ENVIRONMENTAL CONSEQUENCES 

CHAPTER 4 
4.0 Environmental Consequences 

The vertical line in the margin identifies text that has been modified in this Final EIS and

differs from the corresponding text in the Draft EIS 

4.1 Analysis Assumptions and Analysis Guidelines 

Assumptions 

1. Overland Pass’ construction and operation methods and environmental protection measures contained in 

the Construction, Reclamation, and Revegetation Plan (Appendix C) would be implemented on federal 

lands, and similar procedures would be used on non-federal lands, with the primary differences identified 

in Chapter 2.0 and Appendix A. Individual landowners may include specific construction and reclamation 

requirements in ROW agreements with Overland Pass. These requirements would likely result in similar 

or less environmental impacts than discussed in this section. 

2. Overland Pass would acquire all necessary federal, state, and local permits and approvals to construct 

and operate the Overland Pass Pipeline system (but not including powerlines, which would be controlled 

and operated by power companies), regardless of whether the requirements for these permits and 

approvals are listed in this document. 

Guidelines 

1. For the Proposed Action and all alternatives, the term “Construction Phase” is defined fully in Chapter 2.0. 

Activities in this phase include the surface-disturbing activities needed to construct the pipeline, pump 

stations, meter stations, pigging facilities, valves, and permanent access roads so that the entire pipeline 

system can be placed into service. It also includes reclamation activities for areas where the surface has 

been disturbed. 

2. For the Proposed Action and all alternatives, the term “Operation Phase” is defined fully in Chapter 2.0. 

Activities in this phase include transportation of NGLs in the Overland Pass Pipeline system. This 

definition also includes normal operations; routine pipeline ground and aerial inspections; emergency 

response activities; future routine internal and external integrity inspections and repairs along short 

segments of the entire pipeline; and future remedial restoration activities such as reseeding and repair of 

erosion control structures. 

3. Prior to abandonment, Overland Pass would coordinate with appropriate federal and state management 

agencies to ensure that abandonment procedures follow agency-approved procedures at that time. 

4. For all resources, unless specific exceptions are stated, short-term impacts are those that would occur 

over a 5-year period or less, while long-term impacts are those that exceed 5 years.

5. Overland Pass’ committed environmental protection measures included in their draft POD were used to 

evaluate environmental impacts. Key applicant-committed measures are identified in Appendix A, 

Table A-1. Several site-specific plans that are part of the applicant’s draft POD have been included as an 

appendix to the EIS. Other specific plans are not attached but are referred to in this document and can be 

found on the BLM website as technical reference reports (www.blm.gov/wy/st/en/info/NEPA/rfodocs/ 

overland_pipeline.html). The POD is currently a draft document that will be finalized by Overland Pass 

and submitted to BLM for review and approval after completion of a Final EIS. 

4.1-1
6. Additional mitigation measures contained in the EIS are recommendations and are summarized in 

Appendix A, Table A-2. If the project was approved, the Authorized Officer would determine which 

mitigation measures would be added as stipulations in any ROW grant that BLM would grant for the 

project. 

7. Applicability of key applicant-committed mitigation measures is identified in Appendix A, Table A-1. 

Unless specifically stated, additional mitigation measures recommended by the BLM (Appendix A, 

Table A-2) would be applicable to federal lands only. 

4.1-2
4.2 Climate and Air Quality 

4.2.1 Proposed Action 

Construction Phase 

Issues 

• Construction dust generation. 

• Construction equipment pollutant emissions. 

Analysis 

In addition to the new NGL pipeline, Overland Pass plans to construct three pump stations (including one 

future pump station) and seven meter stations as listed in Table 2.1-1. The proposed pipeline project would 

generate air emissions through short-term construction activities. Emissions from all phases of construction 

would be subject to applicable state and federal air regulations. The air emissions potentially resulting from 

construction of the proposed compression facilities and presented in this report represent worse-case 

scenarios based on currently available equipment. 

Construction of the proposed pipeline and pump stations would result in intermittent and short-term fugitive 

emissions. The average daily uncontrolled fugitive dust emissions for a typical pipeline spread (4 miles per 

day) are estimated at 1430 pounds per day using an emission factor of 1.2 tons per acre per month for 

construction activities (USEPA 1995). By applying water as a control measure, the potential emissions may be 

reduced by 50 to 80 percent, resulting in actual emissions of approximately 700 – 300 pounds per day. 

Emissions would be restricted to the brief construction period along each stretch of the pipeline route. 

Construction impacts would diminish once construction activities end and after disturbed areas are reclaimed. 

These emissions would include dust from soil disruption and combustion emissions from the construction 

equipment. The fugitive dust emissions would depend on the moisture content and texture of the soils that 

would be disturbed. However, emissions from construction are not expected to cause or significantly contribute 

to a violation of an applicable ambient air quality standard because the construction equipment would be 

operated on an as-needed basis during daylight hours only. Emissions from the gasoline and diesel engines 

would be minimized because the engines must be built to meet the standards for mobile sources established 

by the USEPA mobile source emission regulations (Title 40 CFR Part 85). In addition, the USEPA is requiring 

that the maximum sulfur content of diesel fuel for highway vehicles be reduced from 500 ppmw to 15 ppmw 

beginning June 1, 2006, making lower sulfur diesel available nationwide. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

The procedures proposed by Overland Pass are sufficient to minimize impacts to air resources. 

Operation Phase 

Issues 

• Operational emissions. 

4.2-1
Analysis 

The proposed pipeline project includes long-term operation of the stationary emission units at the pump 

stations. The pumps are electric and therefore do not emit any emissions. Emergency flares would be the only 

source of emissions at the proposed pump stations. The emergency flares are used when a blow down of the 

pipeline is necessary. Blow downs occur only during emergency situations and are not required for routine 

maintenance of the pump station. 

Emissions from operation would be subject to applicable state and federal air regulations. Potential emissions 

would be less than the PSD major source thresholds of 250 tpy for all criteria; therefore, the project sources 

would not be subject to PSD permitting. and are not expected to have a significant impact on air quality. As 

such, dispersion modeling is not required under the federal construction permitting program. Overland Pass 

would not need to obtain air permits for the proposed pump stations. The facilities associated with this project 

would be located in attainment or maintenance areas; therefore, the project sources would not be subject to 

NNSR permitting. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

No operational impacts to air quality are expected. 

4.2.2 No Action Alternative 

Under the No Action Alternative, the BLM would reject Overland Pass’ application to construct the pipeline as 

proposed and the project would not be constructed. Because natural gas extraction in the region would 

continue and associated NGL production is expected to exceed existing pipeline capacity, other pipeline 

projects may be proposed in the future. 

When viewed in its entirety, the proposed Overland Pass proposed pipeline route is a fairly direct route from 

NGL supply sources to delivery points in Kansas. Other pipeline routes that would achieve the stated purpose 

and need of the project likely would be of similar or longer in overall length. Consequently, other future 

pipelines would have similar or greater impacts to air quality during construction and operation due to the 

additional length of pipe and pump power sources with similar or greater emissions. 

4.2.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

The Southern Energy Corridor – Copper Ridge Bypass Alternative would be 4.8 miles greater in length than 

the Proposed Action. As a result, there would be an increase in the emissions and dust during construction. 

However, the overall change in length represents less than a 1 percent change for the entire route and 

therefore would not result in significant overall differences between the alternatives. 

The Southern Energy Corridor – Copper Ridge Bypass Alternative would not require additional pumps or 

pump stations to be constructed. The alternative would, however, require 42.5 hp, compared to the 30 hp 

required by the Proposed Action. Despite this difference in horsepower, no change in air quality is anticipated 

because the pump stations would be electric-powered. 

4.2-2
4.3 Geology 

4.3.1 Proposed Action 

4.3.1.1 Physiography and Geology 

Construction Phase 

Issues 

• Disturbances to topography. 

Analysis 

The effects of construction would include disturbances to the topography along the ROW and at aboveground 

facilities due to grading and trenching activities. Upon completion of construction, Overland Pass would restore 

topographic contours and drainage patterns as closely as possible to the pre-construction condition. 

Blasting potentially could adversely impact the geologic and physiographic environment. Limited blasting could 

be required in areas where shallow bedrock or boulders were encountered that could not be removed by 

conventional excavation with a trackhoe trencher, ripping with a bulldozer followed by trackhoe excavation, or 

hammering with a trackhoe-attached device (hoe-ram) followed by excavation. Blasting is more likely to be 

required in areas where hard bedrock is near the surface. 

Overland Pass’ construction specialists reviewed the proposed pipeline route and estimate that blasting may 

be necessary along approximately 21.6 miles (3 percent) of the proposed pipeline route. Based on the 

proposed construction spreads, the areas where blasting may be required are identified in Table 4.3-1. 

Table 4.3-1 Areas Containing Shallow Bedrock where Blasting may be Required 

State County Location (RP) 

Length of Area Containing 

Shallow Hard Bedrock 

(miles) 

Wyoming Lincoln, Sweetwater 0.0 – 45.0 1.3 

Sweetwater 45.0 – 103.0 3.5 

Sweetwater, Carbon 103.0 – 147.0 3.5 

Carbon, Sweetwater 147.0 – 194.0 3.8 

Carbon 194.0 – 196.0 0.6 

Carbon 196.0 – 208.0 4.2 

Carbon, Albany 208.0 – 281.0 0.7 

Wyoming/Colorado Albany, Weld 281.0 – 330.0 3.9 

Project Total 21.6 

Blasting operations could damage nearby structures, including buildings, springs and wells, and existing

underground pipelines. Blasting is not expected to be conducted in close proximity to known springs. 

Additional Mitigation

No additional mitigation was identified. 

4.3-1
Conclusion 

The construction techniques proposed by Overland Pass are largely sufficient to minimize impacts and restore 

surface contours. However, agricultural lands that rely on flood irrigation may have overland flow of water 

disrupted by the pipeline trench, even after compaction and restoration (Section 4.4.1). 

Overland Pass developed a blasting plan as part of their draft POD that incorporates notification and 

monitoring requirements (Overland Pass 2007). While blasting could adversely affect nearby structures, 

springs and wells, and existing underground pipelines that may be in the vicinity, Overland Pass has 

committed to repair or fairly compensate landowners for damage to these features. Based on Overland Pass’ 

proposed procedures and committed mitigation, no significant adverse impacts would be anticipated from 

blasting activities. 

Operation Phase 

Issues 

• No issues associated with geological resources were identified with operation. 

Analysis 

Operation of the proposed pipeline and associated aboveground facilities would not materially alter the 

geologic and physiographic conditions or worsen existing unfavorable geologic conditions in the area. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

No significant adverse impacts to geological resources would be anticipated. 

4.3.1.2 Mineral Resources 

Construction Phase 

Issues 

• Potential interference with existing mining operations. 

Analysis 

Construction activities along the proposed ROW could interfere with current mining or mineral extraction 

activities. As shown in Tables 3.3-2, the proposed pipeline route crosses numerous oil and gas fields. In 

addition, the proposed pipeline route crosses or is close to areas of known trona mining, coal resources, and is 

close to active sand and gravel quarries (Table 3.3-3). Nevertheless, construction would have very minor and 

short-term impact on current mineral extraction activities due to the temporary and localize nature of pipeline 

construction activities. 

No oil and gas wells were identified within the proposed pipeline construction ROW. However, blasting 

operations potentially could damage nearby oil and gas wells, and trenching could encounter underground 

gathering pipelines associated with the wells. Because oil and gas generally is produced from depths of more 

than 1,000 feet, construction of the pipeline would not be expected to affect the ability of the wells to produce 

oil and/or natural gas. Rather, any construction-related damage that could occur would be limited to surface or 

near-surface components of the wells and gathering systems, which could temporarily disrupt production until 

4.3-2
repairs were made. Potential affects of blasting on nearby wells would be mitigated by implementing Overland 

Pass’ Blasting Plan (Overland Pass 2007). Prior to construction, Overland Pass shall identify any associated 

underground pipelines in the project construction ROW and take appropriate precautions to protect the 

integrity of such facilities. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Potential impacts to surface mining operations, if any, would be limited to temporary short-term encumbrances 

during construction and would be minimized by Overland Pass working with the owners and/or operators of 

these mining operations during ROW negotiations and facilities construction to minimize conflicts where 

mineral resources could be affected. Because construction of the pipeline would be limited to near-surface 

disturbance, the proposed project would not impact oil and gas production in the area or other underground 

resource recovery operations, such as trona. 

Operation Phase 

Issues 

• Potential for reduced access to underlying minerals. 

• Potential interference with future mining operations. 

• Potential damage to pipeline and ancillary facilities from mine-induced subsidence. 

Analysis 

Long-term operation of a pipeline has the potential to preclude access to mineral resources. Overland Pass 

recognized the potential conflicts with trona mining and re-routed around leased areas where mining is 

anticipated in the foreseeable future, thereby reducing the potential for future conflicts with trona mining 

(Section 2.3.3.3). 

Placement of a pipeline over underground mining operation could place the pipeline at risk for surface 

subsidence to result in damage to the pipeline, aboveground facilities, and interruption of service. Since most 

of the proposed pipeline route is co-located in existing pipeline ROW, there is low potential for the preclusion of 

mineral resources. However, subsidence over active mining areas could present some problems. Subsidence 

over trona mining areas is on the order of around 6 feet. The amount of subsidence is influenced by a number 

of factors including, but not limited to, the mining method, thickness of mined-out material, the depth of the 

overburden, and the strength of overburden materials (Dunrud 1976). No underground salt mining operations 

were identified beneath the proposed pipeline route in Kansas. 

Additional Mitigation 

GEO-1: Overland Pass shall monitor for subsidence during construction and operation in susceptible areas. 

Overland Pass shall use appropriate design standards and ground monitoring devices to assure 

pipeline integrity. 

Conclusion 

Operation of the proposed pipeline and aboveground facilities would not have a significant added impact on 

current or future mineral recovery operations in the area because most of the proposed pipeline route would 

follow existing ROWs that have already precluded mineral development along the proposed pipeline route. 

Additionally, impacts on future mineral development would not constitute a significant loss of mineral resource 

4.3-3
or mineral availability because of the narrow, linear nature of the pipeline ROW relative to the expanse of 

areas with mineral resource potential. 

It is anticipated that the pipeline trench would be backfilled with materials derived from the trench excavation, 

and it might be necessary to obtain some construction sand and gravel from local, existing commercial 

sources for use as pipe padding, road base, or surface facility pads. These demands for sand and gravel 

would not substantially affect the long-term availability of construction materials in the area. 

While there is a slight risk of mine-induced subsidence along localized portions of the Proposed Action, federal 

regulations require Overland Pass to design, operate, and maintain its pipeline to account for risk factors, such 

as subsidence. 

4.3.1.3 Geological Hazards 

Construction Phase 

Issues 

• Geological hazards that could affect pipeline and workers during construction. 

Analysis 

The hazard of concern during construction of the pipeline would be from unintentional undercutting of slopes or 

construction on steep slopes resulting in instability that would lead to landslides. Overland Pass attempted to 

minimize the amount of steep slopes crossed by the pipeline. Special pipeline construction practices described 

in Section 2.2.1.3 would minimize slope stability issues during construction. Implementation of Overland Pass’ 

Construction, Reclamation, and Revegetation Plan (Appendix C) and Blasting Plan would reduce the potential 

for construction-related activities to trigger landslides or other slope failures. Additional committed measures 

for potential ground failure would include the implementation of erosion control measures as described in the 

POD. At a minimum, these measures would include the construction of trench breakers, permanent slope 

breakers, and establishment of permanent vegetation within the ROW. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Construction of the proposed project facilities would not materially alter the geologic and physiographic 

conditions or worsen existing unfavorable geologic conditions in the area. 

Operation Phase 

Issues 

• Potential damage to pipeline and ancillary facilities from earthquakes (ground shaking and 

subsidence) and fault displacement. 

• Potential damage to the pipeline and ancillary facilities from ground subsidence in karst terrain. 

• Potential damage to the pipeline from flood scour. 

4.3-4
Analysis 

Seismicity. Seismic hazards could potentially damage the project facilities through strong ground shaking, 

surface faulting, or secondary ground deformation such as liquefaction and flow failure. Pipelines and 

aboveground facilities are capable of withstanding substantial ground motion. The proposed project is in an 

area where the probability of a strong earthquake is low. Since ground motion hazard probability is low, there 

is a low risk of related hazards of earthquake induced landslides. The proposed project does not cross 

identified active faults so ground displacement due to fault movement is not a concern. 

To protect the pipeline and facilities from seismic activity and its associated hazards, project facilities would be 

constructed and tested to meet federal standards outlined in 49 CFR Part 195 and geotechnical studies would 

be conducted so that facilities would be designed and constructed to minimize any effects that shaking or 

faulting could have on the project facilities. 

Subsidence. Potential subsidence as a result of underground mining is discussed in Section 4.3.1.2. Two other 

causes of potential subsidence were discussed in Section 3.3.1.3 and include solution of subsurface salt or 

chalk beds by the natural circulation of groundwater. Subsidence also can be induced by leakage of water 

from improperly cased or damaged oil field produced water disposal wells. 

Overland Pass avoided areas prone to subsidence whenever practical and sites of proposed surface facilities 

were selected to avoid any known underground mines in the area. Overall, the potential for localized 

subsidence or collapse features to develop along the proposed pipeline route is low. 

Localized areas of subsidence that materialize as a sinkhole can cause a span area in the pipeline. The length 

of acceptable span varies depending on the pipe design parameters, but can be easily calculated. The 

strength and ductility of the pipeline allows it to span over a considerable distance without threatening the 

integrity of the pipeline. Overland Pass would monitor potential subsidence areas (RP 675 to RP 749) for 

sinkholes during construction and operation. If a span was created that posed a safety hazard, Overland Pass 

would be required to mitigate the hazard as required by USDOT regulations. 

Flooding and Scour. Flooding could damage the project facilities by inundating surface facilities, causing 

debris flows which could damage surface facilities, or scouring stream beds at the point of the pipeline 

crossing, which could impact pipelines by leaving unsupported spans of pipe. In general, seasonal flooding 

hazards exist where the proposed pipeline route would cross major streams and rivers, and flash flooding 

hazards exist where the pipeline would cross small watersheds. The proposed pipeline route would have 

67 perennial stream crossings, 405 intermittent stream crossings, and 5 seasonally dry lake crossings in 

Wyoming; 10 perennial stream crossings; 73 intermittent stream crossings, and 6 seasonally dry lake 

crossings in Colorado; and 17 perennial stream crossings, 313 intermittent stream crossings, and 0 seasonally 

dry lake crossing in Kansas. All these crossings are locations where seasonal or flash flooding could occur. 

Though flooding in and of itself does not represent a significant risk to buried pipelines, stream scour and 

mud/debris flows that can accompany flooding can impact pipelines by exposing and leaving unsupported 

spans of pipe. To minimize these effects, the pipeline would be buried at a sufficient depth to avoid possible 

scour at waterbody crossings. In addition, regular visual inspection of the proposed pipeline route would be 

used to identify areas that might be potentially exposed after flood events. 

Flooding also could damage the project facilities by inundating surface facilities, scouring streambeds at the 

point of the pipeline crossing, or causing debris flows that could damage surface facilities. Aboveground 

facilities (pump stations, meter stations, pigging stations, and MLVs) are not located within areas susceptible 

to flooding. 

Additional Mitigation 

USDOT pipeline regulations specifically address mitigation of geological hazards. No additional mitigation was 

identified. 

4.3-5
Conclusion 

Operation of the pipeline and its associated facilities would not affect the geologic and physiographic 

conditions in the project area. Due to the routing of the pipeline and its design, it is unlikely that the pipeline 

facilities would suffer significant damage from geologic hazards or other naturally occurring events during 

operation. Further, construction and operation of the project and facilities would not worsen unfavorable 

geologic conditions in the area. 

4.3.1.4 Paleontological Resources 

Construction Phase 

Issues 

• Potential damage and loss of scientifically valuable fossils from ROW clearing and trench excavation. 

Analysis 

Construction activities have the potential to damage or destroy scientifically important or unique fossils. 

Potential impacts to fossil localities during construction could be both direct and indirect. Trenching through 

significant fossil beds could result in direct damage to or destruction of fossils. Indirect effects during 

construction could include erosion of fossil beds due to slope regrading and vegetation clearing. Another 

possible indirect effect could be unauthorized collection of significant fossils by construction workers or the 

public due to increased access to fossil localities along the ROW. 

To manage impacts to fossil localities, Overland Pass intends to prepare and would implement a 

Paleontological Monitoring and Mitigation Plan (Paleo Plan) to protect fossil resources on federal lands that 

may be encountered during project construction, including the resources identified during the field survey. 

Primary elements of the Paleo Plan include: 

• Paleontological monitoring and spot checking of construction activities across Condition 1 and 2 units; 

• Mitigation procedures for fossil localities identified during construction (e.g., avoidance, excavation, 

recording of localities); 

• Provisions for the preparation and curation of fossil collections; and 

• Provisions for the preparation of a final report based on the recovered data. 

All work conducted under the Paleo Plan would be performed by qualified paleontologists with trained 

assistants. 

Under no circumstances would fossils be removed from private lands for any reason, including curation, 

without the written consent of the landowners. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Adherence to the Paleo Plan would minimize adverse impacts to paleontological resources on federal lands. 

Important paleontological resources on non-federal lands may be recovered only with approval of the 

landowners, and therefore may be unavailable for scientific curation. 

4.3-6
Operation Phase 

Issues 

• Future maintenance activities could cause potential damage and loss of scientifically valuable fossils. 

Analysis 

Any potential effects would be isolated due to the probable dispersed nature of maintenance activities. Also, 

potential damage during operations and maintenance would be minimal since work would occur on previously 

disturbed ROW. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Normal operation of the proposed pipeline and its associated facilities would not disturb important 

paleontological resources. Maintenance activities would result in surface disturbance, but typically would occur 

within the trenchline previously disturbed during construction. Since no new disturbances would be anticipated 

from maintenance activities (i.e., maintenance activities would occur within the ROW), impacts to 

paleontological resources would be negligible. 

4.3.2 No Action Alternative 

Under the No Action Alternative, none of the identified potential project-specific impacts would occur. Impacts 

would occur at present levels as the result of natural conditions and existing development in the project area. 

4.3.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

The geological resources affected by the Southern Energy Corridor – Copper Ridge Bypass Alternative would 

be the same as the Proposed Action except for a greater amount of steep or side slopes (Table 4.3-2) and 

their associated potential hazards. 

Table 4.3-2 Comparison of Steep Slopes and Side Slopes Along the Proposed Action

and the Southern Energy Corridor – Copper Ridge Bypass Alternative 

Areas with Steep Slopes or Side Slopes (miles) 

Proposed Pipeline Route <10% 10 – 19% 20 – 29% >30% Total 

Proposed Action 3.4 0.8 1.5 0.0 5.7 

Southern Energy Corridor – Copper Ridge Bypass 8.4 1.4 1.7 0.1 11.6 

4.3-7
4.4 Soils 

4.4.1 Proposed Action 

Construction Phase 

Issues 

• Potential topsoil losses from wind and water erosion on disturbed surfaces during and after 

construction. 

• Potential reduction in soil productivity and quality from topsoil losses, soil mixing and compaction. 

• Pre-existing soil contamination or contamination from construction operations. 

Analysis 

Impact assessments were based on a wide range of soil characteristics. Acres of disturbed soils along the 

proposed pipeline route are summarized according to important soil characteristics that influence the 

magnitude of construction impacts (Table 4.4-1). Topsoil depth and slope classes based on aggregate 

percentages of component soil series within a particular class are identified in Table 4.4-2. 

Erosion by Water and Wind 

Susceptibility to erosion is a complex function of characteristics such as soil texture and structure, topography, 

surface roughness, soil cover (made up of vegetation, duff/litter, rock, and woody debris), and climate. Erosion 

also may be influenced by the length of time the soils are bare and by disruption of drainage and erosion 

control structures. Erosion resulting from water occurs primarily on loose, non-cohesive soils on moderate to 

steep slopes, particularly during high intensity storm events. Wind-induced erosion often occurs on dry, fine 

sandy soils where vegetation cover is sparse and strong winds are prevalent. 

The majority of the proposed pipeline route crosses range and shrublands on gently rolling to moderately 

steep slopes that are highly erodible. Of the total 6,906 acres (excluding TWA’s, aboveground facilities, access 

roads and open water acres) potentially affected by pipeline construction, the majority (3,793 acres, 

55 percent) are considered highly erodible by water. Approximately 8 percent (516 acres) of the soils along the 

proposed pipeline route are highly erodible by wind, although there is considerable overlap between wind and 

water erosion classes in some counties. Approximately 65 percent (4,474 acres) of the soils along the 

proposed pipeline route have average slope-ranges in the 0 to 5 percent category, 608 acres of which are on 

federally managed lands. Thirty-three percent of the remaining soils range from greater than 5 percent to 

30 percent slope (2,256 acres), 475 acres of which are on federally managed lands. Approximately 2 percent 

of soils have slopes greater than 30 percent (176 acres), 37 acres of which are on federally managed lands. 

Many of the soils within the proposed disturbance footprint are considered susceptible to water and wind 

erosion. Approximately 2,385 acres of soils highly susceptible to erosion by water would be crossed in 

Wyoming, 977 acres would be crossed in Colorado, and 431 acres would be crossed in Kansas. 

Approximately 241 acres of soils highly susceptible to erosion by wind would be crossed in Wyoming, 

265 acres would be crossed in Colorado, and 10 acres would be crossed in Kansas. Of the total, 

approximately 868 and 113 acres of soils susceptible to water and wind erosion, respectively, are on federally 

managed lands. 

Soils subject to water erosion include steeply sloping land with shallow soils. Highly wind erodible soils along 

the proposed pipeline route are associated with sandy and silty textured, sparsely vegetated soils on a variety 

of parent materials. Although accelerated erosion due to construction-related soil disturbance could occur at 

any stage of construction, the maximum potential for erosion within the construction ROW would be expected 

while soils are loose, on top of the soil surface in spoil piles. Erosion also would be of concern after final 

grading has occurred but before a vegetative cover had been reestablished. If the ground surface was left 

4.4-1
Table 4.4-1 Acreage Summary by State of Soil Characteristics for the Proposed Pipeline Route 

State/County 

Total Acres1 

Highly 

Erodible 

Water2 

Highly 

Erodible 

Wind3 

Prime 

Farmland4 Hydric5 

Compaction 

Prone6 Stony – Rocky7 Shal

Bed

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Wyoming 

Lincoln 95 106 75 67 21 22 0 0 1 3 0 0 10 8 51 Sweetwater 535 738 392 573 52 70 0 0 7 7 0 0 56 81 319 Carbon 267 564 224 518 34 36 0 0 0 0 0 0 59 107 87 Albany 19 462 18 334 0 6 0 0 0 30 0 7 7 139 13 Laramie 0 186 0 184 0 0 0 13 0 3 0 0 0 134 0 

Subtotal 916 2,056 708 1,676 107 134 0 13 8 43 0 7 132 469 470 

Colorado 

Larimer 0 <1 0 0 0 0 0 0 0 0 0 0 0 0 0 Weld 204 532 159 394 6 33 118 349 0 0 0 0 1 30 37 

Morgan 0 67 0 49 0 18 0 54 0 0 0 0 0 0 0 Logan 0 90 0 53 0 26 0 67 0 4 0 1 0 4 0 Washington 0 264 0 99 0 48 0 206 0 0 0 0 0 0 0 Yuma 0 405 0 223 0 134 0 211 0 6 0 1 0 30 0 

Subtotal 204 1,358 159 818 6 259 118 887 0 10 0 2 1 64 37 

Kansas 

Cheyenne 0 350 0 127 0 5 0 236 0 5 0 0 0 3 0 Rawlins 0 174 0 47 0 1 0 129 0 3 0 0 0 0 0 Thomas 0 224 0 25 0 0 0 197 0 2 0 0 0 0 0 Sheridan 0 318 0 68 0 3 0 249 0 2 0 0 0 0 0 Gove 0 10 0 5 0 0 0 4 0 0 0 0 0 0 0 Trego 0 326 0 75 0 1 0 236 0 0 0 0 0 10 0 Ellis 0 293 0 43 0 0 0 209 0 0 0 0 0 19 0 Russell 0 48 0 12 0 0 0 40 0 0 0 0 0 4 0 

4.4-2
Table 4.4-1 Acreage Summary by State of Soil Characteristics for the Proposed Pipeline Route 

State/County 

Total Acres1 

Highly 

Erodible 

Water2 

Highly 

Erodible 

Wind3 

Prime 

Farmland4 Hydric5 

Compaction 

Prone6 Stony – Rocky7 Shal

Bed

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Barton 0 254 0 13 0 0 0 251 0 0 0 0 0 0 0 Ellsworth 0 72 0 4 0 0 0 72 0 0 0 0 0 0 0 Rice 0 254 0 12 0 0 0 249 0 1 0 2 0 2 0 McPherson 0 49 0 0 0 0 0 49 0 0 0 1 0 0 0 

Subtotal 0 2,372 0 431 0 10 0 1,921 0 13 0 3 0 38 0 

Project Total10 1,120 5,786 868 2,925 113 403 118 2,821 8 66 0 12 133 571 507 1Acreage was calculated using actual pipeline length and assumes a 75-foot-wide ROW. Values do not include 1,408 acres associated with abovegroun

and contractor yards, TWAs, and access roads, or 3.5 acres associated with open water. Values within a table row do not add up to the total listed in because soils may occur in more than one characteristic class or may not occur in any class listed in the table. Federal lands data based on BLM-p

USFS jurisdictional boundaries for the FGNRA and PNG. 

2Includes land in capability subclasses 4E through 8E and soils with slopes greater than or equal to 9 percent. 3Includes soils in wind erodibility groups 1 and 2. 4Includes land listed by the NRCS as potential prime farmland if adequate protection from flooding and adequate drainage are provided. 5As designated by the NRCS. 6Includes soils that have clay loam or finer textures in somewhat poor, poor and very poor drainage classes. 7Includes soils that have either: 1) a cobbley, stony, bouldery, gravelly, or shaly modifier to the textural class, or 2) have > 5 percent (weight basis) of sto

in the surface layer. 

8Includes soils that have bedrock within 60 inches of the soil surface. 9Includes coarse-textured soils (sandy loams and coarser) that are moderately well to excessively drained. 10Slight discrepancies in state and project totals are due to rounding. 

4.4-3
Table 4.4-2 Acreage Breakdown of Topsoil Depth and Average Slope Class Along the Proposed Pipeline Route 

State/County 

Total Acres1 

Topsoil Depth2 (inches) Slope Class3 (perce

0 – 6 >6 – 12 >12 – 18 >18 – 24 >24 0 – 5 >5 – 8 >8 – 15 

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Wyoming 

Lincoln 95 106 70 73 20 29 5 4 0 0 0 0 66 81 0 0 20 18 Sweetwater 535 738 378 537 91 108 66 93 0 0 0 0 256 336 41 54 104 153 Carbon 267 564 189 404 78 160 0 0 0 0 0 0 120 201 49 96 51 130 Albany 19 462 15 333 4 68 0 47 0 14 0 0 5 231 1 30 2 76 Laramie 0 186 0 87 0 82 0 14 0 3 0 0 0 34 0 26 0 37 

Subtotal 916 2,056 652 1,434 193 447 71 158 0 17 0 0 447 883 91 206 177 414 

Colorado 

Larimer 0 <1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Weld 204 532 85 182 108 329 11 20 0 1 0 0 161 384 31 90 9 38 Morgan 0 67 0 23 0 41 0 3 0 0 0 0 0 55 0 7 0 0 

Logan 0 90 0 48 0 37 0 5 0 0 0 0 0 80 0 2 0 0 Washington 0 264 0 106 0 154 0 4 0 0 0 0 0 195 0 29 0 2 Yuma 0 405 0 181 0 206 0 18 0 0 0 0 0 246 0 29 0 38 

Subtotal 204 1,358 138 486 108 767 11 50 0 2 0 0 161 960 31 157 9 78 

Kansas 

Cheyenne 0 350 0 99 0 201 0 50 0 0 0 0 0 245 0 9 0 72 Rawlins 0 174 0 34 0 121 0 18 0 1 0 0 0 130 0 2 0 24 Thomas 0 224 0 24 0 190 0 10 0 0 0 0 0 200 0 1 0 19 Sheridan 0 318 0 39 0 247 0 29 0 3 0 0 0 254 0 1 0 39 Gove 0 10 0 2 0 6 0 2 0 0 0 0 0 5 0 0 0 3 Trego 0 326 0 12 0 256 0 43 0 15 0 0 0 259 0 17 0 42 Ellis 0 293 0 0 0 228 0 33 0 32 0 0 0 268 0 9 0 16 

4.4-4
Table 4.4-2 Acreage Breakdown of Topsoil Depth and Average Slope Class Along the Proposed Pipeline Route 

State/County 

Total Acres1 

Topsoil Depth2 (inches) Slope Class3 (perce

0 – 6 >6 – 12 >12 – 18 >18 – 24 >24 0 – 5 >5 – 8 >8 – 15 

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Federal 

Other

Russell 0 48 0 0 0 40 0 3 0 5 0 0 0 42 0 0 0 6 Barton 0 254 0 3 0 228 0 13 0 10 0 0 0 251 0 0 0 3 Ellsworth 0 72 0 1 0 64 0 4 0 3 0 0 0 71 0 0 0 1 Rice 0 254 0 7 0 214 0 20 0 13 0 0 0 249 0 1 0 4 McPherson 0 49 0 3 0 44 0 1 0 1 0 0 0 49 0 0 0 0 

Subtotal 0 2,372 0 224 0 1,839 0 226 0 83 0 0 0 2,027 0 40 0 229 

Project Total 1,120 5,786 737 2,198 301 3,053 82 434 0 101 0 0 746 3,870 122 403 186 721 

1 Acreage was calculated using actual pipeline length and assumes a 75-foot-wide ROW. Values do not include 1,408 acres associated with aboveground 

contractor yards, and additional TWAs, access roads, or 3.5 acres associated with open water. Federal lands data based on BLM-provided land layeboundaries for the FGNRA and PNG. 

2 Topsoil includes A-horizons (layers 1, 11, and 12) listed in the STATSGO database layer table. 

3 Slopes are grouped by the averages of the high and low slope ranges provided in the STATSGO database for each MUID component soil series. For exa

10 percent slopes, is 20 percent of MUID CO010. Its average slope is 6.5 percent. The representative acreage, calculated by multiplying percent comacreage, is included in the >5 to 8 percent slope class. 

4.4-5
smooth and bare during this period, winds could dislodge soil particles and rainfall intercepting bare surfaces 

could result in increased erosion. Since the Draft EIS, Overland Pass has adopted additional mitigation to 

reduce impacts from wind and water erosion (Appendix A, Table A-1). 

Soil Productivity 

The mixing of soil horizons during grading, trenching, and backfilling would lower soil productivity of agricultural 

and rangeland by diluting the physical, biological and chemical properties of the topsoil with less productive 

subsoil. This could affect revegetation success. Segregation of topsoil helps to mitigate these effects. If topsoil 

is lost, mitigation can be difficult because it may take hundreds to thousands of years for a topsoil horizon to 

form naturally. 

Erosion of the topsoil spoil pile could occur during construction, leading to a decreased amount of topsoil to be 

placed back on the surface. This could affect nutrient cycling and soil productivity. Approximately 2,903 acres 

of prime farmland or potentially prime farmland on highly productive agricultural soils would be affected by the 

proposed project. Protecting topsoil spoil piles from wind and water erosion is essential in these areas. 

Approximately 49 percent of the soils affected by the proposed project would have between 6 and 12 inches of 

topsoil, while approximately 42 percent of soils have between 0 and 6 inches of topsoil. Erosion, rutting, and 

the mixing of topsoil and subsoil horizons is of particular concern in areas with thin topsoil horizons because 

soil productivity can be drastically decreased if topsoil is mixed with subsoil or topsoil is lost to erosion. Only 

approximately 9 percent of the proposed project would affect soils with more than 12 inches of topsoil. 

Summaries of acres of various topsoil depths are located in Table 4.4-2. 

Soil Compaction and Rutting 

Soil compaction occurs when soil particles are pressed together and the pore spaces between them are 

reduced and bulk density is increased. Moist fine textured soils are most susceptible to severe compaction. 

However, compaction may occur on loamy to coarse textured soils and under drier conditions due to multiple 

passes by heavy mechanical equipment. 

Rutting occurs when the soil strength is not sufficient to support the applied load from vehicle traffic. Rutting 

affects the surface hydrology of a site as well as the rooting environment. The process of rutting physically 

severs roots and reduces the aeration and infiltration of the soil, thereby degrading the rooting environment. 

