Appendix A 

Mitigation Measures 
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

Air Resources 

• Overland Pass will implement its Traffic and Transportation 

Management Plan that includes dust control measures. 

all lands, unless otherwise 

specified in the plan 

• Overland Pass will employ dust suppression techniques, such as 

watering construction areas as necessary in construction zones 

near residential and commercial areas and along major highways 

and interstates. 

all lands 

• Dust control measures would be used on access roads and the 

construction ROW when fugitive dust resulting from construction 

activities creates a nuisance to nearby residences or a safety 

hazard. Overland Pass’ EIs and agency monitors will determine on 

a case-by-case basis whether or not dust has become a nuisance 

or hazard in a particular area. 

all lands 

• If water is obtained from wells or surface water sources to 

suppress dust, written approval from the landowner or regulatory 

agency will be obtained prior to appropriation. 

all lands 

• Use of salts as a suppressant will be limited to magnesium 

chloride, if allowed by local, state, and federal agencies for 

application. Magnesium chloride will not be used along the 

pipeline construction ROW on federal lands. 

all lands 

• Soils tracked on to paved roads will be removed. Soil tracked onto 

paved roads that extends more that 50 feet from the point of origin 

will be removed within 1 day of discovery. 

all lands 

Geology and Mineral Resources 

• Overland Pass will implement its Blasting Plan that identifies 

blasting procedures including safety, use, storage, and 

transportation of explosives. 

all lands, unless otherwise 

specified in the plan 

• All blasting will be performed by registered licensed blasters who 

will be required to secure all necessary permits and comply with 

regulatory requirements in connection with the transportation, 

storage, and use of explosives, and blast vibration limits for nearby 

structures, utilities, wildlife, and fish (where blasting is conducted in 

waterbodies). 

all lands 

• Appropriate flags, barricades, and warning signals will be used to 

ensure safety during blasting operations. Blast mats would be 

used when needed to prevent damage and injury from fly rock. 

all lands 

• Blasting in the vicinity of other pipelines will be coordinated with the 

pipeline operator, and would follow operator-specific procedures, 

as necessary. 

all lands 

• Overland Pass will either repair, or fairly compensate the owner, for 

damages that result from blasting. 

all lands 

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Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

Paleontological Resources 

• Overland Pass will implement its Monitoring and Mitigation Plan 

(Paleo Plan) to protect fossil resources that may be encountered 

during project construction, including the resources identified 

during the field survey. 

federal lands, unless 

otherwise specified in the 

plan 

• High sensitivity paleontological units (e.g., those requiring 

avoidance, excavation, recording of sites) have been identified. 

federal lands only 

• The Paleo Plan includes provisions for the preparation and curation 

of any fossil collections. 

federal lands only 

• The Paleo Plan includes provisions for the preparation of a final 

report based on the data recovered. 

federal lands only 

• All work conducted under the Paleo Plan will be performed by 

qualified paleontologists with trained assistants. 

federal lands only 

• Future maintenance activities that occur outside the previously 

excavated trench line in Condition 1 and 2 areas will be evaluated 

for Paleontological resources prior to surface disturbance. 

federal lands only 

Soils 

Erosion 

• Overland will implement its POD that details construction 

procedures, environmental requirements, project plans, and 

mitigation measures to be used during construction of the 

proposed Overland Pass Pipeline Project. 

all lands, unless otherwise 

specified in the plan 

• Temporary erosion and sediment control devices will be installed 

promptly after soil disturbance and would be inspected on a daily 

basis in areas of active construction; on a weekly basis in areas 

with no construction; and within 24 hours of each 0.5 inch of 

rainfall. 

all lands 

• Damaged temporary erosion and sediment control structures will 

be repaired within 24 hours of identification. 

all lands 

• Overland Pass will construct slope breakers across the pipeline 

construction ROW to slow the velocity of runoff and move water off 

the ROW. 

all lands 

• Temporary slope breakers (e.g., certified weed-free straw bales, silt 

fence, earthen berms) will be used during construction, and 

permanent slope breakers will be installed during final grading 

following backfilling, as needed. 

all lands 

• Slope breakers will be constructed and maintained according to 

slope-dependent spacing indicated in the Construction, 

Reclamation, and Revegetation Plan. 

all lands 

A-2
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• Overland Pass will install and maintain sediment barriers (e.g., silt 

fences, staked certified weed-free straw bales, combination of 

both) at the base of slopes adjacent to road crossings, waterbody 

crossings, and wetlands, as appropriate, and in other areas as 

necessary until permanent revegetation measures are judged 

successful and the potential for siltation is minimized. 

all lands 

• Trench breakers consisting of sacks of soil or sand, polyurethane 

foam, or bentonite clay bags will be installed around the pipe in the 

trench to prevent subsurface channeling of water along the trench. 

all lands 

• Topsoil will not be used for trench breakers. all lands 

• Permanent trench breakers will be installed on slopes just before 

backfilling. The spacing of trench breakers will be determined by a 

qualified professional or installed at the same spacing as 

permanent slope breakers. 

all lands 

• Trench breakers also will be installed on slopes greater than 

5 percent that are adjacent to waterbodies and wetlands. 

all lands 

• Overland Pass will attempt to complete final cleanup and 

installation of permanent erosion control measures in an area 

within 20 days (10 days in residential areas) after backfilling the 

trench in that area, weather and soil conditions permitting. 

all lands 

• In no case will final restoration of an area be delayed beyond the 

next available seeding season. 

all lands 

• Overland Pass will make every effort to ensure the rapid, 

successful establishment of vegetation on areas requiring 

revegetation as described in the Construction, Reclamation, and 

Revegetation Plan. 

all lands 

• Following final grading and cleanup, Overland Pass will condition 

the construction ROW for planting including the preparation of a 

seedbed to a depth of 3 to 4 inches and application and 

incorporation of soil amendments at rates agreed to by the 

landowner or land management agency, or specified in writing by 

the local soil conservation authority. 

all lands 

• On the PNG, certified weed-free straw or hay mulch will be crimped 

in at a rate of 1.5 tons/acre. 

PNG only 

• Where disturbed slopes are greater than 20 percent, Overland 

Pass will utilize stabilization measures immediately after final 

grading such as applying 1.5 tons per acre of weed free straw 

mulch, soil pocking, or installing commercial erosion control fabrics. 

