ENVIRONMENTAL CONSEQUENCES 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

CHAPTER 4 

Environmental Consequences 

This chapter of the environmental assessment provides an analysis of the potential 

environmental consequences that could result from implementation of the Proposed 

Action and the No Action alternatives. Potential consequences or impacts under these 

two alternatives are discussed in separate sections for each resource (Sections 4.1 

through 4.18), and cumulative impacts are discussed by resource in Section 4.19. An 

environmental impact may be either a direct or indirect result of the Proposed Action, 

and either permanent and long-term or temporary and short-term. This EA assumes that 

all applicant-committed measures described in Section 2.1.8 would be successfully 

implemented, and other protection measure required by the BLM or committed to as part 

of the project’s MSUP would apply as well. Additional mitigation was recommended 

where additional reduction in impacts was warranted by BLM policy and Land Use Plan 

decisions for specific environmental resources. 

4.1 AIR QUALITY 

4.1.1 Proposed Action 

Air pollutant emissions would be generated from the small number of exploratory wells 

and facilities proposed for the Pilot Project during well pad construction activities and 

production. Emissions would occur temporarily during well pad construction and over the 

life of the project for production. 

Air pollutant emissions from the well pad construction activities would result in low level, 

temporary effects to air quality in the immediate project vicinity, caused by particulate 

matter and exhausts from vehicles and equipment. As delineated in the project MSUP 

(see Appendix A), dust abatement measures would comply with all applicable WOGCC 

requirements. 

If these 15 pilot wells were deemed economical to produce, a complete air quality 

construction permit application would be prepared in strict accordance with WAQSR. 

The construction permit application package would be completed pursuant to 

requirements set out under WAQSR Chapter 6, Section 2. 

Temporary air pollutant emissions would occur from project construction and production 

of gas wells within the Hanna Draw Pilot Project area. Emissions from construction 

would include PM10, SO2, NOx, CO, and volatile organic compounds (VOCs) from ground 

clearing, use of heavy equipment, drilling, and well completion, as well as from 

construction of access roads. Emissions from construction would be temporary and 

would occur in isolation, and would not likely interact with emissions from adjacent wells. 

Production emissions of NOx, CO, VOCs, and HAPs (specifically formaldehyde) would 

result primarily from operation of the compressor engines. Estimated impacts to air 

quality assumed that the average potential emission rate of NOx for the compressor 

engines would be approximately 1.5 grams per brake horsepower hour (g/bhp-hr) of 

operation and CO and VOC emissions would be approximately 0.5 g/bhp-hr. Application 

of state-regulated BACT was considered in estimating emissions from compression. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-1 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Current control technology can reduce NOx emissions to between 0.7 and 1.5 g/bhp-hr. 

Emissions of CO and HAPs (formaldehyde) would be controlled with an oxidation 

catalyst. The emissions generated from operation of the compressors would contain 

negligible amounts of SO2 and particulate matter because of the composition of natural 

gas. The emissions resulting from compression operations were calculated for a total of 

2,300 horse power (hp) (based on 2 IC engines rated at 1,151 bhp each) resulting in 

33 tons per year (tpy) NOx, 11 tpy CO, 11 tpy VOC, and less than 1.6 tpy formaldehyde. 

Production emissions from the compressor engines would occur over the life of the 

project. Emissions from production wells would be negligible because the produced gas 

is nearly 100% methane and would require no ancillary production facilities at the well 

site. 

The BLM issued the Final Environmental Impact Statement for the Desolation Flats 

Natural Gas Development Project in 2004 (BLM 2004a). The proposed project is 

located south of the Pilot Project and targets similar productive horizons. Detailed air 

quality modeling was conducted for Alternative A of this NEPA analysis. Alternative A 

consists of the drilling and production of 592 gas wells at 555 locations with an assumed 

65% production rate, leading to 385 producing wells. Planned gas compression for the 

field development is estimated at 32,000 horsepower. Modeling was conducted at 

sub-grid, near-field (to 50 kilometers [km]) and far-field (50 to more than 200 km) levels. 

The results of the modeling studies for this project indicate that no adverse impacts to air 

quality from the Desolation Flats Project alone would be anticipated as a result of 

development of any alternative for sub-grid or near-field domains. Therefore, no 

adverse impacts to air quality would be expected from the much lower levels of 

development for the Pilot Project. 

The Pilot Project is located approximately 60 miles southeast of the Bridger Wilderness 

and approximately 120 miles northwest of the Mt. Zirkel and Savage Run wilderness 

areas, all Class I sensitive receptor areas. The Proposed Action would not materially 

detract from the area's far field visibility. Localized increases in criteria pollutants would 

occur, but maximum concentrations would be below applicable federal and state 

standards. 

In summary, no violations of applicable ambient air quality standards (NAAQS/WAAQS), 

PSD increments, or Air Quality Related Values (AQRV) would be expected to occur as a 

result of direct or indirect emissions of air pollutants from natural gas development 

(including both construction and operation) in the project area, particularly when 

compared to the detailed air quality impact assessment completed for the proposed 

Desolation Flats full-field development (BLM 2004a). Future well development would be 

in strict accordance with the WAQSR. Additionally, APC measures to reduce impacts to 

air quality, as outlined in Section 2.1.5.4 of this EA and the MSUP in Appendix A, would 

reduce non-particulate emissions by ensuring vehicles, rig engines, and other similar 

equipment are maintained in proper operational condition. Frequent watering of project 

access roads would likely achieve reductions in PM10 emissions by 50% or better. 

4.1.2 No Action Alternative 

Under the No Action Alternative, proposed development would not occur and no 

increased project-related air pollutant emissions would be generated in the short term. 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

4.1.3 Mitigation 

No additional mitigation or monitoring measures have been developed for air quality 

resources. 

4.2 GEOLOGY AND GEOLOGIC HAZARDS 

4.2.1 Proposed Action 

The Proposed Action would result in the removal of CBNG resources from Hanna 

Formation coals through the drilling of wells and the construction of pipelines. The 

process would involve drilling and completing wells to depths of approximately 5,000 feet 

below the ground surface. Installation of the proposed CBNG interconnect pipeline from 

the well sites to the south and southwest would necessitate trenching through soil cover 

and weathered bedrock units including the Hanna, Ferris, Medicine Bow, Lewis and 

Mesa Verde Group formations. 

No impacts from reduced slope stability would be anticipated from project construction in 

the drilling area. Some changes to topography from cut and fill operations during 

construction of new roads, drill pads, and ancillary facilities would occur; however, this 

level of impact would be low for a project of this scale and given the project area 

topography. 

Potential geologic hazards that could impact the proposed project include seismicity, 

flooding, subsidence, and landslides. The proposed Pilot Project activities would pose 

no additional risk to seismic activity as the project would involve the extraction of water 

as opposed to underground injection of fluids. Overall, the seismic risk in southern 

Wyoming is very low so that the impact of potential seismic activity on the proposed 

project is anticipated to be low. 

Flooding would pose little risk to infrastructure associated with the Pilot Project. 

Although the proposed CBNG interconnect pipeline would cross several drainages, once 

constructed, flash-flooding would not affect a completed and operational pipeline. 

Construction may provide an increase in sediment load to local drainages. Given the 

high sediment yield associated with flash flooding in this region, this increase would be 

temporary and negligible as stream bed and vegetation is re-established. 

The proposed interconnect pipeline alignment would avoid active and historic coal 

mining operations in the area, thereby minimizing potential subsidence impacts from 

project construction. As stated in Section 3.2.3, ground subsidence from the withdrawal 

of produced water is of concern for CBNG development. The removal of groundwater 

from unconsolidated sand and gravel aquifers has resulted in subsidence in areas such 

as the San Joaquin Valley, Las Vegas, New Orleans, Houston, and Mexico City. As 

much as 29 feet of subsidence has been recorded. However, the geologic strata 

underlying the Pilot Project consists of consolidated rock with porosities much lower than 

unconsolidated sand and gravel, and, therefore, much less likely to be compressed 

following dewatering. The estimates of ground subsidence associated with CBNG 

production for the Wyodak coal in the Powder River Basin predict subsidence of less 

than 0.5 inch (Case et al. 2002). Additionally, affected coal seams are much deeper 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-3 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

than those in the Powder River Basin and any subsidence would be expected to be 

attenuated because of the increased depth. 

Landslides deposits or active landslides have not been documented within the project 

area. Excavation for pipeline construction on steep slopes or along the toe of hillslopes 

could trigger small slides under ideal slope, soil type, and saturation conditions. 

Movement of backfill material in the pipeline excavation could lead to small slides after 

completion of pipeline construction activity. Overall potential for slope failure would be 

considered low, however, given the use of erosion control and reclamation procedures to 

minimize soil erosion from pipeline backfill. 

4.2.2 No Action Alternative 

Under the No Action Alternative, the Pilot Project would not be implemented and CBNG 

in the project area would not be developed through surface disturbance or excavation 

related to drilling and pipeline construction activities. Therefore, there would be no 

impacts related to geology and geologic hazards from the No Action Alternative. 

4.2.3 Mitigation 

No additional mitigations have been developed for geology or geologic hazards. 

4.3 PALEONTOLOGICAL RESOURCES 

4.3.1 The Proposed Action 

Potential direct impacts to paleontological resources could occur during implementation 

of the Pilot Project if surface disturbance associated with the project results in the 

exposure and destruction of important fossil resources and the loss of geologic 

information. Paleontological resources may be exposed and/or destroyed during 

excavation activities associated with drill pad, facility, and pipeline construction for the 

Pilot Project. As discussed in Section 3.3, Paleontological Resources, several 

geological formations underlie the Pilot Project area that meet the criteria for PFYC 

Class 4 with exposures of geological units or settings that have high potential to contain 

vertebrate fossils or noteworthy occurrences of invertebrate or plant fossils. An indirect 

impact to resources also could occur due to private collection or vandalism related to 

increased human presence in the area. 

Potential impacts to paleontological resources would be minimized because of the 

requirement in the BLM’s Great Divide Resource Management Plan (BLM 1987, 1988) 

which requires the recovery or avoidance of paleontological resources uncovered during 

ground-disturbing activities. Additionally, APC has committed to the standard BLM 

stipulation to protect paleontological resources, as outlined in Section 2.1.8. If 

paleontological resources were discovered, a BLM-approved professional paleontologist 

would evaluate these finds and BLM would determine the appropriate action or actions 

to maintain the scientific value of a discovery. 

4.3.2 The No Action Alternative 

Under the No Action Alternative, no additional direct or indirect incremental effects to 

4-4 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

undiscovered paleontological resources would occur. 

4.3.3 Mitigation 

No additional mitigation measures have been developed for paleontological resources. 

4.4 SOILS 

4.4.1 Proposed Action 

An estimated 399 acres of soils would be impacted during project construction and 

operation. During the construction phase, facility and utility sites would be cleared of 

vegetation, graded or excavated to specifications, and the construction/burial of facilities 

and utilities completed. As delineated in APC’s MSUP (see Appendix A), surface soils 

would be salvaged and windrowed/stockpiled along the borders of all proposed 

disturbed sites. Subsoils and other subgrade materials would remain in place for the life 

of the project, excepting for utility line burial disturbances where the subsoils would be 

excavated and replaced within a relatively short time span. Erosion and sediment 

control features would be constructed, as required. The construction phase of the 

project would be completed with the implementation of a concurrent reclamation plan 

applied to disturbances not required for the operations phase of this project (see 

Appendix A). 

The operations phase would involve the continued disturbance of soils associated with 

the operating well pads, utility corridors (including roads and utility lines), and CCF. At 

the close of operations, aboveground facilities and road surfacing materials would be 

removed, disturbed sites regraded to the desired contours, stockpiled soil replaced, and 

revegetation completed. Erosion and sediment features would remain in place until no 

longer needed. 

The linear nature of the proposed interconnect pipeline and power line corridors, yielding 

disturbances with high edge:area ratios, would increase the potential for overall 

reclamation success as compared to broader-type and more extensive surface 

disturbances. Desirable plant species establishment from adjacent undisturbed areas 

would be enhanced and the time required to achieve successful reclamation potentially 

shortened. 

4.4.1.1 Impacts to Soil Chemical, Physical, and Microbial 

Characteristics 

Impacts to soil resources resulting from these proposed disturbances include those that 

would affect the chemical, physical, and microbial nature of the endemic soils as well as 

the volumes available for reclamation. Soil chemical parameters that could be 

permanently modified as a result of the proposed soil salvage program include pH, 

salinity, sodicity, and fertility. Soil surface horizons would be mixed during soil salvage, 

resulting in a blending of characteristics, as compared to the soils in their natural state. 

Soil chemistry also would be modified through soil stockpiling as anaerobic conditions 

within the stockpiles develop, depending on stockpile size, depth, and longevity. A 

number of soil physical characteristics such as structure, texture, and rock fragment 

content would be permanently modified through blending during surface soil salvage and 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-5 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

replacement operations. Given that only surface soils would be salvaged/stockpiled, 

individual disturbances would result in little mixing of divergent soil types is likely to 

occur, the impacts to soils associated with salvage and replacement activities are 

considered to be limited in duration and intensity. The surface soil horizons would be 

mixed at any one site and would likely be similar in both chemical and physical 

characteristics and, given the site-specific soil volumes involved, would not likely result 

in a negative impact in terms of reclamation potential. The proposed reclamation 

program should, overall, adequately address these soil chemical and physical concerns 

and limit the impacts of soil salvage and replacement in the short term, following soil 

reapplication on disturbed surfaces. 

Isolated spill accidents, should they occur, would result in soil contamination from oils, 

diesel fuel, solvents, etc. Soils impacted by chemical spills would either be removed to 

an approved disposal site or bio-remediated in-place to effectively reduce the effects of 

this potential impact. No impacts to the revegetation potential of the soil resource would 

be anticipated. 

Compaction, particularly along access road disturbances and along linear ROWs, would 

reduce the aeration, permeability, and water-holding capacity of impacted soils from 

construction through the operations phase of this project. However, APC has committed 

to disk, rip, or otherwise treat disturbed sites where compaction could interfere with 

successful revegetation as part of the project’s reclamation plan (see Section 2.1.8). 

The effects of compaction, once these techniques are properly applied, would be 

reduced to a short-term impact. 

Soil microbial populations would likely change with a potential overall loss of 

nitrifying-type species as surface soils are salvaged and placed in stockpiles. This 

impact would be most notable in larger stockpiles where surface soils supporting 

microbial populations are buried to depths dominated by anaerobic conditions. The loss 

of such species would be less notable in smaller stockpiles windrowed along access 

roads or well pad boundaries where aerobic conditions dominate. Impacted soil 

microbial populations should reestablish readily over time following soil reapplication 

through natural invasion from adjacent undisturbed soils. The reclamation techniques to 

be applied also would aid in reestablishing soil microbial populations as reclaimed plant 

communities develop. This is considered to be a short-term impact. 

It is assumed that any dust control chemicals used onsite would be non-toxic to soil 

micro flora/fauna and no long-term buildup leading to soil sterility would occur. 

Cryptobiotic soils (soil crusts) are of concern to the BLM in terms of the ability of these 

soils to stabilize undisturbed soil surfaces and enhance the growth of plant species in 

semi-arid areas. Cryptobiotic soils are formed by blue-green algae, soil lichens, mosses, 

green algae, micro-fungi, and bacteria. Filaments, sheaths, hyphae, rhizines, and 

rhizoids are produced by these entities resulting in a bonding of soil particles forming a 

biological soil crust. The soil crusts that are formed typically decrease runoff and overall 

erodibility of the soil and increase water filtration and soil fertility levels (Belnap no date; 

USGS 2000). Soil crust development is not typically amenable to surface disturbances 

such as intense fires or cattle grazing. It also is uncommon on soils dominated by high 

coarse fragment contents, rock outcrops, or surface rock exposures. Soils exhibiting 

high herbaceous plant cover percentages do not typically support soil crust formation. 

4-6 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Cyptobiotic soils were not surveyed for in the field as a part this project. It is assumed 

that crusts occur within the boundaries of the proposed disturbances, although to what 

degree is uncertain. It can be assumed that surface disturbance activities associated 

with this project would disturb and/or eliminate crusts onsite. The degree or intensity of 

this impact cannot be accurately assessed. 

4.4.1.2 Impacts to Sensitive Soils 

Saline and sodic soils are rare across the project area as mapped by the NRCS. Such 

soils are associated primarily with the proposed drilling area disturbance. Potential 

impacts to saline and/or sodic soils focus on the suitability of these soils for reclamation 

and the availability of sufficient quantities of soil material for salvage and reapplication. 

These soils often exhibit droughty profiles due to high salinity levels and also may be 

subject to decreased soil aeration, infiltration, and permeability under high sodium levels 

when coupled with clayey soil textures. However, the soils exhibiting these 

characteristics in the proposed Section 2 drilling area support adapted, native vegetation 

communities. It can be assumed that with sufficient soil depths, efficient soil handling, 

and the planting of adapted species, reclamation of these disturbances could be 

achieved. 

No activities, excepting potential temporary disturbances associated with pipeline and 

power line construction ROWs would occur on slopes greater than 25%. Soil map units 

overlying steeper slope ranges occur across the area proposed for such disturbances 

but are most commonly associated with the “breaks” south of the Medicine Bow River 

and in the area of Sand, Edson, and Dana ridges near the southern terminus of the 

proposed CBNG interconnect pipeline ROW. Shallow soil depths coupled with moderate 

to severe wind and/or water erosion potentials are the norm for such map units. 

Stockpiled soils and soils respread over regraded disturbances on steeper slopes may 

be subject to increased runoff and higher erosion potentials until soil stabilization goals 

have been met. Mulching may be required to successfully stabilize these disturbed soils 

and to meet vegetation establishment goals. 

Impacts to steeper slopes are considered to be mitigable and short-term, assuming that 

proper soil handling and revegetation techniques are employed. Disturbance footprints 

may be visible for a limited time beyond the point when they are successfully stabilized 

and vegetation production is restored. 

Shallow soils are common across the project area and dominate all or in part, the 

majority of the proposed disturbances excluding drainage, floodplain, alluvial fan, and 

pediment land forms. Shallow soils are more susceptible to the negative affects of 

increased erosion due to the limited soil material available for supporting vegetation. 

Soil salvage and reapplication operations occurring on more gentle slopes could be 

conducted in shallow soil situations with adequate efficiencies. However, 

salvage/reapplication operations conducted under steep slope conditions would 

potentially be less efficient requiring a greater attention to detail during equipment 

operations. Similarly, surface stabilization following soil reapplication would be important 

to be certain that a sufficient depth of soil remains over disturbed sites to achieve site 

stabilization and plant establishment goals. 

Impacts to shallow soils, where soil salvage/replacement and revegetation techniques 

could be applied efficiently, also are considered to be short-term and mitigable. Impacts 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-7 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

to shallow soils where soils could not be salvaged or replaced due to equipment 

capabilities or slope/topographic influences would be viewed as a long-term impact. The 

few areas proposed to be disturbed as part of the proposed Pilot Project that fall into this 

category are associated with steeper slopes and rock outcrops. 

Soil map units characterized by moderate to severe or severe water and/or wind erosion 

potentials are dominant across the project area. Erosion potentials are typically highest 

during the construction phase of this type of project, decreasing in severity as concurrent 

revegetation, soil stockpile, and erosion control activities are completed. Erosion 

potentials would again rise at specific sites as the project is terminated and 

regrading/resoiling operations are initiated. Erosion hazard potentials would then again 

decline as the reapplied soils are stabilized and vegetation communities become 

established. 

APC has developed a number of site management and construction techniques as part 

of the Proposed Action and the company’s MSUP (see Section 2.1.2 and Appendix A). 

These techniques and approaches include using existing roads for access purposes to 

the degree possible, applying BLM “best management practices” during construction and 

revegetation activities (BLM 1988), minimizing new disturbances to the acreage 

necessary to complete construction and operations, siting project facilities to avoid or 

minimize disturbances to sensitive soils, and employing appropriate road maintenance 

techniques. Overall, impacts to highly erodible soils on more gentle slopes would be 

mitigable and short-term, assuming the application of the appropriate construction and 

reclamation techniques. The confounding factors of steep slopes and/or shallow soil 

depths added to high erosion hazards would inhibit reclamation potentials to varying 

degrees and increase the time required to achieve site stabilization and reclamation 

objectives. 

4.4.2 No Action Alternative 

Under the No Action Alternative, no project facilities would be constructed. The portions 

of the project area proposed for disturbance under the Proposed Action would continue 

in its present state supporting existing land uses. Natural rates of soil development and 

erosion would continue mirroring historic conditions. 

4.4.3 Mitigation 

No additional mitigation measures have been developed for soils resources. 

4.5 WATER RESOURCES 

4.5.1 Surface Water 

4.5.1.1 Proposed Action 

Under the Proposed Action, a maximum of 40,000 bbl/day (equivalent to 2.6 cfs) would 

be generated and stored (under a WYPDES permit) in the permitted, existing reservoir 

located in Section 13 (see Figure 2-2), not to exceed the estimated reservoir capacity of 

500 acre-feet. Produced water would be collected in buried polyethylene flowlines at 

individual wells for transport to the reservoir. 

4-8 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Chapter 2 describes the extent of anticipated surface disturbance from (see Table 2-1) 

project construction. Impacts to surface water are not directly related to surface 

disturbance. Roads and pads can impact surface hydrology beyond the initial 

disturbance concentration of run-off. The Proposed Action may result in adverse but 

localized impacts to intermittent and ephemeral water resources as a result of removal of 

surface cover, mixing of soil horizons, compaction, loss of topsoil productivity, and 

increased susceptibility to erosion. Such impacts, if any, would occur within fee section 

T24N R81W S35 and public section T23N R81W S2 (see Figure 2-2). 

The existing, permitted reservoir intended to accommodate the produced water has an 

estimated capacity of 500 acre-feet with a minimum freeboard of 5 feet. It is expected to 

accommodate the temporary water storage needs under this exploratory drilling program 

and the terms of the WYPDES permit. Based on the maximum anticipated flow rate of 

40,000 bbl/day, the reservoir could contain approximately 97 days of production water. 

APC would operate the system to meet the requirements of the permit while not 

exceeding the holding capacity of the reservoir, as described in the SEO permit for the 

reservoir. 

No removal or diversion of existing surface water resources is planned for the proposed 

project, so no impacts to existing surface water rights would be anticipated. The existing 

reservoir is permitted as a Class 3B water body and is located entirely on private land. 

Water quality data suggest that the produced water would be suitable for livestock and 

wildlife consumption, the likely uses of this water. Furthermore, the data also suggest 

that the produced water will meet the criteria for the designated uses of Class 3B waters 

(aquatic life other than fish, recreation, agriculture (livestock watering), wildlife, industry 

and scenic value). As noted in the WMP and in Section 2.1.7.2, APC would inspect two 

monitoring locations (downstream of each dam face) on a weekly basis during 

operations to ensure there is no reservoir seepage. 

As specified in the renewed permit for the reservoir (Permit #WY0044164), the produced 

water would be contained in an on-channel reservoir within a class 3B receiving stream, 

which is eventually tributary to a class 2AB perennial water of the state. The permit 

establishes effluent limits for the end of pipe are protective of all designated uses of the 

class 3B receiving waters, which include aquatic life other than fish, recreation, 

agriculture (livestock watering), wildlife, industry, and scenic value. 

Some infiltration of waters from the reservoir is anticipated and may result in seepage 

areas below the dikes on the east and west sides of the reservoir. Infiltration from the 

reservoir could potentially result in surface flow below the reservoir during the life of the 

project. The WYPDES permit has two points of compliance on either end of the 

reservoir that would be established to determine if surface flows occur, contrary to the 

intent of the permit for full containment. Monitoring would be done through visual 

inspection, but no monitoring of the shallow groundwater by APC is planned. Based on 

the intent of the WYPDES permit of full containment, there are no impacts expected to 

BLM lands below the reservoir. Impacts to channels below the reservoir due to surface 

flow resulting from reservoir seepage were not evaluated in this analysis (Hanna Draw 

tributary on the west or Pine Draw tributary on the east). No surface flows are 

anticipated based on the WYPDES permit’s intent of full containment of produced water 

in the reservoir. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-9 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

As the reservoir fills, dike faces that have not been saturated in the past would be 

saturated for the first time. Discharge from the reservoir would occur through only 

evaporation of infiltration given that there is no outfall or method to withdraw water from 

the reservoir once the reservoir is filled. In addition, the WYPDES permit does not allow 

any discharge of project-produced water below the reservoir. The long dimension of the 

reservoir is aligned parallel to the prevailing winds, and this coupled with the long fetch 

(~2,500 feet), is likely to result in wind-generated wave action at the dam faces. Since 

there is no outlet works or spillway, if such erosion were observed, the only recourse 

would be to cease discharge, with the expectation that evaporation and infiltration would 

lower the volume of water before further damage or potential failure of the dikes 

occurred. As stated in the WMP APC would reinforce the dam faces with an erosion 

control device to help prevent any erosion due to wave action, and they would inspect 

the dams quarterly or after major storm events for the first year of operation. 

Furthermore, the SEO has determined that this reservoir appears to be properly 

functioning and is not a high hazard dam because dam failure would not likely result in 

the loss of life or significant property loss. 

Upon completion of the proposed Pilot Project, the water in the reservoir would be 

allowed to evaporate. Assuming an annual evaporation rate of 123 acre-feet, an annual 

precipitation input to the reservoir of 35 acre-feet, annual runoff into the reservoir of 13 

acre-feet, and a full reservoir (500 acre-feet) at the end of the project, it would require 

approximately 6 years for complete water evaporation in the reservoir. Complete 

evaporation would likely occur more quickly because, as water levels decline, water 

temperatures would increase and evaporation rates would increase, accordingly. Salts 

and other major constituent concentrations would increase during this process, as is 

commonly observed in local stock ponds and other impoundments, which typically fill 

and dry annually, and because of the salt content in the produced waters. 

Reservoir Reclamation 

For the existing reservoir area, WDEQ would require reclamation of the impoundment 

through its WYPDES permitting process. If the reservoir would not be retained for 

further use following cessation of CBNG produced water discharge, APC may be 

required to perform some or all of the following reclamation activities, in accordance with 

the state permit: 

• Sample and analyze the soil on the floor of the reservoir. 

• Excavate layers of salts and mineral residue that may exceed acceptable 

agronomic concentrations, and isolate or place this material in a shallow disposal 

pit (less than 2 acre disturbance) so it would not leach into surface or 

groundwater. 

• Backfill, contour, and grade the disturbed area of the reservoir to the 

approximate original contours. 

• Stabilize all surface drainage channels that flow through the disturbed area. 

• Replace topsoil and seed and mulch the area with a native grass and shrub seed 

mixture, unless the landowner specifies another seed mixture consistent with the 

4-10 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

land use. If the area is open to active grazing, make arrangements to protect the 

reclaimed area to ensure successful revegetation. 

If APC, as the landowner and with authorization from the SEO, chooses to retain a 

portion of the impoundment for continued use, APC would be required to reclaim 

applicable portions of the reservoir, although the disturbed area would not be required to 

be reclaimed to the approximate original contours. However, the disturbed area above 

the authorized reservoir level, including the remaining embankment, spillway, and outlet 

structures must be stabilized to provide for long-term low maintenance care. 

Runoff and Sedimentation 

Wind and water erosion rates would increase above current rates until disturbed areas 

are successfully reclaimed. However, the potential for increased soil erosion and 

potential stream sedimentation would be minimized through the implementation of the 

applicant-committedmeasures (see Section 2.1.8), APC’s MSUP (see Appendix A), and 

BLM policies as delineated in the Great Divide RMP (BLM 1988). These measures 

include proper facility siting to avoid riparian areas and floodplains, use of best 

management practices, and proper reclamation techniques. No springs or seeps occur 

in the proposed drilling or facilities area. 

Surface water resources located along the proposed CBNG interconnect pipeline 

corridor (i.e., Hanna Draw, Big Ditch, and St. Mary’s Creek) would not be impacted by 

interconnect pipeline construction because of the various protection measures described 

in Chapter 2.0, Appendix A, and the BLM’s RMP (1988) and discussed further in 

Section 4.6 for wetlands resources. The small amount of water used for pipeline testing 

and dust control would not affect downstream users. Proper erosion control and 

hazardous material containment would reduce the potential for impacts to springs and 

seeps. With successful reclamation, only a very minor amount, if any, of project-related 

sediments would reach surface water resources. 

Even successful reclamation may not return an area to the previous function for surface 

hydrology, as perennial forbs and brush generally are more effective at reducing run-off 

energy. These plants are generally not required in reclamation, where seed mixtures 

are dominated by grasses and annual forbs. Conversion of steep forested or brush 

lands to grasslands may increase sediment yield up to five times (Anderson 1975). 

Although these represent extreme cases and are not likely to pertain to the Proposed 

Action, they suggest that interim reclamation, albeit successful, may not return some 

areas to predisturbance conditions for 30 to 50 years. 

4.5.1.2 No Action Alternative 

Hydrology and Water Quality 

Under the No Action Alternative, no discharge of produced water would occur to the 

existing water reservoir. No changes to water quality or hydrology would occur as a 

result of any action related to this project. The existing water reservoir would not be 

used for storage of produced water and would remain in its present condition with the 

potential addition of small quantities of produced water from the existing Well 2-2. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-11 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Sedimentation and Runoff 

No increased sedimentation or runoff over baseline conditions would occur in the 

affected watersheds in the project area or the interconnect pipeline corridor. 

4.5.1.3 Mitigation 

1. Any deviations from WYPDES discharge conditions that could result in potential 

future impacts to receiving waters would be mitigated under the administrative 

procedures set out in the WYPDES to ensure the protection of receiving waters. 

2. If seepage occurs at the reservoir resulting in open water present in Hanna Draw 

or Pine Draw below the reservoir, the operator would notify the WDEQ and the 

BLM immediately and would cease discharges into the reservoir until impacts 

can be assessed. 