Rutting also disrupts natural surface water hydrology by damming surface water flows, creating increased soil 

saturation upgradient from ruts, or by diverting and concentrating water flows creating accelerated erosion. 

Rutting is most likely to occur on moist or wet fine textured soils but may also occur on dry sandy soils due to 

low soil strength. Soil rutting is an important indication that other physical soil impacts may be occurring on a 

site. 

Soil compaction and rutting could result from the movement of heavy construction vehicles along the 

construction ROW and additional TWAs, and on temporary access roads. The degree of compaction would 

depend on the moisture content and texture of the soil at the time of construction. Compaction would be most 

severe where heavy equipment operates on moist to wet soils with high clay contents. Detrimental compaction 

also can occur on soils of various textures and moisture contents if multiple passes are made by high 

ground-weight equipment. If soils are moist or wet where trenchline only topsoil trenching has occurred, topsoil 

also may adhere to tires and/or tracked vehicles and be carried away. Rutting restrictions would help to 

mitigate these concerns. 

Soil that is excessively compacted is limited in its ability to function. Compaction damages soil structure and 

reduces pore space, which impedes the movement of air and water to plant roots and can result in lower 

growth rates and hinder revegetation. Compaction reduces infiltration and results in excessive surface runoff, 

erosion, nutrient loss, and potential water-quality problems. Detrimental soil compaction, when extreme and 

unmitigated, can directly result in an irretrievable reduction in soil productivity. 

4.4-6
Stony/Rocky Soils and Shallow-to-Bedrock Soils 

Grading, trenching, and backfilling may bring stones to the surface that could interfere with or damage 

agricultural equipment and hamper revegetation efforts by reducing soil moisture holding capacity. Ripping and 

blasting of shallow bedrock during construction could result in incorporation of bedrock fragments into topsoil. 

Approximately 10 percent (705 acres) of the proposed pipeline route contains soils with substantial rocks and 

stones in the surface horizons. The majority of stony/rocky soils occur in the Wyoming and Colorado segments 

of the proposed pipeline route with 601 acres located in Wyoming, 65 acres in Colorado, and 38 acres in 

Kansas. Of the total, 133 acres are located on federally managed lands. Summaries of acres in stony-rocky 

classes are listed in Table 4.4-1. 

Soils containing shallow bedrock occupy approximately 26 percent (1,788 acres) of the proposed project. The 

majority of soils containing shallow bedrock are located in Wyoming (1,540 acres), with an additional 

133 acres in Colorado, and 116 acres in Kansas. Of the total, 507 acres are located on federally managed 

lands. Approximately 20 percent of the total acreage of shallow bedrock is designated as hard rock that could 

require blasting. The remaining areas of shallow bedrock are soft enough to be ripped with backhoes or 

bulldozers equipped with rippers. The majority of shallow-to-bedrock soils are located in Sweetwater and 

Carbon counties, Wyoming (789 and 318 acres, respectively). Summaries of acres in shallow bedrock classes 

are provided in Table 4.4-1. 

Droughty Soils 

Revegetation success within the construction ROW could be a concern on droughty soils. Coarse-textured 

soils in moderately well drained or drier drainage classes are particularly susceptible to drought. Revegetation 

success on droughty soils could be compromised if seeding and revegetation efforts occur during dry periods. 

Approximately 13 percent (930 acres) of soils affected by the proposed project are inherently droughty. The 

majority of droughty soils are located in Wyoming (750 acres). An additional 170 acres are in Colorado and 

10 acres are located in Kansas. Of the total, 267 acres are located on federally managed land. Summaries of 

acres in droughty soil-classes are listed in Table 4.4-1. 

Drain Tiles 

Pipeline construction activities could disrupt or damage existing subsurface drainage systems. Hydric soils are 

generally an indicator of areas that may require drain tiles for crop production. The proposed project would 

affect approximately 74 acres (approximately 1 percent of total area) of hydric soils. The majority of hydric soils 

are in Wyoming (51 acres). An additional 10 acres are in Colorado and 13 acres are located in Kansas. Of the 

total, 8 acres are located on federally managed lands. This represents a relatively small percentage of the total 

acreage affected and few if any drain tiles are expected to be encountered. 

Irrigation Systems 

Grading, trenching, and backfilling could disrupt water flow to irrigation systems. Overland Pass has negotiated 

compensation for damages to landowners, as appropriate. 

Soil Contamination 

Soil contamination along the proposed pipeline route could result from material spills during construction and 

trench excavation through pre-existing contaminated areas. These impacts typically would be minor because 

of the low frequency and volumes of these occurrences. However, if large spills occur they could result in the 

removal and disposal of large amounts of soil. Saturated soils may have the potential to diffuse contaminants. 

Mitigations that buffer wetlands and waterbodies from refueling or fuel storage, would help to prevent spills in 

saturated areas. No areas of pre-existing soil contamination were identified along the proposed pipeline route. 

4.4-7
Aboveground and Ancillary Facilities 

Construction of the project would involve the construction of three pump stations (including one future pump 

station at WaKeeney) and seven meter stations. None of these aboveground facilities would be located on 

federally managed land. Meter stations at Opal, Bushton, and Conway would be constructed within existing, 

previously disturbed commercial/industrial properties, resulting in no additional soil impacts than are already 

experienced at these facilities. Additional facilities would affect previously undisturbed lands including the Echo 

Springs Pump and Meter Station, Laramie Pump and Meter Station, Washington County Meter Station 

(RP 447.8), and the WaKeeney Meter (and future pump) Station (Table 4.4.3). Because these sites may exist 

for an indeterminate amount of time, site-specific impacts could result in an irretrievable reduction in soil 

productivity. 

Table 4.4-3 Characteristics and Limitations of Soils at Pump and Meter Stations 

Station Name 

Map Unit 

Symbol1 Map Unit Name 

Susceptibility to 

Erosion 

Prime 

Farmland 

Opal Meter Station NA Previously disturbed 

commercial/industrial site 

NA No 

Echo Springs Pump and 

Meter Station 

WY166 Multiple STASTGO MUIDs Susceptible to water 

and wind erosion 

No 

Laramie Pump and Meter 

Station2,3 

188 McFadden gravelly fine sandy 

loam, 1 to 6 percent slopes 

Not highly susceptible 

to erosion. 

No 

Washington County Meter 

Station (RP 447.8)

2,3 

4 Ascalon fine sandy loam, 3 to 

9 percent slopes 

Susceptible to water 

erosion. 

No 

WaKeeney Meter Station 

(future pump station)2,3 

1620 Keith silt loam, 1 to 3 percent 

slopes 

Not highly susceptible 

to erosion. 

Yes 

Bushton Meter Station NA Previously disturbed 

commercial/industrial site 

NA No 

Conway Meter Station NA Previously disturbed 

commercial/industrial site 

NA No 

1

Map unit estimated from station footprints and soil survey map sheets. 

2

Map unit symbols and names taken from the applicable map sheets in NRCS county soil surveys. 

3

Susceptibility to water and wind erosion and prime farmland designations determined from NRCS data provided in county soil surveys 

and Soil Survey Geographic database (USDA NRCS 2005, 1994). 

Construction activities affecting new land would involve initial soil disturbance due to grading and excavation 

and a change in land use as a result of construction and operation. The majority of the soils that would be 

affected by construction and operation of the pump station exhibit low susceptibility to water and wind erosion. 

At the proposed Wyoming and Colorado locations, no prime farmland soils would be impacted by construction 

and operation of the stations; in Kansas, prime farmland soils potentially would be affected. 

The project also would require the construction and operation of 11 pigging facilities and 94 MLVs along the 

proposed pipeline route (Table 2.2-1). Pigging facilities would be constructed within a 208-foot by 208- to 

250-foot site, while operation of a launcher/receiver would occur within a 175- to 125-foot by 125-foot site. The 

block and check valves would be operated within a permanent 25-foot by 25-foot fenced area, while remote 

valve sites would be operated within a 100-foot by 25-foot site. MLVs would be situated entirely within the 

permanent ROW. Soil constraints for pigging facilities and MLVs would be the same as those identified for the 

surrounding pipeline ROW. 

Ancillary facilities consist of contractor and pipe storage yards and access roads. Overland Pass would use 

24 pipe storage and contractor yards during construction (Table 2.2-6). Each yard is located on non-federal 

land. In Wyoming, seven of the eight yards would be located on previously developed sites, while three would 

be on rangeland. One yard in Colorado would be on previously developed land, while the other four would be 

on agricultural or rangeland. Thirteen yards would be required in Kansas, of which two would be on developed 

4.4-8
or partially developed land. The remaining sites would be on agricultural land. Generally, yard preparation 

would be limited to grading and leveling, and possibly importing some fill. Where the yards would be located in 

rangeland, topsoil would be stripped and stored at the edge of the yard and temporary traffic lanes would be 

installed by placing gravel over geotextile fabric. If gravel compresses through the geotextile fabric, rock could 

be incorporated into the soil and would be difficult to remove. Impacts would be similar to those of pipeline 

construction (i.e., possibility of reduction of soil quality by topsoil loss or mixing with subsoils, compaction, and 

introduction of invasive or noxious weeds). Upon completion of the project, the traffic lanes would be removed, 

compacted soils would be mitigated according to Overland Pass’ POD and topsoil would be restored to its 

original position. 

Access to the project primarily would be via existing public roads that would not require modifications. Some of 

the access roads, however, would be dirt roads, such as BLM or USFS access roads and two-track trails. 

Road maintenance, such as grading and filling, likely would not be required to maintain the dirt roads in a 

passable condition unless rain occurs and travel over the roads deteriorates surface conditions. 

Additional Mitigation 

SOIL-1: In areas where topsoil has not been removed, rutting from construction activities shall not exceed 

4 inches on all federal lands, with the exception of the PNG where the rutting restriction is 3 inches. 

If rutting exceeds these depths, it shall be considered excessive and operations halted until 

conditions are dry. If conditions do not improve, Overland Pass shall consult with the applicable 

federal agencies to determine if alternate topsoil removal techniques may be employed to alleviate 

rutting concern. 

SOIL-2: Prior to preparation of the final POD, Overland Pass shall consult with the federal land 

management agencies to obtain detailed soil inventory information to be used to fine-tune the 

proponent’s site-specific reclamation and revegetation plans. Site-specific changes and mitigation 

measures shall be incorporated by RP into the Construction, Reclamation, and Revegetation Plan. 

The changes shall be incorporated directly into the text of the final POD for the project. 

SOIL-3: On the ANF, topsoil would not be removed from the temporary workspace area. 

Conclusion 

The soils in the project area are diverse with a broad range of textures and depths. Much of the proposed 

pipeline route crosses soils that have shallow topsoil, are susceptible to erosion, have poor reclamation 

potential, and are prone to compaction and rutting. Pipeline construction activities may result in adverse 

impacts on the soil resources. Soil impacts would be mitigated by the implementation of Overland Pass’ POD 

(including the Construction, Reclamation, and Revegetation Plan). Measures to minimize soil impacts include 

erosion control measures, topsoil separation and handling procedures, and remediation of compacted soils. 

Impacts anticipated from pipeline construction include the possibility of reduction of soil quality by topsoil loss 

or mixing with subsoils, compaction, and introduction of invasive or noxious weeds. 

Since the publication of the Draft EIS, Overland Pass has committed to supplemental mitigation measures 

intended to reduce impacts to soils. Benefits of these mitigations include: 

• Reducing the amount of topsoil lost to erosion; 

• Reducing compaction and rutting on two-track roads; 

• Minimizing the expansion of two-tracks by braiding; and 

• Reducing the compaction on the working side of the ROW. 

Application of the recommended additional mitigation measures (SOIL-1, SOIL-2, and SOIL-3) would further 

reduce impacts. 

4.4-9
The STATSGO data used for analysis represents general soil data and does not provide a detailed 

representation of existing conditions. As a result, the BLM and USFS prefer that the project-specific POD 

provide a higher level of resolution to the soils data in order to properly identify areas of concern. SOIL-2 would 

provide an opportunity for land management agencies to work with Overland Pass to identify specific resource 

concerns along the proposed pipeline route and incorporate site-specific mitigations as necessary. 

Operation Phase 

Issues 

• Potential topsoil losses from wind and water erosion on disturbed surfaces during and after 

maintenance activities. 

• Potential reduction in soil productivity and quality from topsoil losses, soil mixing and compaction. 

• Soil contamination from pipeline leaks, particularly in prime farmland. 

Analysis 

Potential topsoil losses from wind and water erosion could occur during maintenance operations along the 

ROW or at aboveground facilities. These activities would be dispersed along the length of the proposed 

pipeline route and would occur intermittently. 

There is a small probability the pipeline could accidentally leak, releasing NGL into the environment 

(Section 3.12). The physical, chemical and toxicological properties of the NGLs that Overland proposes to 

transport were evaluated to determine potential environmental effects (Appendix L). NGLs primarily consist of 

gas that is liquefied by pressure (e.g., propane). Consequently, in the unlikely event of a pipeline release, NGL 

components would rapidly volatilize, thereby resulting in minimal impacts to soil resources. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Operation of the WaKeeney Meter Station would result in the conversion of approximately 1 acre of prime 

farmland to industrial use. 

Maintenance activities would result in localized impacts of short duration (less than 14 days in most cases) and 

these impacts would be dispersed along the entire route. 

If NGLs were accidentally released into the environment, minimal impacts, if any, would be expected to soil 

resources. 

4.4.2 No Action Alternative 

Under the No Action Alternative, the proposed project would not be constructed or operated. No project-related 

disturbance would occur to soils. Impacts would continue at present levels as a result of natural conditions and 

existing development in the project area. 

4.4.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

Soil resources affected by the Southern Energy Corridor – Copper Ridge Bypass Alternative would be the 

same as the Proposed Action except in areas of steep terrain or requiring side slope construction. Steep and 

side slope construction would result in 35 acres of TWAs along the Southern Energy Corridor – Copper Ridge 

4.4-10
Bypass Alternative, compared to 17 acres for the Proposed Action. These areas would be more susceptible to 

erosion and would be more difficult to reclaim. 

Acres of various soil characteristics that would be affected by the construction of the alternative route and the 

corresponding segment of the proposed pipeline route have been provided in Tables 4.4-4 and 4.4-5. The 

alternative route would affect fewer acres of prime farmland relative to the corresponding segment of the 

proposed pipeline route. However, the alternative route would affect more acres of soils susceptible to erosion 

caused by wind and water, hydric soils, stony-rocky soils, shallow depth to bedrock, and droughty soils. 

Impacts to soils with topsoil depths of 0 to 6 inches and greater than 6 inches to 12 inches would be 

comparable between the alternative and corresponding segment of the proposed pipeline route. However, the 

alternative route would affect approximately 59 acres of soils with topsoil depths greater than 12 inches 

compared with the corresponding segment of the Proposed Action, which would not cross soils with topsoil 

depths of greater that 12 inches. In addition, the alternative route would affect more acres of soils with steeper 

slopes than the corresponding segment of the proposed pipeline route. 

Table 4.4-4 Comparison of Soil Characteristics Affected by the Southern Energy Corridor – Copper 

Ridge Bypass Alternative and Corresponding Segment of the Proposed Action (acres) 

Highly 

Erodible 

Water1 

Highly 

Erodible 

Wind2 

Prime 

Farmland3 Hydric4 

Compaction 

Prone5 

StonyRocky6 Shallow-toBedrock7 Droughty8 

Proposed Action 226.1 2.1 2.1 0.0 0.0 24.4 183.1 224.1 

Southern Energy Corridor – 

Copper Ridge Bypass 

Alternative 

279.7 13.7 0.0 1.8 0.0 28.2 223.2 278.2 

1

Includes land in capability subclasses 4E through 8E and soils with slopes greater than or equal to 9 percent. 

2

Includes soils in wind erodibility groups 1 and 2. 

3

Includes land listed by the NRCS as potential prime farmland if adequate protection from flooding and adequate drainage are provided. 

4

As designated by the NRCS. 

5

Includes soils that have clay loam or finer textures in somewhat poor, poor, and very poor drainage classes. 

6

Includes soils that have either: 1) a cobbley, stony, bouldery, gravelly, or shaly modifier to the textural class, or 2) have >5 percent (weight 

basis) of stones larger than 3 inches in the surface layer. 7

Includes soils that have bedrock within 60 inches of the soil surface. 

8

Includes coarse-textured soils (sandy loams and coarser) that are moderately well to excessively drained. 

Table 4.4-5 Acreage Summary of Topsoil Depth and Average Slope Class Affected by the 

Southern Energy Corridor – Copper Ridge Bypass Alternative and Corresponding 

Segment of the Proposed Pipeline Route 

Topsoil

1 

(inches) 

Slope2 

(percent) 

 0-6 >6-12 >12-18 >18-24 >24 0-5 >5-8 >8-15 >15-30 >30 

Proposed Action 162.1 63.9 0.0 0.0 0.0 206.1 0.0 18.4 0.0 0.0 

Southern Energy 

Corridor – Copper 

Ridge Bypass 

Alternative 

205.9 14.4 44.4 15.2 0.0 80.2 28.12 128.32 22.32 20.3 

1

Topsoil includes A horizons (layers 1, 11, and 12) listed in the STATSGO database layer. 2

Slopes are grouped by the averages of the high and low slope ranges provided in the STATSGO database for each MUID component 

soil series. 

4.4-11
4.5 Water Resources 

4.5.1 Proposed Action 

4.5.1.1 Surface Water 

Construction Phase 

Issues 

• Increased turbidity and sedimentation in streams resulting from in-stream construction. 

• Risk of fuels, solvents, or hazardous material spills during construction. 

• Channel and bank modification affecting channel morphology. 

• Reductions in flow volumes in streams where water is withdrawn for hydrostatic testing. 

• Potential transmittal of whirling disease, zebra mussels, or other invasive aquatic species between 

watersheds. 

• Accelerated erosion, turbidity, and sedimentation from disposal of hydrostatic testing water. 

• Increased salt loading from surface discharge in the Colorado River Basin. 

Analysis 

Waterbody Crossings 

Overland Pass proposes to make a total of 94 perennial waterbody crossings, several of which would cross 

the same waterbody multiple times (Appendix H, Table H-1). Of these perennial streams, 67 are in 

Wyoming, 10 are in Colorado, and 17 are in Kansas. Six are located on federally managed lands. Overland 

Pass generally proposes to cross streams using a wet-ditch (open-cut) method. The HDD method would be 

used to cross the South Platte River and several lined irrigation ditches. In addition to geotechnical work at the 

South Platte River, Overland Pass conducted geotechnical investigations for the proposed crossings at the 

Green River, North Platte River, and Medicine Bow River. Borings at these crossings indicated subsurface 

conditions that, in engineering opinions, would lead to high probabilities of failure for HDD crossings. To avoid 

the potential impacts of drilling mud releases, drill recovery, and other clean-up activities associated with an 

HDD failure, dry-ditch (flume) methods are proposed at these crossings. Related applicant-committed 

mitigation measures would be implemented at each crossing (Appendix A). 

The project also will cross 791 intermittent or ephemeral waterbodies (Appendix H, Table H-1). The majority 

of these are dry washes. If these intermittent or ephemeral streams are dry at the time of construction, 

Overland Pass would cross them using conventional upland construction techniques and committed 

reclamation and revegetation measures (Appendix C). If the waterbodies are flowing when crossed, 

Overland Pass would cross them with open-cuts and implement the related committed mitigation measures. 

Depending on the waterbody width, these crossings would generally be completed within 24 to 48 hours. 

On a case-by-case basis, Overland Pass may elect to use dry-ditch crossing methods (i.e., flume or dam-andpump) at selected waterbody crossings. Dry-ditch crossing methods would be implemented on an as-needed 

basis, primarily depending on construction conditions and the presence of flows. 

On the PNG, it is likely that the streams will not contain water, since they typically flow only a few days per 

year. If water is encountered at a stream crossing on the PNG, Overland Pass has agreed to wait up to 

48 hours for the water to subside before constructing the crossing. If the water subsides within that time, 

upland construction techniques would be used. If the water does not subside, a dry-ditch construction 

technique would be used to cross the stream. 

4.5-1
Committed measures are proposed by Overland Pass to reduce the potential for water resource impacts at 

waterbody crossings. In general, these measures include: sediment controls (silt fences or equivalent); 

earthen trench plugs to separate the upland trench from the waterbody trench for as long as possible; erosion 

controls and slope breakers on long, steep sideslopes adjoining streams; and re-establishing the original bed 

and bank configurations. To allow construction equipment to cross, temporary bridges may be installed across 

perennial waterbodies that are greater than 30 feet wide at the time of construction. Overland Pass also has 

prepared an Incised Bank Stabilization Plan, and has committed to protective distances from waterbodies for 

equipment refueling, overnight parking, and materials storage. These practices and additional applicantcommitted measures are further discussed in Chapter 2.0, Appendix A, and in construction and restoration 

practices proposed by Overland Pass (Appendix C). 

In crossing waterbodies, Overland Pass would comply with the requirements of its waterbody crossing permits. 

Site-specific construction plans (Overland Pass 2007) have been developed for a number of waterbody 

crossings, including those listed in Table 3.5-2 and others. These plans address: 

• The method that would be used to excavate the in-stream trench; 

• The location of the spoil storage in the waterbody and onshore, and the mitigative measures that 

would be used to control and store the spoil; 

• The method that would be used to install the pipeline across the waterbody; 

• The method and material that would be used to backfill the trench in the riverbed; 

• The size requirements of the additional TWAs on each bank (such as trench size and work that would 

be done at each workspace); and 

• A description of any special mitigation that would minimize impact on riparian vegetation and in-stream 

habitat. 

As proposed by Overland Pass, all but one of these major and sensitive waterbodies (South Platte River 

[HDD]) would be crossed using the open-cut construction method. 

Stream crossing construction techniques differ in their impacts to water resources and related beneficial uses. 

As discussed in Chapter 2.0, common buried crossing methods include wet ditch open-cut, dry ditch open-cut 

(flume or dam-and-pump), and HDD. An aboveground method, the bridge or aerial pipeline crossing, is 

avoided in present-day oil and gas construction due to costs and hazards from vandalism, explosion and fire, 

flooding, and scour or settlement at abutments (Zwirn 2002). 

The potential impacts from ditched crossings include increased erosion from clearing and grading 

streambanks, traffic in waterbodies, increases in sedimentation and turbidity, changes in stream channel and 

bank morphology, altered flows and water chemistry (particularly temperature and biological oxygen demand), 

and associated adverse effects on aquatic and riparian ecosystems (Zwirn 2002; Anderson et al. 1998). The 

magnitudes of these impacts vary between crossing methods, the equipment used, the time of year, 

construction/restoration practices and the length of time required to implement them, and the characteristics of 

streamflows, channel beds, and banks. 

Dry-ditch open-cut crossing methods consistently generate lower average suspended sediment concentrations 

than wet-ditch methods. However, dry-ditch methods are more complex, time-consuming, and expensive to 

construct (Reid et al. 2004). For dry-ditch crossings, if turbid water is pumped from the ditch to upland areas, 

sediment increases are usually limited to short-term peaks when the dams (and flume, if applicable) are being 

installed and removed. However, dam failures or leaks may allow pulses of sediment to be released (Reid and 

Anderson 2000). Flumed crossings appear to be more prone to such sediment control failures than dam-andpump crossings, possibly due to their application on larger waterbodies (Reid et al. 2004). No matter which 

dry-ditch method is used, an accidental spill of sediment-laden trench water would generate substantial stream 

turbidity (Zwirn 2002). Dry-ditch crossings typically require a longer period of in-stream activity than do wet 

4.5-2
ditch open-cut crossings, and may take three to five times longer to construct. Fish passage may be restricted 

during that time, particularly if pumps are used (Reid et al. 2004). 

Wet-ditch crossings are typically completed in much shorter time than dry-ditch crossings but generate 

substantial suspended sediment concentrations for the duration of the construction and shortly afterward (Reid 

and Anderson 1999, 2000). As a result, fish spawning habitat, incubating fish eggs, invertebrate populations, 

water temperature and biological oxygen demand are adversely affected. The magnitude and duration of 

elevated suspended sediment concentrations are influenced by the size of the waterbody, bed material 

characteristics, streamflow rates, and the type of equipment used (e.g., backhoe, clamshell dredge). Smaller 

streamflows during construction result in minimal dilution and high suspended sediment concentrations, but 

downstream transport may be limited under such conditions. For these reasons, late summer or winter 

construction may reduce the extent of impacts from open-cut crossing construction. In contrast, high flows 

increase background sediment transport and mixing, but also create construction and sediment control 

difficulties that usually result in greater impacts. 

Deposition of coarse sediment often takes place within short stream distances (tens or hundreds of feet) no 

matter which trenching method is used. However, the finer particles (silts and clays) remain suspended for 

considerably longer distances. The extent and magnitude of sediment-related impacts depend highly on 

channel and bank materials, flow rates, proximity to incoming tributaries, and background concentrations. 

Removal of deposited sediment may require several weeks to 2 years or more, depending on flow regimes 

(Reid and Anderson 1999; Zwirn 2002). Sizable deposits of coarse sediment may cause long-term channel 

alterations at or near the crossing location. At any ditched crossing, improper recontouring or stabilization of 

the channel or banks may also affect channel morphology and create unstable waterbody conditions. These 

risks increase when unsuitable backfill materials are used, or during periods when soils and spoil materials are 

frozen into large blocks. Changes in channel geometry may modify flow hydraulics to the point where fish 

passage and aquatic habitats are adversely affected (Zwirn 2002; Reid and Anderson 1999). 

HDD crossings avoid excavation-related impacts on waterbodies, but they are the most costly and timeconsuming to construct. They may not be suited to all large or sensitive crossing locations due to site 

characteristics. Since HDD crossings involve specialized drilling equipment and staff, economic and 

geotechnical concerns often limit their construction. The most common adverse environmental effect from 

HDD crossing construction is degradation of surface water quality by an inadvertent release of drilling fluids 

through porous channel materials. Additional land disturbance occurs from staging, equipment uses, and 

material storage at both the entry and exit locations. 

For the proposed project, open-cut crossings constructed at ephemeral or intermittent streams in winter are 

unlikely to create water quality impacts at the time. Streamflows are likely to be absent during construction at 

these locations. Increased sediment transport may occur at some of these crossings later in the spring, when 

the disturbed sites are exposed to spring runoff. The magnitude and spatial extent of sediment transport 

increases and related impacts at these crossings would be minimized by mitigation and restoration practices 

committed to by Overland Pass. 

Project impacts from open-cut (wet-ditch) crossings at perennial streams would be similar to those described 

above from experience and empirical studies. Perennial streams, including those listed in Table 3.5-2, would 

undergo increases in sedimentation and turbidity, alterations of flow and water chemistry, and associated 

adverse effects on aquatic and riparian ecosystems. These impacts would occur to various degrees in 

perennial streams, major or sensitive waterbodies, and related habitats, even during the winter construction 

timeframe currently anticipated. Significant and ongoing aquatic habitat impacts are known to occur at the 

Hams Fork and Blacks Fork crossings in Wyoming from previous pipeline crossings there. In addition, a large 

concentration of utility crossings already occurs at the proposed crossing location on the Medicine Bow River. 

Because of these existing and potential impacts, Overland Pass is encouraged to utilize dry-ditch (flume or 

dam-and-pump) or HDD crossing methods at perennial streams wherever possible, both on lands under 

federal jurisdiction and elsewhere. 

4.5-3
Nationwide 12 permits have been approved for the project by both the Omaha and Kansas City USACE 

districts, and accompanying Section 401 water quality certifications from Colorado and Kansas are in the 

review process (Wyoming has issued its certification). A number of general conditions must be complied with 

under these nationwide permits. Such conditions involve avoiding or minimizing impacts, or mitigating 

impacts, to aquatic life movement, fish spawning areas, public water supply intakes, endangered species, and 

other resources. Soil erosion and sediment controls, management of water flows, removal of temporary fills, 

and compliance with regional or case-specific conditions are also required under the USACE permits issued 

for the project. 

Overland Pass would adhere to the measures contained in its Construction, Reclamation, and Revegetation 

Plan (Appendix C) to prevent or minimize impacts to surface water. On non-federally managed land, spoil 

would be placed or stored a minimum of 10 feet from the edge of a waterbody. On federally managed land 

spoil would be placed or stored a minimum of 50 feet from the edge of a waterbody. TWAs would be required 

at waterbody crossings unless impractical due to topography or other technical constraint. Overland Pass 

proposes to set these areas back at least 50 feet from the edge of the waterbody or wetland edge on federal 

land and on non-federally managed land (e.g., private) the setback will be 10 feet. Mitigation Measure VEG-1 

(Section 4.6) further addresses the issue of setback distance from riparian areas on federal lands. Refueling, 

storage and use of hazardous materials, and equipment storage would be set back 500 feet from the edge of 

the waterbody or wetland on federal land and 100 feet on private land. 

In general, application of erosion control techniques would keep impacts minimized and localized. At the Hams 

Fork and Blacks Fork, however, open-cut crossings in silt or soft material may have long-term effects, such as 

scouring, sedimentation and erosion. Fine silts and colloids also could result in diminished aesthetics of the 

waterbodies for anglers and other recreational users, and impact potable water supplies that obtain water from 

surface water intakes. There are five known surface water intakes within 10 miles downstream of the proposed 

pipeline crossings (Table 3.5-4). Overland Pass would provide written notification to the authorities responsible 

for potable surface water supply intakes located within 3 miles downstream of the crossing at least 1 week 

before beginning work in a waterbody, or as otherwise specified by that authority. Additionally, Overland Pass 

would notify the appropriate state authorities at least 48 hours before beginning trenching or blasting within the 

waterbody, or as specified in state permits. 

Overland Pass initially planned to HDD the Green River crossing in southwestern Wyoming. Site-specific 

geotechnical investigations have subsequently indicated that such a crossing method would have a high risk of 

failure due to unsuitable soil and rock characteristics, as well as from uncontrolled water flow into the bore from 

the aquifer. Overland Pass has agreed to construct a flume crossing at the Green River. 

Pipeline integrity during floods and related channel scouring is a major concern for the proposed crossing of 

the Green River. The channel is approximately 300 feet wide at the proposed crossing location. If the pipeline 

burial depth was insufficient and bed or bank materials were eroded away, portions of the pipe may become 

unsupported. If deep scouring took place during a large flood event, an exposed pipeline would be subjected 

to the force of the floodwater and to impacts from rocks or debris transported in the flow. Over time, either 

repeated smaller floods or the occurrence of a single large event could threaten the structural integrity of the 

pipeline. A leak or rupture would create adverse impacts to surface water and related fisheries and recreation 

resources downstream. 

Emergency control valves are proposed on either side of the Green River over an approximately 2.6-mile 

length of the pipeline, and the proposed crossing generally is centered within this distance. In case of rupture, 

these valves would activate and minimize the volume of product spilled. In addition, Overland Pass has 

conducted detailed hydrologic and hydraulic studies for the crossing location based on various flood conditions 

including the 100-year, 24-hour flood. A 5-foot burial depth, from the channel bed surface at its deepest point 

to the top of the concrete-coated pipe, has been recommended as a result of these investigations. Based on 

valve placement and burial of the pipeline to this depth, adequate protection of the Green River from flooding 

and scour would be provided. No water resources impacts related to these concerns are anticipated. Other 

construction considerations at the Green River may generate additional impacts on fishery resources; these 

are discussed in the respective resource section (Section 4.7). 

4.5-4
The BLM is concerned about the use of the open-cut method at several crossings: Blacks Fork River, Hams 

Fork River, Bitter Creek, and North Platte River. The use of the open-cut crossing method by other recent 

pipeline projects across the Blacks Fork and Hams Fork rivers resulted in adverse affects by changing channel 

and streambank morphology, modifying flow velocities, increasing sedimentation, and creating related adverse 

impacts to the aquatic community, which includes the presence of special status fish species and game 

fisheries. BLM recommends the Blacks Fork and Hams Fork rivers be directionally drilled to avoid additional 

impacts on game and special status species and to minimize impediments to fish movement in the rivers. 

Overland Pass considered the HDD crossing method at these streams and rejected it. Site-specific open-cut 

crossing plans for these streams have been submitted as part of the permit process and approved by the 

USACE. 

Open-cut crossings at the Blacks Fork and Hams Fork rivers may create additional effects on channel 

geometry, flow depths and velocities, and would increase erosion and sedimentation. If these effects acted in 

combination with previous impacts at these locations, significant habitat impacts could result. 

The BLM has similar concerns for the North Platte River due to its high recreational value and use as a 

municipal drinking water supply. The recent Entrega Pipeline Project open-cut this river. After observing this 

crossing, the BLM recommends the North Platte River be directionally drilled to avoid similar sedimentation 

impacts on water resources. However, since the North Platte River crossing would not occur on federal lands, 

the BLM has no authority to enforce this recommendation. 

Bitter Creek (RP 108) contains a unique population of flannelmouth suckers, considered to be a sensitive 

species by the BLM and WGFD, in the vicinity of the crossing location. Overland Pass proposes to use upland 

construction techniques if no water is flowing at the time of construction. If water is flowing at the time of 

construction, Overland Pass proposes a dry ditch open-cut crossing without disturbing the existing beaver dam 

and aquatic habitat immediately upstream of the crossing location. 

Overland Pass has committed to one HDD river crossing at the South Platte River in Colorado and five HDD at 

other minor waterway crossings in Colorado. Consequently, construction-related impacts on aquatic resources 

due to sedimentation would be minor at this river. HDD minimizes impacts by avoiding instream activities. 

Nevertheless, there is a possibility that mud consisting of water, bentonite and cuttings, from the directional 

drilling (or from HDD failure or tunnel collapse) could inadvertently enter the active stream along the drilling 

route. However, if mud seepage was detected, the drilling operation would be stopped immediately to reduce 

pressure within the bore hole. Corrective measures would be implemented to eliminate or minimize seepage. If 

any seepage enters the stream, increased turbidity of the surface water would be localized and short-term in 

duration (less than 1 day). Long-term impacts from drilling mud would be mitigated by the measures described 

above. 

In the event the HDD is not successful at the South Platte river crossing, an open-cut contingency plan has 

been prepared and submitted to BLM and USACE. Similar impacts described above for open-cut crossings 

(temporary increases in sediment loading) could occur. Erosion control techniques would keep suspended 

sediment localized and conditions would be expected to return to pre-construction levels within several days. 

Fuel Spills 

The use of heavy equipment to complete pipeline installation across waterbodies increases the potential for 

accidental releases of fuels, lubricants, and coolants. The accidental release of these materials could 

adversely affect aquatic species and, in a few cases (e.g., North Platte River, Rock Creek, Smoky Hill River), 

contaminate public water supplies that rely on surface water intakes located downstream of the waterbody 

crossing. Overland Pass would minimize the potential impact of spills of hazardous materials by adhering to its 

SPCC Plan (Overland Pass 2007). The SPCC Plan describes preventive measures such as personnel 

training, equipment inspection, and refueling procedures to reduce the likelihood of spills; and mitigative 

measures, such as containment and cleanup, to minimize potential impacts should a spill occur. On federal 

land, a minimum setback distance of 500 feet from riparian areas would be maintained for all refueling 

4.5-5
activities, storage and use of hazardous materials, and equipment storage. On private land, this minimum set 

back distance would be 100 feet. 

Overland Pass has committed to install bridge structures at all perennial waterbody crossings or at intermittent 

crossings greater than 30 feet that have flowing condition at the time of construction to allow for construction 

equipment and vehicles to cross the waterbody. Additional mitigation WATER-1 requires crossing structures at 

all waterbodies and wetlands on federal land regardless of the size of the waterbody. Clearing equipment and 

equipment for installation of a bridge would be allowed to pass across the waterbody or wetland only once. 

Overland Pass would limit the amount and duration of instream work using heavy equipment at these 

crossings. As described above, Overland Pass would provide advance notification to the operators of surface 

water intakes regarding waterbody construction schedules and would notify the operators and the BLM of any 

accidental releases of hazardous materials that could impact their water supply. 

Vehicle and equipment use within and adjacent to waterbodies also could pose a risk to water quality from fuel 

or lubricant spills. If fuel reached a waterbody, aquatic species could be exposed to toxic conditions, 

depending on factors such as volume spilled, stream velocity, and channel morphology. 

