U.S. Department of the Interior 

Bureau of Land Management 

Rawlins and Rock Springs Field Offices May 2000 

Record of Decision 

Environmental Impact Statement 

Continental Divide/Wamsutter II Natural Gas Project, 

Sweetwater and Carbon Counties, Wyoming 
RECORD OF DECISION

ENVIRONMENTAL IMPACT STATEMENT

CONTINENTAL DIVIDE/WAMSUTTER II NATURAL GAS PROJECT

SWEETWATER AND CARBON COUNTIES, WYOMING

Rawlins and Rock Springs Field Offices

Bureau of Land Management

Rawlins and Rock Springs, Wyoming

May 2000
1793 (930) 

CD/WII ROD 

May 24, 2000 

Dear Reviewer: 

This Record of Decision (ROD) for the proposed Continental Divide/Wamsutter II (CD/WII) Natural Gas 

Project located in Carbon and Sweetwater County, Wyoming, is provided for your information and use. The 

ROD defines the decision, explains the rationale (including key management considerations), and includes 

standards, mitigation, and monitoring requirements for the CD/WII Natural Gas Project. The Bureau of Land 

Management (BLM) decision is subject to appeal as explained in the decision. 

On April 30.1999, the BLM released the draft Environmental Impact Statement (EIS). On December 10, 1999, 

the final EIS for the CD/WII Natural Gas Project was released. The CD/WII EIS was prepared pursuant to the 

National Environmental Policy Act (NEPA) and other regulations and statutes to fully disclose the potential 

environmental impacts which could result from implementation of the CD/WII Natural Gas Project and to 

solicit public comments and concerns. The EIS process is designed to inform the public and to provide 

opportunity to comment on a proposed development and reasonable alternatives proposed for implementation 

on public lands. The analysis discloses through detailed analysis the potential impacts associated with 

implementing the proposal or alternatives and includes reasonable opportunities to mitigate potential impacts. 

A copy of this ROD has been sent to affected government agencies and to those persons who either responded 

to public scoping, commented on the EIS, or otherwise indicated to BLM that they wished to receive a copy of 

the EIS/ROD. Copies of the ROD are available to the public at the following locations: 

Bureau of Land Management Bureau of Land Management Bureau of Land Management 

Wyoming State Office Rock Springs Field Office Rawlins Field Office 

5353 Yellowstone Road 280 Highway 191 North 1300 North Third Street 

Cheyenne, Wyoming 82009 Rock Springs, WY 82901 Rawlins, WY 82301 

Telephone (307) 775-6256 Telephone (307) 352-0256 Telephone (307)324-4200 

The BLM would like to thank the individuals and organizations who provided suggestions and comments on 

the draft and final EIS. Your help has been invaluable in preparing the EIS and the attached ROD. 

Sincerely, 

/s/ Alan L. Kesterke 

Al Pierson 

State Director 

Enclosure 
ABBREVIATIONS AND ACRONYMS 

APD Application for Permit to Drill 

BLM Bureau of Land Management 

C.F.R. Code of Federal Regulations 

CD/WII Continental Divide/Wamsutter II 

CD/WIIPA Continental Divide/Wamsutter II Project Area 

DEIS Draft Environmental Impact Statement 

EID Environmental Impact Statement 

FEIS Final Environmental Impact Statement 

FLPMA Federal Land Policy and Management Act 

GDRA Great Divide Resource Area 

GRRA Green River Resource Area 

IBLA Interior Board of Land Appeals 

LOP Life-of-Project 

NEPA National Environmental Policy Act 

RFD Reasonable Foreseeable Development 

RFO Rawlins Field Office 

RMP Resource Management Plan 

ROD Record of Decision 

ROW Right-of-way 

RSFO Rock Springs Field Office 

SN Sundry Notice 

SRA Sensitive Resource Area 

TPC Transportation Planning Committee 

USFWS U.S. Fish and Wildlife Service 

VRM Visual Resource Management 

WGFD Wyoming Game and Fish Department 

WOGCC Wyoming Oil and Gas Conservation Commission 

WSA Wilderness Study Area 
1.0 RECORD OF DECISION CONTINENTAL DIVIDE/WAMSUTTER II NATURAL GAS

PROJECT 

SWEETWATER AND CARBON COUNTIES, WYOMING

ENVIRONMENTAL IMPACT STATEMENT

This document records the decision made by the Bureau of Land Management (BLM) for managing the public 

land surface and federal mineral estate in the Continental Divide/Wamsutter II Natural Gas Project (hereafter 

referred to as the CD/WII project). The CD/WII project comprises approximately 1,061,200 acres of which 

531,400 acres are federal surface; 9,800 acres are state surface; and 520,000 acres are private surface. The 

project area is located on lands administered by the BLM Rawlins Field Office (RFO) (formerly the Great 

Divide Resource Area [GDRA] Rawlins District), and the Rock Springs Field Office (RSFO) (formerly the 

Green River Resource Area [GRRA] Rock Springs District) (Map 1.1). The CD/WII project is also located 

within the checkerboard land pattern that resulted from early railroad grants made by the federal government to 

the Union Pacific Railroad Company. Most odd_numbered sections within 20 mi of each side of the railroad 

mainline are privately owned (surface and mineral rights) (Map 1.2). The State of Wyoming also owns the 

surface and mineral rights to approximately 16 sections in the area, and the mineral rights to about 75 more 

sections. Therefore, approximately 50% of the surface (531,400 acres) and 45% of the mineral estate 

(474,100 acres) within the CD/WII project area (CD/WIIPA) is managed by the BLM. 

The CD/WII project is proposed by Amoco Production Company, Union Pacific Resources Company, Yates 

Petroleum Corporation, Snyder Oil Corporation, and other companies (hereafter referred to as the "Operators"). 

The BLM's preferred alternative for this project is the Proposed Action. The proposed action is generally in 

conformance with the BLM GDRA (RFO) Resource Management Plan (RMP), and is entirely in conformance 

with the GRRA (RSFO) Resource Area RMP, the Sweetwater and Carbon County land use plans, and the 

State of Wyoming land use plan. This selection is based on the analyses presented in this environmental 

impact statement (EIS) and on mitigation measures as described in the draft EIS (DEIS), final EIS (FEIS), 

and Record of Decision (ROD) that will further reduce environmental impacts. Mitigation measures include 

the following. 

1) Reclamation Plan (Appendix A). 

2) Transportation Plan (Appendix B) and associated Transportation Planning Technical Support 

Document. 

3) Hazardous Materials Summary (Appendix C). 

4) Wildlife Protection Plan (Appendix D) and associated cooperative agreements, the Biological 

Assessment (Appendix E) with additional terms and conditions for protection of black-footed ferret 

and mountain plover from the U.S. Fish and Wildlife (USFWS) Biological Opinion and associated 

implementation protocol developed in coordination between the USFWS and BLM (Appendix G), and 

information identified in Wyoming BLM Instruction Memorandum No. WY-2000-44 (Appendix I) 

clarifying BLM's responsibilities for Endangered Species Act compliance on non-federal lands. 

5) Applicant-committed and BLM_ required mitigation/environmental protection measures (Appendix F). 

The proposed action is to permit up to 3,000 wells at 3,000 well locations (1,500 on BLM_managed lands) in 

the CD/WIIPA. Approximately 1,500 mi of new roads; 1,500 mi of new pipeline; five compressor stations; one 

gas processing facility; 10 evaporation ponds; five disposal wells; and 50 water wells will also be included 

under the proposed action. Standard procedures as currently used in gas field developments throughout 

Wyoming and associated applicant-committed procedures will be employed during project development and 

operations. All project activities will comply with applicable federal, state, and county laws, regulations, and 

stipulations. 

Development will occur on a year-long basis provided there is adequate advance planning and construction. 

1.1 DECISION 

The BLM decision is to approve the Operators' development plan as described in the Proposed Action of the 

CD/WII FEIS with the following modifications. Development will be reduced from the proposed 3,000 wells at 

3,000 well locations to allow up to 2,130 wells at 2,130 well locations within the project area. Allowance of 
the remaining 870 wells/well locations (not more than 435 wells or well locations on federal lands and/or 

federal mineral estate) will be considered pending completion of a planning review of the GDRA RMP for the 

RFO area. 

This ROD will allow approximately 930 new wells/well locations within the jurisdictional boundary of the 

RSFO area (not more than 465 wells or well locations on federal lands and/or federal mineral estate), which 

accounts for approximately 31% of the original project development total and will allow 1,200 new wells/well 

locations within the jurisdictional boundary of the RFO area (not more than 600 wells or well locations on 

federal lands, and/or federal mineral estate) for a total of 2,130 well locations. This is assuming 50% of the 

wells will be drilled on federal lands and/or mineral estate. If private/state land development trends exceed 

50% of the authorized wells, the number of wells permitted on federal estate will be limited accordingly, 

unless federal mineral drainage is identified. The total amount of new roads and new pipelines, and the 

number of ancillary facilities will be reduced to accommodate the number of wells drilled. Detailed rationale 

and justification for these modifications are noted in Chapter 3.0 

Approval of the Proposed Action, as modified, provides for managing the CD/WIIPA in accordance with the 

Federal Land Policy and Management Act of 1976 (FLPMA) (Sec. 202(e)), in a manner that allows for 

natural gas development while continuing to provide for the existing principal and major uses recognized by 

the land use plans (i.e., domestic livestock grazing, wildlife development and utilization, mineral exploration 

and production, and outdoor recreation) for this area. The Proposed Action, as modified, sustains the long-term 

availability of other resources, while promoting stability of local and regional economies, environmental 

integrity, and conservation of resources for future generations. This provides for complete conformance with 

BLM RMPs for the RSFO and the RFO areas. 

The decision to approve the Proposed Action, as modified, recognizes the CD/WIIPA as an area which has 

been under development for natural gas since 1946, has significant reserves, and will continue to be developed 

for its natural gas resource. The decision recognizes that there are other important natural resources and 

values within the area which require consideration and protection from unnecessary or undue degradation. The 

decision incorporates restrictions and mitigative measures in consideration of federal, state, and local 

agencies, and public concerns raised during public meetings and in comments received on the draft and final 

EIS. Common concerns raised during public reviews addressed project compliance with the reasonable 

foreseeable development (RFD) projections in RMPs; potential cumulative impacts as they pertain to air 

quality, wildlife and wildlife habitat, threatened and endangered plant and animal species; changes in lands 

use, water resources, transportation planning, livestock grazing, recreation and visual resources; and 

social/economic impacts. This ROD provides consideration for the protection of the identified concerns 

through planning and protective measures applied with each authorization, operation, and abandonment 

activity as well as project-wide planning and protective measures. 

Approval of the Proposed Action as modified and the individual project components associated with the 

Proposed Action, are subject to administrative requirements, added conditions of approval and mitigation 

measures, and the applicant-committed mitigation/environmental protection measures, all of which are listed 

in Appendix F. It also includes the applicant-committed practices, environmental standards, procedures, and 

requirements found in the EIS as the Reclamation Plan (Appendix A), the Transportation Plan (Appendix B), 

the Hazardous Materials Summary (Appendix C), the Wildlife Protection Plan (Appendix D), and the 

Biological Assessment (Appendix E). The terms and conditions for protection of black-footed ferret and 

mountain plover from the USFWS's recent Biological/Conference Opinion and associated implementation 

protocol developed in coordination between the USFWS and BLM (see Appendix G), including information 

shown in BLM Instruction Memorandum No. WY-2000-44 (Appendix I) are also part of the approved action. 

This ROD authorizes the BLM Rawlins and Rock Springs Field Managers to process Applications for Permit 

to Drill (APDs), Sundry Notices (SNs), and Rights-of-Way (ROWs) on public lands administered by the BLM 

for the CD/WII project Operators and for companies contracted by the Operators. Approval of individual 

applications authorizes the implementation of the various components of the CD/WII project (e.g., access road 

and well pad construction, pipeline and production facilities installation, drilling operations, etc.). 

The Proposed Action, as modified, is not only BLM's preferred alternative, but is also BLM's environmentally 

preferred alternative. Rationale for this determination is described below. 

1.2 APPROVED PROJECT COMPONENTS 
This ROD provides the BLM Rawlins and Rock Springs Field Managers approval to permit the following 

project components on BLM-administered public lands, both surface and/or mineral estate (approximately 

50% of the land ownership) within the CD/WIIPA (see Map 1.2). 

• Up to 465 wells and/or well locations within the jurisdictional boundaries of the RSFO area on 

BLM-administered public lands (total number of wells on all lands [federal, private, and state] will 

not exceed 930). 

• Up to 600 wells and/or well locations within the jurisdictional boundaries of the RFO area 

BLM-administered public lands (total number of wells on all lands [federal, private, and state] will 

not exceed 1,200 until the completion of a RMP review for the RFO area and until the remaining 

wells and development proposals analyzed in the CD/WII EIS are determined to be in compliance 

with any modifications made to the RMP). 

• Approximately 550 mi of new or upgraded access road (average of 0.5 mi per well location) on 

BLM-administered public land with approximately 550 mi of new or upgraded access road on 

private/state lands 

• Approximately 550 mi of new pipeline (average of 0.5 mi per well location) on BLM_administered 

public lands with approximately 550 mi of new pipeline on private/state lands. 

• Three to four compressor stations (located on either federal or private/state lands). 

• Three to four disposal wells (located on either federal or private lands). 

• Seven evaporation ponds (these are likely to be constructed on private/state lands). 

• Thirty-six water wells (located on either federal or private/state lands). 

• One gas processing facility (located on either federal or private/state lands). 

These numbers have been modified to reflect a Proposed Action of 2,130 wells (71% of the original proposal) 

for the entire CD/WIIPA. Development beyond the specified levels will require the re_evaluation of the EIS to 

comply with the possible amendments of the RMP for the RFO area. The remaining 870 wells of the original 

Proposed Action could be authorized if the action is in compliance with the amended RMP. However, the 

preparation of a new environmental analysis for additional development in this project area may be needed if 

there are significant changes to planning decisions which will be determined after the planning review of the 

RMP. In addition, some interim development (i.e., drilling on private/state lands, federal drainage wells, etc.) 

occurred during preparation of the EIS. These wells/developments will be included as part of the Proposed 

Action. 
2.0 SUMMARY OF ALTERNATIVES CONSIDERED 

INCLUDING THE PROPOSED ACTION 

The following describes the Proposed Action (full field development), two development alternatives with 

surface disturbance limitations (Alternative A--14.0_acre maximum surface disturbance per federally managed 

section in sensitive resource areas [SRAs] and Alternative B--30.0_acre maximum surface disturbance per 

federally managed section in SRAs), and the No Action Alternative which were analyzed in the EIS. The 

project entails the development of natural gas resources in the CD/WIIPA beginning in 1999, or subsequent to 

the release of the ROD, and continuing for approximately 20 years. Well location and bottom hole densities 

(as defined by the Wyoming Oil and Gas Conservation Commission [WOGCC]) will vary across the 

CD/WIIPA and will likely range from 640 acres/well to 80 acres/well (one to eight wells per section). As 

areas of the CD/WIIPA are developed and more is learned about the natural gas resources on the area, 

WOGCC-specified spacing orders for the area may change. 

Alternatives involving project_wide well location densities, the drilling and development of varying numbers 

of wells, the exclusion of development on all public lands in the CD/WIIPA, and developments on and 

adjacent to the Adobe Town Wilderness Study Area (WSA) were considered but rejected for economic, 

environmental, and/or legal reasons. 

2.1 PROPOSED ACTION 

A maximum of 3,000 wells at 3,000 well locations would be developed in the CD/WIIPA (an estimated 1,500 

wells or well locations on federal lands and/or federal mineral estate). Operators anticipate that fewer wells or 

well locations would be necessary, and in the event fewer locations are developed, decreased impacts are 

expected. 

Drilling and development would begin in 1999 (or subsequent to the release of the ROD) within the CD/WIIPA 

and continue for approximately 20 years, with a life_of_project (LOP) of 30-50 years. Various associated 

facilities (e.g., roads, pipelines, power lines, water wells, disposal wells, evaporation ponds, compressor 

stations, gas processing facility) would also be constructed throughout the CD/WIIPA. 

The Proposed Action would result in a maximum of: 7,800 acres of new surface disturbance from well 

locations (including on_site gathering, measurement, and dehydration facilities); 1,500 mi (10,000 acres) of 

new roads or upgrades of existing roads, 1,500 mi (4,500 acres) of new pipeline; and approximately 100 acres 

of new surface disturbance from ancillary facilities (i.e., five compressor stations [20 acres], one gas 

processing plant [30 acres], 10 water evaporation ponds [34 acres], five disposal wells [35 acres], and 50 water 

wells [25 acres]). 

2.2 ALTERNATIVE A - 14-ACRE MAXIMUM SURFACE DISTURBANCE PER 

FEDERALLY MANAGED SECTION IN SENSITIVE RESOURCE AREAS 

Surface disturbance throughout the entire CD/WIIPA resulting from Alternative A would be similar to the 

Proposed Action, except that LOP surface disturbance and associated impacts would likely be reduced on 

federal lands in SRAs. SRAs include areas with stabilized sand dunes, raptor nesting concentration areas, 

probable sage grouse nesting areas, crucial big game winter ranges, areas proximal to residential areas, Visual 

Resource Management (VRM) Class II areas, and areas with high densities of cultural resource sites. 

Under Alternative A, a maximum of 14 acres of ground surface disturbance (exclusive of existing disturbance 

present on the area prior to the release of the ROD) would be allowed at any one time within SRAs on any 

given federally managed section (surface and/or mineral estate). Development on private and state surface 

and/or mineral estate would not be restricted under this alternative. 

The 14_acre criteria would allow Operators to explore for natural gas throughout the entire CD/WIIPA, but 

would require notable changes in operational procedures for field developments within SRAs. Under this 

alternative, Operators would be able to explore their leases within SRAs (e.g., one well location per section) 

and to develop a limited number of additional locations (e.g., from one to three) depending upon the extent of 

new surface disturbance and associated reclamation status (see DEIS Table 2.2). 
Surface disturbance limitation requirements would apply to all future oil and gas exploration and development 

activities conducted on federal lands in SRAs. To accommodate surface disturbance limitation requirements, 

Operators would have limited surface disturbance through: 

• operational changes (e.g., multiple wells per pad using directional drilling; modified well location, 

road, pipeline, and/or ancillary facility design; use of surface pipelines; delaying construction/drilling 

operations until all unnecessary project_required federal surface disturbances are reclaimed); 

• selection of alternative locations for ancillary facilities (e.g., outside SRAs or off federal surface); 

and/or 

• reclamation of unnecessary existing surface disturbance on their lease (e.g., two_track roads). 

The BLM, in consultation with other appropriate individuals, agencies, and land user groups (e.g., permittees, 

Wyoming Game and Fish Department (WGFD), USFWS), could modify surface disturbance limitation 

requirements if the Operators can show that alternative operational procedures would provide greater protection 

for sensitive resources than would limiting surface disturbance. To protect federal natural gas reserves within 

SRAs from drainage, these reserves could be developed regardless of reclamation status. 

2.3 ALTERNATIVE B - 30_ACRE MAXIMUM SURFACE DISTURBANCE PER 

FEDERALLY MANAGED SECTION IN SRAS 

Area_wide surface disturbance resulting from Alternative B would be similar to that for the Proposed Action 

and Alternative A, except that surface disturbance and associated impacts would likely be increased on 

federal lands in SRAs from that occurring under Alternative A and reduced from that occurring under the 

Proposed Action. Maximum surface disturbance within SRAs (exclusive of existing disturbance present on the 

area prior to the release of the ROD for this project) would be limited to 30 acres per federal section at any 

one time. The 30_acre maximum surface disturbance limitation was developed via the same means as that 

described for Alternative A and would allow Operators to develop natural gas resources at an intermediate 

level between Alternative A and the Proposed Action in SRAs. Under this alternative, Operators would be 

able to explore and conduct limited development of their leases within SRAs (e.g., from two to eight locations 

per section) depending upon the extent of new surface disturbance and associated reclamation status (see EIS 

Table 2.2). To protect federal natural gas reserves within SRAs from drainage, these reserves could be 

developed regardless of reclamation status. 

2.4 NO ACTION ALTERNATIVE 

Under the No Action Alternative, the BLM would have denied the current proposal for natural gas 

development on federal lands in the CD/WIIPA as proposed by the Operators under the Proposed Action. 

However, denial of the current development proposal would not have been a denial of all natural gas 

development in the area. Under the No Action Alternative, it would be assumed that development of lands in 

the CD/WIIPA are likely to occur at levels similar to those which have occurred on the area in the past and 

would occur as authorized by existing management directives contained in RMPs. Site_specific National 

Environmental Policy Act (NEPA) analyses would have been conducted for all development activities on 

public lands or mineral estate; however, the planning measures identified for the Proposed Action and 

Alternatives A and B (e.g., Reclamation Plan, Transportation Plan, and Wildlife Protection Plan) would not be 

implemented. 

For the purposes of this analysis, the No Action Alternative assumes that lands in the CD/WIIPA would be 

developed for natural gas production at approximately the same rate as has occurred previously (i.e., 

continuation of present management practices). The selection of the No Action Alternative in this EIS would 

not preclude natural gas development in the area. 

Under the No Action Alternative, and for the purpose of this analysis, an estimated 845 well locations would 

be built, 422 mi of road would be constructed or upgraded, 422 mi of pipeline would be laid, and 100 acres of 

new surface disturbance would be required for ancillary facilities. 

2.5 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL 

CD/WIIPA_wide well densities/spacing patterns were examined during initial project design; however, known 

characteristics of the gas reservoirs on and adjacent to the CD/WIIPA indicate that area_wide spacing patterns 
are not practical and could result in unnecessary and undue surface disturbance and/or the potential drainage 

of federal reserves. Therefore, this alternative was rejected. 

Alternatives involving fewer wells and associated facilities on all CD/WIIPA lands were also considered. 

These alternatives were rejected because the total extent of drilling and development necessary to recover 

existing natural gas resources on the CD/WIIPA is presently unknown. By limiting the number of wells in the 

area, these alternatives could inadvertently lead to drainage of the federal mineral estate and/or the necessity 

for future field_level NEPA analyses. Additionally, the BLM has limited authority over access to and 

development of private lands and non-federal minerals; therefore, alternatives guiding development on these 

lands were considered unreasonable (see DEIS Chapter 1.0 and below). 

An alternative addressing increased surface disturbance at each well location (4.5 acres of new surface 

disturbance per location and 1.2 acres of LOP surface disturbance per location) was initially considered. 

However, increased Operator efficiencies regarding drill site and production facility layouts have resulted in 

substantially reduced surface area requirements for drilling and production operations (i.e., 2.6 acres of new 

surface disturbance per location and 0.8 acres of LOP disturbance per location). Therefore, this alternative 

was rejected. 

A phased development alternative (e.g., limiting well numbers at any one point in time on specific areas) was 

considered for analysis, but was rejected since the Proposed Action as described involves the incremental 

development of fields within the CD/WIIPA. Additionally, BLM has limited control of private land 

development. 

Various no development alternatives (i.e., the denial of APD and/or ROW applications on all CD/WIIPA 

lands) were also considered. These alternatives were rejected for the following reasons. 

• More than half of the CD/WIIPA is not federally owned and is managed either by the State of 

Wyoming or private owners, and development of these areas would occur regardless of any decision to 

deny development on federal land. 

• The BLM cannot deny access to private holdings across federal lands. The BLM's policy concerning 

access to oil and gas reserves on non-federal lands is contained in BLM Manual 2800.06D, release 

2_224 (May 15, 1985), which directs the BLM to allow access to non-federally owned land 

surrounded by public land managed under FLPMA as necessary to secure to the owner the reasonable 

use and enjoyment thereof. Ingress and egress need not necessarily require the highest degree of 

access, but rather a degree of access commensurate with the reasonable use and enjoyment of the 

land. The access necessary for the reasonable use and enjoyment of the non-federal land cannot be 

denied, so long as the landowner complies with BLM rules and regulations on federal surface. 

• The denial of all development on federal land could lead to the drainage of federal oil and gas 

reserves from wells on adjacent state and private surface. A drainage stipulation designed to protect 

the federal mineral estate is included in the lease_term contractual agreements for all leased lands in 

the CD/WIIPA, and since private land developments are anticipated, some well development on BLM 

lands would occur. 

• The denial of the right to develop a valid lease could violate the lessees' contractual rights and result 

in the loss of federal royalties. An oil and gas lease grants the lessee the "right and privilege to drill 

from, mine, extract, remove, and dispose of all oil and gas deposits" in the leased lands, subject to 

the terms and conditions incorporated in the lease. The BLM cannot directly or indirectly prohibit, 

altogether, the development of the lease. To deny all activity would constitute a breach of contract of 

the Operator's rights to conduct development activities on the leased lands. Authority for complete 

denial can be granted only by Congress (see EIS Section 2.4). 

Another alternative considered but rejected involved drainage drilling only. This alternative would have 

allowed drilling for federal minerals on federal leases only in areas being drained by offset non-federal wells 

and would have greatly limited the number of wells drilled on federal minerals. In order to estimate the 

number of wells that might be drilled under this alternative, the following assumptions were made. 
1. There would be 1,200 wells drilled on non-federal minerals on a pattern of four wells per section, and 300 

additional wells would be drilled as infill wells to produce a pattern of one well per 80 acres. 

2. Wells drilled to increase well density from one well per 160 acres to one well per 80 acres would be 

drilled near the center of the sections, or within 200 ft of section lines. 

3. The 90 gas wells (within or near the CD/WIIPA) analyzed by the Wyoming BLM Reservoir 

Management Group as part of drainage investigations are representative of all wells drilled to the 

Almond Formation in the project area. The analyses indicate that about 12% of the wells would have 

drainage radii larger than 0.25 mi. Wells drilled on non-federal minerals and with a drainage radius 

larger than 0.25 mi would cause drainage of federal oil and gas and would cause a federal protective 

well to be drilled. 

Based on these assumptions, there would be about 144 drainage protection wells drilled. However, this 

alternative was rejected for the legal reasons listed in the previous bulleted paragraphs. 

An alternative focusing on only federal land developments on the CD/WIIPA was also considered. The 

alternative was rejected because it would inadequately portray anticipated development on non_BLM lands in 

the CD/WIIPA. Development on private lands was considered under all alternatives analyzed (i.e., Proposed 

Action, Alternatives A and B, and No Action) to facilitate appropriate impact analyses. 

The BLM also considered and rejected an alternative mandating the use of directional drilling, since all 

alternatives considered in this EIS may use directional drilling to access natural gas reserves beneath areas 

with sensitive surface resources. Further, due to the geology of the principle gas_bearing zone beneath the 

CD/WIIPA--the main Almond Sandstone Formation--directional drilling may be technically and/or 

economically infeasible. 

One additional alternative involving the development of lands within the Adobe Town WSA was considered. 

This alternative was rejected because the BLM would not allow surface disturbance to occur in WSAs. 
3.0 MANAGEMENT CONSIDERATIONS/RATIONALE FOR DECISIONS

The decision to choose and approve the Proposed Action, as modified, as the preferred alternative and as the 

environmentally preferred alternative of the CD/WII project included careful consideration of the following 

factors: 

1) consistency with land use and resource management plans; 

2) alternatives provide less protection; 

3) public involvement, public scoping issues, and draft and final EIS comments; 

4) agency statutory requirements; 

5) national policy; and 

6) measures to avoid or minimize environmental harm. 

A discussion on each of these factors follows. 

3.1 CONSISTENCY WITH LAND USE AND RESOURCE MANAGEMENT PLANS (RMP) 

The original Proposed Action as outlined above is generally in conformance with the BLM GDRA (RFO) 

RMP, and is entirely in conformance with the GRRA (RSFO) RMP, the Sweetwater and Carbon County land 

use plans, and the State of Wyoming land use plan. However, the BLM must not authorize actions that are 

not completely in compliance with the RMPs. 

The issue revolves around the reasonably foreseeable oil and gas development scenarios projected in RMPs 

and the planning decisions these projections may have influenced. Reasonably foreseeable development for 

oil and gas activity within the RSFO area as described in the GRRA RMP is projected to include 

approximately 1,300 new wells (9,985 acres of long_term disturbance for both private/state and federal lands) 

over a 20_year period (1990_2010). The level of development within the RSFO area required for the CD/WIII 

project as identified in this EIS (see DEIS Table 2.1) includes a maximum of approximately 930 new well 

locations and approximately 2,600 acres of new long_term disturbance (31% of the project development total). 

Therefore, the proposed project is within the reasonably foreseeable estimates for future oil and gas 

development within the RSFO area. 

Reasonably foreseeable development for oil and gas activity within the RFO area (includes both federal and 

private/state lands) as described in the GDRA RMP is projected to include approximately 1,440 new wells 

(16,092 acres of long_term disturbance) over a 20_year period (1986-2006). The level of development within 

the RFO area required for the CD/WII project as identified in this EIS (see EIS Table 2.1) includes a 

maximum of approximately 2,070 new well locations (69% of the project development total). A check of well 

data in 1998 showed that 1,145 wells (including plugged and abandoned wells) have been drilled within the 

RFO area since 1985, which means 295 more wells could be drilled under the existing reasonably foreseeable 

development estimate for the RFO area. If well numbers were the sole criteria for formulating impact 

assessments and planning decisions, the reasonably foreseeable development estimate of the number of future 

oil and gas wells within the RFO area would easily be exceeded by this project. 

It is important to note that RMP impact assessments and planning decisions within the RFO area were based 

on the estimated disturbance acreage, not the number of wells. Since 1985, efficiencies within the oil and gas 

industry have resulted in reductions in the disturbance acreage required for oil and gas exploration and 

production. The RMP estimate of future long_term oil and gas disturbance within the RFO area was projected 

to be approximately 16,092 acres for 1,440 wells (approximately 11.2 acres/well); however, estimates based 

on the existing long-term oil and gas disturbance within the CD/WIIPA (7,600 acres for 845 wells; see DEIS 

Table 2.1), reveal that approximately 9.0 acres of long-term disturbance is present for each of the 845 wells. 

This 9.0 acres is a conservative estimate (overestimation) of long_term disturbance. 

Using 9.0 acres of long_term disturbance per well, it is estimated that approximately 10,305 acres of long_term 

disturbance has resulted from the 1,145 wells developed within the RFO area since 1986. An additional 1,200 

acres of long-term oil-and-gas-related disturbance (approximately 298 well locations) has been authorized or 

proposed within the RFO area for the Creston/Blue Gap, Mulligan Draw, Hay Reservoir, Sierra Madre, 

Dripping Rock, and South Baggs (proposed) projects. Therefore, approximately 4,587 acres (16,092 acres 

projected in the RMP less 10,305 acres estimated existing long_term disturbance and 1,200 acres authorized 

for proposed future disturbance) remain for long_term oil and gas development disturbance in the RFO area. 
The CD/WII project is estimated to require approximately 5,727 acres of long_term disturbance in the RFO 

area (2,070 well locations at 2.77 acres per well). Therefore, long_term disturbance acreage estimates for the 

CD/WII project exceed the GDRA RMP/EIS reasonably foreseeable development estimates for future oil and 

gas development in the RFO area. 

The GDRA RMP projected a planning period of 20 years, and data used in RMP analyses for oil and gas 

development was compiled through 1985. Monitoring and tracking of well development since the completion 

of the RMP will continue. BLM initiation of a RFO area RMP review and possible amendment will need to 

occur prior to reaching the reasonably foreseeable disturbance estimates made in the current RMP. This could 

take between 3 and 5 years to complete and the BLM will not authorize oil-and-gas-development actions 

(APDs, ROWs) that exceed current reasonably foreseeable disturbance estimates prior to the plan review and 

possible amendment. Based on the long-term disturbance acreage required per well for the CD/WII project 

(2.77 acres) approximately 1,655 wells could be authorized in the RFO area under the existing reasonably 

foreseeable disturbance acreage estimate (i.e., 1,655 wells = 4,584 acres of available long-term disturbance 

divided by 2.77 acres per well). However, this could preclude or delay future proposed oil and gas 

developments within the RFO area if all these wells be dedicated to the CD/WIIPA before a RMP review and 

possible amendments are completed. 

It is anticipated that field developments within the CD/WIIPA will require 10_20 years, with approximately 

150 to 300 wells being drilled per year. The average for the last 2 years has been about 150 wells. However, 

with favorable changes in natural gas prices and with upward trends in demand, yearly increases in drilling 

could easily exceed 150 wells per year and be as high as 300 wells per year. 

The 20_year planning period for the RFO area RMP extends until approximately year 2005. Assuming well 

development occurs within the first 10 years, and over 250 wells are drilled each year, the CD/WII project 

could be 50% developed by this date. This could result in approximately 1,000-1,200 wells being drilled in the 

project area (i.e., 1,200 well locations = 3,324 additional acres of long-term disturbance) within the 

jurisdictional boundaries of the RFO area. This allows approximately 455 wells (1,260 acres of long-term 

disturbance at 2.77 acres per well) for future for oil and gas development proposals outside the CD/WIIPA. 

All proposed land and resource use and management actions must conform with RMP decisions. In the 

absence of conformance, actions must either be denied or modified so they do conform or the RMP decisions 

must be changed. Therefore, the Proposed Action for this project is modified to authorize no more than 1,200 

wells (i.e., 870 fewer wells than proposed) within the RFO area. This will allow a plan review and possible 

changes to RMP decisions to be made through established procedures which involve public notice, public 

input, and formal decision_making. This process is anticipated to take from 3 to 5 years to complete. 

In summary, limiting the number of proposed wells (including roads, pipelines, etc.) to 930 wells/well 

locations within the CD/WIIPA within the jurisdictional boundary of the RSFO area and to 1,200 wells/well 

locations within the CD/WIIPA within the jurisdictional boundary of the RFO area will allow: 

a) a reasonable amount of drilling and development activity within the CD/WIIPA for at least 5 years; 

b) an opportunity for other future oil and gas developments to occur outside of the project area; 

c) an adequate amount of time for the BLM to conduct a review of the existing RMP for the RFO area; 

and 

d) the Proposed Action to be in complete conformance with RMPs for both the RSFO and RFO areas. 

3.2 ALTERNATIVES PROVIDE LESS PROTECTION 

Throughout the development of the EIS, it was believed that the formulation of the alternatives would add 

further protection to sensitive resources and was necessary considering the size and scope of this project. It 

was believed that Alternatives A and B would provide that increased protection. However, through the 

analysis it became apparent that by choosing Alternatives A or B, operators may elect to concentrate initial 

exploration and development on non-BLM lands or on BLM lands outside SRAs to avoid increased protection 

and mitigation requirements (i.e., increased development costs). This could effectively negate the whole 

purpose of protecting certain resources (i.e., fragmentation and major disturbance of wildlife habitats). 

Therefore, increase in the extent of surface disturbance on private or state lands within SRAs and on federally 

managed lands outside of SRAs could be avoided if the proposed action is chosen. 
In addition, Alternatives A and B seem better adapted to managing sensitive resource values on projects in 

areas with solid block federal ownership. Alternatives A and B would not be as effective in the checkerboard 

land pattern found in the CD/WIIPA. The opportunity for proponents to relocate activity from federal surface 

on to private surface under Alternatives A or B could occur. Past experience during the development of this 

EIS has shown that proponents were not willing to wait for the completion of the EIS, and instead, moved to 

private land where access was available. Proponents would be more likely to reroute activity to private land 

than to operate under the more restrictive construction practices required on public land by Alternatives A or 

B. Overall, BLM will be able to better manage placement of facilities on federal lands and better influence 

placement on private lands if operators are not so restricted to development time-frames in SRAs on federal 

lands. The reclamation requirements under Alternatives A and B would delay new activity on federal land and 

it is likely that the operators would further develop private land adjacent to the federal land. BLM would 

therefore lose the opportunity to influence how the action occurred. 

Finally, the analysis in the EIS showed that long-term surface disturbance would be similar under the Proposed 

Action and Alternative B and potentially could be the same for all alternatives if wells drilled on private land 

resulted in drainage of the federal land or if other surface developments were forced onto private lands due to 

restriction on the adjacent federal land. The DEIS indicates the potential for 144 drainage wells on federal 

land under the No Action Alternative. It is likely that similar drainage well numbers would occur under 

Alternatives A and B. Wells drilled on private land adjacent to federal land SRAs could create a situation 

where Alternative A or Alternative B surface-disturbance limitations would be waived in order to address a 

drainage situation in a timely manner. 

In review of these findings, it appears that choosing the Proposed Action, as modified, will provide the BLM 

more discretion and opportunity to manage development on public lands and therefore, help lessen 

development impacts on the private lands. 

3.3 PUBLIC INVOLVEMENT, PUBLIC SCOPING ISSUES, AND EIS COMMENTS 

Opportunity for public involvement was provided throughout the environmental process. A public scoping 

(public involvement effort) to determine issues and concerns to be addressed in this EIS was commenced on 

March 6, 1995. Due to a change in the extent of the project, public scoping was reinitiated on May 30, 1997. 

Scoping notices were mailed to 1,040 individuals, agencies, and groups (including government offices, elected 

officials, public land users and groups, lessees and operators, private landowners, newspapers, and radio and 

TV stations). The notices described the project and requested comments. Additionally, two public scoping 

meetings were held to provide further opportunity for public comment. Forty_seven comment letters and 15 

telephone calls were received, and 18 comments were provided during the public meetings. A summary of the 

scoping issues is found on pages 1-13 and 1-17 through 1-21 of the DEIS. 

The DEIS was made available for public review on April 30, 1999, and public meetings were held on May 24 

and 25, 1999. Over 600 copies of the DEIS were distributed to the public for review and comment. 

Approximately 12 individuals commented at public meetings and 94 letters were receive in the mail. Of those 

commenting during public meetings for the DEIS, all expressed strong support for the CD/WII project as 

proposed. Some comment letters presented concerns and new data for the air quality analysis, expressed 

concerns about impacts to wildlife and threatened and endangered species, requested emphasis on monitoring 

mitigation measures, and requested compliance with the RMP reasonable foreseeable development scenarios. 

The majority of the comment letters were in favor the project as proposed. 

In regards to issues of threatened and endangered plant and animal species, the BLM initiated formal 

consultation and conference with the USFWS to evaluate protective measures for black-footed ferret (listed 

species) and mountain plover (proposed listed species). The outcome, findings, and clarifications as rendered 

in the USFWS's opinion are found in Appendix G. Reasonable and prudent measures, the terms and conditions 

as outlined in the opinion, and associated implementation protocol developed in coordination between the 

BLM and USFWS including procedures identified in BLM Instruction Memorandum No. WY-2000-44 

(Appendix I) are part of the Proposed Action as modified. 

The FEIS was issued December 10, 1999, for a 30_day comment period. Over 700 copies of the FEIS were 

distributed to the public for review and comment. In addition, media releases were sent to newspapers in 

Wyoming announcing the availability of the FEIS for public review. Only four comment letters were received 

(Appendix H). Three of the letters expressed some concerns about adding additional mitigation and 
amending/revising the RMP for the RFO area; however, all four comment letters were generally in support of 

the analysis and/or proposed development. 

In addition to public scoping and EIS document reviews, a Transportation Planning Committee (TPC) 

comprised of county, state, federal, industry, and private groups and/or individuals was organized in 1998. 

This was a direct result of the Proposed Action mitigation for Transportation Planning as discussed in 

Appendix B. A memorandum of understanding was developed and signed to further define the goals and 

objectives of this planning group. The group has been meeting twice yearly to address current needs and 

issues in the project area. 

Action has also been taken to develop a formal cooperative agreement between industry and state and federal 

agencies to better address monitoring and protection of wildlife within the project area. Final agreement and 

signature on the document is still pending. This initiative was a direct result of Proposed Action mitigation as 

outlined in the Wildlife Protection Plan (Appendix D). 

3.4 AGENCY STATUTORY REQUIREMENTS 

The BLM decision is consistent with all federal, state, and county authorizing actions (EIS, Table 1.1) 

required to implement the CD/WII Operator's proposed action. All pertinent statutory requirements applicable 

to this proposal were considered. These include consultation with the USFWS regarding threatened, 

endangered, and candidate species; coordination with the State of Wyoming regarding wildlife, environmental 

quality, and oil and gas conservation; and coordination with Carbon and Sweetwater County Commissioners 

for obtaining construction and use permits. 