3. If it appears that the reservoir capacity would be exceeded, APC would either 

shut in wells or reduce the rate of water discharge in one or more wells until the 

issue is resolved. 

4. If the existing water reservoir would not be needed for further storage of 

produced water following the end of the proposed project, the reservoir would be 

managed, removed, or reclaimed in accordance with reclamation and closure 

guidance from the SEO and WDEQ. 

4.5.2 Groundwater 

4.5.2.1 Proposed Action 

The Hanna Formation is a complex connection of interbedded sedimentary rocks with 

multiple aquifers under unconfined to confined groundwater conditions interspersed with 

multiple aquitards. The water table within the formation varies in depth from near 

surface to several hundred feet below grade depending on topography. Under the 

Proposed Action, confined groundwater would be produced from deep within the Hanna 

Formation (greater than 4,000 feet) at a rate of approximately 300 gpm for a period of 

1 year. This rate effectively equates to the reservoir capacity distributed over a 1-year 

period with no surface water discharge. Potential impacts to groundwater during 

operation of the Pilot Project could include the loss of groundwater in existing wells due 

to dewatering of the coal seams. 

The targeted coal seams are classified as confined to semi-confined aquifers because 

they are bounded by confining layers of fine-grained strata consisting of claystone and 

siltstone. Given these conditions along with the depth of the coal seams to be 

dewatered, the hydraulic connection to between the coal seams and any aquifer 

stratigraphically above or below is limited. The primary effects on groundwater 

resources as a result of project activities would be associated with the removal of 

groundwater contained in coal seam aquifers. The removal of groundwater from the 

coal aquifer results in the reduction of the hydraulic pressure head. The hydraulic 

pressure head is the vertical distance between the water level in a well and the top of the 

confined aquifer in which the well is completed. The lowering of water levels in an 

aquifer also is referred to as drawdown. Given the proposed pumping conditions, the 

4-12 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

drawdown and radius of influence can be estimated using an equation for confined 

aquifers (Theis 1935). 

Using the Theis equation to calculate drawdown effects for the proposed pumping 

parameters, a drawdown of up to 10 feet would occur within the coal beds (if lumped 

together), a distance approximately 2.5 miles outward from the section in which the 

pumping wells would be located. The 10-foot level was used for the analysis to 

differentiate project impacts from seasonal variability, typically in the 1- to 2-foot range. 

Potential impacts to surface water features hydraulically connected to the pumped 

horizons of the Hanna Formation and within the 10-foot drawdown contour could include 

decreased flow instreams, seeps, and springs, and increased seepage loss from 

reservoirs, lakes, and ponds if direct hydraulic connection were to exist between the 

coalbed aquifers and the shallow water table. 

The Wyoming SEO groundwater database contains 88 permitted well records within 

3 miles of the section from which groundwater dewatering is proposed (WSEO 2006). A 

list of the permitted wells within this area is provided in Appendix C. The wells in 

Appendix C represent those that are potentially within the zone of influence from coalbed 

dewatering where at least 10 feet of drawdown was estimated. Well use within the 

potentially affected area is almost exclusively related to oil and gas exploration and from 

wells used for dewatering and monitoring of surface mines in Hanna Basin (Appendix C). 

Given the depth of the coalbeds and their hydraulic isolation from underlying and 

overlying confining units, drawdown at the water table would not be anticipated. This 

assumption also is supported by the isotopic data, which indicates that the water has 

been out of hydraulic communication with surface waters or shallow groundwater for 

thousands of years. 

4.5.2.2 No Action Alternative 

Under the No Action Alternative, groundwater resources would not be further impacted, 

as drilling would not occur and groundwater levels would not be affected by proposed 

dewatering activities. Additionally, no discharge of produced water to surface water 

resources would occur. 

4.5.2.3 Mitigation 

Potentially affected landowners owning properly permitted water wells with the 

Wyoming SEO that may be impacted by water withdrawals from the project shall be 

offered a Water Well Agreement. If a water well agreement is not reached with the 

landowner, APC would mitigate the impact in accordance with State of Wyoming water 

laws. Some examples of mitigation could be drilling an additional supply well or providing 

CBNG water as an offset for the beneficial use. 

4.6 FLOODPLAINS 

4.6.1 Proposed Action 

Flood-prone areas occur adjacent to perennial streams, dry washes, and ephemeral 

streams in the Pilot Project area. Drainages with identified or possible flood hazard 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-13 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

areas include the Medicine Bow River, Hanna Draw, Big Ditch, and Saint Mary’s Creek. 

Impacts could occur to floodplains in the project vicinity if permanent alteration of the 

flood-prone area restricted the movement of floodwaters. 

Elements of the proposed Pilot Project would be constructed along or across flood-prone 

areas identified in the project area. Northern portions of the interconnect CBNG pipeline 

would follow Hanna Draw and would be located within flood-prone areas. In addition, 

the interconnect pipeline would cross floodplains associated with Big Ditch and Saint 

Mary’s Creek at approximately right angles to the direction of flow. Since pipeline 

construction would occur over a relatively short period of time and would not result in 

permanent alteration of the floodplain surface, negligible impacts to floodplain areas are 

anticipated from construction of the interconnect pipeline. 

4.6.2 No Action Alternative 

Under the No Action Alternative there would be no construction or potential for surface 

modification of flood-prone areas. 

4.6.3 Mitigation 

No additional mitigation measures have been developed for floodplain or wetland 

resources. 

4.7 VEGETATION, WETLANDS, AND RECLAMATION 

4.7.1 Proposed Action 

Direct effects to vegetation resources from the proposed Pilot Project would include the 

removal of vegetation as a result of the construction of various project components. 

Utility line burial would occur in association with road construction and impact 

approximately 13 acres of vegetation. Construction of the interconnect pipeline would 

impact approximately 306 acres of vegetation in a manner similar to that of the buried 

utility line construction. It is assumed that less than 2 acres of vegetation impacts would 

be associated with construction of the aboveground electric power line. These 

disturbances would be mitigated concurrently following facility burial through backfilling, 

resoiling, and the application of approved revegetation techniques completed the first full 

growing season following disturbance (see Appendix A). 

The construction of access roads, drilling pads, and associated production facilities 

would remove vegetation from approximately 44 acres. Disturbances would typically be 

confined to surface soils leaving the subsoils in place. Portions of these disturbances not 

needed for continuing operations would be available for reclamation following 

construction. The remaining acreage would remain in a disturbed state through the life 

of the project or until such facilities are no longer needed and are reclaimed. 

In comparison to other impacts, the magnitude and duration of impacts related to the 

acreage reclaimed concurrently are lower overall due to the timely application of 

revegetation techniques. The loss of existing vegetation would reduce the plant 

productivity until vegetation has become re-established. It is assumed that acceptable 

revegetation on amenable sites can be achieved in a 5-year period given the application 

4-14 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

of the appropriate revegetation and management techniques. Disturbed sites exhibiting 

low reclamation potentials due to soil physical and chemical limitations could take longer 

to respond and require a greater attention to detail. 

The impacted acres associated with the operations phase of this development would 

remain in a disturbed state for the life of the project. Final reclamation of these sites 

would occur in the same manner as for the sites subject to concurrent reclamation in 

terms of the mitigation approach. However, these sites would remain unvegetated for a 

notably longer period resulting in a loss of vegetation production through time. It is 

assumed that the time frame required to achieve acceptable revegetation for this 

acreage following project element termination would be essentially the same as noted 

above. 

It is reasonable to assume that herbaceous species would become established initially 

with the development of desired forb and shrub components lagging due to typical 

establishment and growth potentials. The narrow, linear nature of road disturbances and 

the relatively small disturbed acreage associated with well pad sites should promote the 

invasion of the desired native shrub and forb species from adjacent, undisturbed areas 

over time. 

It is assumed that any dust control chemicals used onsite would be non-toxic to 

vegetation, either during application or with respect to long-term buildup in the soil. No 

impact to the vegetation resource is expected. However, increased heavy traffic would, 

in turn, increase dust production to some level beyond that existing, as would wind 

erosion from temporarily unvegetated disturbed areas. Heavy dust accumulations on 

adjacent vegetation could cause a decrease in plant productivity and reduce palatability 

for livestock and wildlife. 

Table 4-1 depicts the acreages of each vegetation type likely impacted under the 

Proposed Action for both concurrent and final reclamation. The revegetation potentials 

shown were estimated based on field observations. Reclamation potentials ranging from 

“low to moderate” were assigned to vegetation map units within which 86 acres of 

concurrent and 19 acres of final reclamation would be required. Supporting soil map unit 

characteristic data and soil use interpretations also were reviewed. 

Vegetated wetlands and open water features occur within the project boundaries in the 

form of drainages, stock ponds, isolated ox-bows, diversion ditches, and the Medicine 

Bow River. The majority of such sites occur along the interconnect pipeline ROW. As 

stated in Section 2.1.8, APC has committed to span the existing vegetated wetlands of 

the Mixed Grass-like/Grass Meadow Community along the proposed electric distribution 

line ROW and avoid disturbance to other vegetated wetlands and open water features, 

where practicable. Avoidance of vegetated wetlands and open water features along the 

ROW may not be possible where such features cross the ROW in a perpendicular 

manner. The acreage of such features that could be impacted is not known at this time 

but is estimated to total less than 10 acres. It is assumed that, prior to construction APC 

would contact the U. S. Army Corps of Engineers to obtain the proper permits from this 

agency with respect to jurisdictional features. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-15 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Table 4-1 Vegetation Map Unit Impact Acreages and Reclamation Potentials 

Map Unit Name 

Total 

Acreage 

Reclamation 

Potential 

Proposed 

Action 

Impacted 

Acreage 

(Concurrent/ 

Final Phase)1 

No Action 

Alternative 

Impacted 

Acreage 

(Current/ 

Final Phase)1 

Wyoming Sagebrush/Mixed 

Grass Community 283 Moderate 272/11 0/0 

Low Shrub/Mixed Grass 

Community 80 Low to Moderate 62/18 0/0 

Mixed Shrub Community 4 Low to 

Moderate 4/0 0/0 

Greasewood and Basin Big 

Sagebrush Drainages 

21 Low to 

Moderate 20/1 0/0 

Mixed Grass-like/Grass 

Meadow Community <1 High 0/0 0/0 

Reclaimed Grass Community 7 Moderate 7/0 0/0 

Rock Outcrop/Broken 

Land/Miscellaneous Land 

Types 

4 Low 4/0 0/0 

1

"Concurrent" refers to the disturbed acreage to be reclaimed following initial construction. "Final Phase" 

refers to the disturbed acreage remaining to be reclaimed following the conclusion of project operations. 

Both the Wyoming Sagebrush/Mixed Grass and Reclaimed Grass units were given a 

“moderate” rating for reclamation potential. These units typically occur on nearly level to 

moderately rolling terrain and exhibit shallow to moderately deep soil profiles. The 

primary revegetation constraints associated with these map units include moderate to 

high pH values, the potential for sandy soil textures leading to droughty seedbed 

conditions, and occasional steep slopes, particularly across the “breaks” formation 

located south of the Medicine Bow River. Concurrent (i.e., short-term) and final phase 

reclamation (i.e., long-term) would be required on 279 and 11 acres, respectively, in 

these vegetation types. 

The Mixed Shrub community is typically among the more productive of the vegetation 

communities mapped onsite, although elements of these units occupy steeper slopes 

and exhibit shallow soils leading to a lower potential rating. Where deeper soils occur on 

more gentle slopes, reclamation potentials would be higher. Constraints related to the 

Low Shrub/Mixed Grass unit are typically associated with soil chemistry parameters 

including pH and salinity and with a propensity to shallow soil profiles. Deep soils and 

nearly level topographies are characteristic of the Greasewood and Basin Big 

Sagebrush Drainages community resulting in a trend to a higher rating. However, this 

map unit may exhibit the same soil chemistry constraints as noted for the Low 

Shrub/Mixed Grass unit. A lower potential is assumed for this unit where pH and soil 

salinity levels are excessive. 

A “low” reclamation potential was assigned to the Rock Outcrop/Broken 

Land/Miscellaneous Land Type unit due to steep slopes, shallow soil depths, a lack of 

soil material, and high profile coarse fragment contents acting singly or in combination. 

A total of 4 acres of short-term and 0 acre of long-term disturbance would occur within 

this map unit. 

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APC outlines a potential reclamation seed mixture in the MSUP (see Appendix A), if no 

seed mixture specifications are identified for the proposed project. APC also has 

committed to work with the BLM to develop an appropriate seed mixture(s) for the 

varying site characteristics, such as soil chemical and physical parameters and the 

different vegetation community types (see Section 2.1.8). Seed mixtures could be 

developed to specifically address the varying characteristics of the Wyoming 

Sagebrush/Mixed Grass, Low Shrub/Mixed Grass, Mixed Shrub, Greasewood and Basin 

Big Sagebrush Drainages communities. According to the MSUP, seeding is proposed to 

occur in the fall after September, prior to ground frost, or in the spring after frost. This 

reclamation approach would address many of the issues associated with applying an 

appropriate seed mix, such as enhancing revegetation success and minimizing the 

spread of invasive weeds. 

Three state-listed noxious weed species (whitetop, Canada thistle, and Dalmation 

toadflax) and one Carbon County-declared noxious species (halogeton) were found in 

larger populations during the July 2004 field survey. Populations of two additional 

state-listed noxious species (leafy spurge and Russian knapweed) also have been 

observed within, or in close proximity to, the project area boundaries. With respect to 

invasive weed species not listed as noxious, four such species are known to occur within 

the boundaries of the project area. These species include Russian thistle, cheatgrass, 

curly-cup gumweed, and babysbreath. 

Invasive weed populations, whether considered noxious or non-noxious, can increase as 

a result of both project construction and operation, including monitoring. Drill pad 

clearing and grading operations can stimulate the germination and establishment of 

weed seeds present in the soil prior to disturbance. The construction and upgrading of 

roads can result in a similar enhancement of weed populations as can the disturbances 

related to the burial of the proposed pipeline facilities. Equipment initially brought into 

the project area can bring with it weed seeds from offsite sources engendering the 

spread of undesirable invasive species and can enhance such infestations through 

continued travel within project area boundaries. 

APC has committed to monitoring and inspecting project facilities regularly to ensure that 

noxious weeds do not become established in newly disturbed areas. Weed control 

methods would be based on available technology, weed species involved, and the 

applicable BLM requirements associated with the control of noxious weeds (see MSUP 

in Appendix A). Therefore, while the Pilot Project activities would likely enhance the 

spread of noxious weed species, APC has committed to and would be required to 

control such infestations, as per BLM requirements related to monitoring and control 

activities. 

Although not specifically committed to in the MSUP, it need be noted that APC would be 

required, as directed by the BLM, to control specified non-noxious invasive weed 

species such that these species do not expand or become established and pose a threat 

to existing native plant communities. 

4.7.2 No Action Alternative 

The project area would continue in its present state, subject to the vagaries of climatic 

influences and continued land use activities. No vegetation type would be impacted 

under the No Action Alternative for both concurrent and final reclamation. It is assumed 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-17 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

that the existing grazing, recreation, and open space land uses would continue in 

essentially their present form and intensity impacting the vegetation communities onsite 

in a manner consistent with historic land uses. Weed populations would remain present 

and may expand or contract as a result of changes to climate, human activity, and 

human intervention. 

4.7.3 Mitigation 

No additional mitigation measures have been developed for vegetation resources or 

reclamation. 

4.8 TERRESTRIAL WILDLIFE 

4.8.1 Proposed Action 

Habitats and Overview 

The analysis of potential direct, indirect, short-term, and long-term impacts to terrestrial 

wildlife species was based on documented species’ use of the area, associated habitat 

values, relative degree of historical and ongoing mineral (e.g., coal, CBNG) exploration 

and development activities in and near the Pilot Project and its ancillary facilities (i.e., 

Proposed Action). Direct habitat losses would result from well pad, access road, and 

utility line construction, and indirect impacts would occur from increased human 

presence. Short-term impacts would arise from habitat removal and disturbance, as well 

as from activities associated with construction, drilling, and production. These impacts 

would cease upon project closure and completion of successful reclamation. Long-term 

impacts would consist primarily of permanent changes to habitats and the wildlife 

populations dependent on those communities. Historically, the area has experienced a 

low to moderate level of coal extraction and CBNG exploration; however, the area 

habitats, terrain, and landscape features support a diverse number of terrestrial wildlife 

species, as outlined in Section 3.8. The Proposed Action’s project components were 

examined relative to the temporal and spatial patterns of both resident and migratory 

wildlife species and the current wildlife population trends apparent in the project area. 

The Proposed Action proposes a fairly contained drilling scenario of 15 vertical CBNG 

wells; however, the placement and density of these wells entirely within Section 2 

combined with the existing Well 2-2 would fundamentally result in 40-acre well spacing 

for the Hanna Draw Pilot Project. The presence of the existing roads combined with the 

previous, current, and proposed gas exploration and development activities would 

reduce the overall habitat values and associated carrying capacities of these native 

habitats and increase overall habitat fragmentation for area wildlife species in a small, 

but concentrated area. The ancillary CBNG interconnect pipeline and electric 

distribution line ROWs also would contribute to the loss and disturbance of native and 

reclaimed habitats, overall habitat fragmentation, and animal displacement, but effects 

would be more dispersed along these linear features. The potential direct loss of wildlife 

species from project construction and operation would be expected to be low to 

moderate, depending on the species (as discussed below), and habitat fragmentation 

and animal displacement would be moderate to high, as discussed in more detail for 

each species or animal group. 

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Impacts to terrestrial wildlife species from an increase in human presence are generally 

proportional to the size and duration of the project, construction work force, overall land 

use, recreational demands (e.g., hunting ORV use), and other regional activities. 

Increased noise levels during project construction and operation often results in some 

animal displacement in both the short and long term. Typically, animals either avoid 

noise sources or become accustomed to the increased noise levels. Abrupt and 

intermittent noises would be more likely to disturb individuals than the more continuous 

noises (e.g., traffic, equipment operation). The severity of the potential impacts from 

both an increase in human presence and increased noise levels would depend on 

factors such as the species’ sensitivity, seasonal use patterns, the type and timing of 

project actions, noise sources and duration, and physical parameters (e.g., buffering 

capacity of area topography, cover, forage, other environmental factors). 

The Proposed Action would result in 399 acres of new disturbance (i.e., direct habitat 

loss). The habitat types impacted by new surface disturbance associated with the Pilot 

Project are delineated in Section 4.7.1 for vegetation resources. Of the 399 acres of 

disturbance estimated for the Proposed Action, 369 acres would be reclaimed within 

1 year of construction, or as soon as possible, and 30 acres would be left unreclaimed 

for the duration of the project. No impacts to area cliff habitats, which provide a higher 

species’ richness and diversity for terrestrial wildlife (Ward and Anderson 1988), would 

occur from implementation of the Pilot Project. 

The disturbance of wildlife habitat would reduce habitat availability for a variety of small 

birds and mammals. The temporary disturbances that would occur during the 

construction period would tend to favor early successional wildlife species such as 

ground squirrels and horned larks and would have more impact on mid-to-latesuccession species such as sage sparrows, sage thrashers, and voles. The long-term 

disturbance acres would have a minor effect on wildlife species not dependant upon 

shrubs. In addition to the direct disturbance acreage, dust would directly and indirectly 

impact 15% to 30% more acreage. Dust not only directly impacts the plants, but also 

reduces plant palatability for livestock and wildlife, possibly resulting in habitat avoidance 

by birds, mammals, and insects. Indirectly, this may increase inter- and intra-species 

competition for nesting and foraging areas. In habitats already fully occupied (i.e., at 

carrying capacity), density-dependant species would be further displaced, possibly 

outside of the project area. This may force animals to utilize lower quality habitats, 

which may lead to a reduction in reproduction rates or an increase in predation. 

Potential direct and indirect effects to wildlife species from changes in water quantity or 

quality during project construction or operation are discussed in detail for those 

applicable species (e.g., waterfowl and other water birds) dependent on aquatic 

communities. As outlined in Section 2.1.8 for Floodplains and Wetlands, APC has 

committed to span the existing vegetated wetlands of the Mixed Grass-like/Grass 

Meadow Community along the proposed electric distribution line ROW and avoid 

disturbance to other vegetated wetlands and open water features, where practicable. 

Avoidance of vegetated wetlands and open water features along the ROW may not be 

possible where such features cross the ROW in a perpendicular manner; however, the 

acreage of such features that could be impacted is estimated to total less than 10 acres. 

No impacts to water quality from project construction would be anticipated, based on the 

construction practices and protection measures outlined in APC’s MSUP to minimize soil 

erosion and potential materials spills during construction activities (see Appendix A) and 

on the BLM’s guidelines to minimize surface disturbance within 500 feet of surface water 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-19 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

and riparian areas in the BLM’s current Great Divide RMP (BLM 1988). Additionally, 

compliance with the WDEQ stormwater permit would protect water quality during 

construction on the private fee lands. 

The analysis of potential impacts to water and associated terrestrial species 

encompasses use of temporary reserve pits for each well site and use of the existing 

reservoir in Section 13. These analyses focus on the potential effects to resident and 

migratory birds as discussed below for waterfowl and other water birds. 

Big Game Species 

The discussion of potential direct and indirect impacts to big game species focuses on 

the potential short- and long-term impacts to pronghorn (antelope) and mule deer 

relative to these species’ crucial winter range use. No impacts to elk or moose from the 

proposed Pilot Project would be anticipated, based on the habitats found in and near the 

project area and these two species’ distribution and habitat use. 

Over time, individual animals may habituate to certain disturbances, depending on the 

spatial relationship (i.e., distance) between these areas of disturbance to available 

forage, water, and thermal cover. However, this is true for only certain individuals within 

a population. Other individuals may exhibit a lower tolerance to certain human-related 

activity thresholds. Therefore, animals within a population may respond differently to 

construction and operational actions. Pronghorn have a tendency to exhibit a greater 

level of movement on winter ranges, as compared to other big game species. 

Therefore, pronghorn winter range boundaries are somewhat less fixed than those of 

mule deer (Wyoming Chapter of the Wildlife Society 1990). However, Rawlins FO 

biologists have noted anecdotally that in impacted areas, pronghorn herd sizes are 

significantly smaller than in relatively pristine areas. Those animals that potentially 

acclimate seem to do so only in smaller herd sizes. In undisturbed areas, the herds are 

much larger and show flight responses at much greater distances than in disturbed 

zones. 

The following analysis focuses on the limiting factors associated with the pronghorn 

crucial winter/yearlong range that intersects with 10 of the 16 proposed well locations 

located in Section 2, the CCF in Section 35, the northern portion of the proposed 

interconnect pipeline and distribution line ROWs, and farthest terminus of the 

interconnect pipeline ROW (see Figures 3-4 and 3-5). Of the 10 wells located in the 

northern two-thirds of Section 2, one is the existing Well 2-2 (see Figure 3-4). 

Pronghorn crucial winter range, in particular, is considered by the BLM and WGFD to be 

a critical limiting factor for the overall carrying capacity of the native range. 

The BLM stipulation of prohibiting construction and other activities potentially disruptive 

to wintering wildlife during the period of November 15 to April 30 for the protection of big 

game winter habitat would minimize the potential for direct and indirect disturbance of 

wintering mule deer and pronghorn during construction phases (BLM 1988). It does not 

address the potential loss of wintering habitat due to the presence and operation of wells 

in winter range for the life of the project after construction is complete. 

Therefore, no impacts to pronghorn on the crucial winter/yearlong range would occur 

from project construction, based on these BLM requirements (BLM 1988). However, 

relative to project operation, Point 8 of APC’s MSUP (see Appendix A) indicates routine 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

maintenance of producing wells would be conducted approximately every other day. 

Therefore, potential direct and indirect impacts to big game species focused on the 

proposed operation of the Pilot Project. 

The drilling of eight additional wells within the pronghorn crucial winter/yearlong range in 

Section 2, building the ancillary access road and flow line ROWs, and the construction of 

the CCF in Section 35 would result in a total direct loss of 64 acres of this crucial winter 

range in the short term and 17 acres in the long term following site reclamation. 

Following reclamation, herbaceous vegetation and grasses would re-establish in the 

short term, and woody species may require 20 to 50 years to re-establish. The primary 

woody species impacted would be sagebrush, an important winter food component for 

both pronghorn and mule deer. 

Although the direct acreage effects to pronghorn crucial winter range would be only a 

fraction of the entire Medicine Bow Herd Unit (#525) area, potential indirect impacts 

during project operation warrant additional analysis. The proposed well density (i.e., 

approximate 40-acre spacing) is considered to be dense for big game ranges 

(WGFD 2004c). The influence of each project component effectively extends outside 

the surface disturbance footprint, which is generally determined by the individual 

animal’s avoidance and stress responses to an activity or facility. These factors not only 

reduce the associated habitat value of the adjacent areas, they also extend the 

displacement zone of individuals. Consequently, impacts to wildlife could extend farther 

offsite than the actual amount of disturbed area for the Proposed Action. As densities of 

wells, roads, and facilities increase, the effectiveness of adjacent habitats decrease, and 

even if natural features remain unaltered near oil and gas features, wildlife typically uses 

proportionately less of these areas relative to their availability. Additionally, increased 

physical or psychological (i.e., disturbance-related) barriers lead to habitat fragmentation 

and further reduce the availability of effective habitat. These impacts can be especially 

problematic when they occur within limiting habitat components such as crucial winter 

ranges and reproductive habitats (WGFD 2004c). 

Assuming a displacement distance of 0.5 mile for pronghorn, the consequential indirect 

effects to crucial winter range were calculated for the area surrounding and including 

crucial winter range located in Section 2 and approximately one half of Section 35. 

Assuming the development and use of the project components in these areas would 

result in the overall loss and reduction of crucial winter range habitat value, 

approximately 2,747 acres would be affected in the long term (LOP) (see Figure 4-1). 

While this is, as noted, a small portion of the total pronghorn herd unit area 

(approximately 1%), the contiguous winter range habitat block that this project affects is 

much smaller than the herd unit area. The total crucial winter range component 

extending east-west from the project area is approximately 61,593 acres 

(see Figure 3-4), which translates to the loss of approximately 4.5% of this affected 

crucial winter range area from indirect effects in the Pilot Project area. The portions of 

the CBNG interconnect pipeline and electric distribution line ROWs would directly affect 

an additional 29 acres in the short term and only 0.1 acre of pronghorn crucial winter 

range in the long term. Because of the linear nature of these ROWs, temporary nature 

of construction impacts, and successful reclamation efforts, it is assumed that these 

linear facilities would incrementally increase habitat fragmentation and loss in the short 

term, but not result in total displacement of individuals during project operation (i.e., long 

term). 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Although a native range’s carrying capacity for wildlife will vary, based on precipitation 

levels and vegetative trends, the proposed well density and extent of ancillary facilities in 

the immediate project area would reduce the relative carrying capacity of the crucial 

winter range in the drilling area. The habitat fragmentation and animal displacement 

would result in the underuse of habitats in close proximity (within 0.5 mile) of the 

disturbance areas (i.e., a reduction in habitat value); increased animal densities on 

remaining habitats; and increased stress from inter- and intra-specific competition. The 

degree of pronghorn displacement and reduction in habitat values would vary, 

depending on the habitat types, vegetative cover (forage and thermal), topography, 

aspect, existing population dynamics, traffic levels, and future road use. Displacement 

would result in local reductions in wildlife populations if adjacent, undisturbed habitats 

are at carrying capacity. In this situation animals are either forced into less than optimal 

habitats or they compete with other animals that already occupy unaffected habitats. 

Possible consequences of such displacement are lower survival, lower reproductive 

success, lower recruitment, and ultimately lower carrying capacity and reduced 

populations (WGFD 2004c). 

The WGFD (2004c) developed recommended minimum recommendations on thresholds 

for oil and gas development in crucial and other important wildlife habitats on BLM lands. 

These management guidelines were structured to provide a tool to be implemented on a 

programmatic basis on BLM lands in Wyoming. In this review, the WGFD classifies 

“important wildlife habitats,” based on certain defining factors. “Vital habitats” are 

defined as “directly limit[ing] a community, population, or subpopulation, and restoration 

and replacement may not be possible.” Big game crucial winter ranges are classified as 

“vital habitats,” and the WGFD recommends “no loss of habitat function” for these areas 

(WGFD 2004c). 

According to the WGFD (2004c), thresholds based on well pad densities and cumulative 

acreages also may under represent the actual level of disturbance to wildlife. As 

discussed above for pronghorn displacement effects, the WGFD states the function of 

big game crucial winter range would decline in the zone of influence, resulting in the 

effective loss of that habitat for long-term use. The agency also notes that under certain 

impact categories (e.g., extreme) “habitat function is substantially impaired and cannot 

generally be recovered through management or habitat treatments.” However, it is 

difficult to apply these guidelines and thresholds generated for large-scale oil and gas 

development on more of a landscape scale to the Hanna Draw Pilot Project. Parallel 

assumptions between the state’s standards and this project would be the assessment 

that given the well density in Section 2 and presence of ancillary facilities (e.g., road, 

CCF) in Section 35, pronghorn would be displaced in the long term from an estimated 

2,747 acres of crucial winter range for the life of the project (10 to 20 years), and a 

reduction in habitat value for this area would result until final reclamation. 

Herd health and longevity are key in assessing both short- and long-term impacts to 

pronghorn. In 2004, the Medicine Bow Herd Unit (#525) was considered to be at 

objective (i.e., 60,000 pronghorn for the entire unit) (WGFD 2005c). Hunting seasons 

and harvest limits have been established to reduce or maintain this herd. However, the 

ongoing drought in the western U.S. continues to affect native ranges and the big game 

species that depend on these ranges. The WGFD believes that the area may not 

continue to support the herd unit objective given the drought conditions (WGFD 2005c). 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

In addition to animal displacement from human-related activities by avoidance, 

increased human presence also would directly increase the potential for wildlife-human 

interactions, ranging among wildlife harassment, poaching, and increased legal hunter 

success and the associated hunting pressure. Harassment, whether intentional or 

unintentional, can impact wintering animals and can result in both direct and indirect 

mortalities of individuals during periods of high stress and extreme winter conditions. 