Bank Stability and Flooding 

Long-term impacts on water quality could result from alteration of the streambank and removal of riparian 

vegetation. Vegetative cover along streambanks of a waterbody provides bank stability and erosion control. If 

not stabilized and revegetated properly, soil erosion associated with surface runoff and streambank sloughing 

could result in deposition of sediments in the waterbodies after construction was completed. Given the 

relatively small width of disturbance associated with a pipeline crossing, the above potential impacts would be 

considered minor relative to an entire stream system. Overland Pass would ensure that disturbed areas 

successfully revegetate with wetland herbaceous and/or woody plant species by implementing the 

Construction, Reclamation, and Revegetation Plan (Appendix C). 

Overland Pass has identified 29 locations of active erosion or channel incising (Table 4.5-1). To minimize 

impacts to these locations and to avoid exacerbating conditions, Overland Pass defined procedures that would 

be implemented to stabilize these stream crossings, including the use of permanent slope and trench 

breakers, geotextile fabric, and 1 foot of clean gravel or native cobble to reduce bottom scour (Figures 4.5-1 

and 4.5-2). 

If necessary, specialized, site-specific construction practices and plans would be developed in areas where 

standard construction practices are not sufficient to protect a resource. For open-cut crossings, waterbody 

banks would be stabilized and temporary sediment barriers installed within 24 hours of completing instream 

construction activities. For dry ditch crossings, streambed and bank stabilization would be completed before 

returning flow to the waterbody channel. Waterbody banks would be returned to preconstruction contours or to 

a stable angle of repose. 

Construction Water Uses 

The appropriation of large volumes of hydrostatic test water from surface water sources could temporarily 

affect the recreational and biological uses of the resource, if the diversions constitute a large percentage of the 

source’s total flow or volume. According to the Hydrostatic Test Plan, surface water volumes would be 

returned to their sources, near the points of withdrawal and in compliance with water quality permits. This 

would avoid transfer of diseases and nuisance organisms. 

Water withdrawal from the Green River at the crossing would not constitute withdrawal of a large percentage 

of the available surface water. A review of U.S. Bureau of Reclamation (USBOR) data of releases from 

Flaming Gorge Reservoir indicates that the average annual flow in the Green River below the reservoir is 

1,989 cubic feet per second for the period 1964 to 2005. The lowest average monthly flow (in October) is 

850 cubic feet per second (about 382,000 gallons per minute), and the highest average monthly release (in 

4.5-6
 4.5-7

S TREAM B ANK P ROFILE V IEW 

P ERMANENT 

S LOPE B REAKER 

R ESTORE B ANKS


WITH C URLEX OR


E QUIVALENT


G EOTEXTILE .
 S EE N OTE 1 

3	 S EE N OTE 2 3 

1	 1 

5' min. 

INSTALL S LOPE


AND T RENCH


B REAKER AT B ASE


OF S LOPE >5%


NOTES: 

1.	 MATCH SLOPES AS CLOSE AS POSSIBLE TO ADJACENT ROW. 

2.	 TO REDUCE BOTTOM SCOUR, CLEAN GRAVEL OR NATIVE COBBLE WILL BE PLACED IN THE UPPER 1FOOT OF TRENCH 

BACKFILL. 

Overland Pass 

Pipeline Project 

Figure 4.5-1

Typical Incised

Bank Stabilization -

Profile View
 4.5-8

STREAM BANK PLAN VIEW 

PERMANENT

SLOPE

BREAKER

ROW LIMITS ROW LIMITS 

STANDARD

ROW

SEEDING

STANDARD

ROW

SEEDING

SEE

NOTE 2 ROW LIMITS ROW LIMITS 

RESTORE BANKS WITH CURLEX

OR EQUIVALENT GEOTEXTILE

Overland Pass 

Pipeline Project 

Figure 4.5-2

Typical Incised

Bank Stabilization -

Plan View
Table 4.5-1 Locations Where Active Erosion or Channel Incising is Occurring 

RP Name Stream Type 

0.95 Hams Fork River Perennial 

1.08 Trib to Hams Fork Perennial 

12.88 Trib to Blacks Fork Intermittent 

15.82 Trib to Blacks Fork Intermittent 

21.95 Trib to Blacks Fork Intermittent 

25.41 Trib to Blacks Fork Intermittent 

35.49 Trib to Spider Creek Intermittent 

41.33 Blacks Fork Perennial 

55.72 Logan Draw Intermittent 

65.13 Trib to Bitter Creek Intermittent 

74.30 Trib to Sweetwater Creek Intermittent 

76.07 Trib to Bitter Creek Intermittent 

91.20 Trib to Black Butte Creek Intermittent 

107.30 Bitter Creek Perennial 

118.10 Trib to Bitter Creek Intermittent 

200.24 Trib to St. Mary’s Creek Intermittent 

230.75 Trib to Bear Creek Intermittent 

242.21 Irrigation canal Intermittent 

329.20 Trib to Owl Creek Intermittent 

331.73 Trib to Owl Creek Intermittent 

334.42 Trib to Eastmen Creek Intermittent 

479.30 Trib to North Fork Intermittent 

513.26 Bluff Creek Intermittent 

515.62 Trib to Bluff Creek Intermittent 

542.57 North Fork Sappa Creek Intermittent 

679.40 Trib to Smokey Hill River Intermittent 

699.97 Trib to Cow Creek Intermittent 

715.35 Trib to Plum Creek Intermittent 

717.30 Plum Creek Perennial 

May) is 2,000 cubic feet per second (about 898,000 gallons per minute). Recent winter releases to the Green 

River from Flaming Gorge Reservoir (since the year 2000) are on the order of 1,000 cubic feet per second 

(about 449,000 gallons per minute) (USBOR 2006a). The maximum targeted withdrawal rate for proposed 

hydrostatic testing purposes (either 1,000 or 3,000 gallons per minute, depending upon the dates of 

withdrawal) is less than 1 percent of the average winter flow. 

The Overland Pass Hydrostatic Test Plan (Appendix D) lists five streams, numerous private wells in Colorado 

and Kansas, and wells at the ONEOK Bushton Plant as water sources for hydrostatic testing. The withdrawal 

location and volumes are provided in Table 4.5-2. Overland Pass proposes to withdraw water between 

January and March 2008. 

Collectively, hydrostatic testing would use up to 18.1 acre-feet from surface water sources in the Colorado 

River Basin and up to 46.7 acre-feet from surface water sources in the Platte River Basin. 

Potential impacts on surface water resources from hydrostatic testing withdrawals may include reductions in 

flow rates, reductions in streamflow presence and extent within the channels and associated habitats, and 

potential water quality effects. Water quality effects may include increased turbidity from pump installation 

activities, and changes in temperature and dissolved oxygen concentrations due to flow reductions. 

4.5-9
Overland Pass has identified potential water sources to be used for filling each pipe test section and has been 

in consultation with the various agencies regarding water use. Overland Pass will continue these consultations, 

including those with the USFWS regarding water depletion and potential downstream impacts on threatened 

and endangered species if hydrostatic test water is removed from sensitive water resources. Based on these 

continuing consultations and other provisions in the proposed hydrostatic testing plan, potential impacts from 

most surface water withdrawals are likely to present minimal potential for adverse effects. Effects that do occur 

would vary with flow conditions and agency guidance at the time of construction, and would be temporary in 

nature. 

Table 4.5-2 Anticipated Water Sources for Construction of the Proposed Project1 

Approximate 

RP Potential Source(s) 

Volume for 

Dust Control 

Volume for 

Hydrostatic Testing 

Volume for 

HDD Uses 

gallons acre-feet gallons acre-feet gallons acre-feet 

Colorado River Tributaries 

41.3 Blacks Fork River 2,400,000 7.4 

59.3 Green River 3,500,000 10.7 

Subtotal 18.1 

Platte River Tributaries 

195.5 North Platte River 6,800,000 20.9 

277.1 Laramie River 2,500,000 7.7 

412.4 North Sterling Ditch of the 

South Platte River 

5,900,000 18.1 4,500,000 13.8 

Subtotal 46.7 13.8 

Other Sources 

Overall Municipal Wells 22,340,000 68.5 500,000 1.5 

444.2 – 598.6 Bushton Wells or Private 

Wells2 

8,000,000 24.6 

718.0 Wells at ONEOK Bushton 

Plant 

8,300,000 25.5 

Subtotal 68.5 50.1 1.5 

Totals 22,340,000 68.5 37,400,000 114.9 5,000,000 15.3 

1

Source: Supplemental Information, Section 4 (Overland Pass/NRG 2007). Values are approximate; conversion errors are due to

rounding. 

2

Based on an analysis of the well location and relationship to groundwater and lack of connectivity to surface flow, none of this 

groundwater drains into the Platte River surface water tributaries. 

Proposed hydrostatic testing withdrawals from the Green and North Platte rivers and the South Platte-North 

Sterling Canal are minimal with respect to the flows of those channels, and significant adverse impacts to them 

are not anticipated. The potential for significant adverse effects from proposed surface water withdrawals for 

hydrostatic testing is greatest with respect to aquatic life habitats in the Blacks Fork and Laramie rivers. 

Inspection of USGS flow data indicates that the proposed withdrawal rates (1,000 or 3,000 gallons per minute) 

are substantial when compared to many daily average flows on these streams. When proposed withdrawals 

are compared to the total volume that moves past a given point in a month’s time, the hydrostatic testing 

program would use a very small portion of water. This is identified in the Hydrostatic Testing Plan 

(Appendix D), and is an appropriate measure for water storage and supply. However, aquatic life support in 

streams is based on habitat values that depend on the presence of flow in the channel (e.g., depth, velocity, 

temperature, dissolved oxygen). Proposed pumping rates could pose a risk to the presence of streamflow. 

The Blacks Fork supports sensitive fish species near the proposed withdrawal location (Keith 2007), and the 

Laramie River supports a trout fishery. The presence of these species are further detailed in Sections 3.7.1.2 

and 3.7.1.3. Potential flow reductions on the Blacks Fork at the proposed withdrawal location are of particular 

concern (Keith 2007). 

4.5-10
At a pumping rate of 1,000 gallons per minute (2.2 cubic feet per second), Overland Pass would require about 

1.7 days to fill the test sections from the Blacks Fork (Appendix D). This withdrawal rate would be between 

4 and 2.5 percent of the mean January and February flow rates, respectively, over the last 20 years at the 

location. At 1,000 gallons per minute, approximately 0.7 percent of the mean March flow rate would be 

withdrawn. At 3,000 gallons per minute (6.7 cubic feet per second), pumping would require about 0.6 day to fill 

the test sections. That rate would withdraw about 12 and 8 percent of the mean January and February flow 

rates, respectively, over the last 20 years at the Blacks Fork location. The 3,000 gallons per minute rate would 

withdraw about 2 percent of the mean March flow on the Blacks Fork. 

On the Laramie River, the same durations for the respective rates would be required to fill the test sections 

(Appendix D). Recent streamflow data are not available at this location. Based on older records, pumping at 

1,000 gallons per minute would withdraw about 6 percent of the mean January and February flows in the 

channel. The 1,000 gallons per minute withdrawal rate would be about 4 percent of the mean March flow. 

Pumping at 3,000 gallons per minute would withdraw about 19 and 17 percent of the mean January and 

February flows, respectively. The 3,000 gallons per minute rate would withdraw about 13 percent of the mean 

March flow. 

In arid and semi-arid regions, daily, monthly, and seasonal streamflows are highly variable where they are not 

dominated by storage or other flow regulation (e.g., reservoir releases, treatment plant outflows). Mean daily 

flow data from the USGS were examined for approximately 20 years of record at both the Blacks Fork and 

Laramie rivers. When proposed project withdrawal rates are compared to daily streamflow rates, potential 

habitat impacts become apparent at the Blacks Fork and the Laramie rivers. By reviewing daily data at 7-day 

increments, between 12 and 15 percent of the weeks exhibited flows all week long where the proposed 

3,000 gallons per minute (6.7 cubic feet per second) withdrawal rate would remove 50 to 100 percent of the 

flow. A number of periods exhibited flows where the proposed 1,000 gallons per minute (2.2 cubic feet per 

second) withdrawal rate would remove a substantial portion of the streamflow. Most periods of limited flows 

were in August, September, or October on either stream. Overland Pass is not currently proposing 

withdrawals in those months. However, some of these periods occurred in winter months, particularly during 

the drought between 2000 and 2004 on the Blacks Fork. 

Maintenance flows to support various game fish populations in the Green River Basin during late-season, lowflow months have been identified by the WGFD (Tyrell 2001). For the smaller Green River tributaries listed, 

these flows are on the order of 10 to 20 cubic feet per second. However, a maintenance flow for the lower 

Blacks Fork was not listed. Instream flow requirements have not been officially established for either stream 

segment. Tennant (1976) studied instream flow regimens for fish habitats, and developed a set of 

recommended protective flows as portions of mean annual flows. He rated these qualitatively (good, fair, poor, 

etc.). His analysis was largely based on stream studies in Montana and Wyoming. Based on Tennant’s 

results, leaving 10 percent of the mean annual flow would provide a level of protection for aquatic resources in 

both coldwater and warmwater streams (Tennant 1976). 

In the absence of more detailed information, this flow proportion may be useful as a general guide for aquatic 

habitat maintenance during the short-term withdrawals proposed by Overland Pass at the Blacks Fork and the 

Laramie River. Ten percent of the mean annual flow over the past 20 years on the Blacks Fork near Little 

America, Wyoming, would be about 20 cubic feet per second. Based on available data, 10 percent of the 

mean annual flow on the Laramie River at Laramie, Wyoming, would be about 10.5 cubic feet per second. It is 

important to note that existing flows in these streams often fall below these levels. In addition to natural flow 

variations, agricultural diversions are made upstream of the proposed withdrawal locations on both rivers. 

In order for these flows to remain in the streams, Overland Pass would need to restrict withdrawals of 

1,000 gallons per minute to periods when streamflows are above 22 cubic feet per second at the Blacks Fork, 

and above 13 cubic feet per second at the Laramie River. For withdrawals of 3,000 gallons per minute, 

Overland Pass would need to restrict pumping to periods when streamflows are above 27 cubic feet per 

second at the Blacks Fork, and above 17 cubic feet per second at the Laramie River. 

4.5-11
Further study and interactions with appropriate state or federal fisheries agencies could modify these 

maintenance estimates substantially. Neither stream segment has official instream flow requirements. Further, 

WGFD has indicated that from a fisheries standpoint, a more suitable water source than the Blacks Fork might 

be located on the Hams Fork near Opal, Wyoming, or on the Green River (Keith 2007). BLM has concerns 

about impacts to aquatic habitats on both the Blacks Fork and the Laramie rivers during withdrawals, but 

neither location is on federally managed land. Stream reaches at both proposed water source locations are 

entirely on state or privately owned lands. BLM recommends that adequate flow rates for aquatic life habitats 

be maintained in the Blacks Fork and Laramie River during withdrawals for hydrostatic testing. 

Surface water depletions in the Colorado River and Platte River basins for hydrostatic testing or dust control 

purposes are an issue for federally listed species that occur in downstream portions of the Colorado River and 

Platte River basins. The USFWS requires consultation for any water withdrawals in these basins that could 

affect surface water quantity. Section 4.7.1.2 discusses the impacts of water depletions from the proposed 

project on federally listed species in the Colorado River and Platte River basins. 

Overland Pass plans to discharge hydrostatic test water back into the source water or into adjoining suitable 

upland areas. A splash pup would be used to minimize impacts on surface waters. A splash pup is a smaller 

section of pipeline welded at the end of the discharge line at a 90° angle. Use of a splash pup can be an 

effective means of minimizing erosion and dissipating energy to avoid increasing the turbidity of the waterbody 

and causing significant changes to the flow velocity of a river. Hydrostatic testing activities would be monitored 

by inspectors and the outflow rates adjusted as necessary to avoid erosion impacts. Discharge of hydrostatic 

test water would follow NPDES permit requirements for water quality, and discharge permits would be 

obtained from the respective states prior to discharge. 

The discharge of large volumes of hydrostatic test water to surface water sources could temporarily affect the 

biological uses of the resource. If discharge rates are not carefully controlled, discharges into surface waters 

could cause erosion of the stream banks and stream bottoms, resulting in a temporary increase of sediment 

load and destruction of habitat. These discharges could potentially affect state-designated uses. Overland 

Pass would minimize the potential for these effects through the use of energy-dissipating devices that would 

disperse and slow the velocity of any discharges. Overland Pass would not discharge into state-designated 

exceptional value waters, waterbodies which provide habitat for federally listed threatened or endangered 

species, or waterbodies designated as public water supplies, unless appropriate federal, state, and local 

permitting agencies granted written permission. Overland Pass would minimize the potential effects of 

hydrostatic testing on surface water resources by adhering to the measures in the Construction, Reclamation, 

and Revegetation Plan (Appendix C). The Hydrostatic Test Plan (Appendix D) addresses the procedures for 

hydrostatic test water appropriations and discharges. These measures and procedures include regulating the 

rate of withdrawal of hydrostatic test water to avoid adverse impact on downstream flows. Overland Pass 

would be testing only new pipe and no chemicals would be added to the water during hydrostatic testing, 

unless chemical additives are stipulated in the discharge permit. Overland Pass would acquire the necessary 

permits from state agencies before withdrawing hydrostatic test water, including specific approvals from 

applicable resource agencies. 

If the source water is surface water, the hydrostatic test water would be discharged back into the source water 

or onto stable upland areas (well vegetated surfaces with a gradient of less than 10 percent) immediately 

adjoining the source. Committed mitigation measures for managing hydrostatic test water discharges would 

minimize the potential for impacts to surface waters or upland disposal sites. Overland Pass has not 

committed to testing all surface water discharges unless required by specific state permits. BLM mitigation 

measure WATER- 6 requires testing of hydrostatic test water prior to discharge to ensure that the water meets 

local, state, or federal water quality standards, including meeting NPDES permit requirements. 

Transfer of Disease and Nuisance Organisms 

In-stream construction activities and hydrostatic testing could transport whirling disease and parasites or 

invasive organisms such as zebra mussels between drainages. The Proposed Action would cross waters in 

Wyoming where the whirling disease organism may be present (i.e., Green, North Platte, Medicine Bow, 

4.5-12
Laramie rivers). Whirling disease is present in all perennial streams in Colorado except Chief Creek (Walker 

2006; Money 2006). There is no evidence that invasive aquatic fauna exist in the Colorado stream systems 

crossed by the pipeline. In addition, there is at least one drainage in Kansas that now contains zebra mussels, 

and other invasive species also are a possibility. Implementation of Overland Pass’ proposed discharge 

provisions in the Hydrostatic Test Plan and equipment washing proposed at state lines for weed control will 

help control the transfer of such organisms. However, there are a number of streams that flow across state 

lines that are in various conditions with respect to disease and nuisance organisms. Because of concerns 

about transferring these organisms, additional mitigation is recommended. 

Salt Loading to the Colorado River 

By far, most of the salt contributed to the Colorado River originates from background geologic conditions and 

land uses over large areas. Water draining from irrigated agricultural fields, and runoff and erosion from marine 

shale outcrops are two examples of sources of salt loading. Based on construction and operation plans, 

Overland Pass would not contribute to salt loads in the Colorado River. 

Additional Mitigation 

WATER-1: If water is present, all waterbodies (regardless of size and flow) and wetlands on federal lands 

shall have an approved crossing structure consisting of either a temporary culvert, rock fill, or 

equipment bridge. One pass of clearing equipment and equipment for installation of a bridge 

shall be allowed across the waterbody or wetland. 

WATER-2: On an as-needed basis as determined and specified through consultations with appropriate 

state and federal fisheries and water-quality agencies, power washing equipment with water 

and other chemicals as specified shall be required to avoid transfer of whirling disease, 

parasites, or nuisance organisms after equipment crosses perennial streams. Suitable 

chemical treatments may be used for equipment cleaning when sustained daytime 

temperatures are below freezing. Any fluids used for this purpose that contain additives 

(e.g., chlorine) shall not be discharged to streams or drainages, but shall be disposed of in an 

agency-approved manner at an appropriate facility. 

WATER-3: If water is withdrawn from the Green, North Platte, and Laramie rivers (e.g., for HDD or 

hydrostatic testing) during the period from April 1 through October 31, Overland Pass shall 

utilize a filter screen with a mesh size that would prevent impingement and entrainment of 

aquatic organisms. The mesh size would be 3/32-inch to protect salmonid life stages. For 

surface water withdrawals during November 1 through March 31, a 0.5-inch mesh filter screen 

shall be used. 

WATER-4: Overland Pass shall use construction techniques applicable for flowing waterbodies when 

dry/seasonally dry lake beds are crossed during saturated or inundated conditions. 

WATER-5: On federal land, Overland Pass shall reduce the total construction ROW width to 60 feet in 

riparian and wetland areas. 

WATER-6: Prior to any discharge, hydrostatic testing water will be tested and processed to ensure that the 

water meets local, state, or federal water quality standards. This includes meeting NPDES 

permit requirements as stated in Chapter XVIII of the Wyoming Water Quality Rules and 

Regulations. Prior to discharge of hydrostatic testing water from the pipeline, the holder shall 

design and install a suitable energy dissipator(s) at the outlet(s), and design and install suitable 

channel protection measures necessary to ensure that there will be no erosion or scouring of 

natural channels within the affected watershed as a result of such discharge. Overland Pass 

would be responsible for any erosion or scouring resulting from such discharge. Straw bales, 

sandbags, rock, or other materials or objects installed will be removed from the site upon 

completion of hydrostatic testing. 

4.5-13
Conclusion 

Construction impacts to surface waters potentially could include increased turbidity sedimentation in streams 

resulting from in-stream construction; the potential for fuel spills; channel and bank modification, affecting 

channel morphology; reductions in flow volumes in streams where water is withdrawn for hydrostatic testing; 

and potential transmittal of whirling disease, zebra mussels, or other invasive aquatic species between 

watersheds. These surface water impacts would be mitigated by the implementation of Overland Pass’ POD 

including the Construction, Reclamation, and Revegetation Plan, site-specific waterbody crossing plans, and 

the Hydrostatic Test Plan. Measures to minimize surface water impacts include the use of erosion control 

measures such as sediment barriers to prevent silt-laden water from entering wetlands and waterbodies; 

restoring original contours; revegetating disturbed areas; and appropriate setback distances for additional 

TWAs, storage of fuel and hazardous materials, and equipment storage from the edge of wetlands and 

waterbodies. 

Since the publication of the Draft EIS, Overland Pass has committed to supplemental mitigation measures 

intended to reduce impacts to water resources. Benefits of these mitigations include: 

• Protecting water quality by ensuring hydrostatic test discharges meet water quality standards; and 

• Reducing erosion impacts from hydrostatic water discharges. 

Implementation of the recommended additional mitigation measures would further reduce impacts to surface 

waters. WATER-1 would reduce sediment impacts downstream of a crossing by limiting instream and bank 

disturbance from construction equipment. WATER-2 would prevent or minimize the transport of nuisance 

organisms from one waterbody to another. WATER-3 would reduce impacts on aquatic resources during water 

withdrawals associated with dust control and hydrostatic testing. WATER-4 would minimize impacts to 

seasonally dry lakes and ponds. WATER-5 would reduce the extent of construction impacts in riparian and 

wetland areas. WATER-6 would assure hydrostatic test water discharges meet water quality standards. 

Operation Phase 

Issues 

• Potential reductions in surface water quality from pipeline spills or leaks in small, medium, and large 

streams. 

Analysis 

Effects of a possible pipeline rupture at a stream crossing would have a short-term impact on surface water. In 

addition, accidental releases or leaks from the pipeline could impact surface water quality by introducing 

hydrocarbons into soil followed by surface runoff. The Risk Assessment (Appendix L) describes the physical, 

chemical, and toxicological properties of the NGLs that Overland Pass proposes to transport. NGL properties 

were evaluated to determine potential environmental effects in the event of a spill. NGLs primarily consist of 

gases that are liquefied by pressure. NGLs released into the environment would quickly volatilize and are only 

minimally water soluble. Potential impacts would be short-term and low magnitude due to the characteristics of 

NGLs and the localized extent of the affected area. 

Surface water intakes within 10 miles downstream of the pipeline crossing were identified in Table 3.5-4. 

Valves would be placed in close proximity to perennial waterbodies crossed by the proposed pipeline. In the 

event of a pipe failure these valves would be closed to minimize the leakage and allow for repair of the pipe. 

The potential for a pipeline leak is discussed in Appendix L. 

Additional Mitigation 

No additional mitigation was identified. 

4.5-14
Conclusion 

The effects of a pipeline release of NGLs into a waterbody would have minimal, if any, impact on surface water 

quality. 

4.5.1.2 Groundwater 

Construction Phase 

Issues 

• Reduced availability of groundwater near wells pumped as water sources for hydrostatic testing, dust 

control, equipment washing, or other uses. 

• Contamination of near-surface groundwater as a result of spills during refueling or storage and 

handling of lubricants, solvents, or other materials. 

• Interference with existing groundwater movement and supply in areas of shallow groundwater or 

springs, as a result of trenching or blasting. 

• Impacts to terrestrial resources, wetlands, and/or surface water from discharge of poor quality 

groundwater or wastes incidentally encountered during trenching, or from discharge of poor quality 

groundwater used for hydrostatic testing, dust control, or other project purposes. 

• Long-term interference with existing groundwater movement in areas of shallow groundwater or 

springs due to trench backfilling. 

Analysis 

As described in Section 3.5.1.2, groundwater occurs near the land surface at numerous locations along the 

proposed ROW. These areas primarily consist of alluvial aquifer zones that occur in relatively narrow bands 

along streams and rivers. Examples include the Hams Fork at Opal, Wyoming; the Medicine Bow River near 

Elk Mountain, Wyoming; Rock Creek at Arlington, Wyoming; streams in the vicinity of Laramie, Wyoming; the 

South Platte River near Merino, Colorado; and the South Fork of the Republican River near St. Francis, 

Kansas. 

Elsewhere along the proposed ROW, water-bearing zones generally are greater than 50 feet below ground 

surface, and commonly are greater than 100 feet below the ground surface. Under these conditions, little or no 

impacts to groundwater resources would occur from project construction. 

In areas of near-surface aquifers, the potential for contamination of groundwater during construction would be 

avoided or minimized by the implementation of the SPCC Plan, which is part of Overland Pass POD (Overland 

Pass 2007). Components of the plan include good housekeeping, containment requirements, and inspections 

at contractor yards; personnel training in spill prevention and response; readily available clean-up materials 

and containment equipment; and established protocols for spill response, clean-up, and reporting. In addition, 

locations for materials storage, equipment refueling, and maintenance would be restricted to protective 

distances from wells, waterbodies, and wetlands. These practices would avoid or minimize impacts to 

groundwater resources from activities undertaken during the construction sequence. 

Dewatering 

As stated in the project Stormwater Pollution Prevention Plan (SWPPP) (Overland Pass 2007), it could be 

necessary to dewater the trench where shallow groundwater was intercepted and impeded trenching or other 

activities in the construction sequence. Dewatering would be necessary to provide a safe working 

environment. According to the SWPPP, trench dewatering discharges would be directed into sediment control 

structures, such as filter bags placed in well-vegetated upland areas. Well vegetated upland areas typically 

would be located outside, but immediately adjacent to, the bladed construction ROW, but within the areas that 

4.5-15
were inventoried and analyzed in this document. On federal land, the approval to locate a dewatering structure 

outside the construction ROW would be made using a Level 1 variance. The duration of these discharges 

would depend on the length of time the trench was open in a particular locale. In areas of existing or potential 

subsurface drainage, installations such as trench breakers would be placed to minimize changes in the 

existing hydrologic conditions. If tile drains were encountered, they would be repaired to their pre-construction 

level of function. 

Dewatering would cause temporary impacts to shallow groundwater resources over limited areas. The 

magnitude and importance of such impacts would be small, since trench excavation would be relatively 

shallow and trench backfill would not be likely to permanently obstruct groundwater drainage. After pipe 

installation and trench backfilling, near-surface groundwater levels and gradients eventually would be restored 

to approximate pre-construction conditions through natural seepage and re-saturation. Depending on 

site-specific conditions, this process could occur over a period of days to months. This would be an 

unavoidable short-term impact of construction. 

Blasting 

Blasting during construction could reduce groundwater yields to wells and could damage existing pump 

installations. To minimize adverse effects of blasting, a formal Blasting Plan has been developed for the 

project (Overland Pass 2007), and would be in effect prior to the start of construction. In accordance with the 

plan, the peak particle velocity during blasting would not exceed 1.5 inches per second at any aboveground 

structure, including water wells. If blasting were to occur within 200 feet of identified water wells or potable 

springs, Overland Pass has committed to conduct water flow performance and water quality testing before 

blasting. If the water well was damaged by blasting, either the well owner would be compensated for damages 

or a new well would be provided. In addition, Overland Pass would provide an alternative potable water supply 

to the landowner until repairs have occurred. Locations of water wells or systems within 200 feet of blasting 

activities have been identified by Overland Pass. These measures would avoid or minimize adverse impacts to 

groundwater supply locations from blasting activities. 

Construction Water Use 

An additional impact of project construction on groundwater resources may occur from withdrawals made to 

supply dust control efforts (approximately 68.5 acre-feet or 22.3 million gallons), hydrostatic testing 

(approximately 50.1 acre-feet or 16.3 million gallons), and HDD crossings (approximately 1.5 acre-feet or 

0.5 million gallons) (Table 4.5-2). Groundwater for dust control would be pumped from existing municipal 

water wells serving about 40 communities between Green River, Wyoming and WaKeeney, Kansas. The total 

amount withdrawn from any one location would vary between about 0.7 acre-feet (about 225,000 gallons) to 

7.1 acre-feet (about 2.3 million gallons). The greatest withdrawals are anticipated from six widely separated 

municipal wellfields at major communities in Wyoming, and the smallest withdrawals are anticipated in eastern 

Colorado and Kansas. 

In comparison, the total estimated public-supply water use along the proposed route in Wyoming is 

approximately 8 million gallons per day in Lincoln County; approximately 8.9 million gallons per day in 

Sweetwater County; approximately 3.4 million gallons per day in Carbon County; and approximately 6.6 million 

gallons per day in Albany County (USGS 2006). The total fresh groundwater withdrawals for public supplies 

are about 830,000 gallons per day in Yuma County, Colorado; about 540,000 gallons per day in Sheridan 

County, Kansas; and about 770,000 gallons per day in Ellsworth County, Kansas (USGS 2007). 

In Carbon County, Wyoming, Rawlins represents about two-thirds of the county-wide municipal population, 

and the proposed withdrawal there would be about two-thirds of the county’s daily public demand. Elsewhere, 

if the proposed municipal sources generally represent about one-third to one-half of their respective daily 

county withdrawals for public supply, the proposed withdrawals would similarly represent roughly 1 day of 

public demand at each source. Since dust control withdrawals would occur over many days in each area, 

groundwater impacts from proposed project withdrawals for dust control would not be significant. 

4.5-16
The current hydrostatic testing plan proposes to make groundwater withdrawals for this purpose between 

approximate RP 442 and RP 599, and at RP 718 (NRG 2007). The first area extends from eastern Colorado 

(Washington County) into northwestern Kansas (Sheridan County). The South Platte River floodplain extends 

along the proposed route from about RP 413 to RP 416. Thus, the river alluvium is about 22 miles east of the 

potential well-water source area, and may be more distant, depending on the source well locations. Further 

eastward in the area of proposed groundwater sources, the major aquifer is the Ogallala Formation. For 

project purposes, there would be no discernible hydrologic connection between the proposed area of 

groundwater sourcing and the Colorado River tributaries, the North Platte, or the South Platte. There may be 

surface water/groundwater interactions along this stretch of the pipeline with respect to the alluvial deposits 

along the Arikaree River and the South Fork of the Republican River. The Saline and Solomon rivers and their 

tributaries have narrow alluvial deposits that provide relatively little water to wells. Depending on the well 

locations where withdrawals are made, slight drawdown effects may temporarily occur over short reaches of 

perennial streams within a 0.5 mile or so of the source well. If such an effect occurs, it may create a minimal 

impact on streamflows. 

Proposed total hydrostatic test withdrawals from groundwater are approximately 50.1 acre-feet (Table 4.5-2). 

This is a relatively small volume in comparison to extensive agricultural withdrawals in the region. Based on 

water-use values (USDA 2006), an irrigated cornfield of about 130 acres uses approximately 230 acre-feet of 

water to produce a corn crop in northeastern Colorado. Approximately 300 acre-feet are required to produce a 

corn crop on 130 acres in western Kansas. Little or no short-term impact to groundwater levels or availability 

would result from the proposed project uses, since supplies would be purchased from existing groundwater 

users, based on existing rights. 

The change in beneficial use (from agriculture or other existing use to a temporary industrial use) would likely 

create a short-term impact on land use. Mitigating these minor impacts by substituting streamflow or reservoir 

withdrawals for groundwater pumping would generate impacts to surface water and associated resources 

(e.g., fisheries and wildlife). These alternative impacts would probably be greater than the groundwater 

impacts offset by the supply substitution. No impacts to long-term groundwater resource availability or quality 

would result from the proposed withdrawals for project purposes. 

Overland Pass has proposed measures in the project Hydrostatic Testing Plan (Appendix D) to manage test 

water discharges. Compliance with approved permit requirements to control discharge and drainage would 

mitigate potential land and water resources impacts from groundwater discharges. However, many wells on 

the Great Plains intercept aquifers other than the Ogallala Formation or streamlain alluvial deposits. In 

addition, these common groundwater sources are absent in some locales. Because of this, other sources of 

groundwater could be needed for project uses. However, the water quality in alternative aquifer sources (such 

as some waterbearing zones in the Dakota Formation, Carlile Shale, Greenhorn Limestone, or Permian rocks) 

may not be suitable for surface discharge. When discharged on the surface, existing elevated concentrations 

of dissolved solids or other water quality constituents in these aquifers could create water quality impacts to 

vegetation, land use, or nearby wetlands or surface water. Overland Pass has agreed that groundwater 

pumped and discharged aboveground for construction purposes shall meet agricultural water quality standards 

in the respective states and/or districts where it is discharged. 

Groundwater withdrawals for an HDD crossing at the Cheyenne Hub would require about 1.5 acre-feet 

(500,000 gallons). The anticipated water source consists of industrial wells owned by gas companies at the 

site. No impacts to aquifers in that area are anticipated. 

Springs and Wells 

The proposed alignment would be located several hundred feet away from springs that are known to occur in 

specific locales from RP 205 to RP 209 (east of Wolcott, Wyoming), and from RP 282 to RP 286 (southeast of 

Laramie, Wyoming). Due to topographic and geologic conditions, trenching would not be likely to affect these 

known seep or spring features. The backfilled trench is not likely to permanently obstruct groundwater 

drainage through alluvial deposits or other areas where groundwater is at relatively shallow depths, though it 

may act as a conduit to transport water unless proper trench plugs are installed. Because of this, Overland 

4.5-17
Pass has agreed that when groundwater is observed during construction (e.g., sites requiring dewatering due 

to groundwater, saturated wetlands), permanent trench breakers shall be installed to prevent unintentional 

transport of groundwater by the pipeline trench. 

The existence and locations of wells have been investigated for the project. The search of recorded well data 

identified 47 wells in Wyoming, 54 wells in Colorado, and 108 wells in Kansas that are within 500 feet of the 

proposed ROW. Five of these are on federally managed lands. Of the total number of wells identified, six are 

within 50 feet of the proposed construction workspace, and 27 are within 100 feet (NRG 2006). 

To avoid impacts to water wells during construction, Overland Pass would conduct pre- and post-construction 

monitoring of well yield and water quality on all potable wells located within 50 feet of the construction work 

area. In addition, the Blasting Plan prepared by Overland Pass addresses environmental aspects of blasting 

activities, identifies areas of concern along the proposed ROW, and identifies practices to promote safety and 

minimize blasting effects. Overland Pass would either repair or replace potable water supply wells damaged 

by construction activities (including blasting), or fairly compensate the landowner for damage to potable water 

supply wells resulting from pipeline construction (NRG 2006). As a result of these practices and mitigation 

measures, no significant impacts to water wells are anticipated from construction activities. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Potential impacts to groundwater resources from pipeline construction include damage to nearby wells, well 

yield, and pumps from blasting; contamination of shallow aquifers from fuel, lubricant, or hazardous material 

spills or leaks; temporary modification of shallow groundwater flow (where present) through trench dewatering 

and pipeline installation; and reduction in groundwater levels where wells are pumped for hydrostatic testing 

purposes. Impacts to groundwater resources would be minimized or avoided by use of standard construction 

practices and protection measures as described in Overland Pass’ Blasting Plan, SPCC Plan, Hydrostatic 

Testing Plan, and Construction, Reclamation, and Revegetation Plan. All of these plans are included in 

Overland Pass’ POD (Overland Pass 2007). The applicant-committed measures would ensure that 

groundwater used for hydrostatic testing purposes is of sufficient quality so as to not impact terrestrial 

resources when discharged aboveground. Committed measures also would prevent the unintentional transport 

of groundwater via the pipeline trench. 