These measures also will be utilized to minimize the effects of wind 

and water erosion on less severe slopes where sandy or other 

erosion prone soils create conditions that are adverse to achieving 

successful reclamation. On private lands, Overland Pass will utilize 

the same measures unless other requirements are required by the 

landowner. 

all lands except the PNG 

A-3
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• On the PNG, pocking will not be used. At the time of final slope 

recontouring, Overland Pass will install photodegradable or 

biodegradable erosion control fabric that is non-toxic to vegetation 

or germination of seed, and non- toxic or injurious to humans or 

wildlife, on waterbody banks and slopes over 10 percent. Overland 

Pass will anchor the erosion control fabric in accordance with the 

manufacturer’s specifications 

PNG only 

• Overland Pass will employ additional measures in areas of heavy 

compaction; the additional measures are discussed in greater 

detail in the Construction, Reclamation, and Revegetation Plan. 

all lands 

• Overland Pass will seed areas to be revegetated in accordance 

with written recommendations for seed mixes, rates, and dates 

obtained from the local soil conservation authorities or land 

management agencies. 

all lands 

• Seeding and mulching in cultivated areas will conform to the 

adjacent off ROW area unless otherwise requested in writing by 

the landowner. 

all lands 

Open Trench 

• In the Kemmerer and Rock Springs field offices, open trench 

sections will be limited to a 10-day period (RP 0 to RP 110). 

Exceptions may be made through a variance approval on a caseby-case basis, when rocky conditions exist. 

Kemmerer and Rock 

Springs BLM land only 

• To minimize topsoil erosion, hydrologic impacts, and potential 

impacts to range and wildlife on the PNG, Overland Pass will limit 

the amount of trench open at one time to no more than 2 miles at 

the end of each construction day. Trench plugs will be installed at 

0.5-mile intervals (except at previously agreed upon locations such 

as road crossings). 

PNG only 

Topsoil Segregation 

• Double-ditching will be used for trenching in eastern Colorado and 

Kansas, along Spreads 3, 4, and 5. 

all lands 

• Trenchline and spoil side and/or the full ROW practices will be 

used in areas where double-ditching is not used. In arid areas 

(e.g., Wyoming and some portions of Colorado along Spreads 1, 2, 

and 3) with limited topsoil, topsoil may be removed from the full 

ROW. 

all lands except PNG 

• In all areas, stripped topsoil will be stored separately and not 

allowed to mix with trench spoil. 

all lands 

• The PNG will allow a 50-foot offset from the existing Southern Star 

pipeline. As part of this mitigation, Overland Pass has agreed to a 

one-time reseeding of identified portions of the southern half of the 

Southern Star ROW. The total area to be reseeded will not exceed 

25 acres. 

PNG only 

A-4
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• On the PNG, synthetic polyacrilamide (PAM) tackifiers will be used 

to control topsoil erosion if the EI or PNG inspector determines 

there is a need and the PNG inspector requests tackifer 

application. Tackifer application will occur within 24 hours of 

request. Only anionic PAM should be used as it is safe to humans, 

wildlife, and fisheries. Magnesium chloride will not be used on the 

PNG. 

PNG only 

• On non-federal lands in Wyoming and portions of Colorado, 

6 inches of topsoil will be removed, unless it is determined by the 

EI or Compliance Monitor that there is not 6 inches of suitable 

topsoil present. Where deep topsoil is present on non-federal 

lands in Colorado and Kansas, 1 foot of soil will be removed on the 

trenchline and spoil side to minimize impacts on agricultural 

activities. 

non-federal lands only 

• On lands managed by the BLM and the ANF, full ROW topsoil 

stripping will occur to a depth of 6 inches. On the PNG, the full 

depth of the topsoil horizon will be removed from the trenchline 

only. 

federal lands only 

• Following backfilling and rough grading of the construction ROW, 

the stripped topsoil will be returned to its original position. 

all lands 

• Topsoil will not be used to pad the pipe or to manufacture trench 

breakers. 

all lands 

• Topsoil segregation will be monitored by clearing inspectors and 

Overland Pass’ EIs, and, where required, agency monitors. 

all lands 

Soil Compaction and Rutting 

• Overland Pass will minimize compaction by restricting activities on 

susceptible soils during wet soil conditions. 

all lands 

• Overland Pass will identify areas of compacted soils by conducting 

compaction tests across the construction ROW using appropriate 

devices, and will plow severely compacted soils with a paraplow or 

other deep tillage implement, or other methods as agreed to by the 

landowner or land management agency. 

all lands 

• Overland Pass would test for compaction at regular intervals no 

less than every 0.25 mile on the working side of the ROW. Where 

the soil has a 15 percent increase in bulk density from the average 

undisturbed density, mitigate for compaction by ripping to the depth 

of compaction with a ripper or subsoiler. 

federal lands 

• On the PNG, the entire length of the working side of the ROW will 

be ripped to the depth of compaction using the required 

compaction reduction tool, equipped with winged shanks. 

PNG only 

• Where topsoil is segregated from the working side of the 

construction ROW or additional temporary workspace areas, 

Overland Pass will decompact the subsoil first before re-spreading 

topsoil. 

all lands 

A-5
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• In areas where topsoil has not been removed, rutting from 

construction equipment will be considered excessive if greater than 

4 inches on BLM and ANF lands, or greater than 3 inches on PNG 

lands. 

federal lands only 

• On federal lands, Overland Pass will consult with the applicable 

federal agency on roads that require maintenance or reclamation 

during or after construction. Two track roads found to be disturbed 

by construction activities will be reclaimed, at the agencies 

discretion, by decompacting soils, constructing permanent erosion 

control (such as drivable water bars), and reseeding the entire 

roadbed. The two- track will be allowed to reestablish through 

normal traffic patterns and use. 

federal lands only 

Stony/Rocky Soils and Shallow-to-Bedrock Soils 

• Overland Pass will segregate topsoil from trench spoil and will 

replace topsoil after cleanup. 

all lands 

• Overland Pass will remove excess rock from the top 12 inches of 

soil, to the extent practical, in cultivated and rotated croplands, 

hayfields, pastures, residential areas, and other areas at the 

landowner’s or land management agency’s request. In these areas, 

the amount of rock on the ROW after construction will be similar to 

adjacent, off-ROW areas 

all lands 

• Overland Pass will take precautions to minimize the mixing of blast 

rock with backfill and will replace rock in the trench to a level that is 

not higher than the original bedrock profile. 

all lands 

• In areas where bedrock is within 12 inches of the surface, Overland 

Pass will replace rock in the trench to the original bedrock profile, 

and will then backfill the remaining depth with excavated subsoil 

before replacing the topsoil. 

