MONITORING APPENDIX

MONITORING APPENDIX

MON-1 

MONITORING APPENDIX

Introduction

For each resource, a series of items will be 

monitored. Each item is evaluated by location, 

technique for data gathering, unit of measure, and 

frequency and duration of data gathering. When a 

duration is not specified, the duration is for the next 

20 years. The monitoring plan states the event that 

will be evaluated and lists the key resources that will 

be monitored. If an adverse impact can be corrected 

by a management action within the scope of this plan, 

the change will be implemented. If the adverse impact 

can be corrected only by a management action that is 

outside the scope of this plan the Billings or Powder 

River Resource Management Plans (RMPs), the 

management change will be a formal amendment. 

Under the phased development alternatives addressed 

in this SEIS resource based screens are used to phase 

development. The screens applicable to the preferred 

alternative (H) are described in detail in this section.

The Department of Natural Resources and 

Conservation (DNRC) Technical Advisory 

Committee (TAC) for the Powder River Basin 

Controlled Groundwater Area has proposed a 

groundwater monitoring plan for coal bed natural gas

(CBNG) development. The monitoring 

recommendations are incorporated into the 

monitoring table. A complete copy of that plan is at 

the end of this appendix. Much of this plan has been 

adopted and put in place (see reports at 

http://www.mt.blm.gov/mcfo/cbng/CBNGMonitoring.htm). 

The Bureau of Land Management (BLM), Fish and 

Wildlife Service (FWS), and the State of Montana 

(state) have developed a wildlife monitoring and 

protection plan. It is located as an attachment to the 

Wildlife Appendix.
MONITORING APPENDIX

MON-2

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

AIR QUALITY Gaseous and 

particulate critical 

air pollutants

area-wide air quality modeling and 

ambient air samples

μg/m3 and parts per 

million 

concentrations as 

(μg/m3

) 

hourly to 24 hr 

samples as per 

standards 

predicted or measured 

exceedances of NAAQS 

and/or PSD increments 

by MDEQ

implement additional 

emission controls or 

operating limits

Gaseous and 

particulate critical 

air pollutants

Birney/Ashland area ambient air samples μg/m3 and parts per 

million 

concentrations as 

(μg/m3

) 

hourly to 24 hr 

samples as per 

standards 

before expanded 

development activity

implement additional 

emission controls or 

operating limits

Gaseous and 

particulate critical 

air pollutants

area-wide emission inventory lbs/hr and tons/yr annually continuous require submittal of 

annual reports

 Cumulative 

compressor 

horsepower 

area-wide tracking horsepower continuous when horsepower 

requirements for CBNG 

wells in the Montana 

portion of the PRB 

exceed 133,956 

subsequent visibility 

modeling; if it indicates 

unacceptable impacts 

would occur at a future 

point in the PRB 

development, the 

modeling work would 

include mitigation 

scenarios 

CLIMATE areas affected by land 

disturbance

RAWS or COOP Stations bulk precipitation daily during the 

growing season

extremes affecting 

revegetation operations

CULTURAL 

RESOURCES

Area of Critical 

Environmental 

Concern (ACECs)

area-wide site inspection site, surrounding 

area

annually any noticeable trend 

indicating increased 

disturbance—natural or 

human-caused

increase frequency of 

monitoring to ensure 

ACEC values are not 

being impaired

20% of National 

Register eligible 

sites

CBNG emphasis area site inspection site, surrounding 

area

annually impacts to sites from 

unauthorized uses 

affecting qualities that 

make sites eligible for 

listing on National 

Register of Historic 

Places

halt activity affecting 

eligible sites. Increase 

monitoring of nearby 

eligible sites. Evaluate 

damage to sites.

random sample of 

50 sites

CBNG emphasis area site inspection site, surrounding 

area

annually any noticeable trend 

indicating increased 

disturbance—natural or 

human-caused

increase frequency and 

number of sites 

monitored, if sites are 

being impacted by 

CBNG-related activities.

Evaluate damage to 

sites.
MONITORING APPENDIX

MON-3

MONITORING APPENDIX

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

HYDROLOGY surface water 

quality and 

quantity

Regionally at the 

monitoring stations 

identified by the IWG

(see 2005 report later 

in this appendix).

Note that the 10% of 

7Q10 criteria for 

untreated water will 

apply unless stations 

upstream and 

downstream from 

proposed outfalls are 

monitored 

as determined by the IWG as determined by 

the IWG

as determined by 

the IWG

exceedance of any 

parameter above the 

state of MT surface 

water quality standards, 

or the identified BLM 

thresholds 

report exceedances to 

MDEQ, who will 

determine cause, and 

take appropriate actions 

If monitoring indicates 

that BLM thresholds 

have been met or 

exceeded untreated 

discharge of CBNG 

water from federal well 

will no longer be 

allowed upstream from 

that station. Previous 

approvals may be 

modified. 

groundwater 

drawdown 

regionally at locations

determined by the 

IWG (see TAC report 

later in this appendix)

monitoring wells would be 

finished in bedrock units; 

especially coal seams 

expected to be developed for 

CBNG. 

depth to water 

reported in 

hundredths of feet

depth to water 

measurements will 

be made 

approximately 

monthly to establish 

an initial baseline. 