Additionally, increased traffic levels on new and existing access roads could increase the 

potential for wildlife-vehicle collisions. 

The potential effects to native habitats surrounding the proposed reservoir site in 

Section 13 from a potential increase in future use by big game and other terrestrial 

wildlife species would be expected to be small. Although some increase in vegetation 

removal and trampling along the margins of the reservoir may be expected during 

project operation, the reservoir site is located outside of crucial winter range for 

pronghorn (see Figure 3-4) and water available from the Medicine Bow River and other 

area stock tanks or ponds would aid in minimizing effects to the terrestrial habitats 

surrounding the reservoir. 

The anticipated direct and indirect impacts to mule deer from implementation of the 

construction and operation of the Proposed Action would be less than those discussed 

for pronghorn. The only project component that intersects with crucial winter range for 

mule deer is an approximate 3-mile segment of the proposed gas transmission ROW. 

An estimated 27 acres of this range would be affected in the short term from project 

construction. Assuming successful ROW reclamation, it is assumed that the habitat 

along this corridor would return to pre-construction conditions, and no habitat loss was 

calculated for the long term. Projected habitat loss and fragmentation, increased human 

presence, and indirect effects to local deer in the proposed drilling area would result in 

impacts to mule deer winter-yearlong range for the Shirley Mountain and Platte River 

Herds. 

In summary, a number of factors apply and should be examined relative to the Proposed 

Action, its potential direct and indirect effects to pronghorn on designated crucial winter 

range, and certain factors that help to mitigate these effects. First, the immediate project 

area is located on the edge of this crucial winter range and pronghorn generally exhibit 

greater variance in movements on winter range than other big game species (Wyoming 

Chapter of the Wildlife Society 1990). Therefore, the scale, location, and nature of the 

Pilot Project would result in incremental effects to this range and the animals that 

depend on it. Second, potential effects from this small, but concentrated project 

scenario extend beyond the proposed footprints of the anticipated surface disturbance. 

The proposed well density (approximate 40-acre spacing) would reduce the habitat 

effectiveness for an area that encompasses the assumed displacement distance of 

0.5 mile for pronghorn surrounding and including the proposed drilling area and ancillary 

facilities. Third, the Medicine Bow Herd Unit is currently at herd objective, although the 

continuing western drought may affect pronghorn numbers and the established 

population threshold of 60,000 animals. Finally, proposed development at the current 

well and facility density in the immediate project area (i.e., Section 2 and a portion of 

Section 35) would likely result in the loss of that crucial winter habitat component in the 

long term for pronghorn. Although some individual animals can habituate to the 

increased infrastructure, it is generally assumed the increased human footprint on a 

previously lightly developed area would be detrimental to big game species. As well, 

acclimation to activity may increase predation on some species. However, although the 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-24 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Proposed Action would result in relatively concentrated effects to pronghorn and to a 

lesser extent mule deer in the immediate project area, the anticipated scale of this 

potential habitat loss and fragmentation and resulting effects to the local animals from 

the Pilot Project applies to a relatively small area and would not likely affect the overall 

herd health and ability to support the state and federal objectives for the Medicine Bow 

Herd. 

Upland Game Birds, Waterfowl, and Other Water Birds 

Potential impacts to terrestrial species generally associated with open water or the 

riparian community (e.g., waterfowl, wading birds, shorebirds) may occur. As discussed 

above for general wildlife habitats, APC has committed to span the existing vegetated 

wetlands of the Mixed Grass-like/Grass Meadow Community along the proposed electric 

distribution line ROW and avoid disturbance to other vegetated wetlands and open water 

features, where practicable (see Section 2.1.8). Also, no impacts to water quality from 

project construction would be anticipated, based on the construction practices and 

protection measures outlined in APC’s MSUP (see Appendix A) and the assumption the 

APC would follow these measures in activities occurring on fee estate. 

There could be potential impacts to birds that may be attracted to the temporary reserve 

pits during project operation. As stated in the project MSUP (see Appendix A), APC has 

committed to develop procedures to prevent wildlife from accessing temporary reserve 

pits, in the event that water quality is determined to be potentially detrimental to wildlife 

(e.g., oil deposition). However, even with the best available protection measures, not all 

wildlife can be excluded from reserve pits. Consequently, some impacts to wildlife may 

occur through their inadvertent access to pits. 

Potential effects to terrestrial wildlife from operation of the existing reservoir in 

Section 13 also was examined. During project operation, increased soil salinity from 

continual water evaporation in the reservoir area would likely occur; however, elevated 

soil or water salinity levels would not impact bird species that may use this resource. 

This analysis focused on the possible exposure risks of avian species to metals and 

other constituents of concern from ingestion of water, plants, or macroinvertebrates. 

Although water quality analyses conducted to date (e.g., wells 14-35 and 2-2) indicate 

that impacts to terrestrial species would likely be none to small, some unknowns still 

exist for long-term project operation. 

APC must adhere to state and federal water quality regulations, meeting at a minimum 

the limits and monitoring requirements set by WDEQ for end-of-pipe water quality in 

off-channel impoundments. The storage in the existing water reservoir is permitted as a 

Class 3B water body. Water quality data suggest that the produced water would be 

suitable for livestock and wildlife consumption, the designated uses applicable to this 

class of waters. The possibility of bioaccumulation of constituents of concern for 

terrestrial wildlife species within the reservoir pool is discussed further. 

From past studies, potential bioaccumulative substances that may be found in CBNG 

produced water include selenium, boron, cadmium, chromium, and mercury (Ramirez 

2005). Presently, the WDEQ water quality classification standard for selenium is 5 μg/L. 

However, a Powder River Basin report for CBNG produced water states, “The WDEQ 

aquatic life chronic criterion of 5 μg/L (parts per billion) selenium is not adequate for 

preventing adverse effects on fish and aquatic birds. Several scientific experts on 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

selenium have recommended a 2 μg/L criterion because concentrations exceeding 

2 μg/L may create a bioaccumulation risk for fish and sensitive species of aquatic birds 

(Lemly 1993; Skorupa and Ohlendorf 1991).” 

The existing, permitted reservoir would be the only receiving water for production water 

discharge and does not and would not maintain a fish community. It may be used 

intermittently by birds for resting and limited ingestion of water, plant materials, and/or 

macroinvertebrates. Top level consumers in aquatic systems, such as waterfowl, can 

accumulate selenium concentrations leading to low reproduction, embryonic deformities, 

and increased mortality (Ohlendorf et al. 1988). Previous testing on well 2-2 did not 

identify these constituents in the analysis; however, the detection limit for selenium was 

5 μg/L. Therefore, an assessment of selenium in the range of 2-4 μg/L is not possible at 

this time. 

Testing on the 14-35 well (the first test well) included: 

• Dissolved mercury at 0.12 μg/L. The chronic (long term exposure) aquatic 

standard under WDEQ regulations for total mercury is 0.77 μg/L. 

• Dissolved cadmium was not detected. 

• Boron and chromium were not analyzed. 

The low concentrations of tested metals indicate that bioaccumulation potential into 

terrestrial food webs from the permitted reservoir is low. However, without test results 

from the 15-blended well effluent for these additional potential bioaccumulates, the 

potential for these constituents cannot be definitively discounted and it is unknown if the 

potential for selenium to bioaccumulate would exist. 

Raptors 

Raptors exhibit varying tolerances to human-related disturbances (e.g., increased 

presence, noise). Species such as the ferruginous hawk and golden eagle are more 

susceptible to disturbances and may more readily abandon nest sites in the proximity to 

project actions. Ferruginous hawks are particularly sensitive to disturbance during the 

breeding period. An increase in human-related activities (e.g., presence, noise, 

pedestrian, or vehicle traffic) could directly impact nesting raptors if they occur in close 

proximity to the nest site. Loss of eggs or young would be in violation of the Migratory 

Bird Treaty Act, and if the nest were occupied by a golden eagle, potential loss of eggs 

or individual birds in addition to disturbance to adult birds would be in violation of the 

Bald and Golden Eagle Protection Act. 

Figure 4-2 depicts the known raptor nest sites with the applicable buffer areas applied. In 

accordance with the BLM’s permitting stipulations outlined in the existing Great Divide 

RMP (BLM 1988) and expanded in APC’s committed protection measures in 

Section 2.1.8, raptor nests are protected during the breeding season to minimize the 

potential for nest abandonment or loss of eggs or young. Therefore, project construction 

would be restricted within 1 mile of a ferruginous hawk or golden eagle nest and 0.75 

mile for other raptor species between February 1 and July 31 to protect breeding raptors 

and their nests. If a nest exists, it represents a “nesting opportunity” for raptors and 

thus, all nests would receive this protection (except for “historic” nests, e.g., nests that 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

have been destroyed). As stated in Section 2.1.8, an exception to these seasonal 

restrictions would be approved only after a thorough, site-specific analysis by the BLM or 

designated representative concluded that a negative impact would not occur. 

Table 4-2 summarizes known raptor nest sites located with these established buffer 

areas, based on previously documented nest sites for the project area. Four golden 

eagle nest sites occur immediately adjacent to the proposed CBNG interconnect pipeline 

corridor and electric distribution line ROW; three of these four nests are likely alternate 

nest sites for the same breeding pair, given the proximity of the nests to each other (see 

Figure 4-2). A fifth golden eagle nest also was previously recorded immediately 

adjacent to the existing access road in Section 12, which would parallel the proposed 

water pipeline to the existing water reservoir. Three red-tailed hawk nests occur 

immediately adjacent to the proposed interconnect pipeline ROW (one of these also 

parallels a portion of the power line ROW). Three prairie falcon eyries are located 

adjacent to the proposed pipeline and power line ROWs; again, these nest sites are 

likely alternate sites for the same breeding pair given their locations. One northern 

harrier nest occurs adjacent to the pipeline and power line ROWs (see Figure 4-2). One 

ferruginous hawk nest has been documented within 1 mile of the proposed drilling area 

and 16 nests occur within 1 mile of the proposed gas and power line corridors, which is 

discussed further for special status species in Section 4.10.2.2. 

Therefore, based on the implementation of these BLM policies and the supporting 

committed measure in Section 2.1.8, no impacts to nesting raptors from short-term 

project construction of the Pilot Project would be anticipated. Long-term effects would 

include habitat loss and fragmentation, small changes in prey species distribution and 

abundance, and changes in vegetation composition from the operation of the specific 

project components. 

This EA analysis also examined the potential for avian electrocution risk for birds that 

may perch on the proposed 34.5-kilovolt (kv) electric distribution line associated with the 

proposed Pilot Project. Advanced planning of overhead power line design and 

construction can greatly reduce the potential for avian electrocution risks during line 

operation. As stated in Section 2.1.8, APC has committed to design, construct, and 

operate the electric distribution line in accordance with the standard raptor protection 

measures outlined in the Avian Power Line Interaction Committee’s (APLIC’s) 

Suggested Practices for Avian Protection of Power Lines: The State of the Art in 2006 

(APLIC 2006). This line design and planning also would require coordinating with the 

operating utility, Pacific Power. Although larger birds (e.g., raptors) are generally of 

primary concern for electrocution hazards, applying the line design specifications 

outlined in APLIC (2006) would aid in protecting birds of all sizes (including smaller birds 

perched on distribution equipment poles). This measure is particularly important given 

the number of raptor nests recorded for the project area (see Figure 3-9), including a 

number of golden eagle, ferruginous hawk, red-tailed hawk, and prairie falcon nests that 

occur in close proximity to the electric distribution line. (Even smaller raptors, such as 

falcons, can be at risk of electrocution on electric equipment structures.) No increased 

avian collision risk was identified for this line, given its location primarily along the 

existing road ROW and the fact it does not cross the Medicine Bow River. 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Table 4-2 Known Raptor Nests Located within Applicable Buffer Areas 

Species 

Construction Buffer 

(1 mile) 

(FEHA and GOEA)1 

Construction Buffer 

(0.75 mile) 

(Other Raptors) 

Operational Buffer 

(1,200 feet) 2 

(FEHA) 

Operatio

(825 

(GOEA and 

Drilling Area (Section 2) and Facility Area (Section 35) Golden eagle 4 Ferruginous hawk 1 0 Red-tailed hawk 1 Great horned owl 2 Northern harrier 1 Gas Pipeline and Power Line ROWs Golden eagle 9 Ferruginous hawk 1 0 Red-tailed hawk 2 Northern harrier 1 Prairie falcon 4 Power Line ROW Only (No Overlap with Gas Pipeline Corridor) Golden Eagle 2 Ferruginous hawk 1 0 Red-tailed hawk 1 Prairie falcon 2 Gas Pipeline ROW Only (No Overlap with Power Line Corridor) Golden Eagle 16 Ferruginous hawk 14 0 Red-tailed hawk 6 Swainson’s hawk 2 Prairie falcon 2 American kestrel 1 1FEHA = Ferruginous Hawk; GOEA = Golden Eagle 2Nest sites coincide and overlap with those reported within the 1-mile construction buffer for ferruginous hawks. 3Nest sites coincide and overlap with those reported within the 1-mile construction buffer for golden eagles and 0.75-mil

other raptor species. 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Other Birds, Mammals, Amphibians, and Reptiles 

Habitat changes and increased human presence described for the Proposed Action would likely 

increase habitat fragmentation effects and displacement for other, more sensitive animals, such 

as the bobcat, mountain lion, and some species of songbirds. However, other species would 

more readily adapt to these types of incremental effects, particularly for a project at this scale. 

Changes to the relative prey density and distribution (i.e., prey base of rodents and other smallor medium-sized mammals) would be expected to be low from implementation of the Proposed 

Action. Potential disturbance from increased noise levels would be more prevalent for terrestrial 

animals, such as songbirds that typically rely more on auditory cues, particularly during 

breeding. Effects to reptiles would be potential loss of individuals in the immediate project area 

and construction zones, especially those species that burrow. 

As discussed for waterfowl and other water birds, the potential for direct impacts to vegetated 

wetlands or other riparian vegetation used by riparian obligate songbirds, amphibians, or other 

water-dependent species would be low, based on the limited amount of these habitats in the 

proposed project area and APC’s committed measures to avoid disturbance to wetlands and 

open water features, where practicable (e.g., spanning vegetated wetlands along the power line 

corridor). As stated in Section 2.1.8, if reserve pit water quality is determined to be potentially 

detrimental to wildlife (e.g., oil deposition), applicable protection measures would be applied to 

protect wildlife species. As previously noted, even with the best available protection measures, 

not all wildlife can be excluded from reserve pits. Consequently, some impacts to wildlife may 

occur through their inadvertent access to pits during project operation. Finally, the potential 

exposure of animals to surface water in the existing reservoir would be the same as discussed 

for waterfowl. It is assumed water quality would meet or exceed state and federal water quality 

regulations, meeting the limits and monitoring requirements set by WDEQ for end-of-pipe. The 

potential for bioaccumulation of constituents of concern in the reservoir area would be small. 

Although, the low concentrations of tested metals indicate that bioaccumulation potential into 

terrestrial food webs from the permitted reservoir is low, without test results from the 15-blended 

well effluent for these additional potential bioaccumulates, the potential for these constituents 

cannot be definitively discounted and it is unknown if the potential for selenium to bioaccumulate 

would exist. 

4.8.2 No Action Alternative 

Under the No Action Alternative, no habitat loss or fragmentation from project construction 

activities would occur beyond those already existing within the immediate project area. The loss 

of habitat value and function in pronghorn crucial winter range would not occur, and an increase 

in big game species’ displacement would not occur. The ranges’ habitat values and associated 

carrying capacities would remain at current levels. No increase in available surface water for 

area wildlife species would occur from groundwater pumping and discharge. Soil salinity also 

would remain at current conditions. 

4.8.3 Mitigation 

No additional mitigation measures have been developed for terrestrial wildlife resources. 

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4.9 AQUATIC RESOURCES 

4.9.1 Proposed Action 

Under the Proposed Action, produced water would be held in the currently empty constructed 

impoundment (i.e., existing reservoir) located in Section 13. Section 4.5.1 presents further 

details on the anticipated volume, water quality, and management of potential future water 

discharges. 

Long-term presence of water in the permitted reservoir would result in the creation of an aquatic 

habitat where none currently exists. The biota present in this impoundment would be limited to 

species adapted to the conditions and able to colonize this upland location distant from other 

bodies of water. Biota may include opportunistic insect species and other invertebrates via egg 

deposition or from birds. Additionally, a population of algae and zooplankton may establish 

within the reservoir, via wind dispersion of propagules or by birds. Because the aquatic biota by 

definition would be adapted to future aquatic conditions, no impacts to aquatic life that may 

become established would be expected. The temporary reserve pits and the lined 

impoundments also may experience similar colonization by adapted species. 

4.9.2 No Action Alternative 

Under this alternative no discharges of produced water would occur. The reservoir 

impoundment would remain dry. 

4.9.3 Mitigation 

No additional mitigation measures have been developed for aquatic resources. 

4.10 SPECIAL STATUS SPECIES 

Federal agencies, in consultation with the USFWS, are required to ensure that any action they 

authorize, fund, or carry out is not likely to jeopardize the continued existence of a federally 

listed species or species proposed for federal listing. The BLM, as the federal lead agency, is 

currently coordinating with the USFWS in accordance with the section 7 process of the 

Endangered Species Act (ESA) to analyze the effects of the Proposed Action on federally listed 

species (i.e., the Ute ladies’-tresses orchid, Colorado butterfly plant, desert yellowhead, blowout 

(Hayden’s) penstemon, bald eagle, and black-footed ferret). A separate Biological Assessment 

(BA) is being prepared for the USFWS’ review. Additionally, BLM Manual 6840 establishes 

Special Status Species’ policy for plant and animal species and the habitats on which they 

depend. The BLM in Wyoming also has developed a list of BLM sensitive species to focus 

species management efforts towards maintaining habitats under a multiple-use mandate. This 

policy refers not only to species protected under the ESA, but also to those designated by the 

State Director as “Sensitive.” The goals of this sensitive species policy are to: 1) maintain 

vulnerable species and habitat components in functional BLM ecosystems; 2) ensure sensitive 

species are considered in land management decisions; 3) prevent a need for species listing 

under the ESA, and 4) prioritize needed conservation work with an emphasis on habitats. 

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4.10.1 Plants 

4.10.1.1 Proposed Action 

Of the 13 threatened, endangered, or sensitive species and Wyoming species of concern 

considered in this EA, three plant species are considered as potentially occurring within the 

boundaries of the project area. Surveys for persistent sepal yellowcress, a BLM sensitive plant 

species, were conducted in areas of potential habitat in 2004 and none was found. Therefore 

no impacts to this species would be anticipated. Marginal habitat for the Colorado butterfly plant 

is limited to the Mixed Grass-like/Grass Community in Hanna Draw. Marginal habitat for the Ute 

ladies’-tresses orchid also occurs in association with this community in Hanna Draw. No 

impacts to these species would be anticipated along this drainage. 

4.10.1.2 No Action Alternative 

The project area would continue in its present state, subject to the vagaries of climatic 

influences and continued land use activities. It is assumed that the existing grazing, recreation, 

and open space land uses would continue in essentially their present form and intensity 

impacting the vegetation communities onsite in a manner consistent with historic land uses. 

4.10.1.3 Mitigation 

No additional mitigation measures have been developed for special status plant species. 

4.10.2 Animals 

The following impact analyses focus on the special status terrestrial wildlife species that may 

occur in or near the proposed Pilot Project. As summarized in Table 3-9 in Section 3.10.2, the 

BLM identified 21 special status animal species for the Pilot Project, including 2 federally listed 

and 19 BLM sensitive species. 

4.10.2.1 Surface Water Analysis 

The following water analysis for special status wildlife species has been developed specifically 

for three species associated with open water, riparian habitats, and wet meadows and that have 

a moderate probability of occurring in the project area, including the bald eagle, long-billed 

curlew, and white-faced ibis. The effects to surface water would indirectly apply to species such 

as the peregrine falcon and northern goshawk, based on these species’ preferred prey base 

(i.e., birds) and foraging habitat, which includes riparian habitats. 

Potential impacts from potential water quantity and water quality changes were examined from 

project construction and operation. Anticipated impacts from project construction would be 

short-term. Avoidance of vegetated wetlands and open water features along the ROWs would 

not be possible where such features are crossed perpendicularly. The acreage of such features 

that could be impacted is estimated to total less than 10 acres (see Section 4.7.1). No impacts 

to water quality from project construction would be anticipated, based on the construction 

practices and protection measures outlined in APC’s MSUP (see Appendix A). 

Impacts to sensitive birds or mammals that may be attracted to the temporary reserve pits could 

occur, but would be limited to the extent possible. Applicable protection measures would be 

4-32 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
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implemented, such as modified fencing design, temporary covers, or other means acceptable to 

BLM, if warranted. 

Potential impacts to animals from exposure to surface water in the proposed water 

impoundments or the existing reservoir located in Section 13 would be low. APC must adhere 

to state and federal water quality regulations, meeting the limits and monitoring requirements 

set by the WDEQ for end-of-pipe water quality for off-channel impoundments. The possibility of 

bioaccumulation of constituents of concern for terrestrial wildlife species would be low. 

However, as discussed in Section 4.8.1, without test results from the 15-blended well effluent for 

potential bioaccumulates, the possibility for these constituents cannot be definitively discounted 

and it is unknown if the potential for selenium to bioaccumulate would exist. Increased soil 

salinity from continual water evaporation in the reservoir area would likely occur; however, 

elevated soil or water salinity levels would not impact mammal species that may use this 

resource. 

Impacts to aquatic life and other beneficial uses of surface waters would not be anticipated, as 

long as permit requirements are met (see Section 4.10.3). Therefore, these same assumptions 

have been incorporated into the following terrestrial special status species’ assessments. 

4.10.2.2 Species Analyses 

Five special status raptor species were examined for the proposed Pilot Project, including the 

bald eagle, American peregrine falcon, ferruginous hawk, northern goshawk, and burrowing owl. 

Of these five species, the ferruginous hawk and burrowing owl are documented breeders in the 

project area. As discussed in Section 3.10.2, the other three sensitive raptors may occasionally 

occur in the project vicinity for foraging, particularly along the Medicine Bow River, cliff areas, 

and adjacent uplands. Potential impacts to the breeding ferruginous hawk and burrowing owl 

would be the same as those discussed for general raptor species in Section 4.8.1. As stated, 

ferruginous hawks are particularly sensitive to disturbance during the breeding period. 

Burrowing owls are more tolerant of disturbance, but may be directly lost from surface 

disturbance during project construction, as they nest in underground burrows. 

Figure 4-2 depicts the known raptor nest sites with the applicable buffer areas applied, and 

Table 4-2 summarizes these sites relative to the required buffer zones established by the BLM’s 

permitting stipulations outlined in the existing Great Divide RMP (BLM 1988) and expanded in 

APC’s committed protection measures in Section 2.1.8. During project construction, project 

activities would be restricted within 1 mile of a ferruginous hawk nest between February 1 and 

July 31, applicable to all existing nest sites. During project operation, Controlled Surface Use 

would apply within 1,200 feet of an active ferruginous hawk nest. As shown in Figure 4-2 and 

summarized in Table 4-2, one ferruginous hawk nest has been documented within 1 mile of the 

proposed drilling area and 16 nests occur within 1 mile of the proposed gas and power line 

corridors. Based on the implementation of these required BLM policies, no impacts to nesting 

raptors from short-term project construction of the Pilot Project would be anticipated. Long-term 

effects would include incremental habitat loss and fragmentation, small changes in prey species 

distribution and abundance, and changes in vegetation composition from the operation of the 

specific project components. 

The potential for avian electrocution risk for special status raptors would apply primarily to the 

bald eagle, peregrine falcon, and ferruginous hawk, although goshawks have been shown to 

perch on power poles in more open, less forested habitats. As discussed in Section 4.8.1, APC 

has committed to design, construct, and operate the electric distribution line in accordance with 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-33 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

the standard raptor protection measures outlined in the APLIC’s (2006) guidelines (see Section 

2.1.8). Applying these line design specifications would aid in protecting birds of all sizes 

(including species such as peregrine falcons that may perch on distribution equipment poles, 

such as transformers). Additionally, no increased avian collision risk would apply to this line, 

based on its location and avoidance of the Medicine Bow River corridor. 

No other potential impacts to the bald eagle, American peregrine falcon, or northern goshawk 

would be anticipated from construction or operation of the Proposed Action. No water quality 

exposure or bioaccumulation issues would apply to these three sensitive raptor species. 

In accordance with section 7 of the ESA, a “May Affect, Not Likely to Adversely Affect” impact 

determination has been made for the federally threatened bald eagle, based on this species’ 

sporadic distribution; the lack of known nest sites, communal roosts, or winter concentration 

areas in or near the project area; the requirement for APC to meet WDEQ water quality 

standards and the small size and nature of the proposed Pilot Project. 

Black-footed Ferret. No direct impacts to the federally listed black-footed ferret would currently 

be expected from project implementation. Although, historically, ferrets occurred in and near 

the immediate project area (see Figure 3-11), the USFWS and the WGFD have designated 

affected prairie dog colonies as “block-cleared” for the black-footed ferret. This designation 

does not infer that the area has no value for ferrets, but it indicates the discountability of a wild 

population of black-footed ferrets presently occurring in the project area. This designation does 

not preclude the prairie dog colonies within the project area as potential for future black-footed 

ferret reintroduction. Specifically, the Pilot Project is located within the Shirley Basin-Medicine 

Bow black-footed ferret management area. The possibility exists for future reintroductions 

nearby. Dispersal of ferrets within the boundaries of the management area also is expected to 

occur, although where ferrets will re-colonize is not known. At present, no prairie dog towns of 

sufficient size are present within the Pilot Project area. Prairie dogs are capable of recolonizing 

an area only if suitable habitat remains intact. Ferret recovery depends on future availability of 

suitable sites for reintroduction/dispersal. With the concentration of development within the 

project area, it is unlikely in the future that prairie dog colonies would gain sufficient size to 

support ferret dispersal. To date, no direct impacts to ferrets from the Proposed Action would 

be anticipated; however, the proposed project would preclude ferret reintroduction or dispersal. 

In accordance with section 7 of the ESA, a “No Effect” impact determination has been made for 

the federally endangered black-footed ferret. This determination is based on this species’ 

current distribution; the USFWS’ block clearance in this region; and the low probability that 

ferrets could occur. 

White-tailed Prairie Dog. One of the black-footed ferret’s primary prey species, the 

BLM-sensitive white-tailed prairie dog, occurs throughout the project area (see Figure 3-11). 

Potential impacts to prairie dogs from the construction and development of the 15 new wells, 

minor access roads, electric distribution line, gas transmission line, and associated facilities 

could result in crushing of burrows and direct mortality of individual animals, if present in these 

development areas. However, no prairie dog colonies over approximately 10 burrows (field 

onsite, Rawlins BLM wildlife staff, 2005) would be directly impacted by project construction (see 

Figure 3-11), and overall effects would be expected to be incremental and dispersed for a Pilot 

Project of this size. 

Long-billed Curlew. The long-billed curlew is a large shorebird commonly associated with 

drier, upland habitats and mesic meadows and could occur in and near the project area. 

4-34 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

Potential impacts to this species would directly reflect those discussed for general water bird 

species in Section 4.8.1 and the above surface water analysis in Section 4.10.2.1. Minor 

impacts to birds from the proposed reserve pits would be possible (as previously discussed). 

The bioaccumulation potential for long-billed curlew from using the surface water resources at 

the existing reservoir site in Section 13 would be low, based on water quality analyses 

conducted to date (e.g., wells 14-35 and 2-2). However, without test results from the 

15-blended well effluent for potential bioaccumulates, the possibility for these constituents 

cannot be definitively discounted and it is unknown if the potential for selenium to bioaccumulate 

would exist. An increase in soil salinity from continual water evaporation in the reservoir area 

would likely occur; however, as stated for general water bird species, elevated soil or water 

salinity levels would not be expected to impact bird species that may use this resource. 

White-faced Ibis. Although some breeding habitat may exist along the Medicine Bow River 

corridor and some small wetlands/stock ponds may be used during migration for this water bird 

species, the likelihood of occurrence is low. Potential impacts to white-faced ibis from proposed 

project construction and operation would parallel those issues discussed above for the 

long-billed curlew, albeit a lower level, based on the lower probability of occurrence. 

Passerines. Potential impacts to the five sensitive songbirds identified as potentially occurring 

in the project area (i.e., sage thrasher, Brewer’s sparrow, sage sparrow, Baird’s sparrow, and 

loggerhead shrike) would primarily include incremental habitat loss and fragmentation and 

potential displacement of adult breeding birds, if present. Figure 3-10 depicts documented 

locations for two of these special status songbirds (the Brewer’s sparrow and sage thrasher), 

with a number of Brewer’s sparrow occurrences recorded for the proposed power line ROW. 

Displacement of breeding birds could result from project construction and increased human 

presence in native shrubland steppe habitats. Assuming an incremental reduction in habitat, 

some of these breeding birds could be displaced in the short term (i.e., during construction and 

site reclamation) and in the long term (e.g., until shrubs become re-established). Displacement 

or nest abandonment during the breeding season could result in the loss of productivity for that 

breeding season. Birds are highly mobile and would disperse into surrounding areas, using 

suitable habitats to the extent they are available. The long-term loss/reduced usability of shrub 

habitat would lead to an increase in use by all shrub-dependent passerine species. Potential 

impacts to nesting birds would depend on the nest location relative to the proposed project 

components, the species’ breeding phenology, the duration of the potential impacts, and the 

individual bird’s tolerance of disturbances. Project construction would likely have a moderate to 

high impact on breeding birds, if construction activities were to occur during the breeding 

season. Habitat loss and displacement during project operation would likely be low to 

moderate, given the relative size of the proposed project and the level of drilling development 

proposed for Section 2. 