PNG only 

• Where necessary, excess rock would either be hauled off the ROW 

or, subject to landowner or land management agency approval and 

any applicable permit conditions, disposed of on the ROW. 

all lands 

Droughty Soil 

• In areas of droughty soils, Overland Pass will apply mulch and 

stabilize the soil surface to minimize wind erosion and to conserve 

soil moisture. 

all lands 

Drain Tiles and Irrigation Systems 

• Overland Pass will replace/repair any drain tiles or irrigation 

systems damaged by construction activities in accordance with the 

Construction, Reclamation, and Revegetation Plan. 

all lands 

A-6
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

Spills 

• Overland Pass will implement its Spill Prevention, Containment, 

and Countermeasure (SPCC) Plan, which specifies cleanup 

procedures in the event of soil contamination from spills or leaks of 

fuels, lubricants, coolants, or solvents. 

all lands, unless otherwise 

specified in the plan 

• If pre-existing contamination is encountered during trenching 

operations, Overland Pass will suspend work in the area of the 

suspected contamination until the type and extent of the 

contamination is determined. The type and extent of 

contamination, the responsible party, and local, state, and federal 

regulations would determine the appropriate cleanup method(s) for 

these areas. 

all lands 

Aboveground/Ancillary Facilities 

• If contractor yards are located in rangeland, topsoil will be stripped 

and stored at the edge of the yard and temporary traffic lanes will 

be installed by placing gravel over geotextile fabric. 

all lands 

• Upon completion of the project, traffic lanes will be removed, 

compacted soils would be mitigated according to the Construction, 

Reclamation, and Revegetation Plan, and topsoil will be restored to 

its original position. 

all lands 

• Overland Pass will identify roads that will be used on a temporary 

basis to transport personnel, equipment, and vehicles including 

high clearance vehicles and heavy trucks, and materials to the 

proposed project work areas. Overland Pass will implement its 

Traffic and Transportation Management Plan to minimize impacts. 

all lands, unless otherwise 

specified in the plan 

Water Resources 

Surface Water 

• To minimize potential impacts on water quality, Overland Pass will 

implement the measures contained in Overland Pass’s 

Construction, Reclamation, and Restoration Plan, including, but not 

limited to: installing and maintaining sediment barriers to prevent 

silt-laden water from entering wetlands and waterbodies; restoring 

original contours as practical; revegetating disturbed areas; and 

use of energy-dissipating devices to disperse and slow the velocity 

of any water discharges during construction. 

all lands, unless otherwise 

specified in the plan 

• Overland Pass will provide written notification to the authorities 

responsible for potable surface water supply intakes located within 

3 miles downstream of the crossing at least 1 week before 

beginning work in a waterbody, or as otherwise specified by that 

authority. 

all lands 

• Overland Pass will notify the appropriate state authorities at least 

48 hours before beginning trenching or blasting within the 

waterbody, or as specified in state permits. 

all lands 

A-7
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• The size of extra workspace areas will be limited to the minimum 

size needed to construct the waterbody or wetland crossing. 

Overland Pass will locate all extra workspace areas at least 50 feet 

away from the edge of the waterbody, wetland, or riparian area on 

federally managed land and 10 feet from the edge of the waterbody 

or wetland on private land. This buffer distance would be applied to 

flowing waters at the time of construction. On federally managed 

land, spoil excavated from the waterbody trench will be placed or 

stored a minimum of 50 feet from the edge of the waterbody, 

wetland, or adjoining riparian vegetation. 

federal lands/private lands 

• Where waterbodies are adjacent to the construction ROW, 

sediment barriers will be installed along the edge of the 

construction ROW as necessary to contain spoil and sediment 

within the construction ROW or designated extra workspace areas. 

all lands 

• Trench plugs will be used at all waterbody crossings, as necessary, 

to prevent diversion of water into upland portions of the pipeline 

trench and to keep any accumulated trench water out of the 

waterbody. 

all lands 

• All equipment will be parked overnight and/or fueled at least 

100 feet from a waterbody or wetland boundary on non-federally 

managed land and at least 500 feet from a waterbody, wetland, or 

riparian vegetation boundary on federally managed-land. Overland 

Pass will not store hazardous materials, fuels, or lubricants within 

500 feet from a waterbody, wetland, or municipal watershed area. 

Concrete coating activities will not be performed within 100 feet of 

a waterbody or wetland boundary. 

federal lands/private lands 

• Overland Pass will attempt to complete all in-stream work within 

24 hours for all minor waterbody crossings and within 48 hours for 

intermediate waterbody crossings. 

all lands 

• During wet ditch crossings, streambed spoil will be removed and 

subsequently restored to retain the natural bed materials of the 

streambed. Under no circumstances will foreign substrate materials 

(e.g., introduced gravel) be used to back-fill a channel crossing, 

unless they are native to the immediate locale and mimic the 

natural bed material. This practice will apply to perennial, 

intermittent, and ephemeral channels on federal lands. 

federal lands 

• On the PNG, construction across waterbodies that are flowing at 

the time of construction may be delayed for 2 days. Overland Pass 

will use open cut crossing methods if the construction delay results 

in the waterbody drying up due to a weather event. If delaying 

construction does not achieve this objective, intermittent 

waterbodies that are flowing at the time construction will be 

crossed using either the flume or dam and pump crossing method. 

PNG only 

A-8
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

Hydrostatic Test Water 

• Overland Pass will implement their Hydrostatic Test Plan, which 

includes procedures for hydrostatic test water appropriations and 

discharges. Overland Pass will acquire the necessary permits from 

state agencies before withdrawing hydrostatic test water, including 

specific approvals from applicable resource agencies. 

all lands, unless otherwise 

specified in the plan 

• No chemical or biological additives will be allowed during 

hydrostatic testing unless approved by the appropriate agency 

responsible for the NPDES permit. 

all lands 

• When discharging onto upland locations, Overland Pass will use 

energy-dissipating devices (e.g., filter bag, straw bale structures) to 

dissipate and slow the velocity of the discharge water. On the 

PNG, sediment filtration bags will be used in all instances during 

water discharge. 

all lands/PNG only 

• Overland Pass will consult with appropriate state and federal 

agencies (USFWS and others) before discharging hydrostatic test 

waters directly into surface waterbodies. Agency recommendations 

will be implemented prior to such direct discharges, which as 

Overland Pass proposes, will be made to the waterbody of origin 

where the surface water was withdrawn. Test water that is not 

discharged directly to surface waterbodies will be discharged onto 

stable upland locations near the point of withdrawal, or sprayed on 

level or nearly level croplands as irrigation water. Irrigation water 

applications will be done in coordination with landowners as 

proposed. Stable upland areas will have slopes less than 

10 percent, be minimally susceptible to sheet and rill erosion by 

having suitable soil and abundant vegetation, and be large enough 

to provide adequate infiltration while avoiding concentrated flow on 

land surfaces. Discharge rates shall be controlled to minimize 

channel and gulley erosion. Hydrostatic test water will not be 

disposed of via wells or other means of groundwater injection. 

all lands 

Groundwater 

• Upon completion of construction, Overland Pass will restore the 

ground surface as closely as practicable to original contours and 

revegetate the ROW to facilitate restoration of preconstruction 

overland flow and recharge patterns. 

all lands 

• Overland Pass will either repair or replace potable water supply 

wells damaged by construction activities, or fairly compensate the 

landowner for damage to potable water supply wells resulting from 

pipeline construction. 

all lands 

• Overland Pass will contact private well owners to obtain 

groundwater. 