Measurements will 

be made 

approximately 

quarterly thereafter, 

unless a greater 

frequency is 

determined to be 

necessary. 

Monitoring will 

continue until at 

least 80% recovery 

of static water level 

has been achieved

a 20-foot decrease in 

static water level from 

seasonally adjusted 

mean static water level 

(determined from 

baseline data)

if falling water levels 

are determined to be 

caused by CBNG 

activity, operators must 

offer water well 

mitigation agreements 

to all landowners with 

water sources in the 

defined drawdown area 

(20 feet or greater 

drawdown) of their 

development. 

Hydrologic barriers, 

such as injection wells, 

may be an option in 

some cases to prevent 

drainage of Native 

American gas and water 

resources.
MONITORING APPENDIX

MON-4

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

HYDROLOGY 

(con’t)

groundwater 

quality and 

quantity

alluvial groundwater 

would be monitored 

in stream valleys 

topographically down 

gradient from CBNG 

surface discharge 

points 

Since discharge to 

ephemeral streams 

would not be 

allowed, these wells 

would be along larger 

streams.

monitoring wells would be 

finished in the alluvium. 

Depth to water 

measurements and water 

quality parameters, 

including but not limited to 

pH, EC, water temperature, 

common ions (Na, Mg, Ca, 

K, HCO

3, CI, SO4), and 

would be obtained.

standard 

quantitative 

measurements of 

water quality and 

static water level 

(mg/l, °C, μS/cm, 

and hundredths of 

feet)

depth to water 

measurements will 

be made 

approximately 

monthly to establish 

an initial baseline. 

Depth to water will 

then be collected 

approximately 

quarterly thereafter. 

Water quality 

samples will be 

taken approximately 

annually, unless 

more frequent 

monitoring is 

needed. Monitoring

will continue until 

at least 80% 

recovery of static 

water level has been 

achieved

A change in 

groundwater chemistry 

that affects its class of 

use 

Rise in static 

groundwater levels of 5-

feet or more that may 

cause impacts at the 

ground surface

if impacts are 

determined to result 

from CBNG 

development, direct 

discharge of CBNG 

water into waterways in 

the watershed may be 

discontinued until 

modified Water 

Management Plans 

(WMPs) are submitted 

and approved

groundwater 

quality and 

quantity

operators will install 

monitoring wells 

adjacent to 

impoundments 

a monitoring well will be 

installed within the first 

permeable unit and within 

the first groundwater 

encountered, up to 50 feet 

total depth, to determine 

effectiveness of infiltration 

or if evaporation basins are 

leaking

a water quality sample of the 

first groundwater (if 

encountered) will be 

collected to determine class 

of use.

depth to water (feet 

to water reported in 

hundredths of feet). 

Water quality 

samples will be 

collected if rises in 

groundwater are 

observed or if water 

is observed in a 

previously dry zone.

wells will be gauged 

monthly for the first 

year and quarterly 

thereafter unless a 

rise is observed. If a 

rise is observed 

monitoring will be 

monthly. Water 

quality samples will 

be collected 

whenever the water 

level is above 

baseline. 

Monitoring will 

continue at least 

until the end of 

CBNG water 

discharge into the 

impoundment 

a rise of 1-foot or more 

in static water levels 

above seasonally 

adjusted mean water 

levels (determined from 

the first year of data) or 

a change in the class of 

use in the groundwater

Any change in class of 

use will be reported to 

MDEQ. Operators may 

be required to install 

additional monitoring 

wells further 

downgradient, or 

discharge into 

impoundments may be 

required to cease until a 

revised WMP is 

submitted and approved
MONITORING APPENDIX

MON-5

MONITORING APPENDIX

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

HYDROLOGY 

(con’t)

springs a network of springs 

which are determined 

to be fed by the 

regional flow system 

will be identified 

along coal outcrops 

in the CBNG 

development area

spring discharge and water 

quality parameters, 

including but not limited to 

pH, EC, water temperature, 

common ions (Na, Mg, Ca, 

K, HCO

3, CI, SO4), will be 

determined from existing 

springs 

discharge (cfs), pH, 

EC (μS/cm), and 

water temperature 

(°C) will be 

determined in the 

field. Standard 

quantitative 

measurements of 

water quality also 

will be used (mg/l)

Field measurement 

of discharge, pH, 

EC, and water 

temperature will be 

determined 

approximately 

quarterly. An initial 

water quality 

sample will be 

collected; additional 

samples will be 

analyzed if 

substantial changes 

in the field 

parameters are 

observed. 

a 50% decrease in 

spring discharge below 

seasonally adjusted 

mean (determined in the 

first 3 years), or a 

significant change in 

water quality that affects 

its beneficial use

if decreased spring 

discharges or water 

quality are determined 

to result from CBNG 

activity, operators must 

offer spring mitigation 

agreements to 

landowners who use the 

spring. If impacted 

spring is identified as 

important wildlife 

habitat, adaptive 

management practices 

will be used at the 

landscape level to 

improve spring 

ecosystems. Hydrologic 

barriers, such as 

injection wells, may be 

an option in some cases 

to prevent drainage of 

Native American gas 

and water resources.

