CHAPTER 2
 

Alternatives
 

CHAPTER 2: ALTERNATIVES
 

Introduction 

The Council on Environmental Quality regulations 

require an environmental impact statement (EIS) 

“rigorously explore and objectively evaluate all 

reasonable alternatives....” This chapter presents in 

detail the No Action Alternative (existing coal bed 

natural gas [CBNG] Management) and seven action 

alternatives for managing oil and gas resources— 

specifically CBNG exploration and production— 

throughout the Planning Area, which includes the 

Bureau of Land Management’s (BLM’s) Powder 

River and Billings Resource Management Plan 

(RMP) areas. Other alternatives were considered but 

eliminated without detailed analysis. A description of 

these alternatives and reasons for elimination are 

provided in the Alternatives Considered But Not 

Analyzed in Detail section. 

This chapter is presented in five sections: 

Alternatives Development, Alternatives Considered 

But Not Analyzed in Detail, Management Common 

to All Alternatives, Management Actions Specific to 

Each Alternative and Comparison of Impacts. 

Alternatives Development 

The purpose of developing and presenting 

alternatives is to allow the decision maker an 

opportunity to address and resolve issues recognized 

during the scoping process. Alternatives meet the 

purpose and need for doing the plan and balance 

ways to address different resource issues. The 

resolution of key issues forms the framework of an 

alternative, with the resolution of lesser issues 

included around the alternative’s central idea. This 

section describes how those key issues led to the 

development of the alternatives. The development of 

alternatives for this EIS centered on addressing 

regulatory issues in seven general areas: 

• Air quality 

• Coal mines 

• Coal bed methane 

• Hydrology 

• Realty 

• Indian trust resources 

• Environmental mitigation 

Although other relevant issues were considered, these 

key issues played a major role in defining the 

alternatives to be analyzed in detail. 

Air Quality and Climate 

Alternatives were developed by considering potential 

changes in ambient air quality from CBNG activities, 

such as reduced visibility, air quality emissions, dust 

emissions and harmful gases. Alternatives vary by 

limiting the number of wells connected to each 

compressor, the type of fuel required to power 

compressors (diesel, electric, or gas-fired) and 

whether noise suppression measures would be 

required. Potential air impacts, both project related 

and cumulative, were modeled for Alternatives A, B, 

C, D and E under the 2003 Final EIS. A new air 

quality model was conducted for this Final SEIS 

(FSEIS) to evaluate potential project and cumulative 

air impacts for Alternatives E, F and H. Potential air 

impacts for Alternative G were not modeled, as the 

only difference between Alternatives F and G is that 

Alternative G has 65 percent fewer wells. 

Following the Draft Supplemental Environmental 

Impact Statement (DSEIS, BLM 2006), a 

Supplemental Air Quality Analysis (SAQA, BLM 

2007) was prepared to augment the analysis 

conducted for the DSEIS. The SAQA provided 

additional information and analyses regarding the 

level of CBNG development with the potential to 

impact air quality within the Powder River and 

Billings RMP areas. It includes an analysis and 

comparison of the potential for CBNG development 

to impact air quality under different air quality 

emission rates under Alternative 

What has Changed in Chapter 2 

Since the DSEIS? 

Chapter 2 lists the alternatives development process and 

describes the features of each alternative in detail

include a general description of the Supplemental Air Quality 

Analysis, revisions to the preferred alternative and tables 2-2 

and 2-3, as well as edits and clarifications. The preferred 

alternative has been revised based on public comment and 

agency collaboration. The preferred alternative includes 

revised air and wildlife screens. Tables 2-2 and 2-3 were 

revised based on the changes to the preferred alternative 

Table 2-2 is a management comparison of alternatives for 

exploration and development of CBNG; table 2-3, compares 

impacts of alternatives. 

. Updates 

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CHAPTER 2 

Alternatives 

H, the preferred alternative. It also included a revised 

air quality screen that replaces the air quality impact 

screen from the DSEIS. The information contained 

within the Supplemental Air Quality Analysis 

expands on the air quality information presented in 

the DSEIS and the Air Quality Technical Support 

Document (BLM 2007). An Analysis of climate 

change has been added to the to the Air Quality and 

Climate sections of the FSEIS. Best management 

practices (BMPs) for controlling methane emissions 

(greenhouse gases) are identified as part of the BMPs 

available under the preferred alternative. 

Coal Mines 

The alternatives address buffer zone requirements 

around active coal mines, as well as the ability for 

adjacent or nearby coal companies to recover bonds 

and determine the effects on aquifer reconstruction. 

Alternatives also include CBNG water discharge 

affecting new coal mines, the effects on oil and gas 

development, loss of coal production resources from 

CBNG development, loss of methane resources 

because of venting and subsurface coal fires. 

Alternatives vary by the use of a buffer zone around 

active coal mines. 

Coal Bed Methane 

Restrictions on CBNG exploration and production 

activities were considered in developing the 

alternatives. Alternatives A through E vary by 

restrictions such as directional-drilling requirements; 

the number of coal seams produced per well bore and 

chronological coal seam development. Whether a 

Plan of Development (POD) is required in 

consultation with tribes, surface owners and other 

agencies is also addressed differently under each 

alternative. Other matters considered are drainage of 

methane from federal minerals by nonfederal wells; 

methane quantities; varying the amount of 

development based on the reasonably foreseeable 

development (RFD) range (low-high); the effects to 

groundwater from over-pumping water and the use of 

adaptive management. Alternatives F, G and H vary 

restrictions such as the number of federal producing 

CBNG wells based on ranges from the RFD, 

restricting the number of federal CBNG applications 

for permit to drill (APDs) that could be approved per 

year; varying the amount of development on a 

watershed-specific basis; use of adaptive 

management 

Hydrology 

Hydrology issues used in developing alternatives 

include inspection, treatment, storage and 

conveyance of CBNG-produced water. Short- and 

long-term effects on groundwater and surface water, 

impacts on water quality and water rights were 

considered. The alternatives differ by requirements 

for site-specific Water Management Plans, treatment, 

conveyance methods and the beneficial use of 

exploration and production water. In addition, 

alternatives F, G and H incorporate water screens that 

include potential limits on the volume of untreated 

water that can be discharged. Farmers, ranchers, 

irrigators, coal mines, light industry, transportation 

departments, local county governments and others 

could beneficially reuse production waters. 

Realty 

Realty matters center on requirements for right-ofway (ROW) corridors, powerline placement and use 

of or abandonment of roads from CBNG 

development. The alternatives vary by whether roads 

would be open to public use, closed and returned to a 

natural vegetative state, or maintained at the 

discretion of the surface owner. Other differences 

between the alternatives include requirements for 

buried powerlines, installation of raptor safety 

equipment and multiple utility corridor use. 

Indian Trust Resources 

The Crow Tribe of Indians and the Northern 

Cheyenne Tribe are located within the Planning Area 

for CBNG development and therefore, were given 

special consideration with regard to potential impacts 

from off-reservation operations. Issues considered 

include the potential drainage of Reservation 

groundwater and CBNG by off-reservation wells, 

impacts to sacred sites and resources, water rights, 

water quality preservation agreements, stress to 

reservation infrastructure, cultural sites and 

socioeconomic status. To address these issues, the 

use of a federal buffer zone or consultation zone, as 

well as monitoring requirements, were included in 

various alternatives. 

The Northern Cheyenne Tribe has proposed a series 

of mitigation measures, in which the BLM has 

incorporated into a table, a copy of which can be 

found in the Northern Cheyenne Mitigation 

Appendix attached to this EIS. The BLM has 

considered these measures for implementation and 

has developed corresponding requirements that are 

included in Alternatives E, F, G and H. 

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Environmental Mitigation 

Environmental mitigation measures to address 

resources were presented in the scoping comments. 

The mitigation measures have been incorporated into 

the management actions of the various alternatives. 

These include commercially harvesting trees within 

ROWs; implementation of high fire danger 

restrictions; road use enforcement; road placement 

restrictions; wellhead camouflage requirements; 

conducting wildlife surveys; and the use of early 

successional species along with appropriate early and 

late seral stage native species for revegetation. The 

environmental mitigation measures are applied to the 

various alternatives based on their general themes for 

either protection of existing resources, emphasis on 

CBNG development and phasing of CBNG 

development. 

Alternatives Considered 

But Not Analyzed in Detail 

The alternatives below were considered for resolving 

planning questions or issues, but were not analyzed in 

detail because of technical, legal, or other constraints. 

Leasing 

BLM oil and gas leasing decisions and lease 

stipulations, including those applicable to CBNG, 

were previously analyzed in the BLM 1992 Final Oil 

and Gas RMP/EIS Amendment (BLM 1992). Those 

decisions were approved in the project’s Record of 

Decision (ROD) published in February 1994. During 

that process, the public was invited and encouraged 

to participate. Analyzing new federal lease decisions 

such as closing federal areas of oil and gas estate in 

the Powder River and Billings RMP areas, are 

therefore beyond the scope of this plan. The existing 

lease stipulations approved in the 1994 ROD 

continue to be applicable to all CBNG development 

and have been included in Table MIN-5 of the 

Minerals Appendix. CBNG is part of the oil and gas 

estate. Existing oil and gas leases include the right to 

explore and develop CBNG. Issuing separate leases 

for conventional oil and gas and separate leases for 

CBNG would require a regulatory change. 

The purpose of this document is to analyze federal 

CBNG phased development in accordance with the 

U.S. District Court’s directive for supplementing the 

BLM 2003 Final Montana Statewide Oil and Gas EIS 

and Proposed Amendment of the Powder River and 

Billings RMPs (Statewide Document). The 

alternatives analyze different levels of producing 

CHAPTER 2
 

Alternatives
 

CBNG wells between the low range in Alternative A 

to the high range in alternatives E, F and H. The 

alternatives also analyze different mitigation 

measures or restrictions that BLM can impose as 

requirements with approved permits. In addition, 

Alternatives F, G and H analyze phased mechanisms 

that BLM can use to affect the pace and place of 

CBNG development on federal leases, as well as the 

density and intensity of cumulative CBNG 

development. Mitigation measures and a process to 

evaluate projects to determine if restrictions are 

necessary to alter the pace or place of federal 

development are included in alternatives F, G and H 

(the Preferred Alternative). The evaluation would be 

conducted during the permit review process and 

during the production phase. 

Bonding 

Establishment of bond amounts specifically for 

CBNG development activities that cover the full cost 

of CBNG development. This alternative is not 

analyzed in detail because the MBOGC and BLM 

regulations set minimum amounts of bonding 

required before approving drilling permits. The 

regulations allow agencies to raise the bond amount 

required depending on such factors as the number 

and type of wells, type and amount of reclamation 

necessary and operator history. Bond increases 

cannot exceed the total of estimated costs of plugging 

and reclamation, the amount of uncollected royalties 

due and monies owed because of outstanding 

violations. 

Omega Alternative 

The Omega Alternative to drill a large-diameter well 

through the coals and from the base of that shaft to 

directionally drill upward into the various coal seams 

in a circular pattern is an experimental technology 

not yet proven for CBNG. If this technology becomes 

viable for CBNG extraction in the future, further 

consideration would be given to it. 

Alternate Sources of Energy 

The purpose of this FSEIS is to consider federal 

CBNG phased development. Considering alternate 

sources of energy such as wind power and fuel cells 

is therefore beyond the scope of this FSEIS. 

Re-Injection of Produced Water 

into the Same Aquifer Alternative 

Re-injection of produced formation water is an 

accepted practice in conventional oil fields but its use 

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CHAPTER 2 

Alternatives 

in CBNG fields would be counterproductive if the 

produced water was re-injected or could migrate into 

the CBNG producing formation. In conventional oil 

fields, operators have re-injected produced water 

since the 1920s to help maintain reservoir energy and 

to increase ultimate production efficiency, or to move 

oil preferentially to producing wells. When produced 

water is re-injected, original reservoir pressures are 

maintained; this can significantly increase the 

percentage of original oil in place that is produced 

before the field’s economic limit is reached (Thomas 

et al. 1987). Re-injection can also sweep oil out of 

the reservoir toward producing wells in a waterflood, 

also increasing production efficiency. In these 

scenarios, water production is neither desired nor 

absolutely necessary; it is a nuisance that can be 

minimized with standard engineering practice. In the 

history of many oil fields, oil is produced water-free 

for months or even years before water is seen in 

producing wells. 

In CBNG production, formation water must be 

produced before reservoir pressures are sufficiently 

reduced for the adsorbed methane to be liberated. 

Water production is unavoidable and pre-requisite to 

CBNG production. As water is produced from the 

coal seam, the pressure in the seam is reduced. 

Research by the BLM’s Casper, Wyoming, Field 

Office suggests that methane production begins after 

20 percent of the virgin reservoir pressure is 

depleted; significant production does not begin until 

40 percent of the pressure is depleted (Crockett and 

Meyer 2001). Work by Jones et al. (1992) 

corroborates this relationship. If methane production 

is directly related to depletion of reservoir pressure, 

then re-injection of produced water within the 

confines of the CBNG field will directly result in the 

decrease of methane production. Re-injection of 

CBNG-produced water into the producing formation 

is not a reasonable option for management of 

produced water. When and if this technology 

becomes viable, a more detailed analysis would be 

conducted for further consideration. 

It would be reasonable to inject produced water into 

non-productive coal seams that were geologically 

separated from the CBNG field. Separation could be 

the result of faulting or erosion, isolating coals in the 

injection area even from stratigraphically equivalent 

productive coal seams in the CBNG field. Under 

Alternative B the injection of produced water into 

either non-productive coal seams or aquifers with 

water of lesser quality is analyzed. 

This type of injection results in preservation of the 

produced water resource, whether of high or low 

quality. The permit process could mitigate impacts to 

groundwater so that the quality of the injected water 

is matched to the quality of the formation water in the 

prospective injection zone. 

Recently there have been discussions suggesting the 

mandatory injection of all CBNG-produced water. In 

fact, a petition was forwarded to the Montana Board 

of Environmental Review (BER) for consideration of 

this topic. In preparation of this board debate, a report 

entitled the “Potential Effects to Ground Water 

Systems Resulting from Subsurface Injection of 

CBM Production Water” was drafted by the Montana 

Bureau of Mines and Geology (MBMG) (Wheaton 

and Reddish 2005). The report states that, overall, the 

approach of injecting water into Fort Union 

Formation aquifers of the Powder River Basin has 

not been widely tested. Areas where favorable 

conditions exist appear to be limited to approximately 

9 percent of the total area. Mandating injection does 

not mean it is technically feasible, regardless of 

economics. In some areas that have suitable aquifers, 

injection may be technically and economically 

feasible, as well as a means of conserving the water 

resource. Injection cannot, however, be regarded as 

appropriate in all settings. Further, mandated 

injection may force the use of the deeper Madison 

Group geologic formation that has water of lower 

quality than the CBNG produced water. If CBNG 

produced water was injected into the Madison 

formation, the quality of the water might make it 

unsuitable for beneficial uses without treatment. 

Phased Development (other than 

Alternatives F, G and H) 

Comments received during the public scoping period 

varied substantially in their interpretation of what 

constitutes “phased development.” While BLM has 

analyzed phased development under alternatives F, G 

and H, several proposed elements of phasing were 

not analyzed in detail. Those proposed elements and 

BLM’s rationale for not analyzing them in detail are 

addressed below. 

Fully develop one area while resting others. 

Subsequent development occurs as earlier areas 

are completed and restored. 

While BLM could authorize development for one 

watershed or specific area at a time, the purpose 

would be defeated by state and private development 

occurring in all areas or specific areas, which is not 

controlled by BLM actions. In the FSEIS, Table Min1 in the Minerals Appendix indicates that more than 

one half of the wells projected in the RFD would be 

State approved (9700 State approved to 8400 Federal 

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approved). The BLM does not control the approval or 

drilling of the state and private wells. This is 

illustrated by the number of state and private wells 

that have been drilled while the BLM was preparing 

the Statewide Plan (BLM 2003) and the SEIS (as of 

January 2008, approximately 950 CBNG wells have 

been developed under State authorization in Big Horn 

County, the most active CBNG county in the 

planning area). In addition, BLM has contacted the 

Montana Board of Oil and Gas Conservation in 

regard to CBNG management. They state: 

"The Board of Oil and Gas has no underlying 

statutory authority to direct the development of 

oil and gas resources; those resources are 

managed by their owners. The Board does have a 

statutory mandate to prevent the drilling of 

unnecessary wells, prevent economic and 

physical waste, and protect the correlative rights 

of competing mineral owners by establishing 

well location and set-back rules, and reservoir 

spacing rules. We do not envision the 

implementation of a management technique that 

would be less protective of competing property 

rights and more likely to result in waste of 

natural gas, and the drilling of unnecessary 

wells." 

Based on the projection of the number and location of 

wells, the mixed mineral ownership, and the statutory 

authority of the Montana Board of Oil and Gas 

Conservation it is reasonable to assume that 

development of state and private wells would not 

conform to specific areas identified for the 

development of federal wells. Therefore, it is not 

reasonable to fully develop one area while resting 

others followed by subsequent development in other 

specific areas when initial development areas are 

completed, because limiting state and private 

development to specific areas is not achievable. 

Areas where CBNG development cannot avoid 

creating significant environmental impacts 

should be identified and closed to leasing. Those 

areas that require lease stipulations in order to 

reduce environmental impacts to an acceptable 

level should also be identified. 

The rationale for not analyzing oil and gas leasing is 

provided in this section (see "Leasing" above). The 

Preferred Alternative (H) uses adaptive management 

to help prevent significant effects. The Monitoring 

Plan in the Monitoring Appendix identifies resources 

to be monitored and BLM's management options 

should a threshold be met. 

CHAPTER 2
 

Alternatives
 

Consider a phased development alternative that 

allows for the development of only certain coal 

seams at a time. When the initial zones have 

been depleted, produced water from other coal 

seams, developed in subsequent development 

phases could be re-injected into these depleted 

coal seams by converting the original wells into 

reinjection wells. 

The rationale for not analyzing reinjecting produced 

water into the same aquifer is addressed in this 

section (see "Re-Injection of Produced Water into the 

Same Aquifer" above. 

Stop issuing drilling permits during construction 

phases of other projects to reduce the effects of 

impacts associated with the other projects. 

Much of the development occurring in Montana 

occurs in a phased manner. Practical constraints, 

especially infrastructure to get the product out and 

state and federal permitting requirements all dictate 

industry’s proposed development occur in phases. 

Management Common to

All Alternatives 

Management common to all alternatives are the 

management practices for conventional oil and gas, 

as well as CBNG lease operations that are the same 

in each alternative. 

Bureau of Land Management 

The BLM has primary responsibility for managing 

the federally owned oil and gas estate. After lease 

issuance, operations may be conducted with an 

approved permit. Proposed drilling and associated 

activities must be approved before beginning 

operations. The operator must file an APD or Sundry 

Notice (SN) that must be approved according to (1) 

lease stipulations; (2) onshore oil and gas orders; and 

(3) regulations and laws. The steps required to obtain 

approval to drill and conduct surface operations are 

summarized in Appendix A of the 1992 Final Oil and 

Gas RMP/EIS Amendment and in the Minerals 

Appendix of the BLM’s Big Dry Resource 

Management Plan/Environmental Impact Statement 

for the Big Dry Resource Area of the Miles City 

District (Big Dry RMP/EIS) (1995). The process 

described therein is common to all alternatives. 

In addition, under requirements of the Clean Air Act 

(CAA) and the Federal Land Policy and Management 

Act (FLPMA), any activity the BLM authorizes 

(including oil and gas development) must comply 

with all applicable local, state, tribal and federal air 

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CHAPTER 2 

Alternatives 

quality laws, regulations, standards, increments and 

implementation plans. Therefore, land use 

authorizations will specify that operating conditions 

(i.e., air pollutant emissions limits, control measures, 

effective stack heights, etc.) are consistent with the 

applicable air regulatory agency’s requirements. 

State of Montana 

State agencies that have authority over oil and gas 

activities include the Department of Natural Resources 

and Conservation (DNRC), which includes the 

Montana Board of Oil and Gas Conservation 

(MBOGC), the Trust Land Management Division 

(TLMD) and the Water Resources Division; and the 

Montana Department of Environmental Quality 

(MDEQ). Each of these agency’s roles and 

responsibilities were discussed in Chapter 1. Current 

oil and gas development is managed under the 

guidelines developed in the MBOGC’s Record of 

Decision: Statewide Coal Bed Methane Exploration 

and Development (March 26, 2003; 

http://www.bogc.dnrc.state.mt.us/PDF/finalrod.pdf). 

This document outlines how to incorporate any 

necessary environmental review into its rules and 

permitting process in an effort to comply with the 

Montana Environmental Policy Act (MEPA). In 

conducting environmental reviews for new permits, 

MBOGC works with other state agencies that may 

become involved in the process. 

Surface Use Agreements
 

Oil and gas operators on federal leases must submit 

certification that a surface use agreement (SUA) has 

been reached with surface owners of split estate 

lands. These are lands involving private surface 

overlying federal minerals. 

BLM does not consider an APD or sundry notice 

complete until the federal lessee or operator has 

certified that an agreement with the surface owner 

exists, or the lessee or operator complies with Onshore 

Oil and Gas Order 1 (Instruction memorandum No. 

2003-131). Compliance with Onshore Oil and Gas 

Order 1 requires the federal mineral lessee or operator 

to enter into good-faith negotiations with the private 

surface owner to reach an agreement for protection of 

surface resources and reclamation of disturbed areas, 

or payment in lieu thereof, to compensate the surface 

owner for loss of crops or grazing and damages to 

tangible improvements, if any. If such an agreement 

between the surface owner and lessee or operator 

could not be reached, a bond would be required to 

protect against covered damages in the absence of an 

agreement. 

The Stockraising Homestead Act of December 29, 

1916 (SRHA) (43 U.S.C. 299) and regulations at 43 

CFR 3814.1(c) clearly limit covered damages to 

grazing and associated tangible improvements. The 

effective Onshore Oil and Gas Order 1 states that 

compensation is based on the law that reserved the 

mineral estate. It also states the amount of such a 

bond must be a minimum of $1,000 and be sufficient 

to: 1) pay for loss or damages; or 2) comply with the 

provisions of the law that reserved the mineral estate. 

Water Well Mitigation Agreements
 

CBNG development has the potential to impact 

groundwater by decreasing the pressure within the 

coal aquifers (drawdown). As such, it is the subject of 

Montana Code Annotated 82-11-175, which was 

enacted by the Montana Legislature in 2003 and 

MBOGC Order 99-99. This order describes the 

authorities that pertain to CBNG development. A 

copy of the order is included as an appendix to the 

Water Resources Technical Report (ALL 2001b). 

The order outlines water rights issues, mitigation, 

monitoring plans and jurisdiction. 

Montana Code Annotated (MCA) 82-11-175 requires 

CBNG operators offer a reasonable mitigation 

agreement to each appropriator of water who holds 

an appropriation right or a permit to appropriate 

groundwater. This requirement is in effect if the point 

of diversion is within 1 mile of the CBNG well, or 

0.5 mile of a water source that is adversely affected 

by the coal bed natural gas well. 

Mitigation agreements must address the reduction or 

loss of water resources and must provide for prompt 

supplementation or replacement of water from any 

natural spring or water well adversely affected by the 

coal bed natural gas well. An example water mitigation 

agreement is included in the Hydrology Appendix. 

For development on federal minerals, BLM would 

require operators to certify that water well mitigation 

agreements for the proposed federal wells have been 

offered in accordance with MCA 82-11-175. These water 

mitigation agreements would also have to contain 

language addressing how an operator would respond to 

water wells being rendered unusable or unsafe due to 

methane migration and how health- and safety-related 

impacts would be monitored and mitigated. 

3104 Bonds 

Current regulations set minimum amounts (financial) 

of bonding required. BLM may require an increase to 

any bond (43 CFR 3104.5B), whenever it was 

determined the operator posed a risk due to factors 

including, but not limited to, the number and type of 

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wells, type and amount of reclamation necessary and 

operator history. The increase in bond amount can be 

to any level BLM specifies, but it cannot exceed the 

total estimated costs of the total estimated amount of 

uncollected royalties due, monies owed because of 

outstanding violations and estimated well plugging 

and reclamation costs. 

Mitigation Measures 

Management practices common to all alternatives 

include numerous mitigation measures categorized by 

resource topic. These mitigation measures are derived 

from current leasing stipulations, standard operating 

procedures and MBOGC field orders. A list of the 

mitigation measures considered common to all 

alternatives is provided in Table 2-1. 