Operation Phase 

Issue 

• Potential reductions in groundwater quality from pipeline spills, leaks, or ruptures on shallow aquifers 

used for rural residential, livestock, and municipal water supplies. 

Analysis 

Spills/Leaks 

If a pipeline leak occurred, released NGLs would vaporize. Gases would percolate up through the soil and 

sediments, and eventually dissipate into the atmosphere. Most, if not all of the NGL components would 

evaporate on the land surface or within the vadose (unsaturated) zone above the water table. Only 

approximately 2 to 4 percent of the NGL components would not readily volatilize at atmospheric pressure 

(Appendix L). A small portion of these could enter shallow groundwater depending on the location of the 

rupture or leak after eventually migrating through unsaturated materials. Because of their slight solubility in 

water, contamination from NGL components would be limited to a few parts-per-million. These concentrations 

4.5-18
would be further reduced by diffusion and natural attenuation, which would further reduce the risk to potential 

receptors (BLM 2005). 

The potential exists for groundwater contamination and subsequent withdrawal to a use (e.g., domestic or 

municipal supply, livestock watering) if a catastrophic rupture occurs near a well that is pumping during or near 

the time of rupture. Emergency shutoff valves would limit the extent of contamination. Overland Pass would 

implement committed measures that would minimize potential impacts from such an event. 

Due to the geologic setting, operational impacts from the Proposed Action on the sole source aquifer in the Elk 

Mountain area are not expected to occur. Given the characteristics of NGLs and their transport conditions 

within the pipeline, it is unlikely that adverse impacts on groundwater and wells in the Casper Aquifer 

protection zone would occur. Furthermore, applicable USDOT regulations for hazardous liquids pipelines 

promote structural integrity, early leak detection, and rapid response (Section 3.12). These factors would 

provide further protection toward avoiding groundwater impacts. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

In the event of a pipeline rupture or spill, groundwater impacts from pipeline operation likely would be minimal 

due to the rapid volatilization of NGLs once released from pressure and their marginal solubility in water. 

4.5.1.3 Floodplains, Wetlands, and Riparian Areas 

Construction Phase 

Issues 

• Potential modifications in wetland productivity due to modifications in surface and subsurface flow 

patterns. 

• Modifications in wetland vegetation community composition and structure from construction clearing. 

Analysis 

Construction in wetlands primarily would result in temporary effects including the temporary loss of wetland 

vegetation, soil disturbance, and temporary increases in turbidity and fluctuations in wetland hydrology. To 

minimize these impacts on wetlands, Overland Pass would overlap its construction ROW along previously 

disturbed corridors for approximately 83 percent of the proposed pipeline route. No aboveground facilities 

would be located within wetlands. 

Based on wetland field delineation data and a proposed 75-foot-wide construction ROW, the proposed pipeline 

route temporarily would affect 59.0 acres of wetlands (Table 4.6-1). Of that total disturbance, 0.7 acre occurs 

on federally managed land. TWAs would impact an additional 21.6 acres of wetlands, 0.2 acre of the total 

disturbance occurring on federally managed land. 

Large riparian areas are associated with the North Platte River and Medicine Bow River crossings in 

Wyoming. Overland Pass proposes TWAs within these and other riparian areas. 

To minimize environmental impacts to floodplains, wetlands, and riparian areas during the construction phase 

of the project, Overland Pass would implement the construction and mitigation procedures provided in the 

Construction, Reclamation, and Revegetation Plan (Appendix C), which include topsoil salvage and 

replacement, grading the construction ROW to restore pre-construction contours and drainage patterns, and 

4.5-19
limiting human disturbance/access. Following these construction procedures and mitigation measures would 

greatly increase the probability that emergent (PEM) wetland communities (representing 93 percent of all 

wetlands affected) would revegetate rapidly (within 3 years) (Van Dyke 1994; FERC 2004). Disturbance to 

PSS and PFO wetlands would result in a long-term impact as the recovery of these communities would take 

5 to 10 years and 50 to 100 years for a mature forest, respectively. 

Pipeline construction in wetlands could temporarily alter wetland surface and subsurface water flow patterns 

through trenching activities. This hydrologic impact would be localized and temporary until permanent trench 

breakers were installed and the trench was backfilled. 

Additional Mitigation 

Mitigation measures VEG-1 and WATER-5 describe mitigation measures to minimize impacts to riparian areas 

and wetlands. 

Conclusion 

Wetland herbaceous vegetation generally would begin to be re-established along the ROW within 2 to 3 years 

post-construction. Recovery of scrub-shrub wetlands would require up to a decade, and 50 or more years 

would be required for recovery of palustrine forested wetland communities. Impacts on wetland and riparian 

communities would depend on the individual vegetation community and site-specific soil and moisture 

conditions received post-construction. 

Operation Phase 

Issues 

• Modifications in wetland and riparian vegetation community composition and structure from 

operational maintenance. 

• Potential for spills to adversely affect wetlands. 

Analysis 

Following construction, wetland and riparian vegetation would be allowed to regenerate to the original cover 

type, with the exception of 0.5 acre, which would be maintained as herbaceous vegetation within the 

permanent 10-foot-wide operational ROW to facilitate pipeline maintenance and monitoring. Trees greater 

than 15 feet in height would be removed from a 30-foot-wide strip centered over the pipeline. Wetland 

vegetation would be lost temporarily during construction; however, with the exception of scrub-shrub and 

forested wetlands that would be maintained in an herbaceous state, all wetland vegetation would be 

reestablished within 3 years following construction. The success of wetland revegetation would be monitored 

for the first 5 years after construction (in July, during the first, third, and fifth growing seasons) or until wetland 

revegetation is successful. No aboveground facilities would be located in wetlands or floodplains. 

In the unlikely event of a pipeline release in a wetland or riparian area, NGL components would rapidly 

volatilize, thereby posing minimal impacts, if any. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Pipeline operational ROW maintenance activities in wetlands and riparian areas would result in localized, 

short-term impacts as a result of periodic clearing of woody vegetation over the pipeline centerline. If NGLs 

4.5-20
were accidentally released into the environment, minimal impacts, if any, would be expected to wetland and 

riparian resources. 

4.5.2 No Action Alternative 

Under the No Action Alternative, the proposed project would not be constructed nor operated. No 

project-related disturbance would occur for water resources. Impacts to water resources would continue at 

present levels as a result of natural conditions and existing development in the project area. 

4.5.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

The effects of the Southern Energy Corridor – Copper Ridge Bypass Alternative on surface water and 

groundwater resources would be similar to impacts discussed for the Proposed Action. There would be two 

additional perennial streams crossed by the Southern Energy Corridor – Copper Ridge Bypass Alternative 

(Little Bitter Creek and Cedar Creek). No hydrostatic test water withdrawals would occur in these streams. 

Overland Pass estimates this alternative would require approximately 300,000 gallons of additional water for 

hydrostatic testing (Appendix G). 

The effects of this alternative on groundwater, floodplains, wetlands, and riparian resources would be similar to 

impacts described for the Proposed Action. Groundwater resources for this alternative are similar to the 

groundwater resources described for the Proposed Action. 

4.5-21
4.6 Vegetation 

4.6.1 Proposed Action 

4.6.1.1 Vegetation Communities and Special Status Plant Species 

Construction Phase 

Issues 

• Vegetation removal for facility construction with consequent reduction in wildlife habitat and increased 

risk of soil erosion. 

Analysis 

Construction and operation activities would affect vegetation communities in a variety of ways, from temporary 

herbaceous trampling and partial removal of aboveground plant cover to minimal long-term vegetation 

removal. Clearing, trenching, grubbing, blading, and vegetation trampling would occur within the proposed 

project areas. Impacts to vegetation communities associated with construction are classified as short-term or 

long-term. These short-term and long-term disturbance areas would be reclaimed and would provide forage 

and habitat for wildlife within 3 to 5 years following successful reclamation. 

Construction of the proposed project would involve short-term impacts due to construction on approximately 

4,759 acres of grasslands, 768 acres of shrublands, 2,472 acres of agricultural land, 60 acres of forested 

areas, and 81 acres of wetland vegetation as shown in Table 4.6-1. The majority of the pipeline ROW would 

be allowed to revert to pre-construction conditions. 

The primary impact of the proposed project on vegetation would be the cutting, clearing, and/or removal of 

existing vegetation within the construction work area. The degree of impact would depend on the type and 

amount of vegetation affected and the rate at which the vegetation would regenerate after construction. 

To minimize environmental impacts and ensure site stabilization and revegetation, Overland Pass would follow 

construction procedures detailed in its POD, including its Construction, Reclamation, and Revegetation Plan 

(Appendix C). The Construction, Reclamation, and Revegetation Plan describes methods that would be 

implemented to stabilize disturbed sites by reducing runoff and erosion; to reestablish a vegetation condition 

comparable to preconstruction conditions; to restore functional qualities of the area including wildlife habitat 

and livestock forage; and to prevent degradation of areas off the construction ROW. Additionally, Overland 

Pass would follow the measures outlined in the SPCC Plan and the SWPPP to minimize and mitigate potential 

impacts on wetlands. Key applicant-committed mitigation measures are identified in Appendix A. 

Timely stabilization of the construction ROW and reseeding with an appropriate seed mix would minimize the 

duration of vegetation disturbance. The BLM would inspect the pipeline ROW on federal lands for a minimum 

of five years to ensure Overland Pass’ compliance with revegetation standards established in Overland Pass’ 

POD. 

Long-term impacts could occur on short-grass prairie and sagebrush steppe, as well as native grasslands and 

shrublands. Reclamation efforts would re-establish vegetation along the ROW within 2 growing seasons, but 

full recovery of these habitats could take a minimum of 5 to 7 years (or longer for shrublands) due to poor soil 

and low moisture conditions. 

Long-term construction impacts could occur on shrublands, such as sagebrush. Recovery of these habitats 

could take a minimum of 20 to 30 years due to poor soil and low moisture conditions. 

4.6-1
Table 4.6-1 Acres of Land Affected by Construction and Operation of the Project1 

Facility/State 

Grassland Shrubland Agricultural Land Forest Land 

Const. Oper.3 Const. Oper.3 Const. Oper.3 Const. Oper.

Pipeline 

Wyoming Total

Federal 

Non-Federal 

 2,397.0 0.0 409.8 0.0 28.8 0.0 45.4 30.3 

713.4 0.0 153.6 0.0 0.4 0.0 18.6 12.4 

1,683.6 0.0 256.1 0.0 28.4 0.0 26.8 17.9 

Colorado Total

Federal

Non-Federal

 907.5 0.0 232.4 0.0 408.4 0.0 0.2 0.2 

204.4 

0.0 0.0 0.0 0.5 0.0 0.0 0.0 

703.1 

0.0 232.4 0.0 407.9 0.0 0.2 0.2 

Kansas4 Total

Federal 

Non-Federal 

667.2 

0.0 14.6 0.0 1,668.9 0.0 8.4 5.6 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

667.2 0.0 14.6 0.0 1,668.9 0.0 8.4 5.6 

Pipeline Total 

Pipeline Federal 

Pipeline Non-Federal 

3,971.7 0.0 656.8 0.0 2,106.1 0.0 54.0 36.1 

917.8 0.0 153.6 0.0 0.9 0.0 18.6 12.4 

3,053.9 0.0 503.2 0.0 2,105.2 0.0 35.4 23.7 

Additional Temporary Workspace Areas 

Wyoming Total

Federal 

Non-Federal 

 462.5 0.0 92.4 0.0 28.0 0.0 3.2 0.0 

138.4 0.0 43.2 0.0 0.0 0.0 1.5 0.0 

324.1 0.0 49.1 0.0 28.0 0.0 1.8 0.0 

Colorado Total

Federal 

Non-Federal 

 106.2 0.0 16.7 0.0 43.4 0.0 0.0 0.0 

13.3 0.0 0.0 0.0 0.8 0.0 0.0 0.0 

92.8 0.0 16.7 0.0 42.7 0.0 0.0 0.0 

Kansas4 Total

Federal 

Non-Federal 

 175.4 0.0 2.7 0.0 251.3 0.0 3.3 0.0 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

175.4 0.0 2.7 0.0 251.3 0.0 3.3 0.0 

Additional Temporary Workspace Areas Total 

Additional Temporary Workspace Areas Federal 

Additional Temporary Workspace Areas Non-Federal 

744.2 0.0 111.7 0.0 322.8 0.0 6.5 0.0 

151.8 0.0 43.2 0.0 0.8 0.0 1.5 0.0 

592.4 0.0 68.5 0.0 322.0 0.0 5.0 0.0 

Pipe Storage and Contractor Yards (Non-Federal Lands) 

Wyoming 

Opal Yard Blacks Fork Contractor Yard Thayer Junction Pipe Storage/Contractor Yard5Echo Springs Yards (2) Rawlins Pipe Storage/Contractor Yard5Laramie Pipe Storage/Contractor Yard (2) 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

8.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

0.0 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 

7.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

0.0 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

4.6-2
Table 4.6-1 Acres of Land Affected by Construction and Operation of the Project1 

Facility/State 

Grassland Shrubland Agricultural Land Forest Land 

Const. Oper.3 Const. Oper.3 Const. Oper.3 Const. Oper.

Colorado 

Carr Contractor Yard Otis and Unnamed Pipe Storage/Contractor 

Yards5 (4) 

12.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Kansas 

Bird City Pipe Storage Yard Gem Pipe Storage/Contractor Yard Hoxie and Unnamed Yards (4) Rexford Pipe Storage/Contractor Yard Hoisington Pipe Storage/Contractor Yard5 Conway Yard 

0.0 0.0 0.0 0.0 2.5 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 12.2 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 16.2 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 4.1 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 2.1 0.0 0.0 0.0 

Pipe Storage and Contractor Yards Total 27.7 0.0 0.0 0.0 37.1 0.0 0.0 0.0 

Appurtenances (Valves, Pigging Facilities, and Tees) 

Wyoming Total

Federal 

Non-Federal 

3.0 

1.6 0.0 <0.1 0.0 0.1 0.0 0.0 

0.0 0.2 0.0 <0.1 0.0 0.0 0.0 0.0 

3.0 1.4 0.0 <0.1 0.0 0.1 0.0 0.0 

Colorado Total 

Federal 

Non-Federal 

1.0 0.6 0.0 0.0 0.0 0.3 0.0 0.0 

0.0 <0.1 0.0 0.0 0.0 0.0 0.0 0.0 

1.0 0.6 0.0 0.0 0.0 0.3 0.0 0.0 

Kansas4 Total

Federal 

Non-Federal 

1.0 

0.4 0.0 <0.1 2.0 1.3 0.0 0.0 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

1.0 0.4 0.0 <0.1 2.0 1.3 0.0 0.0 

Appurtenances Total 

 Appurtenances Federal 

Appurtenances Non-Federal 

5.0 2.6 0.0 <0.1 2.0 1.7 0.0 0.0 

0.0 0.2 0.0 <0.1 0.0 0.0 0.0 0.0 

5.0 2.4 0.0 <0.1 2.0 1.7 0.0 0.0 

Aboveground Facilities (Non-Federal Lands) 

Wyoming 

Echo Springs Pump Station Echo Springs Meter Station 5 Opal Meter Station5 Laramie Pump and Meter Station 

Aboveground Facilities Wyoming Total 

3.7 1.7 0.0 0.0 0.0 0.0 0.0 0.0 

1.5 0.1 0.0 0.0 0.0 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 5.2 1.8 0.0 0.0 0.0 0.0 0.0 0.0 

10.4 3.6 0.0 0.0 0.0 0.0 0.0 0.0 

4.6-3
Table 4.6-1 Acres of Land Affected by Construction and Operation of the Project1 

Facility/State 

Grassland Shrubland Agricultural Land Forest Land 

Const. Oper.3 Const. Oper.3 Const. Oper.3 Const. Oper.

Colorado 

Washington County Meter Station and Pigging Facility 

Aboveground Facilities Colorado Total

0.0 0.0 0.0 0.0 1.2 0.2 0.0 0.0 

0.0 

0.0 0.0 0.0 1.2 0.2 0.0 0.0 

Kansas 

WaKeeney Meter Station6 Bushton Meter Station and Pigging Facility5Conway Meter Station and Pigging Facility5

Aboveground Facilities Kansas Total 

0.0 0.0 0.0 0.0 1.5 0.2 0.0 0.0 

0.0 

0.0 0.0 0.0 1.2 0.2 0.0 0.0 

0.0 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 

0.0 0.0 0.0 0.0 2.7 0.4 0.0 0.0 

Aboveground Facilities Project Total 10.4 3.6 0.0 0.0 3.9 0.6 0.0 0.0 

Project Total7 4,758.9 6.2 768.5 <0.1 2,471.8 2.3 60.5 36.0 Federal Lands Total7 1,069.6 0.2 196.8 <0.1 1.7 0.0 20.1 12.4 Non-Federal Lands Total7 3,689.3 6.0 571.7 <0.1 2,470.2 2.3 23.6 23.6 1Const. – construction. Oper. – operation. Acres based on a 75-foot-wide construction ROW and 50-foot-wide permanent ROW. Does not include developed, c

water, or barren areas that do not display vegetation characteristics. Vegetation characteristics were as provided on a USGS large-scale land use/land cover (www.mrlc.gov). 2Wetland totals may differ from Table 3.5-7 where National Wetland Inventory map data were used to calculate wetland impacts. 3No permanent impacts would occur as part of pipeline construction as vegetation would be allowed to revert to pre-construction conditions with the excep

aboveground facilities, forested areas that would be maintained in an herbaceous state within the permanently maintained 50-foot-wide operational ROWcentered over the pipeline in palustrine scrub-shrub and forested wetlands areas. In addition, if conditions require, non-forested vegetation would be clea50-foot-wide permanent ROW on an as-needed basis not to exceed once every 3 years. In wetlands and riparian areas, a 10-foot-wide corridor centered maintained annually in an herbaceous state. In addition, if conditions required, trees within a 25-foot-wide corridor centered over the pipeline could be selfrom the ROW on an as-needed basis not to exceed once every 3 years. 4All lands crossed by the proposed pipeline in Kansas would be non-federal lands. 

5Pipe storage/contractor yards or aboveground facility would be located on land that does not display vegetation characteristics (e.g., commercial/industria6Does not include areas in agricultural land associated with the potential future WaKeeney Pump Station. 7The numbers in this table have been rounded for presentation purposes. As a result, the totals may not reflect the exact sum of the addends in all cases. 

82.2 acres for access roads during pipeline operation. 

4.6-4
Impacts on agricultural vegetation communities would be short term in nature, as the vegetation would 

generally be reestablished within 2 years of restoration depending on climatic conditions. Overland Pass would 

not reseed cultivated agricultural areas unless requested by the landowner. 

Clearing of forest and/or woodland vegetation within the construction ROW would result in long-term 

environmental change. Over time, natural growth would restore the unmaintained portions of the temporary 

construction ROW and TWAs back to a forested community. The rate of forest reestablishment would depend 

upon the type of vegetation, the length of growing season, and the natural fertility of the soils. Regrowth to the 

sapling-young tree stage could take 15 to 30 years, while regrowth of forests to mature conditions could take 

between 50 to 100 years depending on the species. 

Riparian communities would be crossed by the project including large riparian areas on private lands 

associated with the North Platte River and Medicine Bow River crossings. On federal lands, riparian areas 

exist at the Green River, Bitter Creek, and Little Bitter Creek crossings. Overland Pass proposes TWAs within 

riparian areas. 

Wetland vegetation would be temporarily lost during construction; however, with the exception of scrub-shrub 

and forested wetlands that would be maintained in an herbaceous state, all wetland vegetation would be 

anticipated to be reestablished within 3 years following construction. 

Successful reclamation of sensitive plant communities could take 10 years or more to return to pre-disturbance 

condition. Successful reclamation of sagebrush communities could take in excess of 50 years, depending on 

the species of sagebrush, soil conditions, and the amount of precipitation received post-construction. The 

severity of these disturbances depends on the timing and duration of the disturbance activities and the 

sensitivity of the plant communities. 

Additional Mitigation 

VEG-1: To minimize impacts to waterbodies, wetlands, and riparian areas, Overland Pass shall set back 

TWAs a minimum distance of 50 feet from the edge of waterbodies, wetlands, or riparian areas, 

whichever distance would provide the greatest protection. The distance shall be measured from the 

water bank of the waterbody, the margin of a wetland, and the exterior edge of a riparian area. In 

addition, erosion and sediment control measures, including but not limited to, silt fence, straw bales, 

berms, water bars, and mulching shall be installed around each TWA to prevent soil movement into 

the nearby sensitive area. Riparian areas form a transition between permanently saturated wetlands 

and upland areas and are typically associated with waterbodies (see Glossary). 

Conclusion 

Herbaceous cover generally would begin to be re-established along the ROW within 2 years post-construction. 

However, full recovery of non-agricultural communities often would require more than 5 years, while recovery 

of agricultural and wetland communities would be expected more quickly. Impacts on vegetation communities 

would depend on the individual vegetation community, site-specific soil conditions, and the amount of 

precipitation received post-construction. Reduction of the construction ROW width to 60 feet in riparian 

woodlands and wetlands in WATER-5 would reduce the area of disturbance to this important vegetation type. 

Implementation of the additional mitigation measure (VEG-1) would reduce impacts to wetlands and riparian 

communities by at least 20 percent on federal lands. 

4.6-5
Operation Phase 

Issues 

• Permanent vegetation changes in the ROW and areas of aboveground facilities. 

• Potential for spills to adversely affect vegetation, particularly threatened and endangered plant 

species. 

Analysis 

Operational impacts on vegetation primarily would be limited to areas required for operation of the pump 

stations, meter stations, and other aboveground appurtenances (approximately 6.2 acres of grassland and 

2.3 acres of agricultural land). In addition, Overland Pass would permanently maintain a 50-foot-wide corridor 

in forested areas and a 10-foot-wide corridor in palustrine forested areas. This corridor would be kept in an 

herbaceous state by periodic mowing or brush clearing according to the guidelines outlined in the 

Construction, Reclamation, and Revegetation Plan (Appendix C). The degree of impact would depend on the 

frequency of vegetation maintenance conducted during operation and the type and amount of vegetation 

affected. Given the long recovery period for woodlands, maintenance of vegetation in the future would be 

nominal. 

The Echo Springs Meter Station at RP 146.5 would be located on grasslands within the existing Echo Springs 

facility. During construction, a total of 3.7 acres would be disturbed, 1.7 of which would be converted to 

operation of the meter station. The Echo Springs Pump Station would be located within a sagebrush steppe 

community and would affect a total of 1.5 acres of grassland temporarily and 0.1 acre of grassland 

permanently. The Laramie Pump and Meter Station (RP 271.7) would be new facilities. The Laramie Pump 

and Meter Stations would be located within a mixed grass prairie community and would affect a total of 

5.2 acres of grassland temporarily and 1.8 acres of grassland permanently. 

The Opal (RP 0.0) and Conway (RP 749.4) meter stations would be located within existing, previously 

disturbed commercial/industrial areas; therefore, no vegetation impacts beyond those already experienced at 

these sites would be anticipated during the construction and operation of these facilities. The Bushton Meter 

Station would impact 1.2 acres of agricultural land during construction and 0.2 acre during operation of the 

facility. The Washington County Meter Station (RP 447.8) and WaKeeney Meter Station (RP 606.0) would be 

new meter stations located in agricultural communities and would affect 2.7 acres of agricultural land 

temporarily and 0.4 acre of agricultural land permanently. If the WaKeeney Pump Station were built in the 

future, it is estimated that it would affect 3.7 acres of agricultural land during construction and 1.7 acres of 

agricultural land during operation. 

Potential vegetation impacts could occur during maintenance operations along the ROW or at aboveground 

facilities. These activities would be dispersed along the length of the project and would occur intermittently. 

There is a small chance that the pipeline could accidentally leak, releasing NGL into the environment 

(Section 3.12). NGLs primarily consist of gas that is liquefied by pressure (e.g., propane). Consequently, in the 

unlikely event of a pipeline release, NGL components would rapidly volatilize, thereby posing minimal impacts 

to vegetation (Appendix L). 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Operational impacts on vegetation would be limited to areas required for operation of aboveground facilities 

affecting approximately 6.2 acres of grassland and 2.3 acres of agricultural land. 

4.6-6
Maintenance activities along the proposed pipeline route would result in localized impacts of short duration 

(less than 14 days in most cases) and these impacts would be dispersed along the entire proposed pipeline 

route. 

If NGLs were accidentally released into the environment, minimal impacts, if any, would be expected to soil 

resources. 

4.6.1.2 Noxious Weeds and Invasive Plant Species 

Construction Phase 

Issues 

• Potential expansion of noxious weeds and invasive plant populations along the pipeline ROW. 

Analysis 

The prevention of the spread of noxious weeds is a high priority to the communities in Wyoming, Colorado, 

and Kansas. Vegetation removal and soil disturbance during construction could create optimal conditions for 

the establishment of invasive, non-native species. Construction equipment traveling from weed-infested areas 

into weed-free areas could disperse invasive noxious weed seeds and propagates, resulting in the 

establishment of noxious weeds in previously weed-free areas. 

To control the spread of noxious and invasive weeds along the pipeline corridor, Overland Pass would 

implement weed control measures in accordance with existing regulations and jurisdictional land management 

agency or landowner agreements and in accordance with its Weed Management Plan (Appendix E). 

Applicant-proposed mitigation measures include, but are not limited to, preconstruction surveys, vehicle 

cleaning stations, and certified weed-free straw bales, and certified weed-free seed mixes for restoration. Key 

applicant-committed mitigation measures are identified in Appendix A. 

In order to accomplish weed prevention and control in the most appropriate and effective manner, Overland 

Pass has committed in their Weed Management Plan to initially monitor noxious weeds annually for 5 years 

following construction. In areas where weed infestations still required management, surveys and control 

measures would be implemented where problem areas still existed. Post-construction weed control measures 

may include the application of herbicide or mechanical, and/or alternative methods. The weed control measure 

chosen would be the best method available for the time, place, and species of weed as mutually agreed upon 

by Overland Pass and the appropriate regulatory agencies. 

Landowners would be consulted regarding weed control status and implementation measures and encouraged 

to report concerns to Overland Pass. In the event noxious weed species become established in the ROW, 

Overland Pass would make good faith efforts to control weeds in the ROW and to work with adjacent 

landowners to prevent spread of the species to adjacent lands. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Despite efforts to prevent the spread of noxious weeds, it is possible that pipeline construction would increase 

the prevalence of noxious and invasive weeds along the ROW or that weeds would be transported into areas 

that were relatively weed-free. Implementation of Overland Pass’ Weed Management Plan would minimize the 

spread of undesirable weed species. Since the publication of the Draft EIS, Overland Pass has committed to 

supplemental mitigation measures intended to prevent the spread of undesirable weeds. These applicantcommitted mitigation measures are presented in Appendix A, Table A-1. 

4.6-7
Operation Phase 

Issues 

• Future maintenance activities may cause the same effects discussed for construction. 

Analysis 

The potential impacts are the same as discussed for construction, but would pertain only to the aboveground 

facility areas and the permanent ROW. 

Additional Mitigation 

VEG-2: Overland Pass shall continue to monitor and control invasive plant species and noxious weeds along 

the ROW for the life of the project. 

Conclusion 

Despite efforts to prevent the spread of noxious weeds, it is possible that pipeline maintenance activities would 

increase the prevalence of noxious and invasive weeds along the ROW or that weeds would be transported 

into areas that were relatively weed-free. Implementation of VEG-2 would minimize the spread of undesirable 

weed species from operational impacts. 

4.6.2 No Action Alternative 

Under the No Action Alternative, the proposed project would not be constructed or operated. No project-related 

disturbance would occur to vegetation and impacts would continue at present levels as a result of natural 

conditions and existing development in the project area. 

4.6.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

Vegetation communities along the Southern Energy Corridor – Copper Ridge Bypass Alternative are 

comparable to those along the Proposed Action. The Southern Energy Corridor – Copper Ridge Bypass 

Alternative would be 4.8 miles longer than the Proposed Action, resulting in an additional 44 acres of 

temporary disturbance. Steep and side slope construction would result in 35 acres of TWAs along the 

Southern Energy Corridor – Copper Ridge Bypass Alternative, compared to 17 acres for the Proposed Action. 

These areas would be more susceptible to erosion and would be more difficult to reclaim. 

4.6-8
4.7 Wildlife, Aquatic Resources, and Special Status Species 

4.7.1 Proposed Action 

4.7.1.1 Wildlife 

Construction Phase 

Issues 

• Habitat reductions and fragmentation from construction clearing. 

• Direct disturbance and loss of individuals from construction activities along the ROW and access 

roads. 

• Indirect effects consisting of displacement of individuals and loss of breeding success from exposure 

to construction noise, and from higher levels of human activity. 

Analysis 

Potential impacts on terrestrial wildlife species from the proposed project can be classified as short-term, 

long-term, and permanent. Short-term impacts consist of habitat removal, activities associated with project 

construction, and changes in wildlife habitats lasting less than 5 years. Long-term impacts would consist of 

changes to wildlife habitats lasting 5 years or more. Permanent impacts result from construction of 

aboveground facilities that convert natural habitat to natural gas operations. The severity of both short- and 

long-term impacts would depend on factors such as the sensitivity of the species impacted, seasonal use 

patterns, type and timing of project activities, and physical parameters (e.g., topography, cover, forage, and 

climate). 

In total, surface disturbing activities would affect approximately 5,639 acres of wildlife habitat of which 

1,183 acres would occur as a new greenfield ROW. The greenfield portions of the proposed pipeline route 

consist of 5 general vegetation communities: shrubland (approximately 633 acres), grassland (192 acres), 

agriculture (387 acres), woodland (29 acres), wetlands (15 acres), developed (8 acres), and no vegetation 

(13 acres). 

Approximately 662 acres of the new greenfield ROW consists of forest land and shrubland habitats. These 

two habitat types require significant timeframes for restoration and impacts to these habitats are considered 

long-term. However, due to the linear nature of the project over a large geographic area, and its configuration 

next to existing disturbance, these acreages represent a minimal amount of available wildlife habitat on a 

regional basis. 

Game Species 

Direct impacts to big game species (elk, mule deer, pronghorn) would include the incremental loss of potential 

forage (native vegetation and previously disturbed vegetation) and would result in an incremental increase in 

habitat fragmentation within the proposed surface disturbance areas. However, as noted above, these 

incremental losses of vegetation would represent only a minimal amount of available habitat within the broader 

project region. The loss of native vegetation would be long term (greater than 5 years and, in some cases 

more than 50 years). In the interim, herbaceous species may become established within 3 to 5 years, 

depending on future weather conditions and management practices (e.g., livestock grazing) that would affect 

reclamation success in the project region. In most instances, suitable habitat adjacent to the disturbed areas 

would be available for wildlife species until grasses and woody vegetation were reestablished within the 

disturbance areas. However, assuming the adjacent habitats are at or near carrying capacity, and given the 

current drought conditions in the project region, displacement of wildlife species as a result of construction 

could cause some unquantifiable reduction in wildlife populations. Indirect impacts would result from increased 

noise levels and human presence during surface disturbance activities. Big game animals (especially 

4.7-1 
pronghorn and mule deer) likely would decrease their use within 0.5 mile of surface disturbance activities 

(BLM 1995). However, this displacement would be short-term and animals would return to the disturbance 

area following construction activities. Vehicular activity associated with construction activities also would 

increase potential for collisions and possible big game mortality within the project area and on associated 

access routes. 

Construction activities within big game crucial winter range would result in the incremental disturbance of 

approximately 338 acres of mule deer habitat, 877 acres of pronghorn habitat, and 99 acres of elk habitat. 

Approximately 140 acres of the identified habitat is crucial winter habitat for two species. Of the 1,141 acres of 

crucial winter habitat that would be impacted, 138 acres would occur as a new ROW. Big game crucial winter 

habitat with timing restrictions and disturbance acreage area is presented in Table 4.7-1. However, on a 

regional basis, these acreages of disturbance would represent a small percentage of the overall habitat within 

these areas. The effects of animal displacement, avoidance, and potential for collision are of greatest concern 

in the crucial winter habitat (WGFD 2005e). 

Table 4.7-1 Big Game Crucial Winter Habitat Affected by the Proposed Action1

State/Range Type 

 Total Acres 

Impacted 

Acres 

Federal Lands Non-Federal Lands 

Wyoming 

Mule Deer Crucial Winter Habitat 338.2 80.0 258.2 

Pronghorn Crucial Winter Habitat 669.5 198.2 471.3 

Elk Crucial Winter Habitat 99.0 6.1 92.9 

Colorado 

Pronghorn Crucial Winter Habitat 207.7 46.3 161.4 

1

Crucial big game ranges identified by WGFD and CDOW. Habitats identified in this table have timing restrictions; crucial winter 

habitat without timing restrictions are not included in this table. 

Multiple agencies have expressed concerns regarding big game species potentially falling into the trench and 

being injured or entrapped when attempting to jump over strung pipe (WGFD 2005e; BLM 2006b). In order to 

reduce potential impacts to wildlife from pipeline construction, Overland Pass has committed to installing 

trench plugs on federal lands at a maximum interval distance of 0.5 mile, with a corresponding gap in the 

welded pipe left open at each trench plug. A 20-foot gap would be left at trench plugs in all spoil and topsoil 

stockpiles. Finally, Overland Pass has agreed to install a suitable ramp-up out of the trench with a 5-foot-wide 

path maintained across the trench plug. 

Indirect impacts resulting from construction include increased noise levels and human presence during surface 

disturbing activities. Big game (especially pronghorn, elk, and mule deer) and more mobile small game 

animals likely would decrease their use within 0.5 mile of surface disturbance activities (Ward et al. 1980; 

Ward 1976). This displacement would be short-term and animals would return to the disturbance area 

following construction activities. 

Nongame Species 

Direct impacts to nongame species from surface disturbance activities would result in the incremental 

long-term loss of habitat and increased fragmentation until vegetation became reestablished. Potential impacts 

also would result in mortalities of less mobile or burrowing non-game species (e.g., small mammals, birds, 

reptiles, amphibians, invertebrates) as a result of crushing from vehicles and equipment. Other impacts would 

include the short-term displacement of some of the more mobile species (e.g., medium-sized mammals, adult 

birds) as a result of surface disturbance activities. Although the habitats adjacent to the proposed disturbance 

area may support some displaced animals, species that are at or near carrying capacity could suffer some 

increased mortalities. 

4.7-2 
Direct impacts to nesting raptors that are located within or adjacent to the proposed pipeline route, would 

include abandonment of a breeding territory or nest sites or the potential loss of eggs or young as a result of 

surface disturbance activities (e.g., ground disturbance, noise, human presence). These losses, if they were to 

occur, would reduce productivity for that breeding season. However, the degree of these potential impacts 

would depend on a number of variables such as the location of the nest site, the species’ relative sensitivity, 

breeding phenology, and possible topographic shielding. Impacts to one bald eagle nest could occur as a 

result of this project. Consultation with the BLM and USFWS will occur to mitigate the potential for these 

impacts if they were to occur during the breeding season. Impacts to one golden eagle nest could result from 

the construction of a transmission line associated with this project. Potential impacts to nesting raptors from 

construction activities could be minimized through related mitigation measures identified in Additional 

Mitigation. 

Migratory bird species that use the scrub-shrub habitat type for nesting in the project area include Brewer’s 

sparrow, sage sparrow, and sage thrasher (Nicholoff 2003). Grassland is frequented by such migratory birds 

as the horned lark, lark bunting, and vesper sparrow (Beidleman 2000). Common migratory birds within the 

woodland community (mainly pinyon-juniper) include the gray flycatcher, Bewick’s wren, chipping sparrow, and 

blue-gray gnatcatcher. Habitat fragmentation and “edge effects” are concerns for nesting migratory birds, 

resulting in overall changes in habitat quality, habitat loss, increased animal displacement, reductions in local 

wildlife and migratory bird numbers, and changes in species composition. However, the severity of these 

effects on migratory birds depend on factors such as sensitivity of the species, seasonal use, type and timing 

of project activities, and physical parameters (e.g., topography, cover, forage, and climate). 

Because the majority of the project would be co-located with an existing ROW, new edge habitat would 

replace existing edge habitat. In addition, most of the pipeline would cross relatively open habitat types 

(e.g., grassland, agriculture, and shrubland) rather than fragmenting dense woodland habitat. As such, effects 

to migratory birds and their habitats from habitat fragmentation resulting from the proposed project would be 

low. 