Mountain Plover. In September 2003, the USFWS determined federal listing of the mountain 

plover as federally threatened was not warranted; however, the species remains a BLM 

sensitive species. Plover nest sites are protected on BLM lands with applied seasonal 

restrictions for surface use and human-related activities from April 10 to July 10. Potentially 

suitable habitat for the mountain plover occurs in and adjacent to the project area. If 

development activities were to occur during the breeding season, increased human presence 

and noise could result in displacing breeding adult plovers (if present) from their respective 

territories resulting in the potential loss of productivity for that season. With the proposed 

density of wells and roads, mountain plovers are not likely to return to utilize the area for nesting 

opportunities during the life of the project and until final reclamation. While mountain plovers do 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-35 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

use disturbed habitats on occasion, the resulting long-term human activity within this disturbed 

area would more than likely preclude nesting activity. 

If project development were to occur within suitable plover habitat during the breeding season, 

the BLM would require specific mountain plover surveys, and if present, applicable restrictions 

would be required near active nest sites. These procedures are outlined in the BLM 

Instructional Memorandum No. WY-2004-035, dated April 16, 2004. Restrictions include 

mountain plover surveys conducted in potentially suitable habitat, if project-related activities 

were to occur between April 10 and July 10. Three surveys (14 days apart) would be required 

prior to the initiation of project actions to minimize impacting breeding or nesting birds. The 

BLM also has developed additional protection measures, in the event a nest site were recorded 

in the vicinity of project activities. 

Greater Sage-grouse. Overall, the potential impacts to the greater sage-grouse from CBNG 

production can include loss of nesting or early brood-rearing habitat; decreased population 

productivity; reduced utilization of suitable habitats from indirect disturbance; loss of winter 

habitat; and displacement of birds into lower quality habitats. Construction of facilities and 

roads creates a long-term loss of greater sage-grouse habitat and increases fragmentation of 

remaining habitat. All of these impacts lead to lower productivity and a possible decline in this 

species’ local populations. In the long-term, recovery of sagebrush to pre-disturbance levels 

would not occur during the life of the project. Therefore, there would be a long-term loss of 

nesting habitat. 

This EA analysis focused on potential disturbance to breeding sage-grouse on or near lek sites, 

nesting hens, and brooding hens and young. Sage-grouse populations statewide appear to be 

in decline. Although there is no documented evidence as to the causes of this decline, wildlife 

specialists from the BLM, USFWS, and WGFD believe that drought conditions of the past 

decade and increased natural resource development activities (e.g., oil and gas exploration and 

development) may be contributing factors. In Wyoming, information suggests that greater 

sage-grouse populations are negatively affected by energy development activities, especially 

those that degrade important sagebrush habitat, even when mitigation measures are 

implemented (Braun 1998; Lyon 2000). Greater sage-grouse populations can repopulate areas 

developed for resource extraction after habitat reclamation for the species (Braun 1987); 

however, there is no evidence that populations attain their previous levels, and reestablishment 

of sage-grouse in a reclaimed area may take 20 to 30 years, or longer (Braun 1998). 

Specific to the proposed Pilot Project and shown in Figure 3-12, no project components would 

directly intersect with a known sage-grouse lek or the 0.25-mile buffer delineating the Controlled 

Surface Use area surrounding the lek site. However, the proposed drilling area in Section 2, the 

CCF in Section 35, portions of the CBNG interconnect pipeline, and portions of the electric 

distribution line would cross the established 2-mile buffers surrounding specific lek sites. The 

BLM has designated this 2-mile buffer primarily to protect nesting hens and minimize noise 

effects to breeding birds occupying lek sites. 

Any loss of an individual nest from project construction would be expected to be only for that 

season, if construction activities were to occur during the breeding season (March 1 to July 15). 

Potential direct noise impacts from project construction to sage-grouse breeding or nesting 

within 2 miles of an active lek would be minimized, based on the BLM’s protection measures 

delineated in the Great Divide RMP (BLM 1988). These measures restrict construction activities 

within the 2-mile-radius buffer zone intersected by the project components from March 1 to 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

July 15. Additionally, human activity (and associated noise) would be restricted within 0.25 mile 

of the lek perimeter between 6 p.m. and 9 a.m. from March 1 to May 20. 

Sagebrush obligate species, such as the greater sage-grouse, depend on habitat features, such 

as shrub structure and patch size. Braun et al. (2002) states that although sage-grouse may 

continue to use areas in and near CBNG development, suitable sagebrush-dominated habitats 

must be available, and birds tend to select the habitats that are not disturbed by or apparent 

from physical structures (e.g., wells, power lines, compressor stations), paved roads, human 

presence, etc. Lyon (2000) reports that sage-grouse appear to shift habitat use when nesting 

near roads to patches of sagebrush with a higher canopy cover and height. A few preliminary 

data also show that sage-grouse tend to select both lek sites and nest sites that are farther 

removed from disturbances, such as active wells, roads, and utility corridors (Braun et al. 2002; 

Lyon 2000; Holloran 2005). Holloran (2005) additionally suggests that natural gas field 

development within 2 to 3 miles of an active greater sage-grouse lek could reduce breeding 

populations, with possible total effects not apparent for 5 to 9 years. Therefore, the incremental 

habitat fragmentation and increased human presence from project operation would likely 

continue to reduce the amount of suitable sage-grouse habitat in the project area. 

Few data exist on noise effects to either species of sage-grouse (i.e., greater or Gunnison). 

Although Holloran’s (2005) study results suggest that increased noise intensity at lek sites 

influence male lek attendance, it is difficult to quantify defensible noise thresholds near lek sites; 

determine adequate distances between these sources and sage-grouse; and compare shortand long-term effects to breeding, nesting, and brooding birds. The Powder River Basin Oil and 

Gas Project EIS and Proposed Plan Amendment (BLM 2003a) references a specific standard 

for compressor noise levels relative to sage-grouse leks, using 49 dBA as the threshold at the 

lek site. Braun et al. (2002) states that sage-grouse numbers on active leks located within 

1 mile of a CBNG compressor station are lower than those leks not in proximity to a compressor 

site. Similar to big game impacts from oil and gas, the WGFD (2004c) outlines impact issues for 

sage-grouse and recommends sources of continuous or frequently intermittent noise should not 

exceed 10 dBA at the perimeter of an active grouse lek between March 1 and May 15, with no 

detectable noise at the lek between 1 hour before and 2 hours after sunrise. The recommended 

noise threshold for “lek habitat” for the federal candidate Gunnison sage-grouse in southwestern 

Colorado and southeastern Utah also is 10 dBA since most grouse vocalizations are less than 

20 dBA, with the recommended noise range for nesting and brooding habitat to be 10 to 49 dBA 

(see Appendix I in Gunnison Sage-grouse Rangewide Steering Committee 2005). 

Section 4.13.1 describes the maximum probable noise level estimates for the various project 

components during both construction and operation. In summary, noise emissions estimates 

are 85 dBA at a distance of 50 feet for construction activities; 86 dBA at 50 feet for drill rigs; 

61 dBA at 50 feet for internal combustion engine driven generators; and 77 dBA at 50 feet for 

large compressors enclosed in buildings. Using 55 dBA as the acceptable target threshold for 

humans, project-related noise during construction would achieve reduction to the standard at 

slightly less than 3,000 feet from the source. During project operation, the combined noise 

emissions would be approximately 80 dBA at 50 feet, and the noise level would drop to the 

55 dBA threshold at approximately 900 feet from the source. 

As shown on Figure 3-12, four sage-grouse leks occur approximately 1 to 2 miles from the 

proposed drilling area and CCF. Given the anticipated noise levels listed above for human 

receptors, it is assumed that project operation, including the proposed compressor station would 

be well below the 55 dBA threshold at lek sites; however, it may not be less than the 10 dBA 

threshold recommended by the WGFD (2004c) for one to four leks located south of the project 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-37 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

area. Since ambient noise levels vary with a number of site factors (such as wind and weather) 

and noise thresholds for greater sage-grouse are not proven, it us unknown whether the 

anticipated noise levels during project operation would impact lek attendance by male or female 

grouse. Until future lek counts are done to determine if the number of strutting males on the four 

leks is impacted over time, the possibility of noise greater than 10 dBA at the lek sites could 

potentially have an impact on breeding sage-grouse. 

For the more uncommon Gunnison sage-grouse, the Gunnison Sage-grouse Rangewide 

Steering Committee (2005) recommended all surface-disturbing activities should be prohibited 

within 0.6 mile of an active lek. As previously stated, the proposed Pilot Project drilling area and 

ancillary facilities are located 1 to 2 miles from the closest sage-grouse lek, which would meet 

this recommended buffer threshold and may minimize impacts to breeding and nesting grouse 

from increase operational noise. 

Other potential impacts to greater sage-grouse, such as habitat changes in mesic meadows 

commonly used for brooding and exposure to reserve pit water would be the same as discussed 

above for special status wildlife species. One unique factor for sage-grouse and water 

resources has been the recent expansion of West Nile Virus into the western U.S. As water 

sources expand and provide additional breeding sites for mosquitoes, the primary disease 

vector for this virus, there is a potential for increased incidences of West Nile Virus in 

sage-grouse. A number of studies have shown sage-grouse to be susceptible to the disease 

and identify potential concerns, including proximity of grouse to CBNG development (Clark et al. 

2006; Naugle et al. 2005; Walker and Naugle 2004). It is feasible the proposed reservoir and 

reserve pits could support mosquitoes capable of transmitting West Nile Virus. 

Finally, the EA analysis examined potential increased predation on grouse in the proximity to 

the proposed electric distribution line and other aboveground structures. There is a current 

theory that predators, such as golden eagles, may use these structures as hunting perches to 

predate on displaying male sage-grouse, nesting hens, and brooding chicks. However, no 

increased predation levels would be expected from the proposed Pilot Project, based on the 

location of aboveground structures greater than 0.5 mile from two lek sites and the 

topographical shielding of the proposed power line poles along the proposed ROW alignment 

(see Figure 3-12). The proposed power line corridor is not within line of sight of the 

sage-grouse leks to the east. 

Swift Fox. Potential impacts to the swift fox from the proposed Pilot Project would be expected 

to be small. As discussed in Section 3.10.2, habitats are potentially suitable for this mammal 

species and documented occurrences have been recorded for the area; however, records are 

rare and incidence would likely be low. Based on the low probability of occurrence, it would be 

a low likelihood that direct mortality could result from equipment crushing and excavation, if fox 

natal dens occurred in proposed construction areas. Overall, impacts from the project would 

primarily encompass incremental habitat fragmentation and reduced habitat values in areas of 

surface disturbance and increased human presence, activities, and noise. 

Pygmy Rabbit. Potential impacts to the pygmy rabbit, if present in the project area, would 

primarily encompass possible crushing of burrows, some direct mortality, and overall habitat 

fragmentation and reduced habitat values. These impacts would parallel those identified for the 

burrowing swift fox, as well. However, the potential presence and distribution of this declining 

rabbit species is presently unknown for the project area; therefore, the anticipated level of 

impacts cannot be defined. Given the small size of the proposed Pilot Project, direct and 

indirect impacts to this species, if present, would be limited in scale. 

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Wyoming Pocket Gopher. Potential impacts to another burrowing mammal would be similar in 

that loss of individuals may occur from project construction. A habitat description taken from the 

Wyoming Natural Diversity Database species assessment states, “The Wyoming pocket gopher 

uses upland drier ridge tops, gravelly loose soils, and greasewood habitats.” Some of this 

potential habitat exists in the project area. Although no surveys have been conducted for this 

species, the likelihood of direct mortality would be small, based on the low likelihood of 

occurrence throughout the project area. Individual pocket gophers could be impacted during 

project construction. 

Townsend’s Big-eared Bat and Spotted Bat. No direct impacts to either the Townsend’s 

big-eared bat or spotted bat would likely occur. No suitable habitat to support communal bat 

roosts (e.g., hibernacula, maternity colonies, or bachelor roosts) for either of these species 

occurs in the project area, and if present, bats would likely occupy individual day roosts only. 

Surface disturbance to potential foraging areas for these bat species would be low. 

4.10.2.3 Mitigation 

No additional mitigation measures have been developed for special status animal species. 

4.10.3 Aquatic Species 

4.10.3.1 Proposed Action 

The BLM sensitive aquatic species identified in Section 3.10.3 were examined for the proposed 

Pilot Project. The boreal toad lacks suitable habitat in the project area; therefore, no impacts to 

this species would be anticipated. Suitable habitat may exist in the project area for the northern 

leopard frog and the Great Basin spadefoot. The northern leopard frog may occur in the 

riparian zone along the Medicine Bow River, although its preferred habitat, backwaters and 

areas with emergent vegetation, are rare along the river. No impacts to the northern leopard 

frog would be anticipated from the Pilot Project, given the avoidance of the Medicine Bow River 

corridor and its associated habitats. The Great Basin spadefoot is primarily a terrestrial species. 

It reproduces in stock ponds, irrigation ditches, and pools. Section 4.6.1 notes that the majority 

of such sites occur along the interconnect pipeline ROW. Since few of these features occur 

along this pipeline corridor and APC has committed to avoid disturbance of water features, 

where practicable (see Section 2.8.1), potential impacts to the Great Basin spadefoot would low 

to none during project construction. 

4.10.3.2 No Action Alternative 

Under the No Action Alternative the current level of area activities would continue and no 

impacts to aquatic resources have been identified. 

4.10.3.3 Mitigation 

No additional mitigation measures have been developed for special status aquatic species. 

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4.11 CULTURAL RESOURCES 

Cultural resources are regarded as significant if they are enrolled in or meet the eligibility criteria 

of the NRHP. NRHP eligibility criteria are enumerated in 36 CFR 60 and are described as 

follows: 

The quality of significance in American history, architecture, archaeology, and culture is 

present in districts, sites, buildings, structures, and objects that possess integrity of 

location, design, setting, materials, workmanship, feeling, and association, and: 

(a) That are associated with events that have made a significant contribution to the 

broad patterns of our history. 

(b) That are associated with the lives of persons significant in our past. 

(c) That embody the distinctive characteristics of a type, period, or method of 

construction, or that represent the work of a master, or that possess high artistic 

values, or that represent a significant and distinguishable entity whose 

components may lack individual distinction. 

(d) That have yielded, or may be likely to yield, information important in prehistory or 

history. 

To qualify for NRHP eligibility, a property must meet two separate types of requirement. It must 

exhibit integrity of location, design, materials, etc. and it must meet one or more of the four 

additional criteria. The National Historic Preservation Act (NHPA) of 1966, as amended, is clear 

that a site need not be of national historic significance to be considered eligible; sites of local, 

state, and regional importance also may be listed, and thus are significant in the legal sense. 

The phrasing of NHPA is critical with respect to actual management of cultural resources. A site 

does not have to be included on the NRHP to receive protection under the law, but must simply 

meet the requirements of eligibility. 

Impacts to cultural resources may be direct or indirect. Direct impacts are those that occur as a 

primary result of project designs and might be associated with actual gas field development 

(e.g., well pad construction activities, equipment staging areas, building of temporary access 

roads) and subsequent gas field maintenance operations. The greatest direct impacts can be 

expected to occur early in the course of any undertaking when surface disturbance takes place. 

Indirect impacts are those that occur as a secondary consequence of a project and are 

generally associated with increased human activity in previously inaccessible areas. Illicit 

surface collection of sites is a common form of indirect impact. Indirect impacts can occur at 

any time during or after construction; however, their effects must be anticipated at the outset. 

4.11.1 Proposed Action 

Class III cultural resource investigations have been conducted for the entire Hanna Draw Pilot 

Project area, resulting in the discovery and documentation of 163 sites (Buenger 2004a, 2004b; 

BLM 2002a; Stainbrook 2004). Of the total, 15 sites are NRHP-eligible and 43 sites remain 

unevaluated. The Proposed Action would directly impact one of the former. Site 48CR135 is a 

large site that includes both prehistoric and historic components. Although the proposed CBNG 

interconnect pipeline would cross some portions of the site, these areas have been tested and 

assessed as non-contributing to the eligible site. Otherwise, APC’s protection measures 

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developed to protect historic and prehistoric cultural resources (see Section 2.1.8) and the 

BLM’s standard policies for cultural resources protection (BLM 1988) are expected to protect 

known and unrecorded cultural sites during proposed project construction and operation of the 

Pilot Project. 

4.11.2 No Action Alternative 

Under the No Action Alternative, no additional impacts to cultural resources would be 

anticipated. 

4.11.3 Mitigation 

No additional mitigation measures have been developed for cultural resources. However, the 

BLM would require an open trench inspection of the CBNG interconnect pipeline, which us the 

only action that would extend beyond the applicant-committed measures delineated in 

Section 2.1.8. 

4.12 RANGE RESOURCES AND OTHER LAND USES 

4.12.1 Proposed Action 

4.12.1.1 Range Resources 

Project development would result in the loss of 399 acres of rangeland. A portion of this loss 

(369 acres) would be relatively short-term since disturbances associated with the utility corridors 

outside of roadways would be reclaimed the first planting season after construction is 

completed. Reclamation of utility corridor disturbances outside of roadways would improve 

forage conditions in these areas once revegetation is complete. A total of 30 acres of rangeland 

disturbance associated with well pads and roads would result in a long-term loss of rangeland 

and reduction in forage availability. Based on an average of 6.25 acres per AUM calculated for 

the Dana Block North Allotment, this would result in a loss of approximately 5 AUMs for the life 

of the project. APC’s commitment to employ Best Management Practices ; spill and fire 

prevention measures; noxious weed control during construction, operation, and reclamation 

activities; vehicle speed limits; and measures to minimize livestock injury in open excavations 

(e.g., pits, trenches) would minimize offsite impacts and maintain rangeland health in adjacent 

undisturbed areas and reclamation sites (see MSUP in Appendix A). 

At the end of the well testing period when closure operations are complete, reclamation would 

focus on establishing mid-successional grass/herbaceous and shrub communities. Reclamation 

goals for disturbed areas would eventually improve overall forage conditions within the Dana 

Block North Allotment and be consistent with BLM Standards for Rangeland Health and 

Guidelines for Grazing Management. 

4.12.1.2 Other Land Uses 

Effects on other land uses from the proposed Pilot Project would be limited to potential conflicts 

with existing uses or inconsistency with adopted plans for the area. As noted in Sections 3.12 

and 3.14, existing uses in the area are limited to grazing, a defunct CBNG exploration project, 

and some amount of dispersed recreation, primarily hunting. Effects on grazing are addressed 

under range resources above in Section 4.12.1.1. There would be no conflict with the defunct 

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CBNG project. Effects on recreation are addressed in greater detail in Section 4.14, but existing 

recreation use is low in the immediate project vicinity; therefore, conflicts would be low, as well. 

Seminoe Reservoir and the existing coal mines are sufficiently distant from the proposed project 

that there would be no conflict with those activities. 

Carbon County’s Land Use Plan (Carbon County 1998) expresses support for sustaining 

agricultural activities over the long term and for development of mineral resources when it can 

coexist with agriculture. The proposed project would be in the county’s RAM zoning district, 

which permits both oil and gas development and commercial agriculture (Carbon County 2004). 

The proposed project would be in compliance with the zoning regulation and, as noted in the 

range resources discussion of this section, would have only small effects on ranching activity. 

Also, the interconnect pipeline parallels existing two-track roads and energy corridors to the 

degree possible to minimize any potential effects from that facility. 

4.12.2 No Action Alternative 

4.12.2.1 Range Resources 

Under the No Action alternative, there would be no change in current range conditions, livestock 

carrying capacity, or rangeland health within the Dana Block North Allotment resulting from the 

proposed activities associated with the Pilot Project. 

4.12.2.2 Other Land Uses 

Under the No Action Alternative, existing land use activities would continue as they have been. 

No effects to land use have been identified. 

4.12.3 Mitigation 

4.12.3.1 Range Resources 

No additional mitigation measures have been developed for range resources. 

4.12.3.2 Other Land Uses 

No additional mitigation measures have been developed for other land uses. 

4.13 NOISE 

4.13.1 Proposed Action 

Development of the proposed Pilot Project would inevitably increase noise in the project area. 

Oil and gas development require extensive use of heavy machinery, which is inherently noisy. 

The significance of that noise, however, depends in the simplest sense on how loud it is, where 

it is, and who (or what) is in a position to hear it. 

The maximum probable development scenario for the Pilot Project would include construction of 

project facilities simultaneously with the operation of two drill rigs and two electric generators. 

Noise emissions estimates for construction activities are 85 dBA at a distance of 50 feet; for drill 

rigs they are 86 dBA at 50 feet; and for internal combustion engine driven generators they are 

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61 dBA at 50 feet (BLM 2003a). Noise levels are measured on a logarithmic scale so the 

emissions numbers can’t simply be added together. The combined noise emission level for two 

drill rigs, two generators and heavy construction activity would be 91 dBA at 50 feet. Using 

55 dBA as the acceptable target threshold, project related noise would achieve reduction to the 

standard at slightly less than 3,000 feet from the source. During quiet times in the vicinity, the 

noise would be audible beyond the 3,000 foot distance, but would not generally be considered 

obtrusive or offensive. 

During the operations phase of the project, the primary noise sources would be natural gas or 

propane-fired compressors, which would be used to raise low pressure gas from the well field to 

between 800 and 1,500 psi for insertion into the pipeline system. Large compressors, enclosed 

in buildings as they would be for the project, generate noise levels estimated at 77 dBA at 

50 feet (BLM 2003a). The Hanna Draw Pilot Project would employ two large compressors, and 

might continue to use the two generators during operations. The combined noise emissions for 

this equipment scenario would be approximately 80 dBA at 50 feet. The noise level would drop 

to the 55 dBA threshold at approximately 900 feet from the source. 

While the distances to comply with the threshold standard may seem large, a key consideration 

is that there are no noise sensitive areas within well over 3,000 feet of the proposed project site. 

Consequently, noise emissions from the proposed project would not be problematic for 

implementation of the Proposed Action. 

4.13.2 No Action Alternative 

The No Action Alternative would not alter the noise environment in the vicinity of the proposed 

project site from the existing conditions discussed in Section 3.13. 

4.13.3 Mitigation 

No additional mitigation measures have been developed for noise. 

4.14 RECREATION 

4.14.1 Proposed Action 

The Proposed Action would have only small effects on recreation. There could be a small 

amount of displacement of hunters, particularly for pronghorn antelope, but hunting activity in 

the immediate project area is believed to be light with areas farther north more popular and 

productive for hunting. Hunters could relocate to other parts of the relatively large hunt units that 

overlap the project site either during the drilling period or longer, depending on their sensitivity 

to the project activities. 

Other recreationists may be displaced by the project, but the disturbance area is a small part of 

a very large scale landscape in the project area. Considering the nature of the existing site and 

the previous disturbance nearby, it is likely that there are very few recreational users of the site 

who would be displaced. Any displacement of recreationists other than hunters that would occur 

would likely continue for the life of the project because of the visual and auditory effect of the 

compressor facilities that would be required to deliver the gas to pipelines. 

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ROS classification of the site would likely change from roaded natural to rural for the life of the 

project. There are ample alternative use areas in close proximity to the proposed project site, 

however, many of which offer more desirable recreation opportunities. 

There would be no effects on Wilderness Study Areas (WSAs). The project also would have no 

measurable effect on recreation activity at Seminoe Reservoir. 

Overall, project effects on recreation resources and activities would be small due to the short 

term nature of drilling and construction activities, relatively small project footprint, and the small 

number of recreationists potentially affected. 

4.14.2 No Action Alternative 

The No Action Alternative would have no effect on existing recreation resources or activities in 

the project vicinity. 

4.14.3 Mitigation 

No additional mitigation measures have been developed for recreation resources. 

4.15 VISUAL RESOURCES 

4.15.1 Proposed Action 

Visual impacts of the Proposed Action are evaluated under the Contrast Rating provisions of the 

BLM’s VRM System (BLM 1986a). The proposed project would introduce structural elements 

into a landscape with only a few small structural features from prior exploration drilling efforts. In 

the short term, one or two drilling rigs would be large, dominant visual features; however, they 

would be present for only approximately 6 to 8 months. After drilling is completed, the remaining 

structures would be smaller and lower to the ground. Longer term structures would include the 

CCF, either electric distribution lines and a relatively small electric substation or a set of 

generators, small wellhead structures, and water pumps. To the degree possible, in compliance 

with safety standards and regulations, structures would be painted with the federal “standard 

environmental color” shale green to blend with the natural color pallet of the area. 

Most of the well field portion of the project site would be screened from CR 291 by terrain 

because the road is in a draw and the site is back to the east on a plateau behind a series of 

small ridges. The electric distribution line, if built, would parallel the road for approximately 

5 miles and would be visible in the foreground from the road. The CCF in Section 35 also would 

be visible from the road at a distance of approximately 0.5 mile. 

Modifications to the existing terrain would be small. Drill pads would be flattened and there 

would likely be some sidehill cuts for the proposed CBNG interconnect pipeline. None of these 

would be visually dominant in the context of the large scale of the existing terrain. 

Vegetation modifications would introduce color contrast and strong linear features, such as the 

interconnect pipeline, that would contrast with the existing landscape that has few linear 

elements. Most of these features would be out of site of most viewers, however, because there 

is little use of back country areas and even the county road is lightly traveled. 

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Considering the relatively small scale of the proposed project, the modest visual changes it 

would introduce, the small number of people who would be in a position to view them, and the 

requirement to use appropriate paint colors on structures to minimize their visual impact, the 

proposed project would readily comply with the standards of the Class IV VRM objective for 

most of the affected area. 

The only project feature that would be in a VRM Class III area would be the southwesterly 

5 miles of the proposed CBNG interconnect pipeline. Portions of the last 2 miles would be 

visible from lightly traveled U.S. 30/287. However, there are three existing pipelines in the 

corridor and none of them is visually dominant at the distance and angle of view from the 

highway. It is anticipated that the proposed interconnect pipeline would, in a similar fashion, not 

be visually dominant once reclamation of the construction disturbance has been successfully 

completed. 

4.15.2 No Action Alternative 

Under the No Action Alternative, the visual landscape as described in Section 3.15 would 

remain unchanged. No visual effects have been identified. 

4.15.3 Mitigation 

No additional mitigation measures have been developed for visual resources beyond the 

standard VRM Class IV stipulation that attempts should be made to minimize visual effects 

“through careful location, minimal disturbance, and repetition of the basic (visual) elements” 

(BLM 1986b). 

4.16 SOCIOECONOMICS 

4.16.1 Proposed Action 

Socioeconomic effects of the proposed Pilot Project would be largely positive. The project would 

provide a small increment of short-term jobs and, if successful, would generate local, state, and 

federal government tax and royalty revenues. The relatively small, short-term drilling and field 

construction workforce would create only an equivalently small increment of demand for 

temporary housing or local government services. The very small operating workforce would 

have essentially no effect on housing or public service needs in Carbon County. 

4.16.2 Population and Demography 

Population effects of the Proposed Action would be small. Most of the skills and services 

required for the project are available in the local and regional labor pool. Although recent 

increases in both conventional and CBNG drilling activity in southwest Wyoming have employed 

much of the available oil and gas service workforce, any shortage of workers would likely result 

in hiring contractors from other areas of Wyoming or from nearby states. Given the short 6- to 

8-month duration of the drilling phase, few, if any, non-local workers would be likely to 

permanently relocate to Carbon County; most would be expected to leave family members at 

home and commute on a weekly basis. Most field development and construction workers would 

likely to be drawn from the local or regional pool of workers and contractors. The relatively 

small workforce and short-term nature of the drilling and field development phase of the 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

proposed project suggests it is likely that area businesses would accommodate the increase in 

economic activity with existing employees. 

Given all of the above considerations, the net effect of the drilling and development phase of the 

Pilot Project on Carbon County population levels would likely be small and temporary. At most 

there would be a small population “bump” from a few non-local contract workers relocating to 

the area for up to 8 months. 

For the operations phase, it is assumed that only a small handful of jobs would be created, most 

of which would be filled from the local labor pool. Consequently, any population change 

associated with the operations phase of the Hanna Draw Pilot Project would be small. 

4.16.3 Economic Conditions 

4.16.3.1 Employment and Income 

The Pilot Project, as described in Chapter 2, proposes drilling up to 15 CBNG wells. It also 

would involve construction of roads, a produced water disposal system, and a pipeline network 

as a gathering system for the gas. It may include construction of an electric distribution line and, 

if production warrants, construction of a CCF and CBNG interconnect pipeline. 

The drilling plan anticipates a crew of 10 to 15 workers per well, in 2 shifts, including a 

supervisor for each shift, an engineer, and a mechanic. It is possible that there would be a 

second drill rig operating with a comparable crew, although it has not yet been determined 

whether this would occur. Each well would take from 7 to 10 days to drill plus 2 to 5 days for 

completion. Fifteen wells at 9 to 15 days each would require from 135 to 225 calendar days to 

complete (half as long if two crews were used throughout). With a crew of 10 to 15, there would 

be between 1,350 and 3,375 worker-days of employment generated by the drilling effort. Based 

on these estimates, and analyses done for gas drilling in southwest Wyoming (BLM 2004d), 

each well would generate the equivalent of approximately one person-year of work, or, stated 

more simply, one direct full-time job for a year. The 15 wells would generate the equivalent of 

15 direct jobs. 

In addition, construction of roads, the electric power line, gas and produced-water gathering 

systems, interconnect pipeline, and other infrastructure would require a number of construction 

workers. These activities would be temporary in nature, involving small crews working in the 

area for a matter of days or weeks. Given the relatively well-developed oil and gas service 

industry in Carbon and surrounding counties, construction crews are likely to be locally based. 

No estimates of actual numbers of workers or jobs have been developed for these jobs. 

It is anticipated that each well would require an investment of approximately $350,000, including 

$30,000 to $45,000 for wages and benefits. The total for 15 wells would be $5.25 million and 

$450,000 to $675,000 for wages and benefits. 