3.5 NATIONAL POLICY 

Private exploration and development of federal oil and gas leases is an integral part of the BLM 

oil-and-gas-leasing program, under authority of the Mineral Leasing Act of 1920 and FLPMA. The United 

States continues to rely heavily on foreign energy sources. Authorization for the lessees to exercise their rights 

in developing oil and gas leases is necessary to encourage development of domestic oil and gas reserves to 

reduce the United States' dependence on foreign energy supplies. Also, natural gas is this nation's 

"energy-of-choice" because it is clean burning and less polluting. Therefore, the decision is consistent with 

national policy. 

3.6 MEASURES TO AVOID OR MINIMIZE ENVIRONMENTAL HARM 

The adoption of the Proposed Action, as modified in this decision, includes all practical means to avoid or 

minimize environmental harm. The decision, to ensure the environmental consequences of the field 

development activities will be minimal, includes not only the required environmental safeguards and resource 

protection measures prescribed by the GRRA (RSFO) and the GDRA (RFO) RMPs, it also includes the 

additional mitigation or protective measures identified in the CD/WII draft and final EIS and this ROD. The 

decision has given full consideration to all public, local, state, and other federal agency input. No substantial 

issues remain unresolved as raised by either governmental agencies, industry, groups, or individuals. 
4.0 COMPLIANCE AND MONITORING

Because of the importance of mitigation for avoiding or minimizing adverse impacts, an intensive monitoring 

program will be implemented by the Operators and BLM with input from state and other federal agencies. 

Mitigation and guidelines for monitoring are incorporated in the Proposed Action as the applicant-committed 

measures (Appendix F), Reclamation Plan (Appendix A), Transportation Plan (Appendix B), Hazardous 

Materials Summary (Appendix C), and Wildlife Protection Plan (Appendix D) and Biological Assessment 

(Appendix E) with the terms and conditions of the USFWS Biological Opinion and associated implementation 

protocol developed in coordination between the BLM and USFWS (Appendix G) and including BLM 

Instruction Memorandum No. WY_2000-44 (Appendix I). 

Monitoring of construction, drilling, and production operations will be routinely inspected by BLM personnel. 

In addition, each Operator may be required to have an individual to serve as Environmental Compliance 

Coordinator. The Environmental Compliance Coordinator will be responsible for assuring that mitigation 

measures are applied and monitoring activities are conducted as necessary to assure surface impacts are 

minimized. Operators and the BLM will provide qualified representatives on-site during construction to 

validate construction commensurate with the approved design. 

The procedures identified for monitoring, evaluation, review, and potential modification (e.g., changed 

mitigative actions) identified in the EIS Reclamation Plan, Transportation Plan, and Wildlife Protection Plan 

(EIS Appendices A, B, and D respectively) provide for an "adaptive environmental management plan" for 

most, if not all, resources with the potential for significant impacts. Although an intensive analysis was 

completed for potential impacts to air quality, an adaptive environmental management plan is not necessary 

for air quality. This is due to finding no project-specific significant air quality impacts and to the fact that 

BLM cannot implement specific air quality mitigations since it has no authority to do so. 

The following provides a brief summary of how the transportation, reclamation, and wildlife protection plans 

provide for compliance, monitoring, and/or adaptive environmental management. 

The Reclamation Plan (Appendix A) involves components designed to protect or otherwise minimize impacts 

to many area resources including surface waters and groundwaters, vegetation communities, wildlife, livestock 

grazing, recreation, and visual resources. The process to assure appropriate reclamation is provided in 

Appendix A, Figure A-1.1. Reclamation monitoring will be the responsibility of both the BLM and the 

Operators. Monitoring will be accomplished through joint, coordinated monitoring efforts. Details on 

BLM/Operator monitoring responsibilities will be provided in site-specific plans. Monitoring protocol and 

success criteria are outlined in detail in the Sections A-6.2 and A_6.3 of Appendix A. Monitoring data will be 

compiled by the BLM to provide future guidance for successful reclamation. 

The transportation planning process as identified in Appendix B and the associated technical support 

document, involves components designed to protect virtually all area resources. A TPC that includes BLM, 

Operators, state and county transportation departments, WGFD, landowners, grazing permittees, and other 

interested parties has been established. Road development and closure planning in the CD/WIIPA will include 

multiple-entity involvement on an annual basis. Where potential problems can be identified prior to road 

development, road development plans may be changed. Furthermore, where problems are identified after 

roads have been constructed, the TPC will work to alleviate these situations. Yearly TPC meetings are 

opened to the public as a method to assist in resolution of issues. 

The Wildlife Protection Plan (Appendix D) is designed to determine the extent of adverse effects occurring to 

sensitive wildlife resources, and in the event adverse effects are found, the plan calls for increased protection 

measures. Currently proposed techniques and associated responsibilities are shown in Appendix D, Tables 

D-2.1, D-2.2, and D-2.3. An annual review of wildlife monitoring, techniques, and collected data will be 

conducted by BLM, Operators, WGFD, and USFWS. Annual reviews will help determine if protection 

measures have been adequate or if additional protective measures are required. To further specify 

responsibilities and commit financial obligations, a cooperative agreement among participating agencies and 

operators will be required. 
5.0 APPEAL

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

accordance with the regulations contained in 43 Code of Federal Regulations (C.F.R.) 3165.4(c). If an appeal 

is filed, the notice of appeal must be filed in this office (Bureau of Land Management, State Director, P.O. 

Box 1829, Cheyenne, Wyoming 82003) within 30 days of the date the notice of the decision appears in the 

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

If you wish to file a petition (pursuant to 43 C.F.R. 3165.4(c)) for a stay (suspension) of the effectiveness of 

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

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

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

submitted to the IBLA and to the appropriate office of the Solicitor at the same time the original documents 

are filed with this office. If you request a stay, you have the burden of proof to demonstrate that a stay should 

be granted. 
6.0 SIGNATURE 

______/s/Alan R. Kesterke______________________ ______May 24, 2000____________________ 

Wyoming State Director Date 
APPENDIX A: 

RECLAMATION PLAN 
RECLAMATION PLAN

FOR THE CONTINENTAL DIVIDE/WAMSUTTER II

 NATURAL GAS PROJECT

Prepared for 

U.S. Bureau of Land Management

Rawlins Field Office

Rawlins, Wyoming

and 

Rock Springs Field Office 

Rock Springs, Wyoming 

By 

TRC Mariah Associates Inc.

Laramie, Wyoming

MAI Project 1295

April 1999
Record of Decision, Continental Divide/Wamsutter II 

ABBREVIATIONS AND ACRONYMS 

APD Application for Permit to Drill 

BLM Bureau of Land Management 

CD/WIIPA Continental Divide/WamsutterII Project Area 

COE U.S. Army Corps of Engineers 

EIS Environmental impact statement 

ERRP Erosion Control, Restoration, and Revegetation Plan 

IDT Interdisciplinary Team 

LOP Life-of-project 

PLS/ac Pounds of pure live seed per acre 

ROW Right-of-way 

VRM Visual Resource Management 

WDEQ Wyoming Department of Environmental Quality 

WOGCC Wyoming Oil and Gas Conservation Commission 
Record of Decision, Continental Divide/Wamsutter II 

A_1.0 RECLAMATION OBJECTIVES 

This reclamation plan will be used by the Operators of the Continental Divide/WamsutterII Natural Gas 

Project as guidance to achieve successful reclamation on federal lands within the Continental 

Divide/WamsutterII Project Area (CD/WIIPA). Alternate reclamation procedures may be implemented on 

private and state lands. The plan complies with Bureau of Land Management (BLM) reclamation policy 

(BLM 1990a) and management directives specified in the Great Divide and Green River Resource Area 

Management Plans (BLM 1987, 1988, 1990b, 1992, 1996). The reclamation plan was developed based on 

these policies and directives, Executive Order 11987, and impacts and scoping issues identified in this 

environmental impact statement (EIS). The procedures presented in this plan are designed to allow flexibility 

based on specific conditions encountered at each proposed disturbance site. Site-specific reclamation 

procedures will be developed in each Application for Permit to Drill (APD), right-of-way (ROW) application, 

or Sundry Notice and submitted to the BLM for review and approval prior to the authorization of 

surface-disturbing activities. 

Short-term reclamation goals will be the immediate stabilization of disturbed areas and the protection of 

adjacent undisturbed areas from unnecessary degradation. The long-term reclamation objective will be to 

restore all disturbed lands to conditions equal to or better than predisturbance conditions by 

developing/re-establishing self-sustaining native vegetation communities that meet or exceed predisturbance 

parameters for cover, species composition, production, and diversity (i.e., ecosystem reconstruction). Other 

goals include the protection of surface and ground water resources through the restoration of a geologically and 

hydrologically stable landform that will support future land uses (i.e., wildlife habitat, recreation, livestock 

grazing, and mineral exploration) and the prevention of the spread of noxious weeds. 

BLM-required reclamation objectives are: 

• the isolation and/or removal of all undesirable materials (e.g., poor quality subsoils, contaminated 

soils, potentially hazardous materials) to protect the rehabilitated landscape from contamination; 

• the assurance of subsurface (downhole) integrity to minimize subsidence and/or eliminate ground 

water co-mingling and contamination (downhole reclamation and abandonment procedures are 

specified in Section2.6.12 of the EIS and will be approved by the BLM through a Sundry Notice prior 

to implementation); 

• the recontouring and implementation of other soil conservation, surface manipulation, and water 

management techniques to establish stable slopes, water courses, and drainage features to minimize 

erosion and sedimentation; 

• the revegetation of reclaimed areas to stabilize soils and establish a self_perpetuating native plant 

community capable of supporting post_disturbance land uses; 

• the establishment of acceptable long-term visual aesthetics by mitigating visual contrasts; and 

• the monitoring and management of reclamation sites by Operators to evaluate and encourage 

continued reclamation success (BLM 1990a). 

Site-specific reclamation objectives will be stipulated in Surface Use Plans and/or Erosion Control, 

Restoration, and Revegetation Plans (ERRPs) (see Section A_6.0). 

The reclamation process has been divided into four major phases: predisturbance planning and site 

preparation, temporary reclamation, permanent reclamation, and reclamation success monitoring. By 

minimizing the amount of land disturbed through predisturbance planning and initially preparing the site for 

construction activities with the understanding that the area will eventually be reclaimed (e.g., top soil stripping 

and stockpiling for later use during site rehabilitation, keeping facilities away from cut-and-fill slopes and in as 

small an area as possible), the acreage requiring disturbance will be reduced and reclamation success will be 

facilitated. Temporary reclamation will involve the restoration of areas that may be utilized for the planned 

development but will not necessarily need to be disturbed for the entire life-of-project (LOP) and will include 

the stabilization of disturbed areas to control runoff and erosion until permanent reclamation procedures are 

applied. Construction-related disturbance areas along road ROWs are examples of temporary reclamation 

sites. 
Record of Decision, Continental Divide/Wamsutter II 

Permanent reclamation will include the rehabilitation of locations no longer needed for theproject. A 

nonproducing well location and associated access road are examples of permanent reclamation sites. Upon 

project completion, all disturbed areas except roads slated to be retained for other land uses will be 

permanently reclaimed as designated by the BLM or other landowner. Reclamation success monitoring will 

involve assessing the status of reclaimed areas to ensure that these areas meet desired site stability and 

productivity standards. Figure A_1.1 illustrates the proposed reclamation process for the CD/WIIPA. 
Record of Decision, Continental Divide/Wamsutter II 

A_2.0 AFFECTED COMMUNITIES 

As described in Section 3.2.1 of this EIS, the CD/WIIPA contains eight dominant vegetation types including 

Wyoming big sagebrush (731,900 acres, 69.0%); greasewood fans and flats (151,100 acres, 14.2%), desert 

shrub (97,100 acres, 9.2%), saltbush fans and flats (40,600 acres, 3.8%), basin exposed rock/soil (31,000 

acres, 2.9%), shrub-dominated riparian (4,500 acres, 0.4%), unvegetated playa (3,400 acres, 0.3%), and mixed 

grass prairie (1,600 acres, 0.2%) (see EIS Map 3.7). 

Approximately 9,200 acres (<1%) of the CD/WIIPA is considered wetland. Wetland areas occur as inclusions 

within the dominant vegetation types and consist primarily of ponds and reservoirs/impoundments located 

along ephemeral stream channels. The greatest concentration of wetlands occurs in the northeastern portion of 

the CD/WIIPA in the Chain Lakes area (see EIS Section 3.2.1.1 and Map 3.6). Stabilized sand dunes and 

other sandy soil areas also occur throughout the CD/WIIPA and occupy approximately 90,000 acres (8.5%) of 

the area (see EIS Section3.1.4.2 and Map3.4). No active dunes are known to occur. 

Reclamation potential within the sagebrush, greasewood, shrub-dominated riparian, and mixed grass 

communities will be good to excellent; however, in the more barren areas, including the desert shrub, exposed 

rock/soil, saltbush, and playa communities, reclamation will be limited by shallow soils, droughtiness, 

salinity, and other adverse conditions. In addition, the sandy soils associated with stabilized dunes are very 

susceptible to wind erosion when vegetation cover is removed, and the restoration of these areas following 

disturbance may pose the greatest reclamation challenge on the CD/WIIPA. Reclamation potential may also 

be limited by other extant conditions on the CD/WIIPA, including: salinity, alkalinity, steep slopes, 

noncohesive soils, weather conditions (high winds, drought), periodic flooding, short growing seasons, and 

livestock and wildlife use. 
Record of Decision, Continental Divide/Wamsutter II 

A_3.0 PREDISTURBANCE PLANNING AND SITE PREPARATION 

During selection of drill site, road, pipeline, and ancillary facility locations, consideration of future 

reclamation needs will facilitate land rehabilitation by minimizing the amount of land disturbed and avoiding, 

where possible, areas where reclamation potential is low. Avoidance areas stipulated in the EIS include: 

• areas with high erosion potential (e.g., rugged topography, steep slopes [>25%], stabilized sand dunes, 

floodplains), 

• areas with saturated soils, 

• wetland/riparian areas (e.g., perennial stream channels and open water areas) and a 500-ft buffer, 

• ephemeral and intermittent channels and a 100-ft buffer, and 

• Visual Resource Management (VRM) ClassII areas and areas visible from and within 0.25 mi of 

contributing segments of the Overland and/or Cherokee Trails. 

Approximate disturbance for well locations will be 2.6 acres/location initially and 0.8acres/location for the life 

of the well. Approximately 1.8 acres/location will be reclaimed temporarily at each producing well location; 

permanent reclamation may be implemented in some or all of an area if it is determined that additional 

disturbance will not be necessary during the LOP. For the purpose of the EIS it is estimated that 

approximately 4.8 acres/mi of short-term tandem road and pipeline disturbance will be required for the project; 

long-term disturbance from tandem road and pipeline corridors is estimated at approximately 1.9 acres/mi. In 

addition, a maximum of approximately 144acres of disturbance will be required for ancillary facility sites (i.e., 

water wells [50wells at 0.5 acres/well], water disposal wells [5 wells at 7.0acres/well], evaporation ponds [10 

ponds at 3.4 acres/pond], compression facilities [5 facilities at 4.0 acres/facility], and a gas processing plant 

[30 acres]) (see EIS Section 2.6.8). Estimated maximum 

disturbance levels for the entire project are shown in Table 2.1 of the EIS, and disturbance limitations under 

the various project alternatives are given in Table2.2. 

Prior to disturbance, Operators and the BLM will conduct on-site inspections of each proposed disturbance site 

to determine the suitability of proposed facility locations and/or alignments and to develop a site-specific 

reclamation plan. In addition, Operators will submit for BLM approval Surface Use Plans, Plans of 

Development, and/or ERRPs for each proposed surface disturbance site. These plans will contain site_specific 

erosion control, revegetation, restoration, and monitoring procedures and will provide detail on the following: 

• project administration, time frames, and responsible parties; 

• reclamation objectives; 

• predisturbance landscape characteristics, including species composition and plant cover; 

• topsoil removal, storage, and handling criteria; 

• runoff, erosion, and sedimentation control procedures; 

• seedbed preparation, seed mixes and rates, and seed application procedures; 

• fertilization, mulching, and/or other site protection (i.e., small-scale fencing and weed, livestock, and 

herbivore control) requirements; and 

• reclamation monitoring and maintenance. 

Stormwater pollution prevention plans will be prepared for all project activities requiring greater than 5 acres 

of disturbance to ensure that precipitation will not cause erosion or sedimentation problems. These plans may 

be prepared for groups of wells, where multiple well, road, pipeline, and/or ancillary facility locations have 

been determined. A Notice of Intent will be submitted to the Wyoming Department of Environmental Quality 

(WDEQ) for review, and a pollution prevention plan prepared and implemented. Copies of the pollution 

prevention plan and inspection reports will be retained on file in the Operators' offices. 

A_3.1 TOPSOIL AND SUBSOIL HANDLING 

Topsoil will be salvaged and stockpiled from all proposed disturbance areas unless the BLM deems that 

leaving topsoil in place (e.g., during pipeline construction) will better facilitate successful reclamation. Prior 

to BLM authorization of surface disturbance, the amount of topsoil or other suitable plant growth material to 

be removed and topsoil storage areas will be specified. If less than 6 inches of topsoil are available, topsoils 
Record of Decision, Continental Divide/Wamsutter II 

may be mixed with suitable subsoil materials for stockpiling so that a minimum of 6 inches of plant growth 

material is available for use during reclamation. The need to strip topsoil for some project activities (e.g., 

along pipeline routes) will be determined on a site-specific basis. Topsoil in excess of 6 inches, if available, 

may be stored for use in areas off-site that lack sufficient topsoil for reclamation. Whenever possible, topsoil 

will be used immediately. Topsoil stockpiled for more than 3 months will be protected from erosion by 

reducing piles to less than 3 ft in height and by seeding and possibly mulching. 

Topsoil stockpile areas will be marked in the field and noted on maps. Topsoil stockpile surface area will be 

maximized to reduce adverse impacts to soil microorganisms. All surface vegetation stripped with topsoils 

will be incorporated directly into the topsoil to augment organic matter content and seed source availability, 

unless shrub materials are required to be handled separately. Runoff will be diverted around topsoil stockpiles 

to minimize erosional loss. Topsoil stockpiles will be located as close as possible to future reclamation sites. 

In most instances, disturbance sites will be designed with a balance of cut and fill, thereby minimizing the 

volume of subsoil stockpiling required. However, in those areas where subsoil materials will be stockpiled, 

they will be isolated from topsoil stockpiles and located so as not to affect existing drainages. These 

stockpiles will be kept as small as possible and will be constructed such that they remain stable until they are 

used during reclamation. In addition, they will be located such that minimal construction activity is required 

during recontouring. 

The collection and analysis of soil samples from disturbed areas may be required as part of reclamation 

planning to determine appropriate reclamation seed mixtures and the need for soil amendments. However, in 

most instances, the vegetation present at and surrounding proposed disturbance sites will provide sufficient 

information for determining reclamation seed mixes. Soil testing and reports will be the responsibility of the 

Operators. Testing (as deemed necessary by the BLM) may include, but is not necessarily limited to pH; 

texture; salinity; alkalinity; nitrogen, phosphorus, and potassium levels; organic matter; and toxic elements 

(e.g., selenium). 

Alternate site preparation procedures may be applied in some areas (i.e., dry alkaline sites, badlands, 

floodplains, wetland/riparian areas) to facilitate reclamation. In dry alkaline areas (which generally occur at 

relatively flat sites associated with playas or broad drainages), there is often very little topsoil, and 

excavations may result in drainage problems. In these areas, vegetation and topsoil removal usually results in 

the need to import materials from off-site to build up required surfaces. Borrow material sources and quantities 

will be defined prior to construction. Badland areas also have limited suitable topsoil, with topsoil found only 

at isolated sandy areas. Augmented volumes of suitable soil materials will be removed from sandy areas and 

stockpiled with vegetation for later use during reclamation of badland sites. In addition, topsoils in floodplain 

areas may not be removed, depending on the potential for shallow ground water occurrence. 

In wetland/riparian areas, vegetation will be cut to ground level, leaving existing root systems intact. Cut 

vegetation will be removed from these areas for disposal. Grading activities will be limited to areas directly 

over pipeline trenches and road surface areas where these corridors cross wetlands. At least 12 inches of 

topsoil will be salvaged and replaced except in areas with standing water or saturated soils. Use of 

construction equipment in these areas will be limited, and if standing water or saturated soils are present, 

wide-track or balloon-tire construction equipment may be used or normal construction equipment will be 

operated on equipment pads or geotextile fabric overlain with gravel fill. Equipment pads will be removed 

immediately following completion of construction activities. Trench spoil will be placed at least 10ft away 

from drainage channel banks, and dirt, rockfill, and brush riprap will not be used to stabilize ROWs. 

A_3.2 WELLPAD AND FACILITY SITE CONSTRUCTION 

Prior to construction, proposed pad and facility site locations will be surveyed and staked. Additionally, all 

erosion control design considerations will be reviewed by the BLM to determine their adequacy. Locations 

will be designed to parallel the contour with reserve pits on the uphill side of pads whenever possible. Reserve 

pits will be imperviously lined, as necessary, and pits will not be constructed in floodplain areas or at other 
Record of Decision, Continental Divide/Wamsutter II 

locations proximal to open water. Wellpads will be designed and constructed to disturb the smallest area 

necessary to provide for efficient and safe operations. 

All cut-and-fill slopes with greater than 3 ft cut and/or fill will be staked at least every 50 ft. Spoil storage 

areas will also be staked. All cut-and-fill work will be designed to minimize the amount of material required 

during construction, and if excess material is generated, it will be incorporated into fill slopes or placed in 

designated areas and stabilized. Backsloping will be necessary only in areas of steep terrain (>10% slopes). 

During construction, interceptor ditches will be installed above cuts and around reserve pits, where necessary. 

Collector ditches and sediment control structures, designed for a 10_year/24-hr storm event, may be required 

below fill areas. Flows of less than the 10_year/24_hr event will be diverted and/or collected before being 

discharged from the disturbed area. Qualified specialists will supervise the installation of all erosion control 

structures, including berms, dikes, and trenches, as deemed necessary by the BLM. 

No surface disturbance will be allowed on slopes of greater than 25% unless proposed erosion control and 

rehabilitation/revegetation procedures are deemed adequate by the BLM. In addition, most construction sites 

in floodplains will be located on imported fill compacted on the existing ground surface or geotextile 

membrane. The entire wellpad may be bermed in these areas. Detailed engineering proposals, revegetation 

and restoration plans, and a site-specific environmental analysis by the BLM will be required. 

A_3.3 ROAD AND PIPELINE LOCATION AND ALIGNMENT 

To minimize disturbance associated with roads and pipelines, pipeline corridors will be partially contained 

within road ROW corridors, where practical. In addition, existing roads within the CD/WIIPA will be utilized 

to the maximum extent possible. 

Where roads or pipelines must cross drainages, construction and installation operations will be designed to 

protect drainages and timed to coincide with periods of low flow (late summer, fall, winter). Crossings will be 

at right angles to drainage channels, where possible. Removal and disturbance of riparian/wetland vegetation 

will be minimized, and these areas will be reclaimed according to site-specific measures developed in 

accordance with approved U.S. Army Corps of Engineers (COE) and WDEQ best management practices. All 

appropriate permits and public notices required by the COE will be obtained prior to construction (e.g., Section 

404 permits). 

A_3.3.1 Roads 

New roads generally will follow natural contours and will be constructed in accordance with BLM road 

standards (BLM 1985, 1991). For roads on slopes of less than 10%, available topsoil will be stripped from the 

construction area and placed in windrows within the construction ROW by sidecasting with a grader. After 

road construction (first fall season during temporary or permanent reclamation), the topsoil will be replaced on 

road outslopes, and these areas will be reseeded (see Sections A_4.0 and A_5.0). 

Surface runoff control will be incorporated into all road designs in accordance with BLM standards (BLM 

1985, 1991) and will be approved by the BLM. Road grades, ditches, culverts, sediment traps, material cuts 

and fills, and topsoil and spoil storage areas will be designed and located in the field prior to construction. 

Road culvert locations and spacings will be approved by the BLM prior to construction and will be in 

accordance with BLM standards. 

A_3.3.2 Pipelines 

When constructing and reclaiming pipelines, existing crowned-and-ditched roads will be used for access, 

where practical, to minimize surface disturbance. Pipelines will follow new or existing roads or other 

pipelines, wherever practical. Pipeline trenches will not be placed in access road borrow ditches unless no 

other reasonable locations are available. In addition, gathering pipelines may be installed on the surface in 
Record of Decision, Continental Divide/Wamsutter II 

areas where slopes are greater than 25% and/or where rock outcrops are crossed. Furthermore, when practical, 

they will be built perpendicular to the contour to minimize the area required for construction. 

Clearing of pipeline ROWs will be accomplished with the least amount of disturbance necessary. Vegetation 

will be removed from pipeline ROWs so as to leave the root systems intact, and the removed vegetation will 

be spread over disturbed areas to provide protection, nutrient recycling, and a natural seed source. Pipeline 

trenches will be excavated with a backhoe to minimize disturbance. 

Topsoil will generally not be segregated from subsoil during pipeline trenching due to the small size of most 

pipeline trenches. However, for larger pipelines (e.g., >10 inches in diameter), the BLM may require topsoil 

salvage from portions of the pipeline ROW. Inthese areas, vegetation and topsoil will be placed away from 

construction traffic. Approximately 6 inches of topsoil, or more, if so directed by the BLM, will be removed, 

and topsoil materials will not be mixed with subsoils. 

Construction will occur as soon as possible after clearing and grading to minimize exposure of soils to erosion. 

However, no construction activities will be allowed when soils are too wet to adequately support construction 

equipment; this action will reduce the potential for rutting. Subsoil and topsoil materials will be stored in 

windrows adjacent to pipeline trenches to facilitate backfilling and topsoil replacement. 

Clean gravel will be used for the upper 1 ft of fill over backfilled pipeline trenches in perennial and 

intermittent streams. Silt fences or other sediment filtering devices also will be installed along channel banks 

where sedimentation is excessive and at the base of all slopes adjacent to wetland/riparian areas. Trench 

plugs will be employed during pipeline construction at nonflumed drainage crossings to prevent diversion of 

drainage channel flows into upland portions of pipeline trenches. Application of riprap will be limited to areas 

where flow conditions prevent vegetative stabilization. Riprap placement and installation will comply with 

COE permit requirements. Pipeline trenches will be dewatered so no silt_laden water flows into drainage 

channels. Where vegetation is disturbed, temporary sediment barriers such as silt fences and/or staked 

weed_free straw bales will be installed along the topographic contour at the base of slopes adjacent to the 

ROW crossing. Temporary sediment barriers will remain in place until permanent revegetation measures have 

been judged successful by the BLM. 
Record of Decision, Continental Divide/Wamsutter II 

A_4.0 TEMPORARY RECLAMATION 

Temporary reclamation will occur on all areas where permanent reclamation is not promptly applied and on 

areas that may be disturbed during final reclamation. Disturbed areas subject to temporary reclamation 

include road cut_and_fill areas, portions of each wellpad and ancillary facility site not needed for 

production-related activities, and topsoil and subsoil stockpiles. Temporary reclamation measures will be 

applied only as needed, since permanent reclamation measures will be applied concurrently with the 

completion of most specific project activities. 

Temporary reclamation objectives include: 

• stabilization of disturbed areas by providing wind and water erosion control to reduce soil loss and the 

chance of slope failure, 

• minimization of surface runoff to prevent the degradation of downstream receiving waters through the 

use of pollution control techniques (e.g., facility sites will be required to approach zero runoff from the 

location, using interception ditches, berms, or other structures to capture accidental spills), 

• establishment of plant communities to protect soil resources, and 

• minimization of visual impacts. 

Upon completion of a specific development activity (e.g., road construction, well testing), the area to be 

temporarily reclaimed will be delineated. For example, all road topsoil storage in outslope areas, as well as 

the potentially disturbed outer portions of road ROWs, will be stabilized and reseeded until permanent road 

reclamation is initiated. 

Disturbed areas will be graded and contoured to slopes of 3:1 (horizontal:vertical) or less as required to 

stabilize the area and to provide a suitable seedbed. Contoured areas will be ripped, as necessary, to 

reduce soil compaction. Ripping in many areas may be conducted after topsoil replacement. Temporary 

erosion control measures (e.g., waterbars, mulch application, biodegradable netting installation) also will be 

applied as necessary. To minimize sedimentation of drainage channels and wetlands during the interim period 

between construction activity and final reclamation, temporary erosion and sediment control measures will be 

applied. Silt fences or other sediment filtering devices such as weed-free straw bales will be installed at 

drainage channel banks where sedimentation is excessive and at the base of all slopes adjacent to 

wetland/riparian areas. Sediment filtering devices will be cleaned out and maintained in functional condition 

throughout the LOP. To avoid the possibility of mulching materials entering waterways, loose mulch (i.e., 

mulch not crimped into the soil surface, tackified, or incorporated into erosion control blankets) will not be 

applied to drainage channel banks. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-4.1 Temporary Reclamation Seed Mixture and Seeding Rates.1 

Species Seeding Rate 

(PLS/acre)2 

Western wheatgrass (Elymus smithii) 2.0 

Slender wheatgrass (Elymus trachycaulum) 2.0 

Streambank wheatgrass (Elymus riparium) 2.0 

Wild blue flax (Linum lewisii) 1.0 

Winter wheat (Triticum aestivum)3 10.0 

Total 17.0 

1 Alternative species may be reseeded in areas where permanent reclamation may be warranted and/or 

where the establishment of proposed species is repeatedly deemed unsuccessful. 

2 PLS/acre = pounds of pure live seed per acre; alternate seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans, Plans of Development, 

and/or ERRPs. 

3 A sterile hybrid will be seeded as cover crop; cover crops would be used only in areas where rapid site 

stabilization is desired and where further reseeding efforts likely would be conducted. After topsoil 

replacement and preparation, the area will be seeded at the first appropriate opportunity, but within 2 

years, using a temporary seed mixture developed to facilitate the rapid establishment of vegetation 

(TableA_4.1). Areas that have been seeded will be visually monitored for seedling establishment and 

the presence of erosional features and will be restabilized and reseeded, as necessary, until adequate 

vegetation establishment and site stability is achieved (see Figure A_1.1 and Section A_6.0). In 

general, the permanent reclamation and success monitoring procedures specified in Sections A_5.0 and 

A_6.0 also will be applied at temporary reclamation sites. 
Record of Decision, Continental Divide/Wamsutter II 

A_5.0 PERMANENT RECLAMATION 

Disturbed areas will be permanently reclaimed as soon as practical, but within 2 years of the determination 

that these areas are no longer required for the project. Permanent reclamation objectives include all those 

listed for temporary reclamation (see Section A_4.0), plus the following: 

• the re-establishment of self_sustaining native vegetation communities that meet or exceed 

predisturbance parameters for cover, production, and diversity, as measured at adjacent undisturbed 

areas; 

• the development of hydrologically stable landforms that meet future land uses including livestock 

grazing, wildlife habitat, recreation, and mineral exploration; and 

• the restoration of the visual quality of the area such that it approximates the visual quality of adjacent 

undisturbed areas in line, form, color, and texture. 

A_5.1 FACILITY AND STRUCTURE REMOVAL 

All gas and water wells will be abandoned according to relevant BLM and/or Wyoming Oil and Gas 

Conservation Commission (WOGCC) recommendations. All aboveground wellpad, pipeline, gas processing, 

and water disposal facilities, including buildings, structures, tanks, reserve pits, flare pits, evaporation pits, 

and associated hardware, will be dismantled and removed from the site after they are no longer needed. These 

materials will be salvaged and re-used or disposed of at approved sites. 

Any liquid or solid wastes remaining at well locations will be tested and properly disposed of according to 

state and federal regulations. Reserve or evaporation pit liners will be disposed of according to BLM 

recommendations by removal to state-approved sites (e.g.,Wamsutter landfill) or by appropriate on-site burial. 

Any concrete foundations, pads, or footings will be adequately broken up and covered or removed. All 

aggregate used for wellpad, road, and/or ancillary facility site construction also will be removed or suitably 

buried. 

Road reclamation will be conducted as deemed appropriate by the BLM; some roads may remain after project 

completion. Road reclamation will include the removal of bridges, culverts, cattleguards, sediment control 

structures, and signs. Drainage-crossing sideslopes will be reduced to no more than 4:1 to reduce bank erosion 

and produce stable sideslopes. In addition, road barriers or signage to discourage travel on the reclaimed road 

surface may be required by the BLM. 

A_5.2 SURFACE PREPARATION 

Surface preparation includes backfilling, grading, and ripping of compacted soils. Additionally, where 

wetlands have been disturbed and where soil structure contributes to wetland form and function, soils will be 

compacted to appropriate depths and densities to retain wetland function. In some temporarily reclaimed 

areas, topsoil removal and short-term storage may also be required. 

A_5.2.1 Backfilling and Grading 

All disturbed areas will be backfilled and graded (recontoured) to restore disturbed areas to the approximate 

original contour after facilities and equipment have been removed. Cut_and-fill slopes will be reduced to 3:1 

or less. Grading will provide a surface suitable for the replacement of a uniform depth of topsoil, while 

promoting cohesion between subsoil and topsoil layers, reducing wind erosion, and facilitating moisture 

capture. 

Specialized grading techniques will be applied as necessary and may include slope rounding, bench grading, 

stair-step grading, and/or contour furrowing. Generally these processes are accomplished either with scrapers 

or motor graders. Equipment selection will be determined on a site-specific basis dependent on the material to 

be graded, the size of the area, on-site operating conditions, and equipment availability. 
Record of Decision, Continental Divide/Wamsutter II 

Areas generally requiring backfilling and/or grading include reserve pits, evaporation pits, pipeline trenches, 

cut-and-fill areas, and any additional areas where unsuitable voids exist or excess fill material has been 

stockpiled. No visible soil berm (i.e., in excess of 3 inches) will be provided above pipeline trenches. 

Operator-provided reclamation specialists will ensure that backfilling and grading operations are conducted so 

as to provide a landscape suitable for successful reclamation. 

A_5.2.2 Ripping 

Compacted areas such as roads and wellpads will be ripped to a depth of approximately 2 ft to improve soil 

aeration, water infiltration, and root penetration. Ripping will be accomplished with a motor grader or a tractor 

using an appropriate attachment. Ripper shanks will be set approximately 1 to 2ft apart. Waterbars and 

erosion control devices will be installed on reclaimed areas prior to topsoil replacement, as necessary, to 

control topsoil erosion (see Section A_5.5). 

A_5.3 SEEDBED PREPARATION 

Seedbed preparation maximizes seeding efficiency and improves reclamation success. It includes topsoil 

replacement (with amendments, where appropriate) and discing. 

A_5.3.1 Topsoil Replacement 

All topsoil salvaged during construction will be uniformly redistributed on the area to be reclaimed to depths of 

at least 6 inches, or more (up to 12 inches) if readily available, using a scraper or dozer, as appropriate, for 

the material and site. Topsoil replacement will be scheduled immediately prior to seeding to maximize the 

potential for seedling establishment. Topsoil may require inoculation with soil microorganisms or fertilization 

at some locations to facilitate plant establishment and growth. Since precipitation in the CD/WIIPA is low, 

fertilizers generally will not be applied. Fertilizers will not be utilized proximal to open waters. 

A_5.3.2 Discing 

After topsoil replacement, newly topsoiled areas will be disced, harrowed, or ripped to reduce soil compaction, 

break up soil clods, improve root and water penetration, and provide a friable but firm seedbed. The 

Operator-provided reclamation specialist will determine how discing or harrowing will be accomplished. 

Generally, discing will be accomplished using a tractor-drawn implement set 2-6 inches deep. 

A_5.4 REVEGETATION PRACTICES 

A_5.4.1 Seeding 

Reclaimed areas will be seeded using specific native species and seeding rates for the various soil and 

vegetation types present on the CD/WIIPA (Tables A_5.1-A_5.9). All seeds utilized for this project will be 

certified weed free. The proposed seed mixes were developed based on the following criteria: general 

conditions within the analysis area; species adaptations to site conditions; usefulness of the species for rapid 

site stabilization; species success in past revegetation efforts; seed costs and availability; and compliance 

with Executive Order 11987 and BLM Manual Section 1745 (i.e., use of native species only). Certain 

introduced species have been successfully used for reclamation in the region; these species may have utility in 

site stabilization and revegetation where revegetation efforts with native species repeatedly have been 

unsuccessful. Operators will consult with the BLM and acquire BLM approval prior to the use of introduced 

species. Seed mixtures applied during revegetation will be designed in coordination with the BLM during the 

APD and ROW application approval processes. 

Final determination of the appropriate seed mixture will be developed on a site-specific basis in coordination 

with the BLM at the time of field review (APD and ROW application review). Selected seed species may be 

inoculated with soil microorganisms to facilitate germination and growth. Soil and watershed protection will 
Record of Decision, Continental Divide/Wamsutter II 

be emphasized when reclaiming disturbed areas. Areas not exhibiting successful revegetation, as determined 

during monitoring (see Section A_6.0) will be reseeded and/or improved with soil amendments as deemed 

necessary by the BLM until adequate vegetative cover is established. 

Seeding generally will be done in the fall between September 16 and freeze-up; however, some areas may be 

seeded in the early spring between spring thaw and April 15. Wherever possible, seed planting will be done 

along the contour using a rangeland drill equipped with an agitator and depth bands to mix seed and ensure 

proper seeding depths. Seeds will be planted 0.25 to 1.50 inches deep; most seeds will be planted 0.25 inches 

deep. When drill seeding is not practical due to steep slopes or wet soil conditions, broadcast seeding will be 

employed, seeding rates will be doubled, and the area will be raked or chained to cover seeds. To facilitate 

seed establishment, broadcast seeding may be used for shrub and forb species, utilizing either hand or 

specialized broadcast seeders; fluffy seeds (e.g., winterfat) may be broadcast simultaneously with drill seeds. 

In addition, at sites where rapid shrub and/or tree establishment is desirable, bare-rooted or containerized stock 

may be hand-planted. Depending on site-specific circumstances, broadcast seeding may be accomplished 

following mulch and crimping operations. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-5.1 Permanent Reclamation Species List for Sagebrush-dominated Communities.1 

Species Seeding Rate 

(PLS/acre)2 

Grasses 

Thickspike wheatgrass (Elymus dasystachyum) 2.0 

Western wheatgrass (Elymus smithii) 2.0 

Bluebunch wheatgrass (Elymus spicatum) 2.0 

Bottlebrush squirreltail (Sitanion hystrix) 2.0 

Indian ricegrass (Oryzopsis hymenoides) 2.0 

Needle-and-thread (Stipa comata) 2.0 

Forbs 

Scarlet globemallow (Sphaeralcea coccinea) 1.0 

Wild blue flax (Linum lewisii) 0.5 

Shrubs 

Wyoming big sagebrush (Artemisia tridentata wyomingensis) 0.5 

Antelope bitterbrush (Purshia tridentata) 1.0 

Total 15.0 

1 This seed mix may be modified based on site-specific conditions, the identification of additional useful 

species for rapid site stabilization, species success in past revegetation efforts, and seed availability and 

cost. 

2 PLS/acre = pounds of pure live seed per acre; alternative seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-5.2 Permanent Reclamation Species List for Greasewood-dominated Fans and Flats.1 

Species Seeding Rate 

(PLS/acre)2 

Grasses 

Western wheatgrass (Elymus smithii) 3.0 

Thickspike wheatgrass (Elymus dasystachyum) 2.0 

Alkali sacaton (Sporobolus airoides) 2.0 

Bottlebrush squirreltail (Sitanion hystrix) 2.0 

Forbs 

Scarlet globemallow (Sphaeralcea coccinea) 1.0 

Evening primrose (Oenothera sp.) 3.0 

Shrubs 

Black greasewood (Sarcobatus vermiculatus) 1.0 

Gardner saltbush (Atriplex gardneri) 1.0 

Total 15.0 

1 This seed mix may be modified based on site-specific conditions, the identification of additional useful 

species for rapid site stabilization, species success in past revegetation efforts, and seed availability and 

cost. 

