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TABLE OF CONTENTS

SUMMARY ......................................................................................................................................... 1

DECISION ........................................................................................................................................... 1

REASONS FOR THE DECISION....................................................................................................... 3

MITIGATION MEASURES................................................................................................................ 8

On-site Requirements....................................................................................................................... 8

Off-site Mitigation............................................................................................................................ 9

PUBLIC INVOLVEMENT.................................................................................................................. 9

SUMMARY OF PROPOSED ACTION AND ALTERNATIVES.................................................... 11

Alternatives Considered ................................................................................................................. 11

No Action Alternative .................................................................................................................... 11

Proposed Action ............................................................................................................................. 11

Alternative A – Minimize Directional Drilling .............................................................................. 12

Alternative B – Minimize Surface Disturbance.............................................................................. 13

BLM Preferred Alternative............................................................................................................. 13

ALTERNATIVES CONSIDERED AND ELIMINATED FROM DETAILED STUDY.................. 15

Draft EIS Alternatives Not Carried Forward for Final Analysis..................................................... 15

Other Alternatives Considered and Eliminated from Detailed Analysis......................................... 15

ENVIRONMENTALLY PREFERRED ALTERNATIVE ................................................................ 16

APPEAL PROCESS........................................................................................................................... 17

ERRATA............................................................................................................................................ 19

APPENDICES

A. Jonah Infill Drilling Project Administrative Requirements, Conditions of Approval, and

Mitigation

B. Operator-Committed Practices

C. Adaptive Management in the Jonah Infill Drilling Project Area

D. U.S. Fish and Wildlife Service Concurrence Letter

E. Summary of Public Comments on the Jonah Infill Drilling Project FEIS and BLM’s

Responses
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List of Figures

1. Jonah Infill Drilling Project Location, Sublette County, Wyoming, 2006...................................2

List of Tables

1. EnCana Proposed CM Funding, Jonah Infill Drilling Project, Sublette County,

Wyoming, 2006 .............................................................................................................................9
1

RECORD OF DECISION

for the

Jonah Infill Drilling Project Environmental Impact Statement

Sublette County, Wyoming

SUMMARY

This Record of Decision (ROD) documents the Wyoming State Director’s decision to approve, with minor

modifications, the preferred alternative as described in the Final Jonah Infill Drilling Project (JIDP)

1

Final

Environmental Impact Statement (FEIS). The JIDP FEIS analyzes various optionsfor oil and gasrecovery

and resource mitigation. The decision emphasizes limiting additional surface disturbance and performing

interim reclamation and off-site mitigation, performance-based outcomes for reducing impacts to air

quality, cooperative air quality monitoring with the State of Wyoming, and continued resource monitoring

and consultation with federal and state agencies. The ROD providesthe plan for future management of the

federal surface and mineral estate in the Jonah Infill Drilling Project Area (JIDPA). The JIDPA comprises

approximately 30,500 acres, of which 28,580 acresisfederalsurface and mineral estate (94%), 1,280 acres

is state surface and mineral estate (4%), and 640 acres is private surface/federal mineral (2%) estate.

Figure 1 shows the location of the JIDPA. The findings in the JIDP FEIS and decisions of this ROD are

based upon an open and collaborative public process. The State of Wyoming, Sublette County, individuals,

stakeholders, and institutions shared their knowledge and insights about the proposed oil and gas field

development with the Bureau of Land Management (BLM). Public involvement was solicited, and the

BLM responses to major issues from public comments on the FEIS are presented in Appendix E.

The JIDP is consistent with the President’s National Energy Policy and the Energy Policy Act of 2005 by

increasing domestic energy supply and helping to reduce the country’s dependence on foreign sources of

oil and gas. The final project plan as described in the JIDP FEIS was recently cited by the U.S.

Environmental Protection Agency (EPA) as a “model of collaboration” that successfully balances

“provid[ing] greatly needed energy resources...while protecting the environment of southwestern

Wyoming.” The proposed project is expected to produce nearly 8 trillion cubic feet (TCF) of natural gas,

providing enough natural gas to heat 96 million homes for one year and generating approximately

$6.1 billion in royalties to be divided between the federal treasury and the State of Wyoming.

DECISION

The BLM adopts the Preferred Alternative (with modifications) for infill drilling of the JIDPA, as

described in the FEIS. The Preferred Alternative involves year-round drilling of approximately

3,100 additional oil and gas wells within the existing JIDPA to recover additional energy resources while

limiting the total surface disturbance within the JIDPA to 46% of the area, or a maximum of 14,030 acres,

at any given time. Operators will be required to begin reclamation as soon as disturbed areas are no longer

1

The Jonah Infill Drilling Project is the proposal of EnCana Oil & Gas (USA), Inc., BP America Production

Company, and other companies (hereafter referred to as “Operators”).

3

needed for drilling activities. Final reclamation will be conducted as soon as sites are no longer needed for

production activities. When reclaimed areas meet the objectives in FEIS Appendix B, reclaimed acres will

be credited back against the total disturbed acres, up to 6,304 acres. The cumulative total disturbed area

cannot exceed 20,334 acres in the JIDPA. Surface disturbance and reclamation credit will be prorated and

tracked on an operated-acreage basis (i.e., leases developed by specific Operators;see Appendix A). Nonproject related disturbance within the JIDPA boundaries will be allocated to Operators on an operatedacreage percentage basis.

Desired future conditions and resource management objectives will be achieved through performancebased mitigation and implementation of best management practices (BMPs). The objectives address key

issues and significant impacts identified through the environmental analyses. Monitoring and surveying

will determine if objectives and desired future conditions are being met.

This decision establishes the Jonah Interagency Monitoring and Mitigation Office (JIO). The objective of

the JIO is to evaluate the effectiveness of guidelines, mitigation, BMPs, and monitoring. The JIO will

make recommendations to the BLM on modifications to proposed projects and mitigation based on its

evaluations. The BLM will use these recommendations in consultation with state and federal agencies to

adapt management decisions.

This decision is consistent with both the Pinedale Resource Management Plan (RMP) and Green River

RMP. This decision is not the final review or approval for actions associated with the JIDP. The

Authorized Officer will review and authorize each component of the project that involves disturbance of

federal lands on a site-specific basis. The methods used to evaluate and authorize each surface-disturbing

activity include, but are not limited to, an Application for Permit to Drill (APD), right-of-way (ROW)

grant, Sundry Notice, or Special Use Permit with the supporting environmental review.

REASONS FOR THE DECISION

The JIDP EIS was prepared in response to leaseholders’ requests to exercise the terms and conditions of

their respective oil and gas leases in the project area. The environmental impacts of this decision are fully

disclosed in the Draft and Final EISs for the project. The decision to approve the JIDP as described in the

Preferred Alternative is in conformance with the BLM land use plans for the Pinedale and Rock Springs

Field Offices covering the JIDPA.

The decisions included in this ROD ensure the effective recovery of the oil and gas resource within the

JIDPA. Performance-based mitigation and BMPs ensure desired future resource conditions will be

achieved. Implementation of this decision will result in production of nationally significant oil and natural

gas resources consistent with The National Energy Policy (May 2001). Although the proposed

development requires intensive surface-disturbing activities that will result in significant impacts to

resource values, including displacement and/or local extirpation of wildlife resources, long-term

reestablishment of habitat value and function will occur through the proposed reclamation practices and

monitoring efforts. While the intensive development will limit opportunities for other uses for many

years, the long-term outcome will be full reclamation and the return of these lands to near prior existing

conditions for other use opportunities in the future. In addition to the onsite mitigation, the BLM will

require off-site mitigation as proposed by the project proponent, EnCana Oil & Gas (USA), Inc.

In reaching this decision, the following key issues were considered. Rationale for mitigation and actions

to address each issue and reduce effects are presented.
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Surface Disturbance. The total area and distribution of surface disturbance associated with further

development of the JIDPA affects other resources (soils, vegetation, wildlife and wildlife habitat, cultural

resources). The extent and duration of surface disturbance can adversely affect management of these

resources.

• To minimize surface disturbance impacts, the Preferred Alternative employs outcome-based

performance objectives and encourages development and implementation of state-of-the-art

technologies for both operational and reclamation activities.

• Soil erosion and salinity transport modeling predicted no sedimentation or salinity reaching the

Green or New Fork Rivers, though multiple repeated runoff events could affect these waterways.

Accelerated reclamation, intensive monitoring, and use of sediment controlstructures will further

minimize impacts. Managing surface disturbance on a field-wide basis and requiring successful

interim reclamation in exchange for allowing additional disturbance provides a strong incentive

for Operators to employ new technologies to reduce their operational footprint and accelerate the

reclamation process to reach their total oil and gas resource recovery objectives. Reducing the

operational footprint will create less overall disturbance, while accelerated reclamation will ensure

vegetation is reestablished in the shortest time possible. The surface disturbance management

philosophy of smaller operational footprints and accelerated reclamation efforts also benefit

wildlife by limiting habitat fragmentation and returning habitat function in the shortest possible

time.

• Surface disturbance impacts on cultural resource are mitigated through avoidance and, where

avoidance is not possible, by recovery actions on a site-specific basis. Additionally, a

programmatic agreement between the BLM, State Historic Preservation Office, and Operators is

being pursued to further reduce the overall potential for impacts to cultural resources.

Socioeconomic Effects. Another issue of concern is the influx of transient workers (those workers not

maintaining permanent residence) and the ability of governmental agencies to address infrastructure

shortfalls such as community support facilities, hospitals and medical clinics, emergency services, housing,

and roads. Gas field employees express the desire to maintain permanent residence in the area, but are

concerned about continued employment opportunities in the JIDPA. Both the project proponents and local

government agencies identify potential revenues from tax dollars, royalties, and jobs associated with the

proposed project as benefits to the state, county, and local communities.

• The FEIS and Socioeconomic Analysis Technical Support Document contain extensive analysis of

potential socioeconomic impacts. To assist local government agenciesin planning, Operators will

annually provide 3-year field development forecasts to the BLM. These forecasts will be made

available to local government agencies to assist in local community/county/state planning efforts.

Air Quality. Ogoing and future natural gas development projectsin the region are contributing to observed

changes in air quality and negatively impacting the nearby Class I wilderness airsheds. Also of concern

are the potential health effects on worker and area residents, the potential for excessive acid deposition, the

potential impacts to nighttime stargazing, and BLM’s authority for requiring air quality mitigation.

• These concerns have been extensively analyzed through air quality modeling in cooperation with

the U.S. Environmental Protection Agency (EPA), Wyoming Department of Environmental

Quality–Air Quality Division (WDEQ–AQD) and USDA Forest Service (USFS).
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• Modeling predicts no significant impacts to public health for the air quality pollutants modeled.

Worker health falls within the purview of the Occupational Safety and Health Administration.

• WDEQ is the regulatory authority to maintain and monitor compliance with state and federal air

quality public health standards. BLM will continue to work in consultation with WDEQ, EPA,

and the USFS to monitor air quality for public health, including ozone monitoring.

• Both modeled and monitored atmospheric deposition is within levels of acceptable change, and

no significant impacts to lake chemistry from the JIDP are anticipated. Mitigation measures

designed to reduce potential visibility impacts are anticipated to also reduce impacts to lake

chemistry and atmospheric deposition.

• The modeling indicated potential significant adverse visibility impacts in various Class 1 areas

using a reasonable-but-conservative scenario. To address this issue, the BLM, WDEQ, EPA, and

USFS jointly developed performance-based mitigation requirements (see Appendix A).

• Mitigation measures designed to reduce potential visibility impacts are anticipated to also reduce

impacts to stargazing.

Wildlife. Wildlife issues focus on three areas: sage-grouse impacts, pronghorn migration corridors, and

habitat impacts. Overall wildlife impact strategy is discussed below, followed by a specific discussion of

each of the three issues.

• After federal decisions authorizing the current level of Jonah Field development (16 well pads per

section, or 40-acre spacing), the Wyoming Game and Fish Department (WGFD) issued a guidance

document for oil and gas development impacts to wildlife (Recommendationsfor Development of

Oil and Gas Resources within Crucial and Important Wildlife Habitats, December 6, 2004).

Using the definitions in this guidance, the current state of development in the Jonah Field had

already reached a threshold (oil and gas development at levels greater than four well pads per 640-

acre section [160-acre spacing]). The WGFD report recommends off-site mitigation to address

impacts when this threshold is exceeded.

• To address the cumulative impacts within the JIDPA, this decision implementsthree strategies; 1)

return field habitat function in the shortest time possible, 2) perform on-site mitigation to the

extent practicable and employ compensatory (off-site) mitigation (CM) when complete on-site

mitigation is not effective in the short-term, and 3) institute an adaptive management process to

ensure monitoring and both on- and off-site mitigation are effective.

• To return habitat function as soon as possible, this decision implements a management approach

that provides an incentive for rapid on-site interim and final reclamation while simultaneously

allowing maximum flexibility in field development. The Operators will establish a fund for CM

as part of their operation. This fund will be administered by the Jonah Interagency Monitoring and

Mitigation Office (JIO) established by this ROD (see Appendix C). The JIO will evaluate

monitoring and mitigation effectiveness and provide annual adaptive management

recommendations as appropriate to the BLM for consideration. WGFD and the Governor of

Wyoming have coordinated on these strategies.

• Sage-Grouse Impacts. Effects to this species and its habitats are an issue because of the decline

from historic population levels of sage-grouse in the JIDPA and the decline in overall populations
6

across their range. Potential project effects to breeding, nesting, brood-rearing, and wintering

habitat and habitat function were identified as potentially contributing to continued population

declines. It was also noted that existing sage-grouse protection measures appear to be inadequate

within the JIDPA and with the proposed increase in development, existing protection measures

would be even less effective.

o The FEIS analysis disclosed the impactsfrom the current and alternative levels of disturbance,

and recognized that the local population will likely be completely displaced and/or locally

extirpated due to full field development. However, this is not anticipated to affect long-term

species sustainability due to the relatively small size of the JIDPA in relation to overall habitat

availability in the area. For example, the Yellowpoint lek complex (which includes the

JIDPA) has seen a 25% reduction in male lek attendance compared to long-term averages,

while the nearby Speedway lek complex (outside the JIDPA) has observed a 48% increase in

male lek attendance. Additionally, substantial off-site CM directed at sage-grouse habitat

improvements will be employed to further mitigate impacts.

• Pronghorn Migration Corridor. Sublette pronghorn herd migrations are affected by current oil and

gas development. Continued development within the JIDPA and at other locations within the

Sublette Herd Unit area will cumulatively affect pronghorn seasonal migrations. Hunters, wildlife

enthusiasts, and wildlife management agencies all consider the maintenance of existing migratory

corridors extremely important to pronghorn population maintenance.

o The FEIS analysis disclosed that these impacts will likely affect traditional pronghorn

utilization of the JIDPA on a long-term basis. As with sage-grouse, the selected action is not

anticipated to affect overall species sustainability due to the project’s small footprint and

availability of suitable alternative habitat surrounding the JIDPA that provides adequate

opportunity for animal displacement. Also, CM will be employed to implement appropriate

projects, such as habitat improvement, to further mitigate impacts.

Wildlife Habitat. Respondents indicated that, with implementation of the proposed project, the JIDPA

would no longer be suitable habitat for many wildlife species (e.g., threatened and endangered species,

BLM-sensitive species, and raptors). Habitat loss was attributed to direct lossthrough surface disturbance,

indirect loss through animal avoidance of areas proximal to developments, and habitat fragmentation

(habitat is no longer suitable for species requiring intact habitat patches larger than what would be

available if the project were constructed).

o The FEIS acknowledged that habitat impacts would be substantial due to full field

development. The mitigation strategy for limiting the allowable surface disturbance is

designed to ensure accelerated reclamation by the Operators and to facilitate the long-term

return of habitat function. Compensatory mitigation, committed to by the Operators and

accepted by the BLM as a condition of approval, should result in significant improvementsto

existing habitats and/or development of additional suitable habitats used by the affected

species. The off-site mitigation will remain in place and offset some of the on-site impacts

until such time as final reclamation of the full field development impacts occurs.