Construction of water and gas gathering systems, the electric distribution line, a substation (or 

generators), and the water transfer system would require materials and labor from a variety of 

local, regional, and possibly national sources, as would the CCF and the interconnect pipeline, if 

sufficient quantities of gas are produced. Expenditures for facilities other than the CCF and 

interconnect pipeline would be approximately $3.35 million; the CCF and pipeline would add 

$6.25 million. The total direct investment required for facilities and drilling for the proposed Pilot 

Project is estimated at nearly $15 million. Based on estimates documented in the Jack Morrow 

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Hills Coordinated Activity Plan (BLM 2004d), the total direct and indirect economic activity 

generated by this level of investment would be approximately $20.4 million. 

Economic impacts from production of CBNG were estimated based on calculations prepared in 

the Jack Morrow Hills Plan. That analysis assumed a wellhead price of $2.81 per thousand 

cubic feet (MCF) and estimated total economic impact of $2,793 per MMCF with .0054 jobs per 

MMCF produced (BLM 2004d). Assuming these impact assumptions are reasonable, the 

estimated second year production of 4,875 MMCF would generate $13.7 million in total 

economic impact and 26.3 direct and indirect jobs annually in the early years. These numbers 

would gradually decline over time as production is estimated to drop to 625 MMCF (12% of the 

second year production) by year 15. It is likely that the actual effects would be larger than those 

estimated in the Jack Morrow Hills Plan because wellhead prices for gas have risen 

substantially since the analysis was conducted in 2002. The average wellhead price for gas was 

$5.49 per MCF in 2004, nearly double the $2.81 price used in the analysis (USEIA 2005). 

Simply scaling the estimated impact up in proportion to the difference in wellhead price would 

increase the total economic impact to $26.8 million. Realistically, the total impact is likely to be 

somewhere between the two figures. 

It should be noted that the Pilot Project is an exploration project and the actual production 

numbers are speculative. If the project meets expectations, the second year production of 

4,875 MMCF would equal approximately 5% of 97,205 MMCF total gas produced in Carbon 

County in 2004. Regardless of whether the production estimates are accurate, the economic 

effects of developing the project would be positive for the county and the state. 

4.16.3.2 Effects on Other Economic Activities in the Vicinity of the Proposed 

Action 

The principal economic activity in the project area vicinity currently is grazing, possibly with a 

small amount of recreational hunting. Implementation of the Proposed Action would result in a 

loss of forage from disturbed areas, both in the short term and, to a lesser extent, for the life of 

the project. These potential losses are discussed in greater detail in Section 4.12. 

As noted in Section 4.14, the few hunters that use the area in the vicinity of the proposed project 

would be displaced for at least the development period and, possibly, up to the life of the 

project. However, the hunt units that include the project area are quite large and the better 

hunting is believed to be farther north in the units. Any displacement that occurs would not be 

expected to measurably lower hunter success rates or satisfaction so the economic effects 

would be small. 

4.16.3.3 Effects on Government Revenues 

The proposed Pilot Project would generate several forms of tax revenues, including local ad 

valorem property taxes on production and facilities; state and local sales and use taxes; federal 

government royalties on production, a portion of which would be returned to state and local 

governments; and state severance taxes. 

Ad valorem and severance taxes and federal mineral royalty estimates are based on the 

$2.81 per MCF gas price forecast developed by the federal Energy Information Administration 

and used in numerous recent BLM documents. As noted above, gas prices are currently notably 

higher than $2.81 per MCF and a higher price is sometimes noted in the text to provide context. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-47 
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Ad Valorem Taxes 

The Proposed Action would generate ad valorem property taxes to Carbon County, the 

Wyoming School Foundation Fund, Carbon County Schools, and various taxing districts within 

the county. Ad valorem taxes would be generated from the fair market value of CBNG produced 

and sold; and from the value of aboveground capital facilities within the well fields. The average 

total mill levy for Carbon County is 63.493 mills. 

Constant Carbon County mill levies were assumed for these estimates. In reality, mill levies are 

set each year by the officials of the taxing jurisdiction based on the assessed valuation of the 

county or district and the revenue needs of the taxing entity, so they may change from year to 

year. Natural gas is assessed based on the previous year’s production; therefore, the revenues 

associated with the assessment would be received the following year. Since it is estimated that 

gas production from the Proposed Action would peak in the second year and then decline over 

the 15-year project life, production-related ad valorem property tax revenues would be highest in 

the third year of production and gradually decline through the end of the project. 

Based on the assumptions described, ad valorem tax revenues from production and facilities 

would total approximately $5.1 million over the 15-year life of the project. Table 4-3 illustrates an 

approximate breakdown of how the total revenues would be distributed. As noted above, if the 

average wellhead price of gas were different from the $2.81 per MCF price used in the analysis, 

tax revenues would differ from these estimates. If the price were to average the $5.49 per MCF 

price seen in 2004, ad valorem revenues could approach $10 million over 15 years. 

Table 4-3 Estimated Total Property Tax Revenues from the Proposed Action 

Jurisdiction Mill Levy Revenue 

Carbon County 12 $1,000,000 

Total Schools 45 $3,750,000 

Special Districts 4.42 $369,000 

Total 61.42 $5,119,000 

Federal Mineral Royalties and Wyoming Severance Taxes 

The federal government collects a 12.5% royalty on the fair market value of gas produced from 

federal leases, less production and transportation costs. Half of mineral royalty revenues are 

returned to the state where the minerals were produced. In Wyoming, a portion of the state’s 

share is distributed to local governments and to the Wyoming School Foundation Fund. Actual 

Mineral Royalty revenues collected would vary based on production levels, gas sales prices, 

and production and transportation costs. Assuming production of approximately 41,000 MMCF 

over the life of the project, at a sales price of $2.81 per MCF, the gross value would be 

approximately $115 million; 12.5% would be approximately $14.4 million. (In actuality, the 

taxable value would be reduced by production and transportation costs. Assuming these costs 

would be approximately 35% of the sale price, the royalty revenue would be closer to $9 million, 

although a higher sale price would increase this value.) Half of the revenue would be returned to 

Wyoming and redistributed to various state and local entities. 

The State of Wyoming collects a 6% severance tax on the fair market value of natural gas 

produced within the state. Federal mineral royalty payments and production and transportation 

costs are exempt from this tax. The state uses revenues from this fund for a variety of purposes, 

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including the General Fund, the Water Development Fund, the Mineral Trust Fund, and the 

Budget Reserve. It also returns a portion to counties and municipalities. Using the same 

assumptions noted above, the 6% tax would yield approximately $3.8 million. Actual severance 

tax revenues would vary based on actual production levels, gas sales prices, and production 

and transportation costs. They may be lower than these estimates if a portion of the gas is used 

for production purposes, or higher if the gas price is higher. 

Sales and Use Tax 

Wyoming levies a 4% sales and use tax on the gross receipts of tangible goods and certain 

services (drilling services are exempted). The state returns 28% of the revenue (less 

administrative costs) to the county and municipalities where the taxes were collected. Carbon 

County also levies a 1% local option sales and use tax, which is distributed to the county and its 

municipalities, and a 1% special purpose tax, for a total of 6% (WDOR 2005). 

During the construction and development phase of the Pilot Project, an estimated $4.3 million 

would be spent for goods and services subject to state and local sales and use taxes. This 

amount would generate about $124,000 for the State of Wyoming and about $134,000 for 

Carbon County and its municipalities. 

4.16.4 Housing 

The relatively small workforce needed for the Proposed Action, the short duration of most of the 

work, and the likelihood that many of the workers would be either local or weekly commuters 

(i.e., not bringing new families into the area) indicates that the project-related demand for 

housing would be small and short-term. Most non-local workers would seek short-term, 

temporary housing such as motel rooms and RV camping sites. The small amount of housing 

needed would be readily accommodated by the large number of motel rooms and camp sites 

available within a reasonable commuting distance of the project site. 

4.16.5 Emergency Services 

The small workforce and population effects of the proposed Pilot Project indicate that existing 

law enforcement, medical, and fire protection service capabilities would be adequate to 

accommodate the project. 

4.16.6 Attitudes and Opinions 

There has been no formal survey of community attitudes since the 1996 survey conducted as 

part of the Carbon County Land Use Plan process. Although the 1996 survey did not 

specifically address CBNG, it has been assumed residents’ attitudes about CBNG development 

would be similar to the attitudes they expressed about traditional natural gas development 

activity (BLM 2001b, 2003b). In general, the residents’ responses indicate they recognized “... a 

need to balance the conservation of natural resources and the economic viability of resourcebased industries in the county” (Carbon County 1998). Residents also expressed some support 

for leasing of more federal lands for oil and gas development. Together, these sentiments have 

been taken to indicate residents, especially those in smaller communities like Hanna and 

Medicine Bow, would likely tend to support CBNG development as long as the development 

wouldn’t damage water resources or wildlife habitat or degrade recreation resources in the 

county. 

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The analyses in this EA conclude that the proposed project would not substantially degrade 

water quality, wildlife habitat, or recreation opportunities. Assuming these conclusions are 

accurate, negative attitudes about the proposed project should be minimized and most residents 

would likely hold positive to neutral attitudes about the project. 

4.16.7 Environmental Justice 

The proposed Pilot Project site is located approximately 50 miles from Rawlins, where the 

nearest identified minority population concentration is located. At this distance, social and 

economic issues would be the only serious concern and, for the proposed project, social and 

economic effects would be positive. There are slightly higher than average concentrations of low 

income families and individuals in the communities closer to the project site. However, no 

residual adverse physical, social, or economic effects from the project have been identified so 

there would be no disproportionate, adverse effects on the low income population to raise 

environmental justice issues. 

4.16.8 No Action Alternative 

The No Action Alternative would result in a continuation of existing social and economic 

conditions and trends in Carbon County and in the vicinity of the Proposed Action. 

4.16.9 Mitigation 

No additional mitigation measures have been developed for social or economic effects, as the 

effects are generally positive or inconsequential, or both. 

4.17 TRANSPORTATION AND ACCESS 

4.17.1 Proposed Action 

The proposed Pilot Project would generate traffic increases primarily during drilling and project 

development with substantially lower volumes during project operation. The highest numbers of 

trips would result from workers commuting to the site on a daily basis, while movement of 

equipment, materials, and supplies would generate smaller numbers but substantially heavier 

loads. Table 2-2 illustrates an estimate of the number of trips that would be generated by well 

field development activities. 

It is assumed that drill rigs, dozers for pad construction, water trucks, and other heavy 

equipment would be transported to the site at the beginning of the project and would remain 

there until the construction/development phase of the project was completed. Materials and 

supplies would be delivered on a weekly basis. Drilling and completion crews and other 

personnel would commute to the project area daily, except for drilling engineers who would stay 

at a trailer on the drill site during the workweek. 

Traffic impact analyses are conducted for peak hour traffic. For a proposal like the Pilot Project, 

peak traffic would occur during a drilling shift change when the fresh crews travel into the site 

and the retiring crews depart. Assuming a maximum case with all types of development 

activities occurring at the same time, including two drill rigs operating, completion activities on 

recently drilled wells, and several construction activities in process, it is assumed that the 

project could generate from 45 to 50 vehicle trips in a morning peak hour with approximately 

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75% (38 trips) inbound and the rest outbound. Most of the traffic would be light vehicles (i.e., 

cars and pickup trucks), although there could be a small number of delivery trucks, as well. It is 

expected that virtually all of the traffic would travel between the project site and the Hanna area 

on CR 291. Traffic would disperse south of Hanna via U.S. 30/287, SH 72, and I-80. This level 

of traffic added to existing traffic, as noted in Section 3.17, would be well within the capacities of 

all potentially affected roadways. 

Although project-related traffic would represent substantial percentage increases to existing 

traffic, all affected roadways have significant amounts of unused capacity at the present time. 

No noticeable degradation of traffic flows would occur on area highways. The capacity of a 

gravel road like CR 291 is generally unquantifiable; however, CR 291 is well maintained and 

has a high quality, all weather surface, so up to 50 cars in an hour should flow reasonably well. 

Over the 6- to 8-month duration of the development phase of the proposed project, the 

increased traffic might cause an increase in maintenance required, but it should be within the 

capability of the road in other respects. 

After the proposed project is developed and enters the operations phase, traffic would be much 

lighter, probably less than a half dozen trips in a typical day. The trip generation would be 

slightly higher periodically for maintenance, but would remain well below the levels estimated for 

project development. 

It is unlikely that project-related traffic would measurably increase the risk of traffic accidents in 

the project vicinity considering the relatively small numbers of estimated vehicle trips and the 

short duration of the higher activity phase of the project. 

Roads within the project site would be built and maintained by APC to BLM standards (see 

Figure 2-4 for a typical road profile). Onsite roads would carry relatively little traffic and would 

generally not be used if conditions were too wet to support vehicle weights. 

4.17.2 No Action Alternative 

The No Action Alternative would have no effect on existing traffic and road conditions in the 

project vicinity. 

4.17.3 Mitigation 

No additional mitigation measures have been developed for transportation and access. 

4.18 HEALTH & SAFETY 

Potential health and safety impacts from implementation of the Pilot Project would include a 

relatively low risk to project workers from industrial accidents and a slight increase in risk of 

traffic accidents for the general public during drilling and field development. Highway safety 

impacts are discussed in Section 4.17, Transportation and Access. 

4.18.1 Proposed Action 

Two types of workers, as classified by the U.S. Department of Labor, would be employed during 

implementation of the Pilot Project: oil and gas workers, who had a 2004 annual incident rate of 

2.6 per 100 workers, and special trade contractors, who had a non-fatal incident rate of 6.8 per 

100 workers (U.S. Department of Labor, Bureau of Labor Statistics 2005). These rates 

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compare with an overall private industry average incident rate for all occupations of 4.8 per 

100 workers. 

During the drilling and field development phase of the project, the statistical probability of 

injuries is low. During field operations, the annual statistical probability of injuries is low, given 

the low level of employment. 

The BLM, Occupational Safety and Health Administration (OSHA), U.S. Department of 

Transportation (USDOT), WOGCC, and Wyoming OSHA each regulate certain safety aspects 

of oil and gas development. Adherence to relevant safety regulations on the part of the 

applicant and enforcement by the respective agencies would reduce the probability of accidents, 

accordingly. Additionally, given the remote nature of the project area, and the relatively low use 

of these lands by others (primarily grazing permittees and hunters), occupational hazards 

associated with the Proposed Action would mainly be limited to employees and contractors 

rather than the public at large. 

The Pilot Project would include the construction of a CBNG interconnect pipeline from the 

drilling area to the southwest. This relatively small amount of new pipeline, as compared to a 

total of over 300,000 miles of gas transmission pipelines in the U.S., coupled with the low 

probability of failure and the remoteness of the project area would result in low risk to public 

health and safety. Nationwide, injuries associated with gas transmission pipelines averaged 

8 per year from 1996 through 2005, fatalities averaged 3 per year, and incidents such as 

ruptures averaged 93 per year (USDOT 2005). Signing of pipeline ROWs could reduce the 

likelihood of pipeline ruptures caused by excavation equipment-particularly in the vicinity of road 

crossings or areas likely to be disturbed by road maintenance activities. 

In summary, the increase in risk to public health and safety as a result of the Pilot Project is 

expected to be small. 

4.18.2 No Action Alternative 

Under the No Action Alternative there would be no development activity within the project area, 

and therefore, no impact to public health and safety from this alternative. 

4.18.3 Mitigation 

No additional mitigation measures have been developed for health and safety. 

4.19 CUMULATIVE IMPACTS ASSESSMENT 

This section provides a discussion of cumulative impacts for each resource analyzed in 

Sections 4.2 through 4.18. Cumulative impacts are those impacts to the environment resulting 

from the incremental impacts of the Proposed Action when added to past, present, and 

reasonably foreseeable future actions. Cumulative impact assessment areas (CIAAs) or 

cumulative domains vary among resources and are generally based on relevant landscape, 

resource, project, and/or jurisdictional boundaries (Table 4-4). 

Table 4-5 outlines the project (well locations, facilities, proposed access roads, gathering 

pipelines, utility lines, interconnect pipeline, and power line) is located within six Hydrologic Unit 

(HU) 12-level watersheds: 

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Table 4-4 Cumulative Effects Analysis Domains 

Resources CIAA1 Rationale 

Climate and Air Quality Sub-grid, Near-field Far-field analysis will refer to most re

Geology and Geological Hazards Project Area Paleontological Resources Project Area Soils Project Area Water Resources 

Surface Waters Six HUC-12 level watersheds (see text) Groundwater Producing formation + 1 mile from outcrops 

Floodplains Six HUC-12 level watersheds (see text) Vegetation, Wetlands, and Reclamation Six HUC-12 level watersheds (see text) Terrestrial Wildlife Project Area + One-Half Home Range Aquatic Resources Project Area 

Special Status Species 

Raptors Project Area + 1 Mile Nesting raptor protection stipulations 

Sage grouse Project Area + 2 Miles Lek protection stipulations proscribeMountain plover Project Area + 1 Mile Available and contiguous habitat 

Big game/CWR CWR 61,593 Acres Management unit of DGF 

Other migratory birds Project Area + 1 Mile Available and contiguous habitat 

Small mammals Project Area + One-Half Mile Available and contiguous habitat Aquatic species Medicine Bow River + Seminoe Reservoir Available and contiguous habitat Sensitive plants Project Area + One-Half Mile Available and contiguous habitat 

Cultural Resources Project Area No trails/viewshed issues with this p

Range Resources and Other Land Uses Allotment(s) Management unit of BLM Noise Project Area +2000' EPA guidelines=55dBA (drilling/consRecreation Project Area + 1 mile buffer Checkerboard ownership: N/A Visual Resources Area visible from County Road 291 Checkerboard ownership: N/A, VRM Socioeconomics Carbon County Ad Valorum 

Transportation and Access 

County Road 291 from its intersection with County Road 

270 to Hanna and Highway 72 from Hanna to the I-80 

interchange, including the Highway 30/287 intersection 

Roads used for project 

Health and Safety Project Area Tie in with Transportation & Access 

 "Project Area" = Section 2, Section 35, and 100-foot buffer of linear features. 

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Table 4-5 Hydrologic Units Associated with Pilot Project Area 

HUC-12 Name Area HUC-12 ID # 

Medicine Bow River- Hanna Draw 26,347 acres 101800040501 

Lower Big Ditch 24,752 acres 101800030202 

Middle Ditch 15,201 acres 101800030203 

Upper Big Ditch 34,924 acres 101800030201 

Middle Saint Mary’s Creek 30,509 acres 101800021202 

Lower Saint Mary’s Creek 23,334 acres 101800021203 

These watersheds (Figure 4-3) are located within the North Platte hydrologic basin, with 

eventual tributary contribution to the Gulf of Mexico. Both portions of Saint Mary’s Creek drain 

to the southern arm of Seminoe Reservoir. The other four watersheds drain to the Medicine 

Bow River. The six HUC 12-level watersheds comprise a total of 155,067 acres. These 

watersheds serve as discrete planning units of a manageable scale for the assessment of 

cumulative impacts associated with surface water, floodplains, and vegetation resources. Thus, 

this 155,067-acre area is considered the CIAA for these resources. 

In total, the Pilot Project would add approximately 399 acres of surface disturbance to the CIAA. 

There are 11 wells that are either producing, shut-in, or in the process of being drilled within the 

CIAA (Figure 4-3) as of February 2006. There are no additional proposed APDs on file at the 

WOGCC. The Proposed Action includes the drilling of 15 additional CBNG wells, resulting in a 

total of 26 existing and reasonably foreseeable APDs in the watershed. 

In development of the Desolation Flats EIS, a natural gas project within south-central Wyoming, 

an analysis of the expected short-term disturbance area for typical oil and gas wells within the 

exploratory development area provided an estimate of 12 acres per well (including well pad, 

access road, and pipeline for most wells). It should be noted that the short-term disturbance 

figure represents the disturbance associated with a typical well prior to any reclamation 

activities. Many of the producing wells have been reclaimed to their production facilities. 

Using an assumption of 12 acres of disturbance per well, the proposed action (399 acres), in 

combination with the 11 existing and reasonably foreseeable (non-project) wells (132 acres), 

would result in a total cumulative oil and gas development disturbance (short-term) of 531 acres 

within the watersheds. This equals approximately 0.3% of the CIAA. 

4.19.1 Past, Present, and Reasonably Foreseeable Future Actions 

Past, present, and reasonably foreseeable future actions applicable to the proposed Pilot 

Project would include a number of activities associated with past and present mineral 

exploration and development in the region in addition to historic land uses, such as livestock 

grazing. Specifically, past oil and gas exploration and development by Williams Production 

Company (formerly Barrett Resources Corporation), coal mining and associated reclamation, 

livestock grazing, road development, utility corridor placement, and a small degree of increased 

recreational access and use (e.g., hunting). 

There are no known, unreclaimed disturbances associated with the coal mining activities, and 

none reasonably foreseeable. Several railroad lines and various roadways also are present 

within the area. The Town of Hanna is located in the center of the CIAA, and includes housing4-54 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
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and municipality-related surface disturbance. The impacts contributed from the Town of Hanna 

are unknown. 

Past actions on or in the vicinity of the Pilot Project include the previous CBNG well exploration 

and development by Williams, the existing water containment reservoir, Hanna Draw Road and 

other ancillary access roads, six coal mines, livestock grazing, and more recent development of 

Well 2-2 by APC. 

The one reasonably foreseeable future action identified for the Hanna Draw cumulative 

assessment is Dudley and Associates proposed CBNG development and operation, Seminoe 

Road Gas Development (Seminoe Road) Project (BLM 2005b). The Seminoe Road Project is 

located approximately 20 miles northeast of Rawlins, in Carbon County, approximately 20 miles 

west of the Hanna Draw Pilot Project area. The Seminoe Road Project proposed to drill and 

develop up to 1,240 wells, on up to 785 well pad sites, spaced at one well pad site per 

160 acres. Associated facilities would include roads, gas and water collection pipelines, 

compressor stations, water disposal systems, and an electric power supply system. This 

project’s analysis area encompassed a 137,000-acre area, which includes a checkerboard 

pattern of mostly federal (greater than 49%) and private (greater than 49%) surface, with some 

state lands (less than 1%). 

Total disturbance for drill pads, access roads, and ancillary facilities would be approximately 

6,174 acres (4.5% of the overall project area). Construction and drilling activities are proposed 

for a 10-year period from the start of the project. Approximately 60% of the initial site 

disturbance would be reclaimed after construction; therefore, an estimated 2,349 acres (1.7% of 

the project area) would remain disturbed in the long-term. This area would be reclaimed at the 

conclusion of the estimated 30-year project life. 

Each project phase of the proposed Seminoe Road Project would involve the drilling of an 

average of 124 CBNG wells, with associated road construction and installation (burial) of water, 

gas and electrical distribution lines. Each project phase would be examined under the 

applicable NEPA analysis before BLM would issue a final decision. 

4.19.2 Air Quality 

The cumulative impact analysis for air quality considered the incremental impacts of the Pilot 

Project when added to the potential impacts predicted for the nearby Seminoe Road Project 

(BLM 2005b). The anticipated emissions level from the Pilot Project would be incremental and 

considerably less than those identified for the Seminoe Road Project. The Seminoe Road 

Project cumulative impact analysis for air quality suggests that air impacts from the Pilot Project 

would be below applicable federal and state standards. Specifically, the Pilot Project would 

represent a very small fraction of emissions resulting from increased oil and gas development 

within south-central Wyoming. 

The Seminoe Road Project’s cumulative impact analysis for air quality predicted an increase of 

340.2 tpy of NOx emissions over the background emissions. The cumulative impact analysis 

predicted that the maximum criteria pollutant concentrations would not exceed federal or state 

ambient air quality standards. Cumulative impacts also were predicted to be less than the PSD 

Class I increments. Impacts to sensitive lake acid neutralizing capacity (ANC) were less than 

the applicable limits of acceptable change. The cumulative visibility analysis for all regional 

sources (including the Seminoe Road Project) revealed that there could be 4 days per year 

(IMPROVE) and 1 day per year (FLAG) when visibility impacts were greater than the 1.0-dv 

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threshold for the Bridger and Popo Agie Wilderness Areas in western Wyoming. However, it 

was determined that the Seminoe Road Project would not be a major contributor to these few 

visibility exceedances. Impacts from the Seminoe Road Project were predicted to be below the 

0.04-dv visibility significance threshold for all days where the cumulative visibility impacts were 

estimated to be 1.0 dv or greater (BLM 2005b). With development of the Pilot Project, NOx 

emissions in the cumulative study area would increase by 33 tpy, a 9.7% increase in emissions 

over those analyzed in the air quality study. Therefore, the Pilot Project would not alter the 

overall assessment of cumulative impacts in the region. 

4.19.3 Geology and Geological Hazards 

Surface and subsurface mining activities along with oil and gas exploration have occurred 

across the Pilot Project area over the past century. Currently, coal mines in or adjacent to the 

Pilot Project area are undergoing reclamation or have been reclaimed. Only CBNG exploration 

was previously conducted by Williams (Barrett) within the Pilot Area. Other proposed CBNG 

activities, such as the Seminoe Road Project are located outside of the geological CIAA. 

Overall, cumulative impacts in the Pilot Project area to geologic resources would be considered 

to be small. 

4.19.4 Paleontological Resources 

The cumulative impact domain for paleontological resources is the immediate project area. 

Previous CBNG exploration and associated infrastructure combined with the proposed Pilot 

Project would be the only cumulative activities that could potentially result in cumulative effects 

to paleontological resources. No other reasonably foreseeable future projects are planned 

within this domain. Implementation of the resource protection measures required in the BLM’s 

Great Divide Resource Management Plan (BLM 1987) would reduce the potential for impacts to 

paleontological resources. 

4.19.5 Soils 

Given that the CIAA for soils is the project area, the 399 acres of soils proposed to be impacted 

as a result of this project constitute the impact to this resource in the analysis area. Past CBNG 

exploration and associated access road construction, in addition to the construction of County 

Road 291, have removed soils from production as has the construction of a few small stock 

ponds and a variety of two-track roads serving local grazing operations. Approximately 4 acres 

of soils have been previously disturbed by coal mining activities along the proposed ROW and 

are in the process of being reclaimed. This acreage would be re-disturbed under the Pilot 

Project and reclaimed following ROW construction. 

4.19.6 Water Resources 

4.19.6.1 Surface Water 

The CIAA for surface water resources are the six HUC-12 watersheds shown on Figure 4-3. 

The Pilot Project, along with other reasonably foreseeable activities in the watersheds, would 

contribute to surface water degradation through increased erosion and sedimentation. 

However, given the small number of wells proposed for the Pilot Project and subsequent 

reclamation of portions of the disturbance areas, the impacts are anticipated to be small. As 

discussed in the introductory section, total cumulative oil and gas development disturbance is 

4-56 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

estimated to equal approximately 0.4% of the CIAA. Therefore, the proposed project, in 

combination with other reasonably foreseeable activities and actions within the CIAA, is not 

expected to cumulatively affect surface water resources if the mitigations provided in the APD 

and Conditions of Approval are implemented. 

4.19.6.2 Groundwater 

The groundwater CIAA for the Pilot Project is defined as an area that extends 1 mile beyond 

outcrops of the producing formation, or the Hanna Formation. This cumulative impact domain 

essentially occupies the central portion of the Hanna Basin. Activities that could potentially 

affect hydrologic conditions within and adjacent to the Pilot Project groundwater domain include 

withdrawal of groundwater for livestock and domestic use and other CBNG exploration 

activities. Domestic and livestock groundwater use in the Pilot Project and adjacent areas are 

considered relatively small compared to CBNG dewatering. The only reasonable foreseeable 

future action is the proposed Seminoe Road Project, another CBNG project located within the 

Hanna Basin. 

Proposed groundwater pumping from the Seminoe Road Project could have additive drawdown 

effects to the Pilot Project area where cones of groundwater depression may overlap. Under 

the Seminoe Road Project, dewatering of coals in the Mesa Verde and Medicine Bow 

formations is proposed. The Mesa Verde coals are hydraulically isolated from the Medicine 

Bow and Hanna Formations by the low permeability of the 2,800-foot-thick Lewis Shale. The 

overlying Medicine Bow coals are isolated from the Hanna Formation, as they are interbedded 

between shales and are separated from the Hanna Formation by the fine-grained rocks of the 

6,000-to 11,000-foot-thick Ferris Formation. Given that the Seminoe Road Project CBNG 

targets are stratigraphically deeper and isolated hydraulically by low-permeability strata, the 

potential for cumulative groundwater impacts is small. 

4.19.7 Floodplains 

Known impacts within the floodplains CIAA consist primarily of historic road, railroad and 

haul/road crossings, as well as domestic developments associated with the Town of Hanna. The 

acreages resulting from implementation of this proposed project would be small, given the 

limited acreage of floodplains affected and short-term construction period along the CBNG 

interconnect pipeline. Additionally, the total cumulative oil and gas development disturbance 

would be approximately 0.4% of the CIAA. Therefore, the Pilot Porject is not expected to 

cumulatively impact floodplain resources. 

4.19.8 Vegetation, Wetlands, and Reclamation 

Approximately 399 acres of vegetation of all community types would be impacted within this 

proposed project area. Other activities that have occurred within the CIAA include road and 

haul road construction, railroad construction, Town of Hanna residential and commercial 

developments, reclaimed coal mine disturbances, and limited oil and gas development 

(132 acres). As stated for floodplains, the total cumulative oil and gas development disturbance 

would be approximately 0.3% of the CIAA; therefore, the BLM does not anticipate cumulative 

impacts to vegetation and wetlands resources. 

With respect to state-list and county-list noxious weed species, no increase in such species 

would be anticipated across the CIAA as a result of the implementation of this project given 

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APC’s commitment to a weed control program. Non-noxious invasive species would also be 

controlled, per BLM requirements and stipulations. 