Not all mitigation measures are applicable under all 

leases; due to the variances between Federal, State 

and private surface and mineral ownership. MEPA 

compliance by state agencies may result in sitespecific mitigation measures being developed that are 

not listed in Table 2-1. Specific mitigation measures 

to be applied depend upon the ownership of both 

surface and minerals and upon the land management 

agency and regulatory agency involved. The TLMD 

is the land manager for state owned lands; BLM is 

both land manager and regulatory agency on BLMadministered lands; and private land owners are 

managers of the private land. The Board of Oil and 

Gas is the regulatory agency for state and private 

lands. Note, current leasing stipulations are not being 

amended under this FSEIS, but can be found in 

tabular form in the Minerals Appendix, Table MIN-5. 

Management Actions 

Specific to Each

Alternative 

Eight alternatives have been developed to evaluate 

the impacts related to the various development 

scenarios associated with CBNG exploration and 

production. Each alternative represents a different 

approach for resolving the issues identified during 

CHAPTER 2 

Alternatives 

scoping. Alternative A, the No Action Alternative, 

would continue existing management. Alternative B 

would allow CBNG development while emphasizing 

resource protection. Alternative C would emphasize 

CBNG development with minimal environmental 

restrictions. Alternative D would encourage CBNG 

exploration and development while maintaining 

existing land uses. Alternative E would allow for 

CBNG exploration and development while sustaining 

resource and social values and existing land uses. 

Alternatives F, G and H would allow exploration and 

phased development of federal CBNG by applying 

multiple screens and mitigation measures designed to 

protect the other resource values through the pace 

and place of CBNG development. Alternative H 

would allow for exploration and development 

coupled with a monitoring feedback loop that would 

provide information for adaptive management 

decisions. 

In Alternatives A through E, crucial habitat for 

wildlife would be managed in accordance with the 

current BLM policies and with the use of mitigation 

measures outlined in the FSEIS and Wildlife 

Monitoring and Protection Plan (WMPP). In 

Alternatives F and G, conditions would be placed on 

any proposed CBNG federal mineral development 

within crucial sage-grouse habitat areas with the goal 

of avoiding the displacement of sage-grouse from 

crucial habitat areas. For Alternative H, results of 

recent research related to sage-grouse would be 

applied. In addition adaptive management would be 

applied to sage-grouse habitat, allowing BLM to alter 

surface disturbance thresholds, adopt new BMPs and 

work with the state to apply BMPs universally to 

protect sage-grouse habitat. 

Each alternative was structured to stress different 

development emphasis, such as resource protection, 

CBNG development and existing land uses. 

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CHAPTER 2 

Alternatives 

TABLE 2-1
 

MITIGATION MEASURES COMMON TO ALL ALTERNATIVES
 

(Applies to BLM Managed Oil and Gas Estate) 

Resource Topic Mitigation Measure 

Air Quality	 Access roads, well pads and production facility sites constructed on soils susceptible to wind 

erosion will be appropriately surfaced to reduce fugitive dust emissions 

Dust inhibitors will be used as necessary on unpaved collector, local and resource roads to 

reduce fugitive dust emissions to the air and resources adjacent to the road 

Cultural Resources	 Cultural resource reviews/surveys will be conducted as required by BLM or TLMD prior to the 

commencement of construction or other surface disturbing activities authorized by BLM or 

TLMD. Results of the survey will be presented as part of the permit review or approval 

process. Decisions regarding relocation of proposed access roads or well pads, data recovery 

and excavation will be made to protect the cultural or historical sites 

Surface occupancy and use is prohibited within sites or areas designated for conservation use, 

public use, or sociocultural use 

Geology and Minerals	 No Surface Occupancy stipulations are placed on new oil and gas leases which are issued for 

lands that have existing coal leases 

Reclamation is required on areas of surface disturbance during the production and 

abandonment phases of development 

Hydrological Resources	 Water well and spring mitigation agreements will be used to facilitate the replacement of 

groundwater lost to drawdown. Replacement water may require supply from offsite sources 

Montana's water quality standards for the Tongue and Powder Rivers are being challenged by 

court actions that are not yet resolved. The states of Montana and Wyoming are in negotiationq 

on appropriate"state-line standards and the methods used to manage CBNG discharges in 

Wyoming to meet the standards that are eventually adopted. 

Oil and gas leases issued for lands that contain floodplains, wetlands, or riparian areas have 

stipulations regarding No Surface Occupancy (NSO) attached. 

Lands and Realty	 Surface disturbance on federal lands will be reclaimed following the BLM-Miles City Field 

Office (MCFO) seeding policy (BLM 1999c) or future revisions 

Roads and utility ROW impacts experienced prior to reclamation are mitigated by 

requirements for repair or replacement in the site-specific review, or through compensation for 

actual damages 

Property damage would be repaired or replaced according to landowner agreements at the 

operator expense 

Surface owners or surface lessee will be consulted regarding the location of new roads and 

facilities related to oil and gas lease operations 

Livestock Grazing Repair or replace damaged gates and fences according to landowner requirements at operator’s 

expense 

When working on or near grazing lands, project-related construction equipment and vehicle 

movement will be minimized to avoid disturbance of grazing lands 

Responsibilities for fence, gate and cattleguard maintenance; and noxious weed control will be 

defined in APDs, Agency Approvals, or ROW grants 

Facilities will be placed to avoid or minimize impacts on livestock water 

2-8 
 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-1 

MITIGATION MEASURES COMMON TO ALL ALTERNATIVES 

(Applies to BLM Managed Oil and Gas Estate) 

Resource Topic Mitigation Measure 

Paleontological Resources	 The BLM APD contains guidance for notifying and mitigating damage to paleontological 

resources discovered during oil and gas construction activities. Limitations include restricted 

use of explosives for geophysical exploration, monitoring requirements and work stoppages for 

discovered damaged resources 

Surface occupancy and use is prohibited within designated paleontological sites 

The Bridger Fossil Area is a designated Area of Critical Environmental Concern (ACEC) is not 

available for oil and gas development 

Recreation	 Surface occupancy and use is prohibited within established recreation areas and undeveloped 

recreation areas receiving concentrated use on lands administered by BLM 

Exploration activities would be coordinated for timing to minimize conflicts during peak use 

periods 

Social and Economic Values	 Economic impacts on groundwater users would be mitigated by the mandatory offering of 

water well and spring mitigation agreements 

Soils	 Construction activities will be conducted in accordance with the BLM Gold Book (USDI and 

USDA 2006; http://www.blm.gov/bmp/goldbook.htm) requirements 

Federal leases with slopes in excess of 30 percent will be required to obtain approval for 

occupancy from the BLM based on mitigation of erosion, surface productivity after 

remediation and mitigation to surface water quality 

Riparian zones will be protected by federal lease stipulations and permit mitigation measures 

Lease roads and constructed facilities will be limited based on the Surface Use Program in the 

APD 

In areas of construction, topsoil will be stockpiled separately from other material and be reused 

in reclamation of the disturbed areas 

Unused portions of the drill location will have topsoil spread over it and reseeded 

Construction activities will be restricted during wet or muddy conditions 

Construction activities will be designed following Best Management Practices (BMPs) to 

control erosion and sedimentation 

If porous subsurface materials are encountered during drilling, all onsite fluid pits will be lined 

During road and utility ROW construction, surface soils will be stockpiled adjacent to the sides 

of the cuts and fills 

Stream crossings will be designed to minimize impacts and impede stream flow 

Erosion control measures will be maintained and continued until adequate vegetation (defined 

by BLM on a case by case basis) cover is re-established 

Water bars will be constructed on slopes of 3:1 or steeper 

Solid and Hazardous Wastes Solid and Hazardous wastes generated as a result of oil and gas lease operations will be 

disposed of in a manner and at a site approved by the appropriate regulating agency. 

Vegetation Site-specific surveys for Special Status Plant Species would be conducted prior to surface 

disturbance commencement 

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CHAPTER 2 

Alternatives 

TABLE 2-1 

MITIGATION MEASURES COMMON TO ALL ALTERNATIVES 

(Applies to BLM Managed Oil and Gas Estate) 

Resource Topic Mitigation Measure 

Vegetation (cont.) 

Visual Resource Management 

Wilderness Study Areas 

Wildlife 

The BLM Seeding Policy (Miles City BLM Seeding Policy, dated October 27, 1999(c)) and 

any future revisions will be followed for all reclamation and reseeding activities 

Vegetation will be removed only when necessary 

Surface occupancy and use is prohibited within designated Visual Resource management 

Class I areas 

All surface-disturbing activities and semi-permanent and permanent facilities in Visual 

Resource Management Class II areas require special design, including location, painting and 

camouflage, to blend with natural surroundings and meet the visual quality objectives of the 

classification 

Laws and regulations established to protect Wilderness Study Areas (WSA) prohibit leasing of 

designated WSA lands for resource extraction 

An extensive list of no surface occupancy and no surface use stipulations by species is 

presented in the Wildlife section of Chapter 4. These stipulations limit and exclude use within 

designated distances from known species’ specific nesting areas and habitat. Measures could 

also include Conditions of Approval, as authorized by IM-2005-069 for on-site and off-site 

mitigation for APDs and ROWs. After implementation of the BMPs, impacts to the wildlife 

resources will be evaluated through the use of the wildlife screen. 

Other restrictions governing development timing, controlled surface use and avoidance 

measures are listed in Table MIN-5 of the Minerals Appendix 

Aquatic Resources Surface occupancy and use is prohibited within 1/4 mile of designated reservoirs with fisheries 

Alternative A—No Action (Existing 

Management) 

This section describes the current management 

practices used by the BLM and the state to manage the 

exploration, development and operation of CBNG 

wells in the Planning Area. 

The BLM issues oil and gas leases that include the 

right to explore for and develop CBNG. The Final Oil 

and Gas RMP/EIS Amendment allowed for the drilling 

of test wells and initial small-scale development of 

CBNG. Under existing management, APDs for CBNG 

wells would be approved on a case-by-case basis, only 

in specific geographic areas where little or no CBNG 

data is available. The APDs would only authorize the 

drilling and testing of wells and associated construction 

activities. CBNG production would not be authorized 

nor would the operator be allowed to discharge waters 

into State or U.S. streams or drainages. All current 

leasing stipulations regulating mitigation measures 

would be applied to new leases and enforced on current 

leases. APDs for CBNG exploration and testing would 

be considered for possible approval, on a case by case 

basis, under an evaluation criterion that would include, 

but not be limited to, areas where the following apply: 

•	 The proposal is in conformance with the Powder 

River and Billings RMPs 

•	 Data for coal, gas or groundwater does not exist 

•	 Data for coal, gas or groundwater is limited 

•	 Data for coal, gas or groundwater might be dated 

or unreliable 

•	 Data for coal, gas or groundwater is only 

available from certain coal seams
 

•	 The proposed placement of wells would optimize 

data collection 

•	 The well, if not productive, could be useful for 

monitoring 

APDs for coal bed natural gas wells would not be 

considered for approval in areas where the following 

apply: 

•	 The proposal is not in conformance with the 

Powder River or Billings RMPs 

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•	 Sufficient and accurate data exists for coal, gas 

and groundwater 

•	 Other coal bed natural gas wells are being drilled 

•	 Other coal bed natural gas wells are producing 

•	 Monitoring wells are in place or not needed 

Water produced during the testing phase would not 

have to be treated and would be contained at the well 

site in either a pit or a steel tank. The water would be 

available for beneficial use by industry (for example, 

pipelines, dust abatement) and landowners. Wells 

drilled on federal minerals would be shut-in or plugged 

after completion of the testing phase. 

Coal seams targeted for exploration would be 

determined by industry and not by the government. 

Vertical wells producing from a single coal seam 

would be allowed. Vertical wells producing from 

multiple coal seams would not be required. Operators 

would be required, when technologically and 

economically feasible, to drill several wells from a 

single well pad, which may require directional drilling. 

The placement of wells would not be restricted through 

the use of buffer zones around active coal mines or 

Indian reservations. 

Transportation corridors for vehicles would not be 

required; however, operators would be encouraged to 

use existing routes, corridors, or previously disturbed 

areas when feasible or as required by the surface 

owner. Powerlines would be either aboveground or 

buried according to operator plans. Placement of roads 

and powerlines or other utilities requiring ROW are 

subject to environmental review and agency approval. 

Diesel, electric, or gas-fired engines would power 

generators used during the testing phase of CBNG 

wells. The number of wells connected to each 

compressor would be dependent on the operator’s 

development circumstances. Equipment would have to 

be removed at the end of the testing phase or at the 

time of abandonment. Areas of surface disturbance 

associated with lease operations would have to be 

reclaimed at the completion of activities in accordance 

with surface owner requirements. Upon abandonment, 

roads providing legal access to BLM-administered 

surface would be open to the public. 

Alternative B—Emphasize Soil, 

Water, Air, Vegetation, Wildlife and 

Cultural Resources 

This alternative would allow CBNG development 

while emphasizing the protection of natural and 

cultural resources. 

CHAPTER 2 

Alternatives 

The following measures would be required to reduce 

environmental impacts. 

All generators and compressors would have to be 

powered by natural gas-fired engines. The number of 

wells connected to each compressor would be 

maximized to reduce the overall number of field 

compressors. 

To the extent agency authority allows, buffer zones 

would be established around Indian lands and active 

coal mines. Until a reservation approves production of 

CBNG on their lands, a 2-mile buffer would be 

enforced around reservations in Montana. A 1-mile 

buffer would be enforced around active coal mines 

where no CBNG production would be permitted. 

Water from exploration wells would be stored in tanks, 

or other approved non-discharging storage facilities. 

Water from producing wells would be injected into a 

different aquifer with the same or lesser quality water. 

Class V permits for injection of produced water with 

less than 3,000 milligrams per liter (mg/l) total 

dissolved solids (TDS) would need to be obtained from 

the EPA Region VIII. If the produced water has 

dissolved solids in excess of 10,000 mg/l, it would 

need to be disposed of via the Class II Underground 

Injection Control (UIC) program maintained by the 

MBOGC. Produced water between 3,000 and 10,000 

parts per million (ppm) TDS can be disposed of in a 

Class II well permitted by MBOGC with concurrence 

from the Environmental Protection Agency (EPA). 

Regardless of the water quality or class of well, the 

produced water would not be injected into the same 

coal seam that the methane was being extracted from 

unless there was some form of geological separation to 

prevent migration of the injected water into the area of 

methane production. 

There are several potential limitations to injecting all the 

water in this alternative. Since certain geological 

conditions are desirable for injection and they are not 

always present in the near surface, it is conceivable that 

in some cases deep injection into the Madison limestone 

would be required. Formations that are potential zones 

for injection may also have limited capacity to accept 

large volumes of water. Due to the high cost of injection 

and the uncertain success in disposing of all produced 

water over the life of a group of CBNG wells, injection 

has not yet been shown to be commercially viable for 

the CBNG industry in the Powder River Basin (PRB). 

Co-location by spacing unit, of single-seam 

development wells on the same well pad would be 

required. Multiple seam completions in a single well 

bore would be encouraged to the extent technology 

permits. CBNG production could occur simultaneously 

from multiple seams or staggered over time from 

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CHAPTER 2 

Alternatives 

separate seams. Directional drilling would be required 

for deeper coal seams to avoid excess surface use or 

disturbance. 

Roads to wells and compressor sites would be limited 

to single lane width with turnouts. Exploration wells 

would not have permanent gravel access roads. 

Utilities would be placed along the road routes, using 

the transportation network as utility corridors. 

Powerlines would be buried in the utility corridors; no 

overhead lines would be permitted. Produced water 

pipelines and gas pipelines would be buried in the same 

trench when feasible. When the well had reached the 

end of its useful life, new access roads on BLM and 

state surface would be rehabilitated if closed. 

The following paragraphs address environmental 

mitigation measures envisioned to reduce impacts on 

various resource topics. 

During the construction of ROWs and roads, 

commercially valuable trees would be harvested and 

the proceeds paid to the resource owner. Long-term 

loss of commercial timber production on these lands 

would be negotiated with the TLMD and private 

landowners. 

Use of CBNG-related roads would be limited to 

industry and enforcement would be increased through 

the use of additional fences and gates to reduce public 

access and overuse. This effort would help educate 

residents that these roads are not part of the public road 

network. Speed limits would be posted and enforced to 

reduce fugitive dust emissions. Road placement would 

be limited to tract boundaries where practical to reduce 

impacts on residential and agricultural lands. 

Operators will be required to comply with agency 

imposed conditions during times of high fire danger. 

Such conditions may include restrictions on types of 

activities allowed, hours of operation and requirements 

for maintaining certain fire suppression equipment at 

the work site. Operators must maintain a current fire 

suppression plan. 

To reduce noxious weeds from spreading during 

CBNG-related activities, operator’s weed prevention 

plans must include measures to prevent the spread of 

weed seeds from any vehicle or equipment. 

Additionally, during reclamation activities, both native 

and non-native early succession plants, along with 

sterile cover crops, would be used for revegetation to 

provide a quick cover before noxious weeds can take 

root. 

Wildlife surveys required by BLM would be conducted 

prior to the approval of APDs. Qualified wildlife 

biologists would conduct the surveys and results would 

be reported to Montana Fish, Wildlife, and Parks 

(MFWP) for consultation regarding avoidance and/or 

other wildlife protective measures. 

Alternative C—Emphasize CBNG 

Development 

This alternative would emphasize CBNG exploration 

and development with minimal restrictions. 

Operators could use diesel engines with Best Available 

Control Technology (BACT) to reduce emissions. 

Operators would not be required to connect a minimum 

number of CBNG wells to a field compressor nor limit 

the number of field compressors delivering gas to a 

sales compressor. 

Roads and utility corridors would be positioned to use 

existing disturbances as much as possible. Powerlines 

would be aboveground or buried per the operator’s 

plans. Gas and water lines would be buried. Upon 

abandonment, new BLM and state surface oil and gas 

roads would be rehabilitated and closed. 

Operators would not be required to drill directional or 

horizontal CBNG wells. Wells would be located by the 

operator and agencies would not require multiple wells 

to be located on the same well pad. 

Water management would be based on a combination 

of beneficial use and surface discharge. Beneficial uses 

would include stock water, coal mine dust suppression, 

irrigation, constructed wetlands, domestic water 

supply, produced water as drilling fluid, de-icing of 

road aggregate storage piles, industrial needs and 

agricultural reuse. Surface discharge would be subject 

to MDEQ permit requirements, Montana Pollutant 

Discharge Elimination System (MPDES) and 

limitations established for discharge into identified 

watersheds. Water discharge via a transportation 

pipeline into a drainage system would not be required. 

The operator must obtain 401 Certification from the 

MDEQ if the disposal action needs BLM approval. 

Injection of produced CBNG water would not be 

required. 

A CBNG production buffer zone would not be imposed 

around Indian reservations or coal mines. 

Alternative D—Encourage 

Exploration and Development 

While Maintaining Existing Land 

Uses 

This alternative would encourage CBNG development 

while maintaining existing land uses and protecting 

downstream water consumers. The following paragraphs 

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CHAPTER 2
 

Alternatives
 

address environmental mitigation measures envisioned 

to balance development with resource protection. 

The number of wells connected to each compressor 

would be maximized to reduce the overall number of 

field compressors required. Natural gas engines with 

electric boosters would be required for all compression 

operations. Operators would be required, when 

technologically and economically feasible, to drill 

several wells from a single well pad, which may 

require directional drilling. Multiple seam completions 

in a single well bore would be encouraged. The 

transportation network also would serve as a utility 

corridor. Roads and utilities would be constructed with 

one way in and out. All powerlines and water and gas 

pipelines would be buried. Upon abandonment, new oil 

and gas roads on BLM-administered surface would be 

rehabilitated if closed. Roads would remain open or 

closed at the surface owner’s discretion. 

To the extent agency permitting allows, buffer zones 

for production would be established around Indian 

lands (2 miles) and active coal mines (1 mile). The 

buffer zone around Indian lands would remain in effect 

until the tribe approves production on its own lands. 

All produced water (depending on water quality) would 

be treated prior to surface discharge or pumping into 

holding facilities such as impoundments, pits and ponds. 

Transportation of treated water for discharge would be 

via a constructed drainage system or pipeline to the 

nearest perennial watercourse if possible. The method of 

treatment is unrestricted, provided the effluent meets 

standards established by the MDEQ for downstream use. 

Beneficial use of produced water would be allowed and 

treatment would vary based on industrial, municipal, or 

agricultural uses such as power plant cooling water, coal 

slurry pipeline, field irrigation, livestock or wildlife 

watering, or municipal power turbines. The operator 

must obtain 401 Certification from the MDEQ if the 

disposal action needs BLM approval. Surface storage of 

produced waters would also require an MPDES permit 

issued by MDEQ. 

Use of CBNG-related roads would be limited to 

industry and enforcement would be increased through 

the use of additional fences and gates to reduce public 

access and overuse. This effort would help educate 

residents that these roads are not part of the public road 

network. Speed limits would be posted and enforced to 

reduce fugitive dust emissions on BLM administered 

surface. 

Operators will be required to comply with agency 

imposed conditions during times of high fire danger. 

Such conditions may include restrictions on types of 

activities allowed, hours of operation and requirements 

for maintaining certain fire suppression equipment at 

the work site. Operators must maintain a current fire 

suppression plan. 

To reduce noxious weeds from spreading during CBNGrelated activities, operator’s weed prevention plans must 

include measures to prevent the spread of weed seeds 

from any vehicle or equipment. Additionally, during 

reclamation activities, early succession plants would be 

used for revegetation to provide a quick cover before 

noxious weeds can take root. 

Wildlife surveys would be conducted prior to the 

approval of APDs. Qualified wildlife biologists and 

botanists would conduct the surveys and results would 

be reported to MFWP (animals) and the Montana 

Natural Heritage Program (MNHP) (plants) for 

consultation regarding avoidance and/or other wildlife 

and plant protective measures. 

Camouflage of all wellheads in Class II Visual 

Resource Management Areas would be required to 

preserve the view shed. Camouflage would consist of 

paint chosen to blend in with the background and 

placement of wellheads to reduce visual obstructions. 

Alternative E—CBNG Exploration 

and Development with Enhanced 

Mitigation to Minimize 

Environmental Impacts While 

Maintaining Existing Land Uses 

Alternative E would provide management options to 

facilitate CBNG exploration and development, while 

sustaining resource and social values and existing land 

uses. 

Exploration and development of CBNG resources on 

BLM-administered minerals are allowed subject to 

agency decisions, lease stipulations, permit 

requirements and surface owner agreements. Operators 

would be required to submit a project POD outlining 

the proposed development of an area when requesting 

CBNG well densities greater than 1 well per 640 acres. 

The project POD would be developed in consultation 

with the affected Tribes, affected surface owner(s) and 

other involved permitting agencies. 

A step-by-step guideline for preparation of the project 

POD developed by BLM is available online at 

http://www.mt.blm.gov/mcfo/cbm/GuidanceMan/index 

.html (CBNG APD and Project POD Guidance 

Manual, May 28, 2003f). The project POD would be 

submitted in draft form so that it can be reviewed and 

any changes made prior to allowing surface disturbing 

activities. At a minimum, the project POD would have 

to contain the following: 

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CHAPTER 2 

Alternatives 

•	 A cover letter naming the project area and 

requesting approval 

•	 An APD (form 3160-3) for each federal well in 

the project area 

•	 A list of all other permitting agencies involved in 

the project and the name for a point-of-contact for 

each office 

•	 A list of all existing wells in the project area, 

including monitoring wells 

•	 Maps submitted in paper or digital format 

(electronic map with any digital geographic 

information system (GIS) coverages used to 

create the map), showing proposed roads, 

compressor stations, pipelines, powerlines, 

CBNG well locations, all existing wells, current 

and proposed monitoring wells, surface 

ownership, mineral ownership, surface features 

and existing structures 

•	 Master drilling information as required by 

Onshore Order No. 1 (for BLM-administered 

lands) 

•	 Master surface use information as required by 

Onshore Order No. 1 (for BLM-administered 

lands) 

•	 A Reclamation Plan for surface disturbance 

•	 A wildlife monitoring plan demonstrating how 

the project will meet the needs of the BLM 

WMPP for BLM-administered lands (See 

Wildlife Appendix for a complete copy of the 

WMPP) 

•	 A Water Management Plan for the project area 

•	 Certification of surface use agreements or surface 

owner protection bond, certification of water well 

mitigation agreements (or notice that the Surface 

Owner Damage and Disruption Compensation 

Act applies and surface owner agreements are 

pending settlement or court action). (See 

Management common section for detailed 

explanation of agreements) 

•	 A list of all potentially affected surface owners 

within the project area 

•	 A cultural resource plan addressing identification 

strategies commensurate with the level of the 

proposed development (for BLM-administered 

lands). This may include a cultural resource 

location and significance model for identifying 

areas of critical concern. 