Maximize Natural Gas Recovery. The BLM was perceived as not responding to its mandate under the

Mineral Leasing Act to maximize recovery of available oil and gas resources. Existing and proposed

development restrictions (lease stipulations, RMP requirements, and Operator-committed practices) limit

the economic feasibility of maximizing recovery of the JIDPA’s natural gas resources.
7

• Under the Preferred Alternative, Operators will be able to achieve their proposed level of

development over time, but must meet interim reclamation goals to reach these objectives.

The BLM believes this approach provides a good balance between oil and gas recovery and

resource protection and provides for long-term reclamation and re-establishment of native

vegetation and wildlife communities.

Range/Grazing. Concerns for livestock operations in the JIDPA include direct loss of livestock forage;

the potential for a reduction in permitted livestock numbers; water quality impairment at existing livestock

watering sources; livestock movement restrictions/alterations due to pipeline trenches, roads, and fences;

livestock management problems associated with the inability to accessrequired area two-track routesfrom

project-developed crowned-and-ditched roads; vehicle collisions; drinking contaminated waters from

project pits; entrapment in pipeline trenches; and the increase in fugitive dust emissions potentially

causing dust-induced pneumonia.

• Though the project results in the temporary and potentially long-term loss of available livestock

forage (depending on the results of the Preferred Alternative’s reclamation requirements), any

loss of animal unit months will be determined through rangeland monitoring and, if necessary,

addressed through the adaptive management process. As discussed in the FEIS, the effect(s) of

other potential impacts (e.g., traffic, roads, open trenches, etc.) on grazing operations cannot be

accurately predicted at this time, but it is reasonable to assume some conflicts may occur.

Mitigation and/or solutions to such conflicts will also be addressed as they arise.

BLM Monitoring/Enforcement Capability. Concern was expressed that BLM would focus on drilling

approvals and neglect monitoring, compliance, and resource protection responsibilities. It was suggested

this may lead to undetected violations of numerous laws, rules, and regulations (e.g., Endangered Species

Act, Clean Water Act, lease stipulations, RMP requirements, Operator-committed practicesrequired under

past project authorizations).

• BLM’s monitoring and enforcement procedures for oil and gas exploration and development

occur in three separate phases: 1) application review and processing, 2) compliance, and 3) longterm monitoring of mitigation effectiveness.

APD processing includes review of the surface-disturbing activity application and on-site

inspection of proposed locations. Resource specialists manage the various aspects of this process

and ensure NEPA analyses, on-site visits, site-specific conditions of approval (COAs), and

mitigation requirements are appropriate. Sufficient personnel are available to meet requirements.

APD compliance includes inspection of road, well pad, and pipeline construction by BLM

Natural Resource Specialists (NRSs) and/or Surface Compliance Specialists(SCSs) to ensure the

construction complies with requirements of the surface use plan in the APD, site-specific and

programmatic NEPA documentation, and the guiding land use plan. NRSs and SCSs also monitor

post-drilling (interim) reclamation processes to ensure the site is adequately stabilized and habitat

restoration is initiated in accordance with this ROD. APD compliance also includes rigging-up,

drilling, and case-setting operations, which are randomly monitored by BLM Petroleum

Engineering Technicians to ensure required safety features such as blow-out preventers operate

properly and the surface casing is properly cemented to protect fresh groundwater zones.

Long-term resource monitoring includes evaluation of the effectiveness of both on-site and off-site

mitigation/reclamation to ensure the objectives of this ROD are met. The Jonah Interagency
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Monitoring and Mitigation Office (JIO) was established to addressthese issues(see Appendix C).

As an interagency office, the JIO staff (WGFD, WDEQ, Wyoming Department of Agriculture,

and BLM) will have the authority to address a wide range of pertinent monitoring, mitigation,

and/or compliance issues. This office will also provide the BLM with adaptive management

recommendations to established procedures when existing data indicates changes are required.

One of the major concerns expressed during this analysis process by both the public and various agencies

was the inability to mitigate all potential impacts in the JIDPA on-site (within the JIDPA boundaries).

In response to this concern, the Operators voluntarily proffered varying levels of CM to provide a means

to complete off-site mitigation that may be necessary due to the level of development authorized.

Additionally, a portion of these funds will be used to establish and operate the JIO to provide projectspecific monitoring and mitigation (both on- and off-site). The JIO also provides a meansto ensure project

monitoring and mitigation requirements are fulfilled and BLM receives relevant adaptive management

recommendations periodically.

The Preferred Alternative meets one of the primary goals of the President’s National Energy Policy and

the Energy Policy Act of 2005, to increase domestic energy supplies and reduce the United States’

dependence on foreign sources of energy. Development of these federal resourcessatisfiesrequirements of

FLPMA and the Mineral Leasing Act. The leasing and subsequent production of federal oil and gas

resources provides the United States, the State of Wyoming, and affected local counties with income in

the form of lease royalty payments. The Preferred Alternative meets the goals of the National Energy

Policy and achieves the objectives of the federal oil and gas leasing programs managed by the BLM.

This decision is made in full consideration of the public, local, state, and other federal agency input. No

substantial issues remain unresolved within the scope of this proposal, as raised by government agencies,

industry, groups, or individuals.

MITIGATION MEASURES

Implementation of the Jonah Infill Drilling Project will be subject to numerous mitigation measures

applicable to both on-site and off-site actions. These measures are addressed in two sections, on-site

requirements and off-site requirements, each of which is described below.

On-Site Requirements

On-site administrative requirements, COAs, and mitigation requirements are used to guide field

development activities to compensate for, resolve, minimize, or avoid impacts to resources. Appendix A

presents administrative requirements, performance-based objectives, and potential mitigation measures

to be applied when supported by site-specific environmental review. Operator-committed practices, which

become mandatory requirements with publication of this decision, are included in Appendix B.

Field development plans contained in Appendix B of the FEIS are also incorporated in this decision, as

modified in the Errata section of this ROD. These development plans include a Transportation Plan,

Reclamation Plan, and a Hazardous Materials Management Summary.
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Off-Site Mitigation

Off-site or compensatory mitigation (CM) is necessary to mitigate some impactsthat cannot be adequately

mitigated on site. Impacts to wildlife from implementing the Preferred Alternative cannot be adequately

mitigated on site. Recognizing this fact, EnCana, and potentially other Operators, committed to fund

varying levels of CM depending on the amount of new surface disturbance authorized in this decision.

These funding levels are included in Table 1 below for the five developmentsscenarios provided for in the

EnCana commitment letter.

Table 1. EnCana Proposed CM Funding, Jonah Infill Drilling Project, Sublette County, Wyoming, 2006

Funding Distribution

Amount of Additional Surface Disturbance

Authorized in the Jonah Drilling Project

ROD

Offsite Wildlife Habitat

Improvement Projects

Other Monitoring,

Inspection, and

Enforcement Activities

Total

16,200 or Greater Acres New Initial Surface

Disturbance

$20.5 million $8 million $28.5 million

Between 12,000 and 16,199 Acres New

Initial Surface Disturbance

$16.5 million $8 million $24.5 million

Between 11,000 and 11,999 Acres New

Initial Surface Disturbance

$13.5 million $6.2 million $19.7 million

Between 10,000 and 10,999 Acres New

Initial Surface Disturbance

$7.5 million $4.6 million $12.1 million

Between 8,300 and 9,999 Acres New Initial

Surface Disturbance

$1.5 million $4 million $5.5 million

The Preferred Alternative permits a total cumulative new surface disturbance of 16,125 acres. This

equates to a total commitment of $24.5 million in CM funding, to be provided as requested by the JIO

Charter Members annually in increments not to exceed 20% of the total CM fund per year. These funds

will be applied to off-site mitigation projects and managed by the JIO, with oversight by the Agency

Managers Committee (see FEIS, Appendix F). In the event CM proffered funds are withheld, further

surface disturbance allowed under this decision would not be authorized.

Project proposals will be accepted from a variety of sources: federal, state or local government agencies,

educational institutions, interest groups, or individuals. Initial project selection will be by the JIO, with

final approval by the BLM. Approved projects will be implemented and managed by the JIO.

PUBLIC INVOLVEMENT

In September 2002, EnCana Oil & Gas (USA), Inc. (EnCana) dba McMurray Oil Company, BP America

(BP), and other natural gas operators, collectively known as the Operators, submitted a proposal to the

BLM to further develop the Jonah Field by “infill” drilling natural gas wells in well spacing that would be

more dense than what had been previously approved.
10

On March 13, 2003, the BLM’s Notice of Intent (NOI) appeared in the Federal Register and invited the

public to comment or provide research information regarding the Operators’ proposal to infill drill in the

Jonah natural gas field. On March 26, 2003, copies of a scoping notice describing the Proposed Action and

seeking comments were mailed to appropriate government offices, elected officials, public land users,

groups, newspapers, and radio and television stations. A scoping meeting was held in Pinedale, Wyoming,

on April 17, 2003. An additional public meeting was held on November 13, 2003, to present to the public

the draft project alternatives that had been developed for analysis in the EIS to address public concerns.

On November 20, 2003, EnCana and BP jointly submitted to the BLM a revised development proposal.

The Operators’ proposed revised development had evolved from the proposed activities described in the

March 2003 NOI.

On December 12, 2003, the BLM notified scoping participants of the Operator-proposed development

plan revisions and solicited further comment. BLM’s letter describing the Operators’ revised proposal

provided the public with a 30-day review and comment period.

Numerous issues and concerns were identified in comments received by BLM. All comments received

between March 2003 and August 2004 were reviewed and analyzed. The BLM identified nine key issues

based primarily upon the assumed quantity, intensity, or duration of a potential impact, and/or the level of

interest in the issue. These issues were used to develop the range of alternatives analyzed in the draft

environmental impact statement (DEIS).

The DEIS, including technical support documents for air quality and socioeconomics, wasreleased to the

public and a notice of availability (NOA) was published in the Federal Register on February 11, 2005. All

documents were available in paper and electronic formats (CD-ROM), as well as being available for

download from the BLM’s website. The comment period ended April 12, 2005.

After publication of the DEIS, BLM determined the air quality modeling and analysis in the DEIS was

inadequate to evaluate impacts. Analysis in the Questar Year-Round Drilling Proposal Environmental

Assessment (November 2004) showed emission levels of certain pollutants within the regional airshed had

increased significantly since the original DEIS data had been compiled.

The BLM in cooperation with other federal and state governments with jurisdiction determined that

supplemental air quality modeling and analysis would be conducted, an air quality technical support

document supplement would be published, and the results of these studies would be incorporated into the

final environmental impact statement (FEIS). On April 12, 2005 BLM published its NOI in the Federal

Register to provide supplemental air quality information for the DEIS. The supplemental air quality

information became available for public review and comment in August 2005, and BLM published an

NOA in the Federal Register and provided the public with an additional 60-day comment period.

BLM received a total of 877 separate written comment submissions (letters, e-mails, forms, etc.) on the

DEIS, TSDs, and the August 2005 supplements. Within these submissions, 1,147 individual comments

were identified as “substantive,” or meaningful to revision of the DEIS and/or its supporting volumes.

BLM responded to each of these substantive comments, which were used to guide revision of the DEIS

analyses. The substantive comments resulted in BLM’s decision to significantly revise the Preferred

Alternative and to eliminate five of the alternatives presented in the DEIS from further consideration in the

FEIS. A detailed description of the comments made on the DEIS and the process by which they were

analyzed by BLM was included with the FEIS.
11

The FEIS was released to the public and an NOA published in the Federal Register on January 13, 2006.

Comments were accepted on the FEIS through February 13, 2006. A total of 45 public comments were

received. A summary of these comments and BLM’s responses are contained in Appendix E of this ROD.

SUMMARY OF PROPOSED ACTION AND ALTERNATIVES

Alternatives Considered

The Jonah Infill Drilling Project FEIS analyzed five alternatives. They are:

1. No Action

2. Proposed Action

3. Alternative A: Minimize Directional Drilling

4. Alternative B: Minimize Surface Disturbance

5. Preferred Alternative

No Action Alternative

Under the No Action Alternative, the BLM would reject the Operators’ proposal for additional field-level

natural gas development on federal lands within the JIDPA. Authorizations for and impacts from

previously approved or analyzed development (533 wells) and surface disturbance (497 well pads with

associated roads, pipelines, and ancillary facilities) would continue. The approved surface disturbance

under the No Action Alternative is 4,209 acres, including 1,409 acres of life of project (LOP) disturbance.

LOP is estimated to be approximately 63 years.

However, rejection of the Operators’ proposal would not preclude all additional natural gas development

in the JIDPA. The No Action Alternative assumes the JIDPA would be managed as approved by existing

management plans and previously approved NEPA documents. Though the extent of potential future

development under this scenario is limited, it cannot be precisely predicted. Therefore, the impact analysis

for the No Action Alternative assumes no new development.

The No Action Alternative serves as a benchmark enabling decision-makers and the public to compare the

magnitude of environmental consequences across action alternatives.

Proposed Action

The Operators would infill drill and develop up to 3,100 new wells on a minimum of 64 well pads/section

(at least 1 pad every 10 acres) with related roads, pipelines, and ancillary facilities on up to 16,200 acres of

new disturbance. Drilling would begin upon issue of the ROD and continue until the total number of

proposed wells has been drilled, the natural gas resources in the field have been fully developed, or

economic conditions are such that it is no longer profitable to drill additional wells.

Operator reservoir modeling shows that 3,100 new wells would be necessary to adequately recover the

natural gas resource present in the area. Their experience indicates that the use of directional drilling is in

some cases not economically feasible and in other cases results in inadequate resource recovery.
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The Proposed Action assumes that 250 wells would be developed annually (~20 rigs operating yearround). LOP would be approximately 76 years. Specific features include:

• up to 3,100 new wells on up to 11,780 acres of new disturbance (2,790 acres LOP)—assumes all

3,100 wells would be drilled from single-well pads with an estimated total disturbance of 3.8 acres

and 0.9 acre LOP per single well pad;

• 465 miles of new resource roads with gathering pipelines—4,131 acres new disturbance

(1,635 acres LOP);

• 8 miles of new collector/local roads—73 acres new disturbance (37 acres LOP);

• an upgrade of approximately 12 miles of the Burma Road—75 acres new disturbance (20 acres

LOP);

• ancillary facilities—41 acres new disturbance (41 acres LOP) for water disposal, storage, and

compressor station facilities; and

• exploration activities—100 acres new disturbance (100 acres LOP) to develop well pads and other

infrastructures necessary to explore for natural gas resources in formations other than the Lance

Pool.

Following successful interim reclamation (post-drilling during production phase), LOP surface

disturbance under the Proposed Action would be 6,040 acres, which includes 1,409 acres of existing

disturbance.

Additionally, Operators identified a number of mitigation/development practicesthey would commit to in

advance (see Appendix B), as well as $28.5 million in compensatory (off-site) mitigation (CM) funding.

Alternative A – Minimize Directional Drilling

Alternative A is similar to the Proposed Action in its estimated surface disturbance requirements

(16,200 acres), development rate (250 wells per year) and LOP (76 years), but differs in that known areas

with sensitive resources in the JIDPA would not be avoided (e.g., Sand Draw,steep slopes, raptor nest and

sage grouse lek buffers). Development of natural gas resources beneath these areas would therefore not

require the use of directional drilling, resulting in increased recovery of the resources by ~250 billion cubic

feet over the LOP. This alternative would not necessarily provide for the RMP-required balance between

gas recovery and other resource protection; therefore, project authorization under this alternative would

require an RMP amendment. Other features of Alternative A include:

• Well pads, access roads, and other aboveground facilities could be located within 825 feet of

active raptor nests.

• Surface disturbance and occupancy would not be prohibited within 0.25 mile of the perimeter of

greater sage-grouse leks.