INDIAN TRUST groundwater adjacent to the 

Northern Cheyenne 

and Crow 

reservations

sampling of dedicated 

monitoring wells in the 

zones of extraction and 

zones above and below the 

expected activity—wells are 

to be placed in the affected 

areas to areas unaffected by 

management activities

standard 

quantitative 

measurements of 

water quality—

measurement of 

depth in feet

field measurements 

6 times yearly prior 

to production 

activities, continue 

throughout the 

activity period and 

for the duration of 

95% of the recovery 

of pre-development 

conditions

where site-specific

studies show a potential 

to affect Reservation 

groundwater, the Tribe 

would be consulted as to 

appropriate protection 

measures and if 

continuous monitoring 

shows a drawdown of 

groundwater that is 

attributed to CBNG 

production 

BLM would require the 

operators to modify 

federal CBNG 

production. Mitigation 

options include reducing 

production rates, 

shutting in the well or 

wells, establishing a 

hydrologic barrier, or 

providing compensation 

to the affected Tribe.

INDIAN TRUST 

(con’t)

monitoring wells will be 

established near the mouth 

of streams that contain 

alluvium

measurements of 

depth in feet

water level 

measurements will 

be taken monthly 

prior to production 

activity and during 

the development - 

water quality 

measurements will 

be taken 4 times per 

year

a 20% rise in the water 

table above its 

seasonally adjusted 

elevation, or a 2 unit 

increase in the SAR 

value

Discontinuance of 

CBNG evaporative 

ponds in that watershed, 

or require ponds to be 

lined
MONITORING APPENDIX

MON-6

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

natural gas area-wide drainage evaluation radius of drainage as needed gas drainage a communitization 

agreement, requiring 

operators to reduce 

production rates, shut-in 

wells, change spacing, 

or establish a hydrologic 

barrier to protect the 

Indian minerals from 

drainage 

LANDS AND 

REALTY

rights-of-way area-widesite inspection right-of-way minimum of once 

during or for 

construction within 

2 years of issuance 

for MLA reviews 

and within 5 years 

of issuance for 

FLPMA reviews; 

then in the 20th year 

after issuance and 

every 10 years 

thereafter

nonuse of right-of-way 

or violation of right-ofway grant stipulations

require compliance with 

right-of-way grant 

stipulations with 

possible suspension 

and/or termination for 

noncompliance or 

nonuse 

MINERALS

Oil and Gas

Geophysical 

Notice of Intent 

(NOI)

area-wide line or area inspection operations 

conducted in 

compliance with 

NOI

minimum of once 

during operations

violation of regulations, 

change from approved 

Notice of Intent, 

unnecessary or undue 

degradation

require operator to 

follow NOI

Geophysical 

Notice of 

Completion 

(NOC) 

area-wide line or area inspection operations 

conducted in 

compliance with 

NOC

minimum of once 

during plugging, 

once after 

reclamation

violation of regulations, 

change from approved 

NOC unnecessary or 

undue degradation

require operator to 

correct violation

MINERALS

Oil and Gas 

(con’t)

Application for 

Permit to Drill 

(APD)

area-wide site inspection operations 

conducted in 

compliance with 

Application for 

Permit to Drill

minimum of once 

and as necessary

violation of regulations, 

change from approved 

Application for Permit 

to Drill

issue an incidence of 

noncompliance (INC) 

with timeframe to 

correct or shut-in 

drilling operations

Sundry Notice area-wide site inspection operations 

conducted in 

compliance with 

Sundry Notice

as necessary violation of regulations, 

change from approved 

Sundry Notice 

unnecessary or undue 

degradation

issue an INC with 

timeframe to correct
MONITORING APPENDIX

MON-7

MONITORING APPENDIX

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

natural gas area-wide drainage evaluation radius of drainage as needed if gas drainage is 