all lands 

A-9
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• Overland Pass will continue to coordinate with those local and 

regional districts during the procurement, permitting and use, and 

discharge of groundwater for project purposes. Coordination with 

groundwater management districts will be integrated with 

regulatory interactions with the respective state water resources 

agencies. 

all lands 

• Groundwater pumped and discharged aboveground for 

construction purposes will meet agricultural water quality standards 

in the respective states and/or districts where it is discharged. 

all lands 

• When groundwater is observed during construction (e.g., sites 

requiring dewatering due to groundwater, saturated wetlands), 

permanent trench breakers will be installed to prevent unintentional 

transport of groundwater by the pipeline trench. 

all lands 

• If a pipeline rupture occurs within 500 feet of a groundwater supply 

source (well or spring), Overland Pass will immediately notify the 

owner of the source, and will comply with any mitigation and/or 

monitoring provisions reached through agreements with the source 

owner and appropriate regulatory agencies. 

all lands 

Floodplains, Wetlands, and Riparian Areas 

• Overland Pass will implement procedures described in the 

Construction, Reclamation, and Revegetation Plan that include 

best management practices for restoring floodplain surfaces and 

subsurface hydrology. 

all lands, unless otherwise 

specified in the plan 

• Overland Pass would minimize impacts to wetlands and enhance 

vegetation recovery by following the wetland construction and 

restoration guidelines contained in the Stream Crossing and 

Wetland Protection Plan developed for the project. 

all lands, unless otherwise 

specified in the plan 

• In riparian wetland areas, Overland Pass will cut the existing 

vegetation to ground level, leaving existing root systems intact. Cut 

vegetation will be removed from these areas for disposal. Grading 

activities will be limited to the area directly over the pipeline trench. 

Except if standing water is present, up to 1 foot of topsoil will be 

stripped and separated from the trench spoil. Overland Pass will 

limit the pulling of stumps to the trench area except where safety 

considerations necessitate stump removal. Excavated stumps will 

be removed from the wetland. 

all lands 

• At least one of the EIs employed on each spread will have 

knowledge of the wetland conditions of the project. 

federal lands only 

• If dewatering of the trench is necessary, it will be conducted in a 

manner designed to prevent heavily silt-laden water from entering 

a waterbody or undisturbed portions of the wetland. 

all lands 

• Overland Pass will ensure that all disturbed areas are successfully 

revegetated with wetland herbaceous and/or woody plant species. 

all lands 

• No lime or fertilizer will be used in wetland areas. all lands 

A-10
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• During operation of its pipeline, Overland Pass will only allow 

herbaceous vegetation in the 10-foot-wide strip centered over the 

pipeline. All woody vegetation greater than 15 feet in height will be 

removed from a 25-foot-wide strip centered over the pipeline to 

eliminate problems with large root structures affecting the pipeline. 

all lands 

• Herbicides or pesticides will not be used in or within 100 feet of a 

wetlands except as allowed by the appropriate land management 

agency or state agency. 

all lands 

Vegetation 

• Overland Pass would use pipeline construction industry standard 

practices and BMPs for site stabilization and vegetation restoration 

in areas disturbed by construction as identified in the Construction, 

Reclamation, and Revegetation Plan. 

all lands, unless otherwise 

specified in the plan 

• On federal land, Overland Pass will be responsible for ensuring 

successful revegetation of soils disturbed by project-related 

activities. Revegetation success will be monitored for 5 years (in 

July, first, third, and fifth growing seasons) following project 

completion to evaluate revegetation and erosion control success, 

according to the Construction, Reclamation, and Revegetation 

Plan. 

federal lands, except PNG 

• On the PNG, monitoring will occur on an annual basis for the first 

five years, and where problem areas exist thereafter, and will be 

subject to the same reporting standards as for the BLM. 

PNG only 

• All areas disturbed by construction activities will be reseeded and 

allowed to revegetate naturally with tree and shrub species after 

construction is completed. This stipulation does not preclude ROW 

vegetation maintenance practices proposed by Overland Pass. 

all lands 

• Overland Pass will implement reclamation procedures on disturbed 

lands immediately following construction as described in the 

Construction, Reclamation, and Revegetation Plan. 

all lands, unless otherwise 

specified in the plan 

• On federal lands, seeding will take place immediately after 

re-grading, but no later than 20 days after regrading is completed, 

regardless of the time of year, unless severe weather precludes 

these activities. If seeding cannot be done within the recommended 

seeding dates, the appropriate interim erosion control measures 

discussed in the Construction, Reclamation, and Revegetation 

Plan would be installed and seeding of permanent vegetation 

would be performed at the beginning of the next season. 

federal lands only 

A-11
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

Noxious Weeds and Invasive Plants 

• Overland Pass will implement their Weed Management Plan that 

incorporates details regarding known occurrences of noxious and 

invasive weeds along the proposed project, current treatment of 

known noxious weed areas, and mitigation measures to minimize 

the spread and establishment of noxious weeds and non-native 

invasive species. 

all lands, unless otherwise 

specified in the plan 

• Prior to construction, Overland Pass will conduct surveys of the 

areas of known and anticipated infestations of noxious weeds to 

identify locations of infestations or presence of noxious weed 

species identified by federal, state, and local agencies. Known 

infestations will be identified and mapped on environmental 

alignment sheets to facilitate post construction weed monitoring. 

all lands 

• Areas of the ROW where weed infestations are identified will be 

clearly marked prior to construction. In these areas, Overland 

Pass will maintain segregated topsoil in areas identified as 

supporting noxious weeds adjacent to the areas from which they 

are obtained to eliminate the transport of soil-born noxious and 

invasive weed propagules to other areas along the ROW. During 

reclamation, the Contractor would return topsoil and vegetative 

material to the areas from which they were obtained. 

all lands 

• Prior to the beginning of construction and at state lines, all 

contractor vehicles and equipment will be cleaned of soil and 

debris capable of transporting weed propagules. All contractor 

vehicles and equipment will be inspected by the EI(s) and may 

require additional cleaning. 

all lands 

• Only certified weed-free straw or hay bales will be used to 

construct sediment control devices or in mulch applications. On 

BLM administered land, only straw bales will be used in mulch 

applications as opposed to hay bales. On the PNG, hay bales will 

not be used for mulching or erosion control, unless approved in 

advance. 

federal lands 

• Overland Pass will ensure that straw or hay bales used to construct 

sediment control devices or used as mulch applications would be 

certified weed free and obtained from approved certified sources 

as recommended by the County Weed and Pest Districts, Weed 

Control Supervisors, and the States of Colorado, Wyoming, and 

Kansas. 

all lands 

• Seed mixes will be tested for viability to ensure that desirable seed 

viability exceeds 95 percent. Seed mixes will have a certified 

content that contains 0 percent noxious weeds. 

federal lands 

• Overland Pass will ensure that seed mixes utilized for revegetation 

would be certified weed free and obtained from approved certified 

sources as recommended by the States of Colorado, Wyoming, 

and Kansas. 