4.19.9 Terrestrial Wildlife 

The CIAA or cumulative domains for terrestrial wildlife vary by wildlife group, based on the 

species’ relative mobility, home ranges, and habitat use. For most species, the CIAA 

encompasses the project area plus half the species’ home ranges. Specific to big game species 

and seasonal ranges, the cumulative areas include portions of the mule deer herd unit for the 

Platte River and Shirley Mountain Herds. The pronghorn CIAA encompasses the contiguous 

crucial winter range within the Medicine Bow Herd unit applicable to the project, which totals an 

estimated 61,568 acres (see Figure 3-4). For most migratory birds, the CIAA includes the 

project area plus a 1-mile buffer, and for smaller, less mobile species (e.g., small mammal 

species), the area extends approximately 0.5 mile beyond the project area boundary. 

Past, present, and reasonably foreseeable future actions applicable to terrestrial wildlife species 

would include a number of activities that have occurred across the landscape within these 

cumulative impact domains. Specifically, past oil and gas exploration and development, coal 

mining and subsequent reclamation, livestock grazing, road development, utility corridor 

placement, and a small degree of increased recreational access and use (e.g., hunting). The 

one future action identified for the cumulative assessment is the Seminoe Road Project, with the 

proposed drilling and development of up to 1,240 wells (160-acre spacing) with approximately 

124 CBNG wells drilled each phase. Associated facilities would include access roads, gas and 

water collection pipelines, compressor stations, water disposal systems, and an electric power 

supply system. 

Cumulative effects to regional terrestrial wildlife species would parallel those issues identified 

and discussed in Section 4.8. The past, present, and future activities combined with the 

proposed Hanna Draw Pilot Project would incrementally contribute to overall habitat loss and 

fragmentation, animal displacement in the short- and long-term, changes in the surface water 

regime, increased vehicle mortalities, increased noise levels and human presence, and 

increased legal or illegal hunting. 

Anticipated cumulative effects to big game species is one of the more important terrestrial 

wildlife resource issues associated with the increased oil and gas development in Wyoming, 

including the cumulative effects issues examined for the Pilot Project. Crucial winter range is 

most important to pronghorn and mule deer during severe storm events, years of high snow 

pack, or during extended and extreme winter conditions. These environmental conditions force 

the pronghorn into the lower elevations that historically contained suitable forage and thermal 

cover necessary to support animals during periods of stress. However, sagebrush communities 

across Wyoming are exhibiting late successional stages of relatively even age classes 

dominated by older plants (>50 years) (WGFD 2004c). Displacement of individual pronghorn 

and mule deer into adjacent areas of winter range that may or may not be characterized by 

plants of reduced vigor, productivity, and nutritional quality may contribute to the decline of 

these populations’ distribution and number. 

Animals may experience severe physiological stress during the winter period, particularly 

gestating does, which require higher levels of energy for survival and successful reproduction. 

Specific to mule deer, Hobbs (1989) determined that human-induced disturbances to mule deer 

(i.e., two disturbances per day, each disturbance causing the animals to move a minimum of 

1,500 feet) during a severe winter period could double doe mortality. Mule deer in South 

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Dakota require an average of 3.5 to 4 pounds of dry-weight forage per 100 pounds of body 

weight during the winter season (Richardson and Petersen 1974). Therefore, disturbances 

during the winter could prevent access to sufficient amounts of forage to sustain individual deer. 

A deer’s ability to survive the winter and a doe’s ability to produce viable offspring ultimately 

depend on the fat reserves, which are continuously used during the winter. Increased stress 

that causes these fat reserves to be used faster reduces survival for deer and reduces the 

interuterine survival of fawns. Therefore, increased human activity or harassment combined 

with a severe winter event could lower deer survival (Richardson 1992; Yarmoloy et al. 1988) 

and lower doe fecundity. These factors would apply to the pronghorn Medicine Bow Herd 

crucial winter range and to a lesser extent the mule deer Shirley Mountain and Platte River 

Herds winter ranges located within the CIAA. 

Available crucial winter range located within the established pronghorn CIAA encompasses an 

estimated 61,593 acres. The proposed Pilot Project could affect approximately 2,747 acres in 

the long term on the edge of this winter range, assuming that well density, human presence, 

and ancillary facilities would likely displace animals outside of this area during the life of the 

project. An estimate of past and present surface disturbances within this same CIAA have not 

been calculated. 

The proposed Seminoe Road Project is the largest activity identified for the big game CIAA. 

This project’s proposed well density is projected to be 4 wells per 1-mile-square section and 

cumulative disturbances of up to 28.6 acres per 1-square-mile (640-acre) section. Assuming full 

field development (1,240 wells on 785 well pad sites) over a 10-year period, the total 

disturbance for drill pads, access roads, and ancillary facilities would be approximately 

6,174 acres (4.5% of the overall project area). Approximately 60% of the initial site disturbance 

would be reclaimed after construction; therefore, an estimated 2,349 acres (1.7% of the project 

area) would remain disturbed in the long-term. This area would be reclaimed at the conclusion 

of the estimated 30-year project life. 

The DEIS (BLM 2005b) states the Seminoe Road Project would “not affect a large amount of 

crucial winter range” for either pronghorn or mule deer. Five wells are proposed to be drilled in 

mule deer crucial winter range in the extreme southeast corner of the EIS analysis area. 

Portions of pronghorn crucial winter/yearlong range would be affected in the west and northwest 

project area, short-term disturbance estimates approaching the 28.6 acres per section and 

long-term (after reclamation) disturbance no more than 20 acres per section. However, no total 

acreage estimates for either of these species’ crucial winter range from this project were 

provided, although the estimate is said to be “low.” 

Existing access roads in the vicinity of the project increasingly fragment native habitats. The 

WGFD’s scoping comments provided June 21, 2004 discuss preliminary results from the 

Southeast Wyoming Cumulative Impacts Analysis. One primary issue identified by the WGFD 

is the existing road network and its cumulative effects on terrestrial wildlife. Access road 

construction and use from the proposed Seminoe Road Project also would contribute to overall 

habitat fragmentation and displacement within the applicable pronghorn and mule deer herd 

units. Although it is not quantified, roads can disrupt large mammal populations, even if they do 

not present a physical barrier (Andrews 1990; Richardson 1992), as typically exhibited in more 

open grassland and scattered shrubland habitats. As an example, roads resulting from energy 

development in the Book Cliffs of Utah were shown to result in a greater impact to mule deer 

than the direct habitat loss (Karpowitz 1984). The cumulative development of regional access 

roads could continue to increase overall habitat fragmentation and animal displacement, both 

from road presence and a change to the vegetation composition in proximity to the road 

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margins, caused by a change in soil temperature, dust accumulation, and moisture content 

(Vaillancourt 1995). Based on applicable resource studies, the plant community composition 

would likely be altered within 165 to 200 feet from the road edge (Gelhard and Belnap 2003; 

Baker and Dillon 2000). 

Combining the degree of specific habitat loss, fragmentation, human activity, and increased 

noise from past, present, and the proposed Seminoe Road Project, the cumulative impacts to 

big game species would reduce the amount and access of crucial winter range available for 

these species. The WGFD (2004c) outlines the impact thresholds relative to oil and gas field 

development. As discussed in this EA, Section 4.8.1 for big game species, the thresholds 

developed by the state wildlife agency are based on two quantitative measures, well density and 

the cumulative acres of disturbance per a 640-acre area, using the density of well pads as a 

general index to well field development and activities. As densities of projects’ wells, roads, 

pipeline and electric ROWs, compressor stations, and other facilities continue to increase and 

expand, habitat is not only lost in these specific areas, but the effectiveness of the adjacent 

habitats (i.e., zone of influence) also may decrease. Displacement of individuals forces animals 

into marginal habitats or they have to compete with animals already occupying the adjacent 

areas. Increased displacement and inter- and intra-species competition ultimately may lower 

survival rates during the winter, reproductive success, population numbers, and the range’s 

carrying capacity to support a certain number of animals. In summary, the proposed Pilot 

Project’s effects would incrementally add to the cumulative effects to big game species in this 

area of south-central Wyoming. The limited amount of crucial winter for both pronghorn and 

mule deer cumulatively affected within the established CIAA would aid in keeping these effects 

more isolated. 

No potential water quality or water quantity effects were identified for terrestrial wildlife species 

for the proposed Seminoe Road Project, specifically the North Platte River located downstream 

of Seminoe Reservoir. Based on the water assessment for the Pilot Project, the potential for 

future water quality and water quantity impacts would parallel the analysis for the proposed 

Hanna Draw Pilot Project. Not all wildlife can be excluded from reserve pits; consequently, 

some cumulative impacts to wildlife may occur through their inadvertent access to pits during 

project operation. Additionally, the bioaccumulation potential to terrestrial wildlife from the 

permitted reservoir is low; however, without test results from the 15-blended well effluent for 

these additional potential bioaccumulates, the potential for these constituents cannot be 

definitively discounted and it is unknown if the potential for selenium to bioaccumulate would 

exist. 

Cumulative issues for other terrestrial wildlife (e.g., waterfowl, water birds, raptors, passerines 

small- and medium-sized mammals, reptiles) would parallel the overall discussion on the 

anticipated habitat loss, fragmentation, some direct mortality (vehicle collisions, burrowing 

animals), and animal displacement in the short and long term. As discussed in Section 4.8, the 

BLM has developed applicable mitigation measures, and the applicants for past, present and 

reasonably foreseeable projects have committed to specific protection measure to minimize 

these effects. 

Residual cumulative effects after these measures are applied would encompass a further 

incremental reduction in the amount of available cover, foraging opportunities, and breeding 

areas for a variety of trophic levels in both the short and long term. Additional development 

could potentially preclude animals from using areas of more intensive human activity. However, 

generally, the severity of the cumulative effects would depend on factors, such as species’ 

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CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

sensitivity, seasonal intensity of use, type and duration of projects activities, and physical 

parameters (e.g., topography, forage, thermal cover, slope, aspect). 

Residual cumulative impacts from habitat loss and fragmentation would be important to certain 

bird species, such as neotropical migrants (e.g., Swainson’s hawk, songbird species) that are 

currently experiencing additional population pressures from external factors outside of the 

project area, unrelated to mineral development. A combination of local, regional, and 

international issues is impacting these overall populations; however, the anticipated cumulative 

effects to these species would once again be considered to be isolated, incremental impacts to 

overall habitat availability. 

In summary, the overall cumulative effects identified within the CIAAs delineated for terrestrial 

wildlife species would continue to contribute incremental direct, indirect, short-term, and 

long-term impacts to both resident and migratory species. Both protection and mitigation 

measures developed for the resource area and cumulative components would aid in minimizing 

impacts. However, residual impacts would remain that encompass overall habitat loss and 

fragmentation, some direct mortality, and some animal displacement, depending on a number of 

factors, including species’ sensitivity, habitat availability, buffering factors, existing prey base, 

and type of project-related activities. 

4.19.10 Aquatic Biology 

Given that no discharge would occur from the existing reservoir to be used for storage of 

produced water and that no impacts to aquatic resources would be expected from the proposed 

project, no cumulative impacts from the Pilot Project would be anticipated. 

4.19.11 Special Status Species 

4.19.11.1 Special Status Plant Species 

No cumulative impacts to threatened, endangered, or sensitive plant species, along with 

Wyoming plant species of concern, are anticipated. Suitable habitat is not present in the project 

area for the majority of the plant species listed as potentially occurring. Where marginally 

suitable habitat does exist for the Ute ladies’-tresses orchid and the Colorado butterfly plant, 

APC has committed to avoiding the vegetation type supporting these plant species, as 

discussed in Section 4.10.1. Limited habitat suitable for supporting persistent sepal yellow 

cress was investigated along the south bank of the Medicine Bow River. This habitat consisted 

of a notably narrow strip of mud bank adjacent to steeply sloping uplands. No individuals of this 

species were found to exist in this area. It is reasonable to assume that this proposed project 

would have no impact on the plant species of concern within the project area or within the CIAA, 

including a buffer zone of 0.5-mile surrounding the project area. 

4.19.11.2 Special Status Animal Species 

The CIAAs used to examine potential effects to special status animal species essentially 

encompassed the project area plus a 1-mile buffer. Exceptions included the greater 

sage-grouse, which used a 2-mile buffer around each lek within the project area; bald eagle, 

whose CIAA extended down the Medicine Bow River to Seminoe Reservoir; black-footed ferret, 

which encompassed the Seminoe Road Project; and small mammal species (e.g., Wyoming 

pocket gopher, spotted bat), where the CIAA extended only 0.5 mile beyond the project 

boundary. Because the long-billed curlew and white-faced ibis are both special status water 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-62 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

birds, they were included in the analysis of water discharge into the existing reservoir in 

Section 13 and the area applicable to the Seminoe Road Project. 

Potential cumulative impacts to special status terrestrial wildlife species would parallel those 

discussed for general wildlife in Section 4.19.9. Potential cumulative impacts to the five special 

status raptor species, bald eagle, American peregrine falcon, ferruginous hawk, northern 

goshawk, and burrowing owl, would entail the incremental short- and long-term habitat loss and 

fragmentation in the overall region; effects to the small mammal prey base from the network of 

roads and associated project infrastructure; and increased human presence, resulting in bird 

displacement within potential foraging areas. In the case of the burrowing owl, there may be 

loss of potential burrow nest sites from cumulative construction projects within the CIAA 

delineated for area raptor species. The BLM requirements and applicant committed protection 

measures developed for raptor species would minimize the potential effects to breeding birds 

and active nest sites. 

No water depletions in the North Platte River were identified for the Seminoe Road Project. As 

stated in that EIS, the BLM would continue to coordinate and consult with the USFWS on 

potential impacts to downstream threatened and endangered species, including the bald eagle, 

once the exact method of produced water discharge is established and before production from 

the Fox Hill/Medicine Bow formations to assess any water depletions in the North Platte River. 

Based on the assumption that water quality and water quantity issues would not result from 

implementation of the proposed Pilot Project, no cumulative impacts have been identified for 

special status species that could or do occur along the Medicine Bow River, at the Seminoe 

Reservoir, downstream of the reservoir along the North Platte River, or near the Hanna Draw 

reservoir site. This assumption and assessment encompass the federally endangered bald 

eagle and the applicable BLM sensitive species, the long-billed curlew and white-faced ibis. 

Potential cumulative effects to the black-footed ferret, if present within the CIAA, would be low. 

As stated for the Seminoe Road Project area, white-tailed prairie dog colonies or complexes 

greater than 200 acres represent potential habitat for black-footed ferrets, and, if development 

within such habitat cannot be avoided, the USFWS requires ferret surveys within 1 year of 

planned development. If no ferrets are found, the prairie dog colony would be cleared for 

development for the next year. A large portion of the Seminoe Road Project is non-block 

cleared. No black-footed ferret surveys are required in areas that are block cleared. 

Additionally, ferret surveys conducted for the Seminoe Road Project were not located 

throughout the project area, but only in conjunction with the interconnect pipeline. Given a 

portion of the Seminoe Road Project area was surveyed, the block clearance for the Hanna 

Draw Pilot Project area, the requirement for future annual surveys and appropriate mitigation 

(avoidance if black-footed ferrets are found) outside of this block-cleared zone, and future 

requirements to protect ferrets if reintroduced into the project area, no cumulative impact issues 

were identified for the black-footed ferret. 

Similarly to general wildlife species, the potential cumulative impacts to the other six special 

status mammal species would include direct and indirect effects. These six species include the 

white-tailed prairie dog, swift fox, pygmy rabbit, Wyoming pocket gopher, spotted bat, and 

Townsend’s big-eared bat. Cumulative effects to burrowing mammals, such as the white-tailed 

prairie dog, swift fox, pygmy rabbit, and Wyoming pocket gopher could include direct mortality 

within the CIAA from surface clearance and project construction activities (e.g., well pads, 

roads), in addition to overall habitat loss and fragmentation. Under the BLM sensitive species 

policies, the agency often requires the applicant to locate development outside of active prairie 

dog colonies, when feasible. Although cumulative activities may result in some short-term 

4-63 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

reduction in white-tailed prairie dog populations, this species have a high reproductive potential 

and should recover following concurrent and final reclamation activities. 

The swift fox and pygmy rabbit are relatively rare. Although these species could be affected by 

cumulative actions, swift fox incidence would likely be rare and sporadic. No information is 

currently available on the presence and extent of the pygmy rabbit in the Hanna Draw Pilot 

Project area. It could be assumed the cumulative impacts anticipated for these two burrowing 

mammals would be similar to those effects described for the Proposed Action. Past and 

present actions occurring within the CIAA (project area plus 1-mile buffer) predominantly entail 

past CBNG exploration, coal mining, livestock grazing, and road development. 

No cumulative impact issues were identified for the Wyoming pocket gopher, based on the low 

likelihood of its occurrence. The only cumulative issues delineated for the spotted bat and 

Townsend’s big-eared bat would be the habitat loss and fragmentation for potential foraging 

sites within these species’ CIAA. However, given the availability of other potential foraging 

habitats in and adjacent to the cumulative projects, impacts to these two bat species would be 

expected to be negligible. 

Potential cumulative impacts to the five sensitive songbirds identified as potentially occurring in 

the project area (i.e., sage thrasher, Brewer’s sparrow, sage sparrow, Baird’s sparrow, and 

loggerhead shrike) would again primarily encompass incremental habitat loss and 

fragmentation, as discussed in Section 4.10.2.2. Given these songbirds are generally 

associated with upland habitats (e.g., shrublands and grasslands), the cumulative effects from 

past and present actions would predominantly entail vegetation removal from construction of the 

proposed Pilot Project. The proposed Seminoe Road Project occurs outside of the CIAAs 

identified for these songbirds; therefore, potential cumulative effects focused on the past ground 

disturbance from CBNG exploration, coal mining, livestock grazing, and road development. 

Displacement and habitat loss generally would extend both short- and long-term until 

reclamation has been completed and both herbaceous and shrubs have become re-established, 

respectively. A small amount of sagebrush and other shrublands would be lost in the long term 

from the proposed Hanna Draw Pilot Project over baseline conditions, which includes past 

actions. 

Cumulative development also would result in a loss of potentially suitable habitat for the 

mountain plover parallel to those effects described for the Proposed Action. Active plover nests 

would be protected by the seasonal restrictions for surface use and human-related activities in 

mountain plover habitat from April 10 to July 10 for both future projects. 

Cumulative impacts to the greater sage-grouse would be similar to that described for the 

Proposed Action. The CIAA extends 2 miles beyond active lek centers. The analysis for the 

proposed Pilot Project automatically includes this 2-mile buffer, given the BLM’s existing 

protection measures required to protect breeding and nesting birds. Combining past and 

present actions with the Pilot Project, cumulative effects would primarily include overall habitat 

fragmentation, increased human presence, and noise. No additional increase in predation 

issues for adult birds, young, or eggs were identified, given lek locations relative to existing and 

proposed aboveground facilities. The additive degree of habitat fragmentation, increased 

human-related activities, and increased noise would be considered to be small over existing 

conditions and that identified for the Proposed Action. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-64 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

4.19.11.3 Special Status Aquatic Species 

Given that no impacts to special status aquatic species would be expected from the proposed 

project, no cumulative impacts to these resources from the Pilot Project would be anticipated. 

4.19.12 Cultural Resources 

The CIAA for cultural resources is the immediate project area. Only past and present actions 

would cumulatively add to the proposed Pilot Project. Past CBNG exploration and associated 

infrastructure could have impacted undiscovered cultural sites. However, the BLM’s existing 

measures to minimize potential effects to prehistoric and historic sites would help to preserve 

and document any sites uncovered during project construction activities. No additional future 

cumulative actions have been identified within the boundaries of the project. 

4.19.13 Range Resources and other Land Uses 

4.19.13.1 Range Resources 

The Proposed Action would result in the loss of 399 acres of rangeland. Approximately 

410 acres of this disturbance would be short term, since utility corridors would be reclaimed 

soon after construction. The long-term loss of 30 acres would result in a loss of 5 AUMs within 

the Dana Block North Allotment (CIAA for range resources). These reductions in livestock 

carrying capacity would add to incremental losses in carrying capacity that have accrued from 

other CBNG exploration and coal mining. Reductions in livestock carrying capacity may be 

compensated somewhat by BLM range improvements to be implemented to treat decadent 

stands of sagebrush. The Seminoe Road project would not impact the Dana Block North 

Allotment. 

4.19.13.2 Other Land Uses 

Potential cumulative effects from development of the proposed Pilot Project would be expected 

to be small. The primary use of the area is livestock grazing, which is addressed above. The 

proposed project and other reasonably foreseeable activities in the CIAA are consistent with 

county ordinances and BLM plans for the area. Adverse effects on the amount of dispersed 

recreation in the area, if any, would be small. 

4.19.14 Noise 

There would be no cumulative noise effects expected from the proposed Pilot Project and other 

reasonably foreseeable activities in the CIAA. Noise levels from the proposed project would be 

relatively low and the distance between the proposed project and other reasonably foreseeable 

activities in the area is sufficiently large that anyone in a position to hear proposed project 

related activities, or within 2,000 feet of the Project Area, would not be able to hear noise from 

other projects under normal atmospheric conditions. 

4.19.15 Recreation 

Small increases in demand for recreation opportunities from population growth related to the 

proposed Seminoe Road Project may be felt in the vicinity of the proposed Pilot Project. 

Recreation resources in the project area are not extensive, however, and recreation 

opportunities are much greater elsewhere in the region. Consequently, any cumulative 

4-65 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

recreation effects from increased demand and temporary displacement of dispersed recreation 

opportunities from the project area would be small. 

4.19.16 Visual Resources 

Cumulative visual effects from the proposed Pilot Project would be low to non-existent in the 

vicinity of the wellfield. The project-related electric distribution line and interconnect pipeline, if 

built, would be visible from CR 291, but terrain would block views of the reasonably foreseeable 

Seminoe Road Project from this viewpoint. 

The southwestern extremity of the interconnect pipeline would be visible from U.S. 30/287 and 

some features of the Seminoe Road Project wellfield would be visible in the middle distance 

from this viewing perspective. The cumulative visual effects should comply with the VRM Class 

III Management Objective since the pipeline would be visually subordinate to the existing 

landscape character after successful reclamation. The wellfield activities, especially the roads, 

would introduce greater levels of visual contrast, but at a somewhat greater distance. Together, 

the visual contrast effects would be low to moderate and should not dominate the view. 

4.19.17 Socioeconomics 

Cumulative effects resulting from the proposed Pilot Project and the Seminoe Road Project 

would generally be positive and relatively small in the context of the Carbon County social and 

economic environment. There would be only a small percentage increase in employment, and 

thus population, from the cumulative activity. As a result, there would be a small increase in 

demand for public facilities and services, all of which have sufficient excess capacity to 

accommodate the growth. Public revenues at both the state and local level would increase from 

the cumulative activity due both to direct payments by the projects and to wages and salaries 

paid to workers. The net effect on the public sector would be positive. 

Existing hotels, motels, mobile home parks and camping facilities in Rawlins and surrounding 

communities would be adequate to accommodate the expected small increase in demand for 

temporary housing. There would be some cumulative loss of grazing capacity on both public 

and private land in Carbon County for the life of the projects. There also would be some 

increase in purchases of goods and services from county businesses by the projects and their 

employees. 

4.19.18 Transportation and Access 

Most traffic effects from the proposed Pilot Project would be limited to CR 291 from its 

intersection with County Road 270 to Hanna and Highway 72 from Hanna to the I-80 

interchange, including the Highway 30/287 intersection. There may be some additional traffic 

from the reasonably foreseeable Seminoe Road Project in this area. Some portion of 

project-related traffic would travel westerly via U.S. 30/287 and I-80 through Walcott Junction 

and Rawlins, where it would interact with traffic from the Seminoe Road Project. However, these 

roadways have ample capacity to accommodate the combined traffic with no effect on 

operational characteristics or safety. Consequently, there would be little, if any, cumulative 

effect on transportation. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 4-66 
CHAPTER 4: ENVIRONMENTAL CONSEQUENCES

4.19.19 Health and Safety 

Cumulative health and safety impacts would be limited to those associated with past and 

present activities in the project area and the incremental impacts of the Pilot Project. 

Furthermore, no additional oil and gas activity or other development is anticipated in the future 

within the project area. Therefore, cumulative affects to public health and safety are expected 

to be low, the same as is anticipated for the Pilot Project. 

4-67 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 5 

CONSULTATION AND COORDINATION 
CHAPTER 5: CONSULTATION AND COORDINATION 

CHAPTER 5 

Consultation and Coordination 

5.1 PUBLIC PARTICIPATION 

A Scoping Notice for the Hanna Draw Coalbed Natural Gas Pilot Project (Pilot Project) 

Environmental Assessment was issued on May 21, 2004 for a 30-day public comment period 

(May 21, 2004 to June 21, 2004). The purpose of the notice was to solicit input on potential 

issues regarding the proposed Pilot Project from government agencies and other interested 

organizations, groups, and individuals. The BLM received a total of 10 comment letters during 

the scoping process expressing both concern about specific resource issues, implementation of 

the NEPA process, other permitting requirements, as well as support for the project. The 

following groups and organizations submitted comment letters on the following topics: 

• Department of Interior, Bureau of Reclamation: The Bureau of Reclamation 

expressed concern regarding the quality and quantity of both surface water and 

groundwater in the project area. 

• Southern Ute Indian Tribe: The Tribe requested that NAPGRA statutes be adhered to 

and that they be notified of inadvertent discoveries of Native American sites, artifacts, or 

human remains. 

• Carbon County Economic Development Corporation: The County expressed 

support for the proposed project and offered guidance for future oil and gas 

development. 

• Wyoming State Engineer’s Office: The State Engineer identified their statutory 

responsibility for permitting and administration of water in the state and applications 

must be filed for each well prior to construction. 

• Petroleum Association of Wyoming: The association expressed support for the 

project and encouraged that the NEPA analysis of the project be completed in a timely 

manner. 

• U.S. Forest Service: The Forest Service expressed concern over potential cumulative 

visibility impacts to nearby Class I wilderness areas and requested that the BLM 

evaluate these impacts in the EA, including consideration of potential off-site mitigation 

to improve the overall air quality in southwestern Wyoming. 

• Wyoming Department of Environmental Quality: The WDEQ commented that as 

many as three water related permits from the Water Quality Division (WQD) may apply 

to the proposed project (Water Discharge, Storm Water Associated with Construction 

Activity, or Underground Injection Control). 

• U.S. Fish and Wildlife Service: The FWS provided comments in anticipation of 

section 7 consultations to be conducted under the Endangered Species Act. The 

comments also provided information on threatened, endangered, and candidate species, 

migratory birds, wetlands and riparian areas, and sensitive species in the area. 

Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 5-1 
CHAPTER 5: CONSULTATION AND COORDINATION 

• Wyoming Game and Fish Department: The WGFD provided information on terrestrial 

and aquatic habitats and species to be evaluated in the EA, expressed concern over 

cumulative impacts (e.g., roads), and offered suggestions to minimize impacts to surface 

water. 

• Biodiversity Conservation Alliance: The alliance expressed concern over potential 

impacts of the proposed project to water quality and quantity, soils, wildlife habitat 

(terrestrial and aquatic), threatened and endangered species, cultural/sacred site, toxic 

substances, earthquakes/subsidence, reclamation potential, and cumulative impacts. 

5.2 CONSULTATION AND COORDINATION 

During the preparation of this EA, the BLM and consultant team contacted and received input 

from the following federal, state, and local agencies: 

Federal Government Agencies 

• Natural Resources Conservation Service 

• U.S. Fish and Wildlife Service 

State Government Agencies 

• Colorado Division of Wildlife 

• Wyoming Department of Environmental Quality, Air Quality Division 

• Wyoming Game and Fish Department 

• Wyoming Natural Diversity Database 

County Government Agencies 

• Carbon County Planning & Economic Development Department 

Local Government Agencies 

• Town of Hanna 

5.3 LIST OF PREPARERS 

This EA was prepared by a third-party contractor under the direction of the BLM Rawlins Field 

Office. The following individuals within the BLM’s Rawlins Field Office (except where noted 

otherwise) contributed to the drafting and review of the document: 

• Travis Bargsten, Natural Resource Specialist; BLM Project Lead 

• Susan Foley, Soil Scientist; Soils/Reclamation 

• Cheryl Newberry, Rangeland Management Specialist; Rangeland Management 

• Frank Blomquist, Botanist; Vegetation Resources, Special Status Species 

• Mark Newman, Geologist; Geology/Paleontology 

• Bob Lange, Hydrologist; Hydrology/Water Quality 

• Susan Caplan, Air Quality Specialist; Air Quality (BLM Wyoming State Office) 

• Michael Bower, Fisheries Biologist; Aquatic Biology, Special Status Species 

• Heath Cline, Wildlife Biologist; Terrestrial and Aquatic Biology, Special Status Species 

• Bill Falvey, Wildlife Biologist; Terrestrial and Aquatic Biology, Special Status Species 

5-2 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 5: CONSULTATION AND COORDINATION 

• Krystal Clair, Recreation Planner; Visual Resources/Recreation 

• Patrick Walker, Archaeologist; Cultural Resources 

• Jon Dull, Petroleum Engineer 

• Mike Jensen, District Engineer 

• Chuck Valentine, Realty Specialist 

• Diane Schurman, Realty Specialist 

• David Simons, Environmental Planner 

• Roy Allen, Economist (BLM Wyoming State Office) 

• Debbie Johnson, Assistant Field Manager - Resources 

The following individuals, along with their affiliation and area of responsibility, were members of 

The RETEC Group, Inc. (RETEC) third-party EA preparation team: 

• Dan Gregory; RETEC; Project Manager, Reviewer 

• Lori Nielsen; EDM International, Inc.; Assistant Project Manager, Terrestrial Wildlife, 

Special Status Animal Species, Technical Editor 

• Gregg Somermeyer; RETEC; Senior Engineer, Surface Water Permitting 

• Bjorn Bjorkman; RETEC; Surface Water Resources, Aquatic Biology, Special Status 

Aquatic Species 

• Bjorn Selvig; RETEC; Geology, Groundwater 

• Christian Zier; Centennial Archaeology; Cultural Resources 

• Mary Painter; Centennial Archaeology; Cultural Resources 

• Mike Phelan; Cedar Creek Associates; Range Resources 

• Steve Long; Cedar Creek Associates; Soils, Weeds, Wetlands and Vegetation, and 

Special Status Plant Species 

• Bernie Strom; Planera; Land Use, Environmental Justice, Socioeconomics, Recreation, 

Visual Resources, Noise, Transportation 

5-3 Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 
CHAPTER 6 

REFERENCES 
CHAPTER 6: REFERENCES 

CHAPTER 6 

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Anderson, R. J. and A. M. Bruce. 1980. Comparison of Selected Bald and Golden Eagle Nests 

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_____. 1998. Sage-grouse Declines in Western North America: What are the Problems? 