occurring, there would 

be a communitization 

agreement, drilling of 

protective wells on 

federal lands, or 

different spacing, to 

protect the federal 

minerals from drainage

certified letter to lessee 

requiring protection, 

compensation royalty, 

relinquishment 

produced water 

disposal 

area-wide site inspection operations 

conducted in 

compliance with 

permit 

minimum of once 

annually or as 

necessary

violation of regulations, 

change from approved 

permit, unnecessary or 

undue degradation

issue an INC with 

timeframe to correct or 

shut-in operations

spill area-wide site inspection area cleaned up, 

reclaimed

minimum of once 

after event and as 

necessary

violation of regulations, 

change from approved 

permit, unnecessary or 

undue degradation

issue an INC and 

operator cleanup 

required 

plugged, 

abandoned wells

area-wide site inspection operations 

conducted in 

compliance with 

permit 

minimum of once 

during operations

violation of regulations, 

change from approved 

permit, unnecessary or 

undue degradation

issue an INC correction 

required 

abandoned well 

reclamation

area-wide site inspection operations 

conducted in 

compliance with 

permit 

minimum of once 

and as necessary 

until reclamation 

complete

violation of regulations, 

change from approved 

permit, unnecessary or 

undue degradation

issue an INC/certified 

letter requiring proper 

operator rehabilitation

PALEONTOLOGY significant 

paleontological 

localities, ACECs

area-wide inspection of area disturbed degradation caused 

by human or natural 

activities that lead 

to loss of significant 

fossil resources

once yearly loss or damage to 

significant fossil 

resources

closure of areas 

surrounding site to 

prevent further 

disturbance to 

significant fossil 

resources

RECREATION general recreation 

use

area-wide with 

emphasis on 

dispersed use of 

undeveloped 

recreation sites

area inspections to look for 

vandalism, resource abuse, 

and install photo points

site condition biannual (June and 

October); 

photograph annually

user conflicts, resource 

degradation, or safety 

hazards

avoid location of oil and 

gas facilities in 

undeveloped recreation 

sites having concentrated 

use, and coordinate 

timing of exploration 

activities to minimize 

conflicts during peak 

periods of use
MONITORING APPENDIX

MON-8

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

concentrated 

recreation use

special recreation 

management areas, 

sites with recreation 

facilities

visitor registration, traffic 

counters estimates, photo 

points

visitor days, site 

condition

visitor registration 

boxes, counters 

checked once 

monthly at the 

minimum, weekly 

or biweekly during 

heavy use periods, 

photograph annually

increased visitor use per 

year or sustained use 

that requires additional 

or improved facilities

avoid location of oil and 

gas facilities in 

developed recreation 

sites having 

concentrated use, and 

coordinate timing of 

exploration activities to 

minimize conflicts 

during periods of use

area-wide 

commercial, 

competitive activities

administrative review, site 

inspection for complexes 

with permit stipulations

permit stipulations, 

resource condition 

success of 

reclamation

on site during 

competitive events, 

periodic site 

inspection for 

commercial 

operations, 

administrative review annually

irreparable resource 

damage, compromise of 

visitor safety, recreation 

experience

avoid location of oil and 

gas facilities in areas 

where know 

commercially permitted 

recreation activities are 

occurring and 

coordinate timing of 

exploration activities to 

minimize conflicts 

during peak periods of 

use 
MONITORING APPENDIX

MON-9

MONITORING APPENDIX

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

SOILS soil erosion, 

uplands 

area-wide where 

management 

activities are 

occurring or expected 

to occur

visual observation and 

surveyed erosion pins

soil loss in tons per 

acre

site will be visually 

examined quarterly. 

Where erosion is 

deemed excessive, 

measurements of 

site characteristics 

will be taken to 

determine rate of 

soil loss.

visual evidence of rill, 

gully, or sheet erosion. 

Loss of soil exceeding 

10 tons per acre

report exceedance to 

BLM, MDEQ, or EPA. 

If caused by CBNG 

discharge or activities, 

enforcement action will 

be taken.

soil erosion, 

streambank, and 

floodplain 

area-wide along 

rivers and tributaries 

where management 

activities are 

occurring or expected 

to occur

visual observation and 

surveyed erosion pins

area effected in 

square feet or acres

site will be visually 

examined quarterly. 

Where streambank 

erosion is deemed 

excessive, 

measurements of 

site characteristics 

will be taken to 

determine soil loss.

a 10% increase in 

streambank loss

report exceedance to 

BLM, MDEQ, or EPA. 

If caused by CBNG 

discharge or activities, 

enforcement action will 

be taken.

soil salinization area-wide where 

management 

activities are 

occurring or expected 

to occur

visual observation, 

measurement of soil 

characteristics such as pH, 

EC, SAR

area effected in 

square feet or acres

site will be visually 

examined quarterly. 

Where salinity 

levels show an 

increase because of 

vegetation or soil 

effects, 

measurements of 

site characteristics 

will be taken to 

determine salinity 

levels.

a 20% increase in 

conductivity levels

report exceedance to 

BLM, MDEQ, or EPA. 

If caused by CBNG 

discharge or activities, 

enforcement action will 

be taken.

compaction areas effected by 

extraction activities

penetrometer or visual 

inspection

pounds per square 

inch

1 to 2 times yearly 10% increase in density limit or block access to 

compacted sites
MONITORING APPENDIX

MON-10

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

VEGETATION

ecological status areas affected by 

disturbance through 

the pre-production, 

production, post-

production processes

ecological site method in key

areas

composition, 

production 

compared to 

potential natural 

community for each 

site

pre-development 

ecological status 

baseline data

status is reduced by 

15% or a drop in class

ecological site integrity 

will be altered to 

increase status of ecological site index by 

15% or an increase in 

ecological class

trend areas affected by 

disturbance through 

the pre-production, 

production, post-

production processes

any suitable methods as 

described in TR 4400-4 or 

the National Range 

Handbook 

apply to the 

technique selected, 

may include 

number of 

individuals per unit 

area, percent cover, 

percent frequency, 

or percent species 

composition

every 3 to 5 years 

after the collection 

of ecological status 

baseline data

a change in the direction 

of trend away from 

management

measure implementation 

of action put forth to 

mitigate reduction of 

ecological status using 

techniques listed in 

monitoring appendix for 

vegetative trend

Noxious Weeds trend areas affected by 

disturbance through 

the pre-production, 

production, post-

production processes

Montana Noxious Weed 

Standards 

acres, plants per 

square feet, species

yearly (through post 

production 

reclamation)

10% increase beyond 

objectives for the 

area/new species 

occurrence or 

infestation

operators will be 

required to contain and 

suppress noxious weeds.