all lands 

A-12
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• Overland Pass will utilize established reclamation practices to 

prevent the establishment of noxious weeds in reclaimed 

construction areas and pipeline ROW. 

all lands 

• In the event noxious weed species become established in the 

ROW, Overland Pass will control weeds in the ROW and to work 

with adjacent landowners to prevent spread of the species to 

adjacent lands. 

all lands 

Wildlife 

General Wildlife Resources 

• Overland Pass will follow its POD and other measures referenced 

in the EIS to minimize impacts to wildlife and their habitats during 

pipeline operation and maintenance. 

all lands, unless otherwise 

specified in the plan 

• On federal lands, trench plugs will be installed at a maximum of 

0.5-mile intervals and at visible wildlife game trails and livestock 

watering trails that intersect the trench line. Twenty-foot gaps 

would be left in spoil and topsoil stockpiles at all trench plugs. A 

suitable ramp-up out of the trench would be sloped and a 5-footwide path maintained across the trench plug. A corresponding gap 

in the welded pipe string would be left at each trench plug. 

federal lands 

• The pipeline and pipeline trench will be inspected on a regular 

basis during construction and immediately prior to backfilling to 

identify entrapped animals. Wildlife found in trenches during 

construction will be coaxed to the nearest ramp and either be 

encouraged to exit the trench, removed by hand, or trapped (if 

other methods are unsuccessful). If any animal in the trench is 

determined to be a special status species, only authorized 

Overland Pass resource monitors will be allowed to remove it from 

the trench. 

all lands 

• Overland Pass will implement a mandatory employee education 

program for all construction personnel to minimize wildlife impacts 

and vehicle collisions during project construction. 

federal lands 

Big Game 

• Unless exemptions are authorized in writing by the BLM or Forest 

Service as appropriate, Overland Pass will avoid construction and 

non-emergency maintenance activities on federal lands within elk, 

pronghorn, or mule deer crucial winter and crucial winter/yearlong 

ranges between November 15 and April 30 in Wyoming and within 

pronghorn severe winter range between December 1 and April 30 

in Colorado. 

federal lands 

Raptors and Other Migratory Birds 

• If construction occurs during migratory bird breeding seasons, 

Overland Pass will consult with the BLM and the USFWS and 

prepare a plan to mitigate construction impacts to nesting migratory 

birds. 

all lands 

A-13
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• Overland Pass will consult with the USFWS and BLM to develop 

mitigation measures to avoid or minimize blasting impacts on 

nesting birds. 

all lands 

• Pre-construction raptor surveys will be completed along the 

proposed ROW in accordance with the methodology outlined in the 

Overland Pass’ Sensitive Species Survey Plan. These surveys will 

identify specific areas where construction may affect active nests 

(and, in the case of burrowing owls, cause direct impacts on 

nesting habitat) and where buffer zones may be required. 

all lands 

• Overland Pass will abide by established spatial and timing buffers 

for active raptor nests identified during pre-construction surveys 

within 1.0 mile of the construction ROW for ferruginous hawks, or 

within 0.75 mile of the construction ROW for northern goshawk, 

peregrine falcon, and burrowing owl from February 1 to July 31 on 

BLM lands within Wyoming and within 0.25 mile of the construction 

ROW from March 1to June 30 on PNG lands. 

all lands 

Aquatic Resources 

• Overland Pass will implement measures to mitigate the effects of 

hydrostatic testing, including screening intake hoses to prevent the 

entrainment of fish and other aquatic organisms and regulating the 

rate of withdrawal of hydrostatic test water to avoid adverse impact 

on aquatic resources or downstream flows. 

all lands 

• Overland Pass will follow construction constraint periods identified 

in the Construction, Reclamation, and Revegatation Plan to avoid 

or minimize impacts to game fish spawning. 

all lands 

• Overland Pass will meet requirements for water withdrawals in the 

Colorado River and Platte River basins. 

all lands 

Special Status Species 

• Overland Pass will follow its Conservation Measure Plan to avoid 

or minimize impacts from construction and operation of the pipeline 

on threatened, endangered, or special status species. 

all lands 

Black-footed Ferret 

• If black-footed ferret is observed during construction, construction 

would cease, and the USFWS would be notified. 

all lands 

Prebles Meadow Jumping Mouse 

• No equipment will be parked closer than 100 feet from the stream 

crossing in suitable habitat. 

all lands 

• When equipment crosses suitable habitat, a biologist will clear the 

area and physically remove mice encountered. These efforts will 

continue ahead of each piece of equipment until the ROW is 

cleared and silt fences have been installed. 

all lands 

A-14
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• If crossing of suitable habitat for Prebles meadow jumping mouse 

occurs during the breeding season (June or July), captured adults 

will be released at the trap site and followed to attempt to 

determine if they have young in a nest. If a nest is located within 

the ROW, a decision will be made whether to move the centerline 

or ROW and avoid the nest or delay the crossing until late July 

when the young should be mobile and able to be trapped and 

moved from the immediate area. 

all lands 

• Construction through suitable habitat areas will be conducted as 

quickly as possible. 

all lands 

• In suitable habitat for Prebles meadow jumping mouse, the width of 

the ROW will be reduced to 60 feet and additional temporary 

workspace will be adjusted or fenced to protect habitat. 

all lands 

• Following construction, areas of potential habitat will be restored to 

preconstruction conditions by broadcast seeding the banks and 

replacing plugs of willow and/or preexisting shrub species from the 

riparian area (one plant every square foot). 

all lands 

• If suitable habitat is grazed, and the landowner provides consent, 

the replanted area will be fenced until vegetation is established. 

all lands 

• The long-term maintenance plan will allow revegetation of native 

shrub species in addition to herbaceous species in areas identified 

as potential Preble’s meadow jumping mouse habitat. 

all lands 

Bald Eagle 

• If construction occurs during the breeding season for the bald 

eagle, Overland Pass will conduct pre-construction bald eagle nest 

surveys at known nest sites and within suitable nesting habitat 

during the appropriate period in accordance with the survey plans. 

all lands 

• On BLM lands, Overland Pass will not construct within 1 mile of 

active bald eagle nest sites during the nesting season February 1 

through July 31. 

all lands 

• In Colorado, Overland Pass will not construct within 0.5 mile of 

active bald eagle nest sites during the nesting season 

November 15 through July 31. 

all lands 

• If Overland Pass encounters a previously unidentified active bald 

eagle nest within 1 mile of the construction ROW, Overland Pass 

will notify the USFWS. Overland Pass will not continue with 

construction until the USFWS staff has reviewed the information, 

and the USFWS notifies Overland Pass in writing that construction 

may proceed or use of mitigation may begin. 

all lands 

A-15
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• In the event that an active bald eagle nest is located within the 

specified buffer zone, Overland Pass will provide an experienced 

biologist to monitor the nest prior to construction to determine when 

young birds are no longer dependent on the natal nest or nest 

area, in accordance with Overland Pass's Conservation Measure 

Plan in the POD. 

all lands 

• In order to minimize impacts to roosting bald eagles, Overland 

Pass will conduct surveys for roosting eagles within potential winter 

roost areas if construction occurs between November 1 and April 1. 