•	 BLM would also require compliance with 

Onshore Oil and Gas Order Number 7 for 

Disposal of Produced Waters. 

Alternative E combines water management options so 

that there would be no unnecessary or undue 

degradation as defined by the MDEQ of water quality 

allowed in any watershed. The preferred water 

management option of water produced with CBNG is 

for beneficial use. Other produced water management 

options include, but are not limited to, injection, 

treatment, impoundment and discharge. The operator 

must obtain 401 Certification from the MDEQ if the 

disposal action needs BLM approval. A Water 

Management Plan for Exploration would be required 

for exploratory wells and for each project POD. The 

Water Management Plan for Exploration would be 

required for CBNG exploration wells drilled under 

statewide spacing rules. At a minimum, the Water 

Management Plan would be part of an Application for 

Permit to Drill and certification that a water well or 

spring mitigation agreement with the owner has been 

ratified for any water well/spring within 1 mile; 

identify any proposed uses of the water (beneficial if 

possible); and a map showing all wells within 1 mile of 

the proposed exploratory CBNG well. 

Water Management Plans developed as part of a 

project POD could include the following additional 

requirements: 

•	 A cover letter identifying the project POD for 

which the Water Management Plan has been 

developed and the watershed(s) affected by the 

project 

•	 A 7.5 minute topographical map indicating the 

location(s) of any proposed storage ponds and/or 

discharge points 

•	 Water quality data for the produced water 

•	 Anticipated rate of water production per well and 

the calculated amount of annual water production 

for the field 

•	 Proposed beneficial uses of the produced water 

addressed in surface owner agreements 

•	 Operator’s approach to ensure no undue 

degradation of the surface water quality within the 

designated watershed(s) 

•	 A copy of any MPDES discharge permit(s) issued 

by the MDEQ, if required; or a copy of the letter 

of compliance for MDEQ’s General Discharge 

Permit; or UIC permit issued by the MBOGC or 

disposal permit issued by the EPA 

•	 A water monitoring plan for the area that meets 

the requirements of MBOGC Rules and the 

Controlled Groundwater Area as outlined in the 

Monitoring Appendix 

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CHAPTER 2
 

Alternatives
 

•	 A statement indicating whether a 401 

Certification is required and if so, a copy of the 

certificate 

•	 A copy of the most current soil map available for 

the project area 

•	 Site-specific stratigraphy for any infiltration basin 

location that is proposed 

Produced water management plans and permits would 

be approved by BLM or the appropriate agency in 

consultation with affected surface owners. Surface 

storage of produced waters would also require an 

MPDES permit issued by MDEQ. Impoundments 

proposed as part of the Water Management Plan would 

be designed and located to minimize or mitigate 

impacts on soil, water, vegetation and channel stability. 

There would be no discharge of produced water 

(treated or untreated) into the watershed unless the 

operator has an approved MPDES permit and can 

demonstrate in the Water Management Plan how 

discharge could occur in accordance with water quality 

laws without damaging the watershed. 

Shallow coal seams would have vertical wells installed 

while directional wells may be drilled to the deeper 

coal seams. Directionally drilled wells would be drilled 

from the same well pad as the vertical wells, unless the 

operator can demonstrate why directional drilling is not 

needed or feasible. 

Development of coal seams would be done either one 

coal seam at a time or multiple coal seams at the same 

time. Production of CBNG would be from one coal 

seam per well or multiple coal seams per well. During 

production of CBNG from multiple coal seams from 

multiple wells, the wells would be collected on the 

same well pad. Well spacing rules would set a limit of 

one well per coal seam per designated spacing unit. 

With regards to air quality, the objectives of this 

alternative are the same as for Alternative B (the 

number of wells connected to each compressor would 

be maximized and natural gas-fired engines for 

compressors and generators would be required), except 

in areas with sensitive resources, including people, 

where noise is an issue. In those areas, the decibel level 

would be required to be no greater than 50 decibels 

measured at a distance of 1/4 mile from the 

compressor. This may require the installation of an 

electrical booster at these locations. Operators of 

federal leases would be required to post and enforce 

speed limits to reduce fugitive dust emissions. 

Transportation corridors would not be required; 

however, proposed roads, pipeline routes and utility 

line routes would be located to follow existing routes 

or areas of previous surface disturbance when possible. 

The operator would also address in the project POD 

how the surface owner was consulted for input into the 

location of roads, pipelines and utility line routes. 

Powerlines are also a project POD consideration. The 

operator would demonstrate in the project POD how 

the proposal for power distribution would mitigate or 

minimize impacts on affected wildlife. For example, on 

BLM-administered lands the operator may be required 

to bury a portion of the powerlines near sage-grouse 

habitat to safely eliminate use by raptors and any 

aboveground lines be designed following raptor-safe 

specifications. 

When wells are abandoned, the associated oil and gas 

roads would remain open or be closed at the surface 

owner’s discretion. If the roads were requested to be 

closed they would be rehabilitated. This includes 

leaving BLM-administered surface roads open if access 

is desirable. 

There would be no buffer zone for CBNG production 

around active coal mines (MSO-IM-2000-053). 

The BLM would require federal lease operators to 

protect Crow and Northern Cheyenne groundwater and 

CBNG from loss or degradation. 

Mitigation measures that would be applied to protect 

Northern Cheyenne Tribal resources are described in 

the Northern Cheyenne Mitigation Appendix. 

In addition to the requirements outlined in the project 

POD and in the Water Management Plan, the following 

general environmental mitigation measures would be 

implemented to further reduce potential impacts: 

•	 The air permitting process would include analyses 

of equipment emissions and associated ambient 

impacts. Emission sources that may violate 

ambient standards will not be issued a permit. 

•	 Road placement would be limited to track 

boundaries where practical to reduce impacts on 

residential and agricultural lands. 

•	 Displaced farmland, whether in crop production 

or not, will be reclaimed to original soil 

productivity through adoption of standard 

reclamation procedures. 

•	 Operators will be required to comply with agency 

imposed conditions during times of high fire 

danger. Such conditions may include restrictions 

on types of activities allowed, hours of operation 

and requirements for maintaining certain fire 

suppression equipment at the work site. Operators 

must maintain a current fire suppression plan. 

•	 During reclamation activities, early succession 

plants will be used for revegetation to provide a 

quick cover before noxious weeds can take root. 

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CHAPTER 2 

Alternatives 

Operators would be required to include plans to 

prevent the spread of noxious weeds as part of 

their development plans. The noxious weed 

prevention plans must include measures to 

prevent the spread of weed seeds from any 

vehicles and equipment from or prior to 

mobilizing it to the project area. 

•	 Operator reclamation plans would be developed 

in consultation with the surface owner. Reclaimed 

areas reseeded with native species would be 

required to be reseeded with a certified weed-free 

seed mix determined by the surface owner and 

would usually require at least two growing 

seasons to ensure a self-sustaining stand of seeded 

species. 

•	 Camouflage of all wellheads in federal surface 

Class II Visual Resource Management Areas will 

be required to preserve the viewshed. Camouflage 

will consist of paint chosen to blend in with the 

background and placement of wellheads to reduce 

visual intrusions. 

•	 Wildlife surveys on state lands to identify special 

status species will be conducted on potential 

habitat near drilling and production sites prior to 

the approval of federal APDs. Qualified wildlife 

biologists would conduct surveys and results will 

be reported to MFWP for consultation regarding 

avoidance and/or other wildlife protective 

measures. 

•	 On BLM-administered lands impacts to wildlife 

will be monitored and addressed in the WMPP in 

addition to the mitigating measures for wildlife 

that are part of the standard APD review and 

approval process. Impacts to wildlife, including 

those species on public lands and on land adjacent 

to the reservations, would be monitored and 

addressed in accordance with the WMPP (see 

wildlife appendix). 

•	 The affected Tribes would be invited to 

participate in the “steering group” that would 

evaluate information gathered during the 

inventory and monitoring phases of the Wildlife 

Monitoring and Protection Plan. 

•	 The results of the Wildlife Monitoring and 

Protection Plan may be used to adjust conditions 

of approval on federal APDs. This includes 

measures needed to protect public lands and 

reservation wildlife from the impacts of CBNG 

development. 

The following special survey activities would be 

conducted for the Gray Wolf, Canada Lynx and 

Grizzly Bear on BLM-administered lands as needed: 

•	 Gray Wolf—Prior to APD approval, surveys 

would be conducted specifically for this animal, 

occupied dens, or scat. The corridor would be 

surveyed in the spring, before construction, by a 

wildlife biologist for scat. If scat is found, the site 

would be surrounded by a buffer zone 

recommended through consultation with a U.S. 

Fish & Wildlife Service (FWS) biologist. If 

wolves or other wolf indicators are found, FWS 

would be consulted and proper protocols 

followed. 

•	 Canada Lynx—Any construction areas or drilling 

pads located in high elevation, old growth 

forested areas, especially areas with populations 

of hares or rabbits, would be surveyed prior to 

APD approval for scat and individual lynx 

following established protocols. If found, the site 

would be avoided and surrounded by a buffer 

zone recommended by FWS biologists. 

•	 Grizzly Bear—Garbage and other human refuse 

would be removed from drilling and construction 

sites on a daily basis in potential bear habitat to 

avoid attracting bears. Surveys for scat and other 

sign of grizzly bears in remote areas would be 

conducted prior to APD approval. If found, 

protocol would be established after consultation 

with FWS biologists. 

In addition, the following measures as prescribed in the 

FWS Biological Opinion will be implemented on 

BLM-administered lands: 

Bald Eagles 

•	 If a dead or injured bald eagle is located during 

construction or operation, the FWS Montana 

Field Office (406- 449-5225), or the Billings 

Suboffice (406-247-7367) and the Service's Law 

Enforcement Office (406-247-7355) will be 

notified within 24 hours of the next working day. 

•	 Implementation of the Wildlife Monitoring and 

Protection Plan (Wildlife Appendix) of the 

Powder River and Billings Resource 

Management Plans. 

•	 Power lines would be built to standards 

identified by the Avian Power Line Interaction 

Committee (1996) and additional standards as 

outlined in the Wildlife Monitoring and 

Protection Plan, to minimize electrocution 

potential. 

•	 Surveys for active raptor nests and winter roost 

sites would be conducted prior to APD approval 

within a 0.5-mile width for bald eagles and bald 

eagle nests and within a 1-mile width for roosts. 

If the proposed CBNG site is found to be within 

a nesting or winter foraging area, CBNG work 

2-16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2
 

Alternatives
 

will be halted until the nest is no longer active or 

until winter has passed and the foraging eagles 

have migrated. 

•	 BLM leasing stipulations pertaining to bald 

eagles apply and will be implemented. This
 

includes No Surface Occupancy (NSO) within 

0.5 mile of nests active in the last 7 years and 

0.5 mile of roost sites. 

•	 Raptor inventories will be conducted over the 

entire CBNG project area every 5 years by BLM 

and MFWP. 

•	 Nest productivity monitoring would be 

conducted by the BLM or a BLM approved 

biologist in areas with one or more well 

locations per section) and within 1 mile of the 

project area. Active nests located within 1 mile 

of project-related disturbance areas will be 

monitored between March 1 and mid-July to 

determine nesting success (i.e., number of 

nestlings or fledglings per nest). 

•	 A seasonal minimum disturbance-free buffer 

zone of 0.5 mile would be established for all 

bald eagle nest sites (February 15 to August 15). 

These spatial and timing restrictions may be 

adjusted based on site-specific criteria after 

written approval from the FWS. 

•	 Signing, speed limits, or speed bumps would be 

placed on all project access roads to reduce 

mortality caused by vehicle traffic. 

Mountain Plover 

•	 The FWS shall provide operators and the BLM 

with educational material illustrating and 

describing the mountain plover, its habitat needs, 

life history, threats and gas development 

activities that may lead to incidental take of 

eggs, chicks, or adults. These materials will be 

provided with the requirement that they will be 

posted in common areas, circulated in a 

memorandum and discussed among all 

employees and service providers. 

•	 If a dead or injured mountain plover is located
 

during construction or operation, the FWS
 

Montana Field Office (406- 449-5225), or the
 

Billings Suboffice (406-247-7367) and the
 

Service's Law Enforcement Office (406-247­

7355) will be notified within 24 hours of the
 

next working day.
 

•	 The BLM, FWS and MFWP will estimate 

potential mountain plover habitat across the 

CBNG area using a predictive habitat model. 

During the next 5 years, information will be 

refined by field validation using the most current 

FWS mountain plover survey guidelines (FWS 

2002c, Wildlife Appendix, Biological 

Assessment) to determine the presence or 

absence of potentially suitable mountain plover 

habitat. In areas of suitable mountain plover 

habitat, surveys will be conducted by the BLM 

or a BLM-approved biologist using the FWS 

protocol at a specific project area, plus a 0.5 mile 

buffer. Efforts will be made to identify mountain 

plover nesting areas that are not subject to 

CBNG development to be used as reference 

sites. Comparisons will be made of the trends in 

mountain plover nesting occupancy between 

these reference areas and areas experiencing 

CBNG development. 

•	 Surveys for nesting mountain plovers will be 

conducted by appropriately trained personnel if 

ground-disturbing activities are anticipated to 

occur between April 10 and July 10. A 

disturbance-free buffer zone of 1/4 mile will be 

established around all mountain plover nesting 

locations between April 1 and July 31. 

•	 No ground-disturbing activities shall occur in 

suitable nesting habitat prior to surveys 

conducted in compliance with the FWS 

Mountain Plover Survey Guidelines (FWS 

2002c or more recent version, Wildlife 

Appendix, Biological Assessment), regardless of 

the timing of the disturbance. If occupied 

mountain plover nesting habitat is located, the 

BLM shall reinitiate consultation with the 

Service on any project-related activities for such 

habitat. The amount and nature of grounddisturbing activity shall be limited within 

identified nesting areas in a manner to avoid the 

abandonment of these areas. 

Because of the potential for CBNG development to 

uncover Tribal culturally significant sites, the BLM 

would provide the tribes a copy of their annual cultural 

resources report, which would summarize CBNGrelated cultural resource activities. 

Alternative F—Phased 

Development Multiple Screens 

(High Range) 

Under this alternative, development of CBNG on 

federal leases in the Billings and Powder River RMP 

areas would be done in a phased manner through 

restrictions imposed by BLM. BLM would limit the 

number of federal APDs approved each year 

cumulatively (both state and federal APDs combined) 

and in each fourth order watershed. BLM would also 

limit the percentage of disturbance on BLMadministered surface or on private surface overlying 

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CHAPTER 2 

Alternatives 

federal minerals within each identified crucial habitat 

area. Finally, BLM would place a limit on the volume 

of untreated water discharged to surface waters from 

federal CBNG wells within each fourth order 

watershed. The fourth order watershed level was 

adopted for this alternative because it provides a 

geographic perspective consistent with the analysis 

completed for the Statewide Document and is 

appropriate for the FSEIS analysis. 

The cumulative limit placed on federal APDs would be 

based on 5 percent (910 wells) of the total number of 

state, private and federal wells (18,225 wells) predicted 

to be drilled in the Planning Area. Alternative F uses 

the high range as identified in the RFD scenario from 

the Statewide Document. This means if the total 

(private, state and federal) number of APDs issued at 

any time during a calendar year exceeded 910, then 

BLM would not issue any additional APDs that year (if 

the 910 limit were reached, APDs could still be 

submitted for review and BLM would process them up 

to the point before approval). The 5 percent limit was 

chosen to level the pace of development over a 20-year 

period and to apply a numerical limit to federal APD 

approvals. 

BLM would also limit its approval of APDs each year 

within each fourth order watershed. This limit would 

be based on the total number of wells (state, private 

and federal) predicted for each watershed times the 

predicted rate of development as identified in the 2003 

document (see Minerals Appendix, Figure Min-4). 

Therefore, cumulative APDs per year, per watershed 

would not exceed that percentage. If this percentage 

were to reduce the number of wells to below 50 wells 

per watershed, the limit would be suspended and 

50 wells per watershed would be considered the upper 

limit for the watershed that year to allow the 

opportunity to develop an economically viable project. 

BLM would also limit the amount of disturbed crucial 

habitat on BLM-administered surface or private surface 

overlying federal minerals. BLM would allow no more 

than 20 percent of any crucial habitat (e.g., crucial 

brood rearing/breeding/ wintering habitat) area to be 

directly impacted over a 20-year period. This would 

include removal of sagebrush resulting from the 

proposed project activities and other unrelated (nonCBNG) projects resulting in habitat removal 

(cumulative 20 percent). In addition, a corridor 

extending 200 meters on either side of travel routes 

with 12 or more vehicle uses per day would also be 

considered habitat directly impacted. 

In crucial sage-grouse habitat (Map 3-18), development 

would be allowed under the following conditions: 

Sage-grouse would not be displaced from crucial 

habitat. Displacement of sage-grouse may occur on a 

small scale around an individual well site. Populations 

in the crucial habitat would be compared to sagegrouse populations in predetermined areas outside of 

the CBNG development (baseline areas). Population 

trends within the CBNG development areas should be 

comparable to the baseline areas. 

The baseline areas would be identified, inventoried and 

monitored. These areas would provide a baseline or 

background dataset for comparison to the sage-grouse 

habitat within the CBNG development area. Criteria 

for selection of the baseline areas, inventory methods 

and comparison methods are discussed in the Wildlife 

Appendix. The baseline areas would encompass areas 

of similar habitat types and contain active strutting 

grounds (leks). To account for variations in 

environmental stressors such as extreme winters, fire 

and West Nile virus (WNV), a minimum of three 

discrete and geographically separate areas would be 

used to establish the sage-grouse population baseline. 

BLM recognizes that maintaining current populations 

within crucial sage-grouse habitat depends on many 

factors, including fire, agricultural practices and other 

land uses. These factors would be considered when 

evaluating monitoring data and determining whether or 

not the objectives of this alternative are met. The 

Wildlife Appendix provides a discussion of monitoring 

data that would be collected, how those data would be 

evaluated and the method for comparing populations 

within the CBNG development areas with the baseline 

areas. 

The crucial habitat areas shown on Map 3-18 are likely 

to change as more information becomes available and 

other crucial lifecycle habitat (e.g., nesting or broodrearing) is identified. These habitat areas are also likely 

to change due to wildfire and changes in land use, such 

as agriculture. 

BLM and CBNG operators would evaluate alternative 

development schemes to maximize recovery of the gas 

resource while meeting the above condition. 

Alternative development schemes could involve 

dewatering centers with widely spaced gas recovery 

wells, siting compressors outside the habitat areas and 

horizontal drilling. In addition, mitigation measures 

could be used to reduce direct impacts on sage-grouse. 

If the above conditions were met and development 

approved, retention of a sustainable sage-grouse 

population would be verified by applying the 

monitoring and data evaluation standards in the 

Wildlife Monitoring Appendix. If monitoring indicated 

sustainable sage-grouse populations were not being 

maintained, then development plans would be modified 

2-18 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2
 

Alternatives
 

or curtailed such that sustainable sage-grouse 

populations were maintained. 

The combined numerical limits for cumulative and 

watershed development, coupled with the disturbed 

habitat limit, would necessitate a varied geographical 

development pattern across the Planning Area. It is 

anticipated only a few watersheds would be developed 

in the initial 3- to 5-year period (Upper Tongue, Lower 

Tongue, Middle Powder, Little Powder), while the 

remaining watersheds would most likely be developed 

in later years. 

In addition to MPDES requirements, BLM would also 

establish a threshold for the volume of untreated water 

that could be discharged to surface waters from federal 

CBNG wells. This volume initially would be based on 

10 percent of the 7Q10 flow, calculated cumulatively 

based on MPDES permits. This is a conservative limit 

based on the volume of water that could be discharged 

under an MPDES permit without exceeding nondegradation criteria. 

The above criteria could be modified over time, as 

needed, based on monitoring data. If monitoring 

showed unacceptable impacts to surface water were 

occurring (i.e., approaching trigger values based on the 

applicable surface water standards), the amount 

allowed may be decreased; if monitoring showed 

noticeable impacts to surface water quality were not 

occurring, the amount allowed may be increased. This 

limit would apply to intermittent and ephemeral 

tributaries, as well as to main streams. Since 

intermittent and ephemeral streams have a 7Q10 of 

zero, no untreated discharge would be allowed from 

federal CBNG wells in these drainages. If state and 

private wells used the entire threshold amount, no 

discharge of untreated water produced by federal wells 

would be allowed into that drainage. All other federally 

produced water would have to be managed by other 

means (beneficial use; injection; treatment; placement 

in evaporation, infiltration, or storage pits or reservoirs; 

or other uses). 

Treated discharges are defined as those waters that 

have been treated to the applicable, in-stream surface 

water standards at the end of a pipe. Mixing of treated 

and untreated waters would be allowed and would not 

be counted towards the cumulative limit, so long as the 

end of pipe water quality met applicable in-stream 

standards. 

Within 5 miles of the Northern Cheyenne and Crow 

reservations, site-specific groundwater and air analyses 

would have to be included with the operator’s POD 

submissions. This buffer is based upon concerns of the 

Northern Cheyenne Tribe and projected groundwater 

drawdowns forecast by modeling in connection with 

the Statewide 2003 EIS. 

The operator’s analyses would have to demonstrate 

whether Indian Trust Assets and air quality would be 

impacted from development of federal CBNG wells 

and must provide protection for these assets and 

resources. If the analyses do not show protection of 

Indian Trust Assets and air quality, BLM would not 

approve the APDs. Monitoring wells and air 

monitoring stations may have to be installed between 

the development area and the reservations to monitor 

impacts and demonstrate protection. 

If monitoring indicates Indian Trust Assets and air 

quality are not being protected, mitigation measures for 

federal CBNG wells, including possible modifications 

to production, would be administered in consultation 

with the affected tribes. If CBNG development 

occurred on a reservation, this requirement may be 

modified in consultation with the tribes and other 

affected parties. The BLM restrictions would apply 

only to BLM-administered leases. Development on 

private and state leases would be managed by the 

Montana Board of Oil and Gas Conservation under 

state regulations. 

BLM would continue to implement the concept of 

adaptive management by using data from studies, 

monitoring and inspections to guide approvals of 

federal lease operations. POD requirements, the use of 

state and federal permits, lease stipulations, surface 

owner agreements and other management actions, as 

described in Alternative E, would also be features of 

this alternative. 

This alternative also requires each CBNG proposal 

with a density greater than one well per 640 acres 

include a water rationale section in the water 

management plan. The water rationale section must 

include a brief discussion of various water management 

options. At a minimum, these options must include 

discharge with and without treatment, beneficial use 

and injection and reinjection options. The discussion 

must include the advantages and disadvantages of 

implementation and operation, the effectiveness and 

the projected quantity of water that may be managed 

under each option. For example, the injection of 

produced water into the same aquifer or other usable 

shallow water aquifers has been analyzed to determine 

if it is feasible within the proposed project area or in 

another area chosen by the operator/lessee. The water 

rationale section would have to show why injection is 

not feasible, if this is the case. It would also have to 

show the percentage of produced water that could be 

injected, if feasible. Following this disclosure, the 

approach the developer proposes to use would be 

presented in detail. 

2-19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

Alternative G—Phased 

Development Multiple Screens 

(Low Range) 

Under this alternative, development of CBNG on 

federal leases in the Billings and Powder River RMP 

areas would be done following the same management 

actions as described under Alternative F; however, 

development would be limited to the low range of 

predicted wells (6,470) from the RFD. Therefore, the 

following would be applied under Alternative G: 

• Annual cumulative limit (5 percent or 325 

APDs/year) 

• Fourth order watershed rate of development 

• Wildlife habitat (20 percent over 20 years) 

• Crucial sage-grouse habitat conditions 

• Untreated produced water (10 percent of 7Q10) 

thresholds 

• Reservation buffer distance (5 miles) 

• Principles of adaptive management 

• POD requirements 

• State and federal permits and lease stipulations 

• Discussion of a range of water management 

options 

The low range of development, as described in the 

RFD, was developed following the same assumptions 

as the high range. 

Alternative H—Preferred 

Alternative - Multiple Screens 

Alternative H is BLM’s preferred alternative for 

managing the development of CBNG resources on 

BLM-administered lands. Development in the Billings 

and Powder River RMP areas would be done in a 

phased manner through restrictions imposed by BLM. 

The phased approach is intended to reduce the overall 

cumulative impacts to any resource by managing the 

pace and place as well as the density and intensity of 

federal CBNG development. In addition to the standard 

POD review, four evaluation screens for water, 

wildlife, Native American concerns and air would be 

applied. The screens would be used when reviewing 

proposals to identify impacts, develop mitigation 

measures and guide the decisionmaking process. 