Conservation measures 

will be required in 

noxious weed sites to 

decrease population of 

noxious weeds and 

increase population of 

native plant community

Riparian/

Wetlands

condition, trend, 

age class structure, 

streambank 

alteration

any federal action 

(including split 

estate)

photo plot, estimate key 

areas by sight inspection, 

Cole Browse Method, Key 

Forage Method, other 

methods found in Technical 

References (TR4400-3, 

TR4400-4, TR4400-7, 

TR1737-3, TR1737-8, 

TR1737-9) including 

MRWA (Montana Riparian 

Wetland Association) 

Riparian Inventory for areas 

not previously inventoried 

MRWA PFC on inventory 

areas

percent species 

composition, 

percent in each age 

class, percent 

utilization, height, 

percent of the 

streambank

based on activity 

plan schedule- a 

minimum of once 

every 5 years

trend away from 

objective or when no 

improvement occurs, in 

unsatisfactory habitat 

condition/functioning at 

risk with downward 

trend 

oil and gas operators 

will be required to alter 

activities in order to provide environmental 

factors for increasing 

functionality or habitat 

conditions of the 

streams/wetlands. Oil 

and gas operators may 

be required to develop 

replacement wetlands in 

order to compensate for 

overall loss of wetlands 

according to Section 

404 of Clean Water Act.
MONITORING APPENDIX

MON-11

MONITORING APPENDIX

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

Special Status and 

Threatened and 

Endangered (T&E) 

Plant Species

condition areas affected by 

disturbance through 

the pre-production, 

production, postproduction processes

Montana Natural Heritage 

Program and visual 

inspection

presence and 

condition

once during the 

growing season, at a 

minimum

downward trend in plant 

condition caused by oil 

and gas activities

oil and gas operators 

will be required to alter 

their activities in order 

to benefit environmental 

factors required by 

special status or T&E 

plant species

WILDLIFE (see also “Wildlife Appendix for the Programmatic Wildlife Monitoring and Protection Plan)

Aquatic Biological 

Diversity 

(flora/fauna)

population 

diversity

intermittent/perennial 

streams associated 

with produced water 

discharge

stream sampling diversity index every 3 years downward trend overall 

stream biological 

diversity

reduction or elimination 

of untreated produced 

water into drainage or 

watershed

Big Game seasonal habitat 

use 

project area plus 1-

mile buffer

air/ground field inspection occupancy annually downward trend in 

habitat occupancy

extension of timing 

stipulations or 

conditions of approval, 

off-site habitat 

management or 

enhancement

Black-footed Ferret occupancy prairie dog towns 

larger than 80 acres 

located within 0.5 

mile of proposed 

activity

ground inspection occupancy determined on a 

site-specific basis in 

coordination with 

U.S. Fish and 

Wildlife Service 

(FWS)

habitat decline or prairie 

dog fatalities caused by 

oil and gas activities - 

occupancy of blackfooted ferrets would be 

managed in a BlackFooted Ferret 

Management Plan

no incidental take; 

reinitiate consultation if 

new information shows 

it may be effected

Burrowing Owl active nest 

locations

specific project area 

plus 0.5-mile buffer 

(within active prairie 

dog town)

ground inspection occupancy twice yearly (June 

to August)

human-caused 

disturbance to owls 

related to oil and gas 

activities such as 

vandalism and 

harassment

extension of timing 

and/or increase of 

distance from nest; 

stipulations or 

conditions of approval

Grey Wolf occupancy Billings RMP area air/ground field surveys number of sitings annually until 

reintroduction 

objectives are met

1- to 3-year downward 

trend in production or 

occupancy

no incidental take; 

reinitiate consultation if 

new information shows 

it may be effected
MONITORING APPENDIX

MON-12

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

Migratory Nongame Birds

occupancy project area plus 

0.25-mile buffer

ground observations occupancy periodically documented fatalities 

caused by oil and gas 

activities

refinements in 

infrastructure planning 

(project plans), 

implementation of travel 

corridors, enhanced 

reclamation standards, 

and off-site habitat 

management or 

enhancement

Mountain Plover active nest 

locations

specific project area 

plus 0.5-mile buffer 

(within areas less 

than 4-inch average 

vegetation height and

prairie dog towns)

ground inspection occupancy twice yearly (April 

15 to June 30)

human-caused 

disturbance to mountain 

plovers related to oil and 

gas activities such as 

vandalism and 

harassment

BLM received an 

exemption from the 

prohibitions of Section 9

of ESA regarding take 

by agreeing to terms and 

conditions in biological 

opinion (BO). Incidental 

take of habitat and 

individuals allowed up 

to level stated in BO. 