• Prairie dog towns would not be avoided
13

• The Sand Draw Conditional Surface Use restriction (formerly referred to as a No Surface

Occupancy restriction) and other drainage and steep slope avoidance areas would not be

maintained.

Operators committed to a number of mitigation/development practices in advance (see Appendix B) and

$28.5 million in CM funding under this alternative.

Alternative B – Minimize Surface Disturbance

Surface disturbance would be reduced under Alternative B by requiring all new wells be drilled from

existing well pads. Existing well pads would be enlarged and new pipelines built within existing pipeline

corridors. A rate of development of 75 wells per year and an LOP of 105 years are assumed under

Alternative B. Specific features include:

• expansion of existing well pads—3,081 acres new disturbance (1,044 acres LOP)— 6.2 acres

new disturbance (3.0 acres LOP) per well pad expansion;

• ancillary facilities—41 acres new disturbance (41 acres LOP) for water disposal, storage, and

compressor station facilities; and

• exploration activities—100 acres new disturbance (100 acres LOP) to develop well pads and other

infrastructures necessary to explore for natural gas resources in formations other than the Lance

Pool.

Following successful interim reclamation, LOP surface disturbance under Alternative B would total

2,622 acres, which includes 1,409 acres of existing disturbance.

Although directional drilling under Alternative B would minimize surface disturbance and thereby benefit

wildlife and other resources, it would also increase air emissions by approximately 20% over the Proposed

Action and Alternative A by extending the amount of drilling time per well. Thus, Alternative B could

have a greater cumulative impact on air quality resources. Additionally, Alternative B results in

significantly lower oil and gas recovery rates in relation to the Proposed Action or Preferred Alternative

(~1.8 trillion cubic feet of natural gas and 18 million barrels of oil).

Operator-committed practices contained in Appendix B would also apply, though no CM funding was

volunteered for this level of development.

BLM Preferred Alternative

BLM revised the Preferred Alternative based on public comment and technical information received on the

DEIS. The revised Preferred Alternative, and its associated outcome-based performance objectives,

mitigation, and Best Management Practices (BMPs), would achieve high levels of natural gas recovery

(potentially that of the Proposed Action) while minimizing impacts related to the key issues. BLM has

concluded that this management approach would achieve the fewest long-term impacts while allowing

recovery of the mineral resource as provided by federal laws and regulations, including FLPMA, and

extant leasing stipulations.
14

The Preferred Alternative would limit total surface disturbance at any given time to 46% of the JIDPA, or

a maximum of 14,030 acres. To mitigate surface disturbance and associated environmental impacts as

quickly as possible, Operators would be required to initiate reclamation of developed well pads and road

and pipeline construction ROWs pursuant to Reclamation Plan specifications (see FEIS, Appendix B).

Credit would thereafter be given, on an acre-for-acre basis for areas the BLM determines have

successfully been reclaimed. Under no circumstances would cumulative total surface disturbance exceed

20,334 acres over the LOP. Surface disturbance and reclamation credit will be tracked on an operatedacreage basis. Non-project related disturbance within the JIDPA boundaries will be allocated to Operators

on a field-wide operated-acreage percentage basis.

For the purposes of analysis, a total of 3,100 new wells and a pace of 250 wells drilled per year are

assumed, resulting in the field development phase being completed in approximately 13 years. However,

the actual pace of development may be limited by air quality impact restrictions and associated mitigation,

which creates the potential to increase the duration of the field development phase. For the purposes of

analysis the LOP is assumed to be 76 years.

Additional provisions of the Preferred Alternative are as follows:

• An interagency mitigation and monitoring implementation group, called the Jonah Interagency

Mitigation and Reclamation Office (JIO), would be established and begin working once the ROD

is issued. Details of JIO composition, objectives, and operating procedures are provided in

Appendix C. General provisions of the JIO are as follows:

o Oversee implementation of mitigation and monitoring of JIDP activities, including

compensatory mitigation.

o The JIO would include BLM, WDEQ, WGFD, and the Wyoming Department of Agriculture.

o Funding for the JIO would be provided by the Operators.

o BLM would consider periodic JIO adaptive management recommendations to adjust COAs,

monitoring, mitigation, and/or BMPs to meet field development and production objectives

throughout the LOP.

• The existing Wildlife Monitoring/Protection Plan developed for the Modified Jonah II Project

would be modified/updated to address activities within the JIDPA.

• To reduce potential wildlife impacts, no further improvements to the Burma Road would be

authorized. That portion of the Burma Road that is currently upgraded would be maintained to

BLM standards.

Following successful interim reclamation and assuming the application of the maximum reclamation credit

(6,304 acres), LOP surface disturbance under the BLM Preferred Alternative would total 6,020 acres,

which includes 1,409 acres of existing long-term disturbance.

Operator-committed practices as described in Appendix B would be required as COAs where appropriate.

Operators would fund compensatory mitigation equal to $24.5 million based on the authorized level of

new surface disturbance (16,125 acres; see Table 1).
15

ALTERNATIVES CONSIDERED AND ELIMINATED

FROM DETAILED STUDY

Draft EIS Alternatives Not Carried Forward for Final Analysis

Of the 10 alternatives that were analyzed in detail in the Draft Environmental Impact Statement (DEIS),

five of these alternatives—Alternatives C, D, E, F, and G—were not carried forward for final analysis in

the FEIS. Additionally, multiple well development rates within any single alternative were not further

analyzed. A description of these alternatives and development rates follows.

Alternatives C and D provided different limits to restrict well numbers and were initially considered in

the DEIS to provide a range of impacts to air quality. Alternative C proposed limiting development to

1,250 new wells and well pads and an estimated surface disturbance of 6,705 acres. Alternative D would

have limited the number of new wells and well pads to 2,200 and an estimated surface disturbance of

11,581 acres. Neither Alternative C nor Alternative D limited well or well pad surface density. These two

alternatives were eliminated from additional analysis because neither alternative is considered reasonable:

at least 3,100 additional wells would be required to fully develop the field and anything less would result

in stranded resources that would most likely never be recovered. Allowing mineral resources to remain

unrecovered, as would occur under these and similar alternatives, would result in waste and prevent BLM

from achieving its statutory and policy goals. In addition to not fully recovering the resource, Alternatives

C and D would result in impacts similar to those resulting from components of the alternatives that are

carried forward in this FEIS. Specifically, these components are individual wellsfrom closely spaced well

pads under Alternative A, multiple wells from a single well pad as analyzed in Alternative B, and a

combination of single and multiple well pads as analyzed under the Preferred Alternative.

Alternatives E, F, and G provided variable surface well pad spacing allowances, and were initially

considered to provide a range in the amount and distribution of surface disturbance across the JIDPA.

Alternative E examined drilling and developing 16 wells from 16 well pads in a section, resulting in

approximately 6,386 acres of additional disturbance. Alternative F analyzed the effects of increasing

the well pad density to 32 well pads per section for a total of 10,446 acres of additional disturbance.

Finally, Alternative G examined the effects of 64 well pads per section (one well pad for every 10 acres) at

an estimated total additional disturbance of 13,898 acres. As with Alternatives C and D, these alternatives

were eliminated from further consideration in the FEIS because the anticipated impacts from the

alternative actions would be similar to those resulting from components of the alternatives that are carried

forward for additional analysis in this FEIS.

Alternate paces of development within each alternative were eliminated from further analysesin this FEIS

because it was determined that providing this information within each alternative introduced a level of

complexity which made it difficult for the public and decision-makers to assess potential impacts across

the full range of alternatives. Two development rates (250 and 75 wells drilled per year) are carried

forward as parts of specific alternatives analyzed in this FEIS, and with these analyses a sufficient range of

resource effects (e.g., LOP, air quality, socioeconomics) is provided.

Other Alternatives Considered and Eliminated from Detailed Analysis

Many suggestions for alternatives were proposed by the public during scoping. Most of the suggested

alternatives involved addressing varying well numbers, varying the rate at which the field is developed,
16

and varying surface disturbance. While not all the suggested well number, development rate, or surface

disturbance suggestions were analyzed, the BLM used these suggestions when developing the range of

alternatives.

An alternative rejecting any new development was also suggested. This was not considered reasonable,

as additional development in the area would likely occur from non-federal activities (e.g., State of

Wyoming land development), over which BLM has no authority. The No Action Alternative sufficiently

considers no new development impacts (see FEIS, Section 2.4.1).

Action alternatives limiting the total number of wells were rejected from consideration based upon known

natural gas reservoir properties indicating that an estimated 3,100 additional wells would be necessary for

adequate resource recovery. Additional justification for eliminating these alternatives from detailed

analyses is provided in the FEIS, Section 2.2.3.1.

Phased development alternatives suggesting a development pace slower than 75 wells per year were

rejected from detailed analyses because the reduced development pace would result in recovery and

operational and safety issues associated with drilling through depressurized zones (i.e., stuck pipe, mud

weight variability problems, blow-out potential). It was determined that the analyzed development paces

of 75 and 250 wells drilled per year provide an adequate range of development pacesto assessthe potential

effects associated with development rate (e.g., socioeconomics, duration of habitat loss). Phased

development alternatives involving systematic extraction of resourcesfrom portions of the JIDPA followed

by appropriate reclamation prior to developing other areas of the JIDPA were not provided detailed

analyses due to the potential for disproportionate adverse effects on resource recovery within some

leaseholds (see also FEIS, Section 2.2.3.1). Allowing mineral resources to remain unrecovered would

result in waste and prevent BLM from achieving its statutory and policy goals.

Two alternatives requiring all new wells to be directionally drilled and requiring no new roads were not

specifically analyzed in detail because Alternative B has a similar potential effect (i.e., no new well pads,

few new roads needed).

An alternative rejecting all further development in the JIDPA until all existing disturbance in the area is

adequately reclaimed was not considered since this action would likely lead to considerable unrecovered

resource and would unnecessarily prolong the LOP.

Numerous alternatives requiring the inclusion/exclusion of multiple resource protection, mitigation, and

monitoring measures were suggested for analysis, including the application of best management practices

(BMPs), the use of adaptive management procedures, and consideration of off-site CM (see FEIS,

Chapter 5). Some of these additional measures have been included as components of the Proposed Action

and Preferred Action alternatives and/or may be included as project requirementsin the ROD. Many if not

all of these suggested requirements are considered under one or more of the alternatives analyzed in detail

(see also Appendices A and C of the FEIS for BLM standard mitigations, Operator-committed measures,

and CM ideas).

ENVIRONMENTALLY PREFERRED ALTERNATIVE

In accordance with Council on Environmental Quality (CEQ) regulations (40 CFR 1505.2(b)), the

environmentally preferred alternative must be identified in the Record of Decision.
17

BLM considers the environmentally preferred alternative for the Jonah Infill Drilling Project to be the No

Action Alternative. This alternative would result in the least amount of impact to a majority of resources

within the Jonah Field. However, the No Action alternative would also fail to effectively recover known

oil and gas resources. Therefore, the BLM Preferred Alternative was selected.

APPEAL PROCESS

This decision may be appealed to the Interior Board of Land Appeals, Office of the Secretary, in

accordance with the regulations contained in 43 CFR 3165.4. If an appeal is filed, your notice of appeal

must be filed in this office (Bureau of Land Management, State Director, P.O. Box 1828, Cheyenne,

Wyoming 82003) within 30 days of the date BLM publishes their notice of the decision in the Federal

Register. The appellant has the burden of showing that the decision appealed from is in error.

If you wish to file a petition pursuant to 43 CFR 3165.4(c) for a stay (suspension) of the effectiveness of

this decision during the time that your appeal is being reviewed by the Board, the petition for a stay must

accompany your notice of appeal. A petition for a stay is required to show sufficient justification based on

the standards listed in 43 CFR 3165.4(c). Copies of the notice of appeal and petition for a stay must also

be submitted to the Interior Board of Land Appeals and to the Rocky Mountain Regional office of the

Solicitor at the same time the original documents are filed with this office. If you request a stay, you have

the burden of proof to demonstrate that a stay should be granted.
18
19

ERRATA

Modifications and Corrections to the

Jonah Infill Drilling Project Final Environmental Assessment

The section describes changes to the FEIS to correct errors or omissions and identify modifications.

Modifications

1. Abstract, page i, 3

rd

paragraph, line 6, change to read “Above a certain level of authorized

development, the several Operators have committed to establishing a fund...”. This statement is

corrected to reflect that all Jonah Field Operators have not committed to compensatory mitigation.

2. Executive Summary, page iii, Proposed Action, 1

st

paragraph, line 8, change to read “The Several

Operators have committed to various mitigation...”. This statement is corrected to reflect that not all

Jonah Field Operators have committed to compensatory mitigation.

3. Executive Summary, page v, BLM Preferred Alternative, 1

st

paragraph, line 1, change to read “(i.e.,

achieved 80% indigenous vegetative basal cover/density and species composition meets reclamation

performance objectives). Under no circumstances...”. This statement is corrected to reflect final

reclamation strategy.

4. Chapter 1, Section 1.3, page 1-4, delete 1

st

paragraph and allsix bullets beginning with “The proposed

development meets the purpose and need...to plan usesthat encourage energy conservation” from this

section and insert in Section 1.5.3, page 1-10, between paragraph 3 (beginning “The Notice of Intent

(NOI) for this EIS...”) and paragraph 4 (beginning “Specifically, the proposed project is in

conformance with...”). This change better organizes the information presented.

5. Chapter 1, Section 1.5.3, page 1-10, paragraph 3, change line 6 to read “...PFO RMP as updated by

the ROD for the Pinedale Anticline Oil and Gas Exploration and Development Project (BLM 2000c)

if development at the proposed level is approved.” Thisstatement is modified to reflect current Interior

Board of Land Appeals decisions.

6. Chapter 2, Section 2.3.1.1, page 2-9, Water, change 1

st

bullet to read “Operators would maintain or

restore groundwater and surface water...”. This bullet is changed to clarify Operators responsibilities

with regards to the Clean Water Act and Wyoming Department of Environmental Quality (WDEQ)

standards.

7. Chapter 2, Section 2.3.1.1, page 2-10, Reclamation, delete 1

st

bullet that begins “Operators would

submit to BLM for approval a reclamation plan...”. This requirement is unnecessary since a

reclamation plan is included in the FEIS and monitoring will be accomplished by the JIO.

8. Chapter 2, Section 2.4.5, page 2-18, BLM Preferred Alternative, 2

nd

paragraph, line 7, change to read

“(i.e., achieved 80% indigenous vegetative basal cover/density and species composition meets

reclamation performance objectives). Under no circumstances...”. This statement is corrected to

reflect final reclamation strategy.
20

9. Chapter 2, Section 2.4.5.2, page 2-22, delete 7

th

bullet from top of page beginning “Operators would

utilize closed drilling systems (no reserve pits)...”. This bullet is unnecessary in light of defined

development plans and procedures and surface disturbance management strategy.

10. Chapter 2, Section 2.4.5.2, page 2-23, delete 2nd bullet from top of page beginning “Operators would

periodically demonstrate that potential impacts...”. This bullet is unnecessary in light of air quality

mitigation requirements included in this ROD.

11. Chapter 2, Section 2.4.5.2, page 2-24, delete 5

th

bullet and both sub-bullets regarding “Minimum

reclamation requirements would be:” and replace with the following bullet and sub-bullets:

• Reclamation objectives will be:

o Rollover reclamation credit requires establishment of viable site-stabilizing plant growth

(e.g., resistant to wind and water erosion) and a plant community that approximates

surrounding or ecologically comparable vegetative composition to the maximum extent

possible.

o Final reclamation requires a range ofspecies composition, diversity, cover and production

equal to pre-disturbance levels.

12. Chapter 2, Section 2.4.5.2, page 2-24, change 7

th

bullet to read “Operators would voluntarily seek

opportunities to participate in and support published...”. This change clarifies a best management

practice.