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Breithaupt, B. H. 1985. Non-mammalian Vertebrate Faunas from the Late Cretaceous of 

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______. 1994. News for University of Wyoming, Department of Geology and Geophysics. 

Society of Vertebrate Paleontology, News Bulletin, February 1994. Pp.89-90 

Buenger, B. A. 2004a. Class III Cultural Resource Inventory Report for the Anadarko 

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_____. 1987. Draft Resource Management Plan/Environmental Impact Statement for the 

Medicine Bow-Great Divide Resource Area, Rawlins District, Wyoming, BLM-WY-ES87-008-4410. 500 pp. 

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Final Environmental Impact Statement. Great Divide Resource Area, Rawlins District, 

Rawlins, Wyoming. 249 pp. 

_____. 1990. Great Divide Resource Area Record of Decision and Approved Resource 

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_____. 1995a. Draft KENETECH/PacifiCorp Windpower Project Environmental Impact 

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_____. 1998. Draft Carbon Basin Coal Project Environmental Impact Statement. DES-98-32. 

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_____. 2001a. Environmental Assessment for the Seminoe Road Coalbed Methane Pilot 

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_____. 2002a. Environmental Assessment for the Hanna Draw Coalbed Methane Exploration 

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Hanna Draw Coalbed Natural Gas Pilot Project Environmental Assessment 6-11 
Appendix A 

Master Surface Use Plan 
MASTER SURFACE USE PLAN (MSUP) 

Hanna Draw Coalbed Natural Gas (CBNG) Project

Anadarko E & P Company LP (AEPC) 

Surface Use Program and Plan of Development for the subject wells listed below:

Lease WYW-148227 Locations 

Well Name Location Footages Q Q Sec T R

Hanna Draw Federal 2-1 SHL 1644 FNL 1220 FEL SE/4 NW/4 2 23N 81W

Hanna Draw Federal 2-2 SHL 1582 FNL 2580 FWL SE/4 NW/4 2 23N 81W 

Hanna Draw Federal 2-3 SHL 1320 FNL 1320 FWL C NW/4 2 23N 81W 

Hanna Draw Federal 2-4 SHL 2640 FNL 1320 FWL C W/2 2 23N 81W 

Hanna Draw Federal 2-5 SHL 2640 FSL 2540 FEL C section 2 23N 81W 

Hanna Draw Federal 2-6 SHL 2625 FSL 1320 FEL C E/2 2 23N 81W 

Hanna Draw Federal 2-7 SHL 1320 FSL 1320 FEL C SE/4 2 23N 81W 

Hanna Draw Federal 2-8 SHL 1320 FSL 2587 FWL C S/2 2 23N 81W 

Hanna Draw Federal 2-9 SHL 1095 FSL 1220 FWL SW/4 SW/4 2 23N 81W 

Hanna Draw Federal 2-11 SHL 1036 FNL 310 FWL NW/4 NW/4 2 23N 81W 

Hanna Draw Federal 2-12 SHL 300 FSL 400 FEL SE/4 SE/4 2 23N 81W 

Hanna Draw Federal 2-21 SHL 505 FSL 1090 FWL SW/4 SW/4 2 23N 81W 

Hanna Draw Federal 2-22 SHL 520 FSL 1902 FWL SE/4 SW/4 2 23N 81W 

Hanna Draw Federal 2-23 SHL 707 FSL 2009 FEL SW/4 SE/4 2 23N 81W 

Hanna Draw Federal 2-24 SHL 2080 FSL 760 FEL NE/4 SE/4 2 23N 81W 

Hanna Draw Federal 2-25 SHL 1980 FNL 760 FEL S/2 NE/4 2 23N 81W 

BLM approved the Hanna Draw Federal 2-2 APD on May 26, 2005 so that AEPC could 

acquire water data for the Water Quality and potential treatment methods for the EA. This well 

spudded on October 16, 2005 and APC is conducting appropriate water treatment trials. 

Plan of Development for the facilities listed below:

Proposed ROW (BLM surface ownership lands): Buried Electrical Utility, Water and

Gas Lines in Section 2 & 34, T23N, R81W (all pipeline corridors within the field will 

parallel roads) 

Proposed ROW (BLM surface ownership lands) Delivery Pipeline for Gas: 

T23N R81W in Section 2 

Proposed ROW (BLM surface ownership lands) access roads: 

Section 34, T23N, R81W 

The MSUP contains surface operating procedures for the Federal Applications for Permits to 

Drill (APDs), as required under Onshore Order No. 1. The enclosed Project Map shows all 

proposed drilling activities associated with the Hanna Draw CBNG Project. Additional 

information on each federal well is contained in the BLM APD Form 3160-3 and Well Survey 

Plat. 

Amended 1/16/2007 1
This MSUP is intended to serve as the ROW application for the gas and water lines, and 

electric lines in the project. Gas-gathering and water-gathering lines will require a 20-foot 

right-of-way and electric lines a 10-foot right-of-way. The delivery pipeline will require a 100-

foot construction right-of-way and 50-foot operational right-of-way. All ROWs located in the

same corridor will overlap each other to the maximum extent possible, while maintaining sound 

construction and installation practices. Where ROW corridors are located along a road,

working space for installation of facilities will be along the road. All flowlines and roads have 

been co-located where possible. Please refer to the schematic for the layout of pipelines and 

roads. The enclosed Project Map shows the location of all access routes, gatherings lines, and 

the delivery pipeline. 

An allocation meter will be used to measure raw produced gas volumes for each well in the

project. A sales meter will be located downstream of the final compressor and dehydration 

unit, at the compressor station, and will be used to measure dry salable-quality gas. A request 

for variance from Onshore Order No. 5, if needed, along with a description of the measurement 

equipment, will be submitted in a Sundry Notice if the wells are deemed producible.

During well testing associated with this project, natural gas, to the extent it is produced, will be

vented or flared on-location in accordance with the applicable BLM Onshore Orders, Notices

To Lessees, and WOGCC regulations, and authorized by the WOGCC and the BLM in Sundry 

Notices. During testing, produced water from the proposed wells will be discharged after 

appropriate treatment to the Medicine Bow River under a Wyoming Pollutant Discharge 

Elimination System (WYPDES) permit, in accordance with the Wyoming Department of

Environmental Quality (WDEQ) and upon Onshore Order #7 approva by the BLM. 

1. EXISTING ROADS AND TRAVELWAYS 

The project area is accessible from Hanna, Wyoming, by traveling approximately 11.4 miles

Northeast on Carbon County Road 291 (Hanna Draw Road). Turn right in Section 34, T24N 

R81W, and travel southeasterly for approximately 2 mile into Section 2, T23N, R81W. This 

road provides access into the project area. 

Local roads are shown on the enclosed map of the project area. Existing roads and gates will

be used when practical. As necessary, existing roads shall be brought up to minimum standards 

for a Resource Road as found in BLM Manual 9113. 

Maintenance of the roads used to access the well locations will continue until final 

abandonment and reclamation of the well locations occur. A regular maintenance program will

include, but is not limited to, blading, ditching, culvert installation and cleanout, and gravel 

surfacing where excessive rutting or erosion may occur. 

Culverts (a minimum of 18-inches in diameter) will be placed in the existing BLM roads as the

need arises or as directed by BLM’s Authorized Officer. 

When necessary, the use of traffic control and speed limits will be implemented to limit

potential livestock conflicts. 

Amended 1/16/2007 2
2. PROPOSED ACCESS ROUTES 

Well Access

New access roads will be sited to avoid sensitive resource areas, such as leks, and areas 

susceptible to increased resource damage from the proposed project, such as areas of steep 

terrain or poor vegetative cover. Every effort will be made to minimize the amount of cut-andfill construction needed to maintain safe, environmentally sound, year-round access to the well 

sites. The special conditions of approval specified for this project by the BLM will be

implemented. 

Where possible existing two-tracks will be upgraded as specified by BLM to provide access to

well sites. Newly constructed access roads will be crowned, ditched, and graveled, as specified 

by BLM. All equipment and vehicles will be confined to identify travel corridors and other 

areas specified in this MSUP and APDs. The access roads will be surfaced with an appropriate 

grade of aggregate or gravel to a depth of 4 inches before the drilling equipment or rig is moved 

onto the pad. 

Unless otherwise exempted, free and unrestricted public access will be maintained on the 

access road. All construction work will be accomplished as specified by the landowner and the 

BLM. Access roads will be maintained in a safe and usable condition. A regular maintenance 

program will include, but is not limited to, blading, ditching, installing or cleaning culverts, and 

surfacing. 

The access roads will be constructed to minimum standards for a BLM Resource Road, as 

outlined in BLM Manual 9113. The minimum travelway width of the road will be 14 feet with 

turnouts. No structure will be allowed to narrow the road top. The inside slope will be 4:1. The

bottom of the ditch will be a smooth V with no vertical cut in the bottom. The outside slope 

will be 2:1 or shallower. Turnouts will be spaced at a maximum distance of 1,000 feet and will 

be visible. 

Wing ditches will be constructed as deemed necessary to divert water from the road ditches.

Wing ditches will be constructed at a slope of .5 percent to 1 percent. 

Topsoil and vegetation will be windrowed to the side of the newly constructed access roads.

After the roads are crowned and ditched, the topsoil will be pulled back onto the cut slopes of

the road right-of-way so no berm is left at the top of the cut slope. 

Drainage crossings on the access routes will be low water crossings or crossings using culverts. 

Culverts would be installed on smaller, steeper channel crossings. Rip-rap will be added at the 

outlet of each culvert to minimize erosion. Topsoil would be conserved before channel 

crossing construction occurs. Additional culverts would be placed as the need arises or as 

directed by the BLM’s Authorized Officer. 

Culverts will be covered with a minimum of 12 inches of fill or one-half the diameter of the 

pipe, whichever is greater. The inlet and outlet will be set flush with existing ground and lined

up in the center of the draw. Before the area is backfilled, the bottom of the pipe will be

Amended 1/16/2007 3
bedded on stable ground that does not contain expansive or clay soils, protruding rocks that 

would damage the pipe or unevenly sized material that would not form a good seat for the pipe. 

The site will be backfilled with unfrozen material and rocks no larger than 2 inches in diameter. 

Care will be exercised to thoroughly compact the backfill under the haunches of the conduit. 

The backfill will be brought up evenly in 6-inch layers on both sides of the conduit and 

thoroughly compacted. A permanent marker will be installed at both ends of the culvert to help

keep traffic from running over the ends. Culverts will be installed in a manner that minimizes

erosion or head-cutting and may include rip rapping or other measures as required. Additional

culverts will be placed in the access road as the need arises or as directed by BLM’s Authorized 

Officer. 

The access roads will be winterized by providing a well-drained travelway to minimize erosion

and other damage to the roadway or the surrounding public land. Construction activity or 

routine maintenance will not be conducted using frozen or saturated soil material or during 

periods when watershed damage is likely to occur. 

No construction or routine maintenance activities will be performed during periods when the 

soil is too wet to adequately support construction equipment. If such equipment creates ruts in 

excess of 4 inches deep, the soil will be deemed too wet to adequately support construction 

equipment, and construction and maintenance will be temporarily suspended. 

The written approval of the Authorized Officer will be obtained before snow removal is 

undertaken outside the new and existing roadways. If approval is given, equipment used for 

snow removal operations outside the road ditches will be equipped with shoes to keep the blade

off the ground surface. Special precautions will be taken where the surface of the ground is

uneven to ensure that equipment blades do not destroy the vegetation. 

If drilling is productive, all access roads to the well site would remain in place for well 

servicing (such as maintenance and improvements). Portions of the drill location outside the 

well pad that are no longer needed would be reclaimed. The outside ditch cuts would be seeded 

and reclaimed. 

3. LOCATION OF EXISTING WELLS 

Water for use in well drilling would be obtained from existing gas wells completed in the coal 

seams of the Hanna Formation. Associated drilling activities also would require almost 

100,000 gallons of water per well for preparation of cement or stimulation of the well, and dust 

control. Dust abatement measures would comply with all applicable Wyoming Oil and Gas 

Conservation Commission (WOGCC) requirements. Only water suitable for livestock use 

would be used for dust abatement. 

The enclosed Project Map shows locations of drilling, producing, and abandoned oil and gas

wells within the EA boundary of the Hanna Draw CBNG wells. The well locations were 

obtained by a search of the WOGCC website. 

Amended 1/16/2007 4
4. LOCATION OF EXISTING AND/OR PROPOSED FACILITIES, IF WELLS 

ARE PRODUCTIVE

On Well Pad 

Wellhead facilities would be installed if the wells are productive. Natural gas and produced 

water would be collected and transported from the wellhead via buried pipelines. Gas and 

water would be measured as specified elsewhere in this MSUP. 

The short-term surface disturbance at the location of each productive well would encompass an 

estimated 1.4 acres for each well pad, approximately 200 feet x 300 feet, covering, not 

including stockpiles and the cut and fill slopes. Typically, only the production facilities at the 

well site would be fenced or otherwise removed from existing uses. A loop road or a small, 

graveled pad area would provide a safe turnaround area for vehicles. 

The wellhead facilities would be contained within an area covering approximately 15 feet by 15 

feet. The surface equipment at each well will consist of the wellhead, a pump panel, and an 

insulated wellhead cover. Additionally, a vertical separator at some well sites would separate 

gas from the water stream. Each productive well is expected to require installation of an electric 

submersible pump below ground level, which will be used to produce water necessary to lower 

pressure within the coal seams. 

AEPC will paint structures at wells and central facilities with flat colors that blend with the

adjacent undisturbed terrain. The paint used will be the color Shale Green, color 5Y 4/2unless 

otherwise specified by the BLM. This measure does not apply to structures that require safety 

coloration in accordance with the requirements of the Occupational Safety and Health

administration (OSHA). 

Electricity would be used to power pumps during well development and to initiate and maintain

production. A temporary generator would be centrally located and used until permanent

electrical services are installed. 

Water transfer pumping stations may be used during production operations to transfer produced 

water from the gas wells to the water handling facilities. The transfer pumping stations are 

needed in areas where differences in elevation require supplemental pumping to transfer the 

produced water. If transfer pumping stations were required, they will be placed on existing

well pad and no new disturbance will occur, and would be authorized prior to construction by 

Sundry Notice. 

Off Well Pad 

Pipelines (Gathering Lines and Delivery Pipeline)/Compressor Station/ 

Water Handling and Disposal Facilities/Injection Wells/Tanks 

Pipelines 

The ROWs for the gathering systems will parallel access roads. ROWs located in the same 

corridor will overlap each other to the maximum extent possible, while maintaining sound 

Amended 1/16/2007 5
construction and installation practices. Where ROW corridors are located along a road,

working space for installation of facilities will be along the road. 

Trenches will be excavated to install the flowlines and electrical lines. In open pipeline 

trenches, plugs will be placed no more than 1,000 feet apart to allow livestock and wildlife to 

cross or escape the trench, if needed. Placement of plugs shall be determined in consultation 

with BLM and any affected landowner or livestock operator. Trenching will occur as close to 

the road as feasible. Trenches excavated for well gathering lines and electrical lines (which 

would require ROWs of 20 feet in width for gas lines and water lines, and 10 feet in width for 

electrical lines) would be reclaimed as soon as practical after trenching and backfilling are 

completed. Gathering line segments in the project area would total about 5 miles, with 4 miles 

located on BLM-administered lands and 1 mile located on private land. 

A gas-gathering pipeline system (low pressure) would be constructed from the wellheads to the 

compressor station. This system would use high-density polyethylene (HDPE) pipe, starting 

with 4-inch diameter pipe at the wellhead and graduating up to 20-inch diameter pipe at the 

inlet to the compressor. 

A produced water-gathering pipeline system (low pressure) would be constructed from the 

wellheads to the centralized facilities and from the centralized facilities to the surface discharge 

outfall. This network of water lines would use 4-inch through 12-inch diameter pipe made of 

steel. 

A gas-delivery pipeline system (high pressure) would be constructed from the compressor 

station to an existing transmission pipeline. This pipeline would be constructed of 8-inch to 12-

inch diameter steel pipe.

Top soil material will be stockpiled to the side and segregated. Top soil material will not be

mixed or covered with subsurface material. After construction cut and fill slopes will be

waterbarred or regraded to conform to the adjacent terrain as specified by BLM. 

In order to minimize surface disturbance, the operator will use wheel trenchers (ditchers) or

ditch witches, where possible, to construct all pipeline trenches associated with this project. 

Track hoes or other equipment will be used where topographic or other factors require their 

use. 

Disposal of Produced Water 

As part of the proposed Hanna Draw Pilot Project, up to 100,000 barrels (4,200,000 gallons) of 

produced water per day from the production operations would be discharged after treatment 

into the Medicine Bow River. Water quality would meet or exceed WYPDES and WDEQ

standards. The project’s Water Management Plan is attached. Produced water quality also 

would be monitored in accordance with WDEQ regulations. 

5. LOCATION AND TYPE OF WATER SUPPLY FOR DRILLING

Water to drill the first well will come from the town of Hanna, following existing access roads,

County Rd 291 into section 2-23N-81W. Thereafter, water produced from project wells will be 

Amended 1/16/2007 6
transported to nearby drilling locations and used to drill subsequent wells. As a contingency, 

water may be purchased from the city of Hanna and trucked to the location. 

Water for use in drilling the wells would be obtained from existing wells completed in the coal 

seams of the Hanna Formation. Approximately 30,000 gallons would be needed to drill each 

well. The actual volume of water used in drilling operations would depend on the depth of the 

well and any losses that might occur during drilling. The proposed project also would require 

almost 70,000 gallons of water per well for preparation of cement and stimulation of the well

(55,440 gallons) and control of dust (14,000 gallons). In all, nearly 100,000 gallons of water 

per well would be used. 

Any changes in the water source or method of transportation must receive written approval 

from BLM’s Authorized Officer before the changes take place. 

6. CONSTRUCTION MATERIALS

Construction materials (mineral material aggregate suitable for surfacing material) will be 

purchased from a nearby private source or a local supplier having a permitted source of 

materials in the area. No construction materials will be removed from federal and/or Indian

lands without prior approval from the BLM. 

7. METHODS FOR HANDLING WASTE DISPOSAL

Drill cuttings (rock fragments generated during drilling) will be produced during drilling of the 

borehole. Cuttings will be buried in the reserve pit upon closure of the reserve pit. 

No oil or other oil-based drilling additives, chromium/metals-based muds, or saline muds will 

be used during drilling of these wells. Only fresh water, biodegradable polymer soap, bentonite

clay, and non-toxic additives will be used in the mud system. Details regarding the mud

program are incorporated within the MDP. These wells will not produce oil or salt water 

typical of oil production. Furthermore, other liquid hydrocarbons are not anticipated. Should 

unexpected liquid petroleum hydrocarbons (crude oil or condensate) be encountered during 

drilling or well testing, all liquid petroleum hydrocarbons will be contained in test tanks on the 

well site. 

Dust abatement using produced water would comply with all applicable WOGCC, WDEQ, or 

BLM requirements. Only water suitable for livestock use would be used for dust abatement. 

Only disturbed areas will be sprayed. Spraying will be done to reduce runoff and channelized 

flow. 

A portable, self-contained chemical toilet will be provided on location during drilling and 

completion operations. Upon completion of operations, or as required, the contents of toilet 

holding tanks will be disposed of at an authorized sewage treatment and disposal facility.

Disposal will be in accordance with State of Wyoming, Carbon County, and BLM requirements 

regarding sewage treatment and disposal. AEPC will comply with all state and local laws and

regulations pertaining to disposal of human and solid wastes. 

Amended 1/16/2007 7
No trash will be placed in the reserve pit. All refuse (trash and other solid waste including 

cans, paper, cable, etc.) generated during construction, drilling, and well testing activities will 

be contained in an enclosed receptacle, removed from the drill locations promptly, and hauled 

to an authorized disposal site. 

Immediately after removal of the drilling rig, all debris and other waste materials not contained 

within trash barrels will be cleaned up and removed from the well location. No potentially

adverse materials or substances will be left on the drill locations. 

Hazardous Materials Management 

All project-related activities involving hazardous materials will be conducted in a manner that 

minimizes potential environmental impacts. An on-site file will be maintained containing 

current Material Safety Data Sheets (MSDS) for all chemicals, compounds, or substances that 

are used in the course of construction, drilling, completion, production, and reclamation 

operations. Netting will be placed over any pits that may contain hazardous substances 

(Comprehensive Environmental Response, Compensation, and Liability Act [CERCLA] 

Section 101(14)), as determined by visual observation or testing. The mesh diameter shall be no 

larger than 1 inch. 

No hazardous substance, as defined by CERCLA, will be used in the construction or drilling

operations associated with these wells. No Resource Conservation and Recovery Act (RCRA)

hazardous wastes will be generated by well-drilling operations. The term “hazardous

materials” as used here means: (1) any substance, pollutant, or containment (regardless of 

quantity) listed as hazardous under CERCLA of 1980, as amended 42 U.S.C. 9601 et seq., and 

the regulations issued under CERCLA; (2) any hazardous waste as defined in RCRA of 1976, 

as amended; and (3) any nuclear or nuclear byproduct as defined by the Atomic Energy Act of 

1954, as amended, 42 U.D.C. 2001 et seq. The operator will be required to provide a referenced 

list of hazardous materials that could be used, produced, transported, disposed of, or stored on

the well location including a discussion on the management of the hazardous materials. 

Any spills of oil, gas, or any other potentially hazardous substance will be reported 

immediately to the BLM, landowner, local authorities, and other responsible parties and will be 

mitigated immediately, as appropriate, through cleanup or removal to an approved disposal site. 

8. ANCILLARY FACILITIES

AEPC would operate all wells, pipelines, and associated ancillary production facilities in a safe 

manner, as set forth in standard industry operating guidelines and procedures. Several selfcontained travel-type trailers may be used onsite during drilling operations. Routine 

maintenance of producing wells would be necessary to maximize performance and detect 

potential difficulties with production operations. Each well location would be visited 

approximately every other day to ensure that operations are proceeding in an efficient and safe 

manner. The visits would include checking separators, gauges, valves, fittings, tanks, 

generators, and pumps. The equipment onsite also would be routinely maintained, as 

necessary. Additionally, all roads and well locations would be regularly inspected and 

maintained to minimize erosion and assure safe operating conditions. 

Amended 1/16/2007 8
9. WELL SITE LAYOUT 

Information on each federal well is contained in the BLM APD Form 3160-3, Well Survey

Plat, and Drill Pad Cross Section on file with BLM. The cross section shows the orientation

of the drill pad with respect to the topographic features (cut and fill), facilities, and access to

the pad. 

At each drill location, surface disturbance will be kept to a minimum. The areal extent of each

drill pad is approximately 200 feet by 300 feet. Each drill pad will be leveled using cut and fill 

construction techniques where needed. Prior to constructing the drill pad the top 6 to 8 inches

of soil (more if available) and associated vegetative material will be removed and stockpiled.

Drainage ditches will be constructed to divert stormwater away from each pad. All surface 

disturbance related to drilling will be confined to each drill site. 

AEPC plans to use one reserve pit at each drilling location. This pit will be designed and

constructed according to WOGCC and BLM requirements. 

A temporary reserve pit about 75 feet wide x 95 feet long x 8 feet deep would be excavated at 

each vertical drill location. Each pit will be excavated within the “cut area” of the drill site to 

minimize any potential for slope failure. Each pit will be designed to prevent collection of

surface runoff and will be closely monitored to ensure no pit overflows occur. The reserve pit 

will be open for an estimated 6 - 12 months to allow for evaporation of pit fluids. During this 

time, the pit would be fenced on all sides with three-strand, barbed wire fencing to prevent 

access from livestock. 

Each reserve pit will be constructed in a manner that minimizes the accumulation of surface 

precipitation runoff into the pit. This will be accomplished by appropriate placement of 

subsoil/topsoil storage areas or construction of berms or ditches. 

In the event that water quality is determined to be potentially detrimental to wildlife (e.g.,oil 

deposition), AEPC would initiate dialog with the BLM to identify if any supplemental 

mitigation measures would be warranted in the short and long term. If netting is necessary over

open production pits to eliminate any hazard to migratory birds or other wildlife, AEPC and the 

BLM would develop an appropriate monitoring program for netted areas. Monitoring 

frequency would depend on 1) pit location, 2) evaluated water quality, 3) estimated water 

residence time, and 4) frequency of well maintenance schedule. AEPC will monitor activities 

as part of project implementation and will notify the BLM in the event a wildlife injury or

fatalities were found at one of the reserve pits. For the protection of livestock and wildlife, all 

pits and open cellars will include a modified fencing design, temporary covers, or other means 

acceptable to BLM or an affected landowner or livestock operator. Fence the reserve pit on 

three sides during drilling, and fence the working side immediately after the drilling rig is 

moved. The reserve pit shall remain fenced until reclamation is initiated. 

A conventional drilling rig would be used to drill the gas wells. Additional equipment and 

materials needed for drilling operations would be trucked to the drill location. Depending on 

the location of the coal seam, each producing well would be drilled to a depth of 4,050 feet to

5,850 feet or deeper. Methane gas in the coal seam would be produced through perforations in 

Amended 1/16/2007 9
the casing. The well control system will be designed to meet the conditions likely to be 

encountered in the hole and will conform to BLM and State of Wyoming requirements. 

The drilling and completion operation for a shallow gas well normally requires a maximum of 

10 to 15 workers at a time, including personnel for logging and cementing. Each well would be 

drilled within 7 to 10 days. A mobile completion rig similar to the drill rig may be transported

to the well site and used to complete each well. Completion operations are expected to average 

2 to 5 days per well. Wells determined to be productive would be shut in until pipelines and 

other production facilities are constructed. 

10. PROGRAMS FOR RECLAMATION OF THE SURFACE 

BLM surface ownership lands that contain disturbed areas or facilities that are no longer 

needed would be reclaimed at the earliest opportunity in accordance with applicable regulations 

and agency guidance. Non-federal lands would be reclaimed in accordance with the

requirements of the surface owner. 

Roads, culverts, cattle guards, pipelines, stock water facilities, or other structures could be left 

in place at the end of the project for any beneficial use, as designated by the affected surface

owners and BLM. Water wells and produced water would be available to the surface owners 

and BLM, provided that appropriations, diversions, and storage rights are properly filed with 

the WSEO. 

As soon as practical after the conclusion of drilling and testing operations, unproductive drill 

holes will be plugged and abandoned and site reclamation will commence. The BLM will be 

notified prior to commencement of reclamation operations. A Notice of Intent to Abandon will 

be filed for final recommendations regarding surface reclamation. 

Any areas, including the drilling locations, reserve pits, or access routes, that are disturbed by 

earthwork will be recontoured to a natural appearance as near to the original contour as

possible as soon as practical after the conclusion of operations. Any flowline trenches that may 

be constructed will be backfilled completely. 

Recontoured areas will graded to be outsloped, and waterbreaks will be constructed where 

needed to avoid concentrating surface waters and producing gullies. The land surface will be

left “rough” after recontouring to ensure that the maximum surface area will be available to

support the reestablishment of vegetative cover. 

All topsoil conserved during earthwork will be redistributed evenly and left “rough” over these 

recontoured areas. BLM goals for vegetative cover will guide revegetation efforts. Common 

goals are erosion control, weed control, palatable and nutritious forage for livestock and 

wildlife, and visual aesthetics. 

Revegetation efforts will comply with BLM specifications on all BLM surface ownership

lands. If no specifications are provided, the following specifications will be used. Seeding is

expected to occur in the fall after September, prior to ground frost, or in the spring after frost 

has left the ground. The seed mixture, including fertilizer and mulching requirements, seeding 

Amended 1/16/2007 10
depth, and seed drilling specifications, will be developed in consultation with the BLM. Seed

will be drilled on the contour using a seed drill equipped with a depth regulator to ensure even 

depths of planting. Seed will be planted between one-quarter to one-half inch deep. The 

anticipated seed mix to be applied and rates of application are listed below. Soil material that 

will be stockpiled for 10 months or longer will be seeded according to BLM specifications, to 

the extent practicable. Prior to seeding, the stockpile will be protected from wind and water 

erosion by roughening the soil surface, covering the stockpile with vegetation that has been

removed, and mulching, if necessary.

SEED MIX FOR RECLAMATION 

Species Rate of Application* 

Grasses 

Slender wheatgrass 2 lbs./Acre 

Thickspike wheatgrass 4 lbs./Acre 

Western wheatgrass 2 lbs./Acre 

Indian ricegrass 1 lb./Acre 

Bottlebrush squirreltail 1 lb./Acre 

Needle-and-thread 1 lb./Acre

Shrubs

Gardner’s saltbush 1 lbs./Acre 

These rates of application apply to pure live seed (PLS) that is used for drill seeding. For 

broadcast seeding, the rates of application will be doubled. 

11. SURFACE OWNERSHIP 

U.S. Bureau of Land Management 

Rawlins Field Office 

1300 North Third 

Rawlins, Wyoming 82301-2407 

(307) 328-4200 

12. OTHER INFORMATION 

AEPC is the lessee or operator for the federal oil and gas leases associated with this MSUP and 

these APDs. 

No slopes in excess of 25 percent would be affected by this proposal. No activities are planned 

near existing highways, railroads, pipelines, or powerlines. There are no occupied buildings or 

residences within one-quarter mile of the proposed drill sites. 