Figure 2-1 illustrates the process BLM would follow 

when reviewing PODs. This process involves 

reviewing the POD, making a permit decision, 

monitoring and assessing impacts and adjusting 

operations, implementing mitigation measures and 

reviewing thresholds. Thresholds would be adjusted 

when monitoring data justified a change (e.g. see 

"sage-grouse" in the Monitoring Appendix and the 

WMPP in the Wildlife Appendix. 

Slower development rates (fewer wells approved and 

drilled each year) may extend the overall time required 

for extraction of the CBNG resources. If monitoring 

data indicate impacts to resources are being mitigated, 

the pace of development could increase. 

The following would be applied under Alternative H. 

• Wildlife crucial habitat (maintain source 

population) 

• Untreated produced water (10 percent of 7Q10 

thresholds) 

• Discussion of a range of water management 

options 

• Reservation buffer distance (5 miles) 

• Principles of adaptive management 

• POD requirements 

• State and federal permits and lease 

BMPs/conditions of approval (COAs) 

Water Screen 

BLM recognizes MDEQ has the lead role in managing 

water resources. BLM would coordinate all water 

monitoring efforts with MDEQ. While Onshore 

Order 7 reinforces BLM's approval authority for 

produced water disposal, it does not provide BLM with 

primacy for the management of water within the state 

of Montana. Therefore, BLM would apply the water 

quality screen in close coordination and under the lead 

of MDEQ. Close coordination would avoid duplication 

of effort and ensure each agency fulfilled its roles 

relative to resource management. 

If proposed untreated discharges within a watershed are 

projected to exceed 10 percent of the 7Q10, BLM 

would coordinate with MDEQ to prepare an annual 

cumulative surface water monitoring report for that 

watershed. This report would incorporate The U.S. 

Geological Survey (USGS) and Discharge Monitoring 

Report (DMR) data collected within that watershed and 

evaluate the data against the applicable surface water 

quality standards. USGS collects data on a wide variety 

of parameters and DMRs are required for discharges to 

surface waters under MPDES permits. MDEQ 

determines the parameters reported in DMRs. If the 

results of analysis indicate CBNG discharges have the 

potential to cause exceedances of surface water quality 

standards, BLM would coordinate with MDEQ to 

2-20 
 

 

FIGURE 2-1 PREFERRED ALTERNATIVE – DECISION FLOW CHART 

CH

A

P

T

ER 2

Alternatives

2-21

Operator Submits Plan of 

Development (POD) 

BLM requires significant 

information for appropriate 

analyses. 

Will POD 

exceed 

screening 

thresholds? 

Attach Mitigation to POD 

POD Modifications 

Conditions of Approval 

Mitigation Measures 

Voluntary Mitigation 

No 

Approve POD 

No 

Modify Production Operations 

Production Suspensions 

Limiting Water Discharges 

Retrofit Compressor Motors 

Stakeholder Recommended Measures 

Or 

Conduct Consultation 

Tribes 

State Historic Preservation Office 

U.S. Fish Wildlife Service 

Prepare 

Environmental 

Analysis 

No 

Yes 

Ongoing 

quantification of

cumulative impacts

and evaluation of 

thresholds 

Screen PODS against 

Resource Specific Thresholds1 

Air Quality 

Wildlife 

Water Quality/Quantity 

5-mile Reservation Buffer 

Adjust 

Thresholds 

and Apply 

new BMPs 

Are 

modifications 

needed? 

Are 

modifications 

needed to 

operations or 

thresholds? 

Yes 

Yes 

Return to Operator 

1 Thresholds are displayed in the Monitoring Appendix. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

develop appropriate mitigation measures to prevent 

exceedances. 

In addition, if surface water monitoring indicated 

permitted levels of CBNG discharge would have a 

potential to cause water quality standards to be 

exceeded, no future untreated discharge of CBNG 

water would be allowed from federal wells unless the 

regional surface water monitoring stations above and 

below the proposed discharge were active. If CBNG 

discharges caused surface water quality standards or 

land health standards (i.e., excessive erosion) to be 

exceeded, even if discharges did not exceed the 10 

percent of 7Q10 threshold, no additional CBNG 

discharges would be allowed from federal wells 

upstream of the exceedances. 

Previously approved water management plans would 

be modified if monitoring indicated unacceptable 

impacts were occurring. Surface water monitoring 

requirements are detailed in the Monitoring Appendix. 

Wildlife Screen 

To meet the objectives of conserving wildlife habitat 

and the sagebrush steppe/mixed grass prairie complex 

in the FSEIS planning area, BLM would implement 

adaptive management based on available science and 

monitoring information. BLM would require BMP 

measures and alternative development schemes as 

permit COAs. See the WMPP in the Wildlife Appendix 

for the current list of specific COAs and BMPs. BLM 

would work with CBNG operators, surface owners, 

Native American tribes, FWS and MFWP to identify 

any additional protection measures necessary. On split 

estate lands, BLM recognizes that achieving the 

objectives of this alternative would require cooperation 

with surface owners. 

All Wildlife Species 

Data on potentially impacted wildlife habitat would be 

provided before, or in association with, the operator's 

POD. The POD would clearly identify how 

development activities would be designed to minimize 

impacts to wildlife habitat and maintain wildlife 

populations within the proposed POD area. 

To help protect wildlife species that rely seasonally or 

year-long on crucial habitats (e.g., mule deer, 

pronghorns, sage-grouse, other sagebrush obligates), 

BLM would manage disturbance in such crucial 

habitats (e.g., crucial brood rearing, breeding and 

wintering habitat) where federal mineral ownership 

occurs. Crucial habitat for additional species, 

particularly Tier 1 species identified in the Montana 

Comprehensive Fish and Wildlife Strategy (2005d), 

may be identified and existing crucial habitats may be 

modified based on additional habitat monitoring 

surveys, wildlife population surveys and other 

information provided by industry, BLM and MFWP. 

With more information, the crucial areas may be 

modified or new areas identified. If crucial habitats are 

identified for species not presently addressed in this 

plan, additional environmental analysis and planning 

may be necessary. 

Monitoring is described in the WMPP (including the 

defined methodology, responsibility and frequency). 

To use adaptive management and make meaningful 

determinations on the impact of development on 

wildlife habitat, up to 10 years of monitoring may be 

needed (see the Wildlife and Monitoring appendices). 

If science and monitoring indicate changes in 

development practices are warranted, these changes 

will be coordinated with MFWP. 

BLM’s management actions would be designed to 

affect the location and timing, as well as the density 

and intensity, of CBNG activities. Management may be 

modified if science and/or monitoring data indicate a 

change in wildlife species populations within crucial 

habitats on or adjacent to POD areas. For example, 

authorizations would not be given, or the pace of 

development would be restricted in crucial habitat 

areas that approach or exceed population change 

thresholds. Other examples of management actions 

BLM could impose include reducing the number of 

seasonal and/or yearlong authorized vehicle trips in 

existing areas of development, securing road access to 

limit vehicles not associated with development and 

modifying reclamation requirements for disturbed sites. 

If the population trend is downward, but has not yet 

reached the threshold, interim changes in management 

could occur. Similarly, if populations remain consistent 

with adjacent trend areas or increase, development may 

be less restricted, or the pace of development could be 

increased. Other factors such as wildfire, agricultural 

practices, recreational activities and disease would also 

be considered in determining the management for 

crucial habitat areas. 

For mule deer and pronghorn habitat, the following 

thresholds would be used to initiate change: 

• A 30 percent or more decline (based on MFWP 

adaptive harvest thresholds) in mule deer or 

pronghorn populations over a 3-year period 

relative to baseline and/or adjacent populations. 

Similarly, if populations remained consistent with 

adjacent trend areas or increase, development may 

be less restricted. 

• Sage-grouse: See Sage-grouse Habitat Section. 

These population thresholds, as well as population 

thresholds for other species, may be modified or 

established prior to POD approval based on relevant 

science, as well as suggestions from agency partners 

such as MFWP and FWS. 

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CHAPTER 2
 

Alternatives
 

Sage-Grouse Habitat 

The general approach described in the All Wildlife 

Species section would also apply to sage-grouse 

habitat. Additionally, BLM would manage sage-grouse 

habitat to meet the following objectives: 

•	 Maintain the connectivity of habitats. 

•	 Manage habitat to maintain healthy sagegrouse populations to serve as source 

populations. 

•	 In crucial habitat areas, maintain sage-grouse 

habitat so that population trends follow the 

general magnitude of decline or increase on 

control leks. Changes in management of 

future development would occur if male 

attendance on leks within two miles of CBNG 

development declines by 25 percent over a 5­

year increment. Changes may also be made if 

lesser declines occur in a period of less than 5 

years, when compared with predetermined 

control leks. Management actions would 

include not authorizing or limiting the number 

of federal well sites, roads and infrastructure 

and not authorizing or restricting the timing of 

operations conducted on federal leases. 

Similarly, if populations remained comparable 

with the control leks or increase over a 5-year 

monitoring period, management of 

development may be modified to be less 

restrictive, or the pace of development may be 

increased. 

o These thresholds could be further refined 

before POD approval based on monitoring, 

relevant science, as well as suggestions from 

o When development is proposed within 

agency partners such as MFWP and FWS. 

crucial sage-grouse habitat, BLM would 

rely on science, professional judgment and 

monitoring data to determine the acceptable 

level of disturbance. 

The objectives for crucial sage-grouse habitat would be 

to maintain sage-grouse populations on the northern 

end of the Powder River Basin, encourage genetic 

diversity, permit genetic exchange with other 

populations and ensure source populations would 

remain available for areas where sage-grouse may have 

been reduced or displaced due to CBNG development 

or other factors. 

Sage-grouse habitat (leks, nesting, brood rearing and 

wintering) outside the crucial sage-grouse habitat 

boundaries would be managed to maintain connectivity 

by reducing habitat fragmentation. Management would 

focus on minimizing disturbance on seasonal habitats. 

BMPs would be used to minimize surface disturbance 

and these measures may be the basis for COAs. If 

management actions, COAs and/or BMPs were 

insufficient or overly restrictive, BLM would make the 

needed changes in order to maintain sage-grouse 

populations. Science and monitoring data would 

provide the basis for formulating alternative 

development scenarios and decisions would be 

coordinated with MFWP. 

To meet the objectives for sage-grouse habitat 

management, PODs would have to demonstrate 

specific actions to conserve sage-grouse. Actual 

placement of wells would depend on the operator's 

ability to outline a strategy where effects to sagegrouse would be minimized and where sage-grouse 

would not be displaced from any of the crucial habitat 

as a result of these actions. The following examples 

illustrate such a situation: 

• Within 1 mile of a lek, surface disturbance 

proposals would be sited to meet objectives for 

sage-grouse habitat management, including: avoid 

the loss of sagebrush, especially in linear routes 

(roads, flowlines and buried powerlines); avoid 

installation of perching structures; and keep noise 

disturbance levels at leks to less than 10 decibels 

above background noise on active leks. Special 

attention would be paid to proposals that would 

result in increased human presence, opportunities 

for increased predation, or loss of nesting and 

brood rearing habitat and function. This would not 

necessarily translate into no development within 1 

mile of a lek, but would suggest special attention 

should be paid to features resulting in increased 

human presence, opportunities for increased 

predation and loss of nesting and brood rearing 

habitat and function. 

• Proposals for storage ponds or produced water 

discharge into vegetated drainages in summer 

sage-grouse habitat would be designed to 

minimize the potential for outbreaks of WNV. 

• The operator would be required to map and avoid 

seasonal habitats when proposing placement of 

infrastructure. 

Crucial habitat areas have been identified in only a 

portion of the FSEIS planning area. BLM would 

continue to identify crucial habitat areas. New areas 

would be managed per this section. As research and 

monitoring continue, BLM and partners may develop 

new COAs and BMPs to supplement those already 

contained in the WMPP and other BLM publications. 

Native American Concerns Screen 

The Crow and Northern Cheyenne tribes consider 

groundwater and air to be critical resources for their tribal 

health and welfare. Tribal CBNG is an Indian Trust Asset. 

Groundwater is used on the reservations for stock watering 

and drinking water supplies. The tribes highly value air 

2-23 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

resources, as well. In response to these concerns, BLM 

would require federal lease operators to protect 

groundwater, CBNG and air quality. 

For proposed federal CBNG development within 5 

miles of the Northern Cheyenne and Crow 

reservations, BLM, in consultation with the tribes, 

would require site-specific groundwater and air 

analyses (see Northern Cheyenne Mitigation Appendix 

for details). These analyses would be submitted as part 

of the operator’s POD submissions. The operator’s 

analyses must demonstrate development associated 

with the proposed POD would be protective of Indian 

Trust Assets (groundwater and CBNG) and air quality. 

BLM could disapprove additional CBNG APDs if 

available monitoring and air modeling of new 

proposals indicated effects that violate state or federal 

regulatory standards. In such cases BLM would first 

consider mitigation measures that would reduce 

impacts so that actions would comply with such 

standards. If implementation-level analyses indicate 

that unacceptable levels of impairment to these 

resources would occur and could not be mitigated, 

BLM would not approve the APDs. Unacceptable 

levels of impairment to the resources would be 

determined in consultation with the affected tribe(s) 

and the State of Montana, as appropriate. BLM may 

require operator(s) to install groundwater monitoring 

wells and air monitoring stations between the 

development area and the reservations to confirm the 

initial findings of the analyses. Modeling and 

monitoring groundwater would also provide critical 

data to determine if CBNG or resources were being 

affected. 

As development proceeded, BLM would monitor the 

effects to air, water and other resources of concern to 

the Native American tribes. BLM would approve 

additional APDs only if available monitoring and 

evaluation of new proposals indicated effects would 

not exceed state or federal regulatory standards and 

were not substantially greater than those anticipated in 

the FSEIS (see Chapter 4 and Table MON-1 in the 

Monitoring Appendix.) 

BLM would consult with affected tribes when 

operator’s proposed actions were near American Indian 

traditional cultural properties, such as the Rosebud 

Battlefield, the Wolf Mountain Battlefield, 

Weatherman Draw and Sacrifice Cliffs. Consultation 

could result in mitigation of impacts to traditional 

cultural properties. 

Air Quality Impact Screen
 

MDEQ has permitting authority over emission sources. 

EPA has permitting authority in the adjacent areas of 

Indian Country. BLM would conduct an annual review 

of available monitoring data collected in designated 

Class I areas (Northern Cheyenne Reservation) and 

federally mandated Class I areas (wilderness areas) 

within the Montana portion of the Powder River Basin. 

In addition, MDEQ has agreed to complete an annual 

cumulative air quality impact model to track air quality 

impacts of CBNG development, including relevant 

CBNG development in Wyoming. The MDEQ requires 

all major sources (>25 tons/year) and all oxides of 

nitrogen (NOx) emitting sources, in counties which 

make up the CBNG development area, to perform nearfield air quality modeling. An evaluation of potential 

cumulative effects for each proposed air quality permit 

is also required (see description of Additional Air 

Quality Modeling Studies in Chapter 3 of the FSEIS) 

If observed effects and modeled impacts completed for 

the annual review by MDEQ show state or federal 

regulatory standards or applicable thresholds for air 

quality related values would be exceeded, BLM would 

require additional mitigation measures on 

development. BLM could disapprove additional CBNG 

APDs if available monitoring and air modeling of new 

proposals indicated effects that violate state or federal 

regulatory standards. In such cases BLM would first 

consider mitigation measures that would reduce 

impacts so that actions would comply with such 

standards.. 

To minimize potential air impacts from CBNG 

operations, the number of wells connected to each 

compressor would be maximized and natural-gas-fired 

or electrical compressors or generators would be 

required. When compressors or generators were located 

close to noise sensitive areas (such as occupied 

residences or sage grouse strutting grounds), a 

maximum noise level of 50 decibels measured 0.25 

miles from the compressor would be required, except at 

sage-grouse leks. At sage-grouse leks, no more than 10 

decibels above background measured at the lek would 

be required. 

To reduce dust, operators of federal leases would have 

to post and enforce speed limits for their employees 

and contractors. Operators would work with local 

government to use dust suppression techniques on 

roads. 

Given the potential for the level of development to 

vary, BLM and MDEQ would perform additional 

visibility modeling to better assess the visibility 

impacts as development proceeds (e.g., when 

exploration programs help define the limits of 

development within the Montana portion of the Powder 

River Basin). The potential for project wells to impact 

visibility is due to emissions of sulfur dioxide and 

oxides of nitrogen from compressor engines. The total 

potential for emissions of oxides of nitrogen from 

2-24 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2
 

Alternatives
 

compressor engines is based on horsepower 

requirements, which for the high-end development 

scenario of 18,225 project wells drilled would be 

297,680 horsepower. The visibility modeling would be 

performed when horsepower requirements for CBNG 

wells in the Montana portion of the PRB exceed 

133,956. Current modeling results indicate 0 days of 

visibility impacts would occur on the Class I Northern 

Cheyenne area up to a horsepower level of 148,840. 

BLM has selected 90% of this value as the visibility 

screening threshold to ensure appropriate actions can 

be taken in time to mitigate visibility impacts, if 

needed. The Class I Northern Cheyenne area was 

selected as the “trigger Class I area” due to its 

proximity to the CBNG development, and the 

sensitivity to CBNG development of this Class I area 

when compared to other Class I areas in the region. 

The visibility modeling effort would provide an 

updated prediction for future impacts and assumptions 

would be verified or modified to properly characterize 

actual conditions and technological changes. The 

conditions that may change or become more certain as 

development proceeds include: 

• The total number and type of wells (type – 

single zone completion vs. multi-zone or 

commingled completions). 

• The pace of development. 

• BACT and the effect on compressor emission 

rates. 

• Compressor locations. 

• Compressor to well ratios. 

• Limits of high development potential 

If this subsequent modeling work indicates 

unacceptable impacts would occur at a future point in 

the PRB development, the modeling work would then 

include mitigation scenarios that would investigate 

mitigation measures. Mitigation efforts would focus on 

compressor motors and the extent of operating 

compressors because it appears that gas-fired 

compressor motors account for approximately 90% of 

the overall project emissions and visibility impacts. 

Standard Operating Procedures and 

Best Management Practices 

BMPs would be used, as appropriate, in CBNG 

development. BMP guidance is found in the Western 

Governors' Association April 2006 “Coal Bed Methane 

Best Management Practices,” the “Surface Operating 

Standards for Oil and Gas Exploration and 

Development, Fourth Edition” (Gold Book) and BLM's 

national web site at http://www.blm.gov/bmp. The 

EPA has also developed BMPs for the prevention of 

methane emissions which are known as the Gas STAR 

BMPs. The Gas STAR BMP guidance is found at 

http://www.epa.gov/gasstar. 

In addition to applying BMPs, CBNG operators would 

submit a project POD outlining the proposed 

development of an area when requesting CBNG well 

densities greater than one well per 640 acres. The 

project POD would be drafted in consultation with the 

affected tribes, affected surface owner(s) and 

permitting agencies. 

POD Requirements 

A complete project POD consists of the following: 

• Master Drilling Plan 

• Master Surface Use Plan 

• Water Management Plan 

• Cultural Resource Inventory Plan or completed 

inventory 

• Wildlife Monitoring and Mitigation Plan 

• Reclamation Plan for surface disturbance 

• Digital project maps depicting all infrastructure 

installations necessary for the project, etc. 

• Applications for Permits to Drill (form 3160-3) 

for each federal well 

• List of all permitting agencies involved 

• Certification of surface use and water well 

mitigation agreements 

• A cover letter naming the project area and 

requesting approval 

• A list of all known existing wells in the project 

area, including monitoring wells 

• A list of all potentially affected surface owners 

within the project area 

• Any additional information required by the rules 

of MBOGC 

See Alternative E for a full description of each POD 

component. 

Individual well APDs (those located at one well per 

640 acres) would be accepted and processed without a 

project POD in accordance with requirements of 

Onshore Order 1. A project POD would be required 

before processing and approving APDs for multiple 

wells from an operator in the same geographic area. 

BLM would approve the project POD and individual 

APDs once they were technically and administratively 

complete and had met all BLM requirements. 

On-site inspections would be conducted at the 

proposed federal well sites and associated 

2-25 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2
 

Alternatives
 

infrastructure before any ground-disturbing actions 

were approved. 

PODs that include development within the crucial 

sage-grouse habitat areas must include information that 

clearly demonstrates how the proposal would not 

displace sage-grouse from this habitat. This 

information would be based on recent research and 

science, monitoring data and may also include 

alternative development schemes within these habitat 

areas. 

Wells and Well Pads 

CBNG well spacing rules are set by the MBOGC on 

state and private lands and on federal lands as specified 

in the Memorandum of Understanding between BLM 

and MBOGC; however, MBOGC has no authority on 

Indian lands. A wellpad may contain multiple wells 

(one well per coal seam), or a single well could open 

across multiple seams. Wells may be directionally or 

vertically drilled, depending on the surface location 

and desired bottomhole location. 

Coal Mines 

There would be no buffer zone excluding CBNG 

production around active coal mines (BLM-IM-2006­

153, May 11, 2006). BLM advocates the extraction of 

oil and gas resource, including methane, before mining 

and promotes the development of multiple mineral 

resources. 

Roads, Pipelines and Other Infrastructure 

Corridors would be required for placement of roads, 

pipelines and utility lines in a common area of 

disturbance wherever possible. Proposed roads, 

pipeline routes and utility line routes would be located 

to follow existing routes, or areas of previous surface 

disturbance, or to minimize disturbance to important 

habitats, where possible. In the POD, the operator 

would also address how the surface owner, BLM and 

adjacent oil and gas operators and infrastructure 

companies were consulted for input into the location of 

roads, pipelines and utility line routes. 

There would be minimal road construction. Before 

approving a road, the operator, landowner, BLM and 

adjacent landowners and gas leaseholders would 

coordinate long-term planning for roads in the area. 

Discussions with affected parties would take place to 

help meet the transportation corridor requirement to 

minimize new roads. 

Low-voltage (440-v) distribution powerlines would be 

buried. The authorized officer (AO) could approve 

proposed high-voltage, aerial powerlines by 

application. The AO would approve above-ground, 

low-voltage distribution powerlines only if the operator 

could demonstrate it would not be feasible or would be 

impractical to bury them (technically impossible, etc.). 

All aerial powerlines would be constructed according 

to the Avian Power Line Interaction Committee 

(APLIC) Guidelines, 1996. 

Produced Water Management 

A water management plan (WMP) would be required 

for exploratory wells and for each project POD. The 

WMP would be submitted with the APD(s). The WMP 

must comply with all federal, state and local laws and 

regulations, including the Clean Water Act, the 

Montana Water Quality Act and Onshore Order 7. The 

WMP must be prepared in accordance with the Miles 

City CBNG POD Guidebook. The basic elements of a 

WMP would include the following: 

• Water quality data for the produced water 

• A copy of any needed discharge or injection 

permit(s) or applications for such permits 

• Applications for unlined impoundments proposed 

as part of the Water Management Plan that must 

demonstrate that the infiltration of water would 

not degrade the quality of surface or subsurface 

waters in the area (Onshore Oil and Gas Order 

No. 7, Section III.D.2.) 

• A water balance projection showing the 

anticipated rate of water production over time, the 

proposed water management practices (preferably 

beneficial uses) and the amount of water that 

would be managed by each of the practices over 

time 

The operator would have to list the water management 

options available and provide a brief rationale for using 

or not using each method. At a minimum, injection; 

treatment; surface discharge; the use of infiltration, 

storage, or evaporation pits or reservoirs; and 

beneficial uses, such as wildlife and livestock watering, 

dust control and managed irrigation, would have to be 

addressed. 

Wildlife Monitoring Program and Mitigation 

Measures 

On BLM-administered lands, impacts to wildlife would 

be monitored and addressed following procedures in 

the WMPP, in addition to applying mitigating 

measures that are part of the standard APD review and 

approval process. Impacts to wildlife, including those 

species on public lands and adjacent to reservations, 

would be monitored and addressed in accordance with 

the WMPP (see Wildlife Appendix). 

2-26
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Bald Eagles 

• If a dead or injured bald eagle were located 

during construction or operation, the FWS 

Montana Field Office (406-449-5225) or 

the Billings Suboffice (406-247-7366) and 

the Service’s Law Enforcement Office 

(406-247-7355) would be notified within 24 

hours of the next working day. 

• The WMPP (Wildlife Appendix) of the 

Powder River and Billings Resource 

Management Plans would be implemented. 