13. Chapter 2, Section 2.4.5.3, page 2-25, modify the 5

th

bullet to read “Institute nighttime lighting/glare

restrictions (e.g., install light shades/hoods, directional lighting, colored lights, wattage limits, motion

detectors; extinguish all unnecessary lighting during non-working hours), consistent with Occupational

Safety and Health Administration requirements.”

14. Chapter 3, Section 3.1.6.2, subsection “Groundwater Use”, page 3-43, paragraph 1, change line 7 to

read: “...Map 4.1). No groundwater irrigation occurs in the JIDPA or CIAA Some irrigation occurred

within the JIDPA to support experimental reclamation procedures.”

15. Chapter 5, Section 5.1.1, page 5-2, paragraph 1, change line 1 to read “The following actions could

further reduce overall cumulative emissions, which in turn...”.

16. Chapter 5, Section 5.1.2, subsection “Visibility”, page 5-5, paragraph 3, change line 7 to read “...as

soon as possible to no days with an impact greater than or equal to 1 deciview (dv).”

17. Appendix B, Subappendix DP-B, page DP-B-3, Section DP-B-2.1, 2

nd

paragraph, change line 1 to

read “The reclamation success standards objectives provided in Section DP-B-2.2 are the measures

will be used to develop specific reclamation success criteria that will show whether or not these goals

are being met.”

18. Appendix B, Subappendix DP-B, page DP-B-3, Section DP-B-2.2, delete text from entire Section

beginning with “The following reclamation successstandards are...” and ending with “...standards 1-

5, 6d, 6e, 6f, and 7 have been achieved.” Replace with the following:
21

“BLM will use two separate criteria for reclamation success in the JIDPA; rollover and release. When

the rollover criteria are achieved acreage will be credited back to the Operators against the 46%

surface disturbance ceiling. When the release criteria are achieved the Operators will be released from

final bond obligation.

The specific objectives of rollover reclamation criteria include site stabilization (e.g., resistant to wind

and water erosion) and establishment of a plant community that approximates surrounding or

ecologically comparable vegetative composition, to the maximum extent possible.

Reclamation success standards for bond release will meet the objectives of species composition,

diversity, cover and production levels equal to pre-disturbance levels.

In general, success standards may require a range of species composition, diversity and cover

requirements based on varying conditions and/or locations. To deal with these unknowns, specific

success criteria will be developed by the JIO, with public participation, and approved by the BLM.

Final determination concerning whether or not a reclaimed area meetsthe rollover or release standards

will be made by the Authorized Officer for the BLM.

19. Appendix B, Subappendix DP-B, Section DP-B-4.1.2.2, page DP-B-10, paragraph 1, change line 11

to read “Temporary reclamation (see Section DP-B-4.3) would be implemented immediately on all

topsoil and spoil stockpiles that would be in place more than 6 months.” This change clarifies these

requirements.

20. Appendix B, Subappendix DP-B, Section DP-B-5.4, page DP-B-27, paragraph 1, change line 2 to read

“...monitored qualitatively (annually and after large rainstorms or snow melt runoff events).” This

change clarifies these requirements.
22
APPENDIX A

JONAH INFILL DRILLING PROJECT ADMINISTRATIVE

REQUIREMENTS, CONDITIONS OF APPROVAL, AND

MITIGATION
A-1

APPENDIX A

JONAH INFILL DRILLING PROJECT ADMINISTRATIVE

REQUIREMENTS, CONDITIONS OF APPROVAL, AND MITIGATION

All approved actions within the Jonah Infill Drilling Project Area (JIDPA) may include all or some of the

following Conditions of Approval (COAs), administrative requirements, mitigation requirements, and/or

Best Management Practices (BMPs).

Authorizing Actions

JIDPA Operators are responsible for adhering to all applicable federal, state, and local laws and/or

regulations and for obtaining all necessary federal, state, and county permits. Absent specific revisions in

this ROD, Operators will comply with the management objectives, COAs, and mitigation measures

identified in the BLM Pinedale RMP ROD (BLM 1988b) and BLM Green River RMP ROD (BLM

1997b) to the extent feasible and practicable.

Land Use/Surface Disturbance

1. Surface disturbance is limited to 46% of the JIDPA at any given time, or a maximum of

14,030 acres. Disturbance will be tracked on an operated-acreage basis. Within six (6) months of

the approval of the ROD, all JIDPA Operators shall provide the Authorized Officer the lease

number and legal description for all acres they operate, including those acreagesthey individually

operate and those co-operated with others.

2. Credit will be applied to the surface disturbance ceiling for operated acreages on an acre-for-acre

basis for areas the BLM considers to have met reclamation objectives (see FEIS Appendix B,

Reclamation Plan).

3. Total cumulative field-wide surface disturbance is limited to a maximum of 20,334 acres over the

life of the project (LOP).

4. Operators will track surface disturbance acreage and provide BLM and the JIO with Federal

Geographic Data Committee (FGDC)-compliant metadata and geographic information system

(GIS)/global positioning system (GPS) location data for all newly developed facilities and

reclaimed areas within 30 days of completion of disturbance and/or reclamation activities.

5. By January 31 each year, the Operators will provide the JIO and Authorized Officer annual

operating plans that include the following information:

a. all previous year activity to include number of wells drilled, total new surface disturbance by

well pads, roads and pipelines, and current status of all reclamation activity; and

b. plan of development for the upcoming year to include planned number of wells to be drilled

and an estimate of new surface disturbance and reclamation activity.

6. Operators will inventory all roads/trails in the JIDPA not already inventoried by BLM within

1 year of the ROD for this project; GIS data will be provided to BLM and the JIO with
A-2

FGDC-compliant metadata. Operators will initiate coordination with the JIO prior to

implementing this action.

7. Well pad surface disturbance will not exceed 7.0 acres for parent and multi-well pads, 4.0 acres

for single-well pads, and 2.0 acres for satellite well pads, unless the Operator can demonstrate to

the satisfaction of the Authorized Officer on a case-by-case basis that the size limitation for a

given pad would create a significant safety concern for the workers, the public at large, or the

environment. These acreages include cut-and-fill slopes, but do not include access roads and

pipelines.

8. All new development and production facilitiesin the JIDPA will be placed at centralized locations

to accommodate multiple wells, unless proven to the satisfaction of the Authorized Officer on a

case-by-case basis that centralization of development and production facilities would not be

technically or economically feasible, or that another method would create less environmental

impact. The Operators will centralize existing development and production facilitiesto the extent

economically feasible.

9. Centralized fracturing processes will be required for all well pads when surface density is  1 well

pad/40 acres, and recommended when well pad surface density is < 1 pad/40 acres, unless the

Operator can demonstrate to the satisfaction of the Authorized Officer that centralized fracturing

is not reasonable or technically or economically feasible, or that another well completion

procedure would create less surface impact.

10. Where technically and economically feasible, and at the earliest possible date, Operators will

begin piping produced water and condensate from all wells in the JIDPA to an appropriate

condensate collection point or sales line and an appropriate produced water treatment, disposal, or

centralized transportation facility. Analyses must be provided within one (1) year of the ROD.

11. Operators are encouraged to use closed loop drilling systems for all drilling operations within the

JIDPA. A closed-loop drilling system shall be used in the following circumstances:

a. the well is completely or partially drilled using oil-based drilling mud;

b. a groundwater aquifer is suspected or known to occur within 50 feet of the pre-disturbance

ground surface (in the event groundwater is not encountered within 50 feet of the surface

when the hole for the conductor pipe is drilled, the Operator may revert to a reserve pitsystem

for this well);

c. there is not sufficient area due to terrain features (deep drainages, cliffs, steep slopes, etc.) at

the proposed well pad site for a pad with reserve pit;

d. there is not sufficient area due to (fill in the blank the constraining value [i.e., critical wildlife

habitat (describe), unmitigatable culturalresource site, etc.]) at the proposed well pad site for

a pad with a reserve pit.

12. Operators will remove/vacuum fluids from reserve pits within 60 days from well completion or

they must notify the Authorized Officer. In all cases, fluids will be removed as soon as practical.

13. Surface-disturbing activities shall not be conducted on slopes in excess of 25 percent or within

500 feet of surface water and/or riparian habitat.
A-3

14. No well pad, road, or other construction shall be conducted in or with frozen materials, or during

periods when the soil is saturated, or when watershed damage is likely to occur.

15. No surface occupancy will be allowed within 300 feet of Sand Draw.

Air Quality

1. Tier II or equivalent diesel engine emission technologies will be required for all drill rigs at the

earliest possible date.

2. The BLM will work cooperatively with state and other federal agencies, and with industry, to

track emissions in the Pinedale Field Office area.

a. BLM will track numbers of wells, numbers of drill rigs, drilling emissions, and compressor

stations.

b. The Wyoming Department of Environmental Quality, Air Quality Division (WDEQ–AQD)

will continue to track permitted emissions.

c. Operators will provide BLM with information on their drill rigs, including drilling days,

horsepower, load factors, and emission factors within 10 days of the completion of drilling

operations for each well.

3. Operators will demonstrate by January 31 each year that emission reductionsfrom the Jonah Infill

Drilling Project will reduce the potential impact to visibility as follows:

a. Demonstration Period: Operators in the JIDPA will begin a 12-month demonstration period

beginning with the signing of the ROD. In correspondence with BLM, WDEQ affirmed the

State’s position that BLM “require the use of Tier II diesel technology on drill rigs used in the

Jonah area at the earliest possible date” (WDEQ 2005). Because preliminary modeling

conducted for the DEIS indicated that emissions from engines for drilling rigs would have to

be further reduced to attain the air quality goals stated above, BLM treats emission factorsfor

Tier 2 engines (EPA 1998) as a reference point for the minimum control of emissions during

the demonstration period. Operators in the Jonah and Pinedale fields have suggested several

technologies that could achieve emissions lower than Tier 2. As part of this demonstration

period, the Operators in the Jonah field will conduct emission tests on various drilling engine

technologies as defined in a plan to be developed by the Operator(s) and approved byWDEQAQD. The results from this demonstration period will be provided to WDEQ as soon as

possible, but no later than 1 year after the ROD is signed. WDEQ will then consider the

emissions testing data in the determination of the appropriate Best Available Technology

(BAT) for the engines associated with all drilling operations. Until such time as the WDEQAQD establishes appropriate BAT standards, Operators will be required to demonstrate that

the impact levels from the proposed project will be less than the impact levels of the 80%

emission reduction scenario as described in FEIS Section 4.1.2.5 and AQTSD Appendix G,

Section G-2. Within 90 days of the ROD, the Operators will submit a plan to BLM that

describes in detail how the potential impacts will be minimized.

b. Implementation Period: All Operators will comply with WDEQ-established BAT standards.
A-4

c. In the absence of WDEQ-established BAT standards, the Operators will submit annual

operating plans that report the emissions from all emitting units in order to demonstrate that

the potential visibility impact from the proposed project will be less than the potential

visibility impact levels of the 80% emission reduction scenario described in FEIS

Section 4.1.2.5 and AQTSD Appendix G, Section G-2, at a minimum, and to demonstrate

that any potential visibility impact decreases as soon as possible to no days with an impact

greater than or equal to 1 deciview (dv).

d. Based upon emissions data collected during the demonstration period, BLM may run an air

dispersion model, comparable to the model run for the AQIAS, to reassess air quality impacts.

BLM, in conjunction with the JIO, will use the results of the model to assess whether

emission controls in the JIDPA adequately control emissions to achieve the air quality goals.

Annually thereafter, BLM will determine whether an additional model run is necessary based

upon field-wide emissions or a comparable indicator selected by BLM (in cooperation with

the JIO). Operators should continue to innovate by demonstrating and using new techniques

for controlling emissions after the demonstration period.

e. The method by which the Operators will demonstrate potential project visibility impact will

be determined by BLM in consultation with WDEQ, EPA, USFS, and National Park Service

(NPS). BLM will rely on the Operators to determine how they will attain the reduction in

potential visibility impacts from the Jonah Infill project.

f. BLM’s performance objective for visibility will be attained if actual visibility monitored by

the Bridger Wilderness IMPROVE aerosol sampler complies with the reasonable progress

goal of the Wyoming Regional Haze State Implementation Plan.

4. In cooperation with the JIO established under the ROD, BLM will review ozone data collected in

the area. If in the future air monitoring were to show ozone exceedances attributable at least in

part to sources in the Jonah field, BLM will consult with WDEQ-AQD, EPA, USFS, and NPS to

determine whether adaptive management would be needed to mitigate impacts.

5. BLM will continue to work cooperatively with WDEQ, EPA, USFS, and NPS to maintain and

enhance concentration, atmospheric deposition, and visibility monitoring in the Pinedale Field

Office area. The BLM and cooperating agencies will contribute technical expertise and financial

resources to maintaining and enhancing air quality monitoring. The Operators will fund and

participate in a joint industry/state/federal monitoring agreement to maintain and enhance air

quality monitoring.

Wildlife

Monitoring & Inventory

1. Operators will monitor nesting of raptors, including ferruginous hawk, bald eagle, and burrowing

owl; greater sage-grouse lek attendance; and occurrence of othersagebrush-obligate species within

the JIDPA in coordination with Authorized Officer and the JIO.

2. Operators will inventory greater sage-grouse seasonal habitats within the JIDPA not already

inventoried by BLM or WGFD within 1 year after signing of the ROD for this project; GIS data

would be provided to the Authorized Officer with FGDC-compliant metadata. Operators

would initiate coordination with the Authorized Officer and JIO prior to implementing this action.
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3. Operators will coordinate with the Authorized Officer and JIO to review and revise the Jonah Wildlife

Monitoring and Protection Plan within 1 year of the ROD for this project.

Raptors

1. Well pads, access roads, and other aboveground facilities will not be located within 825 feet of an

active raptor nest, within 1,000 feet of an active ferruginous hawk nest, or within 2,640 feet of any

bald eagle nest.

2. The following seasonal restrictions for surface-disturbing activities near active raptor

nests/roosting sites/foraging areas will be imposed: (see Appendix A, Table A.3, of the FEIS)

3. February 1 through July 31, within 0.5 mile of all active raptor nests;

4. February 1 through July 31, within 1.0 mile of all active ferruginous hawk nests;

5. February 1 through August 15, within 1.0 mile of all active bald eagle nests;

6. November 1 through April 1, within 1.0 mile of active bald eagle communal winter roosts; and

7. November 1 through April 1, within 1.0 mile of winter forage areas.

Sage Grouse

1. Surface-disturbing and disruptive activities in greater sage-grouse winter habitat will be avoided

from November 15 through March 14.

2. Surface-disturbing and disruptive activities in greatersage-grouse nesting and early brood-rearing

habitat within 2.0 miles of an occupied lek, or in identified greater sage-grouse nesting and early

brood-rearing habitat outside the 2.0-mile buffer will be prohibited from March 15 through

July 15.

3. Surface disturbance and occupancy will be prohibited within 0.25 mile of the perimeter of greater

sage-grouse leks, and human activity in these areas will be avoided between 8 p.m. and 8 a.m.

from March 1 through May 15.

4. Compressor stations will be sited at least 2.0 miles away from greater sage-grouse leks and no

closer than 0.5 mile to an active raptor nest.

Soils/Water

1. A groundwater monitoring program for all water wells in or affected by activities in the JIDPA

will be implemented. The following specifics apply:

a. Water wells will be tested annually for static water level, general chemical constituents as

determined by the Authorized Officer, and total petroleum hydrocarbons, using WDEQapproved methods. Annual reports will be provided to the JIO, BLM (Authorized Officer),

WDEQ, and WSEO by January 31.
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b. Water withdrawal volumes from all water wells utilized within the JIDPA will be monitored

and annual depletion reports provided to the JIO, BLM (Authorized Officer), WSEO, and

U.S. Fish and Wildlife Service (USFWS) by January 31 each year.

2. Hydraulic structures (culverts, bridges, low water crossings, silt traps, catchments, retention

dams, etc.) placed in existing, natural drainage courses will be engineered and designed by a

certified civil engineer to ensure the structures are stable and erosion is minimized. Cross-drain

structures installed outside existing, natural drainage courses will not require certified civil

engineer design.