Overland Pass’s proposed construction schedule could overlap with the breeding season for many migratory 

bird species. Potential impacts to migratory birds resulting from construction would be the same as those 

discussed above for raptor species. 

EO 13186 requires federal agencies to avoid or minimize negative impact to migratory bird populations. The 

executive order also requires the federal agency to identify where unintentional “take” is likely to have a 

measurable negative effect on migratory bird populations. Effects to non-sensitive ground-nesting birds (which 

do not have significantly reduced populations) would not result in long-term or significant population-level 

effects, given the stability of local populations and the abundance of available habitat outside of the proposed 

ROW, and the linear nature of the project over a large geographic range. As a result, population-level impacts 

to migratory bird species would not be anticipated from the construction of the proposed project. 

Additional Mitigation 

WILD-1: The duration a trench is open shall be limited to 10 days from RP 0 to RP 110 on federal land 

administered by the BLM Kemmerer and Rock Springs field offices. In areas with large amount of 

rock where trenching may take longer and may include blasting, Overland Pass may request 

variances from this mitigation measure on a case-by-case basis. 

Conclusion 

Construction of the Overland Pass Pipeline would disturb wildlife habitat, displace individual animals, and 

contribute to habitat fragmentation by creating 138 miles of new greenfield ROW and expanding 622 miles of 

existing pipeline corridors. Impacts to wildlife would be mitigated by implementation of Overland Pass’ POD 

(Overland Pass 2007), including the Conservation Measure Plan; Construction, Reclamation, and 

Revegetation Plan (Appendix C); SPCC Plan, Traffic Management Plan; and Weed Management Plan 

(Appendix E). Measures to minimize impacts to wildlife include co-location of the pipeline with existing ROWs 

4.7-3 
where possible, use of a minimum construction ROW width and work space areas to reduce impacts to wildlife 

habitat, the use of trench plugs on federal lands every 0.5 mile intervals or at game trail crossings (and a 

corresponding gap in the welded pipe string), limiting the amount of time and distance of open trench, 

avoidance of construction activities in elk, mule deer, and pronghorn wintering areas during seasonal closure 

periods, adherence to spatial and timing buffers for active raptor nests, and reclamation of disturbed areas. 

Limiting open trench segments to 10 days will minimize the potential for wildlife and livestock to fall in the 

trench and become trapped or injured. Some areas of heavy rock concentrations will take longer to excavate 

and could involve the need for blasting in order to construct the trench. In these rocky areas, it is probable that 

the trench will need to remain open for longer than 10-day periods during construction. Extensions to the 

10-day open trench condition will be handled on a case-by-case basis through the variance process. 

Since the publication of the Draft EIS, Overland Pass has committed to supplemental mitigation measures 

intended to reduce impacts to wildlife. Benefits of these mitigations include: 

• Reducing injuries and fatalities to wildlife by providing escape ramps and inspecting the trench 

frequently; 

• Avoiding the take of active nests during actual construction; 

• Minimizing the effects of blasting on nesting birds; and 

• Reducing the compaction on the working side of the ROW. 

Application of the recommended additional mitigation measures would further reduce impacts. Mitigation 

WILD-1 would further reduce direct impacts to wildlife by reducing the possibility of injury or death as a result 

of pipeline construction activities by limiting the duration the trench is open. Reduction of the construction 

ROW width to 60 feet in riparian woodlands and wetlands in WATER-5 would reduce the area of disturbance 

to this valuable wildlife habitat type, particularly since the clearing of riparian woodlands would result in a 

long-term impact. 

Operation Phase 

Issues 

• Habitat reductions and fragmentation from ROW maintenance during operations. 

• Indirect effects consisting of displacement of individuals, and loss of breeding success from exposure 

to operational noise, and from higher levels of human activity. 

• Potential loss of individuals from exposures to spills. 

Analysis 

Direct impacts to wildlife species from maintenance activities associated with the Proposed Action would be 

the same as discussed above for construction. In order to reduce potential impacts to important wildlife 

resources as a result of maintenance activities on BLM-administered lands, Overland Pass would gain 

approval from the authorized BLM officer. The authorized BLM officer would coordinate with the appropriate 

BLM wildlife biologist(s) to determine if the activity would result in a direct impact to important wildlife 

resources. 

Potential indirect impacts on general wildlife (big game, nesting birds, small game, etc.) could result from 

increased noise levels from the operation of the three proposed pump stations. The distance wildlife is 

displaced is strongly influenced by the level and timing of the human activity, topography, and the presence of 

vegetation (Lyon 1979), presumably due to noise attenuation and visual cover. Overall, reductions in bird 

population densities in both open grasslands and woodlands are attributed to a reduction in habitat quality 

produced by elevated noise levels (Reijnen et al. 1995, 1997). Reijnen et al. (1996) determined a threshold 

4.7-4 
effect for bird species to be 47 dBA, while a New Mexico study in a pinyon-juniper community found that 

effects of gas well compressor noise on bird populations were strongest in areas where noise levels were 

greater than 50 dBA. However, moderate noise levels (40 to 50 dBA) also showed some effect on bird 

densities in this study (LaGory et al. 2001). 

An additional indirect long-term impact to wildlife species would result from increased levels of human-wildlife 

interaction within the proposed project area. By expanding the existing ROWs, and creating 1,237 acres 

(136 miles) of new greenfield ROW, the project could add to the existing matrix of open areas, jeep trails, and 

cleared ROWs currently attracting OHV users. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Impacts to wildlife from pipeline operations include the permanent habitat conversion of approximately 

6.2 acres of grassland and 2.3 acres of agricultural land to aboveground facilities use. Maintenance and 

operation of the pipeline would result in localized impacts to wildlife related to noise and an increase in 

human-wildlife interactions. Maintenance and operation of one transmission line would result in impacts to one 

golden eagle nest. These impacts would be of short duration and the majority would be dispersed along the 

entire proposed pipeline route. 

4.7.1.2 Aquatic Resources 

Construction Phase 

Issues 

• Direct loss of individuals or effects on habitat from short-term disturbance to stream channels from 

construction equipment and trench dewatering. 

• Direct loss of individuals or effects on habitat from short-term increases in sedimentation from 

open-cut pipeline crossings and erosion from adjacent disturbed lands. 

• Potential fuel spills from equipment and toxicity to aquatic biota if fuel reached a waterbody. 

• Local short-term reductions in habitat if surface water is affected by hydrostatic testing. 

• Potential loss of aquatic organisms during pumping for hydrostatic testing. 

• Potential loss of individuals from disease or invasive species if contaminated water or mud is 

transferred between watersheds. 

• Potential direct mortalities to amphibians from vehicle traffic. 

Analysis 

Crossings 

Since Overland Pass has committed to horizontal directional drilling at one river crossing (South Platte River), 

construction-related impacts on aquatic biota and their habitat in this river would be minor. The HDD crossing 

of the river would minimize impacts to game and nongame fish species and invertebrates by avoiding instream 

construction activities. It is possible that mud from the directional drill could inadvertently enter the active 

stream. However, if mud seepage was detected, the drilling operation would be stopped immediately to reduce 

pressure within the bore hole. Corrective measures would be implemented to eliminate or minimize seepage 

(Overland Pass 2007). If any seepage enters the stream, increased turbidity or physical disturbance to the 

bottom substrate would be localized and short-term in duration (less than 1 day). If the HDD crossing method 

4.7-5 
fails at the South Platte River and a decision is made to abandon this method, an open-cut crossing would be 

completed. Impacts for this method are discussed below. 

Open-cut trenching would be used at the other perennial streams, 33 of which contain 1 or more game fish 

species (Table 3.7-4). Details on construction procedures for stream crossings are provided in the 

Construction, Reclamation, and Revegetation Plan (Appendix C). Open-cut trenching could result in the 

following impacts to aquatic biota: 

• Loss or alteration of in-stream habitat through direct disturbances from equipment; 

• Loss of riparian vegetation along streambanks; 

• Disruption of fish movement; 

• Direct disturbance to spawning; and 

• Water quality effects involving sedimentation or possible fuel spills. 

Crossing techniques for PNG intermittent streams are described in surface water impacts (Section 4.5.2). 

In-stream Habitat 

Construction methods for crossing waterbodies would be based on the presence or absence of water, flow 

conditions, and stream width. If a waterbody has no perceptible flow at the time of crossing, upland 

construction techniques would be used. Wet-ditch construction techniques (i.e., open-cut) would be used for 

streams less than 30 feet wide. Construction would be completed within 24 to 48 hours. Dry-ditch methods 

may be used for streams with perceptible flow and widths greater than 30 feet. Site-specific construction plans 

have been developed and provide detailed crossing methods for the 10 major and sensitive waterbody 

crossings listed in Table 3.5-2 as well as 5 minor perennial waterbodies (Overland Pass 2007). 

Trenching and backfilling within the trenchline would result in physical alteration of channel morphology 

including streambanks and bottom substrates. The impact duration and extent of impact largely would depend 

on the composition of soil materials within the trench and stream channel. Disturbance to channels with firm 

substrates consisting of gravels, cobble, or clay material would exhibit short-term sedimentation as a result of 

trenching activities. These types of substrates are present in most of the streams proposed for trenching. 

These types of soils on the streambanks also would be less prone to erosion. By implementing erosion control 

techniques as part of the Construction, Reclamation, and Revegetation Plan, suspended sediment levels 

would be localized and expected to return to pre-construction levels within several days. In contrast, 

disturbance to channels with silt or soft materials would result in a long-term alteration of bottom substrates 

and channel morphology. Examples of these types of perennial streams include the Hams Fork River, one of 

the Blacks Fork River crossings (RP 18.9), and Bitter Creek. Past trenching activities and placement of gravels 

in backfill at the Blacks Fork River crossing has resulted in long-term effects such as scouring of stream 

bottom materials, sedimentation, and erosion from unstable streambanks. Channel modifications in the Blacks 

Fork River also has contributed to decreased depth to the point that it limits fish movement through the area. 

Within the FGNRA, the Green River also would be trenched, which would result in alteration of stream bottom 

habitat, increase in sedimentation and turbidity, and disturbance to streambank morphology and vegetation, as 

described in the water resource impacts (Section 4.5). The estimated disturbance to the channel bottom from 

trenching and placement of flume pipes across the width of the river would be approximately 10,200 square 

feet, based on a trench width of 34 feet and a channel width of 300 feet at the proposed crossing. The flume 

pipes would be used as a temporary bridge for equipment, as well as a means to maintain flow in the river. 

In-stream construction activities would require approximately two weeks. Impacts to aquatic habitat could 

continue beyond the construction period as a result of potential channel scouring or bank erosion. Additional 

impact information is provided in the Bank Cover, Water Quality Effects, Fish Movement, and Spawning 

sections. 

4.7-6 
Trenching also could result in possible mortalities to macroinvertebrates and small-size fish. Large-size fish 

are expected to move away from the construction area. Based on previous studies, macroinvertebrate 

communities typically recolonize disturbed areas in the spring and summer during the following year after 

disturbance (Waters 1995). 

Overland Pass has proposed to use bridge structures for construction equipment on all waterbodies that are 

flowing and widths greater than 30 feet. Bridge structures would avoid impacts to aquatic habitat. However, 

equipment use in streams less than 30 feet wide with water present would alter or disturb bottom substrates 

and channel structure. Additional mitigation would be provided by measure WATER-1, which would require 

bridges for all waterbodies (regardless of size and flow) and wetlands. This measure would eliminate the 

effects of vehicle crossings on aquatic habitat. 

Bank Cover 

Vegetative cover along streambanks of a waterbody provides cover for fish, shading, bank stability, erosion 

control, and increased food and nutrient supply due to the deposition of insects and vegetative matter into the 

watercourse. Loss of bank during construction at stream crossings may reduce cover and shading in a 

relatively small stream segment (up to 50-foot width per bank). Given the relatively small width of disturbance 

associated with a pipeline crossing, the above potential impacts would be considered minor relative to an 

entire stream system. All waterbody banks would be restored to preconstruction contours or to a stable angle 

of repose, as approved by the EI. 

The Construction, Reclamation, and Revegetation Plan (Appendix C) also indicates that TWAs would be 

located at least 50 feet from the water’s edge of perennial and intermittent waterbodies on federally managed 

land and at least 10 feet away on non-federally managed land. Additional mitigation would be provided by 

measure VEG-1, which would require that the setback distance from TWAs would be 50 feet from riparian 

areas adjacent to waterbodies. This would reduce effects on riparian vegetation. 

Direct Disturbance to Spawning 

Construction at stream crossings may occur in the fall or winter months. In-stream construction activities could 

displace spawning fish from preferred habitat and result in the utilization of lower quality spawning habitat. As 

shown in Table 3.7-5, spawning periods for coldwater fish species are March through May or September 

through November. Warmwater fish species generally spawn from May through July or August. Based on 

recommendations from WGFD and CDOW, the Construction, Reclamation, and Revegetation Plan would 

implement the following construction windows to minimize impacts on spawning fish. The construction period 

for warmwater fisheries would avoid peak spawning periods for game fish species. The proposed construction 

window for coldwater fisheries would avoid spawning periods for trout species in all streams except the Green 

River in Wyoming and Chief Creek and North Fork Republican River in Colorado. Potential impacts on trout 

spawning in these streams are discussed below. The additional mitigation measure, WILD-2, would be 

implemented to minimize construction effects on kokanee salmon and brown trout in the Green River. 

As part of project-committed mitigation, Overland Pass would construct during the following timeframes to 

minimize effects on game fish spawning: 

• Coldwater fisheries (except Green River) – May 16 through September 30 and November 15 to 

March 30; 

• Warmwater fisheries – October 1 through June 1; 

• Hams Fork and Blacks Fork Rivers and Bitter Creek – October 1 through June 1; and 

• South Platte River – August 1 through November 30. 

The effects of trenching on game fish species in the Green River would depend on the timing of construction. If 

construction occurred in late August through late October, construction activity could potentially affect 

4.7-7 
spawning movements for kokanee salmon and brown trout. Although flumes would be used at the crossing to 

maintain river flow, physical activity in the trench area at the upstream end of the flumes could affect fish 

movement. The first run of kokanee salmon occurs from late August through late September. A second run 

occurs from late September into November, although most of the run is completed by early November. The 

additional mitigation measure, WILD-2, would be implemented to avoid the first kokanee run and most of the 

second run by avoiding the period from August 20 through October 15. Mitigation measure WILD-3 also would 

be required, which would involve notifying WGFD of construction at streams with sensitive fisheries at least 

72 hours prior to initiation. Alteration of bottom substrates also could affect eggs deposited by kokanee salmon 

and brown trout. Eggs could be crushed by flume pipes or trenching or indirectly affected by sedimentation in 

areas located downstream of the crossing. 

If construction occurred in October or November in Chief Creek or the North Fork of the Republican River, fall 

spawning brown trout could be affected. Impacts could include disturbance to spawning substrates or eggs 

and early life stages, alteration of spawning habitat quality due to sedimentation, interruption to spawning 

movements, and displacement of spawning adults from preferred spawning areas. If construction occurred 

after mid-November, impacts would be limited to streams that may have eggs or early life stages within the 

construction disturbance area. The CDOW indicated that brown trout is an introduced species in these 

streams. For this reason, a construction timeframe of July 1 through April 15 is proposed for these streams to 

protect two special concern fish species (orangethroat darter and stonecat) (see Section 4.7.1.3, Aquatic 

Species). 

Water Quality Effects 

In-stream construction activities would result in short-term increases in total suspended solids (TSS) levels and 

turbidity in a section of the stream within and immediately downstream of the crossing. The estimated 

disturbance area would range from approximately 270 to 4,250 square feet, depending on the width and soil 

type at the crossing. Other surface disturbance activities associated with TWAs and road improvements near 

streams also could contribute short-term sedimentation. The setback distance for TWAs would be 50 feet from 

the water’s edge of perennial and intermittent streams on federally managed land and 10 feet from the water’s 

edge on private land. This buffer is applicable to streams with flow at the time of construction. Additional 

mitigation measure VEG-1 would require that the setback distance from TWAs would be 50 feet from riparian 

areas adjacent to waterbodies, which would help reduce sediment input to streams. The extent of downstream 

movement of suspended sediment would depend on flow and channel configuration. Sedimentation and 

increased turbidity conditions could continue in the Green River for at least 4 weeks (2-week construction plus 

2 or more weeks after construction is completed), as a result of the extensive area disturbed within the channel 

and the use of the TWA adjacent to the river. By constructing during the low flow period, movement of 

suspended sediment would be limited in downstream extent. Localized increases in sediment could affect fish 

by clogging gills or damaging gill membranes, reducing vision, contributing to susceptibility to disease from 

added stress, or burying eggs or larvae. Macroinvertebrates could be affected by direct mortalities from 

equipment or physiological effects from sediment covering the organisms. 

Vehicle and equipment use within and adjacent to waterbodies also could pose a risk to aquatic biota from fuel 

or lubricant spills. If fuel reached a waterbody, aquatic species could be exposed to toxic conditions, 

depending on factors such as volume spilled, stream velocity, and channel morphology. Impacts could include 

direct mortalities or reduced health of aquatic organisms. 

Interruption of Fish Movement 

Most water crossing methods allow movement of fish across the ROW. However, some techniques, such as 

dry-ditch crossing techniques, may block or delay normal movements. Trenching techniques in larger streams 

such as the Laramie River would maintain flow through the construction area using flumes. Long-term 

interruption of fish movement in a waterbody or a relatively short-term delay in spawning migration could result 

in adverse impacts. By adhering to the construction periods discussed above, impacts on spawning migrations 

would not be expected in most perennial streams. Exceptions would include the Hams Fork, Blacks Fork, and 

Green rivers, where fish movements could be affected by construction activities. As discussed in the in-stream 

4.7-8 
habitat section, trenching could result in a barrier to fish movement in the Hams Fork and Blacks Fork rivers 

during low flow periods due to scouring. Mitigation measure WILD-2 would be used at the Green River to 

minimize impacts to spawning migrations of kokanee salmon and brown trout. 

Transfer of Disease and Nuisance Organisms 

Overland Pass’ POD indicates that construction equipment would be washed at the state lines. In-stream 

construction activities could transport whirling disease and parasites or invasive organisms such as zebra 

mussels between drainages within each state. Whirling disease is present in a number of the streams that 

would be crossed (i.e., Green, North Platte, Medicine Bow, Laramie rivers in Wyoming and all perennial 

streams in Colorado except Chief Creek) (Walker 2006; Money 2006). Whirling disease and parasite 

infestations on fish could affect their overall health. Fish numbers could be reduced as a result of mortalities or 

effects on reproduction. Mitigation measure WATER-2 would be implemented, which would involve power 

washing of equipment at all perennial stream crossings to avoid transfer of whirling disease, parasites, or 

nuisance organisms. 

Construction Water Use 

Hydrostatic testing, dust control, and HDD crossings would result in temporary reductions in surface water and 

groundwater quantity. The Hydrostatic Test Plan (Appendix D) lists five streams and numerous wells as water 

sources for hydrostatic testing, dust control, and HDD crossings. The withdrawal location and volumes are 

provided in Table 4.5-2. The water would be withdrawn during the period January through March 2008. As 

discussed in Section 4.5, hydrostatic testing withdrawals would result in relatively small reductions in the 

Green River (10.7 acre-feet), North Platte River (20.9 acre-feet), and South Platte River (North Sterling Ditch) 

(18.1 acre-feet). 

Water withdrawals in the Blacks Fork and Laramie rivers could result in flow reductions of greater than 

25 percent when comparing the withdrawal volume to the base flow conditions. The magnitude of the percent 

reduction would depend upon stream flows at the time of withdrawal. The duration of the flow reduction would 

continue until a precipitation event increased base flows. As a result of the flow reductions from hydrostatic 

testing in the Blacks Fork and Laramie rivers, there could be substantial temporary decreases in the amount of 

habitat for aquatic biota. Additional discussions of effects of water withdrawals for construction use on fish 

habitat are provided in Section 4.5.1. 

Dust control water would be obtained from groundwater sources (municipal wells) located in the following 

basins: 28.4 acre-feet from the Green River Basin, 14.2 acre-feet from the South Platte Basin, and 14.2 acrefeet from the North Platte Basin. In addition, HDD would use 12.1 acre-feet from the South Platte River (North 

Sterling Ditch). Collectively, hydrostatic testing, HDD, and dust control would result in a temporary withdrawal 

of 47.2 acre-feet in the South Platte Basin and 42.7 acre-feet in the North Platte Basin. There would be 

conflicts regarding minimum flow requirements for the five streams, since minimum flows have not been 

established for fisheries in segments at or downstream of the proposed crossings. 

Although the WGFD and CDOW do not have standards for pump mesh sizes, appropriate size mesh sizes 

would be used on pumps to minimize entrainment of fish species or nuisance organisms that may be present. 

The Hydrostatic Test Plan (Appendix D) proposes using a 0.25-inch mesh on intake hoses. As part of the 

applicant-committed mitigation, the discharge of hydrostatic test water would follow state permit requirements, 

which would minimize potential effects on aquatic biota. As part of applicant-committed mitigation, water would 

be tested for potential pollutants and then discharged to stable upland areas along the construction ROW if the 

source was surface water. Water would be returned to each source after meeting water quality standards, or 

discharged to an upland site located at least 50 to 100 feet from the edge of a waterbody to avoid erosion or 

introducing nuisance organisms into streams. Specific discharge locations are provided in the Hydrostatic Test 

Plan. Energy dissipaters also would be used at the discharge points to prevent erosion. 

4.7-9 
Amphibians 

Construction activity within the Proposed Action ROW would cross potential habitat for amphibian species in 

all three states. Potential habitat would consist of flooded areas, wetlands, streams, ponds, and lakes. Most of 

the frog and turtle species use these habitats throughout the year. Some of the toad species migrate from 

upland terrestrial areas to use aquatic habitats for breeding in the spring or summer. Vehicle traffic within the 

ROW and waterbody crossing could potentially affect breeding for these species. Construction activities within 

waterbodies could alter habitat used for eggs and rearing of young, as well as possibly causing direct 

mortalities. Vehicle activity also could cause increased sediment in the disturbance area. Toads also could be 

affected during movements between upland areas and water sources used for breeding (spring and summer). 

Vehicle traffic could crush individual toads during movements to and from waterbodies. 

The implementation of mitigation (VEG-1) involving a 50-foot setback for TWAs on federally managed lands, 

as measured from the edge of riparian vegetation to perennial and intermittent streams, would eliminate direct 

disturbance to some of the potential breeding sites for this species. 

Operational effects of maintenance activities are not expected to impact amphibians unless vehicles 

inadvertently crushed individual during movements to and from breeding sites or affected shallow burrow 

areas. 

Additional Mitigation 

WILD-2: To avoid impacts to kokanee salmon and brown trout movements and effects on habitat from ice in 

the winter and high flows in the spring, construction across the Green River shall occur between 

July 1 and August 15 or between October 15 and November 20. 

WILD-3: Overland Pass will notify WGFD at least 72 hours prior to initiating construction at streams with 

sensitive fisheries (Table 3.5-2). 

Conclusion 

Aquatic resource impacts anticipated from pipeline construction at most stream crossings include a temporary 

increase in sedimentation to waterbodies crossed by the open-cut method; short-term disturbance to stream 

channels, aquatic habitat, bank cover, and spawning sites; potential short-term reductions in habitat from water 

withdrawals for hydrostatic testing and dust control; potential loss of aquatic organisms during pumping for 

hydrostatic testing, potential loss of individuals from invasive species or disease if contaminated water is 

transferred between watersheds, and potential fuel spills from construction equipment and toxicity to aquatic 

organisms if the fuel spill reached a waterbody. These impacts would be mitigated by the implementation of 

the Construction, Reclamation, and Revegetation Plan, various site-specific waterbody crossing plans 

(designated for environmentally sensitive waterbody crossings), and other aspects of the POD. Measures to 

minimize aquatic resource impacts include erosion control and streambank stabilization measures, reducing 

the amount of time conducting instream construction activities, and workspace and refueling setbacks from 

waterbodies. Overland Pass would avoid bank and channel disturbance to the South Platte River by using the 

HDD crossing method. The remaining streams and rivers would be open-cut in accordance with Overland 

Pass’ POD (Overland Pass 2007). Overland Pass would avoid construction of crossings during state agency 

coldwater and warmwater fisheries spawning periods. Open-cut crossings would cause short-term (usually 

3 days or less) suspended sediment increases in stream and river channels. Long-term impacts to habitat and 

fish populations in the Hams Fork and Blacks Fork rivers could occur as a result of scouring and channel 

disturbance. In addition, trenching at the Green River crossing would adversely affect spawning movements 

and eggs deposited by kokanee salmon and brown trout. Mitigation measure WILD-2 would be implemented 

to minimize effects of trenching at the Green River crossing on the late-run of kokanee salmon. 

Since the publication of the Draft EIS, Overland Pass has committed to supplemental mitigation measures 

intended to reduce impacts to fisheries. Benefits of these mitigations include avoiding the alteration of 

4.7-10 
streambed substrate (i.e., roughness) that can affect sedimentation and erosion regimes, degrade the 

channel, and create fish barriers. 

Application of the additional mitigation measures would further reduce impacts to aquatic resources. WATER-1 

and VEG-1 would further reduce the amount of sediment input into waterbodies during construction. WATER-2 

would reduce the risk of the inadvertent introduction of nuisance organisms, whirling disease, or parasites from 

one waterbody into another. WATER-3 would reduce impacts on aquatic resources during water withdrawals 

associated with dust control and hydrostatic testing. 

Operation Phase 

Issues 

• Potential localized sedimentation and disturbance to habitat if maintenance activities were required at 

a stream crossing. 

Analysis 

Routine maintenance of the pipeline ROW would consist of removing woody vegetation from over the top of 

the pipeline periodically to prevent roots from interfering with the pipeline. Vegetation removal adjacent to 

waterbodies would be limited to at least a 25-foot-wide riparian strip, as measured from the waterbody’s mean 

high water mark. As a result, maintenance activities would not affect aquatic biota or their habitat. 

Operational effects of a possible pipeline rupture at a stream crossing are limited to localized stream bottom 

disturbance. Since released product would be in a gaseous state and quickly volatilize, it would not be toxic to 

aquatic biota. Additional information on the fate of the NGLs and potential toxicity is provided in Appendix L. If 

a rupture occurred at a stream crossing, stream substrates could be dissipated from the rupture point. 

Macroinvertebrate mortalities could occur at the rupture point. Fish are expected to move away from the 

rupture area. Potential impacts would be short-term and low magnitude due to the localized extent of the 

affected area. 

Additional Mitigation 

No additional mitigation for project operation is required to further reduce impacts on aquatic biota and their 

habitat. 

Conclusion 

Routine operation and maintenance activities would have minor effects on aquatic resources. Minimal impacts, 

if any, would be expected to aquatic biota if NGLs were accidentally released into waterbodies. 

4.7.1.3 Special Status Species 

Construction Phase 

Issues 

• The construction issues for wildlife special status species are the same as listed for wildlife resources 

(Section 4.7.1). 

• The construction issues for special status fish species are the same as listed for aquatic resources. 

4.7-11 
• Hydrostatic testing is an issue for federally listed species that occur in downstream portions of the 

Colorado River and Platte River basins. The USFWS requires consultation for any water withdrawals 

in these basins that could affect surface water quantity. 

• The construction issues for special status plant species are the same as listed for vegetation 

resources (Section 4.6.1). 

Analysis 

The impact analysis for special status species focused on those species that were identified as potentially 

occurring within the project area. A total of 77 terrestrial species and 15 aquatic species have been identified 

as potentially occurring within the project area (Table 4.7-2 and Appendix I). As required under Section 7 of 

the ESA, a draft BA was prepared for the project to determine whether the proposed action is likely to affect 

any federally listed species. Sixteen federally threatened and endangered species and two candidate species 

were analyzed in the BA. BLM- and USFS-sensitive species also were analyzed in the BR/BE. Impacts to 

special status species are summarized in Tables 4.7-2, 4.7-3, and in the BA, and in the BR/BE. 

Table 4.7-2 Impacts for Special Status Species

Common Name Scientific Name Status1

 Impact Potential

2 

 Wyoming Colorado Kansas 

Federally Listed Species 

Mammals 

Black-footed ferret Mustela nigripes FE; CO-E; WY-NSS1; 

KS-E; USFS-R4S 

MA MA NE 

Preble's meadow jumping 

mouse 

Zapus hudsonius preblei FT; CO-T MA MA NE 

Birds 

Yellow-billed cuckoo Coccyzus americanus FC; BLM-WY; WY-NSS2; 

USFS-R4S 

MA NE NE 

Whooping crane Grus americanus FE; CO-E; KS-E MA MA NE 

Interior least tern Sterna antillarum athalassos FE; CO-E; KS-E MA MA NE 

Piping plover Charadrius melodus 

circumcinctus 

FT; CO-T; KS-T MA MA NE 

Lesser Prairie Chicken Tynpanuchus pallidicinctus FC NE NE NE 

Amphibians 

Wyoming toad Bufo baxteri FE, WY-NSS1 MA NE NE 

Fish 

Bonytail Gilia elegans FE; CO E; USFS-R4S MA NE NE 

Colorado pikeminnow Plychocheilus lucius FE; CO-E MA NE NE 

Humpback chub Gilia cyphus FE; CO E; USFS-R4S MA NE NE 

Razorback sucker Xyrauchen texanus FE; CO-E; USFS-R4S MA NE NE 

Pallid sturgeon Scaphirhynchus albus FE; KS-E MA MA NE 

Plants 

Colorado butterfly plant Gaura neomexicana spp. 

Coloradensis 

FT MA MA NE 

Blowout penstemon Penstemon haydenii FE MA NE NE 

Ute ladies' tresses Sprianthes diluvialis FT ; USFS-R4S MA MA NE 

Western prairie fringed 

orchid 

Platanthera praeclara FT MA MA NE 

BLM Sensitive Species 

Mammals 

Fringed myotis Myotis thysanodes BLM-WY; 

WY-NSS2; USFS-R2S 

MI MI NI 

Long-eared myotis Myotis evotis BLM-WY; WY-NSS2 MI MI NI 

Spotted bat Euderma maculatum BLM-WY; WY-NSS2; 

USFS-R4S 

MI MI NI 

Townsend's big-eared bat Plecotus townsendii BLM-WY; USFS-R4S 

WY-NSS2; CO-SOC; 

KS-SINC 

MI MI MI 

Pygmy rabbit Brachylagus idahoensis BLM-WY; USFS-R4S MI NI NI 

Swift fox Vulpes velox CO-SOC; USFS-R2S; 

BLM-WY 

MI MI MI 

4.7-12 
Table 4.7-2 Impacts for Special Status Species

Common Name Scientific Name Status1

 Impact Potential

2 

 Wyoming Colorado Kansas 

White-tailed prairie dog Cynomys leucurus BLM-WY MI MI NI 

Black-tailed prairie dog Cynomys ludovicianus BLM-WY; USFS-R2S; 

CO-SOC 

NI MI MI 

Idaho pocket gopher Thomomys idahoensis BLM-WY MI NI NI 

Wyoming pocket gopher Thomomys clusius BLM-WY MI NI NI 

Birds 

Bald eagle Haliaeetus leucocephalus CO-T; WY-NSS2; KS-T; 

BLM-WY; USFS-R4S 

MA MA MA 

Burrowing owl Athene cunicularia USFS-R2S; BLM-WY; 

CO-T 

MI MI MI 

Brewer's sparrow Spizella breweri BLM-WY; USFS-R2S MI MI NI 

Ferruginous hawk Buteo regalis CO-SOC; BLM-WY; 

USFS-R2S; KS-SINC 

MI MI MI 

Loggerhead shrike Lanius ludovicianus BLM-WY; USFS-R2S MI MI MI 

Mountain plover Charadrius montanus BLM-WY; CO-SOC; 

USFS-R2; KS-SINC; 

USFS-R4S 

MI MI MI 

Long-billed curlew Numenius americanus CO-SOC; BLM-WY; 

USFS-R2S; KS-SINC 

MI MI MI 

Northern goshawk Accipiter gentiles BLM-WY; USFS-R4S MI NI NI 

Golden eagle Aquila chrysaetos BLM-WY; 

KS-SINC 

MI MI MI 

Peregrine falcon Falco peregrinus KS-E; BLM-WY; USFSR4S MI NI MI 

Sage sparrow Amphispiza belli BLM-WY MI NI NI 

Sage thrasher Oreoscoptes montanus BLM-WY MI MI NI 

Trumpeter swan Cygnus buccinators BLM-WY; WY-NSS2; 

USFS-R4S 

MI NI NI 

White-faced ibis Plegadis chihi BLM-WY MI MI MI 

Greater sage-grouse Centrocercus urophasianus CO-SOC; BLM-WY; WYNSS2; USFS-R4S MI NI NI 

Reptiles 

Midget faded rattlesnake Crotalus viridis concolor BLM-WY; CO-SOC MI NI NI 

Amphibians 

Western boreal toad Bufo borealis boreas CO-E; BLM-WY; 

WY-NSS2 

MI MI NI 

Great Basin spadefoot toad Spea intermontana BLM-WY MI NI NI 

Spotted frog Ranus pretiosa BLM-WY; USFS-R4S MI NI NI 

Northern leopard frog Rana pipiens BLM-WY; USFS-R2S; 

CO-SOC 

MI MI NI 

Fish 

Bluehead sucker Catostomus discobolus BLM-WY; WYGF-NSS1 MI NI NI 

Flannelmouth sucker Catostomus latipinnis BLM-WY; WYGF-NSS1 MI NI NI 

Leatherside chub Gila copei BLM –WY; WYGF-NSS1 MI NI NI 

Roundtail chub Gila robusta BLM-WY; WY-NSS1; MI NI NI 

Plants 

Laramie columbine Aquilegia laramiensis BLM -WY MI NI NI 

Nelson's milkvetch Astragalus nelsonianus BLM-WY MI MI NI 

Trelease's 

racemose milkvetch 

Astragalus racemosus var. 

treleasei 

BLM-WY MI NI NI 

Cedar Rim thistle Cirsium aridum BLM-WY MI NI NI 

Ownbey's thistle Cirsium ownbeyi BLM-WY MI NI NI 

Large-fruited bladderpod Lesquerella macrocarpa BLM-WY MI NI NI 

Prostrate bladderpod Lesquerella prostrata BLM-WY MI NI NI 

Gibbens' beardtongue Penstemon haydenii BLM-WY MI NI NI 

Tufted twinpod Physaria condensata BLM-WY MI NI NI 

Persistent 

sepal yellowcress 

Rorippa calycina BLM -WY MI NI NI 

Laramie false sagebrush Sphaeromeria simplex BLM -WY MI NI NI 

Green River greenthread Thelesperma caespitosum USFS- R4S; BLM -WY MI NI NI 

USFS Sensitive Species 

Birds 

Cassin's sparrow Aimophilia cassini USFS-R2S MI MI MI 

McCown’s longspur Calcarius mccownii USFS-R2S MI MI NI 

4.7-13 
Table 4.7-2 Impacts for Special Status Species

Common Name Scientific Name Status1

 Impact Potential

2 

 Wyoming Colorado Kansas 

Chestnut-collard longspur Calcarius ornatus USFS-R2S MI MI NI 

Northern harrier Cirus cyaneus USFS-R2S MI MI MI 

Grasshopper sparrow Ammodramus savannarum USFS-R2S MI MI NI 

Black tern Childonias niger USFS-R2S; KS-SINC MI MI MI 

Plants 

Dwarf milkweed Asclepias uncialis USFS-R2S NI MI NI 

Prairie moonwort Botrychium campestre USFS-R2S NI MI NI 

Wyoming feverfew Parthenium alpinum Former USFS-R2S NI MI NI 

State Status Species 

Mammals 

Northern pocket gopher Thomomys talpoides CO-SOC MI MI NI 

Franklin’s ground squirrel Spermophilus franklinii KS-SINC NI NI MI 

Long-legged myotis Myotis volans WY-NSS2 MI MI NI 

Pallid bat Antrozous pallidus WY-NSS2; KS-SINC MI MI NI 

Eastern spotted skunk Spilogale putorius KS-T NI NI MI 

Birds 

Snowy plover Charadrius alexandrinus KS-T; CO-SOC MI MI MI 

Black rail Laterallus jamaicensis KS-SINC NI NI MI 

Short-eared owl Asio flammeus KS-SINC MI MI MI 

Bobolink Dolichonyx oryzivorus KS-SINC MI MI MI 

Reptiles 

Glossy snake Arizona elegans KS-SINC NI MI MI 

Western hognose snake Heterodon nasicus KS-SINC MI MI MI 

Common garter snake Thamnophis sirtalis CO-SOC MI MI MI 

Eastern hognose snake Heterodon platirhinos KS-SINC MI MI MI 

Yellow mud turtle Kinosternon flavescens CO-SOC NI MI MI 

Amphibians 

Northern cricket frog Aeris crepitans CO-SOC NI MI MI 

Plains leopard frog Rana blairi CO-SOC NI MI MI 

Fish 

Plains minnow Hybognathus placitus CO-E; KS-SINC NI MI NI 

Brassy minnow Hybognathus hankinsoni CO-T; KS-SINC NI MI NI 

Orangethroat darter Etheostoma spectable CO SOC NI MI NI 

Stonecat Noturus flavus CO SOC NI MI NI 

Suckermouth minnow Phenacobius mirabilis CO-E NI MI NI 

Invertebrates 

Cylindrical papershell Anodontoides ferussacianus KS-SINC NI NI MI 1

 Status Definitions: 

FC = Federally Candidate 

FE = Federally Endangered

FT = Federally Threatened 

WY-NSS1= Wyoming Critically Imperiled Species 

WY-NSS2= Wyoming Imperiled Species 

CO-E = Colorado Endangered 

CO-T = Colorado Threatened

KS-E = Kansas Endangered

KS-T = Kansas Threatened 

KS-SINC= Kansas Species in Need of Conservation 

BLM-WY = Wyoming BLM sensitive 

USFS-R2S = USFS Region 2 sensitive species 

USFS-R4S = USFS Region 4 sensitive species (considered with BLM sensitive species) 

PNG= Pawnee National Grassland 2

 Impact Definitions: 

MA= indicates that this federally listed species may be affected by the proposed action. 