2 PLS/acre = pounds of pure live seed per acre; alternative seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-5.3 Permanent Reclamation Species list for Mixed Desert Shrub Communities.1 

Species Seeding Rate 

(PLS/acre)2 

Grasses 

Western wheatgrass (Elymus smithii) 2.0 

Bluebunch wheatgrass (Elymus spicatum) 2.0 

Great basin wildrye (Elymus cinereus) 2.0 

Indian ricegrass (Oryzopsis hymenoides) 2.0 

Needle-and-thread (Stipa comata) 1.0 

Sandberg bluegrass (Poa sandbergii) 1.0 

Forbs 

Scarlet globemallow (Sphaeralcea coccinea) 1.0 

Common yarrow (Achillea millefolium) 1.0 

Wild blue flax (Linum lewisii) 1.0 

Northern sweetvetch (Hedysarum boreale) 1.0 

Shrubs 

Wyoming big sagebrush (Artemisia tridentata wyomingensis) 0.5 

Rubber rabbitbrush (Chrysothamnus nauseosus) 1.0 

Common winterfat (Krascheninnikovia lanata) 1.0 

Shadscale (Atriplex confertifolia) 2.0 

Total 18.5 

1 This seed mix may be modified based on site-specific conditions, the identification of additional useful 

species for rapid site stabilization, species success in past revegetation efforts, and seed availability and 

cost. 

2 PLS/acre = pounds of pure live seed per acre; alternative seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-5.4 Permanent Reclamation Species List for Badlands (Basin Exposed Rock and Soil) Communities.1 

Species Seeding Rate 

(PLS/acre)2 

Grasses 

Sheep fescue (Festuca ovina) 3.0 

Bottlebrush squirreltail (Sitanion hystrix) 3.0 

Alkali sacaton (Sporobolus airoides) 3.0 

Forbs 

Gooseberryleaf globemallow (Sphaeralcea grossulariaefolia) 1.0 

Northern sweetvetch (Hedysarum boreale) 2.0 

Evening primrose (Oenothera sp.) 1.0 

Shrubs 

Winterfat (Krascheninnikovia lanata) 1.0 

Gardner saltbush (Atriplex gardneri) 1.0 

Total 15.0 

1 This seed mix may be modified based on site-specific conditions, the identification of additional useful 

species for rapid site stabilization, species success in past revegetation efforts, and seed availability and 

cost. 

2 PLS/acre = pounds of pure live seed per acre; alternative seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-5.5 Permanent Reclamation Species List for Saltbush Fans and Flats Communities.1 

Species Seeding Rate 

(PLS/acre)2 

Grasses 

Sandberg bluegrass (Poa sandbergii) 1.0 

Western wheatgrass (Elymus smithii) 1.0 

Thickspike wheatgrass (Elymus dasystachyum) 1.0 

Alkaligrass (Puccinellia distans) 2.0 

Bottlebrush squirreltail (Sitanion hystrix) 1.0 

Alkali sacaton (Sporobolus airoides) 2.0 

Forbs 

Gooseberryleaf globemallow (Sphaeralcea grossulariaefolia) 1.0 

Northern sweetvetch (Hedysarum boreale) 2.0 

Evening primrose (Oenothera sp.) 1.0 

Shrubs 

Winterfat (Krascheninnikovia lanata) 1.0 

Gardner saltbush (Atriplex gardneri) 1.0 

Shadscale (Atriplex confertifolia) 1.0 

Black greasewood (Sarcobatus vermiculatus) 1.0 

Total 16.0 

1 This seed mix may be modified based on site-specific conditions, the identification of additional useful 

species for rapid site stabilization, species success in past revegetation efforts, and seed availability and 

cost. 

2 PLS/acre = pounds of pure live seed per acre; alternative seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-5.6 Permanent Reclamation Species List for Wetland/Riparian Communities.1 

Species Seeding Rate 

(PLS/acre)2 

Grasses/Grass-like 

Streambank wheatgrass (Elymus riparius) 1.0 

Nebraska sedge (Carex nebrascensis) 1.0 

Beaked sedge (Carex rostrata) 1.0 

Redtop (Agrostis stolonifera) 1.0 

Bluejoint reedgrass (Calamagrostis canadensis) 1.0 

Tufted hairgrass (Deschampsia caespitosa) 2.0 

Alkali bulrush (Scirpus maritimus) 2.0 

Cattail (Typha latifolia) 0.5 

Forbs 

Northern sweetvetch (Hedysarum boreale) 1.0 

Blue-leaf aster (Aster glaucodes) 1.0 

Golden banner (Thermopsis montanus) 1.0 

Red clover (Trifolium pratense) 1.0 

Shrubs/Trees3 

Golden currant (Ribes aureum) 1.0 

Red osier dogwood (Cornus stolonifera) 1.0 

Silver buffaloberry (Shepherdia argentea) 1.0 

Woods rose (Rosa woodsii) 1.0 

Narrowleaf cottonwood (Populus angustifolia) NA4 

Sandbar willow (Salix exigua) NA4 

Total 17.5 

1 This seed mix may be modified based on site-specific conditions, the identification of additional useful 

species for rapid site stabilization, species success in past revegetation efforts, and seed availability and 

cost. 

2 PLS/acre = pounds of pure live seed per acre; alternative seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans. 

3 Planting of shrubs and trees will be dependent on site-specific riparian objectives. 

4 Planted as containerized stock, sprigs, or poles. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-5.7 Permanent Reclamation Species List for Mixed Grass Prairie Communties.1 

Species Seeding Rate 

(PLS/acre)2 

Grasses 

Western wheatgrass (Elymus smithii) 2.0 

Thickspike wheatgrass (Elymus dasystachyum) 3.0 

Slender wheatgrass (Elymus trachycaulum) 2.0 

Indian ricegrass (Oryzopsis hymenoides) 2.0 

Bottlebrush squirreltail (Sitanion hystrix) 1.0 

Needle-and-thread (Stipa comata) 1.0 

Green needlegrass (Stipa viridula) 2.0 

Forbs 

Wild blue flax (Linum lewisii) 2.0 

Scarlet globemallow (Sphaeralcea coccinea) 2.0 

Total 17.0 

1 This seed mix may be modified based on site-specific conditions, the identification of additional useful 

species for rapid site stabilization, species success in past revegetation efforts, and seed availability and 

cost. 

2 PLS/acre = pounds of pure live seed per acre; alternative seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-5.8 Permanent Reclamation Species List for Playas and Alkaline Areas.1 

Species Seeding Rate 

(PLS/acre)2 

Grasses 

Muhly (Muhlenbergia spp.) 2.0 

Alkaligrass (Puccinellia distans) 3.0 

Alkali sacaton (Sporobolus airoides) 2.0 

Western wheatgrass (Elymus smithii) 2.0 

Forbs 

Gooseberryleaf globemallow (Sphaeralcea grossulariaefolia) 1.0 

Strawberry clover (Trifolium fragiferum) 2.0 

Northern sweetvetch (Hedysarum boreale) 2.0 

Shrubs 

Gardner saltbush (Atriplex gardneri) 1.0 

Black greasewood (Sarcobatus vermiculatus) 1.0 

Total 16.0 

1 This seed mix may be modified based on site-specific conditions, the identification of additional useful 

species for rapid site stabilization, species success in past revegetation efforts, and seed availability and 

cost. 

2 PLS/acre = pounds of pure live seed per acre; alternative seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans. 
Record of Decision, Continental Divide/Wamsutter II 

Table A-5.9 Permanent Reclamation Species List for Stablilized Sand Dune Communities.1 

Species Seeding Rate 

(PLS/acre)2 

Grasses 

Prairie sandreed (Calamovilfa longifolia) 3.0 

Bluebunch wheatgrass (Elymus spicatum) 1.0 

Sand dropseed (Sporobolus cryptandrus) 1.0 

Indian ricegrass (Oryzopsis hymenoides) 2.0 

Needle-and-thread (Stipa comata) 1.0 

Basin wildrye (Elymus cinerus) 1.0 

Forbs 

Gooseberryleaf globemallow (Sphaeralcea grossulariaefolia) 1.0 

Desert Indian paintbrush (Castilleja chromosa) 1.0 

Northern sweetvetch (Hedysarum boreale) 1.0 

Wild blue flax (Linum lewisii) 1.0 

Shrubs 

Wyoming big sagebrush (Artemisia tridentata wyomingensis) 1.0 

Rubber rabbitbrush (Chrysothamnus nauseosus) 1.0 

Spiny hopsage (Grayia spinosa) 1.0 

Douglas rabbitbrush (Chrysothamnus vicidiflorus) 1.0 

Total 17.0 

1 This seed mix may be modified based on site-specific conditions, the identification of additional useful 

species for rapid site stabilization, species success in past revegetation efforts, and seed availability and 

cost. 

2 PLS/acre = pounds of pure live seed per acre; alternative seeding rates may be applied in some areas as 

deemed appropriate by the BLM and specified in approved Surface Use Plans. Operators will consult with 

the BLM and acquire BLM approval prior to the use of introduced species. Seed mixtures applied during 

revegetation will be designed in coordination with the BLM during the APD and ROW application 

approval processes. 
Record of Decision, Continental Divide/Wamsutter II 

Final determination of the appropriate seed mixture will be developed on a site-specific basis in coordination 

with the BLM at the time of field review (APD and ROW application review). Selected seed species may be 

inoculated with soil microorganisms to facilitate germination and growth. Soil and watershed protection will 

be emphasized when reclaiming disturbed areas. Areas not exhibiting successful revegetation, as determined 

during monitoring (see Section A_6.0) will be reseeded and/or improved with soil amendments as deemed 

necessary by the BLM until adequate vegetative cover is established. 

Seeding generally will be done in the fall between September 16 and freeze-up; however, some areas may be 

seeded in the early spring between spring thaw and April 15. Wherever possible, seed planting will be done 

along the contour using a rangeland drill equipped with an agitator and depth bands to mix seed and ensure 

proper seeding depths. Seeds will be planted 0.25 to 1.50 inches deep; most seeds will be planted 0.25 inches 

deep. When drill seeding is not practical due to steep slopes or wet soil conditions, broadcast seeding will be 

employed, seeding rates will be doubled, and the area will be raked or chained to cover seeds. To facilitate 

seed establishment, broadcast seeding may be used for shrub and forb species, utilizing either hand or 

specialized broadcast seeders; fluffy seeds (e.g., winterfat) may be broadcast simultaneously with drill seeds. 

In addition, at sites where rapid shrub and/or tree establishment is desirable, bare-rooted or containerized stock 

may be hand-planted. Depending on site-specific circumstances, broadcast seeding may be accomplished 

following mulch and crimping operations. 

A_5.4.2 Mulching 

Immediately following seeding, selected areas with a high erosion potential, including steeply sloped areas 

along roads and/or pipelines, will be uniformly mulched (75% minimum cover) with native grass, hays, small 

grain straw, wood fiber, and/or live mulch, at a rate of approximately 1.0-2.0 tons/acre. Cotton, jute, or 

synthetic netting also may be applied at some sites. Only certified weed-free mulches will be used, thereby 

minimizing the potential for noxious weed introduction. Mulch will be crimped in place, as necessary, using a 

serrated disc crimper or similar implement. Mulch protects the soil from wind and water erosion, raindrop 

impact, and surface runoff and holds seeds in place. On slopes of greater than 30% or exceeding the operating 

limits of the equipment, sites containing 35% surface rock content, sandy soil areas, or other unstable areas, 

hydromulch, biodegradable erosion control netting, rock mulch, or matting attached firmly to the soil surface 

will be applied, as necessary. 

A_5.5 SEDIMENTATION AND EROSION CONTROL DEVICES 

Erosion and sediment control measures and structures will be installed, as appropriate, on all reclaimed 

areas. The type of control measure used will depend on slope gradient and the susceptibility of disturbed soils 

to wind and water erosion. Runoff control along linear disturbances such as roads and pipelines will be 

accomplished using standard measures, including but not limited to waterbars, silt fences, energy dissipators, 

mulches, and cross ditches. Waterbars will be installed in accordance with BLM specifications and will 

discharge water into undisturbed vegetation. Waterbars generally will be 12_18inches deep. When used, silt 

fences will be placed at the base of all steep fill slopes and will be installed using manufacturer's directions 

and BLM regulations to prevent overland flow from washing beneath or around the structures. Instream 

protection devices (e.g., drop structures) also may be required to prevent erosion in drainages crossed by 

pipelines. Information on the techniques to be implemented, as determined based on site-specific conditions 

and associated BLM interdisciplinary team requirements, will be included in APDs, ROW applications, and/or 

Sundry Notice Surface Use Plans, Plans of Development, and/or ERRPs. 

Additional runoff and erosion control along ROWs will be accomplished by implementing standard cross drain, 

culvert, road ditch, and turnout design, as well as timely stabilization and revegetation of exposed areas. 

Culvert entrances and exits will be riprapped or protected with energy dissipators or other scour_reducing 

techniques, as needed and where appropriate. Water discharged from culverts, cross drains, road ditches, and 

turnouts will be directed appropriately either into undisturbed vegetation or natural drainages. Erosion and 

sedimentation control measures and structures, as approved by the BLM, will be installed across all 

cut-and-fill slopes within 100 ft of drainage channels. All runoff and erosion control structures will be 
Record of Decision, Continental Divide/Wamsutter II 

inspected by Operators annually and after major runoff events and will be maintained (e.g., cleaned out) 

throughout the LOP. 
Record of Decision, Continental Divide/Wamsutter II 

A_6.0 RECLAMATION SUCCESS MONITORING 

Reclamation success will be based on the objectives specified in this plan, and monitoring will occur annually 

or at shorter intervals until reclamation efforts are deemed successful by the BLM. Monitoring activities will 

evaluate the condition of reclamation efforts, determine the prognosis for reclamation success, and determine 

the need for remediation. The actual monitoring procedures for quantitative and qualitative evaluations of 

reclamation success will be implemented as specified in Surface Use Plans or Plans of Development and 

approved by the BLM. Standard revegetation success criteria involve the attainment of 50% of predisturbance 

vegetation leaf or ground cover in 3 years and 80% of predisturbance vegetation leaf or ground cover in 5 

years; however, alternative revegetation success criteria (e.g., time frames, percent cover values) may be 

developed on a site-specific basis as established by BLM on-site interdisciplinary teams (IDTs) (BLM 1997). 

The monitoring program presented herein is designed to provide an approach to reclamation monitoring on the 

CD/WIIPA and includes evaluations which will assist in making future land management decisions in the area. 

More specific objectives include: 

• delineation of BLM and Operator monitoring responsibilities, 

• identification of reclamation success criteria, and 

• specification of monitoring protocols. 

Both temporary and permanent reclamation success will be monitored. Temporary reclamation monitoring will 

include visual observations of soil stability, effectiveness of erosion control practices, and qualitative 

evaluations of vegetation establishment and assessments of weed invasion. Operators will be responsible for 

weed control on surface disturbance and reclamation sites. Control measures will adhere to those specified by 

the BLM. If chemical weed controls are deemed to be necessary by the BLM, chemicals will be used only in 

the season or growth stage during which they are most effective. In addition, they will be applied only by 

certified personnel using approved precautions, application methods, and rates in compliance with all 

applicable federal, state, and local regulations. Use of herbicides will be avoided near open waters or during 

extremely windy conditions. 

Permanent reclamation will be visually monitored for soil stability, particularly near wetland/riparian areas, 

open waters, or ephemeral stream channels. Mulch effectiveness and other erosion control devices will be 

assessed, and qualitative evaluations of vegetation establishment and success will be made. Quantitative 

measurements for vegetation success as measured by percent leaf and ground cover, production, shrub 

establishment, and/or measures of diversity will be implemented as specified by the BLM. If reclamation 

monitoring reveals that soil stability, weed abundance, or vegetation establishment/productivity do not meet 

required standards, additional treatments will be promptly undertaken by Operators in cooperation with the 

BLM. Continued efforts will be required until satisfactory cover and productivity are achieved and the site is 

adequately stabilized. Additional treatments could include, but are not limited to, installation of additional 

erosion control devices, fencing, herbicide or fertilizer application, reseeding, or remulching. 

A_6.1 MONITORING RESPONSIBILITY 

Reclamation monitoring will be the responsibility of the BLM and the Operators. Monitoring will be 

accomplished through joint coordinated monitoring efforts. Further detail on BLM/Operator monitoring 

responsibilities will be provided in site-specific Surface Use Plans and/or ERRPs. 

Operators will submit an initial monitoring plan, including monitoring locations, time frames, and 

methodologies, for each proposed disturbance in Surface Use Plans or ERRPs, and plans will be approved by 

the BLM prior to disturbance. The initial monitoring plan will constitute the Implementation Phase of 

monitoring and will follow the guidelines presented in Addendum A-A (FORM I) of this appendix. Monitoring 

will be conducted by a qualified Operator representative (in coordination with the BLM) following initial 

rehabilitation work. Monitoring areas will be re_examined at the end of the first growing season. Results will 

be documented in a report (see AddendumA_B, FORMII) to the BLM. Problem areas identified during 

monitoring will receive follow-up rehabilitation/erosion control measures. 
Record of Decision, Continental Divide/Wamsutter II 

During the second growing season, the BLM will revisit established monitoring sites. Original methodologies 

will be repeated and the status of reclamation efforts will be assessed using the guidelines established in 

FORMII (AddendumA_B). Results will be documented and a report prepared. Monitoring results will be 

provided to each Operator to show progress and call attention to additional stabilization/reclamation needs. 

Additional monitoring sites will be established by the BLM (in coordination with the Operator) for long-term 

monitoring on significant problem areas not covered by initial efforts. 

Follow-up monitoring using the established sites and methodologies will be conducted annually or as 

necessary by the BLM until reclamation goals are attained (see SectionA_6.3). Once reclamation goals are 

attained, the monitoring site may be abandoned; however, reference points will remain to allow for potential 

future evaluation. It is expected that most monitoring sites will reveal adequate site reclamation within 

approximately 5 years, and therefore monitoring activities usually will be discontinued after 5 years. This will 

allow personnel to concentrate on monitoring installation and evaluation on long-term problem sites. Operators 

will be advised of reclamation status through joint review of monitoring sites. Annual reports will continue, as 

will direction for additional remedial reclamation efforts, if necessary. 

Generally, reclamation success will be based on site-specific potential. Revegetation objectives and success 

criteria (FORM I) will be tailored to site potential and agreed on by both Operators and the BLM. When the 

site has reached long-term stabilization and the composition of desired forage is consistent with the above 

objectives and criteria, the monitoring site will be abandoned. Monitoring data will be compiled by the BLM 

to provide future guidance for successful reclamation planning. 

A_6.2 MONITORING PROTOCOL 

The forms presented in Addenda A and B serve as guidelines for the collection of site_specific information, 

identification of revegetation success standards, documentation of treatments, and a record for evaluation. 

The monitoring plan contained in Surface Use Plans and/or ERRPs will cover the parameters outlined on the 

Revegetation and Erosion Monitoring/ Background Data form (AddendumA_A, FORMI) and will identify the 

Operators that will collect these data. Background data will be collected following initial reclamation work. 

A report containing this information will be prepared prior to annual reviews. Data collection will be 

accomplished using point sampling transects on adjacent undisturbed areas of the same vegetation type. 

These transects will be established with permanent stakes on locations described in Surface Use Plans and/or 

ERRPs. 

The Revegetation and Erosion Monitoring Evaluation form (AddendumA_B, FORMII) will be used for annual 

monitoring conducted by the Operators during the first growing season and by the BLM in subsequent years 

and until monitoring ceases. Data collection will take place during the seed-ripe stage of plant development, 

and evaluation reports containing this information will be prepared for annual reviews. 

A_6.3 GENERAL SUCCESS CRITERIA 

The following general success criteria will be used to determine the attainment of adequate site rehabilitation 

and whether bond liability should be released; alternative criteria (e.g., time frames, percent cover values) 

may be developed site-specifically based on BLM IDT on-site determinations. Additional success criteria 

(e.g., productivity, diversity, shrub establishment) will be included, as necessary, in site_specific Surface Use 

Plans, Plans of Development, or ERRPs and will be approved by the BLM prior to site disturbance. Interim 

reclamation criteria (see Section A-6.3.2) generally will be applied for determining the disturbance limit 

thresholds identified for project development Alternatives A and B (see EIS Sections 2.2 and 2.3). 
Record of Decision, Continental Divide/Wamsutter II 

A_6.3.1 General Criteria 

• There will be no contaminated materials remaining at or near the surface, and all buried undesirable 

materials will be physically isolated for long-term stabilization. 

• The subsurface will be stabilized, holes will be plugged, and subsurface integrity will be ensured. No 

indications of open or unplugged holes, subsidence, slumping, and/or significant downward movement 

of surface soil materials will be visible. 

• The reclaimed area will be stable and will not exhibit large rills or gullies (e.g., 3 inches wide/deep), 

perceptible soil movement or head cutting in drainage, and/or slope instability on or adjacent to the 

reclaimed area. 

• The soil surface will be stable and have adequate surface roughness to reduce runoff and capture 

rainfall and snow melt. 

• Vegetative canopy cover, production, and species diversity will approximate the surrounding 

undisturbed areas. The vegetation will stabilize the site and support postdisturbance land uses, 

provide for natural plant community succession and development, and be capable of renewing itself. 

There will be evidence of successful on_site establishment of species included in the planting mixture 

or other desirable species and/or evidence of vegetation reproduction, either spreading by rhizomatous 

species or seed production. 

• The reclaimed landscape will have characteristics that approximate the visual quality of the adjacent 

area with regard to location, scale (e.g., line, form, and texture), shape, color, and orientation of 

major landscape features and will meet the needs of the postdisturbance land uses. 

• During and following reclamation activities, Operators will monitor and protect the reclaimed 

landscape to help ensure reclamation success until the liability and bond are released. Each of the 

previous six standards will be maintained until it can be determined that the reclamation effort was 

successful. 

• With the exception of active work areas, all disturbed highly erosive or sensitive areas to be left bare 

or unreclaimed for more than 3 months will have a protective cover of suitable material in the form of 

mulch, matting, or vegetative growth. All other disturbed areas will have an effective protective 

cover within 1 year. 

A_6.3.2 Interim Reclamation Criteria (Years Two - Five) 

• Seeding density. The density and abundance of desirable species will be at least three to four 

seedlings/ft of drill row (if drilled) or transect (ifbroadcast) for most areas. In some sparsely vegetated 

areas such as badlands and sodic and saline/alkaline bottomlands, this standard may be reduced to 

one to two seedlings/ft to be commensurate with the naturally low vegetative cover, unless significant 

surface erosion is anticipated. 

• Percent cover. Total vegetative (foliar) or ground cover will be 30-50% of predisturbance cover as 

measured along the reference transect for establishing baseline conditions. 

• Species diversity. At least 20% of the species contained in the seed mix and/or present on adjacent 

areas will be present, and no single species will account for more than 50% of the total vegetative 

cover unless its dominance is higher than 50% on adjacent undisturbed areas. 

• Undesirable species. Weeds or other undesirable species will comprise no more than 10% of the total 

vegetative cover. All noxious weeds will be controlled. 
Record of Decision, Continental Divide/Wamsutter II 

A_6.3.3 Final Reclamation Criteria (Years Three - Ten) 

• Percent cover. Total vegetative (foliar) or ground cover will be 50_80% of predisturbance cover as 

measured along the reference transect for establishing baseline conditions. 

• Dominant species. Ninety percent of therevegetation will consist of species included in the seed 

mix and/or occurring in the surrounding natural vegetation or as will be deemed desirable by the BLM 

as measured along the reference transect for establishing baseline conditions. 

• Erosion condition/soil surface factor. Erosion condition of reclaimed areas will be equal to or in better 

condition than that measured for the reference transect for establishing baseline conditions. 
Record of Decision, Continental Divide/Wamsutter II 

A_7.0 REFERENCES

Bureau of Land Management.1985. Manual 9113: Roads. Engineering, Rel. 9-247. U.S.Department of the 

Interior, Bureau of Land Management. 

. 1987. Draft Resource Management Plan/environmental impact statement for the Medicine Bow-Divide 

Resource Area, Rawlins District, Wyoming, BLM-WY-ES-87-008-4410. U.S. Department of the Interior, 

Bureau of Land Management. 500pp. 

. 1988. Final Resource Management Plan/environmental impact statement for the Medicine 

Bow-Divide (Great Divide) Resource Area, Rawlins District, Wyoming, BLM_WY-ES-88-015-4410. U.S. 

Department of the Interior, Bureau of Land Management. 249pp. 

. 1990a. Wyoming policy on reclamation. U.S. Department of the Interior, Bureau of Land

Management, Rawlins District Office, Rawlins, Wyoming. February 2, 1990.

. 1990b. Great Divide Resource Area Record of Decision and approved Resource Management Plan, 

BLM_WY-PT-91-010-4410. U.S. Department of the Interior, Bureau of Land Management, Great Divide 

Resource Area, Rawlins District, Rawlins, Wyoming. 74pp. 

. 1991. Wyoming supplement to the Bureau 9113 Manual. U.S. Department of the Interior, Bureau of 

Land Management, Wyoming State Office, Cheyenne, Wyoming. 16 pp. 

. 1992. Green River Resource Area Management Plan and draft environmental impact statement. U.S. 

Department of the Interior, Bureau of Land Management, Rock Springs District, Rock Springs, Wyoming, 

BLM-WY-ES-92-019-4410. 901 pp. 

. 1996. Green River Resource Area Management Plan and final environmental impact statement. U.S. 

Department of Interior, Bureau of Land Management, Rock Springs District, Rock Springs, Wyoming, 

BLM/WY/PL-96/012+1610. 1,009 pp. 

. 1997. Rock Springs District reclamation monitoring report 1997. Prepared by J. MacDonald, U.S. 

Department of the Interior, Bureau of Land Management, Rock Springs District, Rock Springs, Wyoming. 

6 pp. + attach. 
Record of Decision, Continental Divide/Wamsutter II 

ADDENDUM A-A: 

FORM I

REVEGETATION AND EROSION

MONITORING/BACKGROUND DATA
Record of Decision, Continental Divide/Wamsutter II 

FORM I Page 1 of 3 

Revegetation and Erosion Monitoring/Background Data 

A. Revegetation Project Name: 

Company: Telephone No: ( ) 

Data Collected By: (Company/Agency Representative) 

Monitoring Site Number: 

B. Legal Location C. Slope % D. Key Species in Reference Vegetation 

Twp. Aspect - %

Rng. Elevation - %

Sec. (include construc- - %

Sub. tion map with - %

transect site - % 

marked) - % 

E. Soil: Texture - Rock Content Texture - Rock Content 

0-6" - % 12-18" - % 

6-12" - % 18-24" - % 

F. Disturbance Description: Date 

G. Revegetation Objective(s): 

H. Criteria for Determining Success: 

I. Reclamation Treatment Record - Data/season applied: 

1. Topsoiling: 

2. Erosion Control (type and method of installation): 
Record of Decision, Continental Divide/Wamsutter II 

Page 2 of 3 FORM I, Continued 

3. Soil Amendments (type, amount, and method of application): 

4. Seed Mix (lbs pure live seed/acre by species): 

5. Mulch (type and method of application): 

6. Mechanical treatments (type and rationale): 

7. Remarks: 

J. Attach a 35 mm photograph of the monitoring transect and reference plot (if applicable) with dates. 

Photograph sites should be clearly marked on a reference map. 
Record of Decision, Continental Divide/Wamsutter II 

Page 3 of 3 

Items requiring further explanation: 

B. A 1:24,000 topographic map can be used to attain this information. This report will include the 

monitoring site transect location on the detailed construction drawings contained in the Surface Use 

Plans or ERRPs. 

D. Reference vegetation serves as a standard of comparison to assess potential species for revegetation 

and success. The nature of comparisons with reference vegetation will depend on revegetation 

objectives. A reference plot location will be established on the ground and marked on Surface Use 

Plan and/or ERRP maps. A 35 mm photo of the plot will accompany the form. 

G. Soil stability, productivity restoration, and wildlife habitat enhancement are general examples of 

objectives. More specific objectives may be provided. 

H. Examples of Criteria for Success could include 60% ground cover for erosion control, soil surface 

factors of less than 45 (see AddendumA_B), specific plant species density and/or diversity 

requirements for wildlife habitat, and specific production for livestock grazing. Criteria must be 

defined and measurable. 

I. The reclamation treatment record will document what was actually done on the ground, not 

necessarily what is outlined in Surface Use Plans and/or ERRPs. Short explanations of when 

topsoiling was completed, the erosion control methods used, fertilizer types and rates, seed mixes and 

seeding rates, mulching methods, etc., will be described in this section. Any additional erosion 

control measures should be included under remarks. 

J. A photo record of the transect line and any additional erosion control measures will be included. Each 

transect will have one photo showing the general view along the transect and one photo showing 

transect detail of vegetation/soil surface. Date, transect, and direction of view will be labeled on 

each photo. Permanent photomonitoring points also will be established at appropriate vantage 

locations of drill sites, pipeline and access road ROWs, and ancillary facility sites. Each 

photomonitoring point will be permanently marked with rebar and identified on a topographic map of 

the area. The location of each point will be described in detail to assist in relocation. Photos will be 

taken at each photomonitoring point prior to initiation of construction. Photos, framing the same 

scene as previously taken, will be taken at each formal site visit until reclamation standards have 

been met. 
Record of Decision, Continental Divide/Wamsutter II 

ADDENDUM A-B: 

FORMII

REVEGETATION AND EROSION

MONITORING EVALUATION
Record of Decision, Continental Divide/Wamsutter II 

FORM II Page 1 of 4 

Revegetation and Erosion Monitoring Evaluation 

A. Revegetation Project Name: 

Company: Telephone No: ( ) 

Data Collected By: (Company/Agency Representative) 

Monitoring Site Number: 

B. Revegetation Evaluation:

 Relative 

1. Percent Cover 2. Dominant Species - Percent

 % Plant -

% Litter -

% Rock -

% Bare Ground -

% Water -

100 % Total -

-

-

-

3. Seedling Density & Abundance 

: Average plants per linear ft (drill row/transect) 

: Rating 

4. Grazing Impact (Utilization) 

: Utilization 

: Rating 

5. Weed Investigation: 

6. Erosion Evaluation (see the attached table): 

7. Other Comments: 
EROSION EVALUATION: Evaluate conditions 50 ft on either side of transect line. Assign a numerical rating for each category. 

(See page 4 of 4 for explanation) 

S U R F A C E 

LITTER 

SURFACE 

ROCK 

MOVEMENT 

PEDESTALLING 

FLOW

PATTERNS

RILLS 

GULLIES 

SOIL

MOVEMENT

No movement, or if present,

less than 2% of the litter has 

been translocated and 

redeposited against obstacles. 

0 or 3 

No movement, or if present,

less than 2% of the surface 

rock fragments have been 

translocated and/or

redeposited against obstacles

and show an even distribution 

on the landscape. 

0 or 2 

Pedestals are mostly less than Pedestals are mostly between Pedestals are mostly between Pedestals are mostly between Pedestals are mostly over 

0.1inch (2.5 mm) high and/or

less frequent than 2 pedestals per 100 ft 2. 

0.1 and 0.3 inch (2.5 to

8.0mm) high and/or have a

frequency of 2 to 5 pedestals per 100 ft 2. 

0.3 and 0.6 inch (8.0 to

15.0mm) high and/or have a

frequency of 5 to 7 pedestals per 100 ft 2. 

0.6 and 1.0 inch (15.0 to

25.0mm) high and/or have a

frequency of 1 to 10 pedestals per 100 ft 2. 

1.0inch (25.0 mm) high and/or have a frequency of

over 10 pedestals per 100ft2. 

0 or 3 6 9 12 14 

If present, less than 2% of the

surface areas shows evidence 

of recent translocation and 

deposition of soil and litter. 

0 or 3 

Rills, if present, are mostly less

than 0.5 inch (13.0 mm) deep,

and generally at infrequent intervals over 10 ft. 

0 or 3 

No gullies, or if present, less

than 2% of the channel bed 

and walls show active erosion 

(are not vegetated); gullies

make up less than 2% of the 

total area. 

0 or 3 

Depth of recent deposits

around obstacles or in 

microterraces, and/or depth of

truncated areas is between 0 

and 0.1 inch (9.0to 2.5 mm) 

0 or 3 

Between 2 and 10% of the 

litter has been translocated 

and redeposited against obstacles. 

6 

Between 2 and 10% of the 

surface rock fragments have

been translocated/redeposited

against obstacles and have

begun to show localized concentration. 

5 

Between 2 and 10% of the 

surface area shows evidence 

of recent translocation and 

deposition of soil and litter. 

6 

Rills are mostly 0.5 to 1.0 inch

(13.0 to 25.0 mm) deep and generally at infrequent

intervals over 10 ft. 

6 

Between 2 and 5% of the 

channel bed and walls show 

active erosion (are not

vegetated), or gullies make up

between 2 and 5% of the total 

area. 

6 

Depth or recent deposits

around obstacles or in 

microterraces, and/or depth of

truncated areas is between 0.1 

and 0.2 inch (2.5to 5.0 mm). 

5 

Between 10 and 25% of the 

litter has been translocated 

and redeposited against obstacles. 

8 

Between 10 and 25% of the 

surface rock fragments have been translocated, 

redeposited against obstacles, and show localized 

concentration. 

8 

Between 10 and 25% percent

of the surface area shows 

evidence of recent 

translocation and deposition of soil and litter. 

9 

Rills are mostly 1.0 to 1.5inches (25.0 to 38.0 mm)

deep and generally at 10-ft intervals. 

9 

Between 5 and 10% of the 

channel bed and walls shows 

active erosion (are not

vegetated), or gullies make

up between 5 and 10% of the 

total area. 

9 

Depth of recent deposits

around obstacles or in 

microterraces, and/or depth

of truncated areas is between 

0.2 and 0.4 inch (5.0 to

10.0mm). 

8 

Between 25 and 50% of the 

litter has been translocated 

and redeposited against obstacles. 

11 

Between 25 and 50% of the 

surface rock fragments have

been translocated, redeposited

against obstacles, and show

localized concentration. 

11 

Between 25 and 50% of the 

surface area shows evidence 

of recent translocation and 

deposition of soil and litter. 

12 

Rills are mostly 1.5 to 3.0inches (38.0 to 76.0 mm)

deep and at intervals of 5 to 10ft. 

12 

Between 10 and 50% of the 

channel bed and walls show 

active erosion (are not

vegetated), or gullies make up

between 10 and 50% of the 

total area. 

12 

Depth of recent deposits

around obstacles or in 

microterraces, and/or depth of

truncated areas is between 0.4 

and 0.8 inch (10.0 to 20.0 cm). 

11 

More than 50% of the litter 

has been translocated and 

redeposited against obstacles. 

14 

More than 50% of the 

surface rock fragments have been translocated, 

redeposited against obstacles,

and show extreme localized 

concentration. 

14 

Over 50% of the surface 

area shows evidence of 

recent translocation and 

deposition of soil and litter. 

15 

Rills are mostly 3.0 to 6.0inches (76.0 to 152.0mm)

deep and at intervals of less than 5 ft. 

14 

Over 50% of the channel bed 

and walls show active erosion 

(are not vegetated) along

their length, or gullies make

up over 50% of the total area. 

15 

Depth of recent deposits

around obstacles or in 

microterraces, and/or depth

of truncated areas is over 

0.8inch (20.0 cm). 

14 

Erosion Condition Class: Soil Surface Factor: 
1-40 

Record of Decision, Continental Divide/Wamsutter II 

Page 3 of 4

Items requiring further explanation: 

B.1 Percent cover is determined by examination of points along a 100-ft transect. Documentation consists 

of recording the total number of hits for plant, litter, rock, and bare ground. Each point noted 

corresponds to each 1-ft increment along the 100-ft transect. Data summarized from this transect will 

be recorded here. 

B.2 Dominant plant species along the transect are listed and their relative percent cover determined based 

on the number of hits for each species. 

B.3 Seedling Density and Relative Abundance is the total number of plants occurring within plots at the 

20, 40, 60, and 80-ft mark along the transect. At these points, perennial seedlings per linear ft or drill 

row (or in the case of broadcast seedling, per linear ft of transect) are recorded and averaged. Ratings 

are based on the following evaluation system: 

PLANTS/LINEAR FT RATING 

8+ 

5-7 

3-4 

0-2 

Excellent 

Good 

Fair 

Poor 

B.4 The grazing impact is assessed as an ocular estimate of the percent utilization along the transect (at 

10-ft intervals). Utilization is based on the removal of seeded species (current year's growth). The 

amount of utilization is expressed as the percent of aboveground biomass grazed. The following 

describes the rating for various utilization ranges: 

PERCENT RATING 

UTILIZATION RANGE 

Light 

41-60 Moderate 

61-100 Heavy 

GENERAL DESCRIPTION

The revegetation may be topped, skimmed, or grazed in 

patches, 50 to 80% of the number of current seed stalks 

remain intact. Most young plants are undamaged. There is 

little or no use of nonpalatable species. 

The revegetation appears entirely covered (grazed) as 

uniformly as natural features and facilities will allow. 

Fifteen to 25% of the number of current seed stalks remain 

intact. No more than 10% of the nonpalatable species are 

utilized. 

The revegetation has the appearance of complete and 

repeated grazing use. Less than 10% of the current seed 

stalks are remaining. The remaining stubble of preferred 

grasses may be grazed to the soil surface. 
Record of Decision, Continental Divide/Wamsutter II 

Page 4 of 4 

C. The Erosion Condition Class/Soil Surface Factor method numerically rates soil movement, surface 

litter, surface rock, pedestalling, flow patterns, and rill/gully formation and translates these physical 

factors into an evaluation of the vegetation and erosion stability of an area. Results are an expression 

of current erosion activity and can be used to reflect revegetation success as a function of site 

stability. 

Identify the numerical factor that most nearly describes the current erosion condition by circling the 

factors. Evaluate each erosional feature if water erosion is the most prevalent type of erosion. Omit 

surface rock if not present. If wind erosion is mostly prevalent, do not include rill and gully features in 

the computation. The following identifies the Erosion Condition Class based on the Soil Surface 

Factor: 

EROSION SOIL SURFACE FACTOR 

CONDITION CLASS (Range) 

Stable 1_20 

Slight 21_40 

Moderate 41_60 

Critical 61_80 

Severe 81_100 
APPENDIX B: 

TRANSPORTATION PLAN 
DRAFT

TRANSPORTATION PLAN

CONTINENTAL DIVIDE/WAMSUTTER II

NATURAL GAS PROJECT 

Prepared for 

U.S. Bureau of Land Management

Rawlins Field Office

Rawlins, Wyoming

and 

Rock Springs Field Office

Rock Springs, Wyoming

By 

Uintah Engineering and Land Surveying

Vernal, Utah

and 

TRC Mariah Associates Inc.

Laramie, Wyoming

MAI Project 1295

April 1999
Record of Decision, Continental Divide/Wamsutter II 

ABBREVIATIONS AND ACRONYMS 

APD Application for Permit to Drill 

BLM Bureau of Land Management 

CD/WIIPA Continental Divide/Wamsutter II Project Area 

EIS Environmental impact statement 

GIS Geographic Information System 

GRBAC Green River Basin Advisory Committee 

I-80 Interstate 80 

NEPA National Environmental Policy Act 

Network The network of proposed and existing collector and local roads used within the 

CD/WIIPA 

Operators Amoco Production Company, other oil and gas companies, and their subcontractors 

working on the CD/WIIPA 

RFO Rawlins Field Office 

ROW Right-of-way 

RSFO Rock Springs Field Office 

TP Transportation Plan 

TPA Transportation planning area 

TPC Transportation Planning Committee 

TPTSD Transportation Planning Technical Support Document 

Truck or heavy truck All trucks used for hauling equipment or freight or trucks mounted with 

special equipment with axle weights of under 32,000 lbs and gross weights of 

under 80,000 lbs. This could also include trucks with overweight or overwidth 

permits 
Record of Decision, Continental Divide/Wamsutter II 

B-1.0 INTRODUCTION 

B-1.1 OBJECTIVES 

This Transportation Plan (TP) was prepared to supplement a proposal by oil and gas companies (Operators) to 

drill new wells in the Continental Divide/Wamsutter II Project Area (CD/WIIPA) (Map B-1.1), as described in 

the Continental Divide/Wamsutter II Natural Gas Project environmental impact statement (EIS). Additionally, 

a TP required for the Greater Wamsutter II Project (Bureau of Land Management [BLM] 1995) and this TP, as 

expanded herein based on the revised development proposal, serves as the TP for the Greater Wamsutter II 

Project. This document provides an assessment of future road development and use in and around the 

CD/WIIPA and provides a basis for future oil- and gas_related exploration and production transportation 

planning within the area. Potential impacts to the existing transportation system are described in the EIS. 