• Surveys for active bald eagle nests and 

winter roost sites would be conducted 

before APD approval. Surveys would be 

conducted within a 0.5-mile radius of 

proposed development for bald eagles and 

their nests and within a 1-mile radius for 

roosts. If the proposed CBNG site were 

found to be within a nesting or winter 

foraging area, CBNG related activities 

would be halted until the nest was no longer 

active or until winter had passed and the 

foraging eagles had migrated. 

• The BLM leasing stipulations pertaining to 

bald eagles would apply and would be 

implemented. This would include NSO 

within 0.5 mile of nests active within the 

past 7 years and 0.5 mile of roost sites. 

• Raptor inventories including bald eagles 

would be conducted over the entire CBNG 

project area every 5 years by BLM and 

MFWP. 

• Nest productivity would be conducted by 

BLM or a BLM-approved biologist in areas 

with one or more well locations per section 

and within 1 mile of the project area. Active 

nests within 1 mile of project-related 

disturbance areas would be monitored 

between March 1 and mid-July to determine 

nesting success (i.e., number of nestlings or 

fledglings per nest). 

• A seasonal, minimum-disturbance-free 

buffer zone of 0.5 mile would be 

established for all bald eagle nest sites 

(February 15 to August 15). These spatial 

and timing restrictions may be adjusted 

based on site-specific criteria with written 

approval from FWS. 

• Signing, speed limits, or speed bumps 

would be placed on all project access roads 

to reduce mortality caused by vehicle 

traffic. 

CHAPTER 2 

Alternatives 

Mountain Plover 

Listing the mountain plover under the Endangered 

Species Act (ESA) is not warranted at this time. 

BLM would continue monitoring to help prevent 

the bird from being listed in the future. 

•	 FWS would provide operators and BLM 

with educational material illustrating and 

describing the mountain plover, its habitat 

needs, life history, threats and gas 

development activities that may lead to the 

incidental taking of eggs, chicks, or adults. 

These materials would be provided with the 

requirement they be posted in common 

areas, circulated in a memorandum and 

discussed among employees and service 

providers. 

•	 If a dead or injured mountain plover were 

located during construction or operation, the 

FWS Montana Field Office (406- 449­

5225) or the Billings Suboffice (406-247­

7367) and the Service's Law Enforcement 

Office (406-247- 7355) would be notified 

within 24 hours of the next working day. 

•	 BLM will determine the acreage of 

occupied black-tailed and white-tailed 

prairie dog habitat within suitable mountain 

plover habitat on federally managed surface 

and mineral estate lands. Further, a 

reasonable effort should be made to 

estimate the actual impacts, including 

habitat loss, CBNG development will have 

on occupied black-tailed and white-tailed 

prairie dog acres within suitable mountain 

plover habitat over the entire project area. 

The BLM, FWS and cooperators will 

develop a survey protocol that may include 

prioritization of subsets of the project area 

to be analyzed. 

•	 In areas of suitable mountain plover habitat, 

surveys would be conducted by BLM or by 

a BLM-approved biologist using the FWS 

protocol at a specific project area, plus a 0.5 

mile buffer. Efforts would be made to 

identify mountain plover nesting areas not 

subject to CBNG development to be used as 

reference sites. Comparisons would be 

made of the trends in mountain plover 

nesting occupancy between these reference 

areas and areas experiencing CBNG 

development. 

•	 Surveys for nesting mountain plovers would 

be conducted by appropriately trained 

personnel if ground-disturbing activities 

were anticipated to occur between April 10 

and July 10. A disturbance-free buffer zone 

2-27 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

of 0.25-mile would be established around 

all mountain plover nesting locations 

between April 1 and July 31. 

• No ground-disturbing activities would occur 

in suitable nesting habitat before surveys 

were conducted in compliance with FWS’s 

Mountain Plover Survey Guidelines (FWS 

2002c or more recent version, Wildlife 

Appendix and Biological Assessment), 

regardless of the timing of the disturbance. 

The amount and nature of grounddisturbing activity must be limited within 

identified mountain plover nesting areas in 

a manner to avoid the abandonment of these 

areas. 

Sage-grouse 

• BLM and cooperators, including MFWP 

will conduct sage-grouse lek inventories 

over the CBNG project area with high 

potential for development every five years. 

Surveys of different areas may occur during 

different years, with the high potential 

CBNG project areas surveyed at least every 

five years. Inventories and protocol will be 

consistent with the Montana Sage Grouse 

Conservation Plan, coordinated by the 

BLM and MFWP. In areas of development, 

aerial or ground inventories will be 

conducted annually on affected sections, 

two mile buffers and selected undeveloped 

reference areas. Surveys may be conducted 

aerially or on the ground, as deemed 

appropriate by the BLM and MFWP. 

Operator may provide financial assistance. 

• Reference leks are leks located in similar 

habitat and within close proximity to areas 

currently being developed. These “reference 

leks” will be identified by BLM and 

MFWP. 

• Aerial or ground surveys will be used for 

determining lek locations. BLM, MFWP or 

BLM-approved Operator-financed biologist 

will monitor sage-grouse lek attendance 

within two miles of areas of development, 

such that all leks on these areas are 

surveyed annually. Data collected during 

these surveys will be recorded on BLM and 

MFWP approved data sheets and entered 

into the approved database. The number of 

males/lek in areas of development will be 

compared to reference leks. 

• Sage-grouse winter use surveys of suitable 

winter habitat within two miles of a project 

area will be coordinated by the BLM and 

conducted by the BLM and/or MFWP 

during November through February as 

deemed appropriate by these agencies. 

Results will be provided in interim and/or 

annual reports. Historical information of 

winter sage-grouse locations will be useful 

in focusing efforts in areas suspected of 

providing winter habitat. 

Big Game 

Elk, mule deer, white-tailed deer and pronghorn 

are the common big game species that occur 

within parts or all of the CBNG planning area. 

BLM and/or MFWP will collect annual big 

game seasonal habitat use data and make it 

available to operators, Tribes and landowners. 

Big game use of seasonal habitats is highly 

dependent upon a combination of environmental 

factors including terrain, forage quality and 

snow depth. Therefore, it is difficult to attribute 

changes in habitat use to a single factor. 

Comparisons in trends between big game 

seasonal habitat reference areas and seasonal 

habitats associated with CBNG development 

may provide some insight into the response of 

big game to CBNG development. 

Comparison of Alternatives 

The differences between alternatives by development 

theme are shown in Table 2-2. The variations for 

development by theme are compared for the eight 

alternatives carried forward for detailed analysis. 

A range of potential issues affecting development has 

been analyzed in the context of the themes described 

for each alternative. The comparison focuses on the 

various techniques typically used to develop CBNG 

fields. The variations between alternatives reflect the 

different potential drilling technologies, water disposal 

methods, transportation corridor construction, 

compressor engines, socioeconomic issues, etc. These 

alternatives represent the majority of development 

techniques commonly used with CBNG operations. 

There are general and specific assumptions as to 

percentages of use per theme within each alternative. 

These assumptions are presented in Chapter 4, 

Environmental Consequences. 

Table 2-3 shows a comparison summary of the impacts 

expected under each alternative. 

2-28 
 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-2 

ALTERNATIVE MANAGEMENT FOR CBNG 

Alternative E—CBNG 

Alternative B— Exploration and 

CBNG Development Alternative D— Development with 

with Emphasis on Encourage CBNG Enhanced Mitigation to Alternative F (High 

Soil, Water, Air, Exploration and Minimize Environmental Range) & Alternative Alternative H— 

Alternative A— Vegetation, Wildlife Alternative C— Development While Impacts While G (Low Range)— Preferred 

No Action (Existing and Cultural Emphasize CBNG Maintaining 

Issue Topic Management Action CBNG Management) Resources Development Existing Land Uses Land Uses Multiple Screens Multiple Screens 

Maintaining Existing Phased Development Alternative ­

Air Maximize the number of 

wells connected to each 

compressor 

No Yes No Yes Yes Yes Yes 

Type of fuel to power 

compressors 

Diesel, electric, or gasfired 

Gas-fired Diesel, electric, or 

gas-fired 

Gas-fired with 

electric boosters 

Gas-fired or electric 

boosters 

Gas-fired or electric 

boosters 

Gas-fired or electric 

boosters 

Noise suppression 

required 

No No No No Yes Yes Yes 

Implementation of a 

speed limit on CBNG 

roads on BLM 

No Yes No Yes Yes Yes Yes 

Air permit analysis Yes Yes Yes Yes Yes Yes Yes 

Air screen No No No No No No Yes 

Bonding 43 CFR 3104 - BLM to 

set amount based on 

several factors. 

Yes Yes Yes Yes Yes Yes Yes 

Section 9 SRHA Yes Yes Yes Yes Yes Yes Yes 

Coal Mines Buffer zone (1 mile) 

around active coal mines 

No Yes No Yes No No No 

Coal Bed 

Natural 

Gas 

APD to be filed and 

approved prior to drilling 

CBNG exploration limits 

Yes 

Yes 

Yes 

No 

Yes 

No 

Yes 

No 

Yes 

No 

Yes 

No 

Yes 

No 

CBNG production limits Yes No No No No Yes, based on 

watershed level 

resource analysis 

Yes, based on four 

screens 

2-29 
 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-2 

ALTERNATIVE MANAGEMENT FOR CBNG 

Alternative E—CBNG 

Alternative B— Exploration and 

CBNG Development Alternative D— Development with 

with Emphasis on Encourage CBNG Enhanced Mitigation to Alternative F (High 

Soil, Water, Air, Exploration and Minimize Environmental Range) & Alternative Alternative H— 

Alternative A— Vegetation, Wildlife Alternative C— Development While Impacts While G (Low Range)— Preferred 

No Action (Existing and Cultural Emphasize CBNG Maintaining 

Issue Topic Management Action CBNG Management) Resources Development Existing Land Uses 

Maintaining Existing 

Land Uses 

Phased Development 

Multiple Screens 

Alternative ­

Multiple Screens 

Coal Bed 

Natural 

Gas (cont.) 

Project POD required in 

consultation with tribes, 

surface owners and other 

agencies 

No No No No Yes Yes Yes 

Directional drilling 

required 

No Yes No Yes Yes, unless exempted Yes, unless exempted No 

Multiple coal seams 

developed per well bore 

required 

No Yes No Yes No No No 

Simultaneous coal seam 

development required 

No Yes No Yes No No No 

Wellhead camouflage 

required by BLM 

No No No Yes Yes Yes Yes 

Hydrology Exploration water 

disposal 

Untreated and stored, 

except for CX Ranch 

Untreated and stored Untreated surface 

discharge 

Treated and 

conveyed 

Exploration WMP required Exploration WMP 

required 

Exploration WMP 

required 

Production water disposal CX Ranch only Injection Untreated surface 

discharge 

Treated and 

conveyed 

Various methods WMP 

required 

Water screen (10% of 

7Q10) WMP required 

Water screen (10% 

of 7Q10) WMP 

required 

Site-specific WMP 

required 

Yes No No No Yes Yes Yes 

Exploration/production 

water available for 

beneficial use 

Yes No Yes Yes Yes Yes Yes 

Ponds (evaporation, 

infiltration, holding) 

No Lined holding only Yes Yes Yes Yes Yes 

Water balance projection 

included in POD 

No No No No Yes Yes Yes 

West Nile Virus 

management mitigation 

required 

No No No No No No Yes 

2-30 
 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-2 

ALTERNATIVE MANAGEMENT FOR CBNG 

Alternative E—CBNG 

Alternative B— Exploration and 

CBNG Development Alternative D— Development with 

with Emphasis on Encourage CBNG Enhanced Mitigation to Alternative F (High 

Soil, Water, Air, Exploration and Minimize Environmental Range) & Alternative Alternative H— 

Alternative A— Vegetation, Wildlife Alternative C— Development While Impacts While G (Low Range)— Preferred 

No Action (Existing and Cultural Emphasize CBNG Maintaining 

Issue Topic Management Action CBNG Management) Resources Development Existing Land Uses Land Uses Multiple Screens Multiple Screens 

Maintaining Existing Phased Development Alternative ­

Realty Corridors required No Yes No Yes No, with surface owner 

consultation 

Possibly, based on 

watershed level 

resource analysis and 

with surface owner 

consultation 

Yes 

Powerline placement Aboveground or 

buried 

Buried Aboveground or 

buried 

Buried Aboveground or buried Aboveground or 

buried 

Buried (lowvoltage) highvoltage by 

application only 

Abandoned access roads Agency/surface owner 

discretion 

Agency/surface owner 

discretion 

Agency/surface 

owner discretion 

Agency/surface 

owner discretion 

Agency/surface owner 

discretion 

Agency/surface owner 

discretion 

Agency/surface 

owner discretion 

High fire danger 

restrictions 

No Yes No Yes Yes Yes Yes 

Road use enforcement on 

and gates to reduce public 

access and overuse, 

coupled with speed limits) 

No Yes No Yes No No Yes 

Long-term stakeholder 

planning 

No No No No No No Yes 

Indian 

Trust and 

Native 

American 

Concerns 

Buffer zone (2 miles) 

around reservations 

Monitoring wells 

required on BLMadministered minerals 

that abut reservations 

No 

No 

Yes 

No 

No 

No 

Yes 

No 

No 

May be required 

No 

May be required 

No 

May be required 

BLM (additional fences 

2-31 
 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-2 

ALTERNATIVE MANAGEMENT FOR CBNG 

Alternative E—CBNG 

Alternative B— Exploration and 

CBNG Development Alternative D— Development with 

with Emphasis on Encourage CBNG Enhanced Mitigation to Alternative F (High 

Soil, Water, Air, Exploration and Minimize Environmental Range) & Alternative Alternative H— 

Alternative A— Vegetation, Wildlife Alternative C— Development While Impacts While G (Low Range)— Preferred 

No Action (Existing and Cultural Emphasize CBNG Maintaining 

Issue Topic Management Action CBNG Management) Resources Development Existing Land Uses Land Uses Multiple Screens Multiple Screens 

Maintaining Existing Phased Development Alternative ­

Indian 

Trust and 

Native 

American 

Concerns 

(cont.) 

Resource protection 

protocols 

No No 

Air quality mitigation 

measures 

No No 

Special cultural resources 

protection measures 

No No 

Buffer zone (5-miles) 

with site specific 

groundwater and air 

analyses 

No No 

Air quality monitoring 

for reservations 

No No 

No No Yes 

No No Yes 

No No 

Plan required in POD 

No No No 

No No Yes, depending on 

negotiated mitigation 

measures 

Yes, Cultural Resource 

Yes
 

Yes
 

Yes, Cultural Resource 

Plan required in POD 

Yes, consultation 

required if resource 

impacts predicted 

within reservation 

Yes, depending on 

developments 

proximity to 

reservations 

Yes 

Yes, based on air 

screen 

Yes, Cultural 

Resource Plan 

required in POD 

Yes, consultation 

required if resource 

impacts predicted 

within reservation 

Yes, depending on 

developments 

proximity to 

reservation 

Vegetation Commercially harvest 

ROW trees on BLM 

No Yes No No Agency or surface owner 

discretion 

Agency or surface 

owner discretion 

Agency or surface 

owner discretion 

Revegetate with early 

successional and late 

seral stage plants on 

BLM 

Agency or surface 

owner discretion 

Agency or surface 

owner discretion 

Agency or surface 

owner discretion 

Agency or surface 

owner discretion 

Agency or surface owner 

discretion 

Agency or surface 

owner discretion 

Agency or surface 

owner discretion 

Noxious weed control by 

operator 

Yes Yes No Yes Yes Yes Yes 

2-32 
 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-2 

ALTERNATIVE MANAGEMENT FOR CBNG 

Alternative E—CBNG 

Alternative B— Exploration and 

CBNG Development Alternative D— Development with 

with Emphasis on Encourage CBNG Enhanced Mitigation to Alternative F (High 

Soil, Water, Air, Exploration and Minimize Environmental Range) & Alternative Alternative H— 

Alternative A— Vegetation, Wildlife Alternative C— Development While Impacts While G (Low Range)— Preferred 

No Action (Existing and Cultural Emphasize CBNG Maintaining 

Issue Topic Management Action CBNG Management) Resources Development Existing Land Uses Land Uses Multiple Screens Multiple Screens 

Maintaining Existing Phased Development Alternative ­

Wildlife Wildlife surveys required Yes Yes Yes Yes Yes Yes Yes 

Gray wolf, Canada lynx 

and grizzly bear surveys 

As needed As needed As needed As needed Yes Yes Yes 

20/20 Screen Sage-grouse 

crucial habitat screen 

No No No No No Yes No 

Crucial Sage-grouse 

habitat – Demonstration 

that viable grouse 

populations will be 

maintained 

No No No No No Yes Yes 

Sage-grouse habitat area 

objectives – Connectivity 

and source populations 

No No No No No Yes Yes 

Manage disturbance in 

crucial wildlife habitats 

where federal mineral 

ownership occurs 

No No No No No No Yes 

Change management if 

sage-grouse populations 

decline by more than 25 

No No No No No No Yes 

Implement WMPP No No No No Yes Yes Yes 

percent over 5-year 

increment 

2-33 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Number of wells predicted for analysis purposes: 

• Federal/State – 

up to 925 

CBNG and 

• Federal/State – 

up to 18,275 

CBNG and 

• Federal/State – 

up to 18,275 

CBNG and 

• Federal/State – 

up to 18,275 

CBNG and 

• Federal/State – up to 

18,275 CBNG and 1,720 

conventional wells. 

1,720 1,720 1,720 1,720 

conventional Conventional conventional conventional 

wells. wells. wells. wells. 

• Cumulative – 

up to 925 

CBNG and 

• Cumulative – 

up to 26,475 

CBNG and 

• Cumulative – 

up to 26,475 

CBNG and 

• Cumulative – 

up to 26,475 

CBNG and 

• Cumulative – up to 

26,475 CBNG and 1,775 

conventional wells. 

1,775 1,775 1,775 1,775 

conventional conventional conventional conventional 

wells. wells. wells. wells. 

• Federal/State – up to 

18,225 CBNG and 

1,720 conventional 

wells. 

• Cumulative – up to 

26,425 CBNG and 

1,775 conventional 

wells. 

• Federal/state – up to 

6,470 CBNG and 

1,720 conventional 

wells. 

• Cumulative – up to 

14,670 CBNG and 

1,775 conventional 

wells. 

• Federal/state – 

up to 18,225 

CBNG and 

1,720 

conventional 

wells. 

• Cumulative – 

up to 26,425 

CBNG and 

1,775 

conventional 

wells. 

Air Quality 

Existing air quality throughout most of the analysis area is in attainment with all ambient air quality standards. However, three areas have been designated as federal nonattainment areas where the applicable 

standards have been violated in the past: Lame Deer (PM10—moderate) and Laurel (SO2—primary), Montana; and Sheridan, Wyoming (PM10—moderate). 

• Localized short­ • Localized 

term increases short-term 

in CO, NOx, 

SO2, PM2.5 and 

PM10 

increases in CO, 

NOx, SO2, PM2.5 

and PM10 

concentrations. concentrations. 

• Maximum • Maximum 

concentrations concentrations are 

are expected to 

be below 

applicable 

state and 

expected to be 

below applicable 

state and NAAQS 

and PSD 

National increments for 

Ambient Air near-field and farQuality 

Standards and 

field modeling. 

PSD 

increments for 

near-field and 

far-field 

modeling. 

•	 Impacts under 

Alternative C are 

expected to be 

comparable to 

those describe for 

Alternative B but 

somewhat 

increased in 

severity due to the 

lack of control 

over operators 

choose for 

compressor fuel, 

reduced limits on 

compressor hook 

ups and the lack of 

enforceable 

control measures. 

•	 Localized 

short-term 

increases in 

CO, NOx, SO2, 

PM2.5 and PM10 

concentrations. 

•	 Maximum 

concentrations 

are expected to 

be below 

applicable state 

and NAAQS 

and PSD 

increments for 

near-field and 

far-field 

modeling. 

• Impacts under Alternative 

E would consist of 

localized short-term 

increases in NOx, SO2 and 

PM10 concentrations. 

Most maximum 

concentrations would be 

expected to be below 

applicable state and 

NAAQS, as well as 

NAAQS PSD increments. 

•	 Alternative E would not 

result in increases in Acid 

Neutralizing Capacity 

above 10 percent for any 

Class I areas in the 

modeling domain. 

•	 Visibility impacts of 1.0 

dv would occur in 7 to 10 

PSD Class I areas and 6 to 

12 PSD Class II Area. 

•

Alternatives F would 

be comparable to 

those described for 

Alternative E, but 

would be lowered 

and leveled over 

time due to the 5% 

annual limit for 

APDs approved on 

BLM-administered 

land. 

Impacts under • Impacts under 

Alternative G 

would be lower 

than for 

Alternatives E or F 

due to fewer wells 

predicted to be 

drilled. This would 

result in a reduction 

of approximately 

65% in the number 

of compressors that 

would be required. 

Fewer well pads 

and roads would 

also have to be 

constructed. 

• Impacts under 

Alternatives H 

would be 

comparable to 

those 

described for 

Alternative E 

but would be 

lowered and 

leveled over 

time due to 

implementing 

the four 

screens for 

CBNG 

development. 

2-34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Air Quality (cont.) 

•	 Potential direct 

impact on 

visibility 

within one 

mandatory 

federal PSD 

Class I, one 

Class II Area 

and the Class 

II Crow 

Reservation. 

•	 Cumulative
 

Impacts:
 

- Potentially exceed 

the 24-hour PM10 

NAAQS and PSD 

Class II 

increments south 

of Spring Creek 

Mine. 

- Potentially 

exceed PSD Class 

I increments for 

24-hour PM10 on 

the Northern 

Cheyenne 

Reservation. 

• Potential direct • Cumulative • Potential direct 

visibility impacts Impacts: visibility 

within seven 

mandatory federal 

PSD Class I Areas 

- Same as 

Alternative B. 

impacts within 

one mandatory 

federal PSD 

and the Northern Class I Areas. 

Cheyenne Additional 

Reservation. visibility 

Additional visibility impacts to 

impacts to seven three PSD 

federal PSD Class II Class II areas 

areas including the including the 

Crow and Fort Crow 

Belknap Reservation, 

reservations and one Wilderness 

three Wilderness Area and one 

• Areas and one 

National Recreation 

Area and one 

National 

Recreation 

Area. 

National • Cumulative 

Monument. Impacts: 

• Cumulative 

Impacts: 

- Potentially exceed 

the 24-hour PM10 

-Potentially exceed 

the 24-hour PM10 

and PM2.5 

NAAQS south of 

and PM2.5 NAAQS 

south of Spring 

Spring Creek 

Mine. 

Creek Mine. - Potentially exceed 

Potentially exceed 

the PSD Class II 

increments for 24­

hour PM10 south of 

Spring Creek 

the PSD Class II 

increments for 24­

hour PM10 south 

of Spring Creek 

Mine. 

Mine. 

• Air quality modeling • • •

indicates visibility Impacts: Impacts: Impacts: 

impacts of 1.0 dv 

would occur in 7 to 

10 PSD Class I areas 

and 6 to 12 PSD 

quality permitting 

process would be 

used to analyze 

emission sources at 

the project level. 

Emission sources that 

would violate 

- Cumulative 

impacts under 

Alternative F 

would be the same 

as for Alternative 

E. 

- Cumulative impacts 

under Alternative G 

would be fewer than 

for Alternatives E or F 

due to fewer wells 

predicted to be drilled. 

This would result in 

fewer compressors, 

well pads and roads 

that would have to be 

constructed. 

- Cumulative 

impacts under 

Alternatives H 

would be 

comparable to 

those described 

for Alternative E. 

standards would not 

be permitted by the 

agencies. 

• Cumulative Impacts: 

- Given the non-project 

emission sources 

located throughout the 

analysis region, there 

would be a potential for 

cumulative air quality 

impacts to exceed 

applicable thresholds 

under Alternative E. 

However, none of the 

predicted impacts would 

exceed state or 

NAAQS. 

Cumulative Cumulative Cumulative 

Class II Area. The air 

2-35 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Air Quality (cont.) 

- Potentially exceed 

atmospheric 

deposition 

thresholds in the 

very sensitive 

Upper Frozen 

Lake in the PSD 

Class I Bridger 

Wilderness Area. 

- Potential visibility 

impacts in 10 of 

17 federal PSD 

Class I including 

the Crow and Fort 

Peck reservations. 

Additional 

visibility impacts 

to 7 of 13 PSD 

Class II sensitive 

areas including 

the Crow and Fort 

Belknap 

reservations. 

- Potentially exceed 

PSD Class I 

increments for 24­

hour PM10 on the 

Northern 

Cheyenne 

Reservation and at 

Washakie. 