In the event that occupied bald eagle winter roost sites are 

identified within 1 mile of construction areas, Overland Pass will 

avoid or minimize construction activity between November 1 and 

April 1 and will avoid ground disturbing activities within 0.5 mile of 

active communal roost sites year round. 

all lands 

Interior Least Tern, Piping Plover, Whooping Crane, Eskimo Curlew 

• If suitable habitat is proposed to be crossed, monitoring during the 

migratory period will occur (RP 680-720 for whooping crane). 

all lands 

• If a least term is identified within the project area, construction will 

cease until the individual vacated the area. 

all lands 

Wyoming Toad 

• If the pipeline route comes within 2 miles of a known location, a 

field survey will be conducted. If surveys identify toads within the 

revised project area, a route re-alignment will be considered. 

federal lands 

• If avoidance of Wyoming toad will not be possible, the ROW will be 

cleared by biologist prior to construction to remove all Wyoming 

toads. Toads would be placed in appropriate habitat. 

federal lands 

• Exclusion fence will be installed to a depth of 4 inches in occupied 

habitat. 

federal lands 

Yellow-billed Cuckoo 

• If pre-construction surveys identify individuals within the project 

area, the construction ROW width will be reduced to a distance to 

be determined by the EI or CM. 

federal lands 

• Construction will be avoided during the nesting season. federal lands 

Townsend Big-eared Bat, Fringed Myotis, Long-Eared Myotis, Longlegged Myotis, Pallid Bat, and Spotted Bat 

• Preferred bat roosting habitats will be avoided (e.g. caves and 

abandoned mines) and BMPs identified in project plans will be 

implemented. 

federal lands 

A-16
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

Swift Fox 

• Construction will occur prior to June 1, or a change in ROW 

configuration will be evaluated (e.g., reducing ROW width) in 

habitat identified with active natal dens. If a natal den cannot be 

avoided, the den will be monitored and construction avoided until 

the juveniles have emerged and are able to relocate from the 

ROW. 

federal lands 

• If identified active non-natal den within the construction ROW 

cannot be avoided, the BLM or USFS will be contacted, as 

appropriate. 

federal lands 

• For active natal or non-natal den identified outside of the 

construction ROW, Overland Pass will avoid the den, install silt 

fence along the ROW; and implement general protection measures 

and BMPs as identified in project plans. 

federal lands 

Black-tailed and White-tailed Prairie Dog 

• Where active colonies occur within or adjacent to the project area, 

the edge of the ROW will be flagged or fenced to avoid the area. 

federal lands 

• Staging areas, temporary workspaces, or pipeyards will be sited 

outside of active colonies. 

all lands 

• Following construction, areas of potential prairie dog habitat will be 

restored to preconstruction conditions. 

federal lands 

Sage Grouse 

• Construction and maintenance will not occur within 2 miles of an 

occupied sage grouse lek from March 15 through July 15 and 

within 0.25 mile of an occupied lek from March 1 through May 15, 

between the hours of 8 p.m. to 8 a.m. on federal lands. 

federal lands 

• Aboveground facilities will not be located within 0.25 mile of a 

known sage grouse lek. 

federal lands 

• Blasting activities will not occur between March 15 and May 31 

within 0.25 mile of a known sage grouse lek, unless otherwise 

permitted by the appropriate resource agency. 

federal lands 

Mountain Plover 

• Construction and maintenance will not occur within 0.25 mile of 

identified mountain plover nests between April 10 and July 10 until 

the young have fledged (7 days post-hatching). 

federal lands 

Migratory Birds (Baird's Sparrow, Brewer's Sparrow, Loggerhead 

Shrike, Long-billed Curlew, Sage Sparrow, Sage Thrasher, Trumpeter 

Swan, White-faced Ibis) 

• Vegetation clearing will avoid the nesting season. all lands 

A-17
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

Great Basin Spade Foot Toad, Northern Leopard Frog 

• The ROW will be cleared in suitable habitat by biologists prior to 

construction to remove all individuals. 

federal lands 

• Exclusion fencing will be installed to a depth of 4 inches in 

occupied habitat. 

federal lands 

Midget-faded Rattlesnake 

• Construct between October and April when the snakes are 

inactive. 

federal lands 

• Restrict trench depth to 5 feet near known active snake dens that 

are within 100 feet of the pipeline ROW. 

federal lands 

• Blasting will not occur within 500 feet of known active snake dens. federal lands 

• If a den site occupied by an individual or by a congregation of 

individuals is uncovered during trenching, construction will be 

stopped, and a biological resource monitor will immediately notify 

the BLM to develop and implement appropriate protection 

measures. 

federal lands 

• All attempts will be made by pipeline personnel to eliminate or 

reduce fatalities or injuries to individual snakes. 

federal lands 

• All personnel working on the pipeline between RP 55 and RP 70 

will have a pre-work orientation addressing the importance of 

avoiding the snakes, including those snakes that may be crossing 

or basking on the ROW, additional temporary workspaces, or 

access roads in the project area. 

federal lands 

• The ROW will be cleared in suitable habitat by biologists prior to 

construction to remove all individuals. 

federal lands 

• Exclusion fencing will be installed to a depth of 4 inches in 

occupied habitat. 

federal lands 

Spotted Skunk 

• Trees felled and brush cleared within 200 feet of the proposed Big 

Creek crossing (RP 670) will be piled in a stack(s) adjacent to the 

existing riparian area to restore/increase habitat for the eastern 

spotted skunk. 

all lands 

Stonecat 

• Per the recommendation of the CDOW (Swigle 2006c), Overland 

Pass will avoid construction across the North Fork of the 

Republican River between May 31 and August 1 to avoid direct 

impacts to spawning and young stonecat (late April to early May). 

all lands 

A-18
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

Land 

• Permits required for installation of the pipeline underneath existing 

public roads and, as needed, to transport equipment will be 

obtained prior to construction. For open-cut road crossings, 

Overland Pass will attempt to: 

• Maintain at least one lane of traffic open with detours around 

construction; 

• Provide plating over the open portion of the trench; or 

• Use other suitable methods when open cutting a road. 

all lands 

• If a construction method requires a road to be closed for up to 

24 hours, Overland Pass will develop a detour for public traffic to 

bypass the construction area. Overland Pass will provide a detour 

for vehicle traffic on CR 437 along the North Platte River for the 

duration of the open cut river crossing. 

all lands 

• Overland Pass will require the construction contractor to post 

caution signs on roads, where appropriate, to alert motorists of 

pipeline construction and warn them of slow traffic. Traffic control 

measures such as traffic control personnel, warning signs, lights, 

and barriers will be used during construction to ensure safety and 

to minimize traffic congestion. 

all lands 

• Pipe trucks transporting pipe joints and low boys hauling heavy 

equipment will travel with flashing yellow caution lights in 

accordance with state law. The construction contractor will employ 

traffic control personnel as required by state DOT safety 

requirements for use on paved roads during equipment crossings 

to ensure safe passage of local traffic. 

all lands 

• Construction vehicles will follow posted speed limits on rural county 

roads and highways and follow a 25 mph speed limit on unposted 

project roads. Speeds will be reduced to 10 mph below posted 

limits on highways when traveling at night. 

all lands 

• Overland Pass will implement the following measures to reduce 

traffic congestion and roadside parking hazards: 

• Project personnel will exercise caution when commuting to and 

from the construction area to minimize the potential for 

accidents, and local speed limits will be enforced. 