Take must be 

monitored. Reinitiation 

of Section 7 will occur 

before allowable take is 

exceeded. 

Prairie Dog active prairie dog 

colony

specific project area 

plus 0.5-mile buffer

air/ground inspection occupancy annually documented prairie dog 

fatalities caused by oil 

and gas activities

establishment of no 

surface occupancy 

zones and/or 

establishment of timing 

restrictions within 

prairie dog towns

Raptors active nest 

locations 

(excluding 

burrowing owls)

project area plus 1-

mile buffer

air/ground field inspection number of nests every 3 years downward trend in 

occupancy

extension of timing 

and/or increase in 

distance from nest; 

stipulations or 

conditions of approval
MONITORING APPENDIX

MON-13

MONITORING APPENDIX

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

WILDLIFE

Raptors

(con’t)

raptor productivity 

(including 

Burrowing owl)

active nests within 1-

mile of project 

disturbance plus 1-

mile buffer

air/ground field inspection nest success/failure 

species productivity

annually downward trend in nest 

success, overall 

productivity

extension of timing 

and/or increase in 

distance from nest; 

stipulations or 

conditions of approval

raptor 

productivityselected 

undeveloped 

comparison area

project area air/ground field inspection nest success/failure 

species productivity

every 5 years information used as 

support to determine 

downward trend

extension of timing 

and/or increase in 

distance from nest; 

stipulations or 

conditions of approval

Sage Grouse sage grouse 

lek location

CBNG overall 

project area

aerial field inspection number, location of 

leks

every 5 years downward trend in 

habitat occupancy

extension of timing 

and/or increase in 

distance from lek; 

stipulations or 

conditions of approval; 

off-site habitat 

management/mitigation

sage grouse

lek attendance

specific project 

development areas 

plus 2-mile buffer

air/ground field inspection number of 

males/lek

annually downward trend in lek 

attendance

extension of timing 

and/or increase in 

distance from lek; 

stipulations or 

conditions of approval; 

off-site habitat 

management/mitigation

sage grouse 

winter habitat

project area plus 2 

mi. buffer

air/ground field inspection occupancy annually downward trend in 

habitat occupancy or 

quality caused by oil 

and gas activities

extension of timing 

and/or increase in 

distance from lek; 

stipulations or 

conditions of approval; 

off-site habitat 

management/mitigation
MONITORING APPENDIX

MON-14

TABLE MON - 1 

Element Item Location Technique

Unit of 

Measure

Frequency and 

Duration

Remedial Action 

Trigger

Management 

Options

Special Status 

Species (BLM and 

Montana Natural 

Heritage Program 

lists)

occupancy specific project area 

plus 1-mile buffer

ground field inspection occupancy annually at a 

minimum via 

species habitat 

requirements 

downward trend in 

habitat occupancy or 

quality caused by oil 

and gas activities

establishment of timing 

and/or distance from 

breeding area through stipulations or 

conditions or approval

Threatened, 

Endangered and 

Proposed Species 

other than 

previously 

described

occupancy, 

productivity

CBNG overall 

project area

air/ground field inspection occupancy determined on a 

site-specific basis in 

coordination with 

FWS

habitat decline or 

fatalities caused by oil 

and gas activities; 

occupancy of species 

would be managed in a 

site-specific 

Management Plan

reinitiate section and 

consultation with FWS
MONITORING APPENDIX

Regional Surface Water Monitoring Network

MON-15 
MONITORING APPENDIX

Regional Surface Water Monitoring Network

MON-16
MONITORING APPENDIX

Regional Surface Water Monitoring Network

MON-17 
MONITORING APPENDIX

Regional Surface Water Monitoring Network

MON-18
MONITORING APPENDIX

Regional Surface Water Monitoring Network

MON-19 
MONITORING APPENDIX

Regional Surface Water Monitoring Network

MON-20
MONITORING APPENDIX

Regional Surface Water Monitoring Network

MON-21 
MONITORING APPENDIX

Effects of CBNG Development on Water Resources

MON-22

REGIONAL-SCALE MONITORING OF POTENTIAL EFFECTS 

OF COAL BED METHANE DEVELOPMENT ON WATER

RESOURCES

Prepared by the Technical Advisory Committee for the Powder River Basin Controlled Groundwater Area

Introduction

Coal bed methane (CBM) is released from coal seams 

by pumping groundwater from coal seams to lower 

ground water pressures. The coal seams targeted for 

CBM development in the Powder River Basin 

constitute important regional aquifers that provide 

water for domestic, livestock, agricultural, and 

industrial uses. Consequently, CBM production will 

probably affect existing water uses in the Powder 

River Basin, although the extent and magnitude of 

effects are difficult to predict.