NE= indicates that no effect to this federally listed species would result from the proposed action.

MI= BLM Sensitive Species, USFS Listed Species, or State Status Species may be impacted by the proposed action. 

NI= No impact to this BLM Sensitive Species, USFS Sensitive Species, or State Status Species would result from the proposed

action. 

As part of Overland Pass’ POD, applicant-committed protection measures have been developed for the project 

in a Conservation Measures Plan to prevent or minimize direct impacts on special status species (Overland 

Pass 2007). The Overland Pass Conservation Measure Plan includes measures that would be implemented if 

4.7-14 
federally listed species, species of concern, a USFS-sensitive species, or a BLM-sensitive species were 

identified along the proposed pipeline route during project-specific surveys. In coordination with the BLM and 

USFS, the Conservation Measure Plan includes protection measures that would prevent or minimize potential 

impacts to federally listed species, such that the proposed project would not be likely to adversely affect these 

species. For special status species, the Conservation Measure Plan includes measures that would prevent or 

minimize impacts, such that the proposed project would not be likely to result in a loss of viability, nor cause a 

trend toward federal listing or a loss of species viability range wide. 

Wildlife Species 

Direct impacts would include the incremental long-term loss or alteration of potential breeding and/or foraging 

habitats, and increased incremental habitat fragmentation until native vegetation has become reestablished. 

Acres of special status wildlife species habitat that would be directly impacted by construction activities are 

included in Table 4.7-3. Potential impacts also could result in mortalities of less mobile or burrowing species 

as a result of crushing by vehicles and equipment, and the potential abandonment of a nest site or territory and 

the loss of eggs or young. Other impacts would include short-term displacement of some of the more mobile 

species from the disturbance areas as a result of increased noise and human presence. However, based on 

Overland Pass’ committed environmental protection measures as defined in their POD and Conservation 

Measure Plan, in combination with additional mitigation measures identified below for special status wildlife 

species, potential impacts to special status wildlife resources would be low. 

Table 4.7-3 Acres of Suitable Habitat Directly Impacted by Construction Activities for Special 

Status Wildlife Species 

Common 

Name 

Scientific 

Name Status1 

Acres of Suitable Habitat Directly Impacted by Construction Activities 

Wyoming Colorado Kansas 

Federally Listed Species 

Mammals 

Black-footed 

ferret 

Mustela 

nigripes 

FE; CO-E; 

WY-NSS1; 

KS-E 

Reproduction/Foraging: 

 399 

Reproduction/Foraging: 

17 

No Impact 

Preble's 

meadow 

jumping 

mouse 

Zapus 

hudsonius 

preblei 

FT; CO-T Reproduction/Foraging: 

3 

Reproduction/Foraging: 

<1 

No Impact 

Birds 

Yellow-billed 

cuckoo 

Coccyzus 

americanus 

FC; BLMWY; WYNSS2 

Nesting: No Impact 

Foraging: 5 

No Impact No Impact 

Whooping 

crane 

Grus 

americanus 

FE; CO-E; 

KS-E 

Downstream Impacts2 Downstream Impacts2 No Impact 

Interior least 

tern 

Sterna 

antillarum 

athalassos 

FE; KS-E; 

CO-E 

Downstream Impacts2 Downstream Impacts2 No Impact 

Piping plover Charadrius 

melodus 

circumcinctus 

FT; CO-T; 

KS-T 

Downstream Impacts2 Downstream Impacts2 No Impact 

Lesser 

Prairie 

Chicken 

Tynpanuchus 

pallidicinctus 

FC No Impact No Impact No Impact 

4.7-15 
Table 4.7-3 Acres of Suitable Habitat Directly Impacted by Construction Activities for Special 

Status Wildlife Species 

Common 

Name 

Scientific 

Name Status1 

Acres of Suitable Habitat Directly Impacted by Construction Activities 

Wyoming Colorado Kansas 

BLM Sensitive Species 

Mammals 

Fringed 

myotis 

Myotis 

thysanodes 

BLM-WY; 

WY-NSS2; 

USFS-R2S 

Roosting: No Impact 

Foraging: 2,974 

Roosting: No Impact 

Foraging: 1,563 

No Impact 

Long-eared 

myotis 

Myotis evotis BLM-WY; 

WY-NSS2 

Roosting: No Impact 

Foraging: 2,974 

Roosting: No Impact 

Foraging: 1,563 

No Impact 

Spotted bat Euderma 

maculatum 

BLM-WY; 

WY-NSS2 

Roosting: No Impact 

Foraging: 2,974 

Roosting: No Impact 

Foraging: 1,563 

No Impact 

Townsend's 

big-eared 

bat 

Plecotus 

townsendii 

BLM-WY; 

WY-NSS2; 

CO-SOC; 

KS-SINC 

Roosting: No Impact 

Foraging: 2,974 

Roosting: No Impact 

Foraging: 1,563 

Roosting: No Impact 

Foraging: 2,372 

Pygmy 

rabbit 

Brachylagus 

idahoensis 

BLM-WY Reproduction/Foraging: 

392 known occupany3 

1758 suitable habitat 

No Impact No Impact 

Swift fox Vulpes velox CO-SOC; 

USFS-R2S; 

BLM-WY 

Reproduction/Foraging: 

667 

Reproduction/Foraging: 

1,316 

Reproduction/Foraging: 

2,336 

White-tailed 

prairie dog 

Cynomys 

leucurus 

BLM-WY Reproduction/Foraging: 

399 known occupancy

3 

1758 suitable habitat 

Reproduction/Foraging: 

No Impact 

No Impact 

Black-tailed 

prairie dog 

Cynomys 

ludovicianus 

BLM-WY; 

USFS-R2S; 

CO-SOC 

Reproduction/Foraging: 

No known occupancy3 

667 suitable habitat 

Reproduction/Foraging: 

17 known occupancy3 

1,316 suitable habitat 

Reproduction/Foraging: 

No known occupancy3 

2,336 suitable habitat 

Idaho pocket 

gopher 

Thomomys 

idahoensis 

BLM-WY Reproduction/Foraging: 

565 

No Impact No Impact 

Wyoming 

pocket 

gopher 

Thomomys 

clusius 

BLM-WY Reproduction/Foraging: 

1,109 

No Impact No Impact 

Birds 

Bald eagle Haliaeetus 

leucocephalus 

CO-T; WYNSS2; KST; BLM-WY; 

USFS-R4S 

Nesting: No Impact 

Foraging: 3 

Nesting: No Impact 

Foraging: 4 

Nesting: No Impact 

Foraging:<1 

Burrowing 

owl 

Athene 

cunicularia 

USFS-R2S; 

BLM-WY; 

CO-T 

Nesting/Foraging: 

399 known occupancy

3 

667 suitable habitat 

Nesting/Foraging: 

17 known occupacy3 

1,316 suitable habitat 

Nesting/Foraging: 

No known occupancy3 

2,336 suitable habitat 

Mountain 

plover 

Charadrius 

montanus 

BLM-WY; 

CO-SOC; 

USFS-R2; 

KS-SINC 

Nesting/Foraging: 

28 known occupancy4 

598 suitable habitat 

Nesting/Foraging: 

No known occupancy4 

1,864 suitable habitat 

Nesting/Foraging: 

No known occupancy5 

2,336 suitable habitat

5 

Brewer's 

sparrow 

Spizella 

breweri 

BLM-WY; 

USFS-R2S 

Nesting/Foraging: 1,758 No Impact No Impact 

Ferruginous 

hawk 

Buteo regalis CO-SOC; 

BLM-WY; 

USFS-R2S; 

KS-SINC 

Nesting: No Impact 

Foraging: 2,914 

Nesting: No Impact 

Foraging:1,568 

Nesting: No Impact 

Foraging: 2,372 

4.7-16 
Table 4.7-3 Acres of Suitable Habitat Directly Impacted by Construction Activities for Special 

Status Wildlife Species 

Common 

Name 

Scientific 

Name Status1 

Acres of Suitable Habitat Directly Impacted by Construction Activities 

Wyoming Colorado Kansas 

Loggerhead 

shrike 

Lanius 

ludovicianus 

BLM-WY; 

USFS-R2S 

Nesting/Foraging: 2,140 Nesting/Foraging: 228 Nesting/Foraging: 15 

Long-billed 

curlew 

Numenius 

americanus 

CO-SOC; 

BLM-WY; 

USFS-R2S; 

KS-SINC 

Nesting/Foraging: 696 Nesting/Foraging: 913 Nesting/Foraging: 669 

Northern 

goshawk 

Accipiter 

gentiles 

BLM-WY Nesting: No Impact 

Foraging: 5 

No Impact No Impact 

Golden 

eagle 

Aquila 

chrysaetos 

BLM-WY; 

KS-SINC 

Nesting: No Impact 

Foraging: 2,914 

Nesting: No Impact 

Foraging:1,568 

Nesting: No Impact 

Foraging: 2,372 

Peregrine 

falcon 

Falco 

peregrinus 

KS-E; BLMWY Nesting: No Impact 

Foraging: 24 

No Impact No Impact 

Sage 

sparrow 

Amphispiza 

belli 

BLM-WY Nesting/Foraging: 1,758 No Impact No Impact 

Sage 

thrasher 

Oreoscoptes 

montanus 

BLM-WY Nesting/Foraging: 1,758 Nesting/Foraging: 228 No Impact 

Trumpeter 

swan 

Cygnus 

buccinators 

BLM-WY; 

WY-NSS2 

Nesting/Foraging: 4 No Impact No Impact 

White-faced 

ibis 

Plegadis chihi BLM-WY Nesting/Foraging: 6 Nesting/Foraging: 4 Nesting/Foraging: <1 

Greater 

sage-grouse 

Centrocercus 

urophasianus 

CO-SOC; 

BLM-WY; 

WY-NSS2 

Nesting/Foraging: 1,758 No Impact No Impact 

Reptiles 

Midget faded 

rattlesnake 

Crotalus viridis 

concolor 

BLM-WY; 

CO-SOC 

Reproduction/Foraging: 

91 

No Impact No Impact 

USFS Sensitive Species 

Birds 

Cassin's 

sparrow 

Aimophilia 

cassini 

USFS-R2S Nesting/Foraging: 639 Nesting/Foraging: 907 Nesting/Foraging: 667 

McCown’s 

longspur 

Calcarius 

mccownii 

USFS-R2S Nesting/Foraging: 123 Nesting/Foraging: 619 No Impact 

Chestnutcollard 

longspur 

Calcarius 

ornatus 

USFS-R2S Nesting/Foraging: 639 Nesting/Foraging: 619 No Impact 

Northern 

harrier 

Cirus cyaneus USFS-R2S Nesting/Foraging: 639 Nesting/Foraging: 907 Nesting/Foraging: 667 

Grasshopper 

sparrow 

Ammodramus 

savannarum 

USFS-R2S Nesting/Foraging: 639 Nesting/Foraging: 907 No Impact 

Black tern Childonias 

niger 

USFS-R2S; 

KS-SINC 

Nesting/Foraging: 58 Nesting/Foraging: 5 Nesting/Foraging: 2 

State Status Species 

Mammals 

Northern 

pocket 

gopher 

Thomomys 

talpoides 

CO-SOC Reproduction/Foraging: 

639 

Nesting/Foraging: 907 No Impact 

Franklin’s 

ground 

squirrel 

Spermophilus 

franklinii 

KS-SINC No Impact No Impact Reproduction/Foraging: 

8 

4.7-17 
Table 4.7-3 Acres of Suitable Habitat Directly Impacted by Construction Activities for Special 

Status Wildlife Species 

Common 

Name 

Scientific 

Name Status1 

Acres of Suitable Habitat Directly Impacted by Construction Activities 

Wyoming Colorado Kansas 

Long-legged 

myotis 

Myotis volans WY-NSS2 Reproduction: No 

Impact 

Foraging:45 

Reproduction: No 

Impact 

Foraging: <1 

No Impact 

Pallid bat Antrozous 

pallidus 

WY-NSS2; 

KS-SINC 

Reproduction/Foraging: 

2,974 

Reproduction/Foraging: 

1,563 

No Impact 

Eastern 

spotted 

skunk 

Spilogale 

putorius 

KS-T No Impact No Impact Reproduction/Foraging: 

669 

Birds 

Snowy 

plover 

Charadrius 

alexandrinus 

KS-T; COSOC Nesting/Foraging: 58 Nesting/Foraging: 5 Nesting/Foraging: 2 

Black rail Laterallus 

jamaicensis 

KS-SINC No Impact No Impact Nesting/Foraging: 2 

Short-eared 

owl 

Asio 

flammeus 

KS-SINC Nesting/Foraging: 691 Nesting/Foraging: 909 Nesting/Foraging: 669 

Bobolink Dolichonyx 

oryzivorus 

KS-SINC Nesting/Foraging: 52 Nesting/Foraging: 1 Nesting/Foraging: 2 

Reptiles 

Glossy 

snake 

Arizona 

elegans 

KS-SINC No Impact Reproduction/Foraging: 

679 

Reproduction/Foraging: 

1,193 

Western 

hognose 

snake 

Heterodon 

nasicus 

KS-SINC No Impact Reproduction/Foraging: 

619 

Reproduction/Foraging: 

561 

Common 

garter snake 

Thamnophis 

sirtalis 

CO-SOC Reproduction/Foraging: 

56 

Reproduction/Foraging: 

1 

Reproduction/Foraging: 

2 

Eastern 

hognose 

snake 

Heterodon 

platirhinos 

KS-SINC No Impact No Impact Reproduction/Foraging: 

563 

1

Status Definitions: 

FC = Federally Candidate 

FE = Federally Endangered

FT = Federally Threatened 

WY-NSS1= Wyoming Critically Imperiled Species 

WY-NSS2= Wyoming Imperiled Species 

CO-E = Colorado Endangered 

CO-T = Colorado Threatened

KS-E = Kansas Endangered

KS-T = Kansas Threatened 

KS-SINC= Kansas Species in Need of Conservation 

BLM-WY = Wyoming BLM sensitive 

USFS-R2S = USFS Region 2 sensitive species 

USFS-R4S = USFS Region 4 sensitive species (considered with BLM sensitive species) 

PNG= Pawnee National Grassland 2

While these species are not impacted within in the states crossed by the Proposed Action, Platte River water depletions could cause 

downstream impacts. 

3 These acreages do not reflect occupied habitat on private lands 

4

As noted during 2006 suitable habitat surveys 

5

Kansas impact acreage derived from vegetation data. Suitable habitat surveys were not completed in Kansas. 

4.7-18 
MIS Species 

Temporary habitat reductions for MIS species would occur in the following habitat types: sagebrush, 

shortgrass prairie, cliff and rock outcrops, and midgrass prairie. A corresponding reduction in populations of 

these species would be minimized by the availability of suitable habitat in the vicinity of the project area. 

Species that are at or near carrying capacity could suffer some increased mortalities. Additional impacts to 

MIS species are discussed by habitat association in Tables 4.7-3 and 4.7-4, below and in the BR. This project 

meets the objectives of Forest Plans for the PNG and the ANF-FGNRA for MIS species. 

Aquatic Resources 

The impact analysis for sensitive fish and amphibian species is generally the same as discussed for aquatic 

resources. Impacts are applicable to streams that contain sensitive fish species, as listed below by state. 

Species potentially occurring in these streams are discussed in Section 3.7.1.1. Potential habitat consisting of 

flooded areas, wetlands, streams, and seasonally dry lakes also occurs in Wyoming and Colorado for special 

status amphibian species (Table 3.7-4). 

• Wyoming – Hams Fork River, Blacks Fork River, Green River, and Bitter Creek; 

• Colorado – South Platte, Chief Creek, North Fork Republican River, and Arikaree River; and 

• Kansas – Smokey Hill and South Fork Republican rivers. 

Since Overland Pass has committed to directional drilling at one waterbody (South Platte River) that contains 

special status fish species, construction-related impacts on special status fish species and their habitat would 

be minor at this river crossing. It is possible that mud from the directional drilling could inadvertently enter the 

active stream along the drilling route. However, if mud seepage is detected, the drilling operation would be 

stopped immediately to reduce pressure within the bore hole. Corrective measures would be implemented to 

eliminate or minimize seepage. If any seepage enters the stream, increased turbidity or physical disturbance to 

the bottom substrate would be localized and short-term in duration (less than 1 day). 

Table 4.7-4 Impacts for Management Indicator Species 

Habitat 

Association 

Species Project-related Impacts 

Sagebrush Sage grouse Sagebrush is a minor component on FGNRA forest service lands located 

within the project area. Potential impacts to sage grouse are identified in 

Section 4.7.1.3 and in the BR. 

Cliffs and Rock 

Outcrops 

Golden eagle Direct impacts to marginal rock cliff habitats occurring in the FGNRA would 

occur as a result of the proposed project. Impacts to raptors and 

passerines potentially nesting in this habitat type would be direct (loss of 

foraging habitat) and indirect (human activity, noise). This species is 

discussed further in the BR. 

Shortgrass prairie Mountain Plover Shortgrass prairie is the major component of USFS lands located within 

the proposed project area. Potential impacts to raptors are identified above 

under non-game species, while mountain plover impacts are discussed in 

Section 4.7.1.3. Both of these species are discussed in the BR. 

 Ferruginous Hawk 

Midgrass prairie Ferruginous Hawk

 Lark Bunting 

Midgrass prairie is a minor component of the USFS lands located within 

the proposed project area. Impacts to raptors and migratory birds are 

discussed above under non-game species. 

Prairie dog towns Black-tailed prairie 

dog; 

 Western burrowing 

owl 

Prairie dog towns and western burrowing owl would be impacted 

throughout the USFS lands located within the project area in the PNG. 

These impacts are discussed in Section 4.7.1.3 and in the BR. 

Prairie woodlands Mule deer No USFS lands located within the project area contain prairie woodlands. 

Various habitats 

economic 

Mule deer; 

Elk 

This habitat type doesn’t occur on USFS lands located within the proposed 

project. 

4.7-19 
Open-cut trenching would be used at the other perennial streams that contain one or more special status fish 

species. Details on construction procedures for stream crossings are provided in the Overland Pass 

Construction, Reclamation, and Revegetation Plan (Appendix C). Open-cut trenching could result in the same 

types of impacts as discussed for aquatic resources. Impact issues would result from trenching in the Hams 

Fork River and one of the Blacks Fork River crossings (RP 18.9), which could adversely affect habitat for 

special status fish species if the open-cut is not properly restored. Improper restoration also could adversely 

affect habitat for flannelmouth sucker and roundtail chub. Mitigation measure SSS-1 would be implemented for 

the Bitter Creek crossing, which would involve a dry crossing method, if perceptible flow exists at the time of 

construction. Mitigation measure WILD-3 also would be implemented, requiring Overland Pass to contact 

WGFD at least 72 hours prior to initiating construction at the Black Fork, Hams Fork, and Bitter Creek 

crossings. 

As part of project-committed mitigation, construction would occur during the following timeframes: 

• Hams Fork and Blacks Fork Rivers – October 1 through June 1; and 

• South Platte River – August 1 through November 30. 

Colorado River Basin Depletion 

Hydrostatic testing and dust control would result in water depletions in the Colorado River Basin. Hydrostatic 

test water would be withdrawn once during the period January through March 2008. In the Colorado River 

Basin, water sources for hydrostatic testing would include the Blacks Fork and Green rivers. A total of 

18.1 acre-feet would be withdrawn from these rivers for hydrostatic testing. Dust control could use up to 

28.4 acre-feet from the Colorado River Basin. The water sources for dust control would be four municipal 

water wells owned by the cities of Green River, Kemmerer, Rock Springs, and Rawlins. These municipal wells 

represent existing water supplies. The total estimated consumptive water use would be 46.5 acre-feet in the 

Colorado River Basin. 

As part of project-committed mitigation for the Proposed Action, water use would comply with the Recovery 

Implementation Program for Endangered Fish Species in the Upper Colorado River Basin (Recovery Plan), 

which was established in 1988 to mitigate for water depletion impacts to federally listed fish species. To ensure 

the survival and recovery of the listed species, water users are required to make a one-time payment to the 

Recovery Plan. The current depletion fee (through September 2007) is $ 17.24/acre-foot. In 1995, an intraUSFWS Opinion determined that the fee for depletions of less than 100 acre-feet (annual average) would no 

longer be required. The relatively small depletions associated with hydrostatic testing and dust control would 

be covered under the existing Recovery Plan and considered a minor depletion. 

Platte River Basin Depletion 

Since 1978, the USFWS determined that actions resulting in depletions to flows in the Platte River system are 

likely to adversely affect one or more federally listed threatened or endangered species and adversely modify 

critical habitat. The four federally listed species that have been the focus of recovery efforts (the “target 

species”) are the whooping crane, the northern Great Plains population of the piping plover, the interior least 

tern, and the pallid sturgeon. 

The Platte River Recovery Implementation Program (PRRIP), established in 2006, is implementing actions 

designed to assist in the conservation and recovery of the target species and their associated habitats along 

the central and lower Platte River in Nebraska through a basin-wide cooperative approach agreed to by the 

States of Wyoming, Nebraska, and Colorado and the U.S. Department of the Interior. The PRRIP addresses 

the adverse impacts of existing and certain new water related activities on the Platte River target species and 

associated habitats, and provides ESA compliance for effects to the target species and whooping crane critical 

habitat from such activities including avoidance of any prohibited take of such species. The State of Colorado 

and the State of Wyoming are in compliance with their obligations under the PRRIP. 

4.7-20 
For federal actions and projects participating in the PRRIP, the program’s Final EIS and the June 16, 2006 

programmatic BO serve as the description of the environmental baseline and environmental consequences for 

the effects of the Federal actions on the listed target species, whooping crane critical habitat, and other listed 

species in the central and lower Platte River addressed in the programmatic BO. Impact discussions relevant 

to the Platte River Basin are provided below. 

y	 Wyoming. Construction of the proposed pipeline project would result in approximately 42.7 acre-feet 

of new, one-time depletions to the North Platte River, at the Wyoming/Nebraska state line as a result 

of hydrostatic testing and dust control water use. The sources of water for the replacement of the 

project’s uses are listed in Table 4.5-2 along with information on the withdrawal points, withdrawal 

schedule, and the duration of water use. The options for discharge of hydrostatic test water would be 

to return it back to the North Platte and Laramie rivers or to discharge it in upland areas located within 

50 to 100 feet of these waterbodies. In Wyoming, the proposed pipeline project qualifies as a “new 

water related activity” because such action constitutes new surface water or hydrologically connected 

groundwater activities which may affect the quantity or timing of water reaching the associated 

habitats of the target species implemented after July 1, 1997. 

y	 Colorado. Construction of the pipeline would result in approximately 47.2 acre-feet of one-time, new 

depletions to the South Platte River associated with hydrostatic testing, dust control, and HDD. The 

estimated water volumes, sources, withdrawal points, withdrawal schedule, and duration of water use 

are provided in Table 4.5-2. Hydrostatic test water would be discharged back to the North Sterling 

Ditch or in an upland area located within 50 to 100 feet of the source waterbody. A hydrostatic test 

water discharge permit will be acquired from the CDPHE prior to discharge. The HDD process and 

dust control would be consumptive uses with no water discharge. In Colorado, the proposed pipeline 

project qualifies as a “new water related activity” because such action constitutes a new surface water 

or hydrologically connected groundwater activity which may affect the quantity or timing of water 

reaching the associated habitats of the target species implemented after July 1, 1997. 

As part of applicant-committed mitigation for the Proposed Action, water use would comply with the June 2006 

programmatic BO. Overland Pass is required to submit documentation to the USFWS to fulfill the 

responsibilities of PRRIP participants. Toward this end, the BA prepared for the Proposed Action includes the 

following documentation certifying the project as a new, one-time use water related activity and Overland Pass’ 

intention to rely on the provisions of the PRRIP to provide ESA compliance for potential impacts to the target 

species and whooping crane critical habitat. Mitigation required in each state under the PRRIP is discussed 

below. 

y	 Wyoming. A letter from the State of Wyoming’s State Engineer’s Office will be sent to Overland Pass 

to certify that the water use is covered under the PRRIP. The letter will confirm that the project’s water 

use conforms to the criteria in Section II of Chapters 2 or 3 of Wyoming’s Depletions Plan. 

y	 Colorado. South Platte Water Related Activities Program (SPWRAP) is a nonprofit corporation 

formed to assist the State of Colorado in complying with its obligations under the PRRIP for projects in 

the South Platte River and North Platte River basins. Funds provided by water users and SPWRAP 

members help support Colorado’s participation in the program. The Proposed Action qualifies as a 

one-time use, new water related activity in Colorado and does not require membership in SPWRAP. 

This one-time use, however, does require a one-time use fee to SPWRAP, which has been paid. 

As part of applicant-committed mitigation, appropriate size mesh would be used on pumps to minimize 

entrainment of early life stages of special status fish species that may be present in the Hams Fork, Blacks 

Fork, Green, and South Platte rivers. 

Plant Species 

A total of 18 special status plant species have been identified as potentially occurring within the project area 

(Tables 4.7-2 and 4.7-5 and Appendix I). Special status plant species may be directly impacted by surface 

4.7-21 
disturbing activities such as clearing, trenching or trampling. The primary impact of the proposed project on 

vegetation would be the cutting, clearing, and/or removal of existing vegetation within the construction work 

area. However, based on Overland Pass’ commitment to follow construction procedures detailed in its POD 

and Construction, Restoration, and Revegetation Plan (Appendix C), potential impacts to special status plant 

species would be low, with the exception of Nelson’s milkvetch (SSS-2). Acres of special status plant species 

habitat that would be affected by construction activities are included in Table 4.7-5. 

Table 4.7-5 Acres Impacted by Construction Activities for Special Status Plant Species 

Common Name Scientific Name Status1

Acres Impacted by Construction Activities 

 Wyoming Colorado Kansas 

Federally Listed Species 

Colorado butterfly plant Gaura neomexicana 

spp. coloradensis 

FT No Impact No Impact No Impact 

Blowout penstemon Penstemon haydenii FE No Impact No Impact No Impact 

Ute ladies' tresses Sprianthes diluvialis FT ; USFS-R4S No Impact No Impact No Impact 

BLM Sensitive Species 

Laramie columbine Aquilegia laramiensis BLM -WY No Impact No Impact No Impact 

Nelson's milkvetch Astragalus nelsonianus BLM-WY 3.4 No Impact No Impact 

Trelease's 

racemose milkvetch 

Astragalus racemosus 

var. treleasei 

BLM-WY No Impact No Impact No Impact 

Cedar Rim thistle Cirsium aridum BLM-WY No Impact No Impact No Impact 

Ownbey's thistle Cirsium ownbeyi BLM-WY No Impact No Impact No Impact 

Large-fruited bladderpod Lesquerella macrocarpa BLM-WY No Impact No Impact No Impact 

Prostrate bladderpod Lesquerella prostrata BLM-WY No Impact No Impact No Impact 

Gibbens' beardtongue Penstemon haydenii BLM-WY No Impact No Impact No Impact 

Tufted twinpod Physaria condensata BLM-WY No Impact No Impact No Impact 

Persistent 

sepal yellowcress 

Rorippa calycina BLM -WY No Impact No Impact No Impact 

Laramie false sagebrush Sphaeromeria simplex BLM -WY No Impact No Impact No Impact 

Green River greenthread Thelesperma 

caespitosum 

USFS- R4S; BLM -

WY 

No Impact No Impact No Impact 

USFS Sensitive Species 

Dwarf milkweed Asclepias uncialis USFS-R2S No Impact No Impact No Impact 

Prairie moonwort Botrychium campestre USFS-R2S No Impact No Impact No Impact 

Sandhill goosefoot Chenopodium cycloides USFS-PNG No Impact No Impact No Impact 

Wyoming feverfew Parthenium alpinum Former USFS-R2S No Impact 1.1 No Impact 

1

 Status Definitions: 

FE = Federally Endangered. 

FT = Federally Threatened.

BLM-WY = Wyoming BLM sensitive. 

USFS-R2S = USFS Region 2 sensitive species. 

USFS-R4S = USFS Region 4 sensitive species. 

PNG= Pawnee National Grassland.

Additional Mitigation 

Flannelmouth Sucker 

SSS-1: If there is perceptible flow within Bitter Creek at the time of crossing, Overland Pass shall use a dry 

crossing method (dam-and-pump or flume method) to protect the flannelmouth sucker populations. 

4.7-22 
Nelson’s Milkvetch 

SSS-2: Overland Pass shall prepare a plan prior to construction to be approved by the BLM to avoid 

disturbance to all Nelson’s milkvetch plant locations. 

Conclusion 

Wildlife Species 

Impacts to special status wildlife species would be avoided or minimized through implementation of Overland 

Pass’ POD, Conservation Measure Plan, Special Status Species Survey Plan, and committed measures 

(Overland Pass 2007). Since the publication of the Draft EIS, Overland Pass has committed to supplemental 

mitigation measures intended to reduce impacts to sensitive species. These mitigations would further minimize 

potential impacts to the Preble’s meadow jumping mouse, migratory birds, mountain plover, eastern spotted 

skunk, and midget faded rattlesnake. These protective measures would prevent or minimize potential impacts 

to special status wildlife species, such that the proposed project would not be likely to result in a loss of 

viability, nor cause a trend toward federal listing or a loss of species viability rangewide. 

Aquatic Resources 

Impacts to special status fish species in eight streams (Bitter Creek, South Platte River, Chief Creek, North 

Fork Republican River, Republican River, Arikaree River, Smokey Hill River, and South Fork Republican 

River) would be minimized through applicant-committed and recommended additional mitigation (SSS-1, 

Appendix A), implementation of Overland Pass’ Construction, Reclamation, and Revegetation Plan 

(Appendix C), and other POD-related plans. These plans would minimize effects on habitat for special status 

fish species as a result avoiding spawning periods, controlling sediment from disturbed areas, and reclaiming 

streambanks. Additional mitigation would include a requirement for bridges at all flowing stream crossings 

(WATER-1) and establishing a setback distance from riparian vegetation (VEG-1). Applicant-committed 

mitigation measures would reduce impacts to sensitive species, such as stonecat, flannelmouth sucker, and 

roundtail chub. Collectively, these protection measures would minimize potential impacts to special status fish 

species such that the proposed project likely would not result in a loss of viability, nor cause a trend toward 

federal listing or loss of species viability rangewide. 

Trenching in the Hams Fork River and the Blacks Fork River at RP 18.9 could result in long-term adverse 

impacts to habitat for special status fish species if the streambed is not properly restored. Scouring also could 

affect fish movements during low flow periods. As a result of these impacts, population levels could decrease 

for one or more of the special status fish species (flannelmouth sucker, bluehead sucker, and roundtail chub) 

in the Hams Fork and Blacks Fork rivers. Potential population declines could contribute to a loss of viability or 

trend toward listing one or more of these fish species. 

Construction activity within the ROW could directly affect special status amphibian species in flooded areas, 

wetlands, streams, or ponds in Wyoming and Colorado. Vehicles could cause mortalities or alter aquatic 

habitat used by these species. Mitigation measure VEG-1 (setback from waterbodies and riparian vegetation) 

would minimize effects on amphibian habitat. The project likely would not result in a loss of viability, nor cause 

a trend toward federal listing or loss of species viability rangewide. 

Plant Species 

Impacts to special status plant species would be avoided or minimized through implementation of Overland 

Pass’ POD, Conservation Measure Plan, Special Status Species Survey Plan, and applicant-committed 

measures (Overland Pass 2007). These protective measures would prevent or minimize adverse impacts on 

special status plant species, such that the proposed project would not be likely to result in a loss of viability, 

either locally or rangewide. 

4.7-23 
Operation Phase 

Issues 

• The issues associated with operations would be similar to the issues described for wildlife, aquatic, 

and vegetation resources. 

• Potential localized sedimentation and disturbance to habitat if maintenance activities were required at 

a stream crossing. 

Analysis 

Wildlife Species 

Both normal and abnormal (e.g., spill event and clean up) operations would have negligible effects on special 

status wildlife resources. Impacts to special status wildlife and plant species from maintenance activities would 

be the same as those discussed above. Direct impacts would include the incremental long-term habitat loss or 

alteration of potential breeding and/or foraging habitats until native vegetation has become reestablished. 

Potential impacts also could result in mortalities of less mobile or burrowing species as a result of crushing by 

vehicles and equipment, and the potential abandonment of a nest site or territory and the loss of eggs or 

young. Other impacts could include short-term displacement of some of the more mobile species from the 

disturbance areas as a result of increased noise and human presence. In order to reduce potential impacts to 

special status wildlife species as a result of maintenance activities on BLM-administered lands, Overland Pass 

would gain approval from the authorized BLM officer. The authorized BLM officer would coordinate with the 

appropriate BLM wildlife biologist(s) to determine if the activity would result in a direct impact to special status 

wildlife resources. If applicable, appropriate mitigation measures identified above in Section 4.7.1 would be 

implemented in order to minimize potential impacts to special status wildlife resources. 

Aquatic Resources 

Operational effects of maintenance activities at a stream crossing are limited to localized stream bottom 

disturbance. In the unlikely event of a pipeline leak at a stream crossing, released product would transition into 

a gaseous state and quickly volatilize. It would not be toxic to aquatic biota (Appendix L). If a rupture occurred 

at a stream crossing, fish are expected to move away from the rupture area. Potential impacts would be 

short-term and low magnitude due to the localized extent of the affected area. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Routine maintenance and operation of the pipeline would result in minimal impact, if any, to special status 

species. Maintenance activities along the proposed pipeline route would result in localized, dispersed impacts 

of short duration along the proposed pipeline route. If NGLs were accidentally released into waterbodies due to 

a pipeline leak, minimal impacts, if any, would be expected to special status species. 

4.7.2 No Action Alternative 

4.7.2.1 Wildlife 

Under the No Action Alternative, the proposed project would not be constructed or operated. No project-related 

disturbance would occur for wildlife resources. Impacts to wildlife would continue at present levels as a result 

of natural conditions and existing development in the project area. 

4.7-24 
4.7.2.2 Aquatic Species 

Under the No Action Alternative, the proposed project would not be constructed or operated. No project-related 

disturbance would occur. Impacts to aquatic resources in the various drainages would continue at present 

levels as a result of natural conditions and existing development in the project area. 

4.7.2.3 Special Status Species 

No project-related disturbance would occur in special status species habitat. Impacts to special status species 

and their habitat would continue at present levels as a result of natural conditions and existing development in 

the project area. 

4.7.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

4.7.3.1 Wildlife 

Vegetation composition along the Southern Energy Corridor – Copper Ridge Bypass Alternative is similar to 

the corresponding portion of the Proposed Action. Consequently, the impacts of this alternative would be 

similar to those discussed for the Proposed Action. However, this alternative contains more pronounced 

elevation relief than that present in the corresponding section of the Proposed Action; therefore, increased 

impacts to cliff-associated species would potentially occur as a result of the implementation of this alternative. 

No additional big game crucial winter habitat would be impacted by this alternative. 