Additional information on road development requirements for this project is provided in the Transportation 

Planning Technical Support Document (TPTSD) (BLM 1999), which is available for review at the BLM 

Rawlins Field Office (RFO) and Rock Springs Field Office (RSFO). Annual road planning, development, 

maintenance, and other issues and concerns are provided in the TPTSD, as is detailed information (including 

maps) on existing roads/routes and natural obstacles. The TPTSD and associated maps will be updated 

annually or as necessary as specified in Chapter B-4.0. 

The transportation planning area (TPA) for this project includes the CD/WIIPA plus adjacent areas that 

include roads which may be used to access the CD/WIIPA (Map B-1.2). The TPA includes Interstate 80 (I-80) 

and its on and off ramps from Rawlins west to exit142; U.S. Highway 287 north of Rawlins to County Road 

4-63; State Highway 789 south from I-80; and several county, BLM, and undeveloped roads/routes on and 

adjacent to the area. (More detailed maps of the TPA are available for review at the BLM RFO and RSFO. 

The use of existing roads and proposed road corridors for local and collector roads is described, and this 

document, the TPTSD, and applicable transportation codes and standards will be used in the localized 

planning efforts for each new well location and associated access. Annual operational updates to the TPTSD 

will be made, as necessary, to detail specific localized transportation networks. All new or upgraded roads in 

the TPA will conform to the general provisions of this planning document. 

The objectives and content of this TP are listed below. 

• Public comment opportunities and the issues/concerns raised are identified. 

• Existing roads in the TPA which are preliminarily identified as potential project-required collector and 

local roads are identified on maps, and resource, two-track, and other unimproved roads are also 

briefly discussed. 

• The annual transportation planning/operational update process for the TPTSD is described, and this 

description includes scheduling, roles and responsibilities, and opportunities for public input. 

B-1.2 SCOPE 

The scope of this plan includes a brief description/presentation of the existing road network (see Map B-1.2) 

and the identification of proposed high traffic volume roads/corridors. Relevant requirements for road 
Record of Decision, Continental Divide/Wamsutter II 

construction or reconstruction and the development of agreements for use, rights_of_way (ROWs), and 

maintenance are identified and outlined in the TPTSD. 

This plan also applies to the transportation of gas, condensate, or water via pipelines and electric power 

transmission (power lines) within the CD/WIIPA. Pipelines and power lines generally will be located adjacent 

to roads to reduce new surface disturbance. In some instances, parallelling roads and lines may lead to 

increased environmental impacts, in which case pipelines and power lines may be located along alternative 

routes, and these alternative routes will be evaluated and sited to minimize environmental impacts. Map 2.2 

of the EIS shows the location of major pipeline routes on the CD/WIIPA. Further detail on pipelines is 

provided in Section 2.6.7 of the EIS. 

Some existing roads to and within the CD/WIIPA are under the jurisdiction of the governmental agencies (e.g., 

BLM, Sweetwater County, Carbon County) who approved their designs and require their maintenance. Roads 

under private easements between Operators and private landowners may or may not have maintenance 

requirements or agreements. In addition, there are many non-oil_and-gas roads/routes that are not maintained. 

Map 2.1 in the EIS illustrates the general location of roads in the CD/WIIPA. Oil and gas field roads may also 

be under the jurisdiction of government agencies; however, maintenance of these roads is generally conducted 

by Operators. Maintenance responsibilities are discussed in the TPTSD for this project (BLM 1999). 

Operators will provide the BLM and Sweetwater and Carbon County officials with copies of road maintenance 

agreements that include the name of the Operators' designated contact persons. Non-oil_and_gas roads will be 

maintained as appropriate by the BLM or other ROW holder. 

B-1.3 LIMITATIONS 

• The condition (e.g., road design, upgrading requirements) and maintenance status (e.g., plowed) of 

existing roads and casual use routes (e.g., two-tracks) in the TPA are generally identified on maps 

available for review with the TPTSD at the BLM offices. Many existing roads may not be passable 

during inclement weather or during winter months. All roads developed and required for this project 

will need upgrading, maintenance, and winter snow removal. Specific road upgrading and 

maintenance responsibilities will be identified in annual operational updates to the TPTSD. 

• Some existing roads within the TPA may not have public access agreements in place with the BLM 

and/or private landowner. Except those identified as state or county roads, access may require 

agreements with private landowners. 

• The transportation network described in this document is focused on local and collector roads and 

potential road corridors; however, existing low traffic volume resource roads and unimproved roads are 

identified on the detailed maps available for review with the TPTSD at the BLM area offices. 
Record of Decision, Continental Divide/Wamsutter II 

B-2.0 PUBLIC INVOLVEMENT/TRANSPORTATION PLAN SCOPING 

Concerns identified during the preparation of past oil and gas development EISs in the region and associated 

Green River Basin Advisory Committee (GRBAC) meetings led the BLM RFO to request public input on the 

transportation needs and concerns for access to the CD/WIIPA and surrounding areas. Public scoping was 

initially conducted in June 1997. Additional input on transportation planning was requested in January 1998, 

scoping letters were issued, and potentially affected area users and management agencies were invited to 

attend a meeting on January 29, 1998. Those invited included Operators, county commissioners, state and 

county transportation departments, the Wyoming Game and Fish Department, recreation/conservation groups, 

landowners, and others commenting during scoping for the EIS. Additionally, drafts of the TP and the TPTSD 

were made available for review by the Wyoming Department of Transportation, Sweetwater and Carbon 

County Road and Bridge and Engineering Departments, Operators, key landowners, environmental groups, and 

individuals. A complete list of contacts can be obtained from the BLM RFO in Rawlins. Additional input 

from interested parties will be incorporated in annual operational updates to the TPTSD (see SectionB-4.0). 

All comments received during the scoping process for the Continental Divide/WamsutterII project were 

considered in developing this TP and the TPTSD. Comments included the following. 

Road Development 

• Roads should not be overdesigned; build roads to minimum standards to deter use and reduce vehicle 

speeds 

• Do not fence roads 

• Roads with parallel drainages should be located outside the 100-year floodplain 

• Road standards should be consistent across checkerboard lands 

• Sources of funding to maintain BLM and county roads should be identified 

• Properly located loop roads can eliminate excessive use of some areas 

• Analyze alternative travel corridors and road standards 

• A transportation planning process that includes the state and counties, and cooperation between all 

interested parties is needed 

• County involvement is necessary in mainline road development and maintenance, and all roads 

should be built to county road design specifications 

• County needs to be involved at APD stage 

• Consider a "no net gain" policy for roads 

• Establish limits for road development and maintenance 

• Address private land access issues from new and existing roads and the problems associated with 

alternative road designs on private lands 

• Implementation of GRBAC transportation planning recommendations, and consideration of Wyoming 

Outdoor Council comments to GRBAC recommendations 

• Road development and transportation management impacts 

• Consistency of road development guidelines across BLM district boundaries and across checkerboard 

lands 

• Mineral ownership may affect Operator rights to construct roads on private lands 

• Landowners should be contacted prior to any new road construction so that their input and concerns 

can be addressed up front, and the BLM should not dictate road development activities on private 

lands 

• All roads as shown on Map B-1.2 should be kept for use as collector roads, and upgraded as necessary 

for proposed uses; additional collector roads will be needed as development progresses 
Record of Decision, Continental Divide/Wamsutter II 

• When maximum road densities are met for the project, road building should cease until an equal 

amount of old roads are closed 

• All stream crossings should be located in areas and constructed in ways that do not decrease channel 

stability or increase water velocity 

• Road construction and reconstruction actions should be designed and conducted to minimize soil 

erosion 

• Road construction costs and area of disturbance are increased when curves are planned for new roads 

to reduce visual impacts 

Road Use 

• Collector roads should be addressed individually in respect to paving or gravel surfacing to prevent 

mud from being carried on to existing highways 

• Operators should enforce speed limits, and vehicle speeds should be reduced 

• Use existing two-track roads to access well locations 

• The use of looped roads should be minimized to avoid increased traffic 

• Identify impacts from fugitive dust 

Road Maintenance 

• Immediately identify the proposed collector roads that currently need maintenance and action 

• County roads should be maintained by the counties since they currently receive funds generated by 

the Operators; Operators should assist in eliminating problem areas on county roads 

• Operators acquiring ROWs over BLM roads will need to enter into cooperative agreements with each 

other for road upgrades and maintenance 

• Road maintenance actions require prioritization 

• Appropriate maintenance of cattleguards, wing ditches, and culverts 

Road Reclamation 

• Closed roads should be obliterated, reclaimed, and signed as such to inform the public 

• All roads developed for this project should be reclaimed when they are no longer required 

• Reclaim 2 mi of road for every 1 mi constructed 

• Roads are prolific in the project area and there is little attempt to decrease their impact to the Muddy 

Creek watershed and other resources 

• Existing roads should be eliminated if another road accesses the same area, and Operators should look 

for opportunities to close and reclaim unused and redundant roads 

• Two-track roads that are not used and which can be reclaimed should be identified 

• Roads need to be reclaimed as soon as possible after abandonment 

• The ultimate road situation (i.e., after the project is completed) should be similar to predevelopment 

(pre-1990) 

Wildife 

• The proposed collector road along Delaney Rim may be a problem to existing raptor nesting habitat 

• Close coordination of the Wyoming Game and Fish Department, BLM, and Operators is needed for 

development in the Chain Lakes area 

• Minimize road densities and total miles of road to minimize impacts to wildlife populations 

• New roads increase access into areas which could increase the probability of wildlife poaching and 
Record of Decision, Continental Divide/Wamsutter II 

other forms of mortality (road kills) 

• New roads cause habitat loss through direct conversion of habitat to road ROWs and increased 

wildlife disturbance (e.g., decreased use of habitats adjacent to roads, increased stress) 

• Use locked gates, signs, and seasonal closures to reduce vehicle traffic thereby protecting wildlife by 

restricting access 

• Field workers should visit wells during mid_day to minimize impacts to wildlife 

• Impose speed limits to reduce big game road kills 

• Impacts of roads on big game, especially antelope 

• All perennial stream crossings should be adequately designed to allow fish passage at all flows 

• Impacts to aquatic resources should be minimized to ensure compliance with Section 404 of the 

Clean Water Act 

• Plow wildlife/livestock outlets through snow banks along roads in the winter season 

• Habitat fragmentation from roads 

• Due to extensive road development, requirements are needed to protect wildlife and other resource 

protection on BLM lands; duplicate roads are being built on private lands 

• Avoid special features such as raptor nesting areas, sage grouse leks, crucial big game winter range, 

and associated buffers 

• Impacts of new power lines on sage grouse predation, and avoid power line construction within 0.75 

mi of sage grouse leks 

• Identify mitigation measures (e.g., vehicular travel restrictions, existing road realignment) to prevent 

lek and ferruginous hawk nest abandonment 

• Noise impacts to sage grouse and ferruginous hawks should be considered 

• Pipeline development may improve winter wildlife habitat by removing decadent sagebrush 

• Power line construction should be in accordance with raptor-safe criteria established by the Avian 

Power Line Interaction Committee 

Interstate 80, Wyoming State Highways, and Other Developed Road Concerns 

• No additional access off I-80 will be allowed 

• Height and width restrictions for I-80 underpasses and weight limits on all highways must be observed; 

fines will be issued for damage and noncompliance 

• A cross-over plan should be developed for the safe and proper use of median cross-overs 

• Space trucks requiring the use of cross-overs at least 5 minutes apart 

• Trucks should not pull onto or be backed_up on the left shoulder of I-80 prior to turning 

• Pull trucks onto emergency lanes prior to turning onto cross_over 

• Drive to a suitable interchange if cross-overs are not available 

• Operators may be liable for repair of cross-over roads 

• Cross-over use creates safety and liability problems, and cross-over use may be restricted 

• Safety and problem areas along I-80 need to be identified on TP maps 

• Approaches off existing highways and county roads will be limited to 2 or 3per mi per side and will 

require cattleguards, paving, and adequate sight distance as appropriate for the classified road use 

• Additional approaches will be restricted 

• Operators are encouraged to use existing approaches 

• Turning lanes will be considered for high traffic_volume approaches 

• Mud on the highway is a safety concern. Surfacing of roads (up to 1 mi from the highway) may be 

necessary, but should not be mandated for all cases 

• Every highway approach is a conflict point, and permits will be required 

• Joint efforts should be made to upgrade (gravel surface) the Red Desert Road 

• Cattle guard damage is a problem 
Record of Decision, Continental Divide/Wamsutter II 

• Overweight loads may damage cattleguards and bridges; construction of gated bypasses may be a

solution

• Counties require notification prior to moving overweight loads 

• Access to permanent facilities needs to be maintained for year_round use and facilities need to be

accessible to emergency vehicles

• Most county roads are not all weather roads; therefore, surfacing is needed 

• Access approaches will require permits and should be at 90E angles 

• The term collector roads needs to be defined and a determination needs to be made if all existing

county roads should be considered collector roads and if they need to be all weather roads

• Dust is a problem on existing county roads, and dust abatement measures will be required 

• The Sweetwater County Road Department does not have adequate funds for road graveling and

upgrading

• Carbon County Road 701 should be considered a collector road and may require gravel surfacing and

dust abatement to maintain safety

Pipelines and Power Lines 

• Maximize use of existing road and pipeline corridors 

• Pipelines and power lines should parallel roads within the same ROW, and impacts should be identified 

• Avoid development within existing power line ROWs 

• Pipelines and power lines should be buried 

• Build cuts along pipeline routes to discourage unauthorized travel along reclaimed ROWs 

• Pipeline development may improve winter wildlife habitat by removing decadent sagebrush 

• Power line construction should be in accordance with raptor-safe criteria established by the Avian Power Line 

Interaction Committee 

• Pipeline densities could be less if paralleling every road was not the rule 

• Pipelines and power lines cannot be constructed within and parallel to I-80 or state highway ROWs; pipeline 

and power line crossings of I-80 must be bored under the highway 

• Identify any improvements to utility lines 

• Crossing impacts must be mitigated by Operators 

• No unreasonable restrictions on construction of utility and pipeline facilities 

Recreation 

• Use of roads by the public, public road designations, and public access 

• Landowners should allow recreational use on their lands and avoid posting of lands 

• Increased access will provide increased recreational opportunity 

• Do not fence roads 

• BLM signs should be removed to limit unauthorized public use of private roads and lands 

• With reclamation, visual impacts are negligible for new roads 

Other Concerns 

• Operators need to do a better job monitoring damage to cattle guards, closing gates, and restricting

unauthorized off_road travel along fencelines, two-track trails, and pipeline ROWs

• Form a task force to develop a coordinated transportation plan to address access issues (county

permits, private lands, drainage, safety, Uniform Fire Code compliance, traffic demands, county

access), construction plans (e.g., permits, construction use, zone changes), and maintenance

specifications (roads, cattleguards, bridges, heavy equipment)

• Difficulties associated with problem-solving by large committees for transportation planning 
Record of Decision, Continental Divide/Wamsutter II 

• The BLM has very few roads in the CD/WIIPA with easements across private and state lands 

• The BLM issues ROWs for all its roads 

• BLM roads are for use, development, protection, and administration of public lands and resources, and 

are not necessarily public roads; although public use is generally allowed, roads may be closed or use 

restricted to fulfill management objectives 
Record of Decision, Continental Divide/Wamsutter II 

B-3.0 EXISTING AND PROPOSED TRANSPORTATION NEEDS 

B-3.1 THE EXISTING NETWORK 

I-80 is the primary access to the entire CD/WIIPA. Other paved or partially paved roads include State 

Highway 789, U.S. Highway 287, a section of County Road 4-19, and County Road 4-63. The remainder of the 

roads are not paved and generally are not surfaced (e.g., gravel, aggregate). Some of these unpaved roads 

become impassable when wet and during winter, and if these roads are used as access for this project, they 

will require improvements and increased maintenance including snow removal. County roads (arterial roads) 

are maintained but in many cases there is no snow removal. County roads provide public access across private 

land; however, BLM roads or other roads which cross private lands may not have public ROWs. Nearly all of 

the existing county roads (proposed high-volume roads) within and adjacent to the CD/WIIPA originate at one 

of the exits of I_80, and most of these roads run north or south from I-80. Most of the routes that are not paved 

highways or county roads will require ROWs for access and will require improvement or reconstruction before 

project use. In addition, some realignment of these routes may occur to minimize impacts to sensitive 

resources, ensure safety, and maximize traffic flow efficiency. Map B-1.2, Maps2.1 and 2.2 in the EIS, and the 

detailed maps available for review with the TPTSD show the existing and proposed locations of high-volume 

roads and/or corridors within the TPA (i.e., arterial roads and other potential collector and local road routes 

with high initial traffic volumes). 

Additional local and resource roads (i.e., local roads = minimum traffic volume roads usually providing the 

internal access network within an oil and gas field; resource roads = normally spur roads providing point 

access to oil and gas well locations) are present on the CD/WIIPA, and additional access roads will be 

constructed as necessary and specified in annual operational updates to the TPTSD (see Chapter B-4.0). 

Where these new roads duplicate existing two-track roads/routes, the existing two-track may be reclaimed. At 

field abandonment, many newly constructed local and resource roads are anticipated to be 

reclaimedunless there is an identified need for the road by other area users. Reclamation activities will be 

addressed during annual planning and corresponding updates to the TPTSD. 

The existing transportation network on the TPA is generally shown on Map B-1.2, and roads/routes are briefly 

described in the TPTSD (BLM 1999). This system includes state, county, and BLM access roads, most of 

which originate at I-80 and its exits. Historic use of the roads has been limited primarily to livestock 

operators, recreationists, and mineral developers. The principle current use of these and other roads in the area 

is for oil- and gas-related traffic; however, other users include grazing permittees and recreationists. The 

existing transportation system is generally suitable for all current users. 

Undesignated two-track roads/routes also may be used to access the area. These routes are used primarily by 

grazing permittees and recreationists. Grazing permittees primarily use the two_tracks to access water 

developments and livestock. 

Numerous pipeline routes deliver gas from the CD/WIIPA (see Map 2.2 in the EIS). Most lines parallel I-80; 

however, numerous gathering system lines are present. Further information regarding the location of pipelines 

on the CD/WIIPA can be found on the detailed maps available for review with the TPTSD at the BLM offices. 
Record of Decision, Continental Divide/Wamsutter II 

B-3.2 PROPOSED NETWORK USE/MODIFICATION 

The stages of a typical trip necessary for the CD/WIIPA transportation system are listed below. 

A. Main movement (i.e., I-80 and state highway lanes for workers with destinations terminating in the 

CD/WIIPA). 

B. Transition (i.e., exits, turnout lanes, where there is a change in travel speed). 

C. Distribution/collection (i.e., county, oil/gas field unit, or ranch access roads; collector and local 

roads). 

D. Terminal access (i.e., well location access roads; resource roads). 

When planning transportation facilities, all of the described traffic stages can be identified within the system, 

but any stage could be eliminated if not needed (e.g., intermediate stages may not be necessary). Each 

movement stage is handled by a separate facility designed specifically for its function. Identifying the stages 

helps to plan traffic flows. 

The TPA transportation network is not anticipated to experience problems at traffic stage changes, due to the 

relatively low volume of expected traffic (Table B-3.1). The distribution by distance of traffic stage changes 

within the CD/WIIPA also eliminates the probability of congestion when vehicles turn from collector or local 

roads to well access roads. The well access roads are dispersed far enough apart and the traffic volumes are 

low enough that traffic congestion will be unlikely. Although traffic volumes on CD/WIIPA roads generally 

will be low, heavy vehicles will use the roads throughout the LOP, and without road upgrades, some of these 

vehicles may become stuck during inclement weather periods, causing traffic flow problems. However, with 

the implementation of this plan, proper road construction and maintenance will occur, thereby minimizing the 

potential for this problem. 

The estimated traffic requirements for each well are provided in Table B-3.1, and examples of potential traffic 

volumes on resource, local, and collector roads are provided in Table B-3.2. Construction, drilling, and 

completion activities have the greatest traffic requirements for the proposed project (an estimated 469 round 

trips per well over a 56-day period). These activities will most likely be concentrated within localized areas 

during the first 20 years as the project is developed. The maximum number of round trips per day is estimated 

to be approximately 1,000, and most trips will originate from I-80. 

Localized construction and drilling activity will temporarily place heavy demands on road servicing. Traffic 

demands will be high in areas where drilling and completion activities are occurring, but will be minimal 

within other areas of the CD/WIIPA. Once all wells have been completed, traffic requirements will be 

minimal for the remainder of the LOP (i.e., averaging less than 150project-required round trips per day for 

the entire area). Nonetheless, CD/WIIPA roads will be used throughout the LOP until all wells in the area are 

abandoned and disturbed areas reclaimed. Maintenance of roads remaining on the area after abandonment will 

be conducted by non-oil-and-gas entities. 
Record of Decision, Continental Divide/Wamsutter II 

Table B-3.1 Vehicle Characteristics and Estimated Number of Trips Required for the Continental Divide/Wamsuter II Project, 

Sweetwater and Carbon Counties, 1999. 

Truck Type Average WeightNo. of Average Average Number ofEstimated Total

(x 1,000 lbs) Wheels Speed on the Round Trips per Round Trips2

CD/WIIPA1 Location (x 1,000)

(mph) 

PROJECT DEVELOPMENT 

Location/Road Construction

 Semi 74 18 20 3 9

Gravel/haul 48 10 20 33 99

Pickup 7 4 30 47 141

Drilling Operations

 Semi 60 18 20 22 66

Fuel and mud 48 10 20 15 45

Logging and water 20 6 20 23 69

Pickup 7-8 4 30 133 399

Completion and Testing

 Semi 74-80 18 20 8 24

Haul A 48 10 20 33 99

Haul B 44 10 20 60 180

Haul C 20 6 20 21 63

Pickup 7-8 4 30 23 69

Pipeline Construction

 Haul B 44 10 20 4 12

Haul C 20 6 20 4 12

Pickup 7-8 4 30 40 120

Development Total -- -- -- 469 1,407 

OPERATIONS 3

 Workover rig4 90 18 20 3 9

Haul5 48 10 20 425 312

Pickup 5 7-8 4 30 2,782 417

Operations Total -- -- -- 3,210 738

1 Some vehicles may drive at speeds of 45 mph on maintained collector roads. 2 Assumes 3,000 wells are drilled and completed as producers. 3 Assumes a well life of 30 years. 4 The workover rig vehicle will be the largest vehicle (i.e., critical vehicle) required for the project.
5 

Record of Decision, Continental Divide/Wamsutter II

Each well loaction will be visited twice a week on average, and approximately 15-20 well locations 
Record of Decision, Continental Divide/Wamsutter II 

Table B-3.2Example Traffic Volumes for Selected Resource, Local, and Collector Roads, Continental 

Divide/Wamsutter II Project, Sweetwater and Carbon Counties, 1999. 

Road Type (No. of wells) 

Resource Road (1 well) 

Estimated Number 

of Round Trips 

3,688 

Estimated Average Daily Traffic 

0.3 

Resource Road (10 wells) 30,688 2.8 

Local Road (50 wells) 184,400 16.8 

Collector Road (100 wells) 306,880 28.0 

Collector Road (500 wells) 1,884,000 168.4 

B-3.3 ULTIMATE ROAD DISPOSITION 

When the field is ready for abandonment (estimated to be approximately 50 years), the transportation network 

within the TPA will be reclaimed to specifications developed during the annual operational updates. 

Reclamation protocol are described in AppendixA of the EIS. Improvements to most existing roads likely will 

be maintained, and some roads identified as necessary or desirable for other area users (e.g., grazing 

permittees, recreationists) during annual operational updates will be retained. 

Resource roads that may be retained after the LOP will be those identified during annual transportation 

planning as duplicating an existing two-track or other low-volume road/route for which these two-tracks or 

other roads/routes were reclaimed. In addition, resource roads that are deemed necessary by the BLM for other 

area uses also may be retained. 

County roads likely will be retained in an upgraded status (local/collector road), as will improvements to BLM 

roads. All other local/collector roads potentially developed as access routes for this project are likely to be 

entirely reclaimed or returned to conditions similar to those occurring on the area prior to oil and gas 

development activities. 

Road use following project completion likely will be limited to two of the three existing uses (i.e., grazing 

management and recreation), and responsibility for maintenance of roads will revert back to the counties, 

private landowners, or BLM. A determination regarding the extent of post-project road maintenance (e.g., 

winter snow removal) on the TPA cannot be determined at this time since the level of future area use is 

unknown. Decisions will be made during the later years of the project based on public input received during 

annual update reviews. 
Record of Decision, Continental Divide/Wamsutter II 

B-4.0 ANNUAL PLANNING AND OPERATIONAL UPDATES

TO THE TRANSPORTATION PLANNING

 TECHNICAL SUPPORT DOCUMENT

To accommodate the uncertainty regarding proposed well locations and associated well productivity, future 

transportation routes within the CD/WIIPA and TPA (see Maps 2.1 and 2.2 in the EIS) will be developed 

incrementally as wells are developed and associated information on Operator transportation requirements 

becomes available. Annual operational updates to the TPTSD for the CD/WIIPA will begin in 1999, and 

annual updates will be available in January each year thereafter until the project is completed or until the 

transportation system is so well-established that further annual planning is not needed. 

To facilitate the planning process, a Transportation Planning Committee (TPC) has been established. The 

TPC is composed of representative from the BLM, Operators, Sweetwater and Carbon County Transportation 

Departments, Wyoming Department of Transportation, Wyoming Game and Fish Department, landowners, 

grazing permittees, recreationists, and other interested groups or individuals. The committee will be 

responsible for overall transportation planning and for identifying and considering issues and concerns, whereas 

subcommittees/groups will likely be established for the resolution of site_specific issues (e.g., 

operational/compliance issues, individual road maintenance, and construction problems). 

Annual transportation planning generally will be conducted to determine the location, maintenance, and 

design criteria for roads developed on the area. This process will involve annual Operator projections for well 

and ancillary facility developments, public input, and updates on sensitive resources. With this information, 

the TPC will assist in designing a road network that accommodates Operator and other area user needs, 

minimizes potential impacts to sensitive environmental resources, and maximizes traffic flow efficiencies 

commensurate with existing and potential needs. 

The existing transportation network in the area is generally suitable for existing uses; however, as areas 

with natural gas resource potential are identified and developed, changes to the existing network will be 

required. Therefore, Operators will be required to provide to the TPC annual projections specifying proposed 

well and facility site locations and associated traffic requirements (e.g., estimated number of round trips; 

duration of construction, drilling, and completion activities; vehicle sizes). This information will be provided 

to the TPC by approximately mid-October of each year for the LOP, or until no longer required by the TPC 

(Table B-4.1). The TPC will evaluate this information, in light of environmental constraints and other known 

uses of the area, and develop tentative road, pipeline, and power line locations, types, and maintenance 

information. A draft update with maps will be developed by the TPC and submitted to area Operators and 

other relevant land users (e.g., grazing permittees, landowners, county and state transportation departments, 

recreationists) by approximately early November of each year. Meetings will then be held with the TPC and 

other interested land users to discuss modifications to the proposed update to accommodate Operator and other 

user concerns. Broad issues potentially affecting most area users will be discussed with the entire TPC, 

whereas site_specific operation, maintenance, or other specific road problems will be delegated for resolution 

to subcommittees. Public meetings will be held as deemed necessary by the TPC to present information and 

solicit additional comment. All issues associated with annual operational updates will be resolved during 

November and December of each year. A final update that considers all comments will be prepared and 

available for review in January of each year. Annual operational updates will be available for review at the 

BLM RFO and RSFO. 

Geographic information system (GIS) technologies will be used to assist in the annual updating of the 

transportation network as appropriate. Maps will be updated to incorporate new sensitive resource locations, 
Record of Decision, Continental Divide/Wamsutter II 

proposed roads, wells, pipelines, and ancillary facility locations. Existing roads designated for reclamation 

also will be identified. This process will result in minimizing the road densities on the area while 

accommodating all land user requirements. 

Information that may be included in annual operational updates includes: 

• the location of all existing wells, roads, pipelines, power lines, and other man_made features on the 

area; 

• the location of all proposed wells, roads, pipelines, power lines, and other project-required features to 

be developed within the next year; 

• the location of all roads to be reclaimed during the next year; 

• the anticipated traffic volumes for all existing and proposed developments; 

• identification of existing roads that require upgrades to accommodate existing and proposed traffic 

requirements (careful planning will be required to ensure roadswill be neither under- nor 

over_designed); 

• the identification of existing and required maintenance and associated maintenance, ROW, and 

cooperative agreements (including scheduling, responsible parties, and activities) for project-required 

roads; 

• surfacing material source locations for road upgrades and maintenance;

 • the location of sensitive resources (e.g., drainages, raptor nest and sage grouse lek buffers) and 

environmental obstacles (e.g., steep slopes, erosive soils) (The precise locations of some 

environmentally sensitive resources [e.g., cultural and paleontological resource sites] may not be 

presented in updates to avoid unauthorized use; however, the locations of these resources and 

associated buffers will be considered during the planning process.); and 

• other identified transportation issues. 

Final road location and design criteria for roads which either cross federal lands or are associated with federal 

wells will be included in Application for Permit to Drill (APD) and/or ROW applications and will be subject 

to independent environmental reviews and National Environmental Policy Act (NEPA) analysis by BLM. 

Some modification to proposed road locations specified in annual updates likely will occur as a result of these 

environmental analyses. For example, ClassIII cultural resource inventories will be required for all new roads, 

and these inventories may reveal the potential for significant cultural resource concerns in some areas. Roads 

will likely be rerouted to avoid such features. Once a road has been constructed, its final location will be 

identified on maps provided in the annual operational updates. 

During the later years of the project (years 30-50), it is anticipated that annual updates primarily will identify 

well locations, ROWs, and other routes designated for abandonment and reclamation. The ultimate 

transportation network on the TPA is anticipated to appear much like the area appeared prior to natural gas 

development. However, public input received during the annual update process may recommend that some 

roads developed for the proposed project remain after the LOP. New roads that remain after the LOP will 

become the responsibility of BLM and/or private landowner. In addition, road upgrades of primary access 

routes will probably remain, and most resource roads developed for this project probably will be reclaimed 

unless they are determined necessary for other area uses as identified during annual planning. 
Record of Decision, Continental Divide/Wamsutter II 

Table B-4.1 Annual Operational Update Responsibilities and Dates, Continental Divide/Wamsutter II Natural 

Gas Project, 1999. 

Action Responsibility Approximate Submittal/ 

Completion Date 

Provision of information regarding annual proposed Operators, TPC, BLM, Mid-October 

well, road, and facility site locations with traffic other interested parties 

requirements; wells and roads to be abandoned; 

major pipeline and power line projects; road 

upgrades; landowner concerns; and other issues 

Development of agenda; evaluation of proposed TPC, BLM, Operators Late October/ 

plans; preparation of updated maps; and review of Early November 

updates and other issues 

Public meetings to review development plans and TPC, BLM, Operators, Early November 

associated issues other interested parties 

Resolution of issues by TPC TPC, BLM, Operators, November/December 

other interested parties 

Final update completion/public meetings to discuss TPC, BLM, Operators, Early January 

resolution measures other interested parties 
Record of Decision, Continental Divide/Wamsutter II 

B-5.0 LITERATURE CITED 

Bureau of Land Management. 1985. Bureau of Land Management manual Section 9113 roads. 

.1991.Bureau of Land Management manual Section 9113 roads and Wyoming supplement. 

.1995.Record of Decision for Union Pacific Resources Company, Greater Wamsutter Area II Natural Gas 

Development Project. Bureau of Land Management, Great Divide Resource Area, Rawlins District, 

Rawlins, Wyoming. 

.1999.Transportation planning technical support document for the Continental Divide/Wamsutter II 

Natural Gas Project. Prepared for the U.S. Department of Interior, Bureau of Land Management, Rawlins 

District, Great Divide Resource Area, Rawlins, Wyoming, and Rock Springs District, Green River 

Resource Area, Rock Springs, Wyoming, by TRC Mariah Associates Inc., Laramie, Wyoming, and Uintah 

Engineering and Land Surveying, Vernal, Utah. 
APPENDIX C: 

HAZARDOUS MATERIALS SUMMARY 
HAZARDOUS MATERIALS SUMMARY FOR THE

CONTINENTAL DIVIDE/WAMSUTTER II

NATURAL GAS PROJECT

Prepared for 

Bureau of Land Management

Great Divide Resource Area

Rawlins District

Rawlins, Wyoming

and 

Green River Resource Area

Rock Springs District

Rock Springs, Wyoming

By 

TRC Mariah Associates Inc.

Laramie, Wyoming

MAI Project 1295

October 1998
______________________________________________________________________________ 

Hazardous Materials Summary, Continental Divide/Wamsutter II Project 1 

C-1.0 INTRODUCTION 

This Hazardous Materials Summary is provided pursuant to Bureau of Land Management (BLM) Instruction 

Memoranda Numbers WO-93-344 and WY-94-059, which require that all National Environmental Policy Act 

(NEPA) documents list and describe any hazardous and/or extremely hazardous materials that will be produced, 

used, stored, transported, or disposed of as a result of a proposed project. The summary serves as a supplement to 

the Continental Divide/Wamsutter II Natural Gas Project Environmental Impact Statement (BLM 1998). 

Materials are considered hazardous if they contain chemicals or substances listed in the Environmental Protection 

Agency's (EPA's) Consolidated List of Chemicals Subject to Reporting Under Title III of the Superfund 

Amendments and Reauthorization Act (SARA) of 1986. Extremely hazardous materials are those identified in the 

EPA's List of Extremely Hazardous Substances (40 Code of Federal Regulations [C.F.R.] 355). 

Hazardous materials anticipated to be used or produced during the project may come from drilling materials, 

casing and plugging materials, fracturing materials, production products, fuels, geophysical survey materials, 

pipeline materials, emissions, and miscellaneous materials. Where possible, the quantities of these products or 

materials have been estimated on a per-well basis. Hazardous and extremely hazardous constituents potentially 

occurring in these products or materials have been identified and are listed in Table C-1.1.Table 

C-1.1 Hazardous and Extremely Hazardous Materials Potentially Utilized or Produced During Construction, 

Drilling, Production, and Reclamation Operations by the Continental Divide/Wamsutter II Natural Gas Project, 

Carbon and Sweetwater Counties, Wyoming, 1997. 

C-1.1 DRILLING MATERIALS 

Water_based drilling fluids consisting of clays and other additives will be utilized by drilling companies for drilling 

each well. Drilling fluid additives potentially containing hazardous materials are listed in Table C-1.1. The 

polyacralamides used in drilling may contain the extremely hazardous substance acrylamide. Drilling fluids and 

additives will be appropriately transported to well locations during drilling operations. Drilling fluids, cuttings, and 

water will be stored in reserve pits located on-site, and reserve pits will be lined as directed by the BLM to 

conserve water and protect near-surface aquifers. When the reserve pit is no longer required, its contents will be 

evaporated or solidified in place, and the pit backfilled, as approved by the BLM. 

C-1.2 CASING AND PLUGGING MATERIALS 

Well completion and abandonment operations include cementing and plugging various segments of the well bore 

to protect freshwater aquifers and other down-hole resources. Wells will be cased and cemented as approved by 

the BLM (for federal minerals) and Wyoming Oil and Gas Conservation Commission (WOGCC) (for state and 

patented minerals). Cementing and plugging materials potentially containing hazardous materials are listed in 

Table C-1.1. The extremely hazardous material acrylamide may be present in fluid loss additives. All cementing 

and plugging materials will be transported in bulk to each well site. Small quantities may be transported and 

stored on_site in appropriate containers. 

C-1.3 FRACTURING MATERIALS 

Hydraulic fracturing is expected to be performed at all proposed wells to enhance gas flow rates. Fracturing fluids 

consist primarily of fresh water, but may contain some additives with hazardous constituents as shown in Table 
______________________________________________________________________________ 

1 Hazardous Materials Summary, Continental Divide/Wamsutter II Project 

C-1.1. Fracturing materials will be transported to well locations in bulk or in manufacturer's containers. Waste 

fracturing fluids will be collected in aboveground tanks and/or reserve pits and evaporated, or they will be hauled 

away from the location and reused at another well or disposed of at an authorized facility. 

C-1.4 PRODUCTION PRODUCTS 

C-1.4.1 Natural Gas 

Natural gas produced from wells will primarily contain methane, ethane, and carbon dioxide. Hexane, polynuclear 

aromatic hydrocarbons (PAHs), and polycyclic organic matter (POM) are hazardous substances potentially present 

in the gas stream (Table C-1.1). No extremely hazardous materials are anticipated to be present. Small quantities 

of natural gas may be flared into a flare pit during well testing operations, pursuant to BLM/WOGCC rules and 

regulations (Notice to Lessees [NTL]-4A). BLM and WOGCC approval will be necessary prior to flaring 

operations. No natural gas will be stored on site. 

C-1.4.2 Liquid Hydrocarbons 

Condensates and/or oil produced in association with the gas stream are expected from productive wells. Hazardous 

materials potentially present in the liquid hydrocarbons are listed in Table C-1.1. No extremely hazardous 

materials are known to be present in the liquid hydrocarbons. 

Liquid hydrocarbons will be stored in tanks at well locations, and all tanks will be fenced and bermed to contain 

110% of the entire storage capacity of the largest tank. Liquid hydrocarbons periodically will be removed from 

storage tanks and transported by truck off the project area for sale to refineries. All necessary authorizing actions 

for the production, storage, and transport of liquid hydrocarbons, including the Oil Pollution Act of 1990, will be 

addressed prior to the initiation of production activities. 

C-1.4.3 Produced Water/Drill Cuttings 

Hazardous materials potentially present in trace amounts in produced water and drill cuttings are listed in Table 

C-1.1. No extremely hazardous materials are expected in the produced water or drill cuttings. 

Produced water will be stored in tanks at well locations and periodically will be removed and transported to 

Wyoming Department of Environmental Quality (WDEQ)- or WOGCC-permitted water disposal facilities. 

Produced water quality from wells will be monitored periodically, and produced water that meets applicable 

standards will be discharged to the surface at appropriate locations. Necessary authorizing actions that must be 

met prior to the disposal of produced water include: 

• BLM approval of disposal methodologies; 

• Resource Conservation and Recovery Act (RCRA) compliance as necessary; 

• WDEQ-Water Quality Division approval of wastewater disposal (e.g., National Pollution Discharge 

Elimination System permits, Underground Injection Control permits pursuant to 40 C.F.R. 144); 

• WOGCC evaporation pond permits; and 

• Wyoming State Engineer's Office (WSEO) dewatering permits (FormU.W.5). 

Drill cuttings will be stored in reserve pits, and after evaporation, the pit will be backfilled as approved by the 

BLM. 
_________________________________________________________________________________________________ 

_________________________________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

Table 1.1 Hazardous and Extremely Hazardous Materials Potentially Utilized or Produced During Construction, Drilling, Production, and 

Reclamation Operations by the Continental Divide/Wamsutter II Natural Gas Project, Carbon and Sweetwater Counties, 

Wyoming, 1998. 

Source Approximate Quantities Hazardous Substances2 Extremely CAS No. 