- Potentially exceed 

PSD Class I 

increments for 

annual NO2 on the 

Northern 

Cheyenne 

Reservation. 

- Potentially exceed 

atmospheric 

deposition 

thresholds in the 

very sensitive 

Upper Frozen Lake 

in the PSD Class I 

Bridger Wilderness 

Area and Florence 

Lake in the Class 

II Cloud Peck 

Wilderness Area. 

- Potential visibility 

impacts in all 

federal PSD Class 

I and II sensitive 

areas including the 

N. Cheyenne, Fort 

Peck, Fort Belknap 

and Crow 

reservations. 

- Potentially exceed 

PSD Class I 

increments for 24­

hour PM10 on the 

Northern 

Cheyenne 

Reservation and 

Washakie WSA. 

- Potentially exceed 

atmospheric 

deposition 

thresholds in the 

very sensitive 

Upper Frozen 

Lake in the PSD 

Class I Bridger 

Wilderness Area. 

- Potential visibility 

impacts in 14 of 

17 federal PSD 

Class I and all 

Class II sensitive 

areas including the 

N. Cheyenne, Fort 

Peck, Fort 

Belknap and Crow 

reservations. 

2-36 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative E—
 

Alternative B— CBNG Exploration and 

CBNG Development Alternative D— Development with 

with Emphasis on Encourage CBNG Enhanced Mitigation to 

Soil, Water, Air, Exploration and Minimize Environmental Alternative F—
 Alternative G— Alternative H— 

Alternative A— Vegetation, Wildlife Alternative C— Development While Impacts While Phased Development Phased Development Preferred 

No Action (Existing and Cultural Emphasize CBNG Maintaining Existing Maintaining Existing Multiple Screens Multiple Screens (Low Alternative ­

CBNG Management) Resources Development Land Uses Land Uses (High Range) Range) Multiple Screens 

Cultural Resources 

Approximately 73,600 cultural resource sites may occur above known coal resources within the CBNG emphasis area 

•	 An estimated 

17 cultural 

resource sites 

could be 

identified 

during 

foreseen 

CBNG 

activities. Of 

these only one 

or two would 

likely be 

eligible for the 

NRHP. 

•	 Cumulative
 

Impacts:
 

- An estimated 

4,285 cultural 

sites would be 

identified. 

resulting in 430 to 

612 sites likely 

eligible for the 

NRHP. 

• The number of cultural resource sites identified would be practically the 

same for Alternatives B, C, D and E based on the level of development, 

associated area of disturbance and minor differences between the 

alternative realty management actions. An estimated 630 cultural resource 

sites would be identified, of these sites, 120 to 170 could be found eligible 

for the NRHP. The number of sites in Alternatives F through H reflect 

additional cultural resource sites located during surveys after April 2003. 

• Cumulative Impacts: 

- An estimated 5,135 cultural sites could be identified resulting in 515 to 

735 sites that could be eligible for the NRHP. 

•	 An estimated 893 to 

1,080 cultural 

resource sites could 

be identified. 

• Cumulative Impacts: 

- An estimated 5,398 to 

5,585 cultural sites 

could be identified. 

• An estimated 893 to 

1,080 cultural 

resource sites could 

be identified. 

• Should no drilling 

occur within crucial 

sage-grouse habitat 

areas, the number of 

cultural resources 

sites that could be 

identified would be 

reduced by 12.8% 

from 942 to 779. 

• Cumulative Impacts: 

• An estimated 5,398 

to 5,585 cultural sites 

could be identified. 

•	 If no drilling 

occurred within 

crucial sage-grouse 

habitat, the number 

of cultural resources 

sites that could be 

identified would be 

reduced from 5,447 

to 5,284. 

• Impacts would be 

similar to Alternative F 

with the exception that 

the number of cultural 

resource sites identified 

would be reduced by 

approximately 65% due 

to fewer federal APDs 

that would have to be 

issued. 

• An estimated 312 to 378 

cultural resource sites 

could be identified, 

based on the reduced 

number of federal APDs 

predicted to be issued. 

• Cumulative 

Impacts: 

- An estimated 4,817 to 

4,883 cultural sites 

could be identified, 

based on the reduced 

number of federal 

APDs predicted to be 

issued. 

•

893 to 1,080 

cultural 

resource sites 

could be 

identified. 

An estimated 

• Cumulative 

Impacts: 

- An estimated 

5,398 to 5,585 

cultural sites 

could be 

identified. 

2-37 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Cultural Resources (continued) 

Approximately 73,600 cultural resource sites may occur above known coal resources within the CBNG emphasis area 

- Identification of traditional cultural properties (TCPs) would increase with the development 

of CBNG. • Identification of TCPs 

would increase with would increase with TCPs would be similar to to TCPs could be 

development of CBNG. development of 

CBNG. 

those for Alternative F, 

but would be reduced by 

similar to 

Alternatives B, C, 

approximately 65%. D, E and F. 

• Identification of TCPs • Potential for impacts to • Potential for impacts 

Environmental Justice 

Executive Order 12898 requires the non-discriminatory treatment of minority and low-income populations for projects under the jurisdiction of a federal agency 

• Few adverse impacts 

with the exception 

of the undetermined 

Wyoming discharge 

influence. 

• No adverse human 

health or 

environmental 

effects would be 

expected to fall 

disproportionately 

on minority or lowincome populations 

from this alternative. 

• No adverse human 

health impacts 

would be expected 

to fall 

disproportionately 

on minority or lowincome populations 

from this 

alternative. 

• The influence of 

Wyoming’s 

discharge on 

Montana’s rivers 

would constitute a 

potential 

environmental 

justice issue if 

unresolved. 

• Same as B except for 

adverse 

environmental 

effects would be 

expected from 

downstream water 

quality changes 

resulting in 

limitations to 

subsistence living 

styles. These 

limitations would 

fall 

disproportionately 

on minority or lowincome populations 

from this alternative. 

Wyoming Discharge 

issues same as 

Alternative B. 

• No adverse human 

health or 

environmental 

effects would be 

expected to fall 

disproportionately on 

minority or lowincome populations 

from this alternative. 

Wyoming Discharge 

issues same as 

Alternative B. 

• No adverse human health or 

environmental effects 

would be expected to fall 

disproportionately on 

minority or low-income 

populations from this 

alternative. 

• Impacts would be mitigated 

as described under the 

Environmental Justice 

section, Alternative A and 

by implementation of the 

Project POD requirements. 

• No adverse human 

health or 

environmental effects 

would be expected to 

fall disproportionately 

on minority or lowincome populations 

from this alternative. 

Wyoming Discharge 

issues would be the 

same as for 

Alternative B 

• Project Plan and 

watershed-level 

analysis requirements 

would help mitigate 

potential impacts. 

• Project Plan 

consultation with 

Tribes and ongoing 

monitoring for 

developments within 5 

miles of a reservation 

would help to protect 

Indian Trust Assets. 

• Impacts would be 

lower than for other 

development 

alternatives due to 

fewer wells being 

developed. 

• No adverse human 

health or 

environmental effects 

would be expected to 

fall disproportionately 

on minority or lowincome populations 

from this alternative. 

Wyoming Discharge 

issues would be the 

same as for 

Alternative B. 

• Project Plan and 

watershed-level 

analysis requirements 

would help mitigate 

potential impacts. 

• Impacts would be 

similar to Alternative 

F due to similar 

number of wells 

developed. With 

mitigation, no adverse 

human health or 

environmental effects 

would be expected to 

fall disproportionately 

on minority or lowincome populations 

from this alternative. 

Wyoming Discharge 

issues same as 

Alternative B. 

• Project Plan, resource 

screens and 

watershed-level 

analysis requirements 

would help to 

mitigate potential 

impacts. 

2-38 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Environmental Justice (continued) 

Executive Order 12898 requires the non-discriminatory treatment of minority and low-income populations for projects under the jurisdiction of a federal agency 

• Project Plan • Project Plan 

consultation with tribes 

and ongoing 

monitoring for 

developments within 

5 miles of a reservation 

would help to protect 

ITAs. 

consultation with 

tribes and ongoing 

monitoring for 

developments 

within 5 miles of a 

reservation would 

help to protect 

Indian Trust 

Assets. 

Geology and Minerals 

Montana’s mineral resources are intimately tied to the complex geologic framework of the state. Locatable minerals and conventional Oil and Gas resources are found throughout the Planning Area in various 

recoverable and non-recoverable amounts 

• Federal: • Federal:
 

- Irretrievable - Irretrievable • Federal: • Federal • Federal: • Federal: • Federal: • Federal: : - Only minor loss - Irretrievable - Same as - Same as - Same as Alternative B with - Irretrievable 

commitment of commitment of of CBNG during commitment of Alternative B with Alternative B. the addition of increased commitment of 

CBNG resources CBNG resources testing operations. CBNG resources the addition of water drawdown and CBNG resources 

from production, from production, from production, increased water potential operational from production, rate 

magnitude and rate of magnitude and drawdown and interference within and of development development complexity complexity to potential adjacent to coal mines would be managed would be 65% less would reflect reflect increase operational without the 1-mile buffer by limit set on the than alternative F. increase scale of scale of interference within zone. number of federal 

development. and adjacent to - Protection of potential tribal APDs that would be - The potential for development 

- Potential mineral coal mines without CBNG from drainage approved per year, mineral drainage - Potential mineral 

drainage between the 1-mile buffer because of resource geographic between federal drainage between 

Federal mineral zone. protection protocols. development of mineral estates federal mineral 

CBNG resources and other mineral estates and state, estates and state,
 

private and tribal managed through owners would be private and tribal 

limits set on the 65% lower than developments developments 

depending on number of APDs for Alternative F depending on 

site-specific allowed for each due to the lower site-specific 

conditions. fourth order number of wells conditions. 

watershed. developed. 

2-39 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative E— 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Geology and Minerals (cont.) 

- The presence of 

shallow CBNG 

production could 

delay or interfere 

with certain 

types of seismic 

prospecting for 

conventional oil 

and gas 

reservoirs. 

- Potential mineral 

drainage between 

federal mineral estates 

and state, private ,and 

tribal developments 

depending on sitespecific conditions 

and increased 

potential for drainage 

of federal minerals 

due to cumulative 

limit on number of 

- Potential 

operational 

interference 

within and 

adjacent to coal 

mines. 

- Protection of 

tribal CBNG 

from drainage 

because of 5-mile 

buffer zone. 

federal APDs allowed 

per year. 

- Protection of tribal 

CBNG from 

drainage because of 

resource protection 

protocols. 

• State: • State: • State: • State: • State: 

- Irretrievable - Increased - Same as - Same as - Same as Alternative B. - Increased - The same as F, - Increased 

commitment of 

CBNG resources 

from CX Ranch 

Field production. 

- Delayed 

commitment of 

CBNG resources 

due to increased 

level of CBNG. 

- Mineral drainage 

Alternative B. 

- Potential mineral 

drainage between 

federal mineral 

estates and state, 

Alternative B. 

- Potential mineral 

drainage between 

Federal mineral 

estates and state, 

- Potential mineral drainage 

between federal mineral 

estates and state, private or 

Tribal developments 

depending on site-specific 

commitment of 

CBNG resources 

due to increased 

level of CBNG 

development. 

but 

approximately 

65% lower. 

commitment of 

CBNG resources 

due to increased 

level of CBNG 

development. 

development or and seismic private, or Tribal private or Tribal conditions. - Potential mineral - Potential mineral 

expansion of 

conventional oil 

interference 

issues same as 

developments 

depending on sitedevelopments depending on sitedrainage between 

federal mineral 

drainage between 

federal mineral 

and gas, coal for Federal under specific specific estates and state, estates and state, 

mining and surface 

mineral mining in 

minor instances 

with no interruption 

to existing 

this alternative conditions. conditions. private and tribal 

developments 

depending on sitespecific conditions. 

private and tribal 

developments 

depending on 

site-specific 

conditions. 

activities. 

• State: • State: • State: 

2-40 
 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative E— 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Geology and Minerals (cont.) 

- CBNG production 

dewatering at 

nearby coal seams, 

in rare occurrences 

can cause 

underground coal 

fires, methane seeps 

and the liberation of 

methane to water 

. - Presence of 

shallow CBNG 

production could 

delay certain 

types of seismic 

prospecting for 

conventional oil 

and gas 

reservoirs. 

- Presence of 

shallow CBNG 

production could 

delay certain 

types of seismic 

prospecting for 

conventional oil 

and gas 

reservoirs. 

wells. 

• Cumulative • Cumulative	 • Cumulative • Cumulative 

Impacts: Impacts: Impacts: Impacts Impacts: to Alternative B. Impacts: Similar to Similar to Impacts: Similar to 

• Cumulative Impacts: Similar • Cumulative • Cumulative Impacts: • Cumulative 

- Reduction in Coal - Increase in wells increased over - Same as - Potential mineral drainage Alternative B. Alternative B, but Alternative B. 

resources from alternative B. and infrastructure	 Alternative B. between federal mineral - Increased lower based on less - Increased 

current and planned could impact	 estates and state, private, or potential mineral development. potential mineral surface mine existing mine	 tribal developments drainage of drainage of operations. expansion greater	 depending on site-specific federal mineral federal mineral possibility of	 conditions. estates by state, - Potential CBNG estates by state, CBNG drainage	 private, or tribal drainage along private, or tribal 

Wyoming Montana than A.	 developments developments depending on site- State Line. depending on site- specific specific conditions. conditions 

2-41 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

• Federal: • Surface Water • Surface Water • Surface Water • Surface Water • Surface Water: 

- No impacts to 

surface or 

groundwater 

resources. 

- No beneficial reuse. 

• State: 

- Negligible increase 

in surface water flow 

and quality changes 

in the Tongue River. 

No change in other 

waterways. 

- Groundwater 

drawdown within the 

immediate vicinity 

of the CX Ranch. 

- Similar to 

Alternative A; 

potential for 

increased 

sediment loads 

due to soil 

disturbance and 

- Surface water quality 

in some watersheds 

would be noticeably 

altered, resulting in 

restricted 

downstream uses. 

- Surface water flow 

would be 

considerably 

increased in some 

watersheds causing 

persistent riparian 

erosion, changes in 

watercourses and 

increased 

sedimentation. 

- Similar to 

Alternative A; 

potential for 

increased 

sediment loads 

due to soil 

disturbance and 

erosion. 

- Surface water flow 

would be similar to 

Alternative C but 

with slight increase 

in volume due to 

reduced conveyance 

loss. 

- Surface water quality 

would be slightly 

altered, however 

downstream uses would 

not be diminished. 

- Surface water flow 

would be moderately 

increased causing some 

riparian erosion, as well 

as increased 

sedimentation. 

-

-

Water quality 

would be slightly 

altered; 

downstream uses 

would not be 

diminished. 

Surface water flow 

would be 

moderately 

increased, causing 

some riparian 

erosion, as well as 

increased 

sedimentation. 

-

-

Water quality would 

be slightly altered; 

however, 

downstream uses 

would not be 

diminished. 

Flows would 

slightly increase 

resulting is slight 

riparian erosion, as 

well as minor 

increases in 

sedimentation. 

- Water quality 

will be slightly 

altered; however 

downstream uses 

would not be 

diminished. 

- Surface water 

flow would be 

moderately 

increased, 

causing some 

riparian erosion, 

as well as 

increased 

sedimentation. 

- Continued beneficial 

reuse of produced 

water at the CX 

Ranch. 

• Surface Water: • Surface Water: 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Hydrological Resources 

Surface water: The Tongue River has generally good quality water with a seasonal flow consistent from year to year and is frequently used for irrigation The Powder and Little Powder Rivers are characterized as 

having fair to poor quality water and can and do go dry, the waters are used for stock and limited irrigation. 

Groundwater: Regional groundwater is available in stream bottoms and alluvium, but becomes scarce away from the water course. Coal beds and interlayered sands are the most commonly used aquifers away 

from riparian areas. Groundwater quality is variable and effects taste and beneficial uses. 

Beneficial Reuse: The southeastern region of Montana is classified as a high plains semi-arid environment and has experienced drought conditions over much of the last decade 

erosion. 

2-42 
 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Hydrological Resources (cont.) 

• Groundwater: 

- Groundwater will 

be drawn down 

over time in the 

Powder River 

Basin. 

- Isolated areas of 

development 

would experience 

an increased 

drawdown effect. 

- Immediate 

drawdown of coal 

seam aquifers 

would be minor 

and limited in 

horizontal extent. 

As CBNG 

production 

matures, coal 

seam aquifer 

drawdown could 

reach 20 feet 4 to 

5 miles from the 

edge of 

production. 

- No change in 

groundwater 

quality. 

• Groundwater: 

- Drawdown same as 

Alternative B. 

- Alluvial 

groundwater 

quality would be 

altered due to 

infiltration of 

untreated 

production water. 

• Groundwater: 

- Drawdown same as 

Alternative B 

- No groundwater 

quality impacts. 

• Groundwater: 

- Drawdown same as 

Alternative B. 

- Minor impacts to shallow 

groundwater quality 

from impoundment 

infiltration and surface 

discharge of some 

untreated production 

water. 

• Groundwater: - Drawdown same as 

Alternative B. 

- Minor impacts 

would occur to 

shallow 

groundwater 

quality from 

impoundment 

infiltration and 

other water 

management 

practices. 

• Groundwater: - Drawdown effects near 

CBNG fields would be 

the same as Alternative 

B, but fewer CBNG 

fields would be 

developed. 

- Minor impacts to 

shallow groundwater 

quality would occur 

from impoundment 

infiltration and other 

water management 

practices. 

• Groundwater: - Drawdown same as 

Alternative B. 

- Minor impacts 

would occur to 

shallow 

groundwater 

quality from 

impoundment 

infiltration and 

other water 

management 

practices. 

2-43 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Hydrological Resources (cont.) 

•	 Beneficial • Beneficial • Beneficial • Beneficial • Beneficial Reuse: 

Reuse: Reuse: Reuse: Reuse: - Required Water - Required WMPs - Required WMPs from - Required WMPs 

- Due to the - Same as - Same as - Increased Management Plans from from all operators all operators would from all operators 

• Beneficial Reuse: • Beneficial Reuse: • Beneficial Reuse: 

increased water Alternative A. Alternative A. availability of all operators would would result in result in beneficial reuse would result in 

volumes from treated water for a result in increased beneficial reuse of of approximately 20% beneficial reuse of 

Wyoming’s variety of beneficial reuse of approximately 20% of production water. approximately 

discharge there downstream and production water, of production water. 20% of production 

would be added	 increased estimate at 20%. water.
 

opportunities for beneficial uses,
 

irrigation, stock estimated at 20%
 

watering and other of production.
 

uses from
 

waterways,
 

depending on the
 

water quality.
 

• Cumulative • Cumulative • Cumulative • Cumulative • Cumulative Impacts: 

Impacts: 

- Surface Water: 

Impacts: 

- Surface water 

Impacts: 

- Surface water 

Impacts: 

- Surface water 

- Cumulative impacts to 

surface water will be 

- Cumulative impacts 

to surface waters 

- Cumulative impacts to 

surface waters would 

Impacts: 

- Cumulative 

Wyoming’s 

discharge of 

CBNG production 

in moderate 

increases in 

surface water flow 

in Montana rivers 

flow and quality 

will be the same 

as Alternative A. 

- CBNG production 

in Montana and 

Wyoming will 

noticeably 

drawdown coal 

quality in some 

watersheds would 

be noticeably 

altered, resulting 

in restricted 

downstream uses. 

quality would not 

be degraded and 

minor impacts 

from Wyoming 

would be diluted. 

- Surface water flow 

impacts would be 

similar to 

reduced dependent on 

MDEQ numerical and 

narrative standards. 

- Surface water quality 

would be slightly altered 

however downstream 

uses would not be 

diminished. 

would be lower than 

MDEQ standards. 

- Surface water quality 

would be slightly 

altered; however, 

downstream uses 

would not be 

diminished 

be lower than MDEQ 

standards. 

- Surface water quality 

would be slightly 

altered; however, 

downstream uses 

would not be 

diminished 

impacts to surface 

waters would be 

lower than MDEQ 

standards. 

- Surface water 

quality would be 

slightly altered; 

however, 

depending on the 

season and 

watershed from 

minor to 

noticeable 

amounts. 

seam aquifers. 

- Groundwater 

quality in 

Montana and 

beneficial reuse 

will be the same 

Alternative C with 

added volume due 

to reduced 

conveyance loss. 

- Surface water flows 

would be moderately 

increased in some 

watersheds and provide 

a source of flow in some 

rivers that would 

- Surface water flows 

would be moderately 

increased. 

- Surface water flows 

would be only 

slightly increased due 

to fewer wells 

developed. 

downstream uses 

would not be 

diminished 

- Surface water 

flows would be 

moderately 

as Alternative A. otherwise have gone dry increased. 

seasonally. 

• Cumulative Impacts: • Cumulative Impacts: • Cumulative 

water would result 

2-44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

- TRR construction 

sediment. 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative E— 

Alternative B— 

CBNG Development Alternative D— 

CBNG Exploration and 

Development with 

with Emphasis on 

Soil, Water, Air, 

Encourage CBNG 

Exploration and 

Enhanced Mitigation to 

Minimize Environmental Alternative F— Alternative G— Alternative H— 

Alternative A— 

No Action (Existing 

CBNG Management) 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Development While 

Maintaining Existing 

Land Uses 

Impacts While 

Maintaining Existing 

Land Uses 

Phased Development 

Multiple Screens 

(High Range) 

Phased Development 

Multiple Screens (Low 

Range) 

Preferred 

Alternative ­

Multiple Screens 

Hydrological Resources (cont.) 

- The surface water - Surface water flow 

quality in the three- would be 

shared rivers considerably 

between Montana increased in some 

and Wyoming would watersheds 

be slightly altered, causing persistent 

however riparian erosion, 

downstream uses changes in 

will not be watercourses and 

diminished. increased 

sedimentation. 

could lead to - Impacts to - Impacts to - Impacts to groundwater - Minor impacts - Drawdown effects near - Groundwater 

localized soil erosion groundwater groundwater drawdown would be the would occur to CBNG fields would be drawdown 

and impact to drawdown, quality drawdown and same as Alternative B. shallow the same as for would be 

surface water 

focused runoff, 

localized increased 

stream flow and 

increased suspended 

- Groundwater: 

Drawdown of 

groundwater from 

Wyoming CBNG 

operations could 

extend several miles 

north into Montana. 

and beneficial 

reuse would be the 

same as in 

Alternative B. 

quality would be 

the same as in 

Alternative B. 

- Increased 

beneficial reuse, 

estimated at 20% 

of production. 

- Shallow groundwater 

quality would be slightly 

altered due to 

impoundment 

infiltration and surface 

discharge of untreated 

production water. 

- Use of Water 

Management Plans and 

agency approval would 

result in increased 

beneficial reuse, 

estimated at 20%. 

groundwater 

quality from 

impoundment 

infiltration and 

other water 

management 

practices. 

Alternative B, but fewer 

CBNG fields would be 

developed. 

- Minor impacts would 

occur to shallow 

groundwater quality from 

impoundment infiltration 

and other water 

management practices. 

similar to 

Alternative B. 

- Minor impacts 

would occur to 

shallow 

groundwater 

quality from 

impoundment 

infiltration and 

other water 

management 

practices. 

- Groundwater quality 

in Montana would 

not be impacted by 

Wyoming CBNG 

operations 

- Drawdown from the 

CX Ranch may 

extend out several 

miles from the 

development. 

2-45 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Indian Trust and Native American Concerns 

Indian Trust Assets (ITAs) are official interests in assets held in trust by the federal government for Indian tribes or individuals. The U.S. Department of the Interior (DOI) Departmental Manual 303 DM 2 defines 

ITAs as lands, natural resources, money, or other assets held by the federal government in trust or that are restricted against alienation for Indian tribes and individual Indians. 

• Federal: • Federal: • Federal: • Federal: • Federal: 

- No measurable - No surface water - Potential for - Groundwater - Effects from - Potential effects from - Potential impacts from - Potential effects 

impacts to Indian 

trust assets would 

occur from the 

CBNG activities. 

quality impacts 

foreseen. 

- Potential CBNG 

drainage, 

dependent on 

specific site 

conditions, 

delayed by buffer 

zone. 

- Visibility impacts. 

- Wildlife 

Adaptation 

resulting in 

changes. 

- Potential cultural 

resource impacts 

to TCPs. 

surface water 

quality and 

quantity impacts. 

- Potential CBNG 

drainage, same as 

Alternative B. 

- Cultural Resource 

impacts same 

as B. 

- Visibility impacts. 

drawdown same as 

Alternative B. 