The Montana Board of Oil and Gas Conservation 

(MBOGC) requires, through its Order No. 99-99, that 

CBM producers submit field development plans that 

include groundwater characterization and monitoring. 

In addition to complying with existing MBOGC rules 

for wildcat gas wells, CBM producers are required to 

describe baseline hydrologic conditions, to inventory 

existing wells and springs, to offer water mitigation 

agreements to existing water users, and to monitor 

water production and shut-in water pressures within 

coal bed methane fields. Water mitigation agreements 

must be offered for a minimum of one-half mile 

(expanded to one mile in Mont. Code Ann. 85-2-521) 

from CBM fields or greater distances if effects extend 

father. The U.S. Environmental Protection Agency 

(EPA) requires monitoring under permits for Class V 

injection wells used to re-inject water produced 

during CBM production. Specific requirements of 

Class V injection permits may include monitoring of 

injection pressure, injection rate and total volume at 

injection wells, and ground water elevations in 

monitoring wells.

There are no clear regulatory requirements for 

monitoring effects to ground water levels or spring 

flows outside the one-mile minimum specified by 

MBOGC or the area affected by Class V injection 

wells. Groundwater monitoring conducted by CBM

producers within and near CBM fields, as required by 

MBOGC or the U.S. EPA, will not reveal broad 

regional effects. Therefore, regional-scale monitoring 

needs to be conducted outside areas of potential CBM

development to allow potential effects to be evaluated 

before, during, and after the period of CBM

production. In addition, the spacing of monitoring 

sites and the frequency of monitoring needs to be 

sufficient to distinguish potential effects attributed to 

CBM development from potential effects attributed to 

other water users, and from ambient/seasonal 

variations in ground water levels and spring flows.

The purpose of this document is to establish design 

criteria for a regional-scale monitoring program 

intended to detect potential effects of CBM

development on existing water uses. The objectives 

of the regional scale monitoring program are to 

characterize baseline hydrologic conditions, detect 

changes in ground water levels and flows from 

springs attributable to CBM development, and verify 

recovery of ground water levels after CBM

development ends. Regional-scale monitoring of 

wells and springs is intended to augment and 

compliment field-scale monitoring established under 

MBOGC Order No. 99-99 or EPA UIC Class V 

injection well permits.

Criteria for selecting locations and spacing for 

monitoring sites, consisting of wells and springs, and 

monitoring practices are proposed here to ensure that 

long-term monitoring is sufficiently comprehensive to 

detect effects that CBM development might have on 

ground-water systems. Priorities are proposed to 

coordinate monitoring with the pace of development 

and the need to evaluate potential effects, and 

recommendations are presented for implementing 

monitoring and managing monitoring data. The 

criteria and monitoring recommendations described 

below are not meant as rigid rules, but rather are

intended to guide qualified personnel in selecting 

monitoring locations and implementing monitoring 

that meet the objectives stated above.

The BLM, at its discretion, will administer the 

regional-scale monitoring program, while operators 

will be responsible for all in-field monitoring. The 

BLM has a commitment to maintaining the water 

monitoring of the PRB region, similar to their 

continued (25+ years) funding of the MBMG for coal 

mine water monitoring. The BLM will also partner 
MONITORING APPENDIX

Effects of Coal Bed Methane Development on Water Resources

MON-23

with operators for in-field monitoring when federal 

gas is produced.

Criteria and Monitoring 

Practices

The portion of the Powder River Basin underlain by 

coals of the Tongue River Member of the Fort Union 

Formation is generally considered to have potential 

for CBM development. Within this area, however, 

CBM is less likely to be developed from coal seams 

with limited thickness and ambient ground water 

pressures; conditions that indicate limited potential 

for gas production. These areas, located primarily 

within 2 to 5 miles of coal outcrops, should be 

targeted for monitoring wells.

The Anderson-Dietz, Canyon, Wall, and Knobloch 

are the four primary coal seams within the Tongue 

River Member (Map 1). Separate monitoring sites 

located within 5 miles of the outcrops of each of these 

coal zones are proposed. Clusters of wells will be 

completed in different coal zones where outcrop areas 

overlap and, where present, springs will be monitored 

near each monitoring site. Monitoring wells will need 

to be completed in alluvial aquifers, in areas where 

water from CBM production is discharged to surface 

impoundments, or in selected sandstone aquifers 

within coal outcrop areas or CBM fields (when not 

required by MBOGC or the U.S. EPA). Springs that 

are current, historical, or potential sources of water

but located away from established monitoring sites 

may also be monitored.

The focus of overall monitoring of the potential 

effects of CBM development will change as CBM

fields mature, and gas production declines and 

eventually ends. Monitoring performed by CBM

operators that is required by MBOGC or the U.S. 

EPA, will gradually be discontinued as portions and 

eventually all of fields are played out. Abandoned 

producing wells or monitoring wells within CBM

fields should be incorporated into the regional 

monitoring program as field mature, in order to 

effectively monitor post-production groundwater 

recovery in affected areas.