3. All well pads, roads, pipelines, and other facilities will be engineered and constructed to minimize

sediment discharge onto adjacent undisturbed land or down-channel from the JIDPA and to meet

WDEQ stormwater discharge requirements.

4. Operators would provide copies of their Spill Prevention, Control, and Countermeasure (SPCC)

plans and Storm Water Pollution Prevention Plans (SWPPPs) to the BLM upon request.

5. Stormwater and snowmelt water would be held on the JIDPA for as long as possible to allow for

infiltration and to reduce surface flow velocity and associated sediment loads using geofabrics,

jute netting, spreader dikes, retention ponds, additional armoring of existing watercourses, or other

appropriate techniques.

Transportation

1. Operators will continue to encourage limiting the speed of all vehicles operated by the

leaseholder, Operator, or Operator agents in the JIDPA, and will implement voluntary fugitive

dust control measures on primary access roads and heavily used resource roads.

2. Project-required traffic in the JIDPA is limited to BLM-approved roads. Operators will continue

to cooperate with the BLM to identify and prohibit use of two-tracks where ROWs have not been

obtained.

3. Operators will utilize remote telemetry or equivalent technology at all wells to minimize well

monitoring trips, unless proven to the satisfaction of the Authorized Officer on a case-by-case

basis that installation of remote telemetry or equivalent technology would not be technically or

economically feasible, or that another method would create less environmental impact.

Paleontological Values Protection

1. Operators will suspend all operations if previously undetected vertebrate fossil materials are

discovered during surface-disturbing activities. Operations will not resume until authorization to

proceed is granted by the Authorized Officer.

Reclamation

1. Operators will maximize interim (production phase) well pad reclamation by recontouring to the

drilling rig anchor pins and reclaiming/revegetating to within 20 feet of the wellhead, or to within

20 feet of the wellhead, facilities, tanks, and spill containment structures on those pads with

production facilities. The initiation of interim reclamation will commence within 30 days after the
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last well scheduled on a pad is put into production. In the event that more than 1 year would lapse

between the drilling of wells on a pad, the Authorized Officer may require temporary site

stabilization measures.

2. Operators will accelerate reclamation of disturbed areas using innovative seed mixtures and

application techniques, supplementing natural precipitation with sprinkler irrigation at key times,

and/or other practices as approved by the Authorized Officer.

3. Operators will undertake aggressive invasive plant species and noxious weed control or removal

in disturbed areas, be responsible for weed control on all disturbed areas in the JIDPA, and be

responsible for consultation with the Authorized Officer and/or local authorities for acceptable

weed control methods. Where applicable, a “Pesticide Use Proposal” (Form WY-04-9222-1),

surfactant material safety data sheet(s), and maps and/or legal descriptions of the area to be treated

will be submitted by the Operator to the Authorized Officer no later than December 1 for use the

following spring/summer.

4. The following reclamation objectives will be used to determine success of reclamation. Final

determination concerning whether or not a reclaimed area meets the rollover or release standards

will be made by the Authorized Officer for the BLM.

a. Rollover reclamation credit requires establishment of viable site-stabilizing plant growth

(e.g., resistant to wind and water erosion) and a plant community that approximates

surrounding or ecologically comparable vegetative composition to the maximum extent

possible.

b. Final reclamation requires a range of species composition, diversity, cover and production

equal to pre-disturbance levels.

5. Wildlife habitat evaluations using Habitat Evaluation Procedures (HEP) and Habitat Suitability

Indices (HSI) for appropriate species will be developed within 1 year of the ROD and will be

used to evaluate impacts to habitat and the effectiveness of reclamation and mitigation.

6. Operators will restore those portions of pads not needed for production operations to as close to

original contours as practical during interim reclamation to minimize or eliminate the need to redisturb those reclaimed areas when wells are plugged and abandoned.

7. Operators will employ appropriate topsoil storage and replacement technology and proceduresto

ensure soil viability and plant rooting potential are maintained.

Noise

1. Operators will utilize flareless completions for all wells within the JIDPA unless proven to the

satisfaction of the Authorized Officer on a case-by-case basis that flareless completion operations

would not be technically or economically feasible or would be unsafe, and that WDEQ hasissued

a permit to conduct well completion flaring for that specific well.

2. As directed on a case-by-case basis by the Authorized Officer, Operators will monitor the

representative noise levels of drilling, cementing, and completion operations 30 feet from the

well pad boundary and provide monitoring data to the Authorized Officer within 30 days of the

data collection for the establishment of noise impact charts.
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3. Operators will monitor noise at noise-sensitive resource locations, as determined by the

Authorized Officer, and annually report results to the Authorized Officer and JIO.

Night Lighting

1. On a site-specific basis, nighttime lighting/glare restrictions (e.g., install light shades/hoods,

directional lighting, colored lights, wattage limits, motion detectors; extinguish all unnecessary

lighting during non-working hours) may be required, consistent with Occupational Safety and

Health Administration requirements.

Cultural/Historic Resources Protection

1. Operators will suspend all operations if previously undetected archaeological or historical

materials are discovered during surface-disturbing activities. Operations will not resume until

authorization to proceed is granted by the Authorized Officer.

Socioeconomic

1. Operators will provide the BLM with their 3-year operational forecasts for the JIDPA by

January 31 of each year during field development. These forecasts will include estimates of total

drilling activity by year.

Livestock Grazing

1. In coordination with the Authorized Officer and JIO, Operators will:

a. Monitor the effects of livestock on reclamation projects and native vegetation including, but

not limited to, forage utilization and percent composition.

b. Monitor the effects of gas field development on livestock operations (i.e., death loss, forage

quality, etc.).

Visual Resource Management

1. New production facilities would be painted a non-contrasting color which is harmonious with the

surrounding landscape (i.e., shale green, unless otherwise specified by BLM on a case-by-case

basis); existing production facilities would be painted that color at the earliest opportunity, and no

later than when facilities are due for routine repainting.
APPENDIX B

OPERATOR-COMMITTED PRACTICES
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APPENDIX B

OPERATOR-COMMITTED PRACTICES

Existing Jonah project National Environmental Policy Act of 1969 (NEPA) documents (Bureau of Land

Management [BLM] 1998, 2000a) provide various programs and policies that would be implemented to

protect the environment during the development and operation of the proposed Jonah Infill Drilling Project

(JIDP). Unless otherwise noted, each of the measures identified in this appendix have been agreed to by

all the Operators currently working in the Jonah Infill Drilling Project Area (JIDPA). The 15 air qualityrelated measures listed at the very end of this document have been committed to by EnCana Oil & Gas

(USA), Inc., but not yet agreed to by any of the other Operators.

Many of these environmental protection measures would be included as Conditions of Approval (COAs)

in this ROD. However, by additionally including them as Operator-committed practices, the various

Operators have made a commitment to implement them throughout the life-of-project (LOP), and the

impact analyses provided in the JIDP EIS take into consideration the implementation of these measures

based on this commitment.

Where Operator-committed practices differ from and are less rigorous than those provided in previous

NEPA documents, the reason for the change is identified. If deemed appropriate by the applicable

regulatory agency, the more stringent measure will be imposed.

Some of the Operator-committed practices are outside the jurisdiction of BLM. These practices are

identified as italicized text.

In addition to Operator-committed environmental protection practices, the various JIDPA leases often

contain one or more stipulations that obligate the leaseholder. These lease stipulations are mandatory and

address a number of issues, including but not limited to seasonal and area restrictions for raptor nests,

greater sage-grouse leks and nesting habitat, unstable soils, steep slopes, and controlled surface occupancy

(see FEIS Appendix A). These lease-specific stipulations may be duplicated by the more general measures

listed below.

Exceptions to Operator-committed practices may be granted if a thorough analysis by the BLM

determines that the resource(s) for which the measure was developed would not be unacceptably impacted

by the proposed project, or if the Operator can demonstrate to the satisfaction of the Authorized Officer on

a case-by-case basis that the required mitigation or practice would not be technically or economically

feasible, or that another method would create less environmental impact.

To assure compliance with the Operator-committed practices stipulated in the FEIS, this ROD, and in sitespecific APDs and ROWs, each Operator will provide qualified individuals to oversee construction and

drilling operations and to consult with the BLM on a case-by-case basis, as necessary, during field

development.

All of the proposed Operator-committed practices identified in this section will be implemented on all

federal lands and minerals within the JIDPA. Development activities on all lands would be conducted in

accordance with all appropriate federal, state, and county laws, rules, and regulations.
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PRECONSTRUCTION PLANNING AND DESIGN MEASURES

1. Implementation of site-specific projects would be contingent on BLM receiving, for

approval/acceptance, the following plans: APD and ROW Surface Use Plans, Plans of

Development, and other site-specific plans/reports (e.g., road and well pad design plans, cultural

clearances, special status species clearances, etc.); Transportation Plan, Reclamation Plan, and

Hazardous Materials Management Summary (see FEIS Appendices DP-A, DP-B, and DP-C).

The above plans may be prepared by Operators for the JIDPA or may be submitted incrementally

with each APD, ROW application, or Sundry Notice.

2. Approval of individual project components (i.e., wells, roads, pipelines, and ancillary facilities)

would be contingent on completion and acceptance of a site-specific cultural resource literature

search, Class III inventory report, and, as necessary, paleontological inventory; threatened,

endangered, proposed, and candidate (TEP&C) and BLM Wyoming sensitive (BWS) species

surveys; greater sage-grouse lek and nesting clearance; raptor nest clearance; and any other

clearances that are justified for scientific data collection and pertinent to a given project.

3. Operators would include in APD, ROW, or other appropriate permit applications a discussion of

site-specific mitigation and environmental protection measures and a map showing specific

locations where these measures would be implemented. Final locations for these measures would

be confirmed by BLM and the Operators following on-site inspections of project locations.

4. Operators would obtain all necessary federal, state, and county permits, including necessary Spill

Prevention and Control Countermeasure Plans (SPCCPs) and Storm Water Pollution Prevention

Plans (SWPPPs), to ensure that project development occurs in an environmentally responsible

manner.

5. EnCana Oil & Gas (USA) Inc., BP America Production Company, and potentially other

Operators would voluntarily implement an off-site mitigation program in part to offset potential

impacts resulting from the project. As currently identified, these projects may entail pronghorn

migration corridor protection; greater sage-grouse habitat preservation, protection, and

enhancement projects; raptor protection; recreational resource augmentation; conservation

easement development; air quality improvement and Air Quality Related Values(AQRV) projects;

on-the-ground reclamation research with an emphasis on sagebrush; and cultural resource

projects. Potential program projects may be proposed by the public, BLM,state agencies, grazing

permittees, or other entities. Final approval for projects on BLM-administered lands would rest

solely with the BLM. See EnCana Appendix 1, Voluntary Compensatory Mitigation Proposal.

AIR QUALITY

6. Operators would treat primary access roads (e.g., Luman Road, Windmill Road, Burma Road,

and North Jonah Road), and heavily used resource roads as necessary during high use periods,

with dust suppressants (e.g., magnesium chloride) and would water construction sites and well

pad access roads as necessary to control fugitive dust during the summer.

7. No open burning of garbage or refuse would be allowed at the well sites or other facilities.

Any open burning would be conducted under the permitting provisions of Chapter 10, Section 2

of the Wyoming Air Quality Standards and Regulations.
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8. Necessary air quality permits to construct, test, and operate facilities would be obtained from

the Wyoming Department of Environmental Quality/Air Quality Division (WDEQ/AQD).

All internal combustion equipment would be kept in good working order.

9. Operators would comply with all applicable local, state, tribal, and federal air quality laws,

statutes, regulations, standards, and implementation plans, including Wyoming Ambient Air

Quality Standards (WAAQS) and National Ambient Air Quality Standards (NAAQS).

10. Operators would cooperate with WDEQ in determining regional oxides of nitrogen (NOx)

emission levels.

11. Operators would continue to encourage contractors and employees to obey speed limits and

support local law enforcement officials in enforcing speed limits(i.e., 35 miles per hour[mph]) to

reduce fugitive dust concerns, as well as for human health and safety reasons.

12. EnCana Oil & Gas (USA) Inc., BP America Production Company, and potentially other

Operators would cooperate with the implementation of any WDEQ-mandated air quality

monitoring program or emissions control program.

TOPOGRAPHY

13. Operators would incorporate in their Surface Use Plans and Plans of Development the procedures

contained in Standard Practices, Best Management Practices, and Guidelines for SurfaceDisturbing Activities, guidelines for road construction contained in BLM Manual 9113 (BLM

1985, 1991), and project-specific requirements in the Transportation and Reclamation Plans for

this project (FEIS Appendices DP-A and DP-B).

14. Unnecessary topographic alterations would be mitigated by avoiding, where practical, steep

slopes, rugged topography, and ephemeral/intermittent drainages and by minimizing the size of

disturbed areas.

15. Upon completion of construction and/or production activities, Operators would restore the

topography to near pre-existing contours at well pads, roads, pipelines, and other facility sites.

The Operators will comply with the requirements of all WDEQ and U.S. Environmental

Protection Agency (EPA) stormwater erosion control permitting practices.

16. No well pads, roads, pipelines, or other facilities would be built within 300 feet of the edge of

Sand Draw or within the tall sagebrush areas associated with this drainage, except for crossings

that would be done at right angles to the channel, where practical. The number of crossings also

would be minimized.

GEOLOGICAL/PALEONTOLOGICAL RESOURCES

17. At the Operator’s discretion, wells, pipelines, and ancillary facilities would be designed and

constructed such that they would not be damaged by moderate earthquakes. Any facilities defined

as critical, according to the Uniform Building Code, would be constructed in accordance with

applicable Uniform Building Code Standards for Seismic Risk Zone 2B.
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18. In areas of paleontological sensitivity, a determination would be made by the BLM as to whether

a survey by a qualified paleontologist is necessary prior to the disturbance. In some cases,

construction monitoring, project relocation, data recovery, or other mitigation may be required to

ensure that significant paleontological resources are avoided or recovered during construction.

19. If paleontological resources are uncovered during surface-disturbing activities, Operators would

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

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

recovery or avoidance plan. Mitigation of impacts to paleontological resources would be on a

case-by-case basis, and Operators would either avoid or protect paleontological resources.

20. Contractors and their workers would be instructed about the potential of encountering fossils and

the steps to take if fossils are discovered during project-related activities. The illegality of

removing vertebrate fossil materials from federal lands without an appropriate permit would be

explained.

SOILS

21. Operators would adhere to the reclamation guidelines presented in BLM 2004. Adverse impactsto

soils would be mitigated by minimizing disturbance; avoiding construction with frozen soil

materials; avoiding areas with high erosion potential (e.g., unstable soils, dunal areas, slopes

greater than 25%, floodplains), where practical; salvaging and selectively handling topsoil from

disturbed areas; adequately protecting stockpiled topsoil and replacing it on the surface during

reclamation; leaving the soil intact (scalping only) during pipeline construction, where practical;

using appropriate erosion and sedimentation control techniques including, but not limited to,

diversion terraces, riprap, and matting; and promptly revegetating disturbed areas using native

species. Temporary erosion control measures such as temporary vegetation cover; application of

mulch, netting, or soil stabilizers; and/or construction of barriers may be used in some areas to

minimize wind and water erosion and sedimentation prior to vegetation establishment. Specific

measures and locations would be identified in Surface Use Plans, Plans of Development, or

SWPPPs prepared during APD and/or ROW application processes.

22. Pipeline ROWs would be located to minimize soil disturbance. Where practical, mitigation would

include locating ROWs adjacent to access roads to minimize ROW disturbance widths or routing

pipeline ROWs directly to minimize disturbance lengths; direct-line routes may be preferable in

areas with high well pad densities.

23. Appropriate erosion control and revegetation measures would be employed. Grading and

landscaping would be used to minimize slopes, and water bars would be installed on disturbed

slopes in areas with unstable soils where seeding alone may not adequately control erosion.