- Surface water 

quality impacts 

reduced by source 

treatment, 

increased 

availability of 

surface waters for 

irrigation and other 

beneficial uses. 

- Increased surface 

water flow could 

result in increase 

riparian erosion. 

- Potential CBNG 

drainage, same as 

Alternative B. 

- Cultural Resource 

impacts same as B. 

- Visibility impacts. 

groundwater drawdown 

mitigated because of 

resource protection 

protocols. Potential 

CBNG drainage 

mitigated through the 

use of resource 

protection protocols. 

- Surface water quality 

impacts reduced with 

increased availability of 

surface waters for 

irrigation and other 

beneficial uses. 

- Increased surface water 

flow could increase 

riparian erosion. 

- Air Quality and 

visibility impacts 

alleviated through site 

specific permits and 

mitigation. 

groundwater 

drawdown would be 

reduced by 

implementation of a 

5-mile buffer zone. 

Potential CBNG 

drainage would be 

mitigated or 

eliminated. 

- Surface water quality 

impacts would be 

reduced through 

implementation of 

water screen and 5­

mile buffer. 

- TCP site would be 

identified sooner 

through use of block 

surveys and tribal 

consultations. 

- Air Quality impacts 

would be mitigated 

through site-specific 

Alternative G would be 

similar to Alternative 

F, except 

approximately 65% 

lower due to reduced 

number of APDs 

predicted to be issued. 

- Surface water quality 

impacts would be 

similar to Alternative F 

although 

approximately 65% 

would be reduced due 

to fewer wells 

developed. 

- TCP site would be 

identified sooner 

through use of block 

surveys and tribal 

consultations. 

- Air quality impacts 

would be mitigated 

through site-specific 

from groundwater 

drawdown would 

be reduced by 

implementation of 

5-mile buffer 

zone. Potential 

CBNG drainage 

would be 

mitigated or 

eliminated. 

- Surface water 

quality impacts 

would be reduced 

through 

implementation of 

water screen and 

5-mile buffer. 

- TCP site would be 

identified sooner 

through use of 

block surveys and 

tribal 

consultations. 

permits and control permits and control - Air Quality 

measures. measures. impacts would be 

mitigated through 

site-specific 

permits and 

control measures. 

• Federal: • Federal: • Federal: 

2-46 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Indian Trust and Native American Concerns (cont.) 

• State: • State: • State: • State: • State: 

- No measurable 

impacts to Indian 

trust assets would 

occur from the 

CBNG activities. 

- Groundwater 

drawdown inward 

from reservation 

boundaries. 

- Limited shortterm surface water 

impacts from 

spills and ruptures 

adjacent to 

reservations. 

- Potential CBNG 

drainage, 

dependent on 

specific site 

conditions, no 

delay due to 

adjacent 

development. 

- Groundwater 

drawdown same as 

Alternative B. 

- Surface water 

quality and 

quantity impacts. 

- Potential CBNG 

drainage, same as 

Alternative B. 

- Groundwater 

drawdown same as 

Alternative B. 

- Surface water 

quality impacts 

reduced. 

- Potential CBNG 

drainage, same as 

Alternative B. 

- Surface water quality 

protected. 

- Same as Alternative 

E. 

- Same as Alternative E. - Groundwater 

drawdown 

potential on 

reservations 

would be 

minimized. 

CBNG drainage 

would be 

minimized by 

state spacing. 

Surface water 

quality would be 

protected. 

• State: • State: • State: 

2-47 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Indian Trust and Native American Concerns (cont.) 

•	 Cumulative • Cumulative • Cumulative • Cumulative • Cumulative Impacts:
 

Impacts: Impacts: Impacts: Impacts: - Same as Alternative B. - Would be same as - Would be same as Impacts:
 

• Cumulative Impacts: • Cumulative Impacts: • Cumulative 

- Reduction in Coal - Same as - Same as - Same as Alternative B, Alternative B, except - Would be same as 

resources from the Alternative A. Alternative B. Alternative B except no potential reduced due to fewer Alternative B, 

Absaloka Mine - Reduction of except no potential air quality impacts wells developed. except no 

operation.	 CBNG resources air quality impacts to PSD Class I potential air 

annual NO2 quality impacts to - Surface water if developed by	 to PSD Class I 

increments.	 PSD Class I quality and Tribes, coupled	 annual NO2 

annual NO2 quantity in the with land	 increments. 

increments. Tongue River disturbances and
 

would not be associated water
 

noticeable altered impacts.
 

from Wyoming - Changes in
 CBNG visibility. 

development. - Air Quality - Drawdown of changes. 

groundwater from - Potential air Wyoming CBNG quality impacts to operations has the PSD class I 24­ potential to lower hour PM10 aquifer levels on increments. the Crow - Potential air Reservation. 

quality impacts to - Potential CBNG PSD Class I drainage along annual NO2 southeastern increments. corner of Crow
 

Reservation from
 

Wyoming
 

operations.
 

2-48 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Lands and Realty 

Emphasis Area Land Ownership: Private 69%, Federal 15%, Tribal 10%, State 5% 

Total Acreage: 19,371,593	 

Miles of Road: Interstate, 386; US; 675; State, 409; Off-System, 24,431 

Miles of Railroad: BNSF, 573; MT Rail Link, 146 

• Federal: • Federal: • All Federal • All Federal and • Federal and State: • Federal: 

− 25,600 acres 

• Federal: • Federal: 

- Minimal land area - Increase fire and State State impacts - Levels of disturbance - 25,600 acres would - 9,100 acres would be 

displaced by hazard and impacts in in Alternative would be slightly be disturbed during disturbed during would be 

roads. motorized access Alternative B B occur in increased due to use of CBNG exploration CBNG exploration and disturbed during 

- 400 acres during 20-year occur in Alternative D impoundments for and construction construction activities CBNG 

disturbed short lease. Alternative C in addition to production water activities (short (short term). exploration and 

in addition to: the following: management (Short term term). - 5,400 acres would be construction term during - Limit public - Impacts to - Federal: 74,000 acres, long term - 15,250 acres would disturbed during activities (short- CBNG access. adjacent mining Permanent loss of 44,000 acres). be disturbed during operation (long term). 

− 15,250 acres 

term). exploration - Disrupt active drilling.	 operations The land use from road - Impacts from operation (long logging operations. land use network. term).	 would be powerlines, roads, - 25,600 short term displacement from pipelines and other	 disturbed during 

acres and 15,250	 roads and utility	 operation (long­ utilities not requiring long term acres lines lease term). transportation corridors disturbed during operations is would be the same as 

CBNG greatest in Alternative C. 

development Alternative C. 

activities.
 

• State: • State: - Increased • State: • State: • State: 

- Increased - Displace disturbances by - 29,550 acres would - 10,500 acres would be - 29,500 acres 

motorized access agricultural lands CBNG activities be disturbed during disturbed during would be 

on the CX Ranch. and disrupt on private, state CBNG exploration CBNG exploration and disturbed during 

irrigation system, and federal estates. and construction construction activities CBNG - Increase increase cost of Short term	 activities (short (short term). exploration and motorized disturbances	 term). construction farm operation. - 6,250 acres would be trespass. 70,000 acres activities (short­ - Reduced property	 - 17,600 acres would disturbed during - 1,100 short term	 (Federal 32, 400, term). values.	 be disturbed during operation (long term). acres disturbed	 State 37,600); long operation (long	 - 17,600 acres and 500 long term - Displace term disturbances term).	 would be 

acres during community and 47,600 acres disturbed during CBNG residential growth. (Federal 22,000, operation (long­ exploration and State 25,600). - Increase dust and	 term). production noise impacts on activities. residential use. 

2-49 
 

 

 

 

 

 

 

 

 

 

 

 

 

• Total • Total • Total • Total cumulative • 20,450 acres would • 88,170 acres 

cumulative 

long term 

disturbance 

including all 

foreseen 

projects such 

as coal mine 

cumulative 

acres disturbed 

long term 

including all 

foreseen 

projects would 

be 

cumulative 

long term acres 

disturbed 

would be 

approximately 

102,300 acres. 

long term acres 

disturbed would be 

approximately 

92,200. 

experience 

cumulative effects. 

experience cumulative 

effects. 

would experience 

cumulative effects. 

expansion, 

transportation 

etc. is 

approximately 

81,000 acres. 

estimated at 

34,000 acres. 

• 88,170 acres would 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative E— 

Alternative B— CBNG Exploration and 

CBNG Development Alternative D— Development with 

with Emphasis on Encourage CBNG Enhanced Mitigation to 

Soil, Water, Air, Exploration and Minimize Environmental Alternative F— Alternative G— Alternative H— 

Alternative A— 

No Action (Existing 

CBNG Management) 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Development While 

Maintaining Existing 

Land Uses 

Impacts While 

Maintaining Existing 

Land Uses 

Phased Development 

Multiple Screens 

(High Range) 

Phased Development 

Multiple Screens (Low 

Range) 

Preferred 

Alternative ­

Multiple Screens 

Lands and Realty (cont.) 

- Increase cost of 

county road 

maintenance. 

- Increase long-term 

motorized access. 

- Invite illegal 

trespass activities. 

- Increase forest 

pests. 

- Disrupt active 

logging operations. 

- Increase motorized 

trespass. 

- 29,750 short term 

acres and 17,700 

long term acres 

disturbed during 

CBNG 

development 

activities. 

2-50 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Livestock Grazing 

AUM is equal to the amount of forage required to support one cow and her calf or 5 sheep for one month.
 

The CBNG Planning Area has an estimated 1,389,908 acres of land classified as grazing, capable of supporting 259,554 AUMs.
 

•	 Exploration wells • Exploration wells • Impacts to livestock • Impacts would be • Impacts to livestock 

located within would result in the grazing would be similar to grazing would be grazing would be similar to Alternative B, livestock grazing 

BLM-permitted temporary loss of similar to but slightly Alternative B with similar to similar to but the land disturbance would be similar 

rangelands would 413 AUMs (BLM greater than those in some exceptions: Alternative B. Suitable Alternative B and area would be 

result in the 163, State 250). Alternative B due to the disturbed acreage CBNG discharge phased in after approximately 65% 

temporary loss of • Production wells discharge of untreated would increase due water could be used 

• WMPs for federal 

watershed analysis. lower. would be screened 

69 AUMs. would result in a production water on to to the piping of for livestock watering. 

• Impacts to livestock • Impacts would be • Impacts to 

for four resources, 

• State: maximum the ground resulting in discharge water to • Transportation CBNG wells would	 of which water 

- The exploration construction loss increased erosion and the nearest disposal corridor impacts incorporate results would have the
 

wells and of 11,960 AUMs no requirements for point. There would would be the same as and requirements most effect on
 

production wells (BLM 4,770, State transportation corridors. be a reduction to Alternative B. identified by
 

• Water 

livestock grazing. 

located at CX Ranch 7,190). • CBNG discharge water forage losses from • Not as much forage watershed-level 

would result in a • Re-vegetating could be used for increased managed would be lost under 

• Impacts from federal 

analysis. Management Plans 

maximum parts of the well livestock watering; irrigation of this alternative for federal CBNG 

construction loss of pads during increased erosion would produced water; and because increased CBNG development wells would 

272 AUMs on state production would result in increased there would be less managed irrigation of would occur incorporate results 

and private reduce the losses surface disturbance, soil and forage loss produced water would primarily in the latter and requirements 

rangelands to 6,904 AUMs which could lead to from erosion of allow more growth. years of the planning identified by 

combined. (BLM 2,484, disrupted grazing soils. There would also be period, generally watershed-level 

- Re-vegetating parts State 4,420). patterns, undermined • Transportation less soil and forage following state and analysis.
 

of the well pads • If all Alternative fencing and reduced corridor and road loss from soils erosion private development.
 

requirements were forage; an increase of impact causing because more during production 

would reduce the	 utilized fully, the noxious weeds and a reductions of surface vegetation would hold
 

area of surface decrease in forage disturbance would the soils in place.
 state-permitted 

disturbances could material could occur if be similar to losses to 194 

AUMs.	 be reduced by an discharged produced Alternative B.
 

additional water is too high in
 

35 percent during saline content; and
 

construction and possible health effects
 

40 percent during to livestock if produced
 

production water that is unsuitable 

primarily because for livestock watering.
 

of required
 

transportation
 

corridors.
 

to Alternative B. 

• CBNG PODs 

2-51 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Paleontological Resources 

Paleontological resources consist of fossil-bearing rock formations that underlie the entire Planning Area. Fossil outcrops are relatively rare throughout the emphasis area, but know areas are protected. 

•	 It is unlikely that 

any of the 

1,500 short term 

acres disturbed 

during CBNG 

development 

activities would 

contain noteworthy 

paleontological 

resources. The 

575-acre Bridger 

Fossil Area ACEC 

(only 

paleontological 

resource) would 

not be disturbed. 

•	 Other impacts 

would include 

vandalism and 

removal of fossils 

by amateur fossil 

collectors resulting 

from minor 

increased 

accessibility to 

remote areas. 

•	 Impacts for Alternative B, C, D and E would be nearly the same based on level of disturbance, known Would be same as 

locations of rich fossil areas, geological formation for paleontological features and protected ACECs. Alternatives B, C, 

• There would be between 55,400 and 74,000 short term acres disturbed during CBNG development activities D and E. 

increasing the chances that a minor fossil discovery would be made. Cumulative impacts would disturb an 

additional 33,400 acres increasing the likelihood of additional fossil discoveries. 

• Increased access would include increased vandalism and removal of fossils by amateur fossil hunters. 

• Impacts would be 

similar to the other 

expanded alternatives 

with the exception that 

they would be reduced 

by approximately 65% 

due to fewer APDs 

• Between 19,400 and 

predicted to be issued. 

25,900 short-term acres 

would be disturbed 

during CBNG 

development activities, 

increasing chances that 

a minor fossil 

discovery would be 

made. Cumulative 

impacts would disturb 

additional 11,700 

acres, increasing 

likelihood of additional 

fossil discoveries. 

• Implementation of 

paleontological 

inventories in areas 

of High Potential 

Fossil Yield 

Formations (See 

BLM Instruction 

Memorandum 

2008-2009) would 

result in fewer 

impacts to 

paleontological 

localities since the 

recorded localities 

would be avoided. 

2-52 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Paleontological Resources (continued) 

• There would be 

between 55,400 

and 74,000 short 

term acres 

disturbed during 

CBNG 

development 

activities 

increasing chances 

that a fossil 

discovery would be 

made. Cumulative 

impacts would 

disturb an 

additional 33,400 

acres increasing 

likelihood of 

additional fossil 

discoveries. 

Recreation 

Montana’s natural features offer a variety of year-round recreational opportunities 

•	 Minor loss of land 

for recreation 

purposes and the 

disruption to 

recreation 

activities. 

•	 Exploratory 

activities such as 

drilling and testing 

would temporarily 

displace game 

species locally. 

•	 Moderate loss of 

land for recreation 

purposes and the 

disruption to 

recreational 

activities. 

•	 Increased 

opportunities for 

access to remote 

areas. 

•	 Impacts would be 

similar to 

Alternative B with 

the exception that 

increased erosion 

could lead to a 

reduced amount of 

land available for 

recreation activities 

and could disrupt 

habitat for game 

species. 

•	 Impacts would be • Impacts would be similar 

similar to to Alternative B with the 

Alternative B. exception that no 

requirements for 

transportation corridors 

would moderately 

increase access to remote 

areas. 

• Impacts would be 

similar to those for 

Alternative B. 

• Impacts from federal 

CBNG development 

would occur 

differently than the 

other alternatives 

based on annual and 

watershed-based 

limits. 

• Impacts would be 

similar to those for 

Alternative B in the 

sequence of 

development, but would 

result in lower impacts 

than other alternatives 

due to fewer wells 

developed. 

• Impacts would be 

similar to or lower 

than Alternative B 

in the sequence of 

development, but 

could result in 

lower visual 

impacts than other 

alternatives due to 

use of resource 

screens and 

mitigation and 

management plans 

for development. 

2-53 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Socio-Economics 

Socio-economics address the changes in demographics; social organization including housing attitudes and lifestyles; economics such as employment, unemployment and per capita income; and, government 

revenue sources including taxes, state oil and gas lease income, federal mineral revenues and private landowner revenues. 

•	 Few social impacts 

(only small 

changes in 

employment, 

population, 

demand for 

services, etc.). 

•	 Small impact on 

economic 

conditions as a 

result of new 

production wells. 

• Most new CBNG 

jobs probably 

would be filled by 

workers 

commuting from 

Wyoming. If this 

occurred, social 

benefits and 

impacts could be 

lower than 

described below. 

•	 Social impacts 

would include new 

jobs and new 

population moving 

to the area. 

•	 Economic impacts 

include generation 

of new personal 

and government 

income. 

•	 Additional 

disposal costs 

associated with 

injection of 

produced water. 

•	 Additional 

demands on public 

services. 

• Social impacts • Social impacts • Social impacts same as 

same as Alternative same as Alternative Alternative B, with the 

B, with increase in B, with small exception that public 

impacts on increase in impacts burden to maintain roads 

lifestyles and on lifestyles and may increase depending 

values. values. on landowner access 

• Economic impacts • Economic impacts decisions. 

same as Alternative same as Alternative • Economic impacts same 

B, with increase in B, with small as Alternative B, except 

impacts to water increase in impacts that oil and gas income 

resource users. to water resource may be less depending on 

users. water treatment costs. 

• Because 

development is 

phased, it is likely 

that most new jobs 

would be filled by 

workers commuting 

• Social impacts 

from Wyoming. 

would be similar to 

those for Alternative 

B and lower than 

those for 

Alternatives C 

through E during 

certain years, but of 

longer duration due 

to phased 

• Economic impacts 

development. 

would be fewer than 

those for 

Alternatives B 

through E, but 

would be of longer 

duration due to the 

evening out of 

CBNG activities 

over the phased 

development period. 

• Social impacts would 

be fewer than those for 

other development 

alternatives, with the 

duration of impacts 

similar to that for 

Alternative F due to 

• Economic impacts 

phased development. 

would be fewer than 

those for Alternatives B 

through F, with the 

duration of impacts 

similar to those for 

Alternative F due to 

phased development. 

• Social and 

economic impacts 

similar to 

Alternative F due 

to similar rate of 

CBNG well 

development. 

2-54 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Soils 

Montana has a wide mix of geologic parent material, which produces a vast array of different soil types 

•	 There would be 

minor occurrences 

of soil erosion, 

runoff and 

sedimentation, 

mostly during 

construction 

activities. 

•	 Approximately 

1,500 acres would 

be disturbed short 

term during CBNG 

exploration and 

construction 

activities. 

•	 500 acres would be 

disturbed longer 

term during 

production, with a 

majority of the 

land reclaimed 

after production is 

ceased. 

•	 Soil disturbances 

could be reduced 

by 35 percent or 

higher on a per 

well basis over 

Alternative A. 

CBNG activities 

would result in 

55,400 short term 

acres being 

disturbed. 

•	 32,950 acres 

would be disturbed 

longer term during 

CBNG production, 

with a majority of 

the land reclaimed 

after production is 

ceased. 

•	 No impacts would 

occur to soils from 

CBNG waters. 

•	 CBNG 

development 

activities would 

disturb corridors. 

Approximately 

70,000 short term 

acres of disturbed 

surface area during 

construction 

activities. 

•	 Surface discharge 

and irrigation of 

produced water 

could result in 

approximately 

47,600 acres 

disturbed in the 

long term. 

•	 Impacts including 

levels of 

disturbance would 

be similar to 

Alternative B. 

•	 One favorable side 

effect would be that 

more water would 

be available for 

irrigation. 

•	 Impacts would be similar 

to Alternative B. There 

would be a slight increase 

in the level of disturbance 

due to increased use of 

impoundments to contain 

produced water. Short 

term acres disturbed 

would be approximately 

74,000 while long term 

would be 44,000. 

•	 Produced water would be 

available for beneficial 

use including irrigation. 

•	 No impacts are expected 

to occur on irrigated 

lands or soils 

• Impacts would be 

similar to those for 

Alternative B, 

although some 

impacts would not 

occur or would be 

delayed due to 

implementation of 

cumulative and 

watershed-specific 

numerical limits on 

the number of 

federal CBNG 

APDs approved per 

• Produced water 

year. 

would be available 

for beneficial use, 

including irrigation. 

• Impacts would be 

similar to those for 

Alternative B, although 

impacts would be fewer 

due to the limit on the 

number of federal 

CBNG APDs (323 

versus 910) approved 

• Produced water would 

per year. 

be available for 

beneficial use, 

including irrigation. 

• CBNG 

development 

would result in 

approximately 

55,100 acres being 

disturbed. 

• An estimated 

32,850 acres 

would be disturbed 

longer term during 

production, with 

most of the land 

reclaimed after 

• No impacts would 

production ceased. 

occur to soils from 

CBNG waters. 

2-55 
 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Solid and Hazardous Wastes 

Solid and hazardous wastes are under the jurisdiction of the MDEQ for RCRA wastes, MBOGC for RCRA exempt wastes and the EPA for wastes generated on tribal lands 

•	 Typical solid waste • Impacts for Alternative B, C, D, E, F and G would include increased quantities of waste requiring onsite disposal or transportation to commercial landfills. 

refuse can be • Oil and gas developers are responsible for any damages to property, real or personal, resulting from the lack of ordinary care during operations. Operators are 

disposed of in local required to maintain SPCC plans and immediately remove and spilled or unused non-exempt wastes from the sites therefore no long term impacts to private, 

landfills. state or federal lands would occur from waste products associated with CBNG development. 

•	 Drilling mud and 

cuttings can be 

disposed of onsite 

with the 

landowner’s 

permission. 

•	 Minor impacts 

would also occur 

from the use of 

pesticides and 

herbicides during 

access and 

construction 

activities. 

•	 Cumulative 

impacts from other 

foreseen projects 

would result in 

increased waste 

generated at 

moderate levels for 

commercial 

disposal. 

• Typical solid waste refuse 

could be disposed of in local 

landfills. 

• Drilling mud and cuttings 

could be disposed of onsite 

with the landowner’s 

permission on private surface 

and on BLM-administered 

• Minor impacts would also 

surface with agency approval. 

occur from use of pesticides 

and herbicides during access 

and construction activities. 

• Impacts would include 

increased quantities of waste 

requiring on-site disposal or 

transport to commercial 

landfills. 

• Oil and gas developers would 

be responsible for any 

damages to property, real or 

personal, resulting from the 

lack of ordinary care during 

operations. Operators must 

maintain SPCC plans and 

immediately remove any 

spilled or unused non-exempt 

wastes from the sites. 

• No long-term impacts to 

private, state, or federal lands 

would occur from waste 

products associated with 

CBNG development. 

2-56 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Vegetation 

Emphasis area acreage by land classifications, overlying known coal reserves: Grasslands, 3.55 million (2.56 million in the FSEIS Planning Area); Shrublands, 1.8 million (1.66 million in the FSEIS Planning 

Area); 

Forests, 1.36 million (1.29 million in the FSEIS Planning Area); Riparian Areas, 378,000 (268,000 in the FSEIS Planning Area); Barren Lands, 372,000 (297,000 in the FSEIS Planning Area); 

and Other Areas, 700,000 (345,000 in the FSEIS Planning Area) Forty BLM sensitive plant species have been recorded in one or more of the Planning Area counties. 

• 1,142 acres of 

native habitat 

would be impacted 

under this 

Alternative, more 

than half (580 

acres) in grasslands 

•	 55,400 acres of 

native habitat 

could be impacted 

short term under 

this Alternative, 

more than half 

(21,450 acres) in 

grasslands. 

•	 70,000 acres of • Native habitat 

native habitat could disturbances would 

be impacted short be similar to those 

term under this discussed under 

Alternative, more Alternative B. 

than half (27,300 

acres) in 

grasslands. 

•	 Impacts would be similar 

to those for 

Alternative D, however 

no riparian habitat would 

be affected. Short term 

impacts would be slightly 

increased (74,000 acres) 

due to the use of 

impoundments for water 

management practices. 

•

similar to those for similar to those for 

Alternative B. Alternative B, but 

from proposed 

development 

projects would be 

the land disturbance 

area would be 

approximately 65% 

lower. 

evaluated on a 

watershed-level 

basis. 

• Impacts would be Impacts would be 

• Resource impacts 

• Impacts would be 

similar to those for 

Alternative B. 

• Resource impacts 

from proposed 

development 

projects would be 

evaluated on a 

watershed-level 

basis. 

• Use of resource 

screens and 

watershed-based 

limits on federal 

CBNG 

development 

would result in 

spatial and 

temporal 

distribution of 

impacts similar to 

Alternative F. 