• Overland Pass will provide the construction contractor with an 

equipment yard to be used as a primary parking area for 

employee personal vehicles. Unauthorized vehicles will not be 

allowed within the construction ROW or along roadsides near 

the ROW. The construction contractor will provide buses for 

transporting workers that do not require personal vehicles to 

the work site from the yard. 

all lands 

• Overland Pass will require its construction contractor to comply 

with local load weight restrictions when using existing public roads 

and crossing public bridges to prevent road and bridge damage. 

all lands 

A-19
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• The construction contractor will be directed to remove soil left on 

the road surface by equipment crossings. At the end of each 

workday, mats or other appropriate measures (e.g., sweeping) will 

be used to reduce deposition of mud and soils on public roads and 

highways. 

all lands 

• Where culverts are required to improve an access road at stream 

crossings, these culverts will be of adequate size to accommodate 

storm runoff as required by federal, state, or county road permits, 

and of sufficient strength to support construction and maintenance 

equipment. All temporary culverts and associated fill material will 

be removed from the stream crossing after construction. 

all lands 

• Overland Pass will notify landowners prior to the start of 

construction adjacent to a residence. 

all lands 

• Overland Pass will maintain traffic flow and emergency vehicle 

access on roadways with traffic control personnel or detour signs 

where necessary. 

all lands 

• Overland Pass will backfill and restore in residential areas as soon 

as possible, and fence off or plate sections of trench left open near 

residences at the end of the construction day. 

all lands 

• Overland Pass will periodically inspect road surfaces near 

residences and, if necessary, clean street surfaces and wet 

exposed soil to prevent generation of fugitive dust. 

all lands 

Visual Resources 

• Downward shield lighting or low profile lighting, and motion sensors 

will be used at all facilities that require night lighting to minimize 

nighttime visual effects. 

all lands 

• MLVs located on the PNG will be painted in earth tones with a 

matte finish and the site will not be graveled. In addition, fences 

around the MLVs on the PNG will be barbed wire similar to 

livestock fences in the area. 

all lands 

Cultural Resources 

• If construction will adversely affect any properties listed on, or 

eligible for listing on, the NRHP, mitigation will be required. 

Mitigation may include, but not be limited to, one or more of the 

following measures: a) avoidance through the use of realignment of 

the pipeline route, relocation of temporary extra workspace, or 

changes in the construction and/or operational design; b) data 

recovery, which may include the systematic professional 

excavation of an archaeological site or the preparation of 

photographic and/or measured drawings documenting standing 

structures; and c) the use of landscaping or other techniques that 

would minimize or eliminate effects on the historic setting or 

ambience of standing structures. 

all lands 

A-20
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

• To minimize unauthorized collecting of archaeological material or 

vandalism to known archaeological sites, Overland Pass and their 

contractors, and all construction personnel, will attend mandatory 

training and be educated on the significance of cultural resources 

and the relevant federal regulations intended to protect them. 

all lands 

Socioeconomics 

• Overland Pass will implement its Traffic and Transportation 

Management Plan to mitigate potential impacts of project-related 

road use and construction. 

all lands, unless otherwise 

stipulated in the plan 

Hazardous Materials Storage and Use 

• Hazardous materials, chemicals, fuels, lubricating oils, and 

materials associated with concrete coating will not be stored within 

500 feet of streams, wetlands, or water wells. On federal lands, 

refueling and lubricating of construction equipment would be 

restricted to at least 500 feet of streams, wetlands, or water wells. 

Fuel and service truck drivers would be responsible for spill 

prevention during refueling and service activities. 

federal lands 

• On non-federal land, refueling and lubricating of construction 

equipment will be restricted to upland areas at least 100 feet from 

the edge of any streams, wetlands, ditches, and other waterbodies; 

200 feet from private water supply wells; and 400 feet from public 

water supply wells, wherever possible. Wheeled and tracked 

construction equipment will be moved to an upland area more than 

100 feet from streams, wetlands, ditches, and other waterbodies 

for refueling and at the end of each work day. 

non-federal lands 

• On private lands, materials such as fuels, other petroleum 

products, chemicals, and hazardous materials including wastes will 

be located in upland areas at least 500 feet away from streams 

and/or 200 feet of private wells (400 feet for public wells). 

non-federal lands 

• Pumps and temporary fuel tanks for the pumps will be stored in 

secondary containment if located within 100 feet of flowing 

waterbodies. Containment will provide a minimum volume equal to 

110 percent of the volume of the largest storage vessel located in 

the yard. 

all lands 

• Any construction spills will be promptly cleaned up and 

contaminated soil hauled to a disposal site approved by Overland 

Pass and that meets local jurisdictional requirements. 

all lands 

• In wetlands where no upland sites are available for refueling, 

auxiliary fuel tanks may be mounted to equipment to minimize the 

need for refueling. Only a fuel truck with a maximum of 300 gallons 

of fuel may enter restricted areas to refuel construction equipment. 

Two trained personnel will be present during refueling to reduce 

the potential for spills or accidents. 

all lands 

A-21
Table A-1 Summary of Key Applicant-Committed Mitigation Measures 

Resource Applicability 

Spills 

• Overland Pass will implement procedures identified in the SPCC 

Plan to minimize the risk of spills and the effects of spills on the 

environment. 

all lands, unless otherwise 

stipulated in the plan 

• For an upland spill during construction, berms will be constructed 

with available equipment to physically contain the spill. Absorbent 

materials will be applied to the spill area. Contaminated soils and 

vegetation will be excavated and temporarily placed on and 

covered by plastic sheeting in a containment area a minimum of 

100 feet away from any wetland or waterbody, until proper disposal 

is arranged. 

all lands 

• If a spill occurred beyond the scope of on-site equipment and 

personnel, an Emergency Response Contractor will be secured to 

further contain and clean up the spill. 

all lands 

• For spills in standing water, floating booms, skimmer pumps, and 

holding tanks will be used as appropriate by the contractor to 

recover and contain released materials on the surface of the water. 

all lands 

• For a spill threatening a waterbody, berms, and/or trenches will be 

constructed to contain the spill before it reached the waterbody. 