Used or Produced Hazardous 

Per Well 1 Substances3 

Drilling Materials 

Barite 16,000 lbs Barium compounds --

Fine mineral fibers --

Bentonite 45,000 lbs Fine mineral fibers --

Caustic soda 750 lbs Sodium hydroxide 1310-73-2 

Glutaraldehyde 20 gal Isopropyl alcohol 67-63-0 

Lime 3,500 lbs Calcium hydroxide 1305-62-0 

Mica 600 lbs Fine mineral fibers --

Modified tannin 250 lbs Ferrous sulfate 7720-78-7 

Fine mineral fibers --

Phosphate esters 100 gal Methanol 67-56-1 

Polyacrylamides 100 gal Acrylamide 79-06-1 

PAHs4 --

Petroleum distillates 64742-47-8 

POM5 --

Retarder 400 lbs Fine mineral fibers --

Cementing and Plugging Materials 

Anti-foamer 100 lbs Glycol ethers --

Calcium chloride flake 2,500 lbs Fine mineral fibers --

Cellophane flake 300 lbs Fine mineral fibers --

Cements 77,000 lbs Aluminum oxide 1344-28-1 

Fine mineral fibers --

Chemical wash 850 gal Ammonium hydroxide 1336-21-6 

Glycol ethers --

Diatomaceous earth 1,000 lbs Fine mineral fibers --

Extenders 17,500 lbs Aluminum oxide 1344-28-1 

Fine mineral fibers --

Fluid loss additive 900 lbs Acrylamide 79-06-1 

Fine mineral fibers --

Napthalene 91-20-3 

Friction reducer 160 lbs Fine mineral fibers --

Napthalene 91-20-3 

PAHs --

POM --

Mud flash 250 lbs Fine mineral fibers --

Retarder 100 lbs Fine mineral fibers --

Salt 2,570 lbs Fine mineral fibers --

Silica flour 4,800 lbs Fine mineral fibers - - Fracturing 

Materials 

Biocides 6 gal Fine mineral fibers --

PAHs --

POM --

Breakers 145 lbs Ammonium persulphate 7727-54-0 

Ammonium sulphate 7783-20-2 

Copper compounds --

Ethylene glycol 

Fine mineral fibers 107-21-1 --

Glycol ethers --
_________________________________________________________________________________________________ 

--

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--

--

--

--

--

--

--

--

--

--

--

--

--

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--

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Record of Decision, Continental Divide/Wamsutter II 1 

Clay stabilizer 50 gal Fine mineral fibers 

Glycol ethers 

Isopropyl alcohol 

Methanol 

PAHs 

POM 

Crosslinkers 60 gal Ammonium chloride 

Methanol 

Potassium hydroxide 

Zirconium nitrate 

Zirconium sulfate 

Foaming agent 120 gal Glycol ethers 

Gelling agent 950 gal Benzene 

Ethylbenzene 

Methyl tert-butyl ether 

Napthalene 

PAHs 

POM 

Sodium hydroxide 

Toluene 

m-Xylene 

o-Xylene 

p-Xylene 

pH buffers 60 gal Acetic acid 

Benzoic acid 

Fumaric acid 

Hydrochloric acid 

Sodium hydroxide 

Sands 2,000,000 lbs Fine mineral fibers 

Solvents 50 gal Glycol ethers 

Surfactants 15 gal Glycol ethers 

Isopropyl alcohol 

Methanol 

PAHs 

POM 

Natural gas 0.25->3.5 mmcfd n-Hexane 

PAHs 

POM 

Liquid hydrocarbons <5-350 bpd Benzene 

Ethyl benzene 

n-Hexane 

PAHs 

POM 

Toluene 

m-Xylene 

o-Xylene 

p-Xylene 

Produced water/drill cuttings <20 bpd water and an

unknown quantity of 

cuttings 

Barium 

Cadmium 

Chromium 

Lead 

Manganese 

Radium 226 

Uranium 

Other radionuclides 

Fuels 

Diesel fuel >36,300 gal Benzene 

Cumene 

Ethylbenzene

Methyl tert-butyl ether 

Naphthalene 

PAHs 

POM 

Toluene 

m-Xylene

o-Xylene 

p-Xylene 

67-63-0 

67-56-1 

12125-02-9 

67-56-1 

1310-58-3 

13746-89-9 

14644-61-2 

71-43-2 

100-41-4 

1634-04-4 

91-20-3 

1310-73-2 

108-88-3 

108-38-3 

95-47-6 

106-42-3 

64-19-7 

65-85-0 

110-17-8 

7647-01-0 

1310-73-2 

67-63-0 

67-56-1 

- - Production 

Products 

110-54-3 

71-43-2 

100-41-4 

110-54-3 

108-88-3 

108-38-3 

95-47-6 

106-42-3 

7440-39-3 

7440-43-9 

7440-47-3 

7439-92-1 

7439-96-5 

71-43-2 

98-82-8 

100-41-4 

1634-04-4 

91-20-3 

108-88-3 

108-38-3 

95-47-6 

106-42-3 
_________________________________________________________________________________________________ 

_________________________________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

Gasoline Unk Benzene 71-43-2 

Cumene 98-82-8 

Cyclohexane 110-82-7 Ethylbenzene 100-41-4 

n-Hexane 110-54-3 

Methyl tert-butyl ether 1634-04-4 Naphthalene 91-20-3 

PAHs -- POM -- Tetraethyl lead 78-00-2 Toluene 108-88-3 

m-Xylene 108-38-3 o-Xylene 95-47-6 

p-Xylene 106-42-3 

Jet A Unk Benzene 71-43-2 

Cumene 98-82-8 Cyclohexane 110-82-7 Ethylbenzene 100-41-4 n-Hexane 110-54-3 Methyl tert-butyl ether 1634-04-4 Naphthalene 91-20-3 PAHs --

POM -- Toluene 108-88-3 m-Xylene 108-38-3 o-Xylene 95-47-6 p-Xylene 106-42-3 

Natural gas Unk n-Hexane 110-54-3 

PAHs -- POM --

Propane Unk Propylene 115-07-1 

Geophysical Survey Materials 

Explosives, fuses, detonators, Unk Aluminum 7429-90-5 boosters, fuels Ammonium nitrate 6484-52-2 Benzene 71-43-2 Cumene 98-82-8 Ethylbenzene 100-41-4 Ethylene glycol 107-21-1 Lead compounds 7439-92-1 Methyl tert-butyl ether 1634-04-4 Naphthalene 91-20-3 Nitric acid 7697-37-2 Nitroglycerine 55-63-0 

PAHs -- POM -- Toluene 108-88-3 m-Xylene 108-38-3 o-Xylene 95-47-6 p-Xylene 106-42-3 

Pipeline Materials 

Coating Unk Aluminum oxide 1334-28-1 

Cupric sulfate solution Unk Cupric sulfate 7758-98-7 

Sulfuric acid 7664-93-9 

Diethanolamine Unk Diethanolamine 111-42-2 

LP Gas Unk Benzene 71-43-2 

n-Hexane 110-54-3 Propylene 115-07-1 

Molecular sieves Unk Aluminum oxide 1344-28-1 

Pipeline primer Unk Naphthalene 91-20-3 

Toluene 108-88-3 

Potassium hydroxide solution Unk Potassium hydroxide 1310-58-3 

Rubber resin coatings Unk Acetone 67-64-1 

Coal tar pitch 68187-57-5 Ethyl acetate 141-78-6 Methyl ethyl ketone 78-93-3 Toluene 108-88-3 Xylene 1330-20-7Emissio 

ns 
_________________________________________________________________________________________________ 

_________________________________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

Gases 127 tons6 Formaldehyde 50-00-0 

Nitrogen dioxide 

Ozone 

Sulfur dioxide 

Sulfur trioxide 

10102-44-0 

10028-15-6 

7446-09-5 

7446-11-9 

Hydrocarbons 492 tons7 Benzene 71-43-2 

Ethylbenzene 

n-Hexane 

PAHs 

Toluene 

m-Xylene 

o-Xylene 

p-Xylene 

100-41-4 

100-54-3 

108-88-3 

108-38-3 

95-47-6 

106-42-3 

--

Particulate matter 24 tons8 Barium 7440-39-3 

Cadmium 

Copper 

Fine mineral fibers 

Lead 

Manganese 

Nickel 

POM 

Zinc 

7440-43-9 

7440-50-8 

7439-92-1 

7439-96-5 

7440-02-0 

7440-66-6 

--

--

Miscellaneous Materials 

Acids Unk Acetic anhydride 108-24-7 

Formic acid 

Sodium chromate 

Sulfuric acid 

64-18-6 

777-11-3 

7664-93-9 

Antifreeze, 

control, 

and dehydration agents 

heat 300 gal Acrolein 

Cupric sulfate 

Ethylene glycol 

Freon 

Phosphoric acid 

Potassium hydroxide 

Sodium hydroxide 

Triethylene glycol 

107-02-8 

7758-38-7 

107-21-1 

76-13-1 

766-38-2 

1310-58-3 

1310-73-2 

112-27-6 

Batteries Unk Cadmium 7440-43-9 

Cadmium oxide 

Lead 

Nickel hydroxide 

Potassium hydroxide 

Sulfuric acid 

1306-19-0 

7439-92-1 

7440-02-0 

1310-58-3 

7664-93-9 

Biocides Unk Formaldehyde 50-00-0 

Isopropyl alcohol 

Methanol 67-63-0 67-56-1 

Cleaners Unk Hydrochloric acid 7647-01-0 

Corrosion inhibitors Unk 4-4' methylene dianiline 101-77-9 

Acetic acid 

Ammonium bisulfite 

Basic zinc carbonate 

Diethylamine 

Dodecylbenzenesulfonic

acid 

Ethylene glycol

Isobutyl alcohol 

Isopropyl alcohol

Methanol 

Napthalene

Sodium nitrite 

Toluene 

Xylene 

64-19-7 

10192-30-0 

3486-35-9 

109-89-7 

27176-87-0 

107-21-1 

78-83-1 

67-63-0 

67-56-1 

91-20-3 

7632-00-0 

108-88-3 

1330-20-7 

Emulsion breakers Unk Acetic acid 64-19-7 

Acetone 

Ammonium chloride 

Benzoic acid 

Isopropyl alcohol 

Methanol 

Napthalene 

Toluene 

Xylene 

Zinc chloride 

67-64-1 

12125-02-9 

65-85-0 

67-63-0 

67-56-1 

91-20-3 

108-88-3 

1330-20-7 

7646-85-7 
_________________________________________________________________________________________________ 

--

--

--

--

--

--

--

--

--

--

--

_________________________________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

Fertilizers Unk Unk 

Herbicides Unk Unk 

Lead-free thread compound 25 gal Copper 

Zinc 

Lubricants Unk 1,2,4-trimethylbenzene 

Barium 

Cadmium 

Copper

n-Hexane 

Lead 

Manganese 

Nickel 

PAHs 

POM 

Zinc 

Methanol 200 gal Methanol 

Motor oil 220 gal Zinc compounds 

Paints Unk Aluminum 

Barium 

n-Butyl alcohol

Cobalt 

Lead 

Manganese 

PAHs 

POM 

Sulfuric acid 

Toluene 

Triethylamine

Xylene 

Photoreceptors Unk Selenium 

Scale inhibitors Unk Acetic acid 

Ethylene diamine tetra 

Ethylene glycol 

Formaldehyde 

Hydrochloric acid 

Isopropyl alcohol 

Methanol 

Nitrilotriacetic acid 

Sealants Unk 1,1,1-trichloroethane 

n-Hexane 

PAHs 

POM 

Solvents Unk 1,1,1-trichloroethane 

Acetone 

t-Butyl alcohol 

Carbontetrachloride 

Isopropyl alcohol 

Methyl ethyl ketone 

Methanol 

PAHs 

POM 

Toluene 

Xylene 

Starting fluid Unk Ethyl ether 

Surfactants Unk Ethylene diamine 

Isopropyl alcohol 

Petroleum naphtha 

7440-50-8 

7440-66-6 

95-63-6 

7440-39-3 

7440-43-9 

7440-50-8 

110-54-3 

7439-92-1 

7439-96-5 

7440-02-0 

7440-66-6 

67-56-1 

7429-90-5 

7440-39-3 

71-36-3 

7440-48-4 

7439-92-1 

7439-96-5 

7664-93-9 

108-88-3 

121-44-8 

1330-20-7Paraffin 

controlUnkCarbon 

disulfide 

Ethylbenzene 

Methanol 

Toluene 

Xylene75-15-0 

100-41-4 

67-56-1 

108-88-3 

1330-20-7 

7782-49-2 

64-19-7 

60-00-4 

107-21-1 

50-00-0 

7647-01-0 

67-63-1 

67-56-1 

139-13-9 

71-55-6 

110-54-3 

71-55-6 

67-64-1 

75-65-0 

56-23-5 

67-63-0 

108-10-1 

67-56-1 

108-88-3 

1330-20-7 

60-29-7 

107-15-3 

67-56-1 

8030-30-6 

1 lbs = pounds; gal = gallons; mmcfd = million cubic feet per day; bpd = barrels per day; Unk = unknown quantities to be listed based on information availability. 
_________________________________________________________________________________________________ 

_________________________________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

2 Hazardous substances are those constituents listed under the Consolidated List of Chemicals Subject to Reporting Under Title III of SARA 1986, as amended. 3 Extremely hazardous substances are those defined in 40 CFR 355. 4 PAHs = polynuclear aromatic hydrocarbons. 5 POM = polycyclic organic matter. 6 Value includes nitrogen oxides (NOx) (107 tons per well) and sulfur dioxide (SO2) (20 tons per well) emission estimates only, as adapted from BLM (1996). 7 Value includes volatile organic compound (VOC) emission estimates only, as adapted from BLM (1996). 8 Value includes particulate matter less than 10 microns diameter (PM10) emission estimates only, as adapted from BLM (1996).
______________________________________________________________________________ 

Hazardous Materials Summary, Continental Divide/Wamsutter II Project 1 

C-1.5 FUELS 

Diesel fuel, gasoline, Jet A Fuel, natural gas, and propane will be used for the project. All contain hazardous 

materials (Table C-1.1). Gasoline and diesel will be used by vehicles providing transport to and from the project 

area. Diesel, gasoline, and Jet A fuel will be used for geophysical survey operations. Diesel fuel will also be used 

in drilling operations and construction equipment, and as a minor component of fracturing fluids. Natural gas 

produced by the proposed project will be used to power pipeline compressor stations and other ancillary facilities. 

Propane will be utilized for miscellaneous heating purposes. 

C-1.5.1 Diesel Fuel 

Diesel fuel for use as a fuel will be used as described for gasoline. Each well location will have aboveground 

storage tanks containing diesel fuel during drilling operations. Tanks will be filled by a local fuel supplier. The 

use, transport, and storage of diesel fuel will be conducted in accordance with all relevant state and/or federal 

rules, regulations, and guidelines. 

C-1.5.2 Gasoline 

Gasoline is known to contain hazardous materials (Table C-1.1). Gasoline will be purchased from regional vendors 

and primarily will be stored and transported in vehicle gas tanks. Some additional gasoline storage may be 

provided in appropriately designed and labeled 1- to 5-gal containers for supplemental use as vehicle fuel. No 

large_scale storage of gasoline is anticipated. Tetraethyl lead, an extremely hazardous material, is present in 

leaded gasoline (regular). 

C-1.5.3 Jet A Fuel 

Jet A fuel is known to contain hazardous materials (Table C-1.1). Jet A fuel will be purchased from regional 

vendors and primarily will be stored and transported in vehicle tanks. Some additional storage may be provided in 

appropriately designed and labeled containers for supplemental use as fuel. No large_scale storage of Jet A fuel is 

anticipated. 

C-1.5.4 Natural Gas 

Natural gas produced on-site will be burned to provide power for compressor stations and other ancillary facilities. 

Hazardous materials are known to be present in natural gas (Table C-1.1). No extremely hazardous materials are 

known to exist in the natural gas from the project area. 

C-1.5.5 Propane 

The only hazardous material known to be present in propane is propylene (Table C-1.1). No extremely hazardous 

materials are known to be present. Propane will be purchased from regional vendors and will be stored and 

transported in appropriate propane tanks. No large-scale storage of propane is anticipated. 

C-1.6 GEOPHYSICAL SURVEY MATERIALS 

Geophysical survey operations, which are subject to separate environmental analyses for purposes of NEPA 

compliance, may be conducted on portions of the project area. Materials utilized for geophysical surveys that 

potentially contain hazardous materials are listed in Table C-1.1. Hazardous materials potentially contained in 

these products will be handled according to applicable state and federal regulations. 
______________________________________________________________________________ 

Hazardous Materials Summary, Continental Divide/Wamsutter II Project 1 

C-1.7 PIPELINE MATERIALS 

Gas produced from wells will be transported from each location through pipelines linking well locations to existing 

natural gas gathering systems. Industry standard pipeline equipment, materials, techniques, and procedures in 

conformance with all applicable regulatory requirements will be employed during construction, testing, operation, 

and maintenance of the project to ensure pipeline safety and efficiency. All necessary authorizing actions for 

natural gas pipelines will be addressed prior to installation. These actions include: 

• Carbon and Sweetwater Counties special use permits; 

• BLM rights-of-way (ROWs) applications; 

• conformance with Department of Transportation pipeline regulations 

(49C.F.R.191-192); and 

• Wyoming Public Service Commission Certificates to act as common carrier for natural gas. 

Materials utilized for pipeline construction, operation, and maintenance that may contain hazardous materials 

are listed in Table C-1.1. Hazardous materials associated with pipeline construction, operation, and 

maintenance will be handled in accordance with applicable state and federal regulations. 

C-1.8 EMISSIONS 

Emissions from combustion engines; well construction, completion, and production; and pipeline construction, 

operation, and maintenance will occur as a result of this project. Hazardous and extremely hazardous materials 

are known to be released directly or formed secondarily (i.e., ozone) from the construction and operation of natural 

gas wells and associated pipelines (Table C-1.1). Extremely hazardous emissions include nitrogen dioxide, sulfur 

dioxide, sulfur trioxide, and ozone (formed secondarily). No releases of these hazardous or extremely hazardous 

materials are anticipated to exceed quantities allowed for in Prevention of Significant Deterioration Class II areas 

of the WDEQ-Air Quality Division Implementation Plan, nor are combustion emissions expected to exceed 

Wyoming Ambient Air Quality Standards or National Ambient Air Quality Standards. Particulate matter emissions 

and larger unburned hydrocarbons will eventually settle out on the ground surface, whereas gaseous emissions will 

react with other air constituents as components of the nitrogen, sulfur, and carbon cycles. 

C-1.9 MISCELLANEOUS MATERIALS 

Miscellaneous materials potentially containing hazardous substances that may be used for the proposed project are 

listed in Table C-1.1. Quantities of these miscellaneous hazardous materials are unknown; however, no extremely 

hazardous substances are known to be present in any of these materials. Miscellaneous materials will be used 

during well construction and production operations; well, pipeline, and equipment maintenance; and reclamation 

activities. 
Record of Decision, Continental Divide/Wamsutter II 6 

C-2.0 MANAGEMENT POLICY AND PROCEDURE 

Each individual Operator will be responsible for ensuring that all production, use, storage, transport, and disposal of 

hazardous and extremely hazardous materials as a result of the proposed project will be in accordance with all 

applicable existing or hereafter promulgated federal, state, and local government rules, regulations, and guidelines. 

All project-related activities involving the production, use, and/or disposal of hazardous or extremely hazardous 

materials will be conducted to minimize potential environmental impacts. 

Each Operator will comply with emergency reporting requirements for releases of hazardous materials. Any 

release of hazardous or extremely hazardous substances in excess of the reportable quantity, as established in 40 

C.F.R. 117, must legally be reported as required by the Comprehensive Environmental Response, Compensation, 

and Liability Act of 1980 (CERCLA), as amended (42 U.S.C. 9601 et seq.). The materials for which such 

notification must be given are the extremely hazardous substances listed under the Emergency Planning and 

Community Right to Know Act, Section 302, and the hazardous substances designated under Section 102 of 

CERCLA, as amended. If a reportable quantity of a hazardous or extremely hazardous substance is released, 

immediate notice must be given to the BLM's Authorized Officer and all other appropriate federal and state 

agencies. Additionally, the Operator immediately will give notice of any spill or leakage, as defined in BLM 

NTL-3A, to the Authorized Officer and other such federal and state officials as required by law. Incidents requiring 

verbal notification by regulation will be given as soon as possible, but no later than 24 hours after discovery of the 

incident. Verbal notification will be confirmed in writing within 15 days or other such time required by the 

appropriate regulatory agency. 

Each Operator will prepare and implement, as necessary, the following plans and/or policies: 

• pursuant to 40 C.F.R. 112, Spill Prevention Control and Countermeasure Plans (SPCCPs) for those 

sites where SPCCPs are applicable; 

• Spill Response Plans (oil/condensate); 

• plans and inventories of hazardous chemical categories pursuant to

Section312 of SARA, as amended; and

• Emergency Response Plans. 

Copies of the above will be maintained with the Operators, as required by regulation, and will be made available 

upon request. 

Development operations are also required to be in compliance with regulations promulgated under the Resource 

Conservation and Recovery Act, Federal Water Pollution Control Act (Clean Water Act), Safe Drinking Water 

Act, Toxic Substances Control Act, Occupational Safety and Health Act, and the Federal Clean Air Act. In 

addition, project operations must comply with all attendant state rules and regulations relating to hazardous 

material reporting, transportation, management, and disposal. 
Record of Decision, Continental Divide/Wamsutter II 6 

C-3.0 LITERATURE CITED/ABBREVIATIONS AND ACRONYMS 

C-3.1 LITERATURE CITED 

Bureau of Land Management. 1996. Moxa Arch and Fontelle EISs Air Quality Technical Support Document. 

Cumulative Impact Analysis of Southwestern Wyoming Natural Gas Development Projects on Air Quality. 

Bureau of Land Management, Kemmerer and Green River Resource Areas, Rock Springs District, Rock Springs, 

Wyoming. 

.1998.Draft Environmental Impact Statement. Continental Divide/WamsutterII Natural Gas Project. Bureau of 

Land Management Great Divide Resource Area, Rawlins District, Rawlins, Wyoming, and Green River 

Resource Area, Rock Springs District, Rock Springs, Wyoming. 

C-3.2 ABBREVIATIONS AND ACRONYMS 

bpd barrels per day 

BLM Bureau of Land Management 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

C.F.R. Code of Federal Regulations 

EPA Environmental Protection Agency 

gal gallon(s) 

lbs pounds 

mmcfd million cubic feet per day 

NEPA National Environmental Policy Act 

NOx nitrogen oxides 

NTL Notice to Lessees 

PAHs polycyclic aromatic hydrocarbons 

PM10 particulate matter less than 10 microns diameter 

POM polycyclic organic matter 

RCRA Resource Conservation and Recovery Act 

ROWs rights-of-way 

SPCCPs Spill Prevention Control and Countermeasure Plans 

SARA Superfund Amendments and Reauthorization Act 

SO2 sulfur dioxide 

Unk unknown quantities to be listed based on information availability 

VOC volatile organic compound 

WDEQ Wyoming Department of Environmental Quality 

WOGCC Wyoming Oil and Gas Conservation Commission 

WSEO Wyoming State Engineer's Office 
APPENDIX D: 

WILDLIFE PROTECTION PLAN 

Modifications to this plan have been made pursuant to the U.S. Fish and Wildlife Service Biological 

Opinion and associated implementation protocol (AppendixG) and including Wyoming 

Bureau of Land Management Instruction Memorandum No. WY-2000-44 (Appendix I).
Record of Decision, Continental Divide/Wamsutter II 1 

WILDLIFE PROTECTION PLAN,

CONTINENTAL DIVIDE/WAMSUTTER II EIS

Prepared for 

U.S. Bureau of Land Management

Rawlins Field Office

Rawlins, Wyoming

and 

Rock Springs Field Office

Rock Springs, Wyoming

By 

TRC Mariah Associates Inc.

Laramie, Wyoming

MAI Project 1295

April 1999
Record of Decision, Continental Divide/Wamsutter II 2 

ABBREVIATIONS AND ACRONYMS 

ANS Artificial nesting structures 

APD Application for Permit to Drill 

APLIC Avian Powerline Interaction Committee 

BLM Bureau of Land Management 

CD/WIIPA Continental Divide/Wamsutter II Project Area 

CSU Controlled Surface Use 

EIS Environmental impact statement 

ft Foot (feet) 

GIS Geographic Information System 

LOP Life_of_project 

mi Mile(s) 

ROW Right_of_way 

SRA Sensitive resource area 

TEC&SC Threatened, endangered, candidate and other species of concern 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

WDEQ-LQD Wyoming Department of Environmental Quality, Land Quality 

Division 

WGFD Wyoming Game and Fish Department 

WNDDB Wyoming Natural Diversity Database 
Record of Decision, Continental Divide/Wamsutter II 2 

D-1.0 INTRODUCTION 

This wildlife monitoring/protection plan was prepared in conjunction with the environmental impact statement 

(EIS) for the Continental Divide/Wamsutter II Natural Gas Project, Sweetwater and Carbon Counties, 

Wyoming. The goal of the plan is to avoid and/or minimize adverse impacts to wildlife present on 

project-affected areas by monitoring wildlife population trends on the Continental Divide/Wamsutter II Project 

Area (CD/WIIPA) during the course of project development and operations and by developing appropriate 

mitigative actions. MapD_1.1 shows the location of the CD/WIIPA and associated wildlife monitoring areas. 

Implementation of the plan will allow land managers and project personnel opportunities to achieve and 

maintain desired levels of wildlife productivity and populations on the CD/WIIPA (e.g., at pre-project levels) 

by minimizing and/or avoiding potential adverse impacts to wildlife species. In addition, the implementation 

of this plan will facilitate the maintenance of a diverse assemblage of wildlife populations on the CD/WIIPA 

simultaneously with the development of natural gas reserves. 

The proposed Continental Divide/Wamsutter II Natural Gas Project involves the development of a maximum 

of 3,000 new well locations and associated facilities (roads, pipelines, compressor stations) on the CD/WIIPA 

over the next 20 years. The proposed life-of-project (LOP) is estimated to be from 30 to 50 years. Alternative 

development strategies also have been proposed (i.e., Proposed Action, 14-acre maximum surface disturbance 

per federally managed section in sensitive resource areas [SRAs], 30-acre maximum surface disturbance per 

federally managed section in SRAs, No Action). A complete description of the proposed project and 

alternatives is provided in Chapter 2.0 of the EIS. 

Proposed inventory, monitoring, and protection measures will be implemented under each potential 

development scenario (i.e., alternative), unless information revealed in the coordinated review of annual 

wildlife reports (see SectionD_2.1.1) indicates these measures are unnecessary for wildlife protection. This 

wildlife plan will not be implemented under the No Action Alternative. 

Implementation of the plan will begin in 1999, and it is estimated that implementation will continue for a 

maximum of 21 years; however, the plan may be terminated at the end of any year when there is sufficient 

evidence that wildlife populations and productivity in the CD/WIIPA have been successfully protected. The 

plan will receive a major review for effectiveness every 5 to 6 years (i.e, years 6, 11, 16, and 21 during 

implementation). 
Record of Decision, Continental Divide/Wamsutter II 2 

D-2.0 IMPLEMENTATION PROTOCOL 

This section provides preliminary wildlife inventory, monitoring, and protection protocol. A summary of primary 

protocol components is provided in TableD_2.1. Additional inventory, monitoring, and protection measures are 

provided for areas of intense development in TableD_2.2. Standard protocol for Application for Permit to Drill 

(APD) and right_of_way (ROW) application field reviews are provided in TableD_2.3. Alternative protocols 

likely will be developed in the future in response to specific needs identified in annual wildlife reports (see 

Section D-2.1.1). Methods are provided for each wildlife species/category, and additional species/categories may 

be added based on needs identified in annual wildlife reports. The wildlife species/categories for which specific 

inventory, monitoring, and protection procedures will be applied were developed based on management agency 

(i.e., Bureau of Land Management [BLM], U.S. Fish and Wildlife Service [USFWS], Wyoming Game and Fish 

Department [WGFD]) and individual concerns identified during the preparation of the EIS (see EIS Section 1.4). 

While considerable efforts will be required by agency and Operator (e.g., Amoco Production Company, Union 

Pacific Resources Company, Snyder Oil Corporation, etc.) personnel for plan implementation; it is anticipated 

that with the newly identified assistance provided by the Operators, this plan could be executed without 

considerable additional agency commitment. Many of the annually proposed agency data collection activities 

are consistent with current agency activities. Additionally, during annual planning (see SectionD-2.1) and 

throughout project implementation, all efforts will be made to accommodate agency personnel schedules and 

responsibilities, and further agency cost_sharing approaches will be considered such that public demands and 

statutory directives are achieved. 

D-2.1 ANNUAL REPORTS AND MEETINGS 

D-2.1.1 Reports 

During project development (i.e., 15 to 20 years), Operators will provide an annual inventory and description of 

all existing project features (i.e., location, size, and associated level of human activity at each feature), as well 

as those tentatively proposed for development during the next 12 months. This inventory will be submitted to the 

BLM by Operators no later than October 15 of each calendar year. These data will be coupled with annual 

wildlife inventory, monitoring, and protection data obtained for the previous year and included in annual reports. 

Annual reports will be prepared by the BLM. When annual wildlife inventory, monitoring, and protection data are 

gathered by parties other than the BLM, those parties (e.g., Operators, WGFD) will be requested to provide the 
Record of Decision, Continental Divide/Wamsutter II 2 

data to the BLM by October 15 of each calendar year. Upon receipt of these data, annual reports will be 

completed in draft form by the BLM and submitted to the Operators, USFWS, and other interested parties no later 

than November 15 of each year. A 1_day meeting of the aforementioned parties will be organized by the BLM 

and held in early December of each year to discuss and modify, as necessary, proposed wildlife inventory, 

monitoring, and protection protocol for the subsequent year. 

Decisions regarding annual Operator-specific financing and personnel requirements will be made at these 

meetings, and it is anticipated that a formula for determining these requirements will be developed at the first 

year's meeting. In addition, a protocol regarding how to accommodate previously unidentified development sites 

will also be determined during the first year's meeting. Final decisions will be made by the BLM based on the 

input of all affected parties. 

A final annual report will be issued by the BLM to all potentially affected individuals and groups by early 

February of each year. The first annual report will be submitted by February 15, 2001. 

Annual reports will summarize annual wildlife inventory and monitoring results, note any trends across years, 

identify and assess protection measures implemented during past years, specify monitoring and protection 

measures proposed for the upcoming year, and recommend modifications to the existing wildlife 

monitoring/protection plan based on the successes and/or failures of past years (e.g., identification of additional 

species/categories to be monitored). Where possible, the data presented in reports will be used to identify 

potential correlations between development and wildlife productivity and/or abundance. Addendum D-A provides 

examples for the tabular presentation of data within annual reports. The BLM's Geographic Information System 
1 

Record of Decision, Continental Divide/Wamsutter II 2 

Table D-2.1 Summary of General Wildlife Reporting, Inventory, and Monitoring, Continental Divide/ 

WamsutterII Natural Gas Project, Sweetwater and Carbon Counties, Wyoming, 1999. 

Action 

Annual area-wide tentative plan of 

development showing locations of 

existing and newly proposed 

development features 

Annual reports summarizing findings 

and presenting protection actions 

Meetings to finalize future year's 

inventory, monitoring, and protection 

measures 

Inventory and Monitoring 

Raptor nest inventories (CD/WIIPA 

plus 1_mi buffer) (excluding burrowing 

owls) 

Raptor productivity monitoring (at 

active nests within 1-mi of 

project-required disturbance areas on 

the CD/WIIPA plus 1-mi buffer) 

Aerial sage grouse lek inventories 

(CD/WIIPA plus 2_mi buffer) 

Sage grouse lek attendance monitoring 

on and within 2mi of the CD/WIIPA 

Big game crucial winter range use 

monitoring (crucial winter range on the 

CD/WIIPA plus a 1-mi buffer) 

Dates 

Annually by October 15 

Annually by: 

Draft - early November 

Final - early January 

Early December and as 

necessary 

Every 5 years during 

April_May 

Every 5 years during March to 

mid_July 

Every 5 years during 

March_April 

Annually during March _ 

mid_May 

As available 

Responsible Entity1 

Operators 

BLM with reviews by Operators, 

USFWS, and other interested 

parties 

BLM with participation by 

USFWS, Operators, and other 

interested parties 

BLM with Operator_provided 

financial assistance for aircraft 

rental 

BLM with Operator-provided 

financial assistance for aircraft 

rental, as necessary 

BLM surveyor with 

Operator_provided financial 

assistance for aircraft rental 

Selected leks will be visited at 

least once by the BLM, such that 

all known leks are visited every 

3years 

BLM will request available data 

from the WGFD 

With Operator assistance, it is anticipated that agency obligations will not greatly exceed currently 

approved personnel or financial commitments. 
1 

Record of Decision, Continental Divide/Wamsutter II 2 

Table D-2.2 Additional Wildlife Inventory and Monitoring Measures On and Adjacent to Areas with High 

Levels of Development ($4 Locations/Section), Continental Divide/Wamsutter II Natural Gas 

Project, Sweetwater and Carbon Counties, Wyoming, 1999. 

Action 

Raptor nest inventory/monitoring on 

areas with $4 locations/ection plus a 

1_mi buffer and selected undeveloped 

comparison areas 

Raptor productivity monitoring on areas 

with $4 locations/section plus a 1_mi 

buffer and selected undeveloped 

comparison areas 

Selected TEC&SC 

inventory/monitoring on suitable 

habitats in areas with $4 

locations/section plus a 1_mi buffer and 

selected undeveloped comparison areas 

Aerial sage grouse lek inventory on 

areas with $4locations/section plus a 

2-mi buffer and selected undeveloped 

comparison areas 

Sage grouse lek attendance monitoring 

on areas with $4 locations/section plus 

a 2-mi buffer and selected undeveloped 

comparison areas 

Other studies on areas with $8 

locations/section and selected 

undeveloped comparison areas 

Dates 

Annually during April and 

May 

Annually during March-July 

Annually during spring and 

summer 

Annually during March-April 

Annually during March to 

mid_May 

Year-long and in any year as 

deemed necessary by BLM 

and/or USFWS 

Responsible Entity1 

BLM surveyor with 

Operator_provided financial 

assistance for aircraft rental 

BLM surveyor with 

Operator_provided financial 

assistance for BLM volunteer 

support 

Operator-financed BLM-approved 

biologist 

BLM surveyor with 

Operator_provided financial 

assistance for aircraft rental 

Each known lek will be visited at 

least once annually by the BLM 

and/or an Operator-financed 

BLM-approved biologist; 

subsequent visits will occur at 

BLM-selected leks by the BLM, 

and/or Operator-financed 

BLM_approved biologist 

USFWS and/or BLM with 

Operator- and other party_provided 

financial assistance (Operator 

assistance will not exceed $5,000 

in any year) 

With Operator assistance, it is anticipated that agency obligations will not greatly exceed currently 

approved personnel or financial commitments. 
Record of Decision, Continental Divide/Wamsutter II 2 

Table D-2.3 Summary of General APD/ROW Application Stage Survey/Protection Measures, Continental 

Divide/Wamsutter II Natural Gas Project, Sweetwater and Carbon Counties, 1999. 

Protection Measure Dates Responsible Entity 

APD-stage general raptor nest survey/ inventory Yearlong BLM, Operators 

within 0.75 to 1.0 mi of proposed disturbance 

APD-stage seasonal raptor nest avoidance within 0.5 February 1 - July 31 Operators, BLM 

to 1.0 mi of active nests (seasonal restriction) 

APD-stage general raptor nest avoidance within 825 Yearlong (Controlled Surface Use Operators, BLM 

ft of active nests (1,200 ft for active ferruginous [CSU] generally excluding surface 

hawk nests) disturbance) 

APD-stage TEC&SC surveys (within 0.5mi of As necessary BLM or Operators 

proposed disturbance sites) 

APD-stage TEC&SC avoidance As necessary Operators, BLM 

APD-stage prairie dog colony mapping and burrow As necessary Operators, BLM 

density determinations 

Black-footed ferret habitat (i.e., prairie dog colony) Where practical Operators, BLM 

avoidance 

Black-footed ferret surveys where suitable habitat As necessary in appropriate season no Operator-financed 

must be disturbed more than 1 year prior to disturbance USFWS_approved biologist 

APD-stage mountain plover surveys (within 200 m of As necessary between April 15 and BLM or Operator_financed 

proposed disturbance) June 30 BLM_approved biologist 

Mountain plover nest/brood avoidance As necessary Operators, BLM 

APD-stage western burrowing owl surveys (within As necessary during June_August BLM or Operator_financed 

0.5 mi of proposed disturbance sites) BLM_approved biologist 

Western burrowing owl nest avoidance As necessary Operators, BLM 

APD-stage sage grouse lek surveys on suitable March 1 _ mid-May Operators, BLM 

habitats within 2mi of proposed disturbance sites 

APD-stage sage grouse lek avoidance on areas March 1 - June 30 Operators, BLM 

within 2.0 mi of a lek 

APD-stage sage grouse lek avoidance on areas Yearlong (CSU generally excluding Operators, BLM 

within 0.25 mi of a lek surface disturbance) 

APD-stage sage grouse nest avoidance As necessary Operators, BLM 

Big game crucial winter range avoidance November 15 _ April 30 Operators, BLM 

APD-stage general wildlife avoidance/protection As necessary Operators, USFWS, BLM 
Record of Decision, Continental Divide/Wamsutter II 2 

(GIS) will be used for information storage, retrieval, and planning, and annual GIS data updates will be 

conducted. Raw data collected each year also will be provided to other management agencies (e.g., WGFD, 

USFWS, Wyoming Natural Diversity Database [WNDDB]) at the request of these agencies. In addition, 

sources of potential disturbance to wildlife will be identified, where practical (e.g., development activities, 

weather conditions, etc.). 

Additional reports may be prepared in any year, as necessary, to comply with other relevant wildlife laws, 

rules, and regulations (e.g., black-footed ferret survey reports [see SectionD_2.2.2.1]). 

D-2.1.2 Additional Meetings 

Meetings will be held as necessary in any given year by the BLM, Operators, and/or USFWS in Rawlins to 

inform and update Operator personnel on the findings of the annual reports. Other management agencies and 

user groups (e.g., WGFD, landowners, grazing permittees, recreationists) will also be invited to attend 

meetings and cooperate in the implementation of this plan. Relevant wildlife laws, rules, and regulations may 

be discussed, as will project-specific wildlife monitoring and protection protocol for the upcoming year. 

Operators and other interested parties will have the opportunity to provide annual input regarding proposed 

inventory, monitoring, and protection measures; however, the BLM will maintain the authority for determining 

the final nature of these activities in any given year. Additional information on the nature of the wildlife 

present in the CD/WIIPA, potential impacts to wildlife, appropriate Operator responses to wildlife encounters 

to avoid or minimize impacts, and other items (e.g., species identification) also may be presented at these 

meetings as deemed necessary and specified in annual reports. 

D-2.2 ANNUAL INVENTORY AND MONITORING 

Inventory and monitoring protocol will be as identified below for each wildlife species/category. These 

protocol will be unchanged across development alternatives, except as authorized by the BLM or specified in 

this plan. Additional wildlife species/categories and associated surveys may be added or wildlife 

species/categories and surveys may be omitted in future years, pending results presented in the coordinated 

review of annual wildlife reports. The WGFD will be contacted during the coordination of survey and other 

data acquisition phases. Opportunistic wildlife observations may be made throughout the year by agency and 

Operator personnel present in the CD/WIIPA. 

The frequency of inventory and monitoring will be dependent upon the level of development in the CD/WIIPA 

(see Tables D_2.1 and D_2.2). In general, inventory and monitoring frequency will increase with increased 

levels of development. Inventory and monitoring results may lead to further currently unidentifiable studies 

(e.g., scientific studies specifically designed to determine cause and effect). The following sections identify 

the minimum level of effort required by this wildlife plan. Site- and species-specific surveys will continue to 

be conducted in association with APD and ROW application field reviews (see TableD_2.3). 

D-2.2.1 Raptors 

Raptor inventories of potentially affected areas (see MapD_1.1 and TableD_2.1) will be conducted in 

April/May of 1998 and every 5 years thereafter for the LOP to determine the location of raptor nests/territories 

and their activity status by the BLM. Known raptor concentration areas and approximate nest locations on and 

adjacent to the CD/WIIPA are shown on MapD_2.1. These surveys may be implemented aerially (e.g., via 

helicopter) or from the ground. Operators will provide financial assistance for aircraft rental. Data collected 

during the surveys will be recorded on Raptor Nesting Record, Raptor Observation Data Sheets, or other 

similar data forms (see Addendum D-B). (Burrowing owl survey requirements are discussed in Section 

D-2.2.2.4). 
Record of Decision, Continental Divide/Wamsutter II 2 

Nest productivity monitoring will be conducted by the BLM at active nests that are located within 1 mi of 

project-required disturbance areas between March 1 and mid-July to determine nesting success (i.e., number of 

nestlings/fledglings). These surveys generally will be conducted from the ground, and attempts will be made 

to determine the cause of any documented nest failure. Operators will provide financial assistance for aircraft 

rental, as necessary. 

Additional raptor nest activity and productivity monitoring measures will be applied in areas with high levels 

of development (i.e., areas with $ 4 locations/section) on and within 1 mi of the CD/WIIPA (see TableD_2.2). 

Inventory/monitoring efforts in these areas, as well as selected undeveloped comparison areas, will be 

conducted annually during April and May, followed by nest productivity monitoring. Site_ and 

species_specific raptor nest inventories will also continue to be conducted as necessary in association with all 

APD and ROW application field reviews (see TableD_2.3). 