Erosion control and revegetation efforts would be monitored by the BLM and Operators and

augmented, as necessary, to control erosion and ensure successful establishment of native

vegetation.

24. Sufficient topsoil or other suitable material to facilitate revegetation would be segregated from

subsoils during all construction operations requiring excavation and would be returned to the

surface upon completion of operations. Soils compacted during construction would be ripped and

tilled as necessary prior to reseeding. Cut-and-fill sections on all roads and along pipelines would

be revegetated with native species.
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25. To the extent practical and necessary, Operators would plan new ground-disturbing activities for

periods when soils are not frozen and would work with the BLM on appropriate construction

actions in the event that they are proposed for periods when soil frost depths exceed 6.0 inches.

26. Operators would revegetate all disturbed sites as soon as practical following disturbance.

27. Operators would restrict off-highway vehicle (OHV) activity by employees and contract workers.

28. Project-related travel would be limited to only that necessary for efficient project operation during

periods when soils are saturated and excessive rutting could occur.

29. Reviews of erosion control structures, culverts, reclamation, etc., would be made by Operator

personnel as required by SWPPPs and WDEQ or EPA regulations.

WATER RESOURCES

30. Operators would comply with U.S. Army Corps of Engineers (COE) requirements when

conducting operations in wetlands, riparian areas, open water areas, and ephemeral or

intermittent drainages, where practical. Where ephemeral or intermittent channels would be

crossed by roads, culverts or low-water crossings would be installed at all appropriate locations as

specified in the BLM Manual 9112 – Bridges and Major Culverts (BLM 1990) and Manual 9113

– Roads (BLM 1985, 1991). Channels would be crossed perpendicular (at right angles) to flow,

where practical, and all stream crossing structures would be designed to carry the 25-year

discharge event or other capacities as directed by BLM.

31. All non-recycled water used in association with this project would be obtained from Wyoming

State Engineer’s Office (WSEO)- approved groundwater wells.

32. Operators would adhere to guidelines specified in SPCCPs. Any spill or accidental discharge of

hazardous material would be remediated. An orientation would be conducted by Operators to

ensure that project personnel are aware of the potential impacts that can result from accidental

spills and that they know the appropriate recourse if a spill occurs.

33. Erosion-prone areas (e.g., drainages) or high-salinity areas would be avoided where practical, and

necessary construction in these areas would be done in the late summer, fall, and winter (prior to

soil freezing) to avoid runoff periods. Proper containment of oil and produced water in tanks,

drilling and fracturing fluids in tanks or reserve pits, and the location of staging areas for

equipment storage away from drainages would prevent potential contaminants from entering

surface waters.

34. Prudent use of erosion control measures, including diversion terraces, riprap, matting, temporary

sediment traps, and water bars, would be employed as necessary. Interceptor dikes or waterbars

would be used to control surface runoff generated at well pads, where necessary. Erosion control

and construction methods would be described in APD and ROW plans, if necessary. If water is

discharged into an established drainage channel, the rate of discharge would not exceed the

capacity of the channel to convey the increased flow without creating erosion induced channel

adjustments. Waters that do not meet applicable state or federal standards would be evaporated,

treated, or disposed of at an approved disposal facility.
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35. Operators would construct reserve pits with 2 feet of freeboard in cut areas or in compacted and

stabilized fill. The subsoil material at proposed pit locations would be inspected to assess soil

stability and permeability and whether reinforcement and/or lining are required. Prior to

installation of reserve pit liners and/or fluids, reserve pits may be inspected by BLM personnel.

Unlined earthen reserve pits would be used only after BLM evaluation of the pit location for

distance to surface waters, depth to useable groundwater, soil type and permeability, and

containment fluid content indicate no potential adverse effects to water resources.

36. If reserve pit leakage is detected, Operators would apply appropriate mitigation techniques in

consultation with the BLM.

37. All wells would be cased and cemented to protect subsurface mineral and freshwater zones.

Unproductive wells and wells that have completed their intended purpose would be properly

abandoned and plugged using procedures identified by the Wyoming Oil and Gas Conservation

Commission (WOGCC) and the BLM.

38. Channel crossings by pipelines would be constructed so that the pipe is buried at least 4 feet

below the channel bottom.

39. Channel crossings by roads and pipelines would be constructed perpendicular to flow.

40. Disturbed channel beds would be reshaped to their approximate original configuration.

41. Disposal of all water (hydrostatic test water, stormwater, produced water) would be done in

conformance with WDEQ/Water Quality Division (WQD) (1993), BLM Onshore Oil and Gas

Order No. 7, and WOGCC rules and regulations.

42. Operators would prepare SWPPPs for all disturbances greaterthan 5 acresin size asrequired by

WDEQ National Pollution Discharge Elimination System (NPDES) permit requirements.

43. Operators would implement SPCCPs if liquid petroleum products or other hazardous materials

are stored on-site in sufficient quantities, in accordance with 40 CFR 112.

44. Any disturbances to wetlands and/or waters of the U.S. would be coordinated with the COE, and

Section 404 permits would be secured as necessary prior to disturbance.

45. To mitigate potential impacts caused by flooding during the LOP, construction in flood-prone

areas would be limited to late summer, fall, or winter when conditions are generally dry and flows

are low or nonexistent. Additional mitigation to lessen any impacts from flooding or high flows

during and after construction would include the avoidance of areas with high erosion potential

(i.e., steep slopes, floodplains, unstable soils); reestablishment of existing contours where

practical; avoidance of areas within 500 feet of wetland edges, riparian areas, and open water,

where practical; avoidance of areas within 100 feet of ephemeral drainages, where practical; and

implementation of appropriate erosion and sediment control and revegetation procedures.

46. Increased sedimentation impacts to surface waters would be avoided or minimized through

construction and erosion control practices approved with each authorization and through the

prompt reclamation of disturbances.
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47. EnCana Oil and Gas (USA) Inc., BP America Production Company, and potentially other

Operators would conduct complete water quality analyses as described in EnCana’s Proposed

Groundwater Monitoring Plan (e.g., pH, alkalinity, total dissolved solids [TDS], oil and grease,

benzene) on all newly developed water wells less than 300 feet in depth. Additionally, annual

water quality testing new and existing project-required water wells would be implemented to

detect water quality changes, and in the event adverse changes are noted, Operators would work

with the BLM and the WDEQ if necessary on developing and implementing appropriate

corrective actions. Water well drilling and quality analysis reports would be submitted by

October 1 of each year to the BLM Pinedale Field Office (PFO), WSEO, and WDEQ/WQD for

review.

NOISE

48. All engines and compressor exhaust stacks would be muffled and maintained according to

manufacturers'specifications.

49. Construction, drilling, completion, testing, and production facility installation activities would be

seasonally restricted proximal to active raptor nests during the nesting period and in greatersagegrouse breeding and nesting areas, unless this restriction is unnecessary based upon site-specific

reviews and the BLM grants a waiver or modification.

50. Road use and travel pattern specifications would be designed, in part, to keep traffic to a minimum

and to reduce noise impacts as identified in the Transportation Plan (FEIS Appendix DP-A).

VEGETATION

51. Herbicide applications would be kept at least 500 feet from known BWS plantspecies populations

or other distance deemed safe by the BLM.

52. Removal and disturbance of vegetation would be kept to a minimum through construction site

management (e.g., using previously disturbed areas and existing easements, limiting

equipment/materials storage yard and staging area sizes, etc.). Well pads and associated roads and

pipelines would be located to avoid or minimize impacts in areas of high value (e.g., TEP&C or

BWS species habitats, wetland/riparian areas).

53. Proper erosion and sediment control structures and techniques would be incorporated by

Operators into the design of well pads, roads, pipelines, and other facilities. Revegetation using a

BLM-approved, locally adapted seed mixture containing native grasses, forbs, and shrubs would

begin in the first appropriate season following disturbance. Vegetation removed would be replaced

with plants of similar forage value and growth form using the following procedures:

• fall reseeding (September 15 to freeze-up), where feasible;

• spring reseeding (post-thaw and prior to May 15) if fall seeding is not feasible;

• deep ripping of compacted soils prior to reseeding;

• surface pitting/roughening prior to reseeding;
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• utilization of native cool-season grasses, forbs, and shrubs in the seed mix;

• interseeding of shrubs into an established stand of grasses and forbs at least 1 year after

seeding the grasses and forbs;

• appropriate, approved weed control techniques;

• broadcast or drill seeding, depending on site conditions; and

• fencing of certain sensitive reclamation sites (e.g., riparian areas, steep slopes, and areas

within 0.5 mile of livestock watering facilities) as determined necessary through monitoring.

54. Operators would implement the resource, mitigation, and monitoring measures found in the

Transportation and Reclamation Plans (FEIS Appendices DP-A and DP-B).

55. Recontouring and seedbed preparation would occur immediately prior to reseeding on the unused

portion of well pads and road ROWs and entire pipeline ROWs outside of road ROWs. In the

event of uneconomic wells, Operators would initiate reclamation of the entire well pad, access

road, and adjacent disturbed habitat as soon as practical. Reclamation would be monitored by the

Operators and the BLM, as specified in the Reclamation Plan (FEIS Appendix DP-B), to

determine and ensure successful and timely establishment of vegetation.

56. Traffic would be confined to the running surface of roads and well pads as approved in APDs and

ROWs. Operators have and will continue to cooperate with the BLM to identify and prohibit use

of two-tracks where ROWs have not been obtained.

57. Operators would monitor noxious weed and invasive non-native species of concern occurrence on

the JIDPA and implement a noxious weed/non-native species of concern control program in

cooperation with the BLM and Sublette County to ensure noxious weed and non-native species of

concern invasion does not become a problem. Weed-free certification by county extension agents

would be required for grain or straw used for mulching revegetated areas. Gravel and other

surfacing materials used for the project would be free of noxious weeds.

58. Operators would evaluate all project facility sites for occurrence of waters of the U.S., special

aquatic sites, and wetlands, per COE requirements. All project activities would be located outside

of these areas, where practical.

59. Where wetlands, riparian areas, and ephemeral or intermittent stream channels must be

disturbed, COE Section 404 permits would be obtained if necessary.

WILDLIFE AND FISHERIES

The following practices would be applied for general wildlife protection.

60. Well pads, access roads, pipelines, and ancillary facilities would be located and designed to

minimize disturbances to areas of high wildlife habitat value, including wetlands and riparian

areas.
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61. Areas with high erosion potential and/or rugged topography (i.e.,steep slopes, dunes, floodplains,

unstable soils) would be avoided, where practical.

62. Removal or disturbance of vegetation would be minimized through construction site management

(e.g., by utilizing previously disturbed areas, and existing ROWs where practical, designating

limited equipment/materials storage yards and staging areas, vegetation scalping), and Operators

would adhere to all reclamation guidelines presented in the Reclamation Plan (FEIS Appendix

DP-B).

63. Operators, in consultation with representatives from BLM, Wyoming Game and Fish Department

(WGFD), U.S. Fish and Wildlife Service (USFWS), and other interested groups such as area

livestock operators, would adhere to the Wildlife Monitoring/Protection Plan for this project

(BLM 1998: Appendix D) as annually updated (TRC Mariah 2004). The plan would be

incorporated into the Operator field operations manual or handbook, a copy of which would be

kept on-site in the JIDPA or with Operator personnel when on-site.

64. To minimize wildlife mortality due to vehicle collisions, Operators would continue to advise

project personnel regarding appropriate speed limits (i.e., 35 mph) in the JIDPA, and roads

would be reclaimed as soon as possible after they are no longer required. Some existing roadsin

the area may be closed and reclaimed by Operators as authorized by BLM. Potential increasesin

poaching would be minimized through employee and contractor education regarding wildlife

laws. If violations are discovered, the offending employee or contractor would be disciplined and

may be dismissed by Operators and/or prosecuted by WGFD.

65. Reserve, workover, and evaporation pits and other areas that contain hydrocarbons would be

adequately protected to prevent access by migratory birds and other wildlife.

66. Firearms and dogs would not be allowed on-site during working hours. Operators would enforce

their existing drug, alcohol, and firearms policies.

67. To protect plant populations and wildlife habitat, project-related travel would be restricted to

established project roads; no off-road/ROW travel would be allowed, except in emergencies.

68. Wildlife-proof fencing would be utilized on reclaimed areas if it is determined that wildlife

species and/or livestock are impeding successful vegetation establishment.

69. ROW fencing associated with this project would be kept to a minimum, and fences, where

necessary, would meet BLM and WGFD specifications for facilitating wildlife movement.

70. Potential impacts to fisheries and wetland or riparian areas would be minimized by using proper

erosion control techniques (e.g., water bars, jute netting, rip-rap, mulch). Construction within

500 feet of open water, 300 feet of Sand Draw, and 100 feet of other intermittent or ephemeral

channels would be avoided, where practical. Channel crossings for roads and pipelines would be

constructed during periods of low or no flow (i.e., late summer or fall). All necessary crossings

would be constructed perpendicular to flow. No surface water or shallow groundwater in

connection with surface water would be utilized for the project.

71. Operators would implement policies designed to control poaching and littering and would notify

all employees (contract and company) that conviction of a major game violation could result in
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disciplinary action. Contractors would be informed that any intentional poaching or littering

within the JIDPA may result in dismissal.

The following practices would be applied for raptors.

72. Operator coordination with BLM, USFWS, and WGFD would be conducted for all mitigation

activities related to raptor, TEP&C, and BWS species(and their habitats), and all permitsrequired

for relocation, removal, and/or establishment of raptor nests would be obtained.

73. Well pads, pipelines, and associated roads would be selected and designed to avoid disturbance to

known active raptor nest sites, where practical.

74. Raptor nest surveys would be conducted within a 1.0-mile radius of proposed surface use or

activity areas if such activities are proposed to be conducted between February 1 and July 31.

75. All surface-disturbing activity (e.g., road, pipeline, well pad construction, drilling, completion,

workover operations) would be seasonally restricted from February 1 through July 31 within a

0.5-mile radius of all active raptor nests, except ferruginous hawk nests, for which the seasonal

buffer would be 1.0 mile. (An active raptor nest is defined as a nest that has been occupied within

the past 3 years.) The seasonal buffer distance and applicable exclusion dates may vary,

depending on such factors as the activity status of the nest, species involved, prey availability,

natural topographic barriers, line-of-site distance(s), and other conflicting issues such as cultural

values, steep slopes, etc. Routine maintenance or emergency health and safety activities would be

allowed on existing well pads.

76. Well pads, roads, ancillary facilities, and other surface structures requiring repeated human

presence would not be constructed within 825 feet of active raptor nests (2,000 feet for bald

eagles), where practical. Facility construction in these areas would require specific approval from

the BLM.

77. Operators would notify the BLM, USFWS, and WGFD immediately if raptors are found nesting

on project facilities and would cooperate with the appropriate agencies as necessary to erect

artificial nesting structures.

The following practices would be applied for black-footed ferret.

78. Where practical, surface disturbance in all prairie dog towns would be avoided.

79. Specific requirements for black-footed ferret surveys are no longer specified since the entire

JIDPA is included within an area identified by the USFWS as no longer requiring surveys.

However, if black-footed ferrets are observed, no further project-specific surface disturbance

would occur to the prairie dog complex in which the ferret(s) were observed.

The following measures would be applied for greater sage-grouse, and these measures may be modified,

with Operator approval, to facilitate participation in ongoing greater sage-grouse studies.

80. Operators would avoid all surface disturbance (including pipelines) within 0.25 mile of active

greater sage-grouse leks.
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81. Permanent high-profile structures such as buildings and storage tanks would not be constructed

within 0.25 mile of an active lek.

82. Greater sage-grouse nest surveys would be implemented during the nesting season (April 1–

July 31) by a qualified biologist prior to the start of construction activities in identified greater

sage-grouse nesting habitat within 2.0 miles of active leks, and if an active greater sage-grouse

nest is identified, surface-disturbing activities would be delayed until nesting is completed.