Any road crossings of dry drainages, riparian, or other wetland areas will use appropriate Best 

Management Practices (BMP) to minimize impacts to these areas. Appropriate permits will be

obtained from the US Army Corps of Engineers, if necessary. 

Amended 1/16/2007 11
The presence, distribution, and density of noxious weeds in the project area will be monitored. 

The well access roads and well pads will be inspected regularly to ensure that noxious weeds

do not become established in newly disturbed areas. Control methods will be based on 

available technology, taking into consideration the weed species present. Methods of noxious 

weed control may include revegetation of disturbed areas to reduce the potential for and

success of weed establishment, mowing, hand-pulling, or application of appropriate herbicides.

All BLM requirements associated with the control of noxious weeds will be met. 

A cultural/historical resource inventory has been conducted on the public lands by a qualified 

archaeologist permitted in Wyoming by the BLM. The findings have been submitted under

separate cover. Any additional areas of potential effect identified subsequent to the completion

of these reports will be inventoried as specified by the BLM, and a supplemental report will be 

prepared. 

Landowner Notification

AEPC has obtained a surface use agreement with the landowner and will ensure that livestock

control structures remain functional (as directed by the livestock operator) during drilling and 

production operations and coordinate timing of planned activities. 

13. LESSEE’S REPRESENTATIVE AND CERTIFICATIONS 

Representative for Anadarko E & P Company 

Name: Jennifer Kastner 

Title: Environmental and Regulatory Analyst II 

Address: 1201 Lake Robbins Drive 

City/State/Zip: The Woodlands, Texas 77380 

Phone: (832) 636-3441 

Bonding 

BLM Nationwide Bond, WY 1280, $150,000 

Certification

I hereby certify that I, or persons under my direct supervision, have inspected the proposed drill

sites and access routes; that I am familiar with the conditions which currently exist; that the 

statements made in this plan are, to the best of my knowledge, true and correct; and that the 

work associated with the operations proposed herein will be performed by AEPC and its 

contractors and subcontractors in conformity with this plan and the terms and conditions under 

which it is approved. This statement is subject to the provisions of 18 U.S.C 1001 for the filing

of a false statement. 

I also certify that AEPC will comply with the provisions of the law or the regulations governing 

the Federal or Indian right of reentry to the surface under 43 CFR 3814. 

Amended 1/16/2007 12
I also certify that AEPC has reached or will reach an agreement with the surface owner(s) and

surface lessee(s) regarding the requirements for the protection of surface resources and 

reclamation of disturbed areas and/or damages in lieu thereof, or if an agreement cannot be 

reached, will comply with the provisions of the law or the regulations governing Federal or 

Indian right of reentry to the surface under 43 CFR 3814. 

I also certify that: 

A. All potentially affected landowners having properly permitted water wells with the 

WSEO within each producible well’s Circle of Influence (one-half mile radius) will be

offered a Water Well Agreement; and 

B. If a Water Well Agreement is not reached with the landowner, AEPC agrees to mitigate 

the impacts of its producible wells in accordance with State of Wyoming water laws;

and 

C. Permits to Appropriate Groundwater have been applied for from the Wyoming State 

Engineer’s Office, concurrently with these Applications for Permits to Drill. 

I also certify that AEPC shall use its best efforts to conduct its approved operations in a manner 

that avoids adverse effects on any properties which are listed, or may be eligible for listing, in 

the National Register of Historic Places (NRHP). If historic or archaeological materials are

uncovered during construction, the operator will immediately stop work that might further 

disturb such materials, and contact the authorized officer (or his/her representative) at the BLM 

Rawlins Field Office. Any paleontological resources or fossils discovered as a result of 

operations associated with these wells will be brought to the attention of the authorized officer 

or his/her representative immediately. All activities in the vicinity of such discoveries will be 

suspended until notified to proceed by the Authorized Officer.

I also certify that AEPC shall use its best efforts to conduct its approved operations in 

accordance with the Project-wide Mitigation Measures and procedures outlined in Chapter 2 of 

the Environmental Assessment (EA) for this project. 

By: ________________________________________ Date: __________________ 

 Jennifer Kastner 

 Environmental and Regulatory Analyst II 

 Anadarko E & P Company LP 

Amended 1/16/2007 13
Appendix B 

Master Drilling Plan 
MASTER DRILLING PROGRAM 

Hanna Draw 

OPERATOR: Anadarko E&P Company LP 

Sections 2,T23N, R81W, 6th PM 

Carbon County, Wyoming 

Drilling Program for the subject wells listed below: 

Hanna Draw Federal 2-1 Hanna Draw Federal 2-9 

Hanna Draw Federal 2-2 Hanna Draw Federal 2-11 

Hanna Draw Federal 2-3 Hanna Draw Federal 2-12 

Hanna Draw Federal 2-4 Hanna Draw Federal 2-21 

Hanna Draw Federal 2-5 Hanna Draw Federal 2-22 

Hanna Draw Federal 2-6 Hanna Draw Federal 2-23 

Hanna Draw Federal 2-7 Hanna Draw Federal 2-24 

Hanna Draw Federal 2-8 Hanna Draw Federal 2-25 

Table 1 contains formation tops and total well depths. 

1. ESTIMATED TOPS OF IMPORTANT GEOLOGIC MARKERS 

Formation SS Depth TMD Depth 

Hanna 79 3197' 3663' 

Hanna 78 2877' 3983’ 

Hanna 2 2350’ 4510’ 

TD 1860’ 4900’ 

** these depths are the shallowest to the deepest 

Hanna 77 2577’ 4283’ 
Hanna Draw Federal POD CBM Master Drilling Plan 

1/16/2007 Page 2 of 10 

Table 1 

Hanna Draw POD CBM Project Well Information 

Well Information 

No. Name Number Footages Sec Tns Rng Elevation Formation Subsea Depth Depth Casing 

1 Hanna

Draw 

Federal 

2-1

1644’FNL 

1220’FEL 

2 23N 81W 6794’ GL Hanna 79 3197’ 3583’ Surface 

Hanna 78 2877’ 3903’ Production 

Hanna 77 2577’ 4203’

Hanna 2 2350’ 4430’

Total

Depth 

1880’ 4900’

2 Hanna

Draw 

Federal 

2-2 1582’FNL

2580’FW

L 

2 23N 81W 6800’ GL Hanna 79 3197’ 3603' Surface 

Hanna 78 2877’ 3923’ Production 

Hanna 77 2577’ 4223’

Hanna 2 2350’ 4450’

Total

Depth 

1900’ 4900’

3 Hanna

Draw 

Federal 

2-3 1320’FNL

1320’FW

L 

2 23N 81W 6793’ GL Hanna 79 3197’ 3603' Surface 

Hanna 78 2877’ 3923’ Production 

Hanna 77 2577’ 4223’

Hanna 2 2350’ 4450’

Total

Depth 

1900’ 4900’

4 Hanna

Draw 

Federal 

2-4 2640’FNL

1320’FW

L 

2 23N 81W 6789’ GL Hanna 79 3197’ 3583' Surface 

Hanna 78 2877’ 3903’ Production 

Hanna 77 2577’ 4203’

Hanna 2 2350’ 4430’

Total 1880’ 4900’
Table 1 

Hanna Draw POD CBM Project Well Information 

Well Information 

No. Name Number Footages Sec Tns Rng Elevation Formation Subsea Depth Depth Casing 

Depth 

5 Hanna 

Draw 

Federal 

2-5 2640’FNL 

2540’FW 

L 

2 23N 81W 6856’ GL Hanna 79 3222’ 3598' Surface 

Hanna 78 2902’ 3918’ Production 

Hanna 77 2602’ 4218’ 

Hanna 2 2375’ 4445’ 

Total 

Depth 

1920’ 4900’ 

Table 1 

Hanna Draw POD CBM Project Well Information 

Well Information 

No. Name Number Footages Sec Tns Rng Elevation Formation Subsea Depth Depth Casing 

6 Hanna Draw 

Federal 

2-6 2625’FSL 

1320’FEL 

2 23N 81W 6838’ GL Hanna 79 3222’ 3598’ Surface 

Hanna 78 2902’ 3918’ Production Hanna 77 2602’ 4218’ 

Hanna 2 2375’ 4445’ 

Total Depth 1920’ 4900’ 

7 Hanna Draw 

Federal 

2-7 1320’FSL 

1320’FEL 

2 23N 81W 6800’ GL Hanna 79 3222’ 3648' Surface 

Hanna 78 2902’ 3968’ Production Hanna 77 2602’ 4268’ 

Hanna 2 2375’ 4495’ 

Total Depth 1970’ 4900’ 

8 Hanna Draw 

Federal 

2-8 1320’FSL 

2587’FWL 

2 23N 81W 6863’ GL Hanna 79 3222’ 3658' Surface 

Hanna 78 2902’ 3978’ Production Hanna 77 2602’ 4278’ 

Hanna 2 2375’ 4505’ 

Hanna Draw Federal POD CBM Master Drilling Plan 

1/16/2007 Page 3 of 10 
Hanna Draw Federal POD CBM Master Drilling Plan 

1/16/2007 Page 4 of 10 

Table 1 

Hanna Draw POD CBM Project Well Information

Well Information 

No. Name Number Footages Sec Tns Rng Elevation Formation Subsea Depth Depth Casing 

Total Depth 1980’ 4900’

9 Hanna Draw

Federal

2-9 1095’FSL 

1220’FWL

2 23N 81W 6849’ GL Hanna 79 3197’ 3663' Surface 

Hanna 78 2877’ 3983’ Production Hanna 77 2577’ 4283’

Hanna 2 2350’ 4510’

Total Depth 1860’ 4900’

10 Hanna Draw

Federal

2-21 506’FSL 

1090’FWL

2 23N 81W 6846’ GL Hanna 79 3222’ 3608' Surface 

Hanna 78 2902’ 3928’ Production Hanna 77 2602’ 4228’

Hanna 2 2375’ 4455’

Total Depth 1930’ 4900’

Table 1 Continued 

Hanna Draw POD CBM Project Well Information

Well Information 

"Well Information 

Cementing Pr

No

. 

Name Number Footages Sec Tns Rng Elevation Formation Subsea Depth Dept h Casing Hole 

11 Hanna 

Draw

Federal 

2-22 520’FSL 

1920’FW

L 

2 23N 81W 6875’ GL Hanna 79 3222’ 3658’ Surface 12 

1/4" 

Hanna 78 2902’ 3978’ Productio

n 

8 

3/4” 

Hanna 77 2602’ 4278’

Hanna 2 2375’ 4405’

Total 1880’ 4900’
Table 1 Continued 

Hanna Draw POD CBM Project Well Information 

Well Information 

"Well Informati on 

Cementing Pr

No 

. 

Name Number Footages Sec Tns Rng Elevation Formation Subsea Depth Dept h Casing Hole 

Depth 

12 Hanna 

Draw 

Federal 

2-23 707’FSL 

2009’FEL 

2 23N 81W 6852’ GL Hanna 79 3222’ 3658' Surface 12 

1/4” 

Hanna 78 2902’ 3978’ Productio 

n 

8 

3/4” 

Hanna 77 2602’ 4278’ 

Hanna 2 2375’ 4405’ 

Total 

Depth 

1880’ 4900’ 

13 Hanna 

Draw 

Federal 

2-24 2080’FSL 

760’FEL 

2 23N 81W 6845’ GL Hanna 79 3222’ 3618' Surface 12 

1/4” 

Hanna 78 2902’ 3938’ Productio 

n 

8 

3/4” 

Hanna 77 2602’ 4238’ 

Hanna 2 2375’ 4465’ 

Total 

Depth 

1940’ 4900’ 

14 Hanna 

Draw 

Federal 

2-25 1980’FNL 

760’FEL 

2 23N 81W 6799’ GL Hanna 79 3197’ 3593' Surface 12 

1/4” 

Hanna 78 2877’ 3913’ Productio 

n 

8 

3/4” 

Hanna 77 2577’ 4213’ 

Hanna 2 2350’ 4440’ 

Total 

Depth 

1890’ 4900’ 

15 Hanna 

Draw 

Federal 

2-11 1036’FNL 

310’ FWL 

2 23N 81W 6800’ GL Hanna 79 3197’ 3623' Surface 12 

1/4” 

Hanna 78 2877’ 3943’ Productio 

n 

8 

3/4” 
Table 1 Continued 

Hanna Draw POD CBM Project Well Information

Well Information 

"Well Information 

Cementing Pr

No

. 

Name Number Footages Sec Tns Rng Elevation Formation Subsea Depth Dept h Casing Hole 

Hanna 77 2577’ 4243’

Hanna 2 2350’ 4440’

Total 

Depth 

1900’ 4570’

16 Hanna 

Draw

Federal

2-12 296’FSL 

415’FEL

2 23N 81W 6793’ GL Hanna 79 3197’ 3663' Surface 12 

1/4” 

Hanna 78 2877’ 3983’ Productio

n 

8 

3/4” 

Hanna 77 2577’ 4283’

Hanna 2 2350’ 4510’

Total 

Depth 

2250’ 4610’
2. ESTIMATED DEPTH OF ANTICIPATED WATER, OIL, GAS OR MINERAL FORMATIONS 

Hanna Formation Methane gas 

Several coal seams may be tested for gas producing formations to total depth. All shallow water zones 

will be protected with casing and cement. Cement will be brought to surface to isolate all Mesa Verde 

formations. 

Planned Objective: Hanna Formations 

3. Minimum BOP Requirements: - refer to attached BOP schematics 

The BOPE shall be closed whenever the well is unattended. 

The BOPE shall be pressure tested when initially installed, whenever any seal subject to pressure 

testing is broken, after repairs, or every 30 days. 

4. Supplementary Information: 

The primary objective of this project is to drill, stimulate, and produce coalbed methane 

gas from the coal seams of the Mesa Verde Group Formations. 

Anadarko proposes to test the coal formations between 1,600’ and 4,800’. Stimulation of the 

perforated coal seams will be done by hydraulic fracturing. Fresh water, gelled water, and/or 

foam fracturing techniques will be used. 

The drilling operations for this well will be conducted in accordance with the Onshore Oil and 

Gas 

Order #2 as provided for in 43 CFR 3164.1. This includes the well control equipment and its 

testing, the 

mud system and associated equipment, and the casing and cementing. 

5. Casing Program: 

Hole Size Casing Size Casing Weight Grade Joint Depth Set New/Used Range 

12 1/4” 9 5/8” 40# J-55 LT& 0-550 New 3 

C 

8 3/4” 7” 23# J-55 LT& 0-TD New 3 

C 

Surface Casing: 9 5/8” 40 ppf. J-55 LTC Collapse Burst Tension

 Ratings: 2570 3950 520,000 
A. Burst = 0.052 * MW * TVD(shoe) 

= 0.052 * 10.0 ppg * 550’ 

= 286 psi 

Safety Factor = Rating/Burst 

= 3950/286 

= 13.8 

B. Collapse = [0.052 * MW * TVD(shoe)] - [Gas Gradient * TVD] 

= [.052 * 10.0 ppg * 550’] - [0.1 * 550’] 

= 231 psi 

Safety Factor = Rating/Collapse 

= 2570/231 

= 11.1 

C. Tension = Weight * TVD * [1 – (MW/65.5ppg)] 

= 40 * 550’ * [1 - 10.0/65.5] 

= 18,641 lbs. 

Safety Factor = Rating/Tension 

= 520,000/18,641 

= 27.9 

Surface casing shall have centralizers on the bottom 3 joints of the casing, starting with the shoe 

joint. 

Production Casing: 7” 23 ppf. J-55 LTC Collapse Burst Tension 

Ratings: 3270 4360 313,000 

A. Burst = 0.052 * 10ppg * 4900’

= 2,548 psi

Safety Factor = Rating/Burst

= 4360/2548

= 1.71 

B. Collapse = [0.052 * 10ppg * 4900’] – [0.1psi/ft * 4900’]

= 1,988 psi

Safety Factor = Rating/Collapse

= 3270/1988

= 1.64 

C. Tension weight = 23lbs./ft * 4900’ * [1 – (10ppg/65.5ppg)] 

= 23lbs./ft * 4900’ * .8473

= 95,490 lbs. 

Safety Factor = Rating/Tension

= 313,000/95,490

= 3.28 
6. Mud Program: 

Drilling mud will be used as the circulation medium. A fresh water, polymer, gel drilling mud will be 

used and visual monitoring will be done from spud to total depth. The anticipated mud weight will be 

between 8.5 – 10 ppg. Sufficient quantities of mud, lost circulation material and barite will be 

available at the well site at all times for the purpose of assuring well control. 

7. Cementing Program 

The following is the proposed procedure for cementing the 9 5/8” surface casing and 7” long string: 

Surface Casing: 

Lead: Type III Cement with 2% CaCl2 and .25/sk cello-flake, mixed at 14 ppg, 1.54 cuft/sk yield 

with 100% excess. 1550 psi compressive strength in 24 hours at 83o F. 

The surface casing shall be cemented back to surface. In the event cement does not circulate to 

surface or fall back of the cement column occurs, remedial cementing shall be done to cement the 

casing back to surface. 

Long String: 

Lead: 160 sacks Premium Lite Plus Cement with 1% CaCl2 and .25/sk cello-flake, mixed at 11 

ppg, 3.18 cuft/sk yield, caliper volume plus 10%. 350 psi compressive strength in 48 hours at 114o 

F. 

Tail: 170 sacks Premium Lite II High Strength Cement, mixed at 13 ppg, 1.89 cuft/sk yield, 

caliper volume plus 10%. 3700 psi compressive strength in 48 hours at 114o F. 

Volumes calculated to circulate cement from TD to surface. 

8. Logging Program 

Cores: Rotary Cores will be taken as needed to evaluate the coal seams. 

DSTs: None Planned 

Logs: Induction, GR, SP, Density, Neutron and Caliper – From surface to TD 

Cement Bond Log – From 9 5/8”casing shoe TD 

Mud Logger – As Needed. 

9. Pressure Data, Potential Hazards 

Bottom hole pressures anticipated @ 1000 – 1100 psi. 

There is no history of hydrogen sulfide gas in the area and none is anticipated.
10. ANTICIPATED STARTING DATES AND NOTIFICATION OF OPERATIONS 

A. Anticipated Starting Dates: 

Anticipated Commencement Date - Fall 2004, or upon approval 

Drilling Days - Approximately 7 Days/Per Well 

Completion Days - Approximately 2 Days/Per Well 

Testing Days - Approximately 7-14 Days/Per Well 

Note: Drilling operations will commence as soon as practical after approval of all necessary 

permits including the APDs. 

B. Notification of Operations: 

Rawlins Field Office, BLM 

1300 North Third 

Rawlins, Wyoming 82301 

(307) 328-4200 

WOGCC 

777 West First Street 

Casper, WY 82602 

(307) 234-7147 
Appendix C 

List of Permitted Wells 
Permit # 

P169546W 

Priority 

6/23/2005 

Status 

GSI 

Township 

23 

Tns Suffix 

N 

Range 

81 

Rng Suffix 

W 

Section 

2 

Qtrqtr 

SENW 

Lots Applicant 

ANADARKO PETROLEUM CORP. 

Facility Name 

HANNA DRAW FEDERAL 2-2 

Uses 

CBM 

Yld Act W

P137145W 3/26/2001 CAN 23 N 81 W 11 SWSE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 28 CBM P128226W 8/21/2000 CAN 23 N 81 W 13 SESW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #11 CBM P128227W 8/21/2000 GST 23 N 81 W 13 NWSW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #9 CBM 11 P128229W 8/21/2000 GST 23 N 81 W 13 NESW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #10 CBM 2 P128419W 8/21/2000 CAN 23 N 81 W 13 NWNW BARRETT RESOURCES CORP HANNA DRAW UNIT #16-13 CBM 4 P128228W 8/21/2000 CAN 23 N 81 W 14 SESE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #5 CBM P128230W 8/21/2000 CAN 23 N 81 W 23 NENE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #12 CBM P128231W 8/21/2000 CAN 23 N 81 W 24 NWNW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #7 CBM P128418W 8/21/2000 CAN 24 N 81 W 35 SWNW BARRETT RESOURCES CORP HANNA DRAW UNIT #14-35 CBM 1 P137141W 3/26/2001 CAN 23 N 80 W 7 SWSW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 20 CBM,RES P137144W 3/26/2001 CAN 23 N 81 W 11 NESE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 27 CBM,RES P137146W 3/26/2001 CAN 23 N 81 W 11 SESW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 29 CBM,RES P137160W 6/22/2001 CAN 23 N 81 W 11 SWNE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #36 CBM,RES P137161W 6/22/2001 CAN 23 N 81 W 11 SWSW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #30 CBM,RES P137164W 6/22/2001 CAN 23 N 81 W 11 NENE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #37 CBM,RES P137165W 6/22/2001 CAN 23 N 81 W 11 NENW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #39 CBM,RES P137153W 3/26/2001 CAN 23 N 81 W 12 SWSE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 24 CBM,RES P137154W 3/26/2001 CAN 23 N 81 W 12 NESW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 25 CBM,RES P137155W 3/26/2001 CAN 23 N 81 W 12 SWSW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 26 CBM,RES P137159W 6/22/2001 CAN 23 N 81 W 12 NENW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #87 CBM,RES P137162W 6/22/2001 CAN 23 N 81 W 12 SWNE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #88 CBM,RES P137163W 6/22/2001 CAN 23 N 81 W 12 SWNW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #86 CBM,RES P137142W 3/26/2001 GST 23 N 81 W 13 NENE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 21 CBM,RES 2 P137143W 3/26/2001 GST 23 N 81 W 13 SWNE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 22 CBM,RES 7 P137156W 3/26/2001 CAN 23 N 81 W 14 NENE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 31 CBM,RES P137157W 3/26/2001 CAN 23 N 81 W 14 SWNE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 32 CBM,RES P137158W 3/26/2001 CAN 23 N 81 W 14 NENW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 33 CBM,RES P137152W 3/26/2001 CAN 24 N 81 W 33 SWSE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 46 CBM,RES P137147W 3/26/2001 CAN 24 N 81 W 35 SESW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 41 CBM,RES P137148W 3/26/2001 CAN 24 N 81 W 35 SESE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 42 CBM,RES P137149W 3/26/2001 CAN 24 N 81 W 35 NWSE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 44 CBM,RES P137150W 3/26/2001 CAN 24 N 81 W 35 SENE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 45 CBM,RES P137151W 3/26/2001 CAN 24 N 81 W 35 NWNE WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT # 43 CBM,RES P119325W 9/27/1999 GST 23 N 81 W 13 SWSW WILLIAMS PRODUCTION RMT, COMPANY Hanna Draw Unit 31 CBM,STO 8 P130596W 9/8/2000 GST 23 N 81 W 13 NENW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #18 CBM,STO 2 P130597W 9/8/2000 GST 23 N 81 W 13 SENW WILLIAMS PRODUCTION RMT, COMPANY HANNA DRAW UNIT #19 CBM,STO 7 P52030W 1/30/1980 ABA 23 N 81 W 17 NWNW ARCH MINERAL CORPORATION S2 79 DEW,RES,MIS 150 P108935W 10/1/1997 UNA 23 N 80 W 18 SESE USDI, BLM** HI ALLEN RANCH DIXIE DRAW WELL #1 MIS 15 

P43960W 6/16/1978 CAN 23 N 81 W 8 SWSE ARCH MINERAL CORP. S2-81 MIS 

P59441W 10/26/1981 CAN 23 N 81 W 10 SWSE ARCH MINERAL CORP.**USDI, BLM 9853 MIS P59440W 10/26/1981 CAN 23 N 81 W 14 NESE ARCH MINERAL CORP.**USDI, BLM 9852 MIS P44546W 8/7/1978 23 N 81 W 16 SWSW CARBON COUNTY COAL COMPANY P-4 MIS 0 P69193W 9/4/1984 23 N 81 W 16 NWSW 

WY BOARD OF LAND COMMISSIONERS** ARCH MINERAL CORP. PIT 79 MIS 650 

P44543W 8/7/1978 UNA 23 N 81 W 21 NWNE RAG SHOSHONE COAL CORPORATION P-1 MIS 0 P44544W 8/7/1978 UNA 23 N 81 W 21 NWNE RAG SHOSHONE COAL CORPORATION P-2 MIS 0 P44545W 8/7/1978 23 N 81 W 21 NWNE CARBON COUNTY COAL COMPANY P-3 MIS 0 P66273W 12/22/1983 CAN 23 N 81 W 22 SWSE ROSEBUD COAL SALES COMPANY**USDI, BLM OPEN PIT #10 MIS P37151W 11/1/1976 GST 23 N 81 W 9 NWSW ARCH MINERAL CORP. S2W-3 MON 0 P37152W 11/1/1976 GST 23 N 81 W 9 NWSW ARCH MINERAL CORP. S2W-4 MON 0 P37153W 11/1/1976 GST 23 N 81 W 9 NESW ARCH MINERAL CORP. S2W-5 MON 0 P156289W 2/13/2004 GST 23 N 81 W 12 SENE 

USDI, BUREAU OF LAND MANAGEMENT** THE SHIPLEY GROUP PL-12 MON 0 

P75768W 10/26/1987 GST 23 N 81 W 16 SWNW ARCH OF WYOMING INC. S2 1679D MON 0 P59645W 3/4/1982 GST 23 N 81 W 17 SESW ARCH MINERAL SEMINOE #1 S2W-20 MON 0 P59646W 3/4/1982 GST 23 N 81 W 17 NESW ARCH MINERAL SEMINOE #1 S2W-21 MON 0 P59647W 3/4/1982 GST 23 N 81 W 17 NESW ARCH MINERAL SEMINOE #1 S2W-22 MON 0 P59648W 3/4/1982 GST 23 N 81 W 17 SWSE ARCH MINERAL SEMINOE #1 S2W-23 MON 0 P73273W 9/3/1986 GST 23 N 81 W 17 NWNW ARCH OF WYOMING INC. 17 79 A MON 0 P75997W 11/23/1987 GST 23 N 81 W 17 NENW ARCH OF WYOMING INC. S2 1779B MON 0 P37037W 3/23/1977 GST 23 N 81 W 21 SENW PETER KIEWIT SONS CO. HANNA #9003 MON 0 P37038W 3/23/1977 GST 23 N 81 W 21 NESW PETER KIEWIT SONS CO. HANNA #9004 MON 0 P55288W 1/6/1981 GST 23 N 81 W 22 NESW ROSEBUD COAL SALES COMPANY WW9019 MON 0 P55289W 1/6/1981 GST 23 N 81 W 22 NESW ROSEBUD COAL SALES COMPANY WW9018 MON 0 P55290W 1/6/1981 GST 23 N 81 W 22 SESE ROSEBUD COAL SALES COMPANY WW9017 MON 0 P55291W 1/6/1981 GST 23 N 81 W 22 SESE ROSEBUD COAL SALES COMPANY WW9016 MON 0 P62558W 11/18/1982 GST 23 N 81 W 22 SENW ROSEBUD COAL SALES CO. R-9018A MON 0 P94258W 12/16/1993 GST 23 N 81 W 22 SESE RAG SHOSHONE COAL CORPORATION TG-3 MON 0 P94261W 12/16/1993 GST 23 N 81 W 22 SESE RAG SHOSHONE COAL CORPORATION TS-1 MON 0 P106061W 5/23/1997 GST 23 N 81 W 23 SENE RAG SHOSHONE COAL CORPORATION BS-1-SS MON 0 P106062W 5/23/1997 GST 23 N 81 W 23 SENE RAG SHOSHONE COAL CORPORATION BS-1-U1 MON 0 P106063W 5/23/1997 GST 23 N 81 W 23 SENE RAG SHOSHONE COAL CORPORATION BS-1-80 MON 0 P106064W 5/23/1997 GST 23 N 81 W 23 SENE RAG SHOSHONE COAL CORPORATION BS-1-80B MON 0 P107331W 8/29/1997 GST 23 N 81 W 23 NWSW RAG SHOSHONE COAL CORPORATION BS-2-SS MON 0 P107332W 8/29/1997 GST 23 N 81 W 23 NWSW RAG SHOSHONE COAL CORPORATION BS-2-80 MON 0 P107333W 8/29/1997 GST 23 N 81 W 23 NWSW RAG SHOSHONE COAL CORPORATION BS-2-U1 MON 0 P94257W 12/16/1993 GST 23 N 81 W 23 SWSW RAG SHOSHONE COAL CORPORATION TG-2 MON 0 P37149W 11/1/1976 GST 24 N 81 W 33 SWNE ARCH MINERAL CORP. S2W-1 MON 0 P37150W 11/1/1976 GST 24 N 81 W 35 NESE ARCH MINERAL CORP. S2W-2 MON 0 P52028W 1/30/1980 CAN 23 N 81 W 8 SWSE ARCH MINERAL CORPORATION S2 81 RES,MIS P61634W 4/9/1982 CAN 23 N 81 W 17 NWNW ARCH MINERAL CORP. S2SR RES,MIS P83080W 7/27/1990 GST 23 N 80 W 17 NENW BURT PALM CHACE #1 STO 5 P83081W 7/27/1990 GST 23 N 80 W 17 NENW BURT PALM CHACE #2 STO 5 P108933W 10/1/1997 GST 23 N 80 W 20 NENW USDI, BLM** HI ALLEN RANCH MISSOURI JOHN WELL #1 STO 15 P108934W 10/1/1997 GST 23 N 80 W 20 NENW USDI, BLM** HI ALLEN RANCH MISSOURI JOHN WELL #2 STO 10 P11207W 12/1/1971 GST 24 N 81 W 26 SESE ROBERT J. KORKOW KORKOW #2 STO 10 P17385W 12/27/1972 GST 24 N 81 W 34 NWNE U.S.A./BUREAU OF LAND MANAGEMENT MEDICINE BOW (INDEX #4266) STO 8 

P3817W 12/18/1969 GST 24 N 81 W 34 NWNE ROBERT J. KORKOW KORKOW #1 STO 8 

P43959W 6/16/1978 CAN 23 N 81 W 17 NENW ARCH MINERAL CORP. MIS