All raptor nest/productivity surveys will be conducted using procedures that minimize potential adverse effects 

to nesting raptors. Specific survey measures for reducing detrimental effects are listed in Grier and Fyfe 

(1987) and Call (1978) and include the following. 

• Nest visits will be delayed for as long as possible in the nesting season. 

• Nests will be approached cautiously, and their status (i.e., number of nestlings/fledglings) will 

be determined from a distance with binoculars or a spotting scope. 

• Nests will be approached tangentially and in an obvious manner to avoid startling adults. 

• Nests will not be visited during adverse weather conditions (e.g., extreme cold, precipitation 

events, windy periods, hottest part of the day). 

• Visits will be kept as brief as possible and in no instance will be greater than 10 minutes. 

• All inventories will be coordinated by the BLM. 

• The number of nest visits in any year will be kept to a minimum. 

• All raptor nest location data will be considered confidential. 

D-2.2.2 Threatened, Endangered, Candidate, and Other Species of Concern 

The level of inventory/monitoring required for threatened, endangered, candidate, and other species of concern 

(TEC&SC) will be commensurate with established protocol for the potentially affected species. Survey 

protocol developed in conjunction with the Biological Assessment for this project (see EIS Appendix E) will 

be conducted as a component of this wildlife protection plan. Methodologies and results of these surveys will 

be included in annual reports or provided in separate supplemental reports. A preliminary list of TEC&SC 

species proposed for management and known from or potentially occurring in the vicinity of the CD/WIIPA is 

shown on TableD_2.4. As TEC&SC species are added to or withdrawn from USFWS, BLM, and/or WGFD 

lists, appropriate modifications will be incorporated to this plan and specified in annual reports. Additional 

species of concern known from or potentially occurring in the vicinity of the CD/WIIPA are shown on 

TableD_2.5. 

TEC&SC data collected during the surveys identified in Tables D-2.2 and D-2.3 and described below will be 

considered confidential and will be provided only as necessary to those requiring the data for specific 

management and/or project development needs. Site- and species_specific TEC&SC surveys will continue to 

be conducted as necessary in association with all APD and ROW application field reviews (see TableD_2.3). 

Data will be collected on appropriate General Wildlife Observation Data Sheets or other similar forms (see 

Addendum D-B). Alternate/additional forms may be used as specified by the BLM. 
Record of Decision, Continental Divide/Wamsutter II 2 

D-2.2.2.1 Black-footed Ferret 

BLM-approved Operator-financed biologists will determine the presence/absence of prairie dog colonies at 

each proposed development site during APD and ROW application field revisions (see TableD_2.3). Sections 

with current and/or historic prairie dog colonies are shown on MapD_2.2. Prairie dog colonies (i.e., potential 

black-footed ferret habitat) on the area will be mapped and burrow densities determined by a BLM_approved 

Operator_financed biologist, as necessary and in association with proposed development plans (i.e., APD and 

ROW application reviews). Colonies that meet USFWS criteria as potential black-footed ferret habitat 

(USFWS 1989) will be surveyed for black-footed ferrets by an USFWS-certified Operator_financed surveyor 

prior to BLM authorizing disturbance of these colonies. Surveys will only be conducted as deemed necessary 

during consultation with the BLM and/or USFWS. Black-footed ferret surveys will be conducted in 

accordance with USFWS guidelines (USFWS 1989) and will be conducted on a site_specific basis, depending 

on the areas proposed for disturbance in a given year as specified in the annual report. 

D-2.2.2.2 Bald Eagle, Peregrine Falcon, and Ferruginous Hawk 

Inventory and monitoring protocol for bald eagle, peregrine falcon, and ferruginous hawk will be as described 

for raptors (see Section D-2.2.1). 

D-2.2.2.3 Mountain Plover 

Suitable mountain plover habitat (i.e., areas with vegetation less than 4 inches high) within 656 ft (200 

meters) of proposed disturbance areas (as identified in annual wildlife reports) will be surveyed within 2 weeks 

of disturbance by the BLM or a BLM_approved Operator_financed Operator biologist to detect the presence of 

plovers (see TableD_2.3). Surveys will be conducted on these areas during the period of April 15 through June 

30. If plovers are not found, no additional surveys will be conducted. If plovers are discovered, observations 

will continue for sufficient duration to determine if a mountain plover nest is present. If no nesting is 

discovered, no additional surveys will be conducted. If nesting is discovered, surveys will be conducted on 

and within 656 ft of areas proposed for development during the period of April 15 through June 30 no more than 

14 days prior to the date that ground_disturbing activities are initiated. If development is proposed for the 

period of April 15 through April 30 or June 15 through June 30, a single survey will be required; however, if 

ground-disturbing activities are proposed for the period of May 1 through June 15, three surveys will be 

required. If three surveys are required, these surveys will be made at least 14 days apart, with the last survey 

no more than 14 days prior to the initiation of ground-disturbing activities. Where access roads and/or well 

locations have been constructed prior to the mountain plover nesting season and use of these areas has not 

been initiated for development actions, site investigations of these disturbed areas will be conducted prior to 

use to determine whether mountain plover are present. 

D-2.2.2.4 Western Burrowing Owl 

In association with APD and ROW application field reviews, prairie dog colonies and other suitable burrowing 

owl nesting areas (i.e., areas with large numbers of ground squirrel burrows) on and within 0.5 mi of existing 

and proposed disturbance areas will be searched for western burrowing owls by the BLM or a BLM_approved 

Operator_financed biologist during June through August to determine the presence or absence of owl nesting 

(see TableD_2.3). Efforts will be made to determine reproductive success. 

D-2.2.2.5 Other TEC&SC Species 

Surveys for other TEC&SC species will be conducted by the BLM or a BLM_approved Operator_financed 

biologist in areas of potential habitat within 0.5 mi of proposed disturbance sites prior to disturbance (see 

TableD_2.3). These surveys may be implemented in conjunction with surveys for other species or as 
Record of Decision, Continental Divide/Wamsutter II 2 

components of APD and/or ROW application processes. In addition, in areas where four or more surface 

locations are developed, the entire section plus a 1.0_mi buffer, as well as selected undeveloped comparison 

areas, will be surveyed annually during spring and summer by a BLM_approved Operator_financed biologist 

for selected TEC&SC species (see TableD_2.2). If any TEC&SC species are observed, the observations will 

be noted on appropriate data forms (see Addendum D-B). In addition, when and if TEC&SC species are 

observed, efforts will be made to determine their activities (e.g., breeding, nesting, foraging, hunting, etc.). If 

any management agency (e.g., BLM, USFWS) identifies a potential for concern regarding any of these 

species, additional inventory and monitoring may be implemented as specified in annual reports. 

D-2.2.3 Sage Grouse 

Sage grouse lek inventories will be conducted on the CD/WIIPA and a 2-mi buffer to determine lek locations 

every 5 years (see TableD_2.1). The approximate locations of known leks on the area are shown on 

MapD_2.3. Inventories will be conducted by the BLM and will be implemented two times, a minimum of 10 

days apart, during March and April every fifth year of this plan. Surveys may be conducted aerially, with 

Operator_provided financial assistance for aircraft rental, or on the ground, as deemed appropriate by the 

BLM; aerial surveys will be used only to determine lek locations. In areas with four or more well locations per 

section, aerial inventories will be conducted annually on affected sections, 2-mi buffers, and selected 

undeveloped comparison areas (see TableD_2.2). 

Selected leks within 2 mi of existing and proposed disturbance areas will be monitored annually to determine 

lek attendance by the BLM between March 1 and May 15, such that all leks on these areas are monitored at 

least once every 3 years (see TableD_2.1). In the event that more than four well locations occur within a 

section the responsibility for lek monitoring will include a BLM-approved, Operator_financed biologist (see 

TableD_2.2). Monitoring efforts will be implemented at all leks present on affected sections, 2_mibuffers, and 

selected undeveloped comparison areas. The BLM will direct lek monitoring efforts (timing, locations) such 

that all efforts are made to have the same individuals monitor the same leks within and across years. Data 

collected during these surveys will be provided on Sage Grouse Lek Records or other suitable forms (see 

AddendumD-B). 

Standard site- and species_specific sage grouse lek surveys will continue to be conducted as necessary in 

association with all APD and ROW application field reviews (see TableD_2.3). 

D-2.2.4 Big Game Crucial Winter Range Use 

To determine the need for the application of crucial winter range seasonal stipulations and assess potential 

impacts to big game species occurring on the CD/WIIPA, data on big game use of crucial winter ranges on the 

CD/WIIPA and an adjacent 1-mi buffer will be requested annually by the BLM from the WGFD, as deemed 

necessary by the BLM (see TableD_2.1). Big game crucial winter ranges are shown on MapD_2.4. 

D-2.2.5 Other Inventory and Monitoring Measures 

Additional inventory and monitoring measures may be applied as specified in annual reports. In areas where 

development levels reach eight or more well locations per section, it is anticipated that detailed cause and effect 

studies will be implemented (see TableD_2.2). Actions also may be applied for passerine birds, herpetiles, 

lagomorphs, and small mammals. Surveys will be conducted in adherence with protocol to be established by the 

BLM, USFWS, and Operators and may be similar to procedures specified by the Wyoming Department of 

Environmental Quality-Land Quality Division (WDEQ-LQD) for surface coal mine baseline studies (WDEQ-LQD 

1995). Operator financial assistance for these investigations will not exceed $5,000 in any year. 
Table D-2.4 Threatened, Endangered, Candidate, and Species of Concern Proposed for Management and Documented or Potentially Occurring on 

or in the Vicinity of the Continental Divide/Wamsutter II Natural Gas Project Area, 1999.1 

Species Status2, 3 Documented on or in Habitat Type(s)5 

Vicinity of the CD/WIIPA4 

Common Name Scientific Name USFWS BLM WGFD WNDDB 

Peregrine falcon Falco peregrinus LE X X X Yes6 UB 

Whooping crane Grus americana LE X X X No FT 

Black_footed ferret Mustela nigripes LE X X X Yes7 BS, BG, SB, DS, 

MG 

Bald eagle Haliaeetus leucocephalus LT X X X Yes UB 

Mountain plover Charadrius montanus C X X X Yes6 DS, MG 

White-faced ibis Plegadis chihi SC X X -- No FT(P/R) 

Swift fox Vulpes velox C X X X Yes7 MG, SR 

Northern goshawk Accipiter gentilis SC X X X Yes6 FT 

Ferruginous hawk Buteo regalis SC X X X Yes6 UB

Western burrowing owl Athene cunicularia hypugaea SC X -- X Yes6 BS, BG, SB, DS,

MG 

Loggerhead shrike Lanius ludovicianus SC X -- X Yes6 UB 

Turkey vulture Cathartes aura -- X -- -- Yes6 UB 

Osprey Pandion haliaetus -- X -- -- No FT 

Northern harrier Circus cyaneus -- X -- -- Yes6 UB 

Sharp_shinned hawk Accipiter striatus -- X -- -- Yes6 FT 

Cooper's hawk Accipiter cooperii -- X -- -- Yes6 FT 

Swainson's hawk Buteo swainsoni -- X -- -- Yes6 PJ, SR 

Red_tailed hawk Buteo jamaicensis -- X -- -- Yes6 UB

Rough_legged hawk Buteo lagopus -- X -- -- Yes UB

Golden eagle Aquila chrysaetos -- X -- -- Yes6 UB

American kestrel Falco sparverius -- X -- -- Yes6 UB

Merlin Falco columbarius -- X X X Yes6 UB
Prairie falcon Falco mexicanus -- X -- -- Yes6 UB 

Barn owl Tyto alba -- X -- X Yes UB 

Great horned owl Bubo virginianus -- X -- -- Yes6 UB 

Long_eared owl Asio otus -- X -- -- Yes6 UB 

Short_eared owl Asio flammeus -- X -- -- Yes6 UB 

Common loon Gavia immer -- X X X Yes FT (SR) 

American white pelican Pelecanus erythrorhynchos -- X X X Yes SR 

American bittern Botaurus lentiginosus -- X X X Yes FT (SR) 

Snowy egret Egretta thula -- X X X Yes FT (SR) 

Black_crowned night heron Nycticorax nycticorax -- X X X Yes FT (SR) 

Long_billed curlew Numenius americanus -- X X X Yes6 BS, SR, MG 

Caspian tern Sterna caspia -- X X X Yes FT (SR) 

Forster's tern Sterna forsteri -- X X X Yes FT (SR) 

Yellow_billed cuckoo Coccyzus americanus -- X X X No FT 

Lewis' woodpecker Melanerpes lewis -- X X X Yes6 SR, PJ 

Ash_throated flycatcher Myiarchus cinerascens -- X X X Yes6 PJ, FT 

Scrub jay Aphelocoma coerulescens -- X X X Yes6 PJ, FT 

Plain titmouse Parus inornatus -- X X X Yes6 PJ, FT 

Bushtit Psaltriparus minimus -- X X X Yes6 PJ, FT 

Scott's oriole Icterus parisorum -- X X X Yes6 PJ, FT 

Dwarf shrew Sorex nanus -- X X X Yes6 UB 

Vagrant shrew Sorex vagrans -- X X -- No SR, BS, SB, BG 

Little brown myotis Myotis lucifugus -- X X -- Yes UB 

Big brown bat Eptesicus fuscus -- X X -- Yes UB 

Pallid bat Antrozous pallidus -- X X X Yes UB 

Cliff chipmunk Tamias dorsalis -- X X X Yes6 SR, PJ, BS 

Canyon mouse Peromyscus crinitus -- X X X No PJ, B/R 

Pinyon mouse Peromyscus truei -- X X X Yes6 BS, B/R, PJ 
Northern leopard frog Rana pipiens -- X X -- Yes SR 

Northern plateau lizard Sceloporus undulatus elongatus -- X X -- Yes BS, B/R 

Northern tree lizard Urosaurus ornatus -- X X -- Yes BS, B/R 

Great Basin gopher snake Pituophis melanoleucus -- X X -- Yes UB 

deserticola 

Midget faded rattlesnake Crotalus viridis concolor -- X X -- Yes BS 

1 Wyoming Natural Diversity Database (WNDDB) searches (1995, 1997); U.S. Fish and Wildlife consultation (1995, 1997); Wyoming Game and Fish Department 

(WGFD) list of priority species (1997); and Fertig (1997). 

2 USFWS = U.S. Fish and Wildlife Service, WGFD = Wyoming Game and Fish Department, WNDDB = Wyoming Natural Diversity Database, and BLM = Bureau of Land 

Management. 

3 LE = USFWS listed endangered, LT = USFWS listed threatened, WNDDB; C = USFWS candidate species (proposed threatened), SC = USFWS species of concern, 

X=given special status by the agency listed (i.e., WGFD, WNDDB, and/or BLM species of concern). 

4 Indicates documentation of amphibian, reptile, or plant species in Sweetwater or Carbon County (Baxter and Stone 1980; Fertig 1997); documentation of bird species 

within latitude 41E, longitude 107_109E (Dorn and Dorn 1990; WGFD 1992, 1996); and/or documentation of mammal species within latitude 41E, longitude 

107_109E (WGFD 1992, 1996). 

5 As described in Section 3.2.1 of the EIS: BS = big sagebrush, BG = black greasewood, DS = desert shrub, B/R = basin/exposed rock, SB = saltbush, SR = 

shrub_dominated riparian, MG = mixed grass prairie, UP=unvegetated playa, PJ = small pockets of pine and/or juniper woodland, UB=ubiquitous, FT=flythrough. 

6 Species has been documented breeding within latitude 41E, longitude 107_109E (Dorn and Dorn 1990; WGFD 1992). 

7 Documentation of historical observation only (WGFD 1992; WNDDB 1995). 
Table D-2.5 Other Species of Concern Documented or Potentially Occurring on or in the Vicinity of the Continental Divide/Wamsutter II Natural 

Gas Project Area, 1999.1 

Species Status1, 2 Documented on or in Vicinity of Habitat Type(s)5

the CD/WIIPA4

Common Name Scientific Name USFWS WNDDB

Western boreal toad Bufo boreas boreas SC -- Yes SR, P/R

Trumpeter swan Cygnus buccinator SC -- Yes FT(P/R)

Black tern Chlidonias niger SC -- Yes FT(P/R)

Small_footed myotis Myotis ciliolabrum SC -- Yes BS, BG, DS, B/R, SR,

MG, PJ 

Long_eared myotis Myotis evotis SC -- Yes BS, BG, DS, SB, SR, PJ 

Long_legged myotis Myotis volans SC -- Yes SR, PJ 

Spotted bat Euderma maculatum SC -- No BS, BG, DS, B/R, SB, 

P/R

Townsend's big_eared bat Plecotus townsendii SC -- Yes DS, PJ

Pygmy rabbit Sylvilagus idahoensis SC -- Yes BS, SR

Eastern shorthorned lizard Phrynosoma douglassi -- X Yes UB

brevirostre 

Northern sagebrush lizard Scleporus graciosus -- X Yes BS, BG, SB, DS, B/R 

Columbian sharp-tailed grouse Tympanuchus phasianellus -- X Yes6 BS, BG, SB, SR, MG 

columbianus

Common tern Sterna hirundo -- X Yes FT (SR)

Baird's sparrow Ammodramus bairdii -- X No FT (MG)

Horned grebe Podiceps auritus -- X Yes FT (P/R)

Red_necked grebe Podiceps grisegena -- X Yes FT (P/R)

Clark's grebe Aechmophorus clarkii -- X Yes FT (P/R)

Ring-necked duck Aythya collaris -- X Yes FT (P/R)

Common goldeneye Bucephala clangula -- X Yes SR
Bufflehead Bucephala albeola -- X Yes SR 

Red_breasted merganser Mergus serrator -- X Yes FT (SR) 

Virginia rail Rallus limicola -- X Yes6 FT (SR) 

Western snowy plover Charadrius alexandrinus -- X Yes6 FT (SR) 

Piping plover Charadrius melodus -- X Yes FT 

Black_necked stilt Himantopus mexicanus -- X Yes6 FT (SR) 

Upland sandpiper Bartramia longicauda -- X Yes FT (MG) 

Red_necked phalarope Phalaropus lobatus -- X Yes FT (SR) 

Franklin's gull Larus pipixcan -- X Yes FT (SR) 

Ring_billed gull Larus delawarensis -- X Yes FT 

California gull Larus californicus -- X Yes FT 

Herring gull Larus argentatus -- X Yes FT (SR) 

Black_tailed cuckoo Coccyzus erythropthalmus -- X Yes FT 

Black_chinned hummingbird Archilochus alexandri -- X Yes6 SR, PJ 

Three_toed woodpecker Picoides tridactylus -- X Yes6 FT 

Blue_gray gnatcatcher Polioptila caerulea -- X Yes6 PJ, SR 

Eastern bluebird Sialia sialis -- X Yes6 SR, PJ, MG 

Red_eyed vireo Vireo olivaceus -- X Yes6 FT 

Virginia's warbler Vermivora virginiae -- X Yes6 PJ, FT 

Black-throated gray warbler Dendroica nigrescens -- X Yes6 PJ, FT 

Blue grosbeak Guiraca caerulea -- X Yes FT (SR) 

Indigo bunting Passerina cyanea -- X Yes BS, BG, SB, SR 

Dickcissel Spiza americana -- X No FT 

Clay_colored sparrow Spizella pallida -- X Yes FT (SR, PJ) 

Black_throated sparrow Amphispiza bilineata -- X No FT 

Chestnut_collared longspur Calcarius ornatus -- X Yes FT 
Bobolink Dolichonyx oryzivorus -- X Yes6 BS, BG, SB, SR, MG 

Red bat Lasiurus borealis -- X Yes FT 

Hoary bat Lasiurus cinereus -- X Yes UB 

Allen's thirteen-lined Spermophilus tridecemlineatus -- X Yes6 UB 

groundsquirrel alleni 

Spotted ground squirrel Spermophilus spilosoma -- X Yes6 BS, SB, MG 

White_tailed prairie dog Cynomys leucurus -- X Yes6 BS, BG, SB, DS, MG 

Wyoming pocket gopher Thomomys clusius -- X Yes6 BG, BR, SB, DS 

Silky pocket mouse Perognathus flavus -- X Yes6 UB 

Great Basin pocket mouse Perognathus parvus -- X Yes6 BS, BG, SB, SR 

White_footed mouse Peromyscus leucopus -- X No UB 

Western spotted skunk Spilogale gracilis -- X No BS, BG, SB, SR, MG 

1 Wyoming Natural Diversity Database (WNDDB) searches (1995, 1997); U.S. Fish and Wildlife consultation (1995, 1997); Wyoming Game and Fish Department 

(WGFD) list of priority species (1997);and Fertig (1997). 

2 USFWS = U.S. Fish and Wildlife Service, WNDDB = Wyoming Natural Diversity Database. 

3 SC = USFWS species of concern, X = given special status by the agency listed (i.e., USFWS, WNDDB). 

4 Indicates documentation of amphibian, reptile, or plant species in Sweetwater or Carbon County (Baxter and Stone 1980; Fertig 1997); documentation of bird species 

within latitude 41E, longitude 107_109E (Dorn and Dorn 1990; WGFD 1992, 1996); and/or documentation of mammal species within latitude 41E, longitude 

107_109E (WGFD 1992, 1996). 

5 As described in Section 3.2.1 of the EIS: BS = big sagebrush, BG = black greasewood, DS = desert shrub, B/R = basin/exposed rock, SB = saltbush, SR = 

shrub_dominated riparian, MG=mixed grass prairie, UP=unvegetated playa, PJ = small pockets of pine and/or juniper woodland, UB=ubiquitous, P/R = pond/riparian, 

FT=flythrough. 

6 Species has been documented breeding within latitude 41E, longitude 107_109E (Dorn and Dorn 1990; WGFD 1992). 

7 Documentation of historical observation only (WGFD 1992; WNDDB 1995). 
Record of Decision, Continental Divide/Wamsutter II 2 

D-2.2.6 General Wildlife 

BLM staff will be responsible for keeping records of selected wildlife species observed during the course of 

their activities on the CD/WIIPA, and interested Operator personnel may also provide data on wildlife 

observations. The information provided will include observations of wildlife species, their numbers, location, 

activity, and other pertinent data as applicable and identified on the General Wildlife Observation Data Sheet 

presented in Addendum D-B of this plan. Some of the desired information may be difficult for Operators to 

define (e.g., specific locations in U.S. Geological Survey [USGS] coordinates, species type for hard to 

recognize species [passerine birds and small mammals], sex). Where Operators are uncertain of the USGS 

coordinates for an observation, a general description of the location may be provided (e.g., 100 yards north of 

well #___), and in instances where species or sex information are questionable, Operators will identify the 

observation as such. 

D-2.3 PROTECTION MEASURES 

The wildlife protection measures proposed herein have been developed from past measures identified for oil 

and gas developments in Wyoming. Additional measures may be included and/or existing measures may be 

modified in any given year as allowable and as deemed appropriate by BLM in consultation with Operators 

and other interested parties, and these measures will be specified in annual reports. It is assumed that as the 

wildlife of the CD/WIIPA are further described and impacts identified, some protection measures will be 

removed, whereas others may be added. Protection measures will be implemented by Operators with 

assistance from and/or in consultation with the BLM. In addition, these measures may be modified on a 

site_specific basis as deemed appropriate by the BLM after completion of APD and ROW application field 

reviews. 

The principle protection measure for most wildlife species will be avoidance of sensitive/crucial habitats (e.g., 

big game crucial winter ranges, raptor nests, sage grouse leks), where possible. However, numerous species_ 

and project-specific measures may be implemented. Additionally, general wildlife protection measures (see 

SectionD_2.3.5) will likely benefit the majority of wildlife species found on and adjacent to the CD/WIIPA. 

D-2.3.1 Raptors 

The primary protection measure for raptor species on the CD/WIIPA will be avoidance of active nest locations 

during the breeding season. Active nests are defined as any raptor nest that has been used within the last 3 

years. Depending upon the timing of proposed construction and drilling activities, all surface-disturbing 

activities will be restricted from February 1 through July 31 within a 0.5- to 1.0_mi radius (depending upon 

species and site_specific conditions) of active or occupied raptor nests/nesting territories (i.e., seasonal nest 

avoidance). This measure may be excepted where raptor pairs are documented using alternate nests greater 

than 1.0 mi from the surface disturbance area within a nesting territory. In addition, well locations, roads, 

ancillary facilities, and other surface structures requiring a repeated human presence will not be constructed 

within 825 ft of active raptor nests, except ferruginous hawk, where the restriction will be to 1,200 ft 

(restrictions will generally exclude surface disturbance). The seasonal buffer distance and exclusion dates 

may vary, depending on factors such as nest activity status, species, prey availability, natural topographic 

barriers, and line-of-sight distances. Actual nest buffers for each active raptor nest will be established in 

annual reports. 

Operators will notify the BLM immediately if raptors are found nesting on or within 1,200ft of project 

facilities, and Operators will assist the BLM as necessary in erecting artificial nesting structures (ANSs), as 

appropriate. The use of ANSs will be considered as a last resort for raptor protection. If nest manipulation or a 

situation requiring a "taking" of a raptor nest becomes necessary, a special permit will be obtained from the 
Record of Decision, Continental Divide/Wamsutter II 2 

Denver USFWS Office, Permit Section. Permit acquisition will be coordinated with the Wyoming State 

USFWS Office in Cheyenne and will be initiated with sufficient lead time to allow for development of 

mitigation. Required corresponding permits will be obtained from the WGFD in Cheyenne. Consultation and 

coordination with the USFWS and WGFD will be conducted for all protection activities relating to raptors. 

If it is found that project activities could potentially affect raptor nesting on or adjacent to the CD/WIIPA as 

determined from decreased raptor productivity or nesting or documented nest abandonment or failure, ANSs 

may be constructed at a rate of up to two ANSs for one impacted nest, or existing degraded raptor nests may 

be upgraded/reinforced to minimize potential impacts. The location, design, and other pertinent data regarding 

ANSs or nests proposed for upgrading will be identified in annual reports, and these ANSs will be located 

within the nesting territory of potentially affected raptor pairs and outside of the line-of-sight or nest buffer of 

actively nesting pairs, where possible. Operators will be responsible for the annual maintenance of ANSs 

throughout the LOP. Annual ANS maintenance activities will be completed after August 1 and prior to 

October 15 each year, as necessary. ANSs will be placed within the nesting territories of potentially affected 

raptor pairs at sites sufficiently removed from development activities to minimize or avoid potential adverse 

effects. All ANSs on public lands will become the property of the BLM upon completion of the project. 

In cases where existing project features (e.g., well locations) are located within the nest buffers of active 

raptor nests, no extensive maintenance activities (e.g., workovers) will be allowed during critical periods (i.e., 

approximately early March through mid-June). The exact dates of exclusion will be determined by the BLM 

and will likely vary between nests and from year to year, depending on the species present and variations in 

weather, nesting chronology, and other factors. 

Any powerline construction will follow the recommendations of the Avian Power Line Interaction Committee 

(APLIC) (1994, 1996) and Olendorff et al. (1981) to avoid collisions and/or electrocution of raptors. 

D-2.3.2 TEC&SC 

USFWS and WGFD consultation and coordination will be conducted for all protection activities relating to 

TEC&SC species and their habitats. Where possible, these actions will be specified in advance in the annual 

reports. 

D-2.3.2.1 Black-footed Ferret 

In general, all prairie dog colonies on the CD/WIIPA will be avoided, where practical. If prairie dog colonies 

of sufficient size and burrow density for black-footed ferrets are scheduled to be disturbed, as identified in 

annual reports, black-footed ferret surveys of these colonies will be conducted pursuant to BLM and/or 

USFWS decisions made during informal consultations. Survey protocol will adhere to USFWS guidelines as 

established in USFWS (1989) and will be conducted by a USFWS-qualified biologist a maximum of 1 year in 

advance of the proposed disturbance. Reports identifying survey methods and results will be prepared and 

submitted to the USFWS and BLM in accordance with Section 7 of the Endangered Species Act of 1973, as 

amended, and the Interagency Cooperation Regulations. Surveys will be financed by the Operators. 

If black-footed ferrets are found on the CD/WIIPA, the USFWS will be notified immediately and formal 

consultations will be initiated to develop strategies that ensure no adverse effects to the species. Before 

ground-disturbing activities are initiated in black_footed ferret habitat, authorizations to proceed must be 

received from the BLM, in consultation with the USFWS. 
Record of Decision, Continental Divide/Wamsutter II 2 

D-2.3.2.2 Bald Eagle, Peregrine Falcon, and Ferruginous Hawk 

Protection protocol generally will be as described for raptors (see Section D_2.3.1). Additional measures will 

be applied on a species- or site_specific basis, as deemed appropriate by the USFWS and/or BLM, and 

specified in annual reports. 

D-2.3.2.3 Mountain Plover 

Mountain plover habitats (e.g., cushion plant communities, playa lakes, areas with vegetation <4inches in 

height) will be avoided where practical, and where these habitats will be disturbed, reclamation will utilize 

procedures designed to reestablish suitable plover habitat. 

If an active mountain plover nest is observed within survey areas (see Section D-2.2.2.3), planned development 

activities will be delayed at least 37days or 1 week post-hatching. If a brood of flightless chicks is discovered, 

planned activities will be delayed at least 7 days. Road construction and maintenance (i.e., grading) activities 

will be minimized from May 25 to June 30 and, where practical, no new surface-disturbing activities will be 

conducted from April 1 to June 30 within 656 ft of identified mountain plover concentration areas (i.e., areas 

where broods and/or adults have been observed in the current year or documented in at least 2 of the past 3 

years). 

D-2.3.2.4 Western Burrowing Owl 

Other than the avoidance of prairie dog colonies and other appropriate nesting habitat, where practical (see 

Section D-2.3.2.1) and the avoidance of active raptor nests during the nesting period (see Section D-2.3.1), no 

additional species-specific protection measures are proposed. 

D-2.3.2.5 Other TEC&SC Species 

If, during surveys of areas within 0.5 mi of proposed disturbance sites (see SectionD_2.2.2.5), nests or other 

crucial features for any TEC&SC species are found (e.g., loggerhead shrike nests), avoidance of these features 

will be accomplished in consultation and coordination with the BLM, USFWS, and WGFD. Construction 

activities in these areas will be curtailed until there is concurrence between BLM, USFWS, and WGFD on 

what activities can be authorized. Activities will, in most cases, be delayed until such time that no adverse 

effects will occur (e.g., after fledging). 

No additional protection measures will be applied for other sensitive species potentially present on the 

CD/WIIPA; however, it is assumed that the protocol specified in SectionD_2.3.5 for general wildlife will likely 

benefit TEC&SC species as well. If any management agency (i.e., BLM, WGFD, USFWS) identifies a 

potential for impacts to any TEC&SC species, additional measures may be implemented as specified in 

annual reports. 

D-2.3.3 Sage Grouse 

Surface disturbance and actions that create permanent and high-profile structures such as buildings and storage 

tanks which are suitable as raptor perches will not be constructed within 0.25mi of sage grouse leks on and 

adjacent to the CD/WIIPA. In addition, power lines will not be constructed within 0.6 mi of leks, as necessary 

to protect leks from raptor predation. To protect nesting sage grouse, Operators will restrict construction 

activities between March 1 and June 30 within a 2.0_mi radius of active sage grouse leks on suitable sage 

grouse nesting habitat as determined during on-site reviews of proposed development areas. In addition, if an 

active sage grouse nest is identified in an area proposed for disturbance, surface-disturbing activities will be 
Record of Decision, Continental Divide/Wamsutter II 2 

delayed in the area until nesting is completed, and proposed disturbance areas will be relocated, where 

possible, to avoid nest locations. 

D-2.3.4 Big Game Species 

No construction activities or extensive maintenance actions (e.g., workovers) will be conducted within big 

game crucial winter range on the CD/WIIPA during crucial winter periods (i.e., November 15 - April 30). No 

road or pipeline ROW fencing is proposed for the project; however, if ROW fencing is required, it will be kept 

to a minimum, and the fences will meet BLM/WGFD approval for facilitating wildlife movement. 

Wildlife-proof fencing will be used only to enclose reclaimed areas where it is determined that wildlife 

species are impeding successful vegetation establishment. Snowfences, if used, will be limited to segments of 

0.25 mi or less. Project personnel will also be advised to minimize stopping and exiting their vehicles in big 

game winter habitat while there is snow on the ground. In addition, escape openings will be provided along 

roads in big game crucial 

winter ranges as designated by the BLM to facilitate exit of big game animals from snowplowed roads. 

Additional habitat protection/improvement measures may also be applied in any given year as directed by the 

BLM, in consultation with Operators and other agencies, and specified in annual wildlife reports. 

Potential increases in poaching will be minimized through employee and contractor education regarding 

wildlife laws (see Section D-2.1.2). If violations are discovered on the CD/WIIPA, Operators will immediately 

notify the BLM, and if the violation is committed by an employee or contractor, said employee or contractor 

will be disciplined and may be dismissed by the Operator and/or prosecuted by the WGFD and/or USFWS. 

D-2.3.5 General Wildlife 

Unless otherwise indicated, the following protection measures will be applied for all wildlife species. 

Additional measures primarily designed to minimize impacts to other CD/WIIPA resources (e.g., vegetation 

and surface water resources, including wetlands, steep slopes, etc.) are identified in EIS Section 2.6.13 and 

Chapter 4.0, and these measures may provide additional protection for area wildlife. Additional actions may 

be applied in any given year to further minimize potential impacts to wildlife. These actions will be specified 

in annual reports. 

All roads on and adjacent to the CD/WIIPA that are required for the proposed project will be appropriately 

constructed, improved, maintained, and signed to minimize potential wildlife/vehicle collisions and facilitate 

wildlife (most notably big game) movement through the CD/WIIPA. Appropriate speed limits will be adhered 

to on all CD/WIIPA roads, and Operators will advise employees and contractors regarding these speed limits. 

Some existing roads on the CD/WIIPA and surrounding transportation planning area may be reclaimed if they 

become redundant or closed (gated and locked) to deny unnecessary access during critical winter periods. 

To protect important habitat in southwestern portions of the CD/WIIPA (i.e., ephemeral draws dominated by basin big 

sagebrush) areas with sagebrush greater than 3 ft tall will be avoided where possible. 

Additional non-species-specific wildlife mitigations include the following. 

• Reserve, workover, and flare pits and other locations potentially hazardous to wildlife will be 

adequately protected by netting and/or fencing as directed by the BLM to prohibit wildlife 

access. 

• No surface water or shallow ground water in connection with surface water will be utilized for 

the proposed project. 

• If dead or injured raptors, big game, migratory birds, or unusual wildlife are observed on the 

CD/WIIPA, Operator personnel will contact the appropriate BLM and WGFD offices. Under 
Record of Decision, Continental Divide/Wamsutter II 2 

no circumstances will dead or injured wildlife be approached or handled by Operator 

personnel. 

• Operators will implement policies designed to control poaching and littering and will notify 

all employees (contract and company) that conviction of a major violation could result in 

disciplinary action. Contractors will be informed that any intentional game law violation or 

littering within the CD/WIIPA could result in dismissal. 

In the event that four or more locations occur on a section, further project_specific wildlife protection 

measures may be applied. These measures may include the installation of remote well monitoring devices at 

well locations to avoid unnecessary visits by Operator personnel and the installation of water and/or 

condensate pipelines from well locations to central processing facilities to avoid repeated trucking of 

condensate and water from these well locations. Additional project_ and site-specific measures may be added 

in future years as specified in annual reports. 
Record of Decision, Continental Divide/Wamsutter II 2 

D-3.0 LITERATURE CITED 

Avian Power Line Interaction Committee. 1994. Mitigating bird collisions with power lines: The state of the art in 1994. 

Edison Electric Institute, Washington, D.C. 78pp. + append. 

.1996.Suggested practices for raptor protection on power lines: The state of the art in 1996. Edison Electric 

Institute/Raptor Research Foundation, Washington, D.C. 125pp. + append. 

Baxter, G.T., and M.D. Stone. 1980. Amphibians and reptiles of Wyoming. Wyoming Game and Fish Department, 

Bulletin No. 16. 137 pp. 

Call, M.W. 1978. Nesting habitats and surveying techniques for common western raptors. U.S. Department of the 

Interior, Bureau of Land Management, Technical Note No. 316. 115 pp. 

Dorn, J.L., and R.D. Dorn. 1990. Wyoming birds. Mountain West Publishing, Cheyenne, Wyoming. 138 pp. 

Grier, J.W., and R.W. Fyfe. 1987. Preventing research and management disturbance. Pages 173-182 In B.A.G. Pendleton, 

B.A. Milsap, K.W. Cline, and D.M. Bird, editors. Raptor management techniques. Institute of Wildlife Research, 

National Wildlife Federation, Scientific and Technical Series No. 10. 420 pp. 

Olendorff, R.R., A.D. Miller, and R.M. Lehman. 1981. Suggested practices for raptor protection on power lines: The 

state of the art in 1981. Raptor Research Report No. 4, Raptor Research Foundation, Inc., University of 

Minnesota, St. Paul. 111 pp. 

U.S. Fish and Wildlife Service. 1989. Black-footed ferret survey guidelines for compliance with the Endangered Species Act. 

U.S. Fish and Wildlife Service, Denver, Colorado, and Albuquerque, New Mexico (April 1989). 10 pp. + append. 

Wyoming Department of Environmental Quality-Land Quality Division. 1995. Coal rules and regulations, Appendix B, 

wildlife monitoring requirements for surface coal mines. 

Wyoming Game and Fish Department. 1992. Wyoming bird and mammal atlas. 170 pp. 

. 1996. Wyoming observation system records. Wyoming Game and Fish Department, Biological Services, Cheyenne, 

Wyoming. 

.1997.Atlas of birds, mammals, reptiles and amphibians in Wyoming. Wyoming Game and Fish Department, Wildlife 

Division, Biological Services Station, Nongame Program, Lander, Wyoming. 192 pp. 

Wyoming Natural Diversity Database. 1995. Wyoming vertebrate species of concern list. Compiled by C. Garber for the 

Nature Conservancy, Wyoming Natural Diversity Database. 21 pp. + append. 
1 

ADDENDUM D-A: 

EXAMPLE DATA SUMMARY TABLES 
Table D-A.1 Summary of Raptor Nest Data, Continental Divide/Wamsutter II Natural Gas Project, Carbon and Sweetwater Counties, Wyoming, 1999. 

Nest 

No. 

L e g a l 

Location 

Status Condition Species (if 

active) 

Buffer 

Radius 

# 

Eggs 

# 

Nestlings 

# 

Fledglings 

Comments (e.g., Distance to Disturbance, Potential Impacts, 

Mitigation) 
Table D-A.2 Summary of Observations of Threatened, Endangered, Candidate, and Other Species of Concern, Continental Divide/Wamsutter II 

Natural Gas Project, Carbon and Sweetwater Counties, Wyoming, 1999. 

Species Total # 

Habitat Type1 Comments (suitable 

habitat, nests, etc.) 

Potential Impacts/Mitigation 

B S M B/ B D R D U S P/ 

Obs. S B R R G S P R R 

1 Indicates presence/absence. BS = Big sagebrush R = Reclaimed 

SB = Saltbush D = Disturbed 

MR = Mixed grassland UP = Unvegetated playa 

B/R = Basin/exposed rock (Badland) SR = Shrub-dominated riparian 

BG = Black greasewood P/R = Pond/riparian

 DS = Desert shrub 
Table D-A.3 Summary of Sage Grouse Lek Data, Continental Divide/Wamsutter II Natural Gas Project, Carbon and Sweetwater Counties, Wyoming, 1999. 

Lek No. Legal Location Date Status # Males # Females Distance to Disturbance/Potential Impacts/Mitigation 
Table D-A.4 Summary of General Wildlife Observations, Continental Divide/Wamsutter II Natural Gas Project, Carbon and Sweetwater Counties, 

Wyoming, 1999. 

Species No. of Habitat Type1 No. of Obs. by Season2 

Obs. 