83. Operators would avoid optimal greater sage-grouse nesting habitats, where practical. Optimal

nesting habitat is defined as areas with sagebrush heights of 20–31 inches and cover of 15–25%

and an understory (grasses and forbs) cover of >15%.

84. EnCana Oil and Gas (USA) Inc., BP America Production Company, and potentially other

Operators would avoid all drilling and construction activities during the greater sage-grouse

strutting period (March 1–May 15) on areas within 1.0 mile of active leks.

85. Operators would utilize directional drilling to access resources beneath the 0.25-mile active

greater sage-grouse lek buffers if reserves beneath these locations are deemed economic.

86. Operators would utilize directional drilling to access resources beneath the 600-foot wide (or tall

sagebrush-dominated) buffer associated with the Sand Draw protection areasif deemed economic.

87. Operators would cooperate in ongoing greater sage-grouse studies in the area.

88. Operators would cooperate with the WGFD on existing/new greater sage-grouse habitat

improvement efforts within Upland Game Bird Management Area 7 (e.g., water developments).

89. To further mitigate potential adverse effects to breeding and nesting greater sage-grouse on the

JIDPA, 0.5-mile facility-free buffers would be applied to greater sage-grouse lek 7 south of the

JIDPA for as long as Operators continue to hold the leases for these areas. No features requiring

repeated human presence would be built within this area.

LIVESTOCK/GRAZING MANAGEMENT

90. Reclamation of nonessential areas disturbed during construction activities would be accomplished

in the first appropriate season after well completion. Nonessential areas include portions of the

well pads not needed for production operations, the outslope portions of new road ROWs, entire

pipeline ROWs outside of road ROWs, and all roads and associated disturbed areas at

nonproductive well pads. Operators would repair or replace fences, cattleguards, gates, drift

fences, and natural barriers that are damaged by development actions to maintain current BLM

standards. Cattleguards would be used instead of gates for livestock control on most road ROWs.

Livestock would be protected from pipeline trenches, and livestock access to existing water

sources would be maintained.

91. BLM, in coordination with livestock permittees, would monitor livestock movements, especially

regarding any impacts to livestock from roads or disturbance from construction and drilling

activities. Operators in consultation with the BLM will take appropriate and reasonable measures

to correct any adverse impacts, if they occur.
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92. All pits containing fluids would be fenced to exclude livestock.

CULTURAL RESOURCES

93. Operators would follow the procedures established by the BLM National Programmatic

Agreement/Wyoming State Protocol Agreement (ratified April 1998) for cultural resource

management and regulation contained within 36 CFR 800 and would either avoid, protect, or

mitigate cultural resource properties.

94. Operators would halt construction activities in the area of concern if previously undetected

cultural resource properties are discovered during construction. The BLM would be notified

immediately, and consultation with the Wyoming State Historic Preservation Office (SHPO)

and/or the Advisory Council on Historic Preservation (ACHP) would be initiated to determine

proper mitigation measures pursuant to 36 CFR § 800.13 or other Treatment Plans, Programmatic

Agreements, or Discovery Plans that may direct such efforts. Construction would not resume

until a Notice to Proceed is issued by the BLM.

95. If areas of religious importance, traditional cultural properties, or othersensitive Native American

areas are identified in affected areas, BLM would consult with affected tribes and, in further

consultation with Operators, would identify potential impacts and determine appropriate

mitigative treatments on a case-by-case basis.

96. Operators in cooperation with the BLM would conduct an educational program to inform

employees and contractors about the regulations concerning cultural resource management and

artifact collection.

97. All recognized eligible sites, areas of Native American concern, and other recognized sensitive

areas would be avoided as much as practical during development permitting. Impacts that cannot

be eliminated by avoidance would be mitigated on a case-by-case basis through BLM-approved

and SHPO-approved methods. Mitigation may include data recovery (including excavation)

and/or Native American consultation/coordination for development in sensitive cultural resource

areas, and costs for these efforts would be borne by Operators.

98. Construction in archaeologically sensitive areas during frozen ground conditions would not

normally be implemented; exceptions would be considered by the Authorized Officer on a caseby-case basis.

99. Operators would work with the BLM, SHPO, and ACHP in developing and implementing

appropriate Programmatic Agreements, Research Designs/ Unanticipated Discovery Plans,

Treatment Plans, and/or Cultural Resource Management Plans for the protection of cultural

resources in the JIDPA.

SOCIOECONOMICS

100. Operators would encourage the use of local or regional workers.
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101. Where feasible, Operators would schedule concentrations of project traffic, such as truck

convoys or heavy traffic flows, to avoid periods of expected heavy traffic flows associated with

recreation.

102. Travel and parking would be restricted to access roads and on-site parking areas.

103. Where feasible, Operators would plan proposed development operations so that seasonal

restrictions do not create a significant reduction in the level of development causing seasonal

workforce layoffs (i.e., work continues at a consistent rate year-round).

LAND STATUS/USE/PRIOR RIGHTS

Mitigation to prior rights would include the following:

104. limiting drilling operations to lands leased or owned by the Operators;

105. locating wells away from known underground cables;

106. regrading and repairing roads, as necessary, in areas damaged by project activities;

107. reestablishing a level compacted surface where pipelines cross existing roads;

108. advance identification and flagging of all existing ROWs that would be crossed by proposed

pipelines and roads;

109. backhoe and hand excavating at pipeline crossings until the exact locations of existing

underground lines have been determined; and

110. restoring native vegetation as soon as practical.

111. Roads and pipelines would be located adjacent to existing linear facilities wherever practical;

direct-line routes may be preferable in areas with high well pad densities.

112. Portions of existing roads not included in the new road ROW and not needed by other users

would be reclaimed and revegetated by Operators, following ClassIII cultural resource surveys.

113. Adequate turnouts on new crowned-and-ditched roads would be built to provide access to

existing two-tracks and other undeveloped roads.

RECREATION

114. Operators would inform their employees, contractors, and subcontractors that long-term

camping (greater than 14 days) on federal lands or at federal recreation sites is prohibited.

115. Operators would direct their employees, contractors, and subcontractors to abide by all state

and federal laws and regulations regarding hunting.
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VISUAL RESOURCES

116. EnCana Oil and Gas (USA) Inc., BP America Production Company, and potentially other

Operators would utilize existing topography to screen roads, pipeline corridors, drill rigs, wells,

and production facilities from view, where practical.

117. Operators would paint all aboveground production facilities with appropriate colors(e.g., Shale

Green or other environmental color required by BLM) to blend with adjacent terrain, except for

structures that require safety coloration in accordance with Occupational Safety and Health

Administration (OSHA) requirements.

TRANSPORTATION

118. Operators would implement the resource, mitigation, and monitoring measures found in the

Transportation Plan (FEIS Appendix DP-A). Annual transportation planning would occur in

coordination with efforts required for the Pinedale Anticline Project (BLM 2000b) to identify

the minimum road network necessary to support annually proposed project activities; Operator

construction and maintenance responsibilities; and road-specific dust abatement, construction,

and surfacing requirements.

119. Existing roads would be used to the maximum extent possible and upgraded as necessary.

120. All new and improved roads not required for routine operation and maintenance of producing

wells or ancillary facilities would be reclaimed as directed by the BLM, State Land Board, or

private landowner. These roads would be permanently blocked, recontoured, reclaimed, and

revegetated by Operators, as would disturbed areas associated with permanently plugged and

abandoned wells. Reclamation of existing two-track roads would be considered on a case-bycase basis.

121. On a case-specific basis, centerline survey and construction designs would be submitted to and

approved by the BLM prior to road construction.

122. Operators would comply with existing federal,state, and county requirements and restrictionsto

protect road networks and the traveling public.

123. Special arrangements would be made with the Wyoming Department of Transportation to

transport oversize loads to the project area. Otherwise, load limits would be observed at all

times to prevent damage to existing road surfaces.

124. All development activities along approved ROWs would be restricted to areas authorized in the

approved ROW.

125. Available topsoil would be stripped from all road corridors prior to commencement of

construction activities and would be redistributed and reseeded on backslope areas of the

borrow ditch after completion of road construction activities. Borrow ditches would be reseeded

in the first appropriate season after initial disturbance.
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126. When practical and feasible, the Operators would maximize the use of temporary fresh water

pipelines during late spring, summer, and early fall from water wells to active drill sites to

decrease water hauling needs.

HEALTH AND SAFETY/HAZARDOUS MATERIALS

127. Operators would utilize WDEQ-approved portable sanitation facilities at drill sites.

128. Operators would place warning signs near hazardous areas and along roadways.

129. Operators would place dumpsters at each construction site to collect and store garbage and

refuse.

130. Operators would ensure that all refuse and garbage is transported to a state-approved sanitary

landfill for disposal.

131. Operators would institute a Hazard Communication Program for its employees and would

require subcontractor programs in accordance with OSHA (29 CFR §1910.1200).

132. In accordance with 29 CFR §1910.1200, a Material Safety Data Sheet for every chemical or

hazardous material brought on-site would be kept on file at the Operator’s field office.

133. SPCCPs would be written and implemented in accordance with 40 CFR §112.

134. Chemical and hazardous materials would be inventoried and reported in accordance with

40 CFR §335. If quantities exceeding 10,000 pounds orthe threshold planning quality are to be

produced or stored, the appropriate Section 311 and 312 forms would be submitted at the

required times to the State and County Emergency Management Coordinators and the local fire

departments.

135. Any hazardous wastes, as defined by the Resource Conservation and Recovery Act of 1976

(RCRA), as amended, would be transported and/or disposed of in accordance with all

applicable federal, state, and local regulations.

136. Operators would adhere to existing internal health and safety policies and procedures.

137. During routine operations, Operators would not release fracturing fluids and condensatesinto

flare pits or surrounding areas; they would be confined in lined pits or tanks.

ADDITIONAL AIR QUALITY MEASURES

Unlike the measures listed in the preceding sections, the following 15 air quality-related measures have

been committed to by EnCana Oil and Gas (USA), but not yet agreed to by any of the other Operators in

the JIDPA.

1. Regular equipment maintenance, including emissions checks, and regular maintenance of roads

would be conducted as necessary throughout the LOP.
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2. Operators would treat primary access roads (e.g., Luman Road, Windmill Road, Burma Road,

and North Jonah Road in the JIDPA) and heavily used resource roads as appropriate with dust

suppressants (e.g., magnesium chloride) and would water construction sites and well pad access

roads as necessary to control fugitive dust during the summer.

3. No open burning of garbage or refuse would be allowed at the well sites or other facilities.

Any open burning would be conducted under the permitting provisions of Chapter 10, Section 2

of the Wyoming Air Quality Standards and Regulations.

4. Necessary air quality permits to construct, test, and operate facilities would be obtained from the

Wyoming Department of Environmental Quality/Air Quality Division (WDEQ/AQD). All internal

combustion equipment would be kept in good working order.

5. Operators would comply with all applicable local, state, tribal, and federal air quality laws,

statutes, regulations, standards, and implementation plans, including Wyoming Ambient Air

Quality Standards (WAAQS) and National Ambient Air Quality Standards (NAAQS).

6. Operators would cooperate with BLM and WDEQ in determining regional oxides of nitrogen

(NOx) emission levels.

7. Operators would continue to encourage contractors and employees to obey speed limits and

support local law enforcement officials in enforcing speed limits(i.e., 35 miles per hour[mph]) to

reduce fugitive dust concerns, as well as for human health and safety reasons.

8. Operators would cooperate with the implementation of any legally enforceable WDEQ-mandated

air quality monitoring program or emissions control program.

9. By January 1, 2006, EnCana commits to achieve average drilling rig emissions equivalent to Tier

1 standards or better from 100% of EnCana operated or contracted drilling rigs in the Jonah

Field.

10. By January 1, 2007, EnCana commits to achieve average drilling rig emissions equivalent to Tier

2 standards or better from 100% of EnCana operated or contracted drilling rigs in the Jonah

Field.

11. By January 1, 2009, EnCana commits to achieve average drilling rig emissions equivalent to Tier

3 standards or better from 100% of EnCana operated or contracted drilling rigs in the Jonah

Field.

12. By January 1, 2006, EnCana commits to capture on average through flareless completion

techniques, 90% of the hydrocarbon and combustion emissions that would have previously been

emitted by flaring during flowback procedures on EnCana operated natural gas wells.

13. Where practical and feasible, EnCana commits to reduce traffic and surface disturbance and

associated dust and tailpipe emissions by utilizing hub and spoke drilling and completion

techniques, centralized fracturing operations, and centralized condensate and water collection.

14. Wherever possible, EnCana commits to vertically drill all EnCana operated natural gas wells in

the Jonah Field in order to reduce associated NOx

, SO2, and PM10 emissions.
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15. Where feasible, EnCana commits to establish plant cover for all areas disturbed by EnCana’s

operations within an agreed time period using accelerated and focused reclamation efforts,

stabilized soil stockpiles, using mulch and geotextile fabrics to stabilize soils, if necessary, and

watering areas under construction to reduce fugitive dust emissions.
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REFERENCES

Bureau of Land Management. 1985. Manual 9113-Roads. Engineering Rel. 9-247. U.S. Department of

the Interior, Bureau of Land Management.

. 1988. Record of Decision and Resource Management Plan for the Pinedale Resource Area.

U.S. Department of the Interior, Bureau of Land Management, Pinedale Resource Area, Rock

Springs District, Rock Springs, Wyoming. 118 pp.

. 1990. Bureau of Land Management Manual Section 9112.

. 1991. Wyoming Supplement to the Bureau 9113 Manual. U.S. Department of the Interior,

Bureau of Land Management, Wyoming State Office, Cheyenne, Wyoming. 16 pp.

. 1998. Record of Decision for Jonah Field II Natural Gas Project, Environmental Impact

Statement, Sublette County, Wyoming. Bureau of Land Management, Pinedale and Green River

Resource Areas, Rock Springs District, Rock Springs, Wyoming.

. 2000a. Decision Record and Finding of No Significant Impact for the Modified Jonah Field II

Natural Gas Project, Sublette County, Wyoming. Bureau of Land Management. Pinedale Field

Office, Pinedale, Wyoming, and Rock Springs Field Office, Rock Springs, Wyoming.

______. 2000b. Record of Decision, Environmental Impact Statement for the Pinedale Anticline Oil and

Gas Exploration and Development Project, Sublette County, Wyoming. Bureau of Land

Management, Wyoming State Office, Cheyenne, Wyoming, and Pinedale Field Office, Pinedale,

Wyoming. BLM/WY/PL-00/026+1310. RODEIS-00-018. 53 pp. + append.

. 2004. Jonah Infill Drilling Project Development Procedures Technical Support Document.

U.S. Department of the Interior, Bureau of Land Management, Pinedale and Rock Springs Field

Offices. Pinedale and Rock Springs, Wyoming.

TRC Mariah Associates Inc. 2004. 2003 Wildlife Studies, Jonah Field II Natural Gas Development

Project. Prepared for U.S. Bureau of Land Management, Pinedale Field Office, Pinedale,

Wyoming, Rock Springs Field Office, Rock Springs, Wyoming, and Jonah II Area Operators, by

TRC Mariah Associates Inc., Laramie, Wyoming.

Wyoming Department of Environmental Quality, Water Quality Division. 1993. Water QualityRules and

Regulations. Chapter I. Wyoming Department of Environmental Quality, Water Quality

Division. 87 pp.
APPENDIX C

ADAPTIVE MANAGEMENT IN THE JONAH INFILL DRILLING

PROJECT AREA
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APPENDIX C

ADAPTIVE MANAGEMENT

IN THE JONAH INFILL DRILLING PROJECT AREA

Introduction

The Bureau of Land Management (BLM) will implement an adaptive management process for the Jonah

Infill Drilling Project Area (JIDPA) that will follow the framework described in this appendix.

To implement this process, the Jonah Interagency Mitigation and Reclamation Office (JIO) is established

and will operate as described below and in the JIO Charter (Attachment C-1) and Escrow Agreement

(Attachment C-2).