Deployment of booms, absorbent materials, and skimmers may be 

necessary if the spill reaches the water. The spilled product will be 

collected and the affected area cleaned up in accordance with 

appropriate state or federal regulations. 

all lands 

Reliability and Safety 

• Overland Pass will prepare an emergency plan that includes 

procedures to minimize the hazards in a natural gas liquids pipeline 

emergency prior to placing the pipeline system in service. 

all lands 

• Impacts from a potential rupture will be minimized by block and/or 

check valves installed on either side of waterbodies with widths 

greater than 100 feet. 

all lands 

A-22
Table A-2 Summary of BLM-Recommended Mitigation Measures 

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

susceptible areas. Overland Pass shall use appropriate design standards and ground 

monitoring devices to assure pipeline integrity. 

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

exceed 4 inches on all federal lands, with the exception of the PNG where the rutting 

restriction is 3 inches. If rutting exceeds these depths, it shall be considered excessive and 

operations halted until conditions are dry. If conditions do not improve, Overland Pass shall 

consult with the applicable federal agencies to determine if alternate topsoil removal 

techniques may be employed to alleviate rutting concern. 

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

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

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

mitigation measures shall be incorporated by RP into the Construction, Reclamation, and 

Revegetation Plan. The changes shall be incorporated directly into the text of the final POD 

for the project. 

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

WATER-1: If water is present, all waterbodies (regardless of size and flow) and wetlands on federal 

lands shall have an approved crossing structure consisting of either a temporary culvert, 

rock fill, or equipment bridge. One pass of clearing equipment and equipment for 

installation of a bridge shall be allowed across the waterbody or wetland. 

WATER-2: On an as-needed basis as determined and specified through consultations with appropriate 

state and federal fisheries and water quality agencies, power washing of equipment with 

water and other chemicals as specified shall be required to avoid transfer of whirling 

disease, parasites, or nuisance organisms after equipment crosses perennial streams. 

Suitable chemical treatments may be used for equipment cleaning when sustained daytime 

temperatures are below freezing. Any fluids used for this purpose that contain additives 

(e.g., chlorine) shall not be discharged to streams or drainages, but shall be disposed of in 

an agency-approved manner at an appropriate facility. 

WATER-3: If water is withdrawn from the surface waters containing fisheries (e.g., for HDD or 

hydrostatic testing) during the period from April 1 through October 31, Overland Pass shall 

utilize a filter screen with a mesh size that would prevent impingement and entrainment of 

aquatic organisms. The mesh size would be 3/32-inch to protect larval fish. For surface 

water withdrawals during November 1 through March 31, a 0.5-inch mesh filter screen may 

be used. 

WATER-4: Overland Pass shall use construction techniques applicable for flowing waterbodies when 

dry/seasonally dry lake beds are crossed during saturated or inundated conditions. 

WATER-5: On federal land, Overland Pass shall reduce the total construction ROW width to 60 feet in 

riparian and wetland areas. 

WATER 6: Prior to any discharge, hydrostatic testing water will be tested and processed to ensure 

that the water meets local, state, or federal water quality standards. This includes meeting 

NPDES permit requirements as stated in Chapter XVIII of the Wyoming Water Quality 

Rules and Regulations. Prior to discharge of hydrostatic testing water from the pipeline, 

the holder shall design and install a suitable energy dissipator(s) at the outlet(s), and 

design and install suitable channel protection measures necessary to ensure that there will 

be no erosion or scouring of natural channels within the affected watershed as a result of 

such discharge. Overland Pass would be responsible for any erosion or scouring resulting 

from such discharge. Straw bales, sandbags, rock, or other materials or objects installed 

will be removed from the site upon completion of hydrostatic testing. 

A-23 
Table A-2 Summary of BLM-Recommended Mitigation Measures 

VEG-1: To minimize impacts to waterbodies, wetlands, and riparian areas, Overland Pass shall set 

back TWAs a minimum distance of 50 feet from the edge of waterbodies, wetlands, or 

riparian areas, whichever distance would provide the greatest protection. The distance 

shall be measured from the water bank of the waterbody, the margin of a wetland, and the 

exterior edge of a riparian area. In addition, erosion and sediment control measures, 

including but not limited to, silt fence, straw bales, berms, water bars, and mulching shall 

be installed around each TWA to prevent soil movement into the nearby sensitive area. 

Riparian areas form a transition between permanently saturated wetlands and upland 

areas and are typically associated with waterbodies (see Glossary). 

VEG-2: Overland Pass shall continue to monitor and control invasive plant species and noxious 

weeds along the ROW for the life of the project. 

WILD-1: The duration a trench is open shall be limited to 10 days from RP 0 to RP 110 on federal 

land administered by the BLM Kemmerer and Rock Springs field offices. In areas with 

large amount of rock where trenching may take longer and may include blasting, Overland 

Pass may request variances from this mitigation measure on a case-by-case basis. 

WILD-2: To avoid impacts to kokanee salmon and brown trout movements and effects on habitat 

from ice in the winter and high flows in the spring, construction across the Green River 

shall occur between July 1 and August 15 or between October 15 and November 20. 

WILD-3: Overland Pass will notify WGFD at least 72 hours prior to initiating construction at streams 

with sensitive fisheries (Table 3.5-2). 

SSS-1: If there is perceptible flow within Bitter Creek at the time of crossing, Overland Pass shall 

use a dry crossing method (dam-and-pump or flume method) to protect the flannelmouth 

sucker populations. 

SSS-2: Overland Pass shall prepare a plan prior to construction to be approved by the BLM to 

avoid disturbance to all Nelson’s milkvetch plant locations. 

LAND-1: Overland Pass shall notify all federal grazing permittees at least 5 days in advance of 

construction activities. Additionally, Overland Pass must take measures to avoid cutting off 

access to rangeland for winter sheep operations. 

LAND-2: Overland Pass shall post notification at recreation sites and on main access roads into 

these recreation sites warning users of heavy traffic related to construction of the project. 

ARCH-1: Adverse effects to historic properties will be mitigated through the implementation of a 

project-wide Memorandum of Agreement among the BLM; Pawnee National Grasslands 

USFS; Overland Pass Pipeline LLC; Wyoming, Colorado, and Kansas SHPOs; and the 

Advisory Council on Historic Preservation. 

SAFETY-1: In order to comply with BLM regulations at 43 CFR 2886.10, prior to operating the pipeline, 

Overland Pass must certify to BLM in writing that it has constructed and tested the pipeline 

in accordance with the terms of the ROW grant and it is in compliance with the plans, 

specifications, and federal and state laws and regulations concerning the pipeline. 

A-24