C o m m o n Scientific BS SB MG B/R GW DS R D UP SR P/R Winter Spring Summer Fall 

Name 

Name 

Mammals

 Total 

Birds 

Total 

R e pti le s 

/Amphibians 

Total 

Grand Total 

1 Indicates presence/absence. BS = Big sagebrushR = Reclaimed

SB = SaltbushD = Disturbed 

MG = Mixed grasslandUP = Unvegetated playa

B/R = Basin/exposed rock (badland)SR = Shrub-dominated riparian

GW = GreasewoodP/R = Pond/riparian

DS = Desert shrub 2 Seasons are defined as follows: Winter = November-MarchSpring = April-May Summer = June-AugustFall = September-October 
ADDENDUM D-B: 

EXAMPLE DATA SUMMARY FORMS 
GENERAL WILDLIFE OBSERVATION DA TA SHEET 

Month/year Observer Type of survey Page of 

Notes 

Date Species 

# indiv. by

age and sex Location Habitat type 

Activity/direction

of movement 

Comments/weather

conditions 

1

 Circle any uncertain data (i.e., partial counts, uncertain age or sex) or note as unknown. 
RAPTOR NESTING RECORD Page of 

Nest Number Location Habitat Type 

Map Location Date first observed 

Initial observer 

Nest type 

Nest material 

Substrate 

Rim/tree height (m) 

Nest height above ground level (m) 

Elevation 

Nest exposure 

Comments 

USGS Quad 

Comments (condition, activity

Date Status Species # adults # eggs # young Observer of individuals, etc.) 

A photo of the nest location may be provided on reverse. 
RAPTOR OBSERVA TION DATA SHEET 

Month/year Observer Type of survey Page of 

Notes 

Date Species 

# indiv. by 

age and sex Location Habitat type Activity Comments/weather conditions 

1

 Circle any uncertain data (i.e., partial counts, uncertain age or sex) or note as unknown. 
Lek Number 

Map Location 

Location 

SAGE GROUSE LEK RECORD 

Habitat Type 

Date first observed 

Initial observer 

Slope/topography 

Elevation 

Lek exposure 

Comments 

Page of 

Date Time Status # males # females 

USGS Quad 

Weather 

conditions Observer Comments 
APPENDIX E: 

BIOLOGICAL ASSESSMENT 

Modifications to this plan have been made pursuant to the U.S. Fish and Wildlife Service Biological 

Opinion and associated implementation protocol (AppendixG) and including Wyoming 

Bureau of Land Management Instruction Memorandum No. WY-2000-44 (Appendix I).
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

BIOLOGICAL ASSESSMENT FOR THE

CONTINENTAL DIVIDE/WAMSUTTER II NATURAL GAS PROJECT

THREATENED, ENDANGERED, CANDIDATE,

AND SPECIES OF SPECIAL CONCERN

Prepared for 

U.S. Bureau of Land Management 

Rawlins Field Office 

Rawlins, Wyoming 

and 

Rock Springs Field Office 

Rock Springs, Wyoming 

By 

TRC Mariah Associates Inc.

Laramie, Wyoming

MAI Project 1295

April 1999
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

ABBREVIATIONS AND ACRONYMS 

APD Application for Permit to Drill 

APLIC Avian Power Line Interaction Committee 

BA Biological Assessment 

BFF Black-footed ferret 

BLM Bureau of Land Management 

CD/WIIPA Continental Divide/Wamsutter II Project Area 

CNHP Colorado Natural Heritage Program 

dBA A-weighted decibel(s) 

DEIS Draft Environmental Impact Statement 

EIS Environmental impact statement 

ESA Endangered Species Act of 1973, as amended 

FREP Ferret Recovery Enhancement Program 

ft Foot or feet 

GCIAA General Cumulative Impact Assessment Area 

GDRA Great Divide Resource Area 

GRRA Green River Resource Area 

IDT Interdisciplinary Team 

LOP Life-of-project 

mi Mile(s) 

mm Millimeter(s) 

NEPA National Environmental Policy Act of 1969 

Operators Amoco Production Company, Union Pacific Resources Company, Snyder Oil Corporation, Yates Petroleum, 

and other companies 

RFO Rawlins Field Office 

RMP Resource Management Plan 

ROW Right-of-way 

RSFO Rock Springs Field Office 

SRA Sensitive Resource Area 

TEC&SC Threatened, endangered, candidate, and other species of special concern 

USDI U.S. Department of the Interior 

USFS U.S. Forest Service 

USFWS U.S. Fish and Wildlife Service 

VRM Visual Resource Management 

WGFD Wyoming Game and Fish Department 

WNDDB Wyoming Natural Diversity Database 

WOS Wildlife Observation System 

WSA Wilderness Study Area 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

E-1.0 INTRODUCTION

 In addition, this BA presents requirements to assure that the construction and subsequent operation of the 

proposed project on federal lands would neither jeopardize the continued existence of these species nor result 

in the destruction or adverse modification of their critical habitats. Analysis of effects of this proposed project 

on federally listed TEC&SC ensures compliance with the provisions of the Endangered Species Act of 1973 

(ESA), P.L. 93-205 (87 Stat. 884), as amended. 

TEC&SC are those that have been specifically designated as such by the U.S. Fish and Wildlife Service 

(USFWS). Threatened species are those that at are likely to become endangered in the foreseeable future 

throughout all or a significant portion of their ranges. Endangered species are those that are in danger of 

extinction throughout all or a significant portion of their ranges. Candidate species (former Category 1 

candidate species) are those for which the USFWS has sufficient data to list as threatened or endangered, but 

for which proposed rules have not yet been issued. Species of special concern (former Category 2 candidate 

species) are those that may warrant designation as candidate species but sufficient data are not currently 

available for such a designation decision; these species are also referred to as "special status species" by the 

Bureau of Land Management (BLM) and "species at risk" by the USFWS (USFWS 1995a). 

Critical habitat for a threatened or endangered species includes: 1) specific locations within the geographical 

area occupied by the species, at the time it is listed in accordance with the provisions of Section 4 of the 

ESA, on which are found those physical or biological features (a) essential to the conservation of the species 

and (b) which may require special management considerations or protection; and 2) specific areas outside the 

geographical area occupied by the species at the time it is listed, upon a determination by the Secretary (i.e., 

Interior, Commerce, or Agriculture) that such areas are essential for the conservation of the species. There 

currently is no designated critical habitat for any threatened or endangered species in the CD/WIIPA. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

Table E-1.1 Threatened, Endangered, Candidate, and Other Species of Special Concern and Their 

Potential for Occurrence on the CD/WIIPA, Sweetwater and Carbon Counties, Wyoming, 

1999.1 

Species Federal Potential 

Status 2 Occurrence 

on CD/WIIPA3 

Common Name Scientific Name 

MAMMALS 

Black-footed ferret Mustela nigripes E X 

Long-eared myotis (bat) Myotis evotis SS R 

Long-legged myotis (bat) Myotis volans SS R 

Pale Townsend*s big-eared bat Plecotus townsendii pallescens SS U 

Pygmy rabbit Brachylagus idahoensis SS X 

Small-footed myotis (bat) Myotis ciliolabrum SS U 

Swift fox Vulpes velox C U 

BIRDS 

Bald eagle Haliaeetus leucocephalus T U 

Black tern Chlidonias niger SS U 

Columbian sharp-tailed grouse Tympanuchus phasianellus SS X 

columbianus 

Ferruginous hawk Buteo regalis SS C 

Loggerhead shrike Lanius ludovicianus SS C 

Mountain plover Charadrius montanus Proposed as T C 

Northern goshawk Accipiter gentilis SS R 

Peregrine falcon Falco peregrinus E R 

Trumpeter swan Cygnus buccinator SS R 

Western burrowing owl Athene cunicularia hypugea SS U 

White-faced ibis Plegadis chihi SS U 

REPTILES 

Eastern short-horned lizard Phrynosoma douglassii brevirostra SS C 

FISH 

Bonytail chub Gila elegans E X, DC 

Colorado squawfish Ptychocheilus lucius E X, DC 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

Flannelmouth sucker Catostomus latipinnis SS X, DL, DC

Humpback chub Gila cypha E X, DC

Razorback sucker Xyrauchen texanus E X, DC 

Roundtail chub Gila robusta SS X , D L , 

DCPLANTS 

Big Piney milkvetch Astragalus drabelliformis SS Unlikely

Cedar Rim thistle Cirsium aridum SS Possible

Devil*s gate twinpod Physaria eburniflora SS Unlikely

Gibben's beardtongue Penstemon gibbensii SS Unlikely

Large-fruited bladderpod Lesquerella macrocarpa SS Possible

Mystery wormwood Artemisia biennis var. diffusa SS Possible

Opal phlox Phlox opalensis SS Possible

Ownbey*s thistle Cirsium ownbeyi SS Unlikely

Tufted twinpod Physaria condensata SS Unlikely

Utes ladies' tresses Spiranthes diluvialis T Unlikely

Wyoming tansymustard Descurainia torulosa SS Possible

1 Adapted from personal communications with USFWS, Wyoming Game and Fish Department (1995), Wyoming Natural 

Diversity Data Base (1995, 1996, 1997), and Fertig et al. (1994). 

2 Federal status: 

E = Endangered 

T Threatened =

Candidate (proposed threatened) =

SSpecial Status Species (BLM-managed, former USFWS category 2 candidate species) = 3 Species occurrence: 

C Locally common; species could occur in abundant numbers, but only in widely scattered or isolated populations. =

Populations or individuals probably would be encountered during construction and field operation, but 

only at a limited number of sites. Species could be present for a significant part of the year (e.g., breeding 

season, summer resident) or the entire year. 

U Uncommon; species may be present in the project area, but in such low numbers or in such small and widely =

scattered populations that an encounter during construction and field operation is unlikely. The species 

could be present for a significant part of the year (e.g., breeding season, summer resident) or the entire year. 

Rare; species may occur in the project area for just a few days or hours (e.g., stopping over during migration), or the =

species has only occasionally or rarely been sighted in the project area. Encounters during construction 

and field operation are very unlikely. 

X Not probable; there has been no recent historical record of the species' occurrence in the project area; probability of =

encountering the species during construction and field operation is extremely unlikely. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

DC Downstream resident of Colorado River System. =

DL = Downstream resident of Little Snake River. 

Possible = Species documented in the general vicinity of the CD/WIIPA, but not within the CD/WIIPA itself. 

Unlikely= Species documented in areas relatively distant from the CD/WIIPA and/or in habitats unlikely 

to be present within the CD/WIIPA. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 3 

E-2.0 PROJECT DESCRIPTION 

Operators propose to expand natural gas exploration and development in and adjacent to other oil and gas 

developments including the Greater Wamsutter Area II, Creston/Blue Gap Area, and the Mulligan Draw Area. 

The proposed CD/WIIPA is located approximately 25mi west of Rawlins and 40 mi east of Rock Springs along 

Interstate 80, which bisects the area east to west (see Map 1.1 in the EIS). The CD/WIIPA is located 

generally within Townships 15 through 23 North and Ranges 91 through 99 West in Sweetwater and Carbon 

Counties, Wyoming. The 1,061,200-acre CD/WIIPA primarily occurs within the checkerboard land pattern 

that resulted from early railroad grants made by the federal government to the Union Pacific Railroad 

Company and includes 531,400acres of federal land, 9,800 acres of state land, and 520,000 acres of private 

land. The entire CD/WIIPA is included in the analysis for this BA since development on private and state 

lands will likely occur in association with federal land development. The proposed project is located on lands 

administered by the BLM Rawlins Field Office (RFO) and Rock Springs Field Office (RSFO). 

Four development scenarios are analyzed in the EIS and in this BA: 

• the Proposed Action (full field development); 

• Alternative A (14_acre maximum surface disturbance per federally managed section in sensitive 

resource areas [SRAs]) (see Map 2.3 in EIS); 

• Alternative B (30_acres maximum surface disturbance per federally managed section in SRAs); and 

• the No Action Alternative. 

SRAs were defined during preparation of the EIS by the BLM Interdisciplinary Team (IDT) based on public 

and agency concerns identified during scoping and during past environmental analyses conducted in the region. 

SRAs include areas with stabilized sand dunes, raptor nesting concentration areas, probable sage grouse 

nesting areas (i.e., areas within 2.0 mi of sage grouse leks), crucial big game winter ranges, areas proximal to 

residential areas, Visual Resource Management Class II areas, and areas with high densities of cultural 

resource sites. 

The project entails the development of natural gas resources in the CD/WIIPA beginning in 1999 and 

continuing for approximately 20 years. Well densities will vary across the CD/WIIPA and will likely range 

from 640 acres/well to 80acres/well (1 to 8 wells per section) for production in areas found to be highly 

productive. Alternatives involving project-wide spacing patterns, the drilling and development of varying 

numbers of wells, the exclusion of development on all public lands in the CD/WIIPA, and developments on 

and adjacent to the Adobe Town Wilderness Study Area were considered but rejected for economic, 

environmental, and/or legal reasons. 

Summary descriptions of the four alternatives are presented below; specific details of construction and 

production activities can be found in the EIS. Project documents and other information are located at the 

BLM GRRA Office in Rock Springs, Wyoming, and the GDRA Office in Rawlins, Wyoming. 

E-2.1 THE PROPOSED ACTION - FULL FIELD DEVELOPMENT (3,000 WELL 

LOCATIONS) 

Definitive predictions on the total number of wells and the timing of drilling operations are not currently 

possible due to the lack of natural gas exploration in much of the CD/WIIPA; however, the BLM's Reservoir 

Management Group and the Operators have indicated that a maximum of 3,000 wells at 3,000 well locations 

may be developed in the CD/WIIPA (approximately 1,500 wells or well locations on federal lands and/or 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 3 

federal mineral estate). Operators anticipate that fewer wells or well locations would be necessary, and in the 

event fewer locations are developed, decreased impacts are expected. Drilling and development would begin 

in 1999 and continue for approximately 20 years, with a life-of-project (LOP) of 30-50 years. Various 

associated facilities (e.g., roads, pipelines, power lines, water wells, disposal wells, evaporation ponds, 

compressor stations, gas processing facility) would also be constructed. 

The Proposed Action would result in a maximum of 7,800 acres of new surface disturbance from well locations 

(including on-site gathering, measurement, and dehydration facilities); 1,500 mi (10,000 acres) of new roads 

or upgrades of existing roads; 1,500 mi (4,500 acres) of new pipeline; and approximately 100 acres of new 

surface disturbance from ancillary facilities (e.g., compressor stations, water disposal sites) (see Table 2.1 in 

EIS). Total new short-term and LOP surface disturbance resulting from the Proposed Action would be 22,400 

acres and 8,300 acres, respectively. With the inclusion of existing disturbance necessary for the Proposed 

Action, total new short-term and LOP surface disturbance would be 33,600 acres and 15,900 acres, 

respectively. Total project-required new and LOP surface disturbance on federal lands and/or mineral estate in 

the CD/WIIPA is estimated to be approximately 50% of the total CD/WIIPA surface disturbance or 16,800 

acres and 7,950 acres, respectively. 

E-2.2 ALTERNATIVE A - 14-ACRE MAXIMUM SURFACE DISTURBANCE PER

 FEDERALLY MANAGED SECTION IN SRAs 

Surface disturbance throughout the entire CD/WIIPA resulting from Alternative A would be similar to that from 

the Proposed Action, except that long-term LOP surface disturbance and associated impacts would likely be 

reduced on federal lands in SRAs (see Table 2.2 in the EIS). It is assumed that reductions in the level of LOP 

surface disturbance would result in reductions in overall disturbance (both direct and indirect) to most 

sensitive resources. Approximately 47% of the CD/WIIPA is within SRAs (see Map 2.3 in the EIS), and under 

Alternative A, a maximum of 14 acres of surface disturbance would be allowed at any one time on any 

federally managed section (surface and/or mineral estate) within SRAs. The 14-acre maximum surface 

disturbance criteria was developed by the BLM based on public, agency, and resource specialist concerns 

regarding potential impacts to sensitive resources from natural gas field developments. The 14_acre criteria 

would allow Operators to explore for natural gas throughout the entire CD/WIIPA, but would require notable 

changes in operational procedures for field developments within SRAs. Under this alternative, Operators 

would be able to explore their leases within SRAs (e.g., one well location per section) and to develop a 

limited number of additional locations (e.g., from one to three) depending upon the extent of new surface 

disturbance and associated reclamation status (see Table 2.2 in the EIS). 

Surface disturbance limitation requirements would apply to all future oil and gas development activities 

conducted on federal lands in SRAs. To accommodate surface disturbance limitation requirements, Operators 

may limit surface disturbance through: 

• operational changes (e.g., directional drilling; multiple wells per pad; modified location, road, 

pipeline, and/or ancillary facility design; use of surface pipelines; delaying construction/drilling 

operations until all unnecessary project-required federal surface disturbances are reclaimed); 

• selection of alternative locations for ancillary facilities (e.g., outside SRAs or off federal surface); 

and/or 

• reclamation of unnecessary existing surface disturbance on their lease (e.g., two-track roads). 

The BLM, in consultation with other appropriate individuals, agencies, and land user groups (e.g., permittees, 

Wyoming Game and Fish Department [WGFD], USFWS), may modify surface disturbance limitation 

requirements if the Operators can show that alternative operational procedures would provide greater protection 

for sensitive resources than would limiting surface disturbance. For example, the use of pipeline 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 3 

collection/distribution systems for condensate, drilling water, and/or produced water, which would temporarily 

increase overall ground surface disturbance, may in some instances be preferable since their use could result 

in a decrease in the level of human activity along access roads and at well locations; thereby reducing indirect 

impacts associated with animal displacement. In addition, remote sensing devices could be installed at well 

locations to further reduce human activity levels. 

Total new area-wide short-term surface disturbance for this alternative could be the same as for the Proposed 

Action. However, total maximum long-term (LOP) disturbance on federally managed sections in SRAs would 

be reduced (see Table 2.2 in the EIS), since newly disturbed areas must be reclaimed prior to the initiation of 

further surface disturbing activities. Some increase in the extent of surface disturbance on private or state 

lands within SRAs and on federally managed lands outside of SRAs would likely occur under this alternative. 

E-2.3 ALTERNATIVE B - 30-ACRE MAXIMUM SURFACE DISTURBANCE PER 

FEDERALLY MANAGED SECTION IN SENSITIVE RESOURCE AREAS 

Area-wide surface disturbance resulting from Alternative B would be similar to that for the Proposed Action 

and Alternative A, except that surface disturbance and associated impacts would likely be increased on 

federal lands in SRAs from that occurring under AlternativeA and reduced from that occurring under the 

Proposed Action (see Table 2.2 in the EIS). Maximum new surface disturbance per federal section would be 

limited to 30 acres at any one time within SRAs. The 30-acre maximum surface disturbance limitation was 

developed via the same means as that described for Alternative A and allows Operators to develop natural gas 

resources within SRAs at a level intermediate between Alternative A and the Proposed Action. Under this 

alternative, Operators would be able to explore and conduct limited development of their leases within SRAs 

(e.g., from two to eight locations per section) depending upon the extent of new surface disturbance and 

associated reclamation status (see Table2.2 in the EIS). To protect federal natural gas reserves within SRAs 

from drainage, these reserves may be developed regardless of reclamation status. 

Total new short- and long-term surface disturbance throughout the CD/WIIPA under this alternative could be 

the same as that for the Proposed Action; however, there would likely be reductions in the level of long-term 

surface disturbance on federally managed lands in SRAs. Some increase in the extent of surface disturbance 

on private or state lands within SRAs and on federally managed lands outside of SRAs would likely occur 

under this alternative. 

E-2.4 NO ACTION 

A No Action Alternative must be considered in all National Environmental Policy Act of 1969 (NEPA) 

documents. Under the No Action Alternative, the BLM would deny further natural gas development on federal 

lands in the CD/WIIPA as currently proposed by the Operators. Denial of the current development proposal is 

not, however, a denial of all natural gas development in the area. Development of lands in the CD/WIIPA 

likely would occur at levels similar to those that have occurred on the area in the past and would occur as 

authorized by existing management directives contained in RMPs. Site-specific NEPA analyses would be 

conducted for all development activities on public lands or mineral estates. 

For the purpose of this analysis, the No Action Alternative assumes that lands in the CD/WIIPA would be 

developed for natural gas production at approximately the same rate as has occurred previously. This 

assumption is highly speculative, since all federal lands within the CD/WIIPA have been leased for oil and 

gas production or are available for lease, the area is rated as suitable for gas production in the GRRA and 

GDRA RMPs, and accelerated development of the area has been proposed. The selection of the No Action 

Alternative in the EIS would not preclude natural gas development in the area. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 3 

An estimated 845 well locations would be built, 422mi of road would be constructed or upgraded, 422 mi of 

pipeline would be laid, and 100 acres of new surface disturbance would be required for ancillary facilities, 

resulting in a maximum of 6,400 acres of new surface disturbance and 2,400 acres of long-term surface 

disturbance (see Table 2.1 in the EIS). With the inclusion of all existing surface disturbances on the 

CD/WIIPA, total new and long-term surface disturbance under the No Action Alternative would be 24,800 

acres and 17,200 acres, respectively, and it is estimated that approximately 50% of this disturbance would be 

on federally managed lands. 

Most leases in the CD/WIIPA contain various stipulations addressing surface disturbance, steep slopes, 

wildlife, and other matters of concern. These stipulations would allow the BLM to preclude development in 

certain areas (e.g., where slopes exceed 25%) or at certain times of the year (e.g., to protect big game crucial 

winter habitat) if operations cannot be acceptably mitigated. However, there is no stipulation, such as a No 

Surface Occupancy stipulation, that would allow the BLM to preclude drilling operations everywhere on a 

lease at all times of the year. If any one of the stipulations cannot be acceptably implemented and impacts 

mitigated, than an exception would not be granted. A decision, therefore, of no action, as authorized by the 

leases, would only be considered, given one of the following conditions. 

• If there were no acceptable means of mitigating significant adverse impacts to stipulated surface 

resource values, then this would trigger denial of the Application for Permit to Drill (APD) and require 

consideration and analysis of another alternative(s). Effectively, exception(s) to one or more of 

the lease stipulations would not be approved. 

• If the USFWS concluded that the Proposed Action and alternatives would likely jeopardize the 

continued existence of threatened or endangered plant and animal species, then the APD and lease 

development may be denied in whole or in part. 

This BA will help to determine whether the proposed project meets the second condition. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 3 

E-3.0 METHODS 

A list of TEC&SC animal and plant species that potentially occur on or adjacent to the project area and 

associated GCIAA (see Map 4.1 in the EIS) was compiled from several sources, including a letter from the 

Wyoming State Supervisor's Office of the USFWS (1995b, 1997), the WGFD Wildlife Observation System 

(WOS) records (WGFD 1995), the Nature Conservancy*s Wyoming Natural Diversity Database (WNDDB) 

(1995, 1996, 1997), and the Nature Conservancy*s Colorado Natural Heritage Program (CNHP) (1995). All 

TEC&SC species in the region are discussed in Chapter E-6.0 of this BA. 

Information pertaining to the listed TEC&SC animal and plant species was gathered from the above sources 

and from published literature. Further site-specific information pertaining to these species will be gathered as 

part of APD and right-of-way (ROW) application processes, and the potential impact of a given construction 

site on a particular species will be determined as part of APD and ROW application reviews. The purpose of 

this BA is to provide a project-wide assessment of potential impacts to the listed TEC&SC species. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 10 

E-4.0 PROJECT-WIDE MITIGATION MEASURES FOR TEC&SC SPECIES 

This section provides some of the measures that will be utilized to avoid, minimize, or mitigate potential 

impacts to TEC&SC species associated with implementation of the proposed CD/WIIPA. Additional 

environmental protection measures designed specifically for other resources present on the area (e.g., soils, 

vegetation, wetlands, visual resources) are given in Section 2.6.13 of the EIS. These measures apply to both 

the Proposed Action and the two development alternatives. Project-wide mitigation measures may be waived 

on a case-by-case basis by the BLM if a thorough analysis determines that the resource(s) for which the 

measure was developed will not be impacted. Further site-specific mitigation measures will be identified 

during APD and ROW application review processes. To ensure compliance with mitigation measures 

presented in this BA and in APDs and ROW applications, each Operator will provide a qualified individual 

available during construction/drilling operations. This individual will consult with the BLM on a case_by_case 

basis as necessary during field development. 

All of the proposed applicant-committed mitigation/environmental protection measures identified in Section 

E-4.1 will be implemented on all federal lands under all alternatives except No Action. Implementation of 

these measures on state and private lands will be subject to landowner preferences and agreements with 

individual Operators, and where these measures are not implemented, additional impacts/adverse effects could 

occur. Development activities on all lands, including those implemented under No Action, will be conducted 

in accordance with all appropriate federal, state, and county laws, rules, and regulations. General mitigation 

measures for TEC&SC species on the CD/WIIPA are presented below. 

E-4.1 APPLICANT-COMMITTED MEASURES 

1. Well locations, access roads, pipelines, and ancillary facilities will be selected and designed to 

minimize disturbances to areas of high wildlife habitat value (e.g., prairie dog colonies, cushion plant 

communities, playa lakes, wetlands and riparian areas). 

2. Areas with high erosion potential and/or rugged topography (i.e., steep slopes [>25%], stabilized sand 

dunes, floodplains, erosive and sandy soils) will be avoided, where possible, or specialized mitigation 

measures will be applied. 

3. All Operator-constructed roads not required for routine operation and maintenance of producing wells 

or ancillary facilities will be reclaimed as directed by the BLM, State Land Board, or private 

landowner. As necessary, these roads will be permanently blocked, recontoured, reclaimed, and 

revegetated by Operators, as will disturbed areas associated with permanently plugged and abandoned 

wells. 

4. Removal or disturbance of vegetation will be minimized through construction site management (e.g., 

by utilizing previously disturbed areas, using existing ROWs, designating limited equipment/ 

materials storage yards and staging areas, scalping, etc.). 

5. Reserve, workover, and evaporation/ production pits potentially hazardous to wildlife will be 

adequately protected (e.g., netted, fenced) to prohibit wildlife access as directed by the BLM, to 

ensure protection of migratory birds and other wildlife. 

6. Any power line construction will follow recommendations by Avian Power Line Interaction 

Committee (APLIC) (1994, 1996) and Olendorff et al. (1981) to avoid collisions and electrocution of 

raptors and other avifauna. 

7. USFWS and WGFD consultation and coordination will be conducted as necessary for all mitigation 

activities related to raptors and TEC&SC species (and their habitats), and all permits required for 

movement, removal, and/or establishment of raptor nests will be obtained. 

8. Proposed disturbance within 1.0 mi of identified raptor nests will be surveyed by a qualified biologist 

to determine activity status prior to commencement of drilling and construction during raptor nesting 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 10 

periods. If an active raptor nest is identified within 0.25 mi to 1.0 mi (depending upon species and 

line of sight) of a proposed disturbance site, Operators will restrict construction during the nesting 

season for that species. Additional mitigations for nesting raptors will be designed on a site-specific 

basis, as necessary, in consultation with the BLM, USFWS, and WGFD. Operators will notify the 

BLM immediately if raptors are found nesting on project facilities and will assist the BLM as 

necessary in erecting artificial nesting structures. 

9. Operators will internally enforce existing drug, alcohol, and firearms policies. 

10. All production facilities (e.g., compressors) will be muffled and maintained to minimize noise levels. 

11. To minimize wildlife mortality due to vehicle collisions, Operators will advise project personnel

regarding appropriate speed limits on the CD/WIIPA.

12. To protect plant populations and wildlife habitat, project-related travel will be restricted to established 

project roads; no off-road travel will be allowed. 

13. Potential impacts to fisheries will be minimized by using proper erosion control techniques (e.g., 

water bars, jute netting, rip-rap, mulch). Construction within 500 ft of open water and 100 ft of 

intermittent or ephemeral channels will be avoided, where possible, and stream crossings for roads 

and pipelines will be constructed during the period of lowest flow (i.e., late summer or fall). All 

required stream crossings will be constructed perpendicular to flow, where possible. No surface water 

or shallow ground waters in connection with surface waters will be utilized for the proposed project 

(see EIS Section 4.1.7.1). 

14. Operators will finance site-specific surveys for TEC&SC plant species prior to any surface disturbance 

in areas determined by the BLM to contain potential habitat for such species (BLM Directive 6840). 

These surveys will be completed by a qualified botanist as authorized by the BLM, and this botanist 

will be subject to BLM*s special status plant survey policy requirements. Data from these surveys 

will be provided to the BLM, and if any TEC&SC plant species or their habitats are found, BLM 

recommendations for avoidance or mitigation will be implemented. Minor relocation of project 

facilities will be made to avoid TEC&SC plant species and/or their habitat. If avoidance is not 

possible, informal consultation with the USFWS will be initiated, as necessary. 

15. Herbicide applications will be kept at least 500 ft from known TEC&SC plant populations. 

16. Site-specific surveys for TEC&SC animal species will be conducted prior to disturbance in areas 

determined by the BLM to contain potential habitat for such species. These surveys will be 

completed by the BLM and/or BLM-authorized biologist during on-site inspections of proposed ROWs 

and well locations prior to disturbance. Surveys will focus on those TEC&SC animal species known 

to occur on the CD/WIIPA, as well as those potentially occurring in the area. Data from these surveys 

will be provided to the BLM. If TEC&SC animal species or their habitats are found on the area, 

construction activities will be delayed and the BLM, USFWS, and WGFD will be consulted to 

determine appropriate avoidance and/or protection measures. Habitats where TEC&SC animal 

species are likely or are known to occur will be avoided where possible through minor relocations of 

project facilities. If avoidance is not possible, informal consultation with the USFWS will be initiated 

as necessary. 

17. Mountain plover habitats (e.g., cushion plant communities, playa lakes, areas with vegetation <4

inches in height) will be avoided, where practical, and where these habitats will be disturbed,

reclamation will utilized procedures designed to re_establish suitable plover habitat. Furthermore,

mountain plover surveys will be conducted within suitable plover habitat on the CD/WIIPA by a

qualified biologist in accordance with USFWS guidelines and as directed by the BLM. The survey

procedures will include the following.

• Visual observation of areas within 656ft (200 meters) of proposed disturbance will be made from 

stationary vehicles and/or all terrain vehicles to detect the presence of plovers. All plovers 

located will be observed long enough to determine if a nest is present. 

• Surveys will be conducted no more than 14 days prior to the date actual ground-disturbing 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 10 

activities begin. If two surveys are required, they will be made at least 14 days apart, with the 

last survey no more than 14 days prior to the start-up date. 

• The number of surveys required to clear a site for mountain plovers prior to beginning a planned 

activity depends on the start-up date, as shown below. 

Date of Planned Activity # Surveys Required

March 15 - March 31 1

April 1 - June 30 2

July 1 - August 15 1

• Surveys will be required by the BLM to clear an action for mountain plovers prior to beginning a 

planned activity, and surveys would be conducted during the period of April 15-June 30 for 

development activities planned during this period. 

• Road construction and maintenance (i.e., grading) activities will be minimized from May 25 to 

June 30. 

• Where practical, no new surface_disturbing activities will be conducted from April 1 to June 30 

within 656 ft (200 m) of identified mountain plover concentration areas (i.e., areas where broods 

and/or adults have been observed in the current year or documented in at least 2 of the past 3 

years. 

• Where access roads and/or well locations have been constructed prior to the mountain plover 

nesting season and use of these areas has not been initiated for development actions, the BLM 

will require site investigations of these disturbed areas prior to use to determine whether mountain 

plover are present. In the event mountain plover nesting is occurring, the BLM may require 

delays in development activities until nesting is complete. 

18. Prairie dog colonies that meet black_footed ferret habitat size and burrow density criteria (USFWS 

1989) will be avoided where practical. 

19. Where prairie dog colonies will be disturbed, Operators would consult with the USFWS and/or the BLM 

and BLM would initiate informal consultation with the USFWS to determine if black-footed ferret 

searches are required. If ferret searches are required, they will be conducted no more than 12 months prior 

to construction by Operator-financed USFWS_approved biologists pursuant to USFWS guidelines 

(USFWS 1989). 

20. All wildlife inventory, monitoring, and protection measures specified in the Wildlife Protection Plan 

(see EIS AppendixD) will be implemented. 

E-4.2 ADDITIONAL BLM-REQUIRED MEASURES 

Pursuant to Instruction Memorandum No. WY-99-24, the BLM will implement or require further protection 

measures for TEC&SC species as shown in Table E-4.1. Additionally, the BLM may recommend that the 

Wyoming Oil and Gas Conservation Commission and State Land Board adopt policies to ensure ESA 

compliance during well permitting on state and private lands. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 10 

Table E-4.1 BLM Requirements for Inventory, Monitoring, and Protection of Threatened, Endangered, 

Candidate, and Species of Special Concern, Continental Divide/ WamsutterII Natural Gas 

Project, Sweetwater and Carbon Counties, Wyoming, 1999. 

Land Status BLM Requirements1 

BLM surface/BLM subsurface Conduct data gathering and avoid or mitigate

impacts as appropriate.

BLM surface/non-BLM subsurface Conduct data gathering and avoid or mitigate

impacts as appropriate.

Non-BLM surface/BLM subsurface2 Request landowner permission to access lands for 

inventory and, if granted, conduct data gathering on 

affected areas and require avoidance or mitigation of 

impacts, as appropriate. If permission is not granted, 

the BLM will require Operators to obtain access 

through appropriate legal action and, if obtained, 

conduct data gathering on affected areas and avoid 

or mitigate impacts, as appropriate. If legal access 

is not obtained, no on_site data gathering will be 

conducted, and all analyses will be done using 

alternate methods and so stated in the appropriate 

analysis document. If it is suspected that TEC&SC 

species or their critical habitats may be affected, the 

USFWS will be notified. 

Non-BLM surface/non-BLM subsurface and Request landowner permission to access lands for 

non_BLM surface/BLM subsurface3 inventory and, if granted, conduct data gathering on 

affected areas and require avoidance or mitigation of 

impacts, as appropriate. If permission is not granted, 

no on_site data gathering will be conducted and all 

analyses will be done using alternate methods and so 

stated in the appropriate analysis document. If it is 

suspected that TEC&SC species or their critical 

habitats may be affected, the USFWS will be 

notified. 

1 The BLM may also require Operators to obtain appropriate TEC&SC species resource data. 

2 For actions that are a direct result of the subsurface estate value (e.g., oil and gas exploration and 

development). 

3 For actions that are not a direct result of the subsurface estate (e.g., ROWs). 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 10 

E-5.0 SPECIES ACCOUNTS 

This chapter presents a discussion of the status, habitat, potential effects, and mitigation for TEC&SC animal 

and plant species that may occur in the CD/WIIPA and surrounding area. A summary of the potential effects 

and mitigations is presented in Table 5.1. Further detail on project and cumulative impacts to vegetation and 

wildlife is provided in EIS Sections 4.2.1, 4.2.2, 4.2.3, and 4.2.5. 

E-5.1 MAMMALS 

E-5.1.1 Black-footed Ferret 

E-5.1.1.1 Current Status and Habitat Use 

The black-footed ferret (BFF), a federal endangered species, was once distributed throughout the high plains 

of the Rocky Mountain and western Great Plains regions (Forrest et al. 1985). Prairie dogs are the main food 

of BFFs (Sheets et al. 1972), and few BFFs have been historically collected away from prairie dog colonies 

(Forrest et al. 1985). BFFs were considered extinct until a small population was discovered near Meeteetse, 

Wyoming, in 1981. Following outbreaks of distemper, surviving BFFs were brought into captivity and a 

captive breeding program was initiated (USFWS 1988). BFFs were reintroduced in the Shirley Basin of 

central Wyoming in 1991; this reintroduction effort continues with the aid of annual supplemental releases. 

Two BFF sightings and the discovery of a partially buried BFF skull have been recorded within the CD/WIIPA 

(WGFD 1995; WNDDB 1995). In July 1972, two young ferrets were observed in the central portion of the 

CD/WIIPA about 5 mi south of Interstate Highway 80 (WNDDB 1995). On August 14, 1975, a BFF was 

observed in saltbush habitat in the northern portion of the CD/WIIPA (WGFD 1995). The most recent 

evidence of BFF occurrence within the CD/WIIPA, a partially buried skull, was found in August 1981. This 

BFF skull was discovered in a white-tailed prairie dog town along the northeastern border of the CD/WIIPA 

and appeared to be quite weathered (WNDDB 1995). Seven additional BFF observations have been recorded 

within the GCIAA, with the latest of these occurring in June 1977, about 5 mi north of Rawlins along State 

Highway 287. 

The CD/WIIPA does not overlap any designated BFF management areas, and it is very unlikely that ferrets 

currently inhabit the CD/WIIPA. No evidence of BFF occupation has been documented in the CD/WIIPA for 

approximately 15 years. 

E-5.1.1.2 Potential Effects 

At present, it is anticipated that the proposed project is unlikely to adversely affect this species because BFFs 

are unlikely to occur in the area, and mitigation measures for BFFs will be applied. 

The proposed project will likely have only negligible additional impacts, if any, to the cumulative effects on 

BFF habitat from ranching, mining, other oil and gas projects, and transportation and on prairie dogs from pest 

control and recreational shooting. However, if mitigation measures for BFFs are not applied on nonfederal 

lands, cumulative impacts may adversely affect BFFs and BFF habitat. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

Table E-5.1 Summary of Potential Effects and Mitigations for Federal Threatened, Endangered, 

Candidate, and Special Concern Animal and Plant Species and Their Habitats On and 

Adjacent to the CD/WIIPA, Sweetwater and Carbon Counties, Wyoming, 1999. 

Species Level of Impact 

to Species1 

Level of Impact 

to Habitat1 

Mitigation Measures 

ANIMALS 

Black-footed ferret 1; potential resident 1; potential habitat only Search per USFWS (1989) 

guidelines to ensure no ferrets are 

in areas to be disturbed, and 

consult with USFWS if ferrets are 

found; disturbance to prairie dog 

colonies (i.e., potential ferret 

habitat) will be minimized. 

Long-eared myotis 3; rare visitor 3; preferred habitat not 

present 

Reserve, workover, and 

evaporation/production pits will 

be adequately protected (e.g., 

netted), as directed by the BLM, 

to prohibit bat access. 

Long-legged myotis 3; rare visitor 3; negligible disturbance to 

foraging habitats 

Reserve, workover, and 

evaporation/production pits will 

be adequately protected (e.g., 

netted), as directed by the BLM, 

to prohibit bat access. 

Pale Townsend*s 

big-eared bat 

3; uncommon visitor 3; negligible disturbance to 

foraging habitats 

Reserve, workover, and 

evaporation/production pits will 

be adequately protected (e.g., 

netted), as directed by the BLM, 

to prohibit bat access. 

Pygmy rabbit 3; not present 3; potential habitat only None. 

Small-footed myotis 3; uncommon visitor 3; negligible disturbance to 

foraging habitats 

Reserve, workover, and 

evaporation/production pits will 

be adequately protected (e.g., 

netted), as directed by the BLM, 

to prohibit bat access. 

Swift fox 2; potential resident 2; negligible disturbance to 

potential habitat 

None. 

Bald eagle 1; uncommon visitor 1; no known nests or roosts 

in CDPA; negligible 

disturbance to potential 

foraging habitat 

If bald eagle roosts or active 

nests are found, no surface 

disturbance/occupancy will be 

allowed within 1.0 mi of active 

roosts or nests during periods of 

use. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

Black tern 3; uncommon visitor 3; minimal amount of Wetland habitats will be avoided 

wetland habitat present during construction. 

Columbian sharp_tailed 

grouse 

3; not present 3; preferred habitat not 

present (i.e., outside 

species known range) 

None. 

Ferruginous hawk 5; foraging birds may be 

displaced from disturbed 

areas 

3; nest disturbance 

unlikely; potential for 

some displacement from 

foraging habitat, but 

overall disturbance to such 

Nest searches will be conducted; 

no surface disturbance will be 

allowed within 1.0 mi of active 

nests during nesting season; 

artificial nest structures will be 

habitat will be negligible erected to replace nests built on 

ancillary structures. 

Loggerhead shrike 5; nesting and foraging 

birds may be displaced 

from disturbed areas 

3; negligible disturbance 

to nesting and/or foraging 

habitats 

Site-specific searches for shrike 

nests will be conducted; nesting 

habitat will be avoided, where 

possible. 

Mountain plover 4; nesting and foraging 

birds may be displaced 

from disturbed areas 

2; unknown amount of 

potential nesting and 

foraging habitat will be 

disturbed 

Disturbance to potential habitat 

will be minimized; site-specific 

searches for nesting plovers will 

be conducted; nesting birds will 

not be disturbed; construction 

activities may be delayed during 

nesting period. 

Northern goshawk 3; rare visitor 3; preferred habitats not None. 

present 

Peregrine falcon 1; rare visitor; no known 

nests in the area 

1; nesting habitat not 

present; negligible 

disturbance to foraging 

habitats 

If nests are found in the area, no 

activity or surface disturbance 

will be allowed within 1.0 mi of 

active nests during nesting 

season. 