The need for detailed information, and the cost of 

installing monitoring wells and monitoring ground 

water-levels and spring flows, will need to be 

balanced to determine the ultimate spacing between 

monitoring sites. At a minimum, one monitoring site 

will be located in every township that lies within 5 

miles of the outcrop of a targeted coal. The ultimate 

spacing of monitoring sites might be greater, 

depending on site-specific conditions such as 

thickness of coal zone and importance of coal or 

sandstone aquifers, and priorities for monitoring 

outlined below.

Monitoring wells may be newly constructed wells, 

existing monitoring or water supply wells, or 

abandoned or transferred CBM production wells. 

Ground-water levels in monitoring wells and flows of 

springs will need to be measured monthly to obtain a 

sufficient data record to characterize patterns of 

seasonal changes in ground-water level or spring 

flows, before the wells or springs can be effected by 

CBM development. Typically two to three years of 

monitoring record is desirable. Monitoring frequency 

should be reduced once a sufficient record of baseline 

conditions is established.

Priorities 

The following priorities are proposed for initiating 

monitoring and selecting monitoring well density and 

frequency, to ensure that a regional ground water 

monitoring program is established in advance of 

anticipated CBM development and before potential 

effects of CBM development can occur.

• Sequence of CBM development—Areas most 

likely to be affected by CBM development first 

are the highest priority for initiating monitoring. 

CBM development is expected to focus initially 

on the Anderson-Dietz coal zone and, therefore, 

monitoring near its outcrop should begin first. 

Records of exploration wells, pipeline plans, and 

identification of prospective coal zones can 

provide more specific information regarding the 

sequence of CBM development.

• Extent of water use—Areas where water from 

coal-beds is heavily used are high priorities for 

monitoring. Within the general area of the 

Anderson-Dietz outcrop, areas of concentrated 

water use, such as the headwaters of Otter Creek, 

will need immediate and more intensive 

monitoring.

• Proximity to political boundaries—Monitoring 

should be established along political boundaries, 

specifically the Montana-Wyoming border and 

reservation boundaries, in order to detect 

potential effects from areas outside the regional 

monitoring network.

• Sensitivity or hydrogeologic setting—More 

intensive monitoring will be necessary where 
MONITORING APPENDIX

Effects of Coal Bed Methane Development on Water Resources

MON-24

faulting or complex stratigraphy result in 

complex hydrogeologic settings.

• Existing monitoring networks—Monitoring 

should be re-established at monitoring wells near 

operating coal mines and coal mining prospects 

studied in the past. New monitoring well 

construction should focus on areas where wells 

are not available.

• Land or mineral ownership—Monitoring should 

be conducted at sites with stable land and/or 

mineral ownership. For example, federally 

owned land, or other land with long-term access 

easements provide more reliable long-term 

access for monitoring.

Implementation and Data 

Management

An important goal of the proposed regional 

monitoring program is to ensure that all monitoring 

data collected are made readily accessible to the 

public. The regional monitoring program can, and 

probably will, be conducted by more than one 

agency, with funding from various sources. However, 

one agency or interagency will need to coordinate or 

review all regional monitoring activities in order to 

assure that monitoring occurs where needed and to 

prevent duplication. Data from field-scale monitoring 

pursuant to MBOGC Order 99-99 and EPA UIC 

Class V injection well permits will need to be 

managed similarly. A further responsibility of the 

lead agency or group should be to ensure that 

regional- and field-scale monitoring data are 

compiled and made available to the public in the 

Ground-Water Information Center (GWIC) and the 

National Resource Information Systems (NRIS).

Summary of 

Recommendations

A regional-scale monitoring program is necessary to 

characterize baseline hydrologic conditions, to detect 

potential effects resulting from CBM development, 

and to verify recovery of ground water levels after the 

period of CBM development. The following 

constitutes the main elements of a regional-scale 

monitoring program that should accomplish these 

objectives:

• Monitoring is needed to augment and 

compliment field-scale monitoring established 

under MBOGC Order No. 99-99 and EPA UIC 

Class V injection permits.

• Groundwater levels need to be measured in wells 

in coals and overlying or underlying sandstone 

aquifers at locations near coal outcrops outside 

of areas of prospective CBM development.

• Groundwater levels need to be measured in wells 

in alluvial aquifers in areas where water CBM

production is discharged to surface 

impoundments, or selected sandstone aquifers 

within CBM fields.

• Flows from springs need to be monitored when 

they are near well monitoring sites or if they are 

important water sources.

• Groundwater levels need to be measured in 

abandoned or transferred CBM wells as CBM

fields mature.

• Monitoring sites need to be located in every 

township near coal outcrops at a minimum.

• Groundwater levels in wells and flows from 

springs need to be measured monthly to 

characterize ambient seasonal patterns.

• Monitoring sites need to be established to ensure 

that the regional monitoring program is 

implemented in advance of localized CBM

development and, consequently, that potential 

effects can be detected.

• One oversight agency or interagency group 

responsible for collecting and compiling 

comprehensive and consistent data should 

implement the proposed regional monitoring 

program.

• Monitoring data need to be compiled and made 

available to the public through GWIC and NRIS.
MON-25
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