2-57 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Vegetation (cont.) 

•	 Potential minor 

loss of plant 

diversity with 

reclamation. 

•	 On non-federal 

land, Ute ladies’­

tresses could be 

slightly impacted 

• No federal 

by disturbances. 

threatened or 

endangered plant 

species are known 

to occur within the 

Planning Area. 

•	 Potential moderate 

loss of plant 

diversity with 

reclamation. 

•	 On non-federal 

land, Ute ladies’­

tresses could be 

impacted by 

disturbances. 

• No federal 

threatened or 

endangered plant 

species are known 

to occur within the 

Planning Area. 

•	 If SAR values 

exceed 10 in water, 

riparian vegetation 

would be impacted, 

affecting as many 

as 3,535 acres of 

riparian habitat. 

•	 Potential loss of 

plant diversity with 

reclamation. 

•	 On non-federal 

land, Ute ladies’­

tresses could be 

impacted by 

disturbance, SAR 

values and water 

level changes, 

particularly 

inundation. 

• No federal 

threatened or 

endangered plant 

species are known 

to occur within the 

Planning Area. 

•	 Hydrology changes 

may affect as much 

as 2,776 acres of 

riparian habitat due 

to increased stream 

flow. 

•	 Potential loss of 

plant diversity with 

reclamation. 

•	 On non-federal 

land, Ute ladies’­

tresses could be 

impacted by 

disturbance and 

water level 

changes, 

particularly 

inundation. 

• No federal 

threatened or 

endangered plant 

species are known 

to occur within the 

Planning Area. 

•	 No federal threatened or 

endangered plant species 

are known to occur within 

the Planning Area. 

• Annual and 

watershed-based 

limits on federal 

CBNG development 

would result in a 

different spatial and 

temporal 

distribution of 

impacts than for the 

other development 

alternatives. 

• Watershed-based 

analysis would limit 

the amount of 

disturbed habitat on 

BLM-administered 

surface or on private 

surface overlying 

federal minerals 

within each fourth 

order watershed, 

based on the 

potential to affect 

species of special 

concern from habitat 

fragmentation. 

• No federal 

threatened or 

endangered 

plant species are 

known to occur 

within the 

FSEIS Planning 

Area. 

• No federal threatened or 

endangered plant 

species are known to 

occur within the FSEIS 

Planning Area. 

• Watershed-based 

analysis would 

limit the amount of 

disturbed habitat 

on BLMadministered 

surface or on 

private surface 

overlying federal 

minerals within 

each 4th order 

watershed, based 

on the potential to 

affect species of 

special concern 

from habitat 

• No federal 

fragmentation. 

threatened or 

endangered plant 

species are known 

to occur within the 

FSEIS Planning 

Area. 

2-58 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Visual Resource Management 

Visual resources include Montana features such as landform, water, vegetation, color, adjacent scenery, uniqueness, structures and man-made features of aesthetic value 

• Federal and State: • Federal: • Impacts common to • Impacts common to • Impacts would be 

- Dust emissions - There would be Alternative B Alternative B reduced from Alternative similar to those for similar to those for similar to or less 

would reduce impacts to VRM would occur with would occur with C by the mitigation Alternative E in the than Alternative E 

visibility to a small 

degree near active 

field operations. 

- Well pads, roads 

and compressors 

would disrupt the 

visual landscape. 

Semi-permanent 

structures are 

designed to blend 

into the surrounding 

environment. 

- Drill rigs, twotrack trails, heavy 

road-making 

equipment and 

BLM Class III and 

IV areas only. 

• Type of impacts 

common to 

Alternative A 

would occur with 

Alternative B, 

though at a scale 

commensurate 

with development. 

• View shed impacts 

from road network 

would last for 20 

years and then 

reclaimed. 

Alternative C, in 

addition to the 

following: 

• Above ground 

powerlines would 

greatly impact 

skyline and 

viewshed. 

• Visual impacts 

from roads and 

utility lines is 

greatest with this 

alternative until 

reclamation. 

Alternative D, in 

addition to the 

following: 

• Production related 

roads that are not 

reclaimed and made 

part of the 

permanent road 

network would 

result in permanent 

visual impact. 

measures in the Project 

POD for visual resources. 

• Impacts would be 

mitigated as described 

under the Alternative B, 

Mitigation subsection. 

of impacts would 

vary compared to 

other alternatives 

based on annual and 

watershed-based 

federal CBNG 

development limits. 

sequence of 

development, but would 

result in lower impacts 

than other action 

alternatives. 

in the sequence of 

development, but 

could result in 

fewer visual 

impacts than other 

alternatives due to 

screening process 

and use of 

mitigation and 

management plans 

for development. 

generators would 

disrupt the visual 

landscape shortterm. 

• Impacts would be • Impacts would be • Impacts would be 

Alternative E. 

• Locations and levels 

2-59 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative E— 

Alternative B— CBNG Exploration and 

CBNG Development Alternative D— Development with 

with Emphasis on Encourage CBNG Enhanced Mitigation to 

Soil, Water, Air, Exploration and Minimize Environmental Alternative F— Alternative G— Alternative H— 

Alternative A— 

No Action (Existing 

CBNG Management) 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Development While 

Maintaining Existing 

Land Uses 

Impacts While 

Maintaining Existing 

Land Uses 

Phased Development 

Multiple Screens 

(High Range) 

Phased Development 

Multiple Screens (Low 

Range) 

Preferred 

Alternative ­

Multiple Screens 

Wilderness Study Areas 

There are 10 WSAs within the CBNG emphasis area (6 in the FSEIS Planning Area) 

• BLM WSAs are 

closed to oil and 

gas leasing so there 

would be no direct 

impacts to WSAs. 

• There would be no 

direct impacts to 

WSAs from 

CBNG 

development. 

• Same as 

Alternative B. 

• Same as 

Alternative B. 

• Same as Alternative B. 

• There would be no direct 

impacts to WSAs from 

CBNG development. 

• Laws and regulations 

established for WSAs 

WSAs would be 

expected from 

phased CBNG 

development. 

• Same as Alternative F. 

to WSAs would be 

expected from 

CBNG 

development. 

prohibit leasing of WSAs 

designated lands for 

resource extraction. 

Wildlife 

Mammal Species: 

- 10 bats 

- 8 Shrews 

- 34 small mammals 

- 17 predators 

- 4 big game 

Bird Species: Reptiles and Amphibian species 

- 32 waterfowl - 1 salamander 

- 33 shore & wading birds - 4 frogs 

- 18 diurnal & - 4 toads 

- 11 nocturnal raptors - 3 turtles 

- 8 gallinaceous - 2 lizards 

- 8 woodpeckers - 9 snakes 

- 137 songbirds 

Species of Concern consist of 16 mammals, 9 reptiles and amphibians and 22 birds, including: 

- Sage-grouse - Mountain Plover 

- Interior Least Tern - Bald Eagle 

- Gray Wolf - Peregrine Falcon 

- Canada Lynx - Black-tailed Prairie Dog 

- Grizzly Bear - Black-footed Ferret 

• No direct impacts to • No direct impacts 

•	 Direct and indirect 

impacts would occur 

at a level 

commensurate with 

the level of CBNG 

development. 

•	 Direct impacts 

include habitat loss, 

death from vehicle 

collisions and effects 

associated with 

greater human access 

into previously 

untraveled areas. 

•	 Same as 

Alternative A but 

on a much larger 

scale. Twenty-five 

times as many 

wells, roads and 

utility corridors as 

under Alternative 

A. 

•	 6,680 miles of 

roads (2.9 to 

8.8 miles per
 

square mile).
 

•	 Direct and indirect 

impacts would 

occur at a level 

commensurate with 

the level of CBNG 

development. 

Indirect impacts to 

wildlife on 884,000 

to 4.7 million acres 

from:­

•	 Impacts would be 

similar to 

Alternative B. 

•	 Discharged treated 

CBNG water would 

erode riparian and 

wetland habitat. 

•	 Increased livestock 

grazing within 2 

miles of CBNG 

discharges that 

occur in areas 

without summer 

water. 

•	 Direct and indirect 

impacts would occur 

similar to Alternative B. 

•	 Indirect impacts to 

wildlife would occur on 

884,000 to 4.7 million 

acres depending on 

development spacing. 

•	 Loss of intermittent 

wildlife habitat 

associated with streams 

because of groundwater 

withdrawal. 

• Direct impacts would 

be fewer than for other 

development 

alternatives due to 

implementation of the 

wildlife screen. 

• Indirect impacts would 

be fewer than for other 

development 

alternatives due to 

implementation of the 

wildlife screen. 

• Direct impacts would 

be similar to Alternative 

F, but reduced by 

approximately 65% due 

to wells being 

• Indirect effects from 

developed. 

new roads and new 

utility lines would be 

lower than for all other 

development 

alternatives due to 

fewer wells being 

developed. 

• Direct and indirect 

impacts under 

Alternative H 

would be reduced 

relative to other 

development 

alternatives due to 

conditions placed 

on development 

within defined 

crucial sage-grouse 

habitat areas, use 

of BMPs and 

adaptive 

management. 

2-60 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Wildlife (cont.) 

•	 20,697 miles of utility - 9,018 miles of • Through mitigation, • Increased livestock 

corridors (9 to 27.1 roads (3.9 to this Alternative grazing within 2 miles of from new roads 

miles per square mile). 11.9 miles per would not directly CBNG discharges that and new utility 

• Indirect effects 

•	 Indirect impacts to square mile). impact any T&E occur in areas without lines would be 

wildlife on 884,000 to listed wildlife summer water. similar to - 27,917 miles of 4.7 million acres. species.	 Alternatives B and utility corridors • Additional types of	 D, but fewer than (12.2 to 36.6 miles 

impacts include loss of	 for Alternatives C per square mile). high value habitats	 and E while 

such as prairie dog federal restrictions 

towns, sage-grouse are applied. 

leks and big game 

winter range. 

•	 Indirect • Loss of intermittent • Discharge of • Potential indirect • Through implementation of 

impacts on wildlife habitat untreated CBNG impacts to T&E WMPP impacts to T&E listed concern not concern would be important 

wildlife include associated with water into species, such as species would be minimized. federally similar to Alternative F, sagebrush-steppe 

disturbance and streams because of drainages would human disturbance, - Species of concern not protected may but would be reduced habitat impacts 

displacement, groundwater impact riparian and or collisions with federally protected may be be impacted by by approximately 65% could result in 

stress, power withdrawal. Through wetland habitat and vehicles, would impacted by habitat changes habitat loss, due to fewer wells slightly fewer 

lines, noxious mitigation, this associated species occur at a level less caused by vegetation removal disturbance and being developed. impacts to wildlife 

weed invasion, Alternative would not because of poor than Alternative C. or access roads that are not habitat changes, relative to other 

user-created directly impact any water quality and fully recovered with but impacts development 

roads, habitat T&E listed wildlife erosion. reclamation after well would be alternatives, 

fragmentation, species. • Increased livestock abandonment. minimized due particularly sagewater quality grazing within 2 - These impacts would be less to implementing grouse and other 

degradation miles of CBNG than alternative B, C and D the wildlife sagebrush-steppe 

• Species of • Impacts to species of • Thresholds for 

from road discharges that through the implementation of 

the WMPP. This alternative 

screen. species
 

runoff and occur in areas
 

increased without summer would include more holding
 livestock water. ponds than any other
 grazing. development alternative,
 •	 Indirect Consequently, it would 

impacts on include a greater risk of WNV 

wildlife would infection to sage-grouse than occur on any other development 

33,840 to alternative. 

84,000 acres. 

2-61 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Wildlife (cont.) 

•	 Potential indirect • Through • Potential indirect - More water would be 

impacts to T&E mitigation, this impacts to T&E available for wildlife as important
 

species, such as Alternative should species from a result of CBNG sagebrush-steppe 

human not directly impact hydrology changes production. habitat impacts
 

disturbance, or any T&E listed caused by increased
 could result in
 

collisions with wildlife species. water levels may
 

• Thresholds for 

•An adaptive management slightly fewer strategy included as vehicles, could	 impact nesting impacts to wildlife part of the WMP would occur. Impacts	 Interior Least Terns. relative to other 

help minimize impacts would be less than	 If hydrology changes development to wildlife and habitat C or D with the	 from surface water alternatives, by using new restricting of runoff cause riparian particularly sage- information to change utilities and	 vegetation changes, grouse and other or form additional roadways to the	 other T&E species sagebrush- and 

conditions of approval. same corridor.	 may be impacted as grassland-associated 

well, such as nesting species. 

Bald Eagles. 

• Potential indirect Similar to 

mitigation, this concern not impacts to T&E 

• Impacts to sagegrouse impacts from human Alternative F. In 

Alternative would federally protected species, such as populations in disturbance or the long term, 

not directly impact may be impacted human disturbance, crucial habitat collisions with vehicles impacts are 

any T&E listed by habitat changes or collisions with areas would be would be reduced by expected to be the 

wildlife species. caused by vehicles, are lower in this approximately 65% same as F; 

Potential indirect vegetation removal greater under this alternative from other development however, some 

impacts to T&E or access roads not Alternative than because CBNG alternatives due to level of impact 

species, such as fully recovered any other because development in fewer wells being that is greater 

human disturbance, with reclamation of the increased crucial habitat developed. than F may occur 

or collisions with after well number of CBNG areas would be within the shortvehicles, would be abandonment and wells permits. allowed only term (<5 years). 

low because of the by increased when operators 

limited number of access through could demonstrate 

CBNG wells increased roads. retention of 

permitted. existing 

populations (as 

defined). 

• Through • All species of • Potential indirect 

2-62 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Wildlife (cont.) 

•	 Species of concern 

not federally 

protected may be 

impacted by 

habitat changes 

caused by 

vegetation removal 

or access roads not 

fully reclaimed 

after well 

abandonment. 

•	 Potential indirect 

impacts to T&E species 

from changes in riparian 

habitat due to increased 

SAR values and 

hydrology are likely to 

occur under this 

Alternative. Bald Eagles 

and Interior Least Terns 

may also be affected if 

SAR changes affect 

forage fish. 

•	 Species of concern not 

federally protected may 

be impacted by habitat 

changes caused by 

vegetation removal or 

access roads not fully 

reclaimed after well 

abandonment or by 

changing streambed 

hydrology and increased 

SAR and salinity values 

in water and soil. 

•	 More water would be 

available for wildlife. 

•	 Species of concern 

that are not 

federally protected 

may be impacted by 

habitat changes 

caused by 

vegetation removal 

or access roads that 

are not fully 

recovered with 

reclamation after 

well abandonment 

or by changing 

streambed 

hydrology. 

• Alternative G includes 

an adaptive 

management strategy 

which would help to 

minimize impacts to 

wildlife and habitats. 

• Species of concern 

not federally 

protected may be 

impacted by 

habitat loss, 

disturbance and 

habitat changes. 

These impacts may 

be lower than 

under the other 

development 

alternatives due to 

established habitat, 

well development 

thresholds and 

implementation of 

the Wildlife 

Monitoring and 

Protection Plan 

and the wildlife 

screen. 

2-63 
 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Wildlife (cont.) 

• Potential indirect 

impacts such as 

human disturbance, 

or collisions with 

vehicles, would be 

lower than those for 

other development 

alternatives due to 

implementation of 

the Wildlife 

Monitoring and 

Protection Plan, and 

well development 

thresholds. 

• Alternative F would 

include an adaptive 

management 

strategy. This would 

minimize impacts to 

wildlife and 

habitats. 

• Potential indirect 

impacts such as 

human 

disturbance, or 

collisions with 

vehicles, would be 

lower than those 

for other 

development 

alternatives due to 

implementation of 

the Wildlife 

Monitoring and 

Protection Plan, 

and well 

development 

thresholds. 

• Alternative H 

would include an 

adaptive 

management 

strategy. This 

would minimize 

impacts to wildlife 

and habitats. 

2-64 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative E— 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Wildlife (Aquatic Resources) 

Fish species vary between watersheds within 

the CBNG emphasis area from 8 in the 

Little Big Horn River to 47 in the 

Yellowstone River 

Special Status Aquatic Species: 

- Montana Arctic grayling 

- Pallid sturgeon 

Species of Special Concern/BLM sensitive species: 

- Blue sucker - Northern redbelly X Finescale dace 

- Paddlefish - Pearl Dace 

- Sauger - Sturgeon chub 

- Yellowstone cutthroat trout 

• Minor short-term • The same types of • The same types of • The same types of 

impacts on aquatic impacts described for impacts described for impacts described described for Alternative A types of 6,500 CBNG wells are impacts described 

resources during Alternative A (No Alternative A would for Alternative A would occur under impacts about 65% fewer than for Alternative A 

CBNG exploration Action) would occur occur under would occur under Alternative E, but they would described for the other action would occur under 

and production under Alternative B. Alternative C, but Alternative D, but occur on a greater scale Alternative A alternatives, resulting Alternative H, but 

may result from 

increased sediment 

delivery and its 

effects on aquatic 

habitat and 

organisms, 

possible impedance 

of fish movements, 

potential for 

accidental spills of 

petroleum products 

and possibly 

increased fish 

harvest. 

• Relatively minor 

long-term increases 

in river flow and 

TDS concentration 

from production 

water discharge 

would not be 

expected to impact 

aquatic resources. 

• The scale of potential 

impacts associated 

with sediment 

delivery, fish 

movements, 

petroleum spills and 

fish harvest would be 

much greater under 

Alternative B 

because of the 

development of over 

18,000 CBNG wells 

across a much larger 

geographic area. 

• No CBNG 

production water 

would be discharged 

to surface drainages 

under Alternative B 

and there would be 

no potential for 

impacting aquatic 

resources from this 

particular activity. 

they would occur on 

a far greater scale 

because of the 

development of over 

16,000 CBNG wells. 

• A total of 0.67 billion 

cubic feet of 

untreated CBNG 

production water 

would be discharged 

to drainages each 

year. Resultant flow 

and TDS increases 

could potentially 

impact aquatic 

organisms, especially 

in smaller drainages 

during dry times of 

the year. 

they would occur 

on a far greater 

scale because of the 

development of 

over 16,000 CBNG 

wells. 

• The annual 

discharge of 

2.24 billion cubic 

feet of treated 

CBNG production 

water through 

pipelines or 

constructed water 

courses and 

resultant flow 

increases could 

impact aquatic 

resources in smaller 

drainages during 

dry times of the 

year. 

because of the development 

of over 18,000 CBNG wells. 

• The potential for affecting 

aquatic resources would be 

greater under Alternative E 

than under Alternatives B or 

D, but less than under 

Alternative C. 

water courses for the 

conveyance of CBNGproduced water and resultant 

flow increases could impact 

aquatic resources in smaller 

drainages during yearly dry 

periods. 

• About 2.24 billion cubic feet 

of CBNG production water 

would be managed through 

flexible options, but would 

allow no degradation of 

water quality (including 

thermal criteria). 

would occur 

under 

Alternative F, 

but the 

impacts would 

occur on a 

greater scale 

because of the 

development 

of more than 

16,000 

for affecting 

aquatic 

resources 

would be 

greater under 

Alternative F 

than under 

Alternatives B 

or D, but 

lower than 

under 

in a lower overall 

impact. 

resources would be 

similar in nature to 

those for Alternative 

F, but substantially 

fewer than those for 

Alternative F due to 

fewer wells being 

developed. 

would be managed 

through flexible 

management options, 

thus reducing the 

volume of untreated 

water discharged to 

surface waters. 

the impacts would 

occur on a greater 

scale because of 

the development 

of more than 

16,000 producing 

CBNG wells. 

affecting aquatic 

resources would 

be greater under 

Alternative H than 

under Alternatives 

B or D, but lower 

than under 

Alternative C. 

Alternative C. 

• The same types of impacts • The same • The approximate • The same types of 

• The effects on aquatic 

• The potential for 

• Pipelines or constructed 

producing 

CBNG wells. 

• The potential 

• About 0.78 billion 

cubic feet of CBNG 

production water 

2-65 
 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Wildlife (Aquatic Resources)(cont.) 

•	 The required WMPs 

and MPDES permits 

would provide 

assurances that water 

quality, aquatic 

resources and 

beneficial uses of 

receiving waters 

would be protected. 

•	 The potential for 

affecting aquatic 

resources in sensitive 

drainages would be 

greater than for 

Alternatives B and D, 

but lower than under 

C. 

•	 Implementation of 

Wildlife Monitoring 

and Protection Plan 

would reduce 

impacts to aquatic 

habitat wildlife and 

invertebrates. 

2-66 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Wildlife (Aquatic Resources)(cont.) 

•	 Conditions of • Based on fish • Conditions of • The treatment of 

MPDES Permits species present, MPDES Permits CBNG production constructed water provide assurances that constructed water 

would provide fisheries would provide water prior to its courses for the water quality, aquatic courses and 

legally enforceable management legally enforceable discharge would conveyance of resources and beneficial resultant flow 

assurances that policies, fisheries assurances greatly reduce the CBNG-produced uses of receiving waters increases could 

water quality, resource values preventing the potential for water and resultant 

• Pipelines or • MPDES permits would • Pipelines or 

• Would limit CBNG 

would be protected. impact aquatic 

aquatic resources and the projected degradation of elevated TDS and flow increases could resources in 

and the beneficial intensity of CBNG water quality, salinity impacts on impact aquatic development and total smaller drainages 

uses of receiving development, the aquatic resources aquatic resources. resources in smaller disturbed habitat annually during dry times 

waters would not drainages most and the beneficial • MPDES Permits drainages during 

• A sequential and • About 

and by watershed. of the year.
 

be degraded by sensitive to the uses of receiving would provide legal 

• About 2.24 billion 

yearly dry periods.
 

production water effects of CBNG waters. assurances that
 controlled development 2.24 billion cubic 

discharges. development • The potential for water quality, cubic feet of CBNG schedule, combined with feet of CBNG­

•	 Impacts from would be the affecting aquatic aquatic resources production water watershed-level analysis, produced water 

CBNG Lower Bighorn, resources in the and beneficial uses would be managed would provide a would be 

abandonment Upper Tongue and sensitive drainages of receiving waters through flexible framework for assessing managed through 

would be minor Little Bighorn; would be greater would be protected. options, but no potential impacts through flexible options, 

and subside over then the Lower under Alternative C • The potential for degradation of water a systematic monitoring but no 

time. Tongue, Little than under affecting aquatic quality would be 

• Would incorporate an 

program. degradation of 

Powder and Alternatives B or resources in the allowed (including water quality 

Rosebud; followed D. sensitive drainages thermal criteria). adaptive management would be 

by the Mizpah. would be greater Required WMPs and approach in the phased allowed 

•	 The potential for under Alternative D MPDES permits development process by (including 

affecting aquatic than under would provide using relevant monitoring thermal criteria). 

resources in Alternative B but assurances that data. 

sensitive drainages less than under water quality, 

would be less Alternative C. aquatic resources permits would 

under and beneficial uses provide 

Alternative B than of receiving waters assurances that 

under Alternatives would be protected. water quality, 

C or D. aquatic resources 

and beneficial 

uses of receiving 

waters would be 

protected. 

• Required WMPs 

and MPDES 

2-67 
 

 

 

 

CHAPTER 2 

Alternatives 

TABLE 2-3 

COMPARISON SUMMARY OF IMPACTS 

Alternative A— 

No Action (Existing 

CBNG Management) 

Alternative B— 

CBNG Development 

with Emphasis on 

Soil, Water, Air, 

Vegetation, Wildlife 

and Cultural 

Resources 

Alternative C— 

Emphasize CBNG 

Development 

Alternative D— 

Encourage CBNG 

Exploration and 

Development While 

Maintaining Existing 

Land Uses 

Alternative E— 

CBNG Exploration and 

Development with 

Enhanced Mitigation to 

Minimize Environmental 

Impacts While 

Maintaining Existing 

Land Uses 

Alternative F— 

Phased Development 

Multiple Screens 

(High Range) 

Alternative G— 

Phased Development 

Multiple Screens (Low 

Range) 

Alternative H— 

Preferred 

Alternative ­

Multiple Screens 

Wildlife (Aquatic Resources)(cont.) 

• Potential for 

affecting aquatic 

resources in 

sensitive drainages 

would be greater 

than for 

Alternatives B and 

D, but lower than 

for C. 

• Would incorporate 

an adaptive 

management 

approach in the 

phased development 

process by using 

relevant monitoring 

data. 

• The potential for 

affecting aquatic 

resources in 

sensitive drainages 

would be greater 

than for 

Alternatives B and 

D, but lower than 

for C. 

• Would incorporate 

an adaptive 

management 

approach in the 

phased 

development 

process by using 

relevant 

monitoring data. 

2-68