Trumpeter swan 3; rare visitor 3; minimal amount of 

wetland habitat present 

None. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

Western burrowing owl 5; nesting and foraging 3; negligible disturbance of Site-specific searches for nesting 

birds may be displaced potential nesting and burrowing owls will be 

from disturbed areas foraging habitat conducted; nesting birds will not 

be disturbed; construction 

activities may be delayed during 

nesting period; disturbance to 

prairie dog colonies will be 

minimized. 

White-faced ibis 3; uncommon visitor 3; minimal amount of None.

foraging habitat present

Eastern short-horned 5; some mortality 3; negligible disturbance to None. 

lizard possible during habitats given the amount

construction, but unlikely of adjacent potential

to adversely impact habitat

population health

Bonytail chub 1; not present 1; no degradation of Proper and adequate construction 

downstream waters techniques will be used when 

waterways must be crossed. 

Colorado squawfish 1; not present 1; no degradation of Same as above.

downstream waters

Flannelmouth sucker 3; not present 3; no degradation of Proper and adequate construction 

downstream waters techniques will be used when 

waterways must be crossed. 

Humpback chub 1; not present 1; no degradation of Same as above.

downstream waters

Razorback sucker 1; not present 1; no degradation of Same as above.

downstream waters

Roundtail chub 3; not present 3; no degradation of Same as above.

downstream waters

PLANTS 

Big Piney milkvetch 3; unlikely to be present 3; outside known range Site-specific surveys will be 

conducted for populations; 

conflict resolution with BLM and 

USFWS will be undertaken; 

potential habitat will be avoided, 

where possible. 
______________________________________________________________________________ 

1

2

3

4

 5 

1 

Record of Decision, Continental Divide/Wamsutter II 1 

Cedar Rim thistle 3; populations 3; minimal disturbance to Same as above.

potentially present potential habitats

Devil*s gate twinpod 3; unlikely to be present 3; outside known range Same as above. 

Gibben*s beardtongue 3; unlikely to be present 3; outside known range Same as above. 

Large-fruited bladderpod 3; populations 3; minimal disturbance to Same as above.

potentially present potential habitats

Mystery wormwood 3; populations 3; minimal disturbance to Same as above.

potentially present potential habitats

Opal phlox 3; populations 3; minimal disturbance to Same as above.

potentially present potential habitats

Ownbey*s thistle 3; unlikely to be present 3; outside known range Same as above. 

Tufted twinpod 3; unlikely to be present 3; outside known range Same as above. 

Utes ladies' tresses 3; unlikely to be present 3; outside known range Same as above. 

Wyoming tansymustard 3; populations 3; minimal disturbance to Same as above.

potentially present potential habitats

Level of impact with project-wide mitigation--a relative measure of the intensity or "seriousness" of the project's 

impacts if only the project's general or project-wide mitigation measures were implemented.

= is not likely to adversely affect listed species.

= is not likely to adversely affect candidate species.

= is not likely to adversely affect species of special concern.

= possible adverse effects to candidate species.

= possible adverse effects to species of special concern. 
Record of Decision, Continental Divide/Wamsutter II 10 

E-5.1.1.3 Mitigation Measures 

Although it is very unlikely that BFFs are present in the vicinity of the proposed project, white-tailed prairie 

dog colonies are scattered throughout the CD/WIIPA and adjacent areas and could provide a potential prey 

base and habitat for BFFs. Aerial surveys of prairie dog colonies/complexes within the CD/WIIPA in 1995 and 

1996 revealed that numerous prairie dog colonies are scattered throughout the CD/WIIPA (see Map 3.10 in the 

EIS); some of these colonies may encompass several hundred acres. If sufficient acreage and density of 

prairie dog colonies are present for potential BFF habitat (as defined in USFWS [1989] guidelines) in areas to 

be disturbed by the proposed project, a search per USFWS guidelines will be made on a site-specific basis to 

ensure that ferrets are not present in the area prior to construction activity. If BFFs are discovered in the 

CD/WIIPA, the USFWS, WGFD, and BLM will be consulted to determine the specific procedures necessary 

to protect the animals under established guidelines. To minimize disturbance to prairie dog colonies, 

project-required facilities will be located outside of prairie dog colonies, where possible. 

E-5.1.2 Long-eared Myotis (Bat) 

E-5.1.2.1 Current Status and Habitat Use 

The long-eared myotis, a species of special concern, occurs throughout southwestern Canada, the western U.S., 

and Baja California (Hall 1981); it has also been observed throughout Wyoming (Clark and Stromberg 1987). 

This bat species is typically found in coniferous forests in mountainous areas (Barbour and Davis 1969) and is 

most common in ponderosa pine forests (Clark and Stromberg 1987). The feeding habits of the long-eared 

myotis are poorly understood, but their diet is probably composed primarily of insects since they feed well 

after sunset among trees and over open water (Barbour and Davis 1969; Clark and Stromberg 1987). A single 

observation of a long-eared myotis was recorded in September 1980, about 3 mi south-southwest of the 

CD/WIIPA (WGFD 1995). Due to the lack of forested habitats within the CD/WIIPA, however, it is likely 

that this was a migrating individual moving through the CD/WIIPA. It is anticipated that this bat species 

occurs only occasionally in the area for relatively short periods of time. 

E-5.1.2.2 Potential Effects 

Given the lack of observations and preferred habitat (i.e., coniferous forest) for the long_eared bat within the 

CD/WIIPA, it is unlikely that this species will be affected by the Proposed Action or alternatives. Cumulative 

impacts to this species or its preferred habitats will not increase as a result of the proposed project. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 10 

E-5.1.2.3 Mitigation Measures 

Reserve, workover, and evaporation/production pits could be attractive to foraging bats, and potentially 

hazardous sites will be adequately protected (e.g., netted), as directed by the BLM, to prohibit bat access. 

E-5.1.3 Long-legged Myotis 

E-5.1.3.1 Current Status and Habitat Use 

The long-legged myotis is a species of special concern, and is one of eight small mouse_eared bats known to 

occur in Wyoming. The long-legged myotis occurs throughout the western half of North America (Hall 1981) 

and has been reported as the most abundant mouse-eared bat species in the western U.S. (Clark and Stromberg 

1987). It has been observed in a variety of habitats in Wyoming, including coniferous (e.g., Ponderosa pine) 

and deciduous forests, basin-prairie and mountain-foothills shrublands, and riparian areas (Clark and Stromberg 

1987; WGFD 1992). The long-legged myotis roosts in tree hollows, snags, buildings, rock crevices, mines, 

and caves (Clark and Stromberg 1987). This species may hibernate in Wyoming during the winter and is 

extremely susceptible to disturbance during hibernation. Long-legged myotis feed exclusively on flying 

insects, especially moths. 

Long-legged myotis have not been observed in the CD/WIIPA according to WNDDB and WGFD records. This 

lack of observations may, at least in part, be due to the nocturnal activity of this species. Long-legged myotis 

are known to occur in a cave in the Shirley Mountains, approximately 60 mi east-northeast of the CD/WIIPA 

(personal communication, January 1995, with Bob Luce, Nongame Mammal Biologist, WGFD). It is possible 

that this bat species occasionally forages over habitats within the CD/WIIPA; however, it is unlikely that it is 

a common resident or visitor in the area. 

E-5.1.3.2 Potential Effects 

The long-legged myotis is an unlikely visitor to the CD/WIIPA given the lack of observations for the area. 

Individuals of this bat species may forage over the CD/WIIPA for short periods of time, but probably roost in 

locations remote from the area. Therefore, it is unlikely that this species will be affected by the Proposed 

Action or alternatives. Potential cumulative impacts to this species or its preferred habitats will not increase 

as a result of the proposed project. 

E-5.1.3.3 Mitigation Measures 

Reserve, workover, and evaporation/production pits could be attractive to foraging bats; and these potentially 

hazardous sites will be adequately protected (e.g., netted), as directed by the BLM, to prohibit bat access. 

E-5.1.4 Pale Townsend*s Big-eared Bat 

E-5.1.4.1 Current Status and Habitat Use 

The pale Townsend's big-eared bat, a species of special concern, occurs in southern British Columbia, 

throughout most of the intermountain and Rocky Mountain regions of the western U.S., and as far south as 

northern Mexico (Hall 1981). This species also occurs throughout Wyoming (Clark and Stromberg 1987) and 

most commonly forages in desert shrublands, pinyon-juniper woodlands, and dry coniferous forests (Barbour 

and Davis 1969). Like many bats, this species roosts primarily in caves and abandoned mine shafts. Pale 

Townsend's big-eared bats have been observed in a cave in the Shirley Mountains approximately 60 mi 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 10 

east-northeast of the CD/WIIPA (personal communication, January 1995, with Bob Luce, Nongame Mammal 

Biologist, WGFD). The pale Townsend's big_eared bat is a moth specialist and hunts in flight (Clark and 

Stromberg 1987). Although no bats of this species have been observed on the CD/WIIPA, it is probably an 

occasional visitor to the area. 

E-5.1.4.2 Potential Effects 

Although the pale Townsend's big-eared bat may be the most likely TEC&SC bat species to inhabit and/or 

visit the CD/WIIPA due to its preference for habitats commonly found in the area, the probability of a 

big-eared bat being displaced or harmed by project construction and/or operation is relatively slight. 

Therefore, it is unlikely that the Proposed Action or alternatives will adversely affect this species. Also, 

potential cumulative impacts to this species or its preferred habitats will not increase as a result of the 

proposed project. 

E-5.1.4.3 Mitigation Measures 

Reserve, workover, and evaporation/production pits could be attractive to foraging bats, and potentially 

hazardous sites will be adequately protected (e.g., netted), as directed by the BLM, to prohibit bat access. 

E-5.1.5 Pygmy Rabbit 

E-5.1.5.1 Current Status and Habitat Use 

The pygmy rabbit, a species of special concern, inhabits the Great Basin of northern Nevada, eastern Oregon, 

western Utah, and southern Idaho (Clark and Stromberg 1987). The population of pygmy rabbits in 

southwestern Wyoming is believed to be isolated from the western Utah population. The Utah population of 

pygmy rabbits is more than 100 mi to the west and separated from the Wyoming population by the Wasatch 

Mountains (Campbell et al. 1982). Pygmy rabbits in southwestern Wyoming are limited to dense tall stands of 

big sagebrush; this habitat is usually found along intermittent streams and occasional riparian areas in 

sagebrush-grasslands (Clark and Stromberg 1987; WGFD 1992). The vast majority (up to 99%) of the diet of 

this rabbit species consists of sagebrush, although it may include some grasses during summer. 

Pygmy rabbits have been observed north and northeast of Rock Springs, Wyoming (WGFD 1995; WNDDB 

1995). The closest recorded observation to the CD/WIIPA was approximately 14 mi northwest of the area and 

included both pellets and burrows. It is unlikely that pygmy rabbits occur within the CD/WIIPA due to their 

limited distribution and specific habitat preference. 

E-5.1.5.2 Potential Effects 

It is unlikely that the Proposed Action or alternatives will adversely affect the pygmy rabbit population in 

southwestern Wyoming. Since there is limited information on the exact distribution of this species within the 

state, an effort will be made during the APD site analysis to look for sign of pygmy rabbits (e.g., 

observations, burrows, pellets) on those potential sites containing large dense stands of big sagebrush. The 

proposed project is unlikely to increase cumulative effects on pygmy rabbit populations or their preferred 

habitats. 
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Record of Decision, Continental Divide/Wamsutter II 10 

E-5.1.6 Small-footed Myotis 

E-5.1.6.1 Current Status and Habitat Us e 

The small-footed myotis, a species of special concern, occurs throughout western North America (Hall 1981) 

and has been captured throughout Wyoming (Clark and Stromberg 1987). This species ranges throughout 

many of the habitats found in Wyoming, from sagebrush-grasslands to montane forests (Clark and Stromberg 

1987; WGFD 1992). Small_footed myotis commonly roost in caves, abandoned mine shafts, rock crevices, 

and buildings (Barbour and Davis 1969); they are extremely tolerant of low temperatures during hibernation. 

The small-footed myotis feeds primarily on moths and beetles, hunts in flight, and uses sonar to locate prey. 

Although there are no recorded observations of this species within the CD/WIIPA, it is likely that small-footed 

myotis occasionally forage over the area. 

E-5.1.6.2 Potential Effects 

Small-footed myotis have not been observed within the CD/WIIPA, but may be potential visitors to the area. 

However, it is anticipated that the small-footed myotis will not be adversely affected by the Proposed Action 

or alternatives, and no increase in cumulative effects to this species is anticipated. 

E-5.1.6.3 Mitigation Measures 

Reserve, workover, and evaporation/production pits could be attractive to foraging bats, and potentially 

hazardous sites will be adequately protected (e.g., netted), as directed by the BLM, to prohibit bat access. 

E-5.1.7 Swift Fox 

E-5.1.7.1 Current Status and Habitat Use 

The swift fox, a federal candidate species (proposed threatened), is a resident of the Great Plains from the 

northern Rocky Mountain foothills in southern Canada to western Texas (Clark and Stromberg 1987). In 

Wyoming, this species primarily inhabits the eastern Great Plains grasslands, occasionally utilizing 

agricultural lands and irrigated native meadows. Prey for the swift fox includes small mammals, insects, and 

birds (WGFD 1992). 

Several observations of swift fox have been reported from the Chain Lakes and Luman Ranch areas of the 

northern CD/WIIPA (personal communication, July 15, 1995, with Greg Hiatt, Wildlife Biologist, WGFD). 

Many of these swift fox observations were in habitats generally considered atypical for this species (e.g., 

greasewood). Another observation of a swift fox occurred in 1977 west of the CD/WIIPA and GCIAA 

(WNDDB 1995). 

E-5.1.7.2 Potential Effects 

Disturbance of sagebrush-grasslands in the northern portion of the CD/WIIPA may reduce potential habitat for 

swift fox; however, no adverse effects to swift fox from the Proposed Action or alternatives are anticipated due 

to the relatively infrequent use of the area by this species and the relatively small amount of potential habitat 

disturbed. As a result, the proposed project will have only negligible additional effects, if any, to existing 

cumulative effects on swift fox habitat in the region. 

E-5.2 BIRDS 
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Record of Decision, Continental Divide/Wamsutter II 10 

E-5.2.1 Bald Eagle 

E-5.2.1.1 Current Status and Habitat Use 

The bald eagle is a federally threatened species that requires cliffs, large trees, or sheltered canyons 

associated with concentrated food sources (e.g., fisheries or waterfowl concentration areas) for nesting and/or 

roosting areas (Edwards 1969; Snow 1973; Call 1978; Steenhof 1978; Peterson 1986). Bald eagles forage over 

wide areas during the non-nesting season (i.e., fall and winter) and scavenge on animal carcasses such as 

pronghorn, deer, and elk. Bald eagles were only recently downlisted from a federally endangered status. 

No known bald eagle nests or winter roosts are present on or within 2 mi of the CD/WIIPA; the lack of suitable 

nesting or winter roosting habitats within the CD/WIIPA precludes its use for such activities by bald eagles. 

There is only one recorded observation of a bald eagle occurring within the CD/WIIPA (WGFD 1995). Bald 

eagles, however, have been observed flying over and foraging throughout the GCIAA (WGFD 1995), and nests 

and concentrated winter roost sites occur along the Little Snake River in the southeastern portion of the 

GCIAA approximately 25 mi south/southeast of the CD/WIIPA. These birds tend to forage on road_killed deer 

in the area (personal communication, November 1993, with Bob Oakleaf, WGFD). 

E-5.2.1.2 Potential Effects 

Migrating bald eagles and those wintering in the Little Snake River drainage may occasionally use the 

CD/WIIPA for foraging; however, such use will likely be intermittent and for relatively short periods. Given 

this intermittent use and the lack of nesting and roosting habitat on the CD/WIIPA, it is anticipated that there 

will be no effect to this species from the Proposed Action or alternatives. 

Cumulative impacts resulting from oil and gas development, surface mining, urban developments, and roads 

are unlikely to adversely affect bald eagles; some additional foraging habitat will be removed, but large areas 

remain available to eagles. Also, all developments (including the proposed project) will avoid winter roosts 

and active nests, further minimizing potential disturbance to the species. 

E-5.2.1.3 Mitigation Measures 

In the unlikely event that bald eagle roosting areas are found within the CD/WIIPA, a No Surface Occupancy 

restriction will be applied to a 1-mi buffer zone around winter roosts, and the area will be closed to 

surface-disturbing activities (e.g., construction, drilling) from November 1 through April 1. If an active bald 

eagle nest is found within the CD/WIIPA, no activity or surface disturbance will be allowed within a 1-mi 

radius of the nest between February 1 and July 31. 

E-5.2.2 Black Tern 

E-5.2.2.1 Current Status and Habitat Use 

Black terns, a species of special concern, are spring and summer visitors to the U.S. which frequent marshes 

and aquatic areas as feeding and breeding sites (Scott 1987; Ehrlich et al. 1988; WGFD 1992). Nests are 

usually constructed in dense emergent vegetation, often on top of muskrat homes, floating debris, or little 

knolls in marshy areas (Bailey and Niedrach 1965; Ehrlich et al. 1988). Loss of wetland areas may be 

contributing to the decline of this species (Ehrlich et al. 1988). 
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Record of Decision, Continental Divide/Wamsutter II 10 

The lack of extensive wetland areas within or adjacent to the CD/WIIPA may be the reason for the lack of 

observations of this species in the project area. There is only one recorded observation of black terns within or 

adjacent to the CD/WIIPA, although five additional observations of black terns have been recorded within the 

GCIAA (WGFD 1995). 

E-5.2.2.2 Potential Effects 

Because black terns are uncommon visitors to the CD/WIIPA and wetlands in the area will be avoided during 

construction, where possible, this species will not be adversely affected by the Proposed Action or alternatives. 

E-5.2.3 Columbian Sharp-tailed Grouse 

E-5.2.3.1 Current Status and Habitat Use 

The Columbian sharp-tailed grouse, a species of special concern, is one of two sharp-tailed grouse subspecies 

found in Wyoming, the other being the plains sharp-tailed grouse. The Columbian sharp-tailed grouse is 

restricted to sagebrush-dominated mountain shrub communities in south-central Wyoming (Klott n.d.). In 

addition to sagebrush, these communities contain serviceberry, chokecherry, snowberry, bitterbrush, 

andrabbitbrush. Although Columbian sharp-tailed grouse were once found throughout western and 

southwestern Wyoming, herbicide treatments of large blocks of sagebrush/grass and mountain shrub habitats 

between 1950 and 1980 may have significantly reduced available habitat for these grouse. 

There are no recorded observations of Columbian sharp-tailed grouse within or immediately adjacent to the 

CD/WIIPA. The majority of recorded observations for this species occur in the southeastern portion of the 

GCIAA (WGFD 1995), where the birds gather in leks during the spring breeding season. 

E-5.2.3.2 Potential Effects 

Columbian sharp-tailed grouse are not likely to occur within the CD/WIIPA or within 10mi of the area. 

Therefore, there will be no effects to Columbian sharp-tailed grouse resulting from the Proposed Action or 

alternatives. Also, there will be no increase in cumulative effects to Columbian sharp-tailed grouse as a result 

of the proposed project. 

E-5.2.4 Ferruginous Hawk 

E-5.2.4.1 Current Status and Habitat Use 

The ferruginous hawk is a species of special concern that breeds in semi-arid plains and intermountain areas of 

the Great Basin and Great Plains (Evans 1983). This species often nests on low cliffs, buttes, and cutbanks 

(Call 1978), as well as in juniper or sagebrush along the edges of pinyon-juniper communities. Ferruginous 

hawks feed primarily on small to medium-sized mammals such as jackrabbits, cottontail rabbits, ground 

squirrels, and prairie dogs (Sherrod 1978). 

Ferruginous hawks occur throughout the CD/WIIPA and GCIAA (WGFD 1995). A raptor nest survey of a 

majority of the CD/WIIPA and an adjacent 1.0-mi buffer was conducted during the 1995 and 1996 breeding 

seasons to provide current information on the activity status of raptor nests. Of a total of 684 raptor nests 

observed, 524 (76.6%) were ferruginous hawk nests. The majority of active raptor nests (69.7%, 23 nests) 

were also those of ferruginous hawks. Most of these ferruginous hawk nests are located in the southern half 

and eastern/northeastern portion of the CD/WIIPA. It is likely that at least several hundred more ferruginous 

hawk nests occur within the entire GCIAA. Ferruginous hawks regularly use the CD/WIIPA for foraging. 
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Record of Decision, Continental Divide/Wamsutter II 10 

E-5.2.4.2 Potential Effects 

The principle threat to ferruginous hawks from project activities is disturbance during nesting. Potential 

conflicts between active nest sites and project-related activities will be resolved by the BLM, in consultation 

with the USFWS and WGFD, to ensure that minimal impacts will occur to ferruginous hawks or their nesting 

success. 

There will be a LOP loss of 8,300 acres, or 0.8%, of potential ferruginous hawk foraging habitat within the 

CD/WIIPA as a result of new disturbance from the Proposed Action. LOP loss of potential foraging habitat 

under the two development alternatives will likely be slightly less than that under the Proposed Action. In 

addition, ferruginous hawks avoid areas in close proximity to human activity; the presence of workers will 

temporarily reduce the availability of adjacent foraging habitat on a localized basis. Ferruginous hawks do not 

avoid areas immediately adjacent to man-made structures if humans are not present and even build nests on 

active oil or gas field facilities in the region (personal communication, January 1992, with Bob Tigner, 

Planning and Environmental Specialist, BLM). Impacts to ferruginous hawks on the CD/WIIPA resulting from 

foraging habitat losses and temporary displacement may adversely affect the species under either the Proposed 

Action or alternative actions; however, sufficient foraging habitat in areas removed from disturbance sites will 

be available to support ferruginous hawks. 

Reduction in ferruginous hawk prey species is not anticipated to be a major concern since disturbance will be 

scattered throughout the CD/WIIPA. Therefore, the reduction in prey species will occur over a relatively large 

number of potential ferruginous hawk territories, limiting prey reduction to negligible levels in any one 

territory. 

Cumulative habitat loss for ferruginous hawks (i.e., foraging and nesting habitat) due to all past, proposed, and 

potential future developments in the region (e.g., oil and gas development, surface mining) is unknown; 

however, sufficient habitats remain and will remain undisturbed and available to ferruginous hawks. 

E-5.2.4.3 Mitigation Measures 

Although no potential conflict between active ferruginous hawk nest sites and project activity is anticipated at 

present, any that may arise during the project will be resolved by the BLM, in consultation with the USFWS 

and WGFD, to ensure that adverse impacts to the species will be minimized (see Wildlife Protection Plan, 

EIS Appendix D). Surveys will be conducted to document the status of ferruginous hawk nests so that 

appropriate protective measures are stipulated during APD and ROW reviews. Activities near active 

ferruginous hawk nests will be prohibited within a 1.0-mi radius or other distance (determined by the BLM) to 

avoid disturbing birds from February 1 through July 31. 

Ferruginous hawks occasionally construct nests on well site facilities in Wyoming (personal communication, 

January 1992, with Bob Tigner, BLM). If ferruginous hawks nest on production/operation facilities, artificial 

nesting structures will be provided as directed by the BLM in consultation with the USFWS. Artificial nesting 

structures have been successfully used by ferruginous hawks in the region (Call and Tigner 1991). The 

Operators will assist in the erection of artificial nesting structures. 
Record of Decision, Continental Divide/Wamsutter II 10 

E-5.2.5 Loggerhead Shrike 

E-5.2.5.1 Current Status and Habitat Use 

In Wyoming, the loggerhead shrike, a species of special concern, inhabits sagebrush_grasslands associated 

with stands of pinyon-juniper and larger shrubs (WGFD 1992). These habitats provide ample open areas in 

which to forage for insects and small vertebrates (Craig 1978; Bystrak 1983), as well as trees and shrubs in 

which to build their large bulky nests (Graber et al. 1973). Declines in loggerhead shrike populations have 

been noted over the past 40 years, and the declines appear to be most significant near the periphery of their 

range (the midwest and eastern U.S.) (Bystrak 1983). Reasons for the decline are unknown; habitat changes 

and pesticide use may play a role. 

There are numerous recorded observations of loggerhead shrikes both within and adjacent to the CD/WIIPA 

(WGFD 1995), and the species is a fairly common summer resident of the area (WGFD 1992). Loggerhead 

shrikes likely nest within the CD/WIIPA. 

E-5.2.5.2 Potential Effects 

There will be a LOP loss of 8,300 acres of potential loggerhead shrike foraging and breeding habitat within the 

CD/WIIPA as a result of new disturbance from the Proposed Action; this represents approximately 0.8% of the 

CD/WIIPA. LOP loss of potential foraging and breeding habitat under the two development alternatives will 

likely be slightly less than that under the Proposed Action. Impacts to loggerhead shrikes on the CD/WIIPA 

resulting from foraging and breeding habitat loss, as well as human presence, may adversely affect the 

species; however, it is anticipated that loggerhead shrikes will not be permanently displaced, and shrikes will 

probably shift their foraging activity to surrounding areas not impacted by the project. 

Because of the relatively minimal amount of loggerhead shrike nesting habitat that will be disturbed by the 

proposed project for the LOP and the scattered nature of this disturbance, it is anticipated that the proposed 

project will result in minimal cumulative impacts to this species. 

E-5.2.5.3 Mitigation Measures 

Surveys for active loggerhead shrike nests will be implemented prior to disturbance during on-site inspections 

of proposed ROWs and well locations conducted as components of ROW application and APD review 

processes. If active loggerhead shrike nests are found in the area to be disturbed, construction activities will 

be rescheduled such that the birds will not be disturbed during the nesting season. 

E-5.2.6 Mountain Plover 

E-5.2.6.1 Current Status and Habitat Use 

The mountain plover is a candidate species (proposed threatened) inhabiting the high dry short_grass 

plains/prairies east of the Rocky Mountains (Dinsmore 1983), as well as the sagebrush grasslands throughout 

Wyoming (WGFD 1997). It is also known from northern Utah and northwestern Colorado (Knopf 1996). The 

focus of breeding activity appears to be northeastern Colorado (Graul and Webster 1976). Parrish et al. (1993) 

noted that mountain plover nests in northeastern Wyoming were found in areas of short (<4 inches) vegetation 

on slopes of less than 3%; any short grass, very short shrub, or cushion plant vegetation type could be 

considered nesting habitat. In Colorado, the mountain plover diet is composed of 99.7% arthropods, with 

beetles, grasshoppers, crickets, and ants the most important food items (Baldwin 1971). Breeding bird surveys 
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Record of Decision, Continental Divide/Wamsutter II 10 

between 1966 and 1987 show an overall decline in the continental population of mountain plovers [U.S. 

Department of Agriculture, Forest Service [USFS] 1994a). Surveys completed in 1991 indicate that only 4,360 

to 5,610 mountain plovers remain on the North American continent (USFS 1994b). Probably the most 

important reasons for the decline of the mountain plover are human impacts and habitat alteration on breeding 

grounds and the degradation in the quality of wintering habitats (e.g., southern Texas, California) (Knopf 1994, 

1996). Loss of breeding habitat due to cultivation and prey base declines resulting from pesticide use are also 

threats to mountain plover survival (Wiens and Dyer 1975). Cattle often maintain the open blue grama/buffalo 

grass habitat favored by mountain plovers, so livestock grazing may benefit the species (Klipple and Costello 

1960). 

Mountain plovers have been observed throughout the CD/WIIPA and adjacent areas, and many of these 

observations occurred during the breeding season (WGFD 1995). Therefore, it is likely that mountain plovers 

not only forage within the CD/WIIPA, but also nest within the area. 

E-5.2.6.2 Potential Effects 

Loss of potential mountain plover breeding and foraging habitat due to proposed project activities may 

adversely affect the species. However, while the total extent of mountain plover habitat on the CD/WIIPA has 

not been defined, with the limited and scattered nature of habitat disturbance as well as proposed survey and 

avoidance measures, it is anticipated that this species will not be jeopardized or permanently displaced. 

Cumulative impacts to the local mountain plover population will probably not jeopardize regional populations. 

Although disturbance due to oil and gas development, surface mining, urban developments, and roads has 

removed an unknown portion of potential mountain plover nesting habitat, it is unlikely that the extent of this 

habitat removal has jeopardized plover reproduction due to the dispersed nature of disturbance associated with 

oil and gas and other developments throughout the region. Therefore, displaced plovers will likely have 

adequate alternate habitats for foraging and nesting activities. Surface disturbance resulting from the proposed 

project will slightly increase cumulative impacts to mountain plovers, and such impacts are unknown for the 

foreseeable future. 

E-5.2.6.3 Mitigation Measures 

Mountain plover habitats will be avoided, where practical, and if construction within suitable mountain plover 

habitat (i.e., areas with low-growing vegetation) is planned between April 15 and June 30, surveys for nesting 

mountain plovers (i.e., a nest and/or defending pairs of adult mountain plovers) will be implemented prior to 

disturbance (see SectionE_4.1, item 17). Surveys will be conducted during on-site inspections of proposed 

ROWs and well locations that are conducted as components of ROW application and APD review processes, 

and the USFWS will be consulted regarding effects determinations. If mountain plover nesting is found in the 

area, the USFWS will be consulted and construction activities will be rescheduled such that the birds will not 

be disturbed. Surveys will not be conducted for construction activities planned for the period July 1 through 

April 15. 

E-5.2.7 Northern Goshawk 

E-5.2.7.1 Current Status and Habitat Use 

The northern goshawk, a species of special concern, inhabits coniferous forests, especially those with a 

significant Douglas fir and lodgepole pine component (WGFD 1992). Goshawks forage in a variety of 

habitats, including sagebrush-grassland areas adjacent to stands of coniferous forest. Prey includes small 
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Record of Decision, Continental Divide/Wamsutter II 10 

mammals, waterfowl, songbirds, and insects (Terres 1980). Nests are often built high (i.e., >30 ft) in 

coniferous trees; some goshawks have been observed nesting in mature cottonwoods along riparian corridors 

(Call 1978). 

Although northern goshawks have been observed in pinyon-juniper habitats within the GCIAA, no goshawks 

have been observed within the CD/WIIPA (WGFD 1995; WNDDB 1995). While goshawks have been 

observed west of the CD/WIIPA (within 5 mi) (WGFD 1995), in general, habitats within the CD/WIIPA are 

not suitable for northern goshawk nesting or foraging. 

E-5.2.7.2 Potential Effects 

Since the CD/WIIPA lacks suitable northern goshawk habitat and no goshawks have been observed within the 

CD/WIIPA, the Proposed Action or alternatives will not adversely impact this species. Cumulative effects to 

northern goshawks will not increase as a result of the proposed project. 

E-5.2.8 Peregrine Falcon 

E-5.2.8.1 Current Status and Habitat Use 

A federally endangered species, the peregrine falcon nests on tall cliffs, usually within 1.0mi of a stream or 

river, or extensive brush or woodlands; these habitats provide concentrated food sources and open areas in 

which to hunt (Snow 1972; Call 1978). Peregrine falcons nest among substantial rock outcroppings (usually 

southern exposure) in small caves or on overhanging ledges large enough to accommodate three to four 

full-grown nestlings (Wilderness Research Institute 1979). Peregrine falcons feed almost exclusively on birds, 

many of which are associated with riparian zones and large bodies of water (e.g., waterfowl). 

No known peregrine falcon nests occur on or within 2 mi of the CD/WIIPA, nor have any peregrine falcons 

been reported in the area. There is only one recorded observation of a peregrine falcon in the entire GCIAA: a 

single bird was observed in the eastern portion of the GCIAA in 1981 (WGFD 1995). The absence of suitable 

cliffs within the CD/WIIPA precludes peregrine falcon nesting, although the area may be used on occasion for 

hunting by wintering or migrating peregrines. 

E-5.2.8.2 Potential Effects 

There is no evidence that peregrine falcons regularly utilize habitats in the vicinity of the CD/WIIPA. It is 

expected, therefore, that implementation of the Proposed Action or alternatives will not have any substantial 

direct or indirect impact (i.e., adverse effect) on the peregrine falcon. 

E-5.2.8.3 Mitigation Measures 

In the very unlikely event that an active peregrine falcon nest is found within or immediately adjacent to the 

CD/WIIPA, no activity or surface disturbance will be allowed within a 1.0_mi buffer zone around the nest 

between February 1 and July 31. 
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Record of Decision, Continental Divide/Wamsutter II 10 

E-5.2.9 Trumpeter Swan 

E-5.2.9.1 Current Status and Habitat Use 

The trumpeter swan, a species of special concern, primarily breeds and winters in eastern Canada and Alaska; 

the majority of the population that occurs in Wyoming frequents the marshes, lakes, and rivers in the Greater 

Yellowstone Ecosystem during the spring and summer months and winters in Idaho (Terres 1980; WGFD 

1992). Nests are usually built on a muskrat house or small island in a large pond or small lake (WGFD 1992). 

Adults feed mostly in shallow water on vegetation growing on the lake bottom (Terres 1980). 

A single observation of a trumpeter swan occurred approximately 7.0 mi west of the CD/WIIPA in September 

1985 (WGFD 1995). This was likely a vagrant individual that temporarily stopped in the area to feed or rest. 

If the limited wetlands within the CD/WIIPA are used by this species at all, it is probably during rare visits by 

transient individuals. 

E-5.2.9.2 Potential Effects 

Since the CD/WIIPA, for the most part, lacks appropriate trumpeter swan habitat, it is unlikely that the 

Proposed Action or alternatives will adversely affect the trumpeter swan, or increase cumulative effects to this 

species or its habitat. 

E-5.2.10 Western Burrowing Owl 

E-5.2.10.1 Current Status and Habitat Use 

This small long-legged owl of short-grass prairie is a species of special concern. The burrowing owl occurs 

throughout western North America and winters on its breeding grounds, except in the northern Great Basin and 

Great Plains region (Terres 1980). This owl nests in colonies, often in abandoned burrows of prairie dogs or 

ground squirrels (Dorn and Dorn 1990; WGFD 1992). Burrowing owls feed primarily on insects, rodents, and 

small birds (e.g., sparrows and horned larks) (Terres 1980). This owl hunts primarily in early evening and 

throughout the night. 

According to WGFD (1995) and WNDDB (1995) observation records, burrowing owls have been observed 

throughout the CD/WIIPA and GCIAA. The most recent known observations in the region were in April 1992: 

a single bird was observed in Wyoming big sagebrush-grassland habitat in the central CD/WIIPA and two birds 

were observed in sagebrush-greasewood habitat about 1.0 mi northwest of the CD/WIIPA (WGFD 1995). It is 

likely that burrowing owls forage and nest within the CD/WIIPA, although burrowing owl observations have 

diminished over the last decade. 

E-5.2.10.2 Potential Effects 

It is possible that the proposed project could adversely affect western burrowing owls on the CD/WIIPA. Some 

potential burrowing owl foraging and nesting habitat will be disturbed due to the proposed project, although 

prairie dog colonies will be avoided, where possible, as part of the mitigation for black-footed ferrets and this 

avoidance will aid in protecting potential burrowing owl nesting habitat from extensive disturbance. 

As with the mountain plover, some increase in disturbance to potential burrowing owl habitat will result in an 

increase in overall cumulative effects to this species. Given the dispersed nature of the disturbance and the 

availability of alternative habitat, cumulative impacts to the burrowing owl are unlikely to jeopardize regional 
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Record of Decision, Continental Divide/Wamsutter II 10 

populations. It should be noted, however, that burrowing owl populations in the region have experienced a 

decline over the last decade, and the reasons for this decline are unclear. Further research and additional 

protection for prairie dog colonies may assist in the stabilization, if not the recovery, of regional owl 

populations. 

E-5.2.10.3 Mitigation Measures 

If construction is planned for spring or early summer, surveys for nesting western burrowing owls (i.e., a nest 

and/or a territorial pair) will be implemented prior to disturbance during on-site inspections of proposed ROWs 

and well locations conducted as components of ROW application and APD review processes. If burrowing owl 

nests are found on the area, construction activities will be moved or rescheduled such that the birds will not be 

disturbed. Prairie dog colonies (i.e., potential burrowing owl nesting habitat) will be avoided, where possible. 

E-5.2.11 White-faced Ibis 

E-5.2.11.1 Current Status and Habitat Use 

The white-faced ibis is a species of special concern that frequents marshes, wet-moist meadows, lake shores, 

and irrigated meadows (WGFD 1992). Typical prey includes insects, leeches, earthworms, frogs, and fish 

(Terres 1980). The species breeds in colonies ranging from a few to several thousand birds in extensive 

freshwater marshes sporadically distributed from the Pacific Coast to the Great Plains (Erwin 1983). Breeding 

colonies have been observed at Hutton Lake National Wildlife Refuge in southeastern Wyoming and several 

locations in southwestern Wyoming (WGFD 1992). 

Although white-faced ibises have been occasionally observed within and adjacent to the CD/WIIPA, no 

breeding colonies occur within the area. The CD/WIIPA contains very little potential nesting habitat for the 

species. Ibises observed on the CD/WIIPA are likely transient individuals using the area for brief periods for 

resting and foraging during migration. 

E-5.2.11.2 Potential Effects 

Because of the lack of potential nesting habitat and low numbers of ibises that use the area, no effects to 

white-faced ibises are anticipated to result from either the Proposed Action or alternatives. Also, no increase 

in cumulative effects to this species or its habitat are anticipated due to the proposed project. 

E-5.3 REPTILES (EASTERN SHORT-HORNED LIZARD) 

E-5.3.1 Current Status and Habitat Use 

A species of special concern, the eastern short-horned lizard is found throughout most of Wyoming below 

about 6,500 ft; it is especially common in sagebrush-grassland communities in the central and southwestern 

counties of the state. Short-horned lizards favor areas with firm soils that are relatively flat and arid (Baxter 

and Stone 1985). These ground dwellers forage diurnally, primarily feeding on ants and beetles, and bear their 

young live in relatively large litters (Baxter and Stone 1985). 

Eastern short-horned lizards have been observed within both the CD/WIIPA and GCIAA (WGFD 1995). The 

species is probably a relatively common resident of sagebrush-grassland and short-grass habitats within the 

CD/WIIPA. 
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Record of Decision, Continental Divide/Wamsutter II 10 

E-5.3.2 Potential Effects 

The proposed project may adversely affect eastern short-horned lizards in the CD/WIIPA; however, the project 

is unlikely to jeopardize regional populations of the species. This reptile species has been observed within the 

CD/WIIPA, and it is likely that much of the project area represents suitable habitat for the eastern short-horned 

lizard. Although some disturbance of areas containing short-horned lizards will likely occur under either the 

Proposed Action or alternatives, overall loss of habitat for this species within the CD/WIIPA probably will be 

negligible (a maximum of 8,300 acres LOP, 0.8% of the CD/WIIPA). A slight increase in direct mortality of 

short-horned lizards may initially occur due to project construction and may remain slightly elevated for the 

LOP due to increased traffic. 

It is anticipated that the proposed project will not significantly increase existing and foreseeable future 

cumulative impacts (e.g., oil and gas development, mining, recreation) to short_horned lizards and their 

habitat in the region (i.e., unlikely to jeopardize). 

E-5.4 FISH 

E-5.4.1 Bonytail Chub, Colorado Squawfish, Humpback Chub, and Razorback Sucker 

E-5.4.1.1 Current Status and Habitat Use 

The bonytail chub, Colorado squawfish, humpback chub, and razorback sucker are federally endangered 

species, and all four species are residents of the Green and Colorado River systems (USFWS 1987; Tyus and 

Karp 1989; Matthews 1990). Although once abundant throughout both of these river systems, all four species 

are now limited to reaches of river that are either relatively undisturbed or controlled to provide appropriate 

flows. Reservoir impoundments and water diversions are the main threats to these species. 

None of these species occur within or adjacent to the CD/WIIPA; it is likely that the closest occurrence of 

these species is in the lower Little Snake River drainage of Colorado (Tyus and Karp 1989). 

E-5.4.1.2 Potential Effects 

No effect to these downstream fish species from the Proposed Action or alternatives is anticipated because of 

the mitigation measures described in Chapter E-4.0 of this BA (see item 13). 

E-5.4.2 Flannelmouth Sucker and Roundtail Chub 

E-5.4.2.1 Current Status and Habitat Use 