4.7.3.2 Aquatic Resources 

The effects of this alternative would be similar to impacts discussed for the Proposed Action. The only 

difference is that two additional streams would be crossed by the Southern Energy Corridor – Copper Ridge 

Bypass Alternative, consisting of one Little Bitter Creek crossing and two Cedar Creek crossings. Aquatic 

resources in these streams consist of nongame fish species and macroinvertebrates. No hydrostatic test water 

withdrawals would occur in these streams. 

4.7.3.3 Special Status Species 

The impacts of this alternative would be similar to those discussed for the Proposed Action. Increased impacts 

to special status cliff obligate species potentially would result from the implementation of this alternative. No 

additional perennial streams with special status aquatic species would be crossed by the Southern Energy 

Corridor – Copper Ridge Bypass Alternative. 

4.7-25 
4.8 Land Use, Recreation, and Aesthetics 

4.8.1 Proposed Action 

4.8.1.1 Agricultural Lands 

Construction Phase 

Issues 

• Construction interference with planting and harvesting annual crop and livestock management (access 

to pasture and water). 

• Reduced crop productivity because of soil mixing and compaction (see Soils). 

• Potential damage to field drainage tiles, terraces in contoured fields, surface irrigation systems and 

buried irrigation systems (center pivots). 

Analysis 

Rangeland, used for livestock grazing, would be the most predominant land use affected by the proposed 

project. The effects of construction on rangeland are expected to be minor and short term. During construction, 

Overland Pass would leave gaps between strung sections of pipe approximately every 0.5 mile, at major game 

crossing trails or livestock trails to water sources, wherever there is a feature crossing (e.g., waterbody, road, 

utility), or where identified by the EI to allow livestock to pass between long, continuous sections prior to 

lowering in. Additionally, ramps would be installed to allow for the escape of livestock should they fall into the 

trench. These measures would mitigate potential impacts to livestock during pipeline construction. Providing 

adequate notice to federal grazing permittees and maintaining access to rangeland for winter sheep 

operations also are important issues. 

The primary impacts on agricultural land during construction would include the loss of crops within the work 

area and the potential for reduced yield of future crops. Agricultural land in the construction area generally 

would be taken out of production for one growing season. Preconstruction herbaceous and shrub communities 

are anticipated to reestablish within one or two growing seasons after construction. Overland Pass would 

implement the Construction, Reclamation, and Revegetation Plan (Appendix C) to ensure timely and 

appropriate revegetation. 

Severely compacted agricultural areas resulting from construction activities would be decompacted. While few, 

if any, drain tiles would be encountered along the proposed pipeline route, Overland Pass would replace/repair 

any drain tiles, as well as irrigation systems, damaged by construction activities in accordance with the 

Construction, Reclamation, and Revegetation Plan. 

The construction techniques proposed by Overland Pass are largely sufficient to minimize impacts and restore 

surface contours. However, agricultural lands that rely on flood irrigation may have overland flow of water 

disrupted by the pipeline trench, even after compaction and restoration (Section 3.8). 

Overland Pass should avoid agricultural properties that rely upon flood irrigation. The majority of agricultural 

lands are on private land. While the BLM has no regulatory authority to require additional mitigation on private 

land, private landowners can request mitigation as part of their easement negotiations. 

Additional Mitigation 

LAND-1: Overland Pass shall notify all federal grazing permittees at least 5 days in advance of construction 

activities. Additionally, Overland Pass must take measures to avoid cutting off access to rangeland 

for winter sheep operations. 

4.8-1
Conclusion 

Overland Pass would implement measures described in the Construction, Reclamation, and Revegetation 

Plan to mitigate impacts on rangeland and agricultural land affected by construction activities. Additionally, 

Overland Pass would implement the measures described in other plans within its POD specific to federal lands 

(Overland Pass 2007). Key applicant-committed measures are identified in Appendix A. 

Preconstruction activities would include measures to mitigate impacts on existing and future drain tiles and 

irrigation systems, livestock exposed to open trenches, and the introduction or spread of noxious weeds. 

Overland Pass would be responsible for ensuring successful revegetation of soils disturbed by project-related 

activities. On federal lands, reclamation would be considered successful if the ROW had 80 percent of the 

species composition and cover of undisturbed, adjacent vegetation. Follow-up inspections of all disturbed 

areas would be done for 5 years (in July of the first, third, and fifth growing seasons) to evaluate revegetation 

and erosion control success. In agricultural areas, revegetation would be considered successful if crop yields 

are similar to adjacent undisturbed portions of the same field. Revegetation efforts on federal lands would 

continue until the above standards are fulfilled. 

On private lands, Overland Pass would construct the pipeline and aboveground facilities in accordance with 

federal regulations and standard industry practices. Some of the mitigation measures that are stipulated for 

federal lands would not be required on private lands unless specified by the land owner in the easement 

agreement with Overland Pass. Federal revegetation standards would not be enforced on private lands, so 

long-term impacts on rangeland could occur. Windbreak trees would be removed, and the restoration of 

windbreaks would depend upon individual agreements with landowners. However, Overland Pass is 

committed to restoration of all land, consistent with its Construction, Reclamation, and Revegetation Plan, to 

ensure longevity and safe operation. 

Operation Phase 

Issues 

• Potential interference with farm field cultivation and harvest. 

• Same issues identified for construction, but on a smaller scale. 

Analysis 

Following construction, rangeland uses would be allowed to continue within the permanent ROW. Temporary 

fences would be removed, the ROW restored to its pre-construction condition, and livestock would be able to 

graze and roam freely over the permanent ROW. No long-term impacts to rangeland are expected. 

Once construction was completed, the majority of agricultural land uses would be able to continue within the 

permanent, operational ROW. However, where aboveground facilities were sited on agricultural land, the land 

use would be permanently changed from agricultural to developed land. Some activities within the permanent 

ROW, such as planting of tree and shrubs would be prohibited. 

Following cleanup and reseeding of the construction ROW in agricultural areas, the affected areas would 

typically regenerate quickly. Vegetation would generally be reestablished within 2 years of restoration, 

depending on climatic conditions. 

While the pipeline would be constructed with a minimum of 30 inches of cover in most areas (per 49 CFR 

Part 195), there is no federal regulation mandating minimum depth of cover during operations. It is possible 

that the soil over the pipeline would erode over time, leaving the pipe with less soil cover and, in some cases, 

possibly exposed. This could pose a safety hazard in agricultural areas where plowing occurs. Consequently, 

Overland Pass would conduct visual surveillance of the ROW to monitor and correct pipeline burial depth as 

necessary. 

4.8-2
Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

During operations, the ROW would revegetate and largely would revert to former uses. Most agricultural crops 

would be permitted to grow in the ROW. With the exception of forest land removed from the permanent ROW 

(accounting for less than 1 percent of land) and placement of aboveground facilities, the majority of previous 

land uses would continue unencumbered. 

4.8.1.2 Transportation 

Construction Phase 

Issues 

• Interference with local traffic and traffic to recreational destinations. 

• Potential damage to roads and highways from open-cuts. 

• Potential damage to roads and bridges from heavy loads. 

Analysis 

Interference with Traffic 

The existing transportation system could be temporarily impacted by commuting construction workers and 

other construction activities. Overland Pass anticipates that approximately 1,300 to 1,500 construction 

personnel would be required to complete the project, which would be divided into 5 construction spreads, each 

consisting of approximately 200 to 300 workers, depending on the length of each construction spread. 

Construction personnel would consist of Overland Pass’ employees, contractor employees, construction 

inspection staff, and environmental inspection staff. The majority of these workers would commute to the 

construction ROW and/or yards early in the morning and return in the evening during non-peak traffic hours. 

The impacts would be minimal because of the work schedule and the predominantly rural locations where the 

pipeline would be constructed. Since the existing rural roadway systems are not at capacity, additional 

vehicles associated with construction would not cause significant traffic congestion problems. 

Temporary traffic increases would occur during construction on several primary public roads in Wyoming. I-80 

would be utilized to access the project area from Green River to Cheyenne. From Opal to Green River, State 

Highway 30 would provide primary access to the project area. State Highways that would experience 

significant, temporary increases in traffic include 789, 130, and 287. These roads would provide construction 

crews with access to lodging and the construction area access roads. 

In Colorado, traffic increases would be slight during construction on I-25 and I-76 between Fort Collins and 

Greeley. Temporary increases also would occur on State Highways 287, 85, 34, and 71, which would provide 

access to the entire northeast portion of the project area and lodging facilities for construction crews. 

Traffic increases would be slight during construction on I-70 from the Colorado border to the Hays area of 

Kansas. Temporary traffic increases also would occur on State Highways 83, 283, 147, and 183. These roads 

would provide access to lodging for construction crews and county roads (section line roads) to be utilized as 

access roads for the project area. 

Up to approximately 7 pipe-stringing trucks would be making up to 2 or 3 round-trips per day on each 

construction spread from the 12 proposed pipe storage yards to reach access roads to the construction ROW. 

It is also expected that water trucks and transport trucks would make 12 or more trips per day on average to 

4.8-3
deliver materials and equipment to the construction ROW. Once a vehicle leaves a pipe yard, the exact route 

taken would vary depending on the current location of construction activity and the construction spread it was 

serving. 

The proposed pipeline route would cross the FGNRA at Cordwood and Davis Bottoms, near Green River, 

Wyoming. The pipeline could temporarily disrupt public access to this area during construction. Short-term 

impacts would reduce public access to the area, during which time the public would have the opportunity to 

access the river corridor further down the Green River. 

The project could directly but temporarily affect dispersed recreationalists on public land within the PNG 

including hikers, birdwatchers, off-highway vehicle (OHV) users at the main OHV area, mountain bikers, and 

hunters as construction passes through the area. Short-term impacts would include reduced access across the 

construction ROW; increased noise, dust, and heavy equipment emissions; and fewer opportunities to view 

wildlife. 

Construction would interrupt recreational floating and fishing traffic to the Rochelle Easement along Carbon 

County Road 347, the primary access to the North Platte River in proximity to I-80. In general, these impacts 

would be short-term and limited to the period of active construction, which typically would be limited to several 

days to several weeks in any one area. Overland Pass would work with land managers to mitigate construction 

impacts such as timing and obtaining the required permits or authorizations. 

Overland Pass has developed a Traffic and Transportation Management Plan to describe how they would 

comply with federal policy and standards relative to planning, location, improvement, maintenance, and 

operation of roads for the project. Impacts would be mitigated by advance notification and posting signs during 

construction to indicate to construction personnel and the public, which roads are being utilized at any given 

time. The Traffic and Transportation Management Plan is included as part of the POD (Overland Pass 2007). 

Road Damage 

Overland Pass has identified 2,577 miles of access roads that could be used during construction. The use of 

dirt roads, particularly farm and ranch roads and two-track trails, by construction vehicles and equipment could 

result in road deterioration even without rain events. Overland Pass proposes to perform road maintenance to 

maintain roads in their existing condition where there is evidence that the roads have been previously graded. 

This maintenance would only occur within the existing footprint of the road (i.e., the road would not be 

widened). “Maintenance” is defined for this project as, “blading or filling activities that would be required to 

maintain the roads’ current condition prior to use.” Mud would not be bladed off the existing road grade. 

As needed in rangeland, permanent cattle guards or steel gates would be installed across access roads to: 

• Avoid safety hazards; 

• Replace a permanent existing cattle guard when damaged or destroyed by construction activities; 

• Fulfill the BLM’s Authorized Officer’s requirements; 

• Provide temporary cattle guards or a metal gate on all fences crossed by temporary roads; 

• Provide temporary or permanent cattle fencing; and 

• Allow access by heavy equipment where needed. 

Overland Pass’ construction contractor would determine if existing cattle guards can support trucks and other 

equipment prior to crossing the guards. The construction contractor would be responsible for either 

strengthening the cattle guard or using another access route. 

Where there is no evidence of previous grading or the existing road requires widening, road improvement 

would be allowed only after Overland Pass completes required cultural resources and biological surveys, and 

4.8-4
associated agency consultations. Roads would be used and improved only with permission of the landowner. 

Access roads used for construction that require grading would be restored to their preconstruction condition, at 

the discretion of the landowner. 

Erosion control, revegetation, and restoration measures outlined in Overland Pass’ Construction, Reclamation, 

and Revegetation Plan would be implemented when applicable to improvements to existing access roads. 

Additional Mitigation 

LAND-2: Overland Pass shall post notification at recreation sites and on main access roads into these 

recreation sites warning users of heavy traffic related to construction of the project. 

Conclusion 

Overland Pass would implement a Traffic and Transportation Management Plan to minimize effects of project 

construction and operation on transportation. Overall, the number and frequency of construction vehicle trips 

on major highways would be low on any particular roadway at any one time because construction activities 

would move sequentially along the construction ROW. Travel by vehicles on the ROW on a regular basis (e.g., 

90 pickups, 12 buses, 25 welding rigs) would be distributed along the length of the proposed pipeline route 

over time as the pipe was installed and construction activity progresses to a different part of the ROW. 

During pipeline construction, little or no disruption of traffic would result at road crossings that are bored (such 

as public, paved roads) or drilled. The open-cut construction method would be used across lightly traveled 

gravel roads and unimproved dirt roads. Disruptions in normal access to recreational facilities would be 

short-term, and alternative access points would be posted. 

Operation Phase 

Issues 

• Same issues as construction, but on a smaller scale. 

Analysis 

The Overland Pass Traffic and Transportation Management Plan describes compliance measures relative to 

planning, location, improvement, maintenance, and operation of roads for the project. As a part of its 

permanent aboveground facilities, Overland Pass would construct short permanent access roads from existing 

public roads to access pump station and meter station sites. These roads would be wholly contained within the 

ROW, or constructed within parcels that Overland Pass has identified for the construction of aboveground 

facilities. 

Operation and maintenance of the pipeline facilities would not significantly affect traffic flow on any of the 

paved roads or highways. Required periodic maintenance and inspection procedures would involve a low 

frequency of light vehicle movement on and off roadways. No impact would be expected from this activity. 

Additional Mitigation 

No additional mitigation was identified. 

4.8-5
Conclusions 

No impacts to traffic would be expected from pipeline operation. 

4.8.1.3 Residential / Commercial 

Construction Phase 

Issues 

• Interference with residence/business access. 

• Potential damage to residential landscapes. 

Analysis 

The proposed pipeline route has been designed to maximize co-location with existing ROWs and to minimize 

impact to the environment, area residents, and local businesses. Structures located within 50 feet of the 

Overland Pass construction ROW are identified in Table 4.8-1. None of the structures appear to be occupied 

residences. Overland Pass would determine whether these structures are residences prior to construction. 

Where construction would cross roads that access private residences and no alternative entrances exist, 

measures would be implemented to maintain passage for landowners during construction. If residential 

property was crossed, turf, ornamental shrubs, and specialized landscaping would be restored in accordance 

with the landowner's request or, alternatively, the landowner would be compensated. 

Table 4.8-1 Structures Within 50 Feet of the Construction Work Area for the Proposed Action 

State/County 

Reference 

Point Description of Building 

Approximate Distance 

from Pipeline 

Centerline1 

Direction from 

Pipeline 

Centerline 

Wyoming 

Lincoln 18.5 Structure Within 50 feet SW 

Lincoln 22.5 Structures (2) Within 25 feet W 

Sweetwater 39.6 Structure Within 50 feet S 

Carbon 146.5 Structure Within 50 feet S 

Sweetwater 163.2 Structure Within 50 feet N 

Carbon 189.8 Structure Within 50 feet N 

Carbon 247.6 Structure Within 50 feet S 

Albany 268.1 Structure Within 50 feet SW 

Albany 286.2 Structure Within 50 feet SW 

Colorado 

Weld 386.1 Structure Within 50 feet N 

Weld 399.1 Structure Within 50 feet SW 

Logan 411.8 Structure Within 50 feet S 

Logan 414.0 Structure Within 50 feet S 

Logan 414.4 Structure Within 50 feet S 

Washington 430.9 Structure Within 50 feet NE 

Washington 446.5 Structure Within 50 feet S 

Washington 447.7 Structure Within 50 feet N 

Yuma 456.3 Structure Within 50 feet S 

Yuma 465.8 Structure Within 50 feet SW 

Yuma 470.4 Structure Within 50 feet S 

Yuma 484.6 Structure Within 50 feet S 

4.8-6
Table 4.8-1 Structures Within 50 Feet of the Construction Work Area for the Proposed Action 

State/County 

Reference 

Point Description of Building 

Approximate Distance 

from Pipeline 

Centerline1 

Direction from 

Pipeline 

Centerline 

Kansas 

Cheyenne 513.6 Structure Within 50 feet S 

Cheyenne 528.7 Structure Within 50 feet SW 

Rawlins 545.6 Structure Within 50 feet NE 

Sheridan 577.4 Structure Within 50 feet N 

Sheridan 587.4 Structure Within 50 feet NE 

Sheridan 595.4 Structure Within 50 feet N 

Sheridan 607.2 Structure Within 50 feet NE 

Gove 608.8 Structure Within 50 feet N 

Trego 626.1 Structure Within 50 feet S 

Trego 635.3 Structure Within 50 feet N 

Ellis 656.8 Structure Within 50 feet N 

Ellis 659.8 Structure Within 50 feet S 

Barton 690.2 Structure Within 50 feet N 

Barton 691.0 Structure Within 50 feet SW 

Barton 698.8 Structure Within 50 feet S 

Barton 705.5 Structure Within 50 feet SW 

Rice 717.5 Structure Within 50 feet E 

Rice 738.3 Structure Within 50 feet S 

Rice 743.4 Structure Within 50 feet N 

1

Includes area affected by construction ROW and additional TWAs. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusions 

Overland Pass would implement the procedures identified in their Traffic and Transportation Management 

Plan which would limit traffic, noise, and dust impacts to area residences and businesses. 

Operation Phase 

Issues 

• Same issues as construction, but on a smaller scale. 

Analysis 

Impacts to residents during operations would be minimal due to the infrequent and temporary nature of 

operational activities. 

Most developed land uses would be able to continue following construction. However, some activities, such as

the building of new commercial or residential structures would be prohibited on the permanent ROW. 

4.8-7
Additional Mitigation 

No additional mitigation is identified. 

Conclusion 

To ensure public safety and pipeline integrity, commercial and residential structures would not be allowed on 

the permanent ROW. 

4.8.1.4 Utilities 

Construction Phase 

Issues 

• Buried utility crossings – water lines, fiber optic lines, natural gas and product lines. 

• Offsets from other utilities (overhead electric transmission lines, other pipelines). 

Analysis 

The Proposed Action has been designed to maximize co-location with existing ROWs and to minimize impact 

to the environment, area residents, and local businesses. Where Overland Pass’ facilities would be co-located 

with an existing pipeline ROW, the proposed pipeline centerline generally would be located 50 feet from the 

existing pipeline’s centerline. In most cases, Overland Pass’ proposed 75-foot-wide construction ROW would 

overlap the area disturbed by the previous construction of these existing pipelines. Co-locating the proposed 

pipeline ROW with existing ROWs would reduce the amount of new disturbance associated with this project. 

While co-location of pipelines reduces the amount of new disturbance on the landscape, there are safety 

considerations that limit how close pipelines may be constructed to one another. Depending on a number of 

factors, transmission pipelines generally are constructed between 25 to 60 feet apart. Overland Pass generally 

would offset 50 feet from existing pipelines. The Southern Star pipeline, which Overland Pass is co-located 

with for a substantial length of the proposed pipeline route, has indicated their preference for 50-foot or more 

separation between pipelines. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

The proposed pipeline centerline generally would be located 50 feet from existing pipeline centerlines, where 

possible. Potential impacts would be limited to construction and would be short-term. 

Operation Phase 

Issues 

• Same issues as construction, but on a smaller scale. 

Analysis 

Following construction, Overland Pass would maintain a 50-foot-wide permanent ROW for operation of the 

pipeline facilities. Overland Pass would participate in the state’s one-call programs to ensure maintenance 

activities do not harm other underground utilities. 

4.8-8
Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Co-location with existing pipeline ROWs would help consolidate and minimize impacts associated with utilities. 

4.8.1.5 Aesthetics 

Construction Phase 

Issues 

• New aboveground facilities (pump stations, valves) and new pipeline ROWs may modify natural 

landscapes viewed from special management areas and public locations. 

• Construction noise to nearby residences. 

Analysis 

Visual Resources 

Public lands that would be affected by the proposed pipeline are composed mostly of lands managed by the 

BLM. The BLM has a VRM standard for each resource area that would be crossed by the proposed pipeline 

route. BLM-owned public lands are managed so that the quality of scenic and visual resources is maintained. 

Overland Pass would adhere to these BLM requirements. Where the proposed pipeline crosses USFS lands, 

these SMS standards would be adhered to. 

Visual impacts associated with the construction ROW and additional TWAs would include the removal of 

existing vegetation and the exposure of bare soils, as well as earthwork and grading scars associated with 

heavy equipment tracks, trenching, blasting, rock formation alteration or removal, and machinery and tool 

storage. Other visual effects could result from the removal of large individual trees that have intrinsic aesthetic 

value; the removal or alteration of vegetation that currently could provide a visual barrier; or landform changes 

that could introduce contrasts in visual scale, spatial characteristics, form, line, color, or texture. 

Visual impacts would be greatest where the proposed pipeline route paralleled or crossed roads, trails, 

recreation areas, or prominent off-site observation points, and where the pipeline ROW could be seen by 

passing motorists or recreationalists. The duration of visual impacts would depend on the type of vegetation or 

land formation that was cleared or altered. The impact of vegetation clearing would be shortest on rangeland 

consisting of short grasses and hay fields, where the reestablishment of vegetation following construction 

would be relatively fast (generally 3 to 5 years). The impact would be greater on shrub rangeland, which could 

take several years to regenerate. The greatest potential visual impact would result from the removal of large 

trees, which would take longer than other vegetation types to regenerate and would be prevented from 

reestablishing on the permanently maintained 50-foot-wide ROW. Topographic alterations such as sidehill cuts 

that could be necessary to construct the pipeline would be restored during ROW restoration. The visibility of 

such alterations would diminish over time as the affected areas aged and began to blend with the surrounding 

landscape. 

To minimize construction impacts on visual resources, Overland Pass aligned the proposed pipeline route, 

where feasible, adjacent to existing pipeline ROWs or other transportation corridors. In areas where ROW 

co-location was not possible for engineering and/or construction reasons, Overland Pass aligned the proposed 

pipeline route to avoid aesthetic features to the extent possible. 

The proposed pipeline route would be co-located with another pipeline (Southern Star) across the PNG. 

Construction adjacent to the pipeline ROW would result in an incremental and visible widening of the existing 

4.8-9
previously disturbed corridor. The visibility of this impact would diminish after the ROW is restored and 

revegetated. Impacts on the PNG are expected to be short-term in nature, as the vegetation would generally 

be reestablished within 3 to 5 years of restoration depending on climatic conditions. 

The proposed pipeline would cross approximately 2.0 miles of the FGNRA within ANF. Visual impacts would 

be within established requirements. Impacts would be greatest in the short term and would become less as 

vegetation occurred. Aboveground facilities would be painted earth tones with matte finish. 

Noise 

Noise associated with construction of the proposed Overland Pass pipeline and aboveground facilities would 

be intermittent. Neighbors in the vicinity of the construction areas may hear the construction noise, but the 

overall impact would be temporary. Nighttime noise due to construction would normally be absent since most, 

if not all, construction would be limited to daytime hours. Estimated construction equipment noise is presented 

in Table 4.8-2. 

Table 4.8-2 Estimated Construction Equipment Noise From the Proposed Aboveground 

Facilities 

Equipment Type Noise at 50 feet (dBA) 

Heavy Equipment 85 

Air Compressors 84 

Welders 67 

Concrete Truck 71 

Miscellaneous Trucks (Pick-ups, etc.) 65 

Source: USEPA 1974. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

The proposed pipeline would be buried and the topographical contours would be returned to their 

preconstruction condition. Therefore, visual impacts associated with construction and operation of the 

proposed pipeline facilities would be within BLM VRM management objectives. 

Operation Phase 

Issues 

• New aboveground facilities (pump stations, meter stations, pigging facilities, valves) and new pipeline 

ROWs may modify natural landscapes viewed from special management areas and public locations. 

• Same issues as construction, but on a smaller scale. 

• Operational noise/smells to nearby residences. 

• Proximity of the pipeline to public gathering places. 

4.8-10
Analysis 

Visual Resources 

Overland Pass proposes to construct pump stations, meter stations, valves, and pigging facilities at various 

locations along the proposed pipeline route. These aboveground structures would be permanent and would 

remain in operation throughout the life of the pipeline. The impacts on visual resources from each individual 

facility would depend on the pre-construction condition and the visibility from the surrounding area. To the 

extent possible the pump stations would be constructed adjacent to existing commercial/industrial facilities that 

already experience a visual impact, and the meter stations would be constructed in association with a pump 

station where applicable or placed within an area to minimize visual impacts. Visual impacts from the operation 

of the aboveground facilities would be low. 

The most substantive long-term visual impacts as a result of aboveground facilities would be limited to valves 

or pigging facilities located on federally managed land. The landscape of much of the proposed pipeline route 

is gently rolling with vegetation limited to shrubs or grasses. The views are long – up to many miles. 

Successful revegetation would blend the belowground portions of the pipeline with its surroundings. However, 

aboveground improvements would be very noticeable in this landscape. Aboveground facilities would meet the 

prudent operational requirements of the pipeline owners and operators and also would be compatible with the 

surrounding landscape. This would entail the selection of ground surfacing, building surfacing, fencing, signing, 

and color selection and finish. 

Noise 

During operation, noise impacts associated with the proposed pump and meter stations would be limited to the 

vicinity of the facility. Estimated noise levels from aboveground facilities are listed in Table 4.8-3. 

Table 4.8-3 Estimated Sound Levels from Pump Stations 

Distance from Pump Station 

Estimated Sound Level from Echo Springs and 

Laramie Pump Stations 

(dBA) 

0.25 mile 41 

0.5 mile 33 

1 mile 24 

2 miles 15 

Based on aerial alignment sheets, no occupied residences appear to be located within 50 feet of the proposed 

project area. The Echo Springs (RP 146.5), Laramie (RP 271.7), and future WaKeeney pump stations would 

be located in rural areas with few noise sources in the immediate vicinity. No NSAs are located within 1 mile of 

the Echo Springs and Laramie pump stations; there would be one NSA within 2,550 feet from the future 

WaKeeney Pump Station, if the station were built (Figure 3.8-1). Given the far distances and relatively rural 

area, noise levels in areas where people are located would not differ from background noise. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Project design and applicant-committed mitigation would minimize visual impacts by locating the aboveground 

facilities in areas already used by other pipelines minimizing unnecessary nighttime lighting, and by using 

agency-approved paint colors. 

4.8-11
No noise impacts would occur from most aboveground facilities due to their rural and isolated locations. 

However, if the WaKeeney Pump Station were constructed in the future, noise impacts could occur to the 

closest NSA. The level of noise would likely be greater than existing background noise at this location. 

4.8.2 No Action Alternative 

Under the No Action Alternative, the proposed project would not be constructed or operated. No project-related 

disturbance would occur. Impacts to aesthetic resources would continue at present levels as a result of natural 

conditions and existing development in the project area. 

4.8.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

The primary land uses crossed by the Southern Energy Corridor – Copper Ridge Bypass Alternative would be 

rangeland. Compared to the Proposed Action, approximately 23 additional acres would be dedicated to 

operational pipeline ROW for the project life, with no additional land required for aboveground facilities (pump 

stations, meter stations, pigging facilities, valves, and permanent access roads). 

4.8-12
4.9 Cultural Resources 

4.9.1 Proposed Action 

Construction Phase 

Issues 

• Construction of the Overland Pass Pipeline and its associated facilities could affect NRHP-eligible 

properties such as prehistoric or historic archaeological sites, districts, buildings, structures, and 

objects. 

• Previously undiscovered cultural resources, including burials and associated funerary objects, could 

be discovered and adversely affected during ground-disturbing activities associated with project 

construction. 

• Unauthorized artifact collection and vandalism. 

• Introduction of visual or auditory elements that diminish the integrity of the property’s significant 

historic feature. 

Analysis 

Section 106 of the NHPA requires that federal agencies take into account the effect of an undertaking on 

historic properties and provide the ACHP an opportunity to comment. Historic property, as defined by the 

regulations implementing Section 106, means “any prehistoric or historic district, site, building, structure, or 

object included in, or eligible for inclusion in, the NRHP maintained by the NPS.” The term includes properties 

of traditional religious and cultural importance to an Indian tribe or Native Hawaiian organization that meet the 

National Register criteria. Potential impacts to historic properties are assessed using the “criteria of adverse 

effect” (36 CFR 800.5[a][1]), as defined in the implementing regulations for the NHPA. “An adverse effect is 

found when an undertaking may alter, directly or indirectly, any of the characteristics of a historic property that 

qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the 

property’s location, design, setting, materials, workmanship, feeling, or association.” The analysis of impacts 

using these criteria is limited to those resources that are listed in the NRHP or have been recommended as 

eligible. 

Those areas in which impacts are planned or are likely to occur are referred to as the “area of potential effect” 

or APE. Specifically, the APE is defined as the geographic area or areas within which an undertaking may 

directly or indirectly cause changes in the character or use of NRHP-eligible cultural resources, if any such 

resources exist. Additionally, the APE is influenced by the scale and nature of an undertaking and may be 

different for different kinds of effects caused by the undertaking (36 CFR 800.16[d]). 

The APE should include: 

• All alternative locations for all elements of the Proposed Action; 

• All locations where the Proposed Action may result in disturbance of the ground; 

• All locations from which elements of the Proposed Action (e.g., pump stations or land disturbance) 

may be visible or audible; 

• All locations where the Proposed Action may result in changes in traffic patterns, land use, public 

access, etc.; and 

• All areas where there may be indirect as well as direct effects. 

Only those cultural resources located in the APE were reviewed to determine if any would be subject to 

impacts that could affect their eligibility for the NRHP based on NRHP criteria for evaluation. 

4.9-1
Project impact or effects include not only the physical disturbance of a historic property, but also may include 

the introduction, removal, or alteration of various visual or auditory elements, which could alter the traditional 

setting or ambience of the property. In consultation with Kansas, Colorado, and Wyoming SHPOs; USFS; and 

Native American Tribes; BLM would determine whether construction of the proposed project would affect any 

properties listed on, or eligible for listing on, the NRHP. The BLM has developed protective measures to 

minimize adverse effects on important cultural resource values. Protective measures are used in response to 

the proposed actions of BLM programs involving surface disturbance. These measures include, but are not 

limited to, cultural resource inventories, evaluation of cultural resources located during inventory, assessment 

of a site’s setting where applicable, BMPs, and mitigation of potential adverse impacts on important cultural 

resources. See Appendix J for a detailed description of standard protective measures and BMPs. 

If a property would be adversely affected, mitigation would be proposed. Mitigation may include, but would not 

be limited to, one or more of the following measures: 1) avoidance through the use of realignment of the 

proposed pipeline route, relocation of temporary extra workspace, or changes in the construction and/or 

operational design; 2) data recovery, which may include the systematic professional excavation of an 

archaeological site; or 3) Historic American Buildings Survey (HABS)/Historic American Engineering Record 

(HAER) or other agreed upon historic recordation process. 

Avoidance through project redesign is the preferred method of mitigation. However, when avoidance is not 

feasible, data recovery, HABS/HAER documentation, or any other agreed upon mitigation measure would be 

implemented prior to construction. Based on the Class III inventory reports for Wyoming, Colorado, and 

Kansas, it is determined that there would be adverse effects to historic properties as a result of project 

construction. 

The potential for the discovery of unanticipated cultural resources during construction activities exists within 

proposed disturbance areas and could result in adverse effects. Unanticipated discoveries would result in 

displacement or loss (either complete or partial) of the cultural resource involved. Displacement of cultural 

resources adversely affects the potential to understand the context of the site and limits the ability to 

extrapolate data regarding prehistoric settlement and subsistence patterns. However, mitigation of impacts 

from discoveries is often accomplished through data recovery excavations. 

Prior to BLM authorization of the project, Overland Pass would submit a cultural resources unanticipated 

discoveries plan to the BLM for review which outlines the way in which cultural resources would be treated 

and the responsibilities of the project proponent. This plan would be reviewed by the BLM archaeologist 

and submitted to the SHPOs for concurrence. If any previously unknown cultural resources are discovered 

during construction, all construction activities would cease within the vicinity of the discovery, and the BLM 

would enact the cultural resources unanticipated discoveries plan. 

If construction or other project personnel discover what they believe to be human remains, funerary objects, 

or items of cultural patrimony, construction would cease within the vicinity of the discovery and the BLM 

Authorized Officer and local law enforcement officials would be notified of the find. Construction would not 

resume in the area of the discovery until the BLM Authorized Officer has issued a notice to proceed. 

Treatment of any discovered human remains and associated funerary objects would be handled in 

accordance with the provisions of NAGPRA and/or applicable Wyoming, Colorado, and Kansas laws. 

Additional Mitigation 

ARCH-1: Adverse effects to historic properties will be mitigated through the implementation of a project-wide 

Memorandum of Agreement among the BLM; Pawnee National Grasslands USFS; Overland Pass 

Pipeline LLC; Wyoming, Colorado, and Kansas SHPOs; and the Advisory Council on Historic 

Preservation. 

4.9-2
Conclusion 

Potential adverse effects to identified NRHP-eligible sites would be mitigated prior to pipeline construction. 

Unanticipated discoveries of cultural resources would be protected as described in the cultural resources 

unanticipated discoveries plan prepared for the proposed project. Therefore, all impacts to NRHP-eligible 

cultural resources from project construction would be mitigated. 

Operation Phase 

Issues 

• Issues would be similar to those identified for construction. 

Analysis 

Maintenance activities would result in localized impacts that would be dispersed along the entire proposed 

pipeline route. Maintenance activities would occur within areas previously disturbed by construction. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Potential adverse effects to identified NRHP-eligible sites would be mitigated prior to pipeline construction. 

Unanticipated discoveries of cultural resources would be protected as described in the cultural resources 

unanticipated discoveries plan prepared for the proposed project. Therefore, all impacts to NRHP-eligible 

cultural resources would be mitigated. 

4.9.2 No Action Alternative 

Under the No Action Alternative, the proposed project would not be constructed. As a result, none of the 

potential impacts to cultural resources as identified for the Proposed Action would occur. However, additional 

knowledge of local or regional prehistory of the project area that would have been obtained through data 

recovery would not be collected. 

4.9.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

At this time, a Class III cultural resources inventory of the Southern Energy Corridor – Copper Ridge Bypass 

Alternative has not been completed. A Class I inventory of previously recorded sites within the project area 

resulted in the identification of nine sites within 100 feet of the proposed Southern Energy Corridor – Copper 

Ridge Bypass Alternative centerline and five sites located within 100 feet of the segment of the proposed 

pipeline centerline that would be eliminated if the bypass were chosen. All of the five sites located along the 

proposed pipeline route are recommended as not eligible for the NRHP. Of the nine previously recorded sites 

identified along the Southern Energy Corridor – Copper Ridge Bypass Alternative corridor, two are 

recommended as not eligible for the NRHP, five are unevaluated, one is eligible for the NRHP with SHPO 

concurrence, and one is an NRHP-eligible linear feature; however, the segment of the linear feature identified 

within 100 feet of the proposed bypass centerline is unevaluated. Therefore, compared to the Proposed 

Action, there potentially would be more impacts to cultural resources if the Southern Energy Corridor – Copper 

Ridge Bypass Alternative were chosen. Potential impacts to cultural resources and measures to protect them 

would be the same as described for the Proposed Action. 

4.9-3
4.10 Native American Concerns 

4.10.1 Proposed Action 

Construction Phase 

Issues 

• Protection of sites with cultural, traditional, or religious importance to the tribes. 

Analysis 

The BLM Rawlins Field Office invited tribal officials from the 22 identified Native American tribes to participate 

in two informational meetings and three field visits. The purpose of the meetings and subsequent field tours 

was to discuss the Proposed Action, visit selected archaeological sites that were thought to have traditional, 

cultural, or religious importance to the tribes, solicit any concerns the tribes may have regarding tribal 

resources in the Proposed Action area, and, in general, discuss the Native American consultation process. 