The potential value of adaptive management to the National Environmental Policy Act (NEPA) processis

discussed by Carpenter (1997)

1

and is strongly supported by a number of agencies at the national level,

including BLM, U.S. Environmental Protection Agency (EPA), and U.S. Department of Agriculture

Forest Service (USFS). Carpenter summarized as follows: “It is increasingly recognized that human

interventions into natural systems seldom proceed as originally planned. Scientific uncertainties prevent

environmental impacts from being reliably or precisely predicted. Thus, the style of management must

provide for monitoring to guide mid-course corrections in adapting to inevitable surprises.” Council on

Environmental Quality (CEQ) NEPA regulations require continual monitoring.

2

Purpose and Need

In addition to the uncertainties about how natural systems will react to human interventions, it has become

apparent that current development guidelines and Conditions of Approval, and the restriction of 1 well

pad/40 acres (16 well pads/640-acre section) authorized in the Modified Jonah Field II Project Area, are

not adequate protection for some JIDPA resources. However, national demand makesit imperative that as

much natural gas as possible be recovered from the JIDPA. Project proponents are continually striving to

develop drilling and production mitigation technologies to lessen the impacts of natural gas recovery, but

those technologies are largely untested. There is uncertainty regarding the short- and long-term

effectiveness of these new technologies, as well as uncertainty regarding the effectiveness of the

mitigations and management restrictions established in this ROD. These uncertainties require that a

number of assumptions be used to predict the impacts associated with infill development; those

assumptions may or may not be partially or wholly correct, which means the impact analysis may or may

not be partially or wholly correct. Also, considering the expected level of impacts associated with proposed

development, a significant off-site mitigation program will be necessary.

Uncertainty regarding the accuracy of the predictive assumptions and models used in the impact analysis,

and uncertainty regarding how the environment will react to future development in the JIDPA using

current and future untested development and mitigation technologies and untried restrictions, creates a

need for a mechanism through which BLM can make incremental adjustments to field management over

time, as information is gained about how area resources are reacting to new technologies and/or

restrictions. That mechanism is adaptive management.
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The adaptive management process allows for changes in management without further NEPA analysis,

unless designated thresholds are reached. The process increases the speed at which managers learn how

resources react to their decisions and development activities, and thereby increases the speed at which

managers can adjust mitigation and management restrictions for unanticipated impacts, or lack thereof.

The adaptive management framework has several continuous steps: decision is implemented; impacts are

monitored; monitoring data are evaluated; modifications to mitigations or management restrictions are

recommended, based on monitoring data; adaptive management decision is made and implemented;

impacts are monitored; etc.

The purpose of this adaptive management process is to ensure that impacts of development and production

are monitored, and the information from that monitoring is evaluated and incorporated, on a regular basis,

into future mitigation and management decisions. One of the purposes of the JIO is to implement this

adaptive management process in the JIDPA, as well as select and manage all off-site mitigation projects.

Goals and Objectives

• Determine the effects of JIDPA development on area resources;

• Determine the effectiveness of the mitigation measures contained in this ROD;

• Suggest modifications to mitigation measures to achieve the stated goals/objectives;

• Assure oil and gas-related BLM decisions regarding the JIDPA are coordinated with non-oil-andgas-related decisions (such as grazing, recreation, etc.);

• Provide a rapid response to unnecessary and undue environmental degradation;

• Validate predictive models used in the EIS and revise the models/projections as necessary based

on field observations and monitoring;

• Accurately monitor and predict cumulative impacts through BLM maintenance of a Geographic

Information System (GIS) for the JIDPA, including all activities (natural gas, agricultural,

recreational, etc.) on federal and non-federal lands and how they are affecting area resources;

• Provide guidance for monitoring upon which the need to initiate Section 7 consultation with the

U.S. Fish and Wildlife Service (USFWS) will be determined.

Implementation Model

BLM will implement and coordinate the adaptive management process. The BLM Pinedale Field Manager

will accomplish that by establishing the interagency JIO in the project ROD. The JIO will be staffed by

full-time employees or contractors from BLM, Wyoming Department of Environmental Quality (WDEQ),

Wyoming Game and Fish Department (WGFD), and Wyoming Department of Agriculture (WDA).

Details on JIO objectives and duties are included in the JIO Charter (Attachment C-1).

JIO Functions

The JIO will be fully staffed by the agencies as soon as possible following issuance of this ROD.

The scope of work for the JIO is as described in the JIO Charter (Attachment C-1).
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JIO Operating Procedures

It is anticipated the JIO will be necessary for the next 5 to 15 years, with funding support provided by

EnCana Oil & Gas (USA), Inc. Office oversight will be provided by an Agency Managers Committee

consisting of individual agency heads or representatives from BLM, WDEQ, WGFD, and WDA. The

Committee will meet at least once per year to provide senior-level guidance, evaluate past progress, and

review staffing levels and future needs.

In accordance with an escrow agreement between the Wyoming Wildlife and Natural Resource Trust

Account Board (an instrumentality of the State of Wyoming) and the Jonah Interagency Office Charter

Members, the Board will receive and hold all compensatory mitigation funding provided by Jonah

Operators (Attachment C-2). As the entity charged with selecting, implementing, and monitoring offsite

mitigation, the JIO will maintain an accurate accounting of all compensatorymitigation fund expenditures

and provide the Agency Managers Committee an annual financial report.

Specific JIO operational procedures will be developed by the office staff to meet defined goals and

objectives.

____________________________

1 Carpenter, R.A. 1997. “The Case for Continuous Monitoring and Adaptive Management Under NEPA.”

In Environmental Policy and NEPA. R. Clark and L. Canter, eds. Boca Raton, FL: St. Lucie Press.

2 CEQ regulations require appropriate application of continual monitoring and assessment. Section 102(2)(B) of NEPA

calls for “methods...which will insure that presently unquantified environmental amenities and values may be given

appropriate consideration.” CEQ regulations at 40 CFR 1505.2(c) and 1505.3(c) state, “a monitoring and enforcement

program shall be adopted and summarized where applicable for any mitigation” and that agencies “may provide for

monitoring to assure that their decisions are carried out and should do so in important cases.” The lead agencymust, “upon

request, inform cooperating or commenting agencies on progress in carrying out mitigation measures which they have

proposed and which were adopted by the agency making the decision,” and, “upon request, make available to the public the

results of relevant monitoring.”












APPENDIX D

U.S. FISH AND WILDLIFE SERVICE

CONCURRENCE LETTER












































APPENDIX E

SUMMARY OF PUBLIC COMMENTS ON THE JONAH INFILL

DRILLING PROJECT FEIS AND BLM’S RESPONSES
E-1

APPENDIX E

SUMMARY OF PUBLIC COMMENTS ON THE JONAH INFILL

DRILLING PROJECT FEIS AND BLM’S RESPONSES

Any person who participated in the EIS process and had an interest that may be adversely affected could

comment on the FEIS for the JIDP. Comments had to be filed with the BLM within 30 daysfrom the date

the EPA published the Notice of Availability of the FEIS in the Federal Register. The comment period

began January 13, 2006 and closed on February 13, 2006. Organizations and individuals who submitted

comments on the JIDP FEIS during this time are identified in Table E.1.

Table E.1. Organizations and Individuals Submitting Comments on the JIDP FEIS

Organization

(Cooperating Organization)

Signer

(Additional Signer)

BP America Production Co. David R. Brown, Manager, Regulatory Affairs-HSSE

Biodiversity Conservation Alliance (BCA)

(Center for Native Ecosystems)

Suzanne H. Lewis

(Jacob Smith)

C.E. Brooks & Assoc., P.C. (Brooks) Constance E. Brooks

City of Rock Springs, WY Timothy A. Kaumo, Mayor

EnCana Oil and Gas (USA) Inc. (EnCana)

John Schopp, Vice President, North Rockies Business

Unit

Gene R. George Associates, Inc. Gene R. George, Wyoming Regulatory Issues Agent for

Yates Petroleum Corp.

Tyler H. Vanderhoef, Wyoming Regulatory Issues Agent

for Yates Petroleum Corp.

Independent Petroleum Assoc. of Mountain States (IPAMS) Andrew Bremner, Director of Government Affairs

Jonah Field Livestock Grazing Permittees

(Hittle Land and Livestock)

(Rendezvous Ranch)

(Don Rodgers Jr.)

(John and Joy Erramouspe)

KC Harvey, LLC, Soil & Water Resources Consult. (Harvey) Kevin Harvey, Principal Scientist

Douglas J. Dollhopf, Associate Scientist

Petroleum Association of Wyoming (PAW) Ericka S. Cook, Vice President

Photon-field Engineering Ronald P. Walker

Public Lands Advocacy Claire M. Moseley, Executive Director

Robert Swigle, LLC Robert Swigle

Rocky Mountain Energy Reporter Geraldine Minick, Publisher

Roughrider Power Kit Jennings

State of Wyoming, Office of the Governor David Freudenthal, Governor

State of Wyoming, Office of the State Treasurer Cynthia Lummis, State Treasurer

Sublette County, Board of County Commissioners Betty Fear, Chairman

Sweetwater Economic Development Association Patricia Robbins, Director

Town of Pinedale, Wyoming Rose Skinner, Mayor

U.S. Energy Corporation/ Crested Corporation Keith G. Larsen, CEO
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Table E.1. Continued

Organization

(Cooperating Organization)

Signer

(Additional Signer)

U.S. Environmental Protection Agency Robert E. Roberts

Wyoming Contractors Assoc. Charles E. Ware, Executive Vice President

Wyoming Outdoor Council Bruce Pendery

(Jackson Hole Conservation Alliance) (Tom Darin)

(Center for Native Ecosystems) (Jacob Smith)

(Greater Yellowstone Coalition) (Lloyd Dorsey)

(The Wilderness Society) (Peter Aengst)

(Biodiversity Conservation Alliance) (Suzanne Lewis)

(Environmental Defense) (Jana Milford)

(Trout Unlimited) (Cathy Purves)

(National Wildlife Federation,) (Michael Saul)

(Upper Green River Valley Coalition) (Linda Baker)

(Wyoming Wildlife Federation) (Dave Gowdey)

Individuals

Andrikopoulos, Judy K. & John G. Hunkins, Raymond B.

Berg, Eric M. Kinnison, Allan

Bousman, Cotton MaGee, Jim

Clark, Ronald Peckler, Matthew K.

Dibrito, Larry Reints, Lloyd

Donham, Rita Reimers, Rebecca

Dunn, Duane Reynolds, Stephen A.

Henderson, Leslie F. Swigle, Robert

Hendricks, Curtis L. White, Monte

Issue Summary

Comments on the JIDP FEIS raised a variety of issues, including the protection of local and regional air

quality, the protection of cultural resources, livestock grazing within the JIDPA,socioeconomic impacts of

the JIDP on local communities, wildlife impacts, reclamation activities, BLM’s legal responsibilities, and

adequacy of oil and gas reservoir estimates. Significant comments and BLM responses, categorized by

resource or resource use, are summarized below.

Air Quality

Several comments stated that the BLM had no authority to regulate air quality emissions. Several other

comments expressed the concern that the BLM had not detailed how it would regulate air quality. In

general BLM responded to all these comments similarly: “BLM recognizes that WDEQ has the authority

and responsibility to regulate air quality. As the lead federal land manager, BLM has the authority and

responsibility to set management guidelines for potential air quality impacts from BLM activities.”
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Several comments expressed technical concerns regarding air quality data, monitoring information, the

appropriateness of dispersion modeling, and the scientific correctness of model assumptions and

methodologies. These comments received responses similar to the following: “BLM maintains that

dispersion modeling results are defensible and not inconsistent with available monitoring data. The Jonah

air quality model was developed cooperatively by an interagency team of experts.”

A few comments expressed concerns regarding monitoring of air quality. A typical response to these

comments was that “BLM recognizes that better data might improve model predictions, and better

document air quality. BLM, in consultation with the interagency air quality team and the JIO, may

consider installation of additional air quality monitoring stations.”

Other air quality issues include the need for additional monitoring locations, adding the Dinosaur National

Monument as a sensitive receptor, double counting of emissions, visibility impacts, and funding for

monitoring and BLM’s annual monitoring budget.

Reclamation

Several comments were received concerning the method to be used to determine successful reclamation

within the JIDPA and questioning feasibility of the metric that required “80% basal cover/density.” The

need to fairly allocate allowable disturbance to each leaseholder was also raised. BLM responded to these

comments by recognizing the need for equitable distribution of disturbance on an “operated-acreage basis”

and to establish separate “rollover” and “release” reclamation objectives.

In addition to these comments, the use of the word “restoration” instead of “reclamation,” and the need for

site-specific soil salvage requirements was identified in comments.

The pace of development and the need for Operators to provide baseline studies and inventories was

identified as a BLM function that was being transferred to the Operators. BLM responded by “recognizing

that published research was voluntary” and that “inventories were necessary to establish baseline

conditions.”

Livestock and Grazing

One comment suggested that loss of grazing preference and purchase of lands for off-site mitigation could

result in Sublette County completely losing its agricultural base and therebymake the county dependent on

the oil and gas industry. BLM responded, “BLM addresses loss of grazing preference in the FEIS and this

ROD. Losses will be mitigated though adaptive management. Effects to livestock grazing and local

socioeconomic structures are considered in the FEIS. Outright land purchase is not contemplated at this

time.” Furthermore, “The intent of mitigation of loss of wildlife habitat through compensatorymitigation

is not to displace agricultural uses or operators, including the grazing of livestock.”

Compensatory Mitigation and the Jonah Interagency Office

Several comments stated that BLM could not require compensatory mitigation. BLM responded to these

comments similar to the following, “Compensatory mitigation is a voluntary program, but once industry

agrees that they will follow this path, it does become part of the mitigation that is considered part of the

implementation of the decisions.” Other comments suggested that the JIO duties and procedures were not

fully described, that BLM was improperly delegating its authority, and that there was no plan for
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dissolving the JIO or overseeing JIO activities. All of these comments were addressed by referring the

commenter to the JIO Charter in Appendix F of the FEIS.

A single comment requested that local government entities be allowed to have a member included in the

JIO staff. BLM responded to this request “The BLM intends to conduct outreach and offer regular

opportunities for local governments and other groups to participate and be informed in proceedings at the

JIO. Addition to or contraction of the office members is not specifically addressed.”

Laws, Regulations and Policies

Numerous comments stated that the FEIS was inadequate, or did not properly follow the law. These

comments alleged violation of BLM mandates under the Federal Land Policy and Management Act

(FLPMA), inadequate range of alternatives, failure to provide for multiple use of the public lands,

incomplete cumulative impacts analysis, and inadequate prevention of undue and unnecessary degradation.

BLM does not believe that these comments are valid and further that the agency has complied with the

public land laws and polices in all cases.

Reservoir Management

BLM received two comments that the recoverable reserve loss calculation in the FEIS, as a result of

requiring directional drilling, was in error. BLM responded to both comments that “BLM believes the

commenter’s analysis is flawed. BLM technical experts have reviewed and concur with the recovery

numbers used in the FEIS, based on available data.” Other comments were received on closed loop drilling

systems and on mitigation requirements under the Energy Policy Conservation Act.

Socioeconomics

One comment questioned the effects of JIDP development on local governments’ infrastructure capacity.

The BLM maintains it has properly disclosed and analyzed socioeconomic impacts of the various

alternatives in the FEIS.

Wildlife

Several comments were received that alleged violation of FLPMA for failure to disclose impacts to

wildlife. BLM disagrees with the comments that assert improper application of public land laws, including

FLPMA. The BLM also “recognizes that the density of development underway and proposed for the Jonah

Field results in impacts that cannot be mitigated within the field,” so that off-site mitigation is the primary

option for wildlife mitigation. Again, the JIO will help to oversee monitoring and mitigation efforts and

provide guidance for the development. One comment requested that the U.S. Fish and Wildlife Service

Letter of Concurrence be included in the ROD. This has been done.