During the field visits, tribal representatives expressed concerns specifically for all cultural resources that 

would be directly impacted by the proposed pipeline route and its construction. Tribes requested the pipeline 

be moved to increase buffers between cultural resources and the pipeline corridor. Of specific importance to 

some tribes was the location of the proposed pipeline in relation to the Foote Creek Rim Archaeological District 

in southern Wyoming. After careful consideration, the BLM determined that the route least likely to impact 

historic properties was the proposed route that follows previously disturbed lands within an existing designated 

utility corridor. Other requests made by the tribes included the presence of tribal monitors during construction, 

having the tribes conduct their own surveys prior to construction, and release of all cultural resource data 

pertaining to the project. The BLM and tribes are working cooperatively to develop a data share agreement to 

facilitate release of pertinent cultural resource data. Additional concerns discussed with the tribes included 

what laws each state has for protection of burials on private and state lands, mitigation of potential impacts, 

and treatment of inadvertent discoveries. 

Potential impacts to NRHP-eligible cultural resources, TCPs, or places of cultural, traditional, or religious 

importance to the tribe as a result of the Proposed Action, as well as measures to avoid or mitigate potential 

adverse effects to these resources, would be the same as those described in Section 4.9. 

Native American consultation regarding potential impacts to NRHP-eligible cultural resources, TCPs, or places 

of cultural, traditional, or religious importance currently is taking place between the BLM Rawlins Field Office 

and tribal representatives. No surface disturbance would occur within or immediately adjacent to the boundary 

of a potentially NRHP-eligible property or place of tribal importance without consultation with interested tribes 

as required by law. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Potential impacts to NRHP-eligible cultural resources, TCPs, or places of cultural, traditional, or religious 

importance to the tribe as a result of the Proposed Action would be the same as those described in 

Section 4.9. 

The BLM intends to continue consultation throughout the environmental review and construction phase of the 

Proposed Action. Renewed contacts with some or all of the tribes may result from unanticipated discoveries. 

4.10-1
Operation Phase 

Issues 

• Issues would be related to maintenance activities and would be similar to those identified for

construction. 

Analysis 

Maintenance activities would result in localized impacts that would be dispersed along the entire proposed 

pipeline route. Maintenance activities would occur within areas previously disturbed by construction. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Potential impacts to identified NRHP-eligible sites, TCPs, or places of traditional, cultural, or religious 

importance to the tribes as a result of the Proposed Action would be the same as those described in 

Section 4.9. 

The BLM intends to continue consultation throughout the environmental review and construction phase of the 

project. Renewed contacts with some or all of the tribes may result from unanticipated discoveries. 

4.10.2 No Action Alternative 

Under the No Action Alternative, the proposed project would not be constructed. As a result, none of the 

potential impacts to NRHP-eligible cultural resources, TCPs, or places of traditional, cultural, or religious 

importance to the tribes as identified for the Proposed Action would occur. 

4.10.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

If the Southern Energy Corridor – Copper Ridge Bypass Alternative were chosen, Native American 

consultation would follow the same protocol as the Proposed Action. Potential impacts to NRHP-eligible sites, 

TCPs, or places of traditional, cultural, or religious importance to the tribes, and measures to avoid or mitigate 

potential impacts, would be addressed as described above for the Proposed Action. 

4.10-2
4.11 Social and Economic Conditions 

4.11.1 Proposed Action 

4.11.1.1 Population, Employment, and Income 

Construction Phase 

Issues 

• Changes in local population and employment during construction. 

• Monetary compensation for easement and damages to land and property. 

Analysis 

Overland Pass proposes to begin construction in October 2007. Construction would last about 6 months and is 

anticipated to be complete with the pipeline in service by the second quarter of 2008. Overland Pass 

anticipates a peak workforce of approximately 1,300 to 1,500 construction personnel consisting of Overland 

Pass employees, contractor employees, construction inspection staff, and environmental inspection staff. The 

proposed pipeline is planned to be built in five spreads, with construction activity occurring simultaneously in 

each spread. Overland Pass anticipates 200 to 300 construction and inspection personnel associated with 

each spread. The workforce needed to construct the aboveground facilities within each spread are included in 

these estimates. The construction of the potential future pump station at WaKeeney would require an 

additional 20 to 28 workers. During construction, personnel would work during daylight hours, 6 to 7 days per 

week depending on schedule constraints. Table 4.11-1 outlines Overland Pass’ proposed construction 

schedule and workforce requirements by spread for the proposed pipeline route. 

Table 4.11-1 Pipeline Construction Workforce 

Spread 

Number RP Range 

Associated Aboveground 

Facilities Counties / States 

Estimated 

Workforce 

1 0.0 – 147 1 Pump Station (Echo Springs) 

2 Meter Stations (Opal and Echo 

Springs) 

Lincoln, Sweetwater, and Carbon 

counties, Wyoming 

300 

2 147 - 281 1 Pump Station (Laramie) 

1 Meter Station (Laramie) 

Sweetwater, Carbon, and Albany 

counties, Wyoming 

300 

3 281 – 438 NA Albany and Laramie counties, 

Wyoming 

Larimer, Weld, Morgan, Logan, and 

Washington counties, Colorado 

300 

4 438 – 591 1 Meter Station (Washington 

County) 

Washington and Yuma counties, 

Colorado 

Cheyenne, Rawlins, Thomas, and 

Sheridan counties, Kansas 

200 

5 591 – 749.4 3 Meter Stations (WaKeeney, 

Bushton, and Conway) 

Sheridan, Gove, Trego, Ellis, 

Russell, Barton, Ellsworth, Rice, and 

McPherson counties, Kansas 

200 

Potential 

Future 

606.0 1 Pump Station (WaKeeney) Sheridan County, Kansas 20 to 28 

Overland Pass, through its construction contractors and subcontractors, would attempt to hire temporary 

construction staff from the local population, if the local population offers skilled workers in fields related to 

pipeline construction. At peak workforce, Overland Pass anticipates that up to approximately 20 percent of the 

4.11-1 
total construction workforce could be hired locally (currently residing in Wyoming, Colorado, and Kansas). The 

remaining portion of the workforce (approximately 80 percent) would include non-local personnel. Based on 

the specialized nature of the position, environmental inspection staff would most likely consist entirely of 

non-local employees. 

The Overland Pass Pipeline would be constructed in predominantly rural and sparsely populated areas. The 

proposed pipeline route would cross approximately 124 miles of federal land, which represents approximately 

16 percent of the total land affected by the project. Overland Pass expects the impacts to socioeconomic 

resources along the proposed pipeline route to be similar on federally owned land as on non-federal land. 

Therefore, Overland Pass’ proposed mitigation measures for socioeconomic resources would be the same, 

regardless of land ownership. 

Overland Pass would acquire pipeline ROW easements from landowners and provide landowners with 

monetary compensation for the conveyance of those easements. Agreements between Overland Pass and the 

landowner would specify compensation for damage to property during construction, loss of use during 

construction, loss of renewable and nonrenewable or other resources, and allowable uses of the permanent 

ROW after construction. If an easement could not be negotiated with the landowner, the property could be 

condemned. In this case, the property owner would still be compensated by Overland Pass, but the amount of 

compensation would be determined by the courts. Overland Pass has stated that they would make every effort 

to negotiate in good faith to avoid using this authority and would condemn only as a last resort. 

The effect that a pipeline easement may have on property values has been factored into the negotiations 

between the parties during the easement acquisition process. The easement acquisition process is designed 

to provide fair compensation to the landowner for the right to use the property for initial pipeline construction 

and subsequent operation and maintenance. Appraisal methods used to value land are based on objective 

characteristics of the property and any improvements. The impact a pipeline could have on the value of a tract 

of land depends on many factors, including the size of the tract, the values of adjacent properties, the 

presence of other utilities, the current value of the land, and the current land use. Because approximately 

83 percent of the proposed pipeline route would parallel existing pipelines corridors, construction of the 

proposed pipeline is not expected to change the general use of the land. On tracts proposed to be crossed 

where pipelines do not currently exist however, the terms and conditions of the easement would preclude 

construction of aboveground structures on the permanent ROW for safety as well as maintenance purposes. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Construction of the proposed pipeline and ancillary facilities would temporarily increase the populations of the 

communities in the vicinity of the project by an average of 200 to 300 people per spread. Additionally, 

landowners would be compensated for the temporary loss of the use of their land during construction as well 

as for damages caused during construction. 

Operation Phase 

Issues 

• Changes in local population and employment during operations. 

Analysis 

Overland Pass estimates that 5 to 20 permanent employees would be required to oversee the operation and 

maintenance of the pipeline, including the pumping stations. These employees would most likely be non-local, 

as they would have specialized responsibilities or have current employment with Overland Pass. No additional 

4.11-2
personnel would be hired to operate and maintain the pumping stations as these facilities would be 

constructed to operate automatically. Any specific operation and maintenance task that could not be 

completed by the existing staff would be completed on a contractual and as-need basis. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

If approved, Overland Pass would obtain pipeline ROW easements from landowners in return for monetary 

compensation. Compensation would be based on fair market value of the land. Landowners may negotiate for 

the loss of use of their property, such as the reimbursement of crops lost due to construction activities. 

Because landowners would be compensated for the value of their property, no long-term impacts are 

anticipated. 

4.11.1.2 Infrastructure 

Construction Phase 

Issues 

• Increased demands on local infrastructure (emergency and fire protection services, hospitals, rental 

housing) during construction. 

Analysis 

Overland Pass’ construction workforce is described in Section 4.11.1.1. Approximately 80 percent of the 

workforce would be non-local. Due to the relatively short period of construction activity in any given area, it is 

anticipated that most non-local workers would not be accompanied by their families during their work tenure. 

Consequently, it is expected that most project workers would use temporary housing, such as hotels/motel, RV 

parks, and campgrounds. Some workers likely would rent furnished apartments and homes, due to the 

constrained availability of other accommodations, though this is generally less preferable because landlords 

and property management companies prefer extended term commitments. Most of the temporary workers 

would seek housing in the more populated, service-oriented towns located within a reasonable commuting 

distance to the work site. As the more convenient options fill, workers would seek alternatives, driving further, 

looking at smaller communities, even using campgrounds in nearby parks, which typically have limits on the 

length of occupancy. Furthermore, some individuals may desire to relocate during the term of the project as 

the active construction area in each spread moves along the proposed pipeline route. The net effect of these 

factors is that the temporary housing demand would be dynamic. 

Considering the various types of temporary housing available according to the year 2000 statistics provided, it 

appears likely that the local housing market would be able to handle the influx of temporary workers during 

construction for the proposed project for some of the proposed pipeline route, but in the more rural areas 

(especially along Spreads 4 and 5), it would be more difficult for local housing markets to fill the temporary 

housing needs due to the more limited availability of temporary housing in close proximity to construction work 

sites. Construction workers in these areas likely would drive further to find housing in nearby small towns or 

rely more heavily on RV parks and campgrounds. 

Caution should be taken in relying too heavily on housing data from the year 2000 census as a basis for 

analysis, particularly in the areas along the proposed pipeline route where the cumulative impacts of the 

energy boom has heavily impacted the region, and the housing situation likely has changed significantly in the 

past six years. Housing values, rents, and camping rates have risen dramatically in the region in recent years, 

particularly along the I-80 corridor through Wyoming and in Larimer and Weld counties in Colorado. It is likely 

that many of the more rural areas and/or those areas further from major interstate highways (e.g., areas along 

4.11-3
Spread 4 and some of Spread 5) have not seen the investment in new construction of rental units and 

hotels/motels necessary to accommodate the multiple pipeline construction crews working in the area because 

the demand for such accommodations is seen as short-term; once the energy boom is over, the demand for 

such facilities would drop significantly. 

Other construction-related impacts on local services would include increased demand for emergency services 

and medical care, local police assistance during construction at road crossings to facilitate traffic flow, and 

permits for vehicle load and width limits. In general, the degree of impact on local services would vary from 

community-to-community, depending on the number of non-local workers and accompanying family members 

that temporarily reside in each community, the duration of their stay, and the size of the community. Although 

these factors are too indeterminate and variable to accurately predict the magnitude of impact, the effects 

would be short-term. 

In the more remote locations along the proposed pipeline route, such as southern Wyoming and northern 

Colorado, where the nearest trauma center may be as far as 30 to 50 miles away, response times to highway 

or construction-related accidents could be lengthy given communication, dispatch, and travel time 

considerations. Overland Pass has developed an on-site ERP to identify emergency response personnel and 

the logical sequence of actions to be taken in the event of an emergency during construction and operation of 

the proposed pipeline project. Overland Pass has committed to working with the local law enforcement, fire 

departments, and emergency medical services to coordinate effective emergency response. 

Additional Mitigation 

No mitigation is proposed based on understanding of current conditions. 

Conclusion 

There would be a temporary increase in local housing demand due to the construction of the project. Effects 

would be localized as construction crews moved along the length of each construction spread. 

Operation Phase 

Issues 

• Increased demand on local infrastructure during operations. 

Analysis 

Overland Pass estimates that 5 to 20 permanent employees would be required to oversee the operation and 

maintenance of the pipeline, including the pumping stations. These employees most likely would be non-local, 

as they would have specialized responsibilities or have current employment with Overland Pass. No additional 

personnel would be hired to operate and maintain the pumping stations as these facilities would be 

constructed to operate automatically. Any specific operation and maintenance task that could not be 

completed by the existing staff would be completed on a contractual and as-need basis. 

The limited number of permanent employees associated with the proposed project would have little or no 

impact on the long-term housing market and negligible long-term impacts on public services. 

Additional Mitigation 

No additional mitigation was identified. 

4.11-4
Conclusion 

No impacts to local infrastructure, including housing, are anticipated during operations due to the small number 

of permanent employees needed to operate the pipeline. 

4.11.1.3 Fiscal Relationships 

Construction Phase 

Issues 

• Short-term fiscal benefits (local purchases and sales taxes). 

• Long-term fiscal benefits (payroll taxes). 

Analysis 

Taxes that may apply, other than property taxes levied by various state, county, or local taxing jurisdictions, 

would include taxes on gross receipts from the sales of goods and services. These taxes and fees vary by 

region or locality and would be received only during the construction period (5 to 6 months). Additionally, 

Overland Pass would make local materials purchases, and pay sales tax for the lease and/or rental of office 

space, construction equipment, and the storage space for construction equipment. 

Construction field offices would include, but not be limited to, the four ROW offices located in Green River and 

Cheyenne, Wyoming; Sterling, Colorado; and Hays, Kansas. Each ROW office would employ between 5 and 

10 persons and operate until the end of the project. 

Overland Pass estimates that local purchases made by personnel associated with the construction of the 

project primarily would include consumables, fuel, and miscellaneous construction-related materials 

(e.g., office supplies). The costs estimated for the entire project related to materials would be: 

• Fuel costs (diesel fuel and gasoline for equipment): 

− Diesel fuel = $5.2 million 

− Gasoline = $1.7 million 

• Miscellaneous lumber, consumables, and office supplies = $12.2 million 

Construction personnel would be lodged locally during construction of the project. Based on the estimated 

workforce and duration of the construction period, Overland Pass estimates that approximately $12.2 million 

would be spent locally on lodging, including RV parks, and food, including restaurants (NRG 2006). 

Payroll taxes also would be collected from the workers employed on the project. Overland Pass anticipates 

that total payroll for temporary employees on the project would be $43.3 million (approximately $17.6 million in 

Wyoming, $10.4 million in Colorado, and $15.3 million in Kansas). This would temporarily increase the tax 

revenue for the states; however, on a state-wide basis, the increase is anticipated to be minimal. Payroll taxes 

from the permanent employees would comparatively have no effect on state, county, or local tax revenues. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

The construction of the project would provide monetary benefits to local economies through employment, local 

purchases, lodging, payrolls, and sales taxes. 

4.11-5
Operation Phase 

Issues 

• Long-term fiscal benefits (property taxes). 

Analysis 

Overland Pass would be required to pay property and ad valorem1

 taxes to the state governments of 

Wyoming, Colorado, and Kansas. The states would then distribute those payments to counties based upon the 

number of miles crossed by the proposed pipeline route in each county. For the first year of operation, 

Overland Pass estimates that $8.4 million ($2.2 million in Wyoming, $2.6 million in Colorado, and $3.6 million 

in Kansas) would be generated in property and ad valorem local taxes2. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Operation of the Overland Pass Pipeline would result in long-term fiscal benefits totaling $10 million in the first 

year of operation. 

4.11.1.4 Environmental Justice 

Construction Phase 

Issues 

• Potential for disproportionate project effects on low-income or minority populations. 

Analysis 

Based on a review of the minority population and income status of communities crossed by and in the 

proximity of the proposed pipeline route, it has been determined that Green River, Rawlins, Laramie, and Little 

America, Wyoming, have the most significantly high minority populations on the proposed pipeline route. The 

minority populations of concern in Green River, Rawlins, and Little America are Hispanic. The Hispanic 

populations account for 1,204 people in Green River (10.2 percent of the total population) and 1,793 people in 

Rawlins (21.0 percent of the total population). The total population of Little America, Wyoming, is significantly 

smaller than these other two cities (only 56 people), but 25 of these (or 44.6 percent) are Hispanic. The 

minority population of concern in Laramie is Asian or Pacific Islander with 2.0 percent of the total population or 

544 out of a total population of 27,204. All other minority populations identified along the proposed pipeline 

route based on the percentage of the population when compared to the population in the state, where not 

significant when raw numbers were considered. For example, Eckley, Colorado, was identified as having a 

Native American minority population 1.5 times greater than that of the surrounding area (the State of 

Colorado); however, when looking at the overall population, this percentage only accounts for 5 people in a 

total population of 278. 

1 Ad Valorem and Property Taxes are synonyms and can be used interchangeably. Ad Valorem is Latin meaning “According To Value” 

which is the basis of property tax calculations. An Ad Valorem tax is based on the principle that the amount of tax paid is determined by 

the fair market value of the Real and Personal Property owned. This valuation is performed by state or local (county) government 

officials, depending on the type of entity being taxed. The tax collection process is performed on the local (county) level. 

2 Colorado construction work in progress is 100 percent tax exempt until the project becomes operational. Materials, supplies and inventory 

are granted a permanent 100 percent property tax exempt status. 

4.11-6
Many of the communities crossed or in the proximity of the proposed pipeline route have been identified as 

having low income populations when compared to the percent of families below the poverty level in the 

respective state, particularly in Colorado (all 3 communities) and Kansas (8 of 10 communities). For each of 

the low income communities in Colorado and Kansas, the median family income is at least $10,000 less than 

that of their respective states ($55,883 for Colorado and $49,624 for Kansas). Conversely, the median family 

incomes in most of the communities crossed by or in the proximity of the proposed pipeline route in Wyoming 

are very near (within $4,000) or above the median family income of the state ($45,685). The one community in 

Wyoming where this is not the case is Little America which has a median family income of only $18,750, but 

the percent of the population below the poverty level for this community is 0 percent according to the 

2000 Census statistics. 

Additional Mitigation 

None proposed based on understanding of current conditions. 

Conclusion 

Although several of the counties that would be affected by the project have higher percentages of minorities 

and higher poverty levels than the states in which they are located, the potential adverse impacts that could be 

associated with construction of the pipeline would not disproportionately affect minorities or those living below 

the poverty level. The proposed project would be expected to create economic benefits for local communities, 

regardless of race, by generating employment opportunities and local expenditures by workers. Completion of 

the project also would result in an increase of state and local property tax revenues that would benefit local 

communities. 

Operation Phase 

Issues 

• Issues are the same as construction. 

Analysis 

No additional analysis necessary. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

The operation of the pipeline would not disproportionally affect areas containing minorities or those living 

below the poverty level. 

4.11.2 No Action Alternative 

Should the No Action Alternative be selected for this project, Overland Pass would not need to acquire pipeline 

ROW easements. Thus, landowners would not receive monetary compensation for the conveyance of those 

easements. Additionally, there would be no potential for damage to property during construction, no loss of use 

of land during construction, and no potential for loss of renewable and nonrenewable or other resources due to 

the construction of the proposed pipeline. 

Under the No Action Alternative, there would be no influx of approximately 1,300 to 1,500 construction 

personnel. Therefore, there would be no increase in the demand for housing or emergency police and/or 

medical services. Additionally, there would be no impact on local traffic during construction. 

4.11-7
Should the No Action Alternative be selected, there would be no increase in short- or long-term fiscal gains by 

states, counties, and local governments from the payment of property taxes, payroll taxes, or taxes on gross 

receipts from the sales of goods and services. Minimally this would include the loss of approximately: 

• $8.4 million or more annually in property taxes ($2.2 million in Wyoming, $2.6 million in Colorado, and 

$3.6 million in Kansas). 

• $43.3 million in payroll taxes ($17.6 million in Wyoming, $10.4 million in Colorado, and $15.3 million in 

Kansas). 

• $19.1 million in sales (and associated sales taxes) of materials and supplies during construction 

(miscellaneous lumber, consumables, and office supplies). 

• $12.2 million (and associated taxes) on lodging, including RV parks, and food, including restaurants. 

Under the No Action Alternative, there would be no impact on minority or low-income populations in 

communities along the proposed pipeline route. 

4.11.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

The Southern Energy Corridor – Copper Ridge Bypass Alternative would direct the pipeline route in an area of 

Sweetwater County, Wyoming, that does not currently cross or is within the proximity of any communities. 

Consequently, any socioeconomic impacts for the Proposed Action with the Southern Energy Corridor – 

Copper Ridge Bypass Alternative would be the same as those for the Proposed Action. 

4.11-8
4.12 Public Health and Safety 

4.12.1 Proposed Action 

4.12.1.1 Hazardous Materials and Wastes 

Construction Phase 

Issues 

• Storage and handling of hazardous materials. 

• Previously contaminated sites. 

Analysis 

Overland Pass would dispose of construction wastes in accordance with Overland Pass’ SPCC Plan 

(Overland Pass 2007). Construction debris would not be placed in or adjacent to waterways and construction 

trash would be removed from the ROW each day. Overland Pass would comply with applicable state and local 

waste disposal, sanitary sewer, or septic system regulations. 

Soil contamination along the proposed pipeline route may result from at least two sources: material spills 

during construction and trench excavation through pre-existing contaminated areas. A variety of potentially 

hazardous chemicals associated with equipment operation, welding, and coating of pipe would be used during 

construction. Impacts from spills would typically be minor because of the low frequency and volumes of these 

occurrences. 

Pipeline construction would necessitate the storage and use of vehicle and equipment fuels, lubricants, and 

hazardous materials. Overland Pass’ SPCC Plan addresses procedures to ensure the proper handling and 

storage of these materials. The plan also addresses inadvertent spills resulting from construction of the 

pipeline and lists federal and state emergency notification personnel that would be contacted in the unlikely 

event the project encounters previously unidentified contamination. Should a spill occur, Overland Pass would 

clean it up in accordance with its SPCC Plan. 

The proposed pipeline would not intercept any known areas of soil or groundwater contamination. A review of 

USEPA Region 8 Superfund Site Status Summaries for Wyoming and Colorado and Region 7 Site Status 

Summaries for Kansas as well as the CERCLIS database shows no Superfund sites intersected by the 

proposed pipeline route (USEPA 2006b). One site listed in the CERCLIS Database, the Pole Mountain Former 

Target and Maneuver Area, is currently managed by the USFS as a recreational area and is located 

approximately 350 feet from the proposed centerline at approximate RP 294.6. This site is not listed on the 

NPL, but could potentially contain unexploded munitions. According to USFS personnel the project should not 

impact the live munitions associated with the site on the south side of I-80, as the actual firing range was sited 

several miles to the north east along Highway 30 (north of I-80). 

Overland Pass would cross the impaired waterbodies located in Wyoming and Kansas (Table 3.5-3) using the 

conventional open-cut method and adhering to the measures contained in its Construction, Reclamation, and 

Revegetation Plan (Appendix C). These measures include, but are not limited to, installing and maintaining 

sediment barriers to prevent silt-laden water from entering wetlands and waterbodies, restoring original 

contours, and revegetating disturbed areas. Overland Pass would cross the South Platte River, an impaired 

waterbody, using the HDD method. 

The proposed project could cross areas where groundwater quality has been impacted, but which were not 

identified in the regulatory review or which are not otherwise known. Because excavations associated with the 

project would be generally less than 8 feet deep, the potential to encounter groundwater in the pipeline trench 

4.12-1
is low, except where the pipeline crosses or approaches surface water bodies. Therefore, the potential to 

encounter pre-existing contaminated groundwater is low. 

If contaminated or suspect soils (e.g., hydrocarbon contamination) were identified during trenching operations, 

Overland Pass would suspend work in the area of the suspected contamination until the type and extent of the 

contamination was determined. The type and extent of contamination, the responsible party, and local, state, 

and federal regulations would determine the appropriate cleanup method(s) for these areas. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Contamination from spills or leaks of fuels, lubricants, coolants, and solvents from construction equipment 

could occur, but the impacts typically would be minor due to the low frequency and volumes of these 

occurrences. There are currently no known contaminated sites crossed by the proposed pipeline route or 

affected by aboveground facilities. If spills or unanticipated contaminated soils were encountered, Overland 

Pass would address the issue by adhering to the procedures identified in its SPCC Plan. 

Operation Phase 

Issues 

• Potential for pipeline leak, fire, or explosion. 

Analysis 

Potential for Leaks 

The transportation of NGL by pipeline involves some risk to the public in the event of an accident and 

subsequent release of NGLs. NGL consists primarily of ethane, butane, isobutene, and propane. These 

compounds are liquid when pressurized, but would immediately volatize if released from the pipeline. These 

compounds are relatively non-toxic, but are classified as simple asphyxiates, possessing a slight inhalation 

hazard. If breathed in high concentration, oxygen deficiency can result in serious injury or death. NGLs are 

highly flammable but require an ignition source to ignite. NGLs released into the environment would rapidly 

disperse in the air. 

The USDOT classifies NGL as a hazardous liquid. The pipeline and aboveground facilities associated with the 

pipeline must be designed, constructed, operated, and maintained in accordance with the USDOT Minimum 

Federal Safety Standards in 49 CFR Part 195. The regulations are intended to ensure adequate protection for 

the public and to prevent pipeline and facility accidents and failures. Part 195 specifies material selection and 

qualification, minimum design requirements, and protection from internal, external, and atmospheric corrosion. 

The USDOT Minimum Federal Safety Standards in 49 CFR Part 195 are intended to ensure adequate 

protection for the public and to prevent hazardous liquid pipeline and associated facility accidents and failures. 

Part 195 specifies material selection and qualification, minimum design requirements, and protection from 

internal, external, and atmospheric corrosion. Overland Pass would design, construct, and operate the pipeline 

in accordance to federal regulations. Important features to ensure the safe operation of the pipeline include: 

• Hydrostatic testing verify the pipeline’s integrity prior to operations; 

• Corrosion protection by using high integrity FBE coating and cathodic protection; 

• Internal inspection of the pipe using “smart pigs” designed to detect irregularities on the internal and 

external surfaces of the pipe; 

4.12-2
• SCADA system to continuously monitor the pipeline and the pressure of its contents; 

• Participation in state “one call” programs; 

• Use of remotely activated valves at key locations; and 

• Thicker wall pipe used in residential areas. 

To enhance public safety, Overland Pass has committed to installing heavier walled pipe at locations where 

existing cities and multiple homes are within 0.5 mile of the proposed pipeline (Table 4.12-1). The heavy-wall 

pipe section would extend 0.5 mile beyond the populated area. 

Table 4.12-1 Locations Where Heavier Wall Pipe Would Be Installed 

Location RP Distance 

Storage / industrial site near Wamsutter, 

Wyoming 

RP 138.2 to RP 139.2 1.0 mile 

Laramie, Wyoming Area RP 275.2 to RP 277.3 2.1 miles 

Laramie, Wyoming Area RP 281.0 end of highway 

crossing to RP 282.0 

1.0 mile 

Raymer, Colorado RP 386.6 to RP 387.9 1.3 miles 

WaKeeney, Kansas RP 623.8 to RP 626.6 2.8 miles 

Susank, Kansas RP 692.0 to RP 693.0 1.0 mile 

Mitchell, Kansas RP 733.9 to RP 735.0 1.1 miles 

Upon obtaining the necessary permits for its project, finalizing the proposed pipeline route, and prior to 

construction, Overland Pass would determine if its proposed pipeline could affect these locations. If 

appropriate, these locations would be incorporated into an Integrity Management Plan specific to Overland 

Pass as required by the USDOT to ensure pipeline safety. 

While pipelines are one of the safest means of transporting large volumes of NGLs (Section 2.8.4.1), pipeline 

accidents can occur. Based on historical accident data gathered by the OPS (2006), leading cause of pipeline 

incidents was caused by outside forces, primarily the damage caused by mechanical equipment, such as 

bulldozers and backhoes. To minimize the hazards posed by outside forces, the pipeline would be constructed 

in rural areas and Overland Pass would participate in the “one call” system. Although some localized areas of 

geological instability (e.g., landslides) occur along the proposed pipeline route, modern pipelines are fairly 

robust to these types of stressors and geological hazards are not expected to pose a major threat to the 

pipeline. The pipeline would routinely be inspected and if outside force damage were suspected (whether 

through outside force or ground movement), internal inspection tools (i.e., “geo pigs” and “smart pigs”) would 

be used to verify the pipeline’s integrity. 

Corrosion is another major factor that contributes to pipeline leaks. To minimize corrosion, the pipeline would 

be constructed with FBE coated pipe and cathodic protection would be installed. As required by federal 

regulations, the pipeline ROW would be routinely inspected with internal inspection tools to identify anomalies 

such as dents and scrapes caused by outside forces, deformities caused by earth movement, and internal and 

external corrosion. Overland Pass would ensure pipeline integrity and public safety by repairing pipeline 

damage as required by federal regulations. 

Overland Pass would use SCADA and other monitoring systems to continuously monitor the pipeline for 

indications of abnormal events. In the unlikely event of a pipeline accident, Overland Pass would be able to 

remotely activate its motorized block valves, thereby isolating the affected segment within minutes of 

detection. Overland Pass would have local personnel available to respond immediately to an emergency and 

expects that these first responders would be on-site within a 1-hour timeframe. 

4.12-3
Prior to operating the pipeline, Overland Pass would develop an ERP that identifies emergency personnel and 

the logical sequence of actions that would be taken in the event of an emergency involving the Overland Pass 

system facilities. The ERP would establish emergency shutdown procedures, communication coordination, 

and clean-up responsibility to minimize hazards that could result from a NGL pipeline emergency, such as 

liquid leaks, explosions, and fires. Key elements of the plan would include procedures for: 

• Receiving, identifying, and classifying emergency events, gas leakage, fires, explosions, and natural 

disasters; 

• Establishing and maintaining communications with local fire, police, and public officials, and 

coordinating emergency response; 

• Emergency shutdown of systems and safe restoration of service; 

• Making personnel, equipment, tools, and materials available at the scene of an emergency; and 

• Protecting people first and then property, and making them safe from actual or potential hazards. 

The ERP would include incident and emergency notification lists; emergency communication procedures; 

emergency preparedness, such as training topics; and emergency response procedures associated with 

natural and construction-related hazards. 

As discussed in Appendix L, release of NGLs into the environment does not pose a major threat to water 

quality or soil contamination. While the probability of an accident is low, there is the potential for a fire if an 

accident resulted in the release of NGL from the pipeline. Overland Pass will develop an Integrity Management 

Plan to minimize environmental impacts including those specific to HCAs occurring within the proposed project 

area. 

Fire, Explosion, Injuries, and Fatalities 

NGLs are flammable liquids. While the probability of an accident is low, there is the potential for a fire. Based 

on OPS historical data (2005), less than 20 percent of NGL pipeline accidents have resulted in fires and 

7 percent have resulted in explosions. Fires and explosions could result in property damage, injuries, and 

fatalities. The OPS data show an overall decreasing trend in the total number of accidents related to 

hazardous liquid pipelines since 1990 (OPS 2005). 

As part of its safety program, Overland Pass would consult with local responders regarding the potential 

hazards posed by the NGL pipeline; however, NGLs do not pose a unique fire hazard and would not require 

specialized training. If a fire or explosion were to occur, Overland Pass’ local emergency responders and local 

fire departments likely would be among the first to respond. In many cases, firefighters may elect to allow the 

fire to extinguish itself, focusing on containment of the fire and protection of nearby property. 

Additional Mitigation 

SAFETY-1: In order to comply with BLM regulations at 43 CFR 2886.10, prior to operating the pipeline, 

Overland Pass must certify to BLM in writing that it has constructed and tested the pipeline in 

accordance with the terms of the ROW grant and it is in compliance with the plans, 

specifications, and federal and state laws and regulations concerning the pipeline. 

Conclusion 

Overland Pass would comply with these federal pipeline safety regulations, including 49 CFR Part 195 and 

43 CFR 2886.10. Compliance with federal pipeline safety regulations would ensure that the Overland Pass 

pipeline was designed, constructed, operated, and maintained in a safe manner. 

The potential for a pipeline incident with the potential for injuries, fires, and explosions along the pipeline would 

be low. Overland Pass’ accident prevention program includes participation in one-call programs and corrosion 

4.12-4
protection measures. Use of the SCADA system and other monitoring capabilities would help to rapidly identify 

pipeline problems and minimize the potential for impacts. Overland Pass would finalize their ERP prior to 

operations. This ERP would define the steps to be taken in the event of a release, so that impacts to humans 

and the environment would be minimized. Additional mitigation at sensitive resource areas would not be 

necessary because of the rapid volatilization of NGLs. 

4.12.1.2 Emergency Response 

Construction Phase 

Issues 

• Worker safety. 

Analysis 

The hazards associated with pipeline construction would be typical of that on most construction sites where 

heavy equipment is operated. Hazards could include driving hazards (including winter conditions and big game 

collisions), explosives, fires, and natural disasters. 

The potential for construction accidents was exemplified by a recent incident in Wyoming. On November 11, 

2006, an existing 36-inch natural gas pipeline owned by Wyoming Interstate Company was struck by a 

bulldozer operated by construction crews building the Kinder Morgan Rockies Express/Entrega Natural Gas 

Pipeline. The incident occurred outside of Cheyenne, Wyoming, and the resulting explosion killed one 

construction worker. The cause of the accident is still under investigation. 

Accidents such as this occasionally occur, though most do not result in fatalities. As discussed in 

Section 4.12.1.1, third-party excavation damage (e.g., the cause of the Rockies Express/Entrega pipeline 

accident) is a leading cause of pipeline incidents. To prevent these types of accidents, pipeline operators 

participate in accident prevention programs, such as the one call programs, which identifies the location of 

underground utilities. The ongoing investigation will determine why the Rockies Express/Entrega pipeline was 

struck and whether the one call system was correctly implemented. 

To minimize risk to workers, Overland Pass would follow pipeline construction industry standard practices and 

BMPs to mitigate potential construction-related incidents. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Adherence to Overland Pass’ POD, pipeline construction industry standard practices, and BMPs would 

minimize potential construction-related incidents. 

Operation Phase 

Issues 

• Emergency response to a pipeline leak, fire, or explosion. 

4.12-5
Analysis 

Overland Pass would meet or exceed federal pipeline safety requirements (49 CFR Part 195), and these 

procedures and programs would increase public safety, maintain the integrity of the pipeline, and minimize the 

potential pipeline incidents related to third-party encroachments. 

As discussed above, Overland Pass’ ERP establishes initial written emergency shutdown procedures, 

communication coordination, and clean-up responsibility to minimize hazards, such as liquid leaks, explosions, 

and fires. Overland Pass would provide the appropriate training to local emergency service personnel before 

the pipeline is placed in service. 

Once the pipeline is constructed and pipeline operations commence, Overland Pass intends to re-define its 

organizational management structure outlined in the ERP and amend the plan so that it meets the minimum 

federal safety requirements. 

Additional Mitigation 

No additional mitigation was identified. 

Conclusion 

Overland Pass anticipates a 1-hour response time in most instances with the assistance of local emergency 

response teams in the surrounding communities. Releases would be quickly contained by sectionalized block 

valves. NGLs would quickly evaporate and dissipate into the atmosphere; however, any residual material 

would be cleaned up and the area remediated as soon as possible. The final ERP would identify the steps to 

be taken to protect health, property, and the environment. 

4.12.2 No Action Alternative 

If BLM rejects the project as proposed, the Proposed Action would not be constructed. Impacts to public safety 

would continue at current levels. 

Given the oil and gas development in the region, NGLs would still need to be transported from the region. 

Other pipelines that would transport NGLs to the Conway, Kansas, region would likely be of similar or greater 

length and, consequently, would have similar or greater impacts on public safety. Alternative transport 

methods (e.g., trucking or rail) would result in substantially greater impacts to public safety (Section 2.8.4). 

4.12.3 Southern Energy Corridor – Copper Ridge Bypass Alternative 

Impacts to public safety associated with this alternative would not be significantly different than for the 

Proposed Action. No HCAs have been identified along the Southern Energy Corridor – Copper Ridge Bypass 

Alternative. 

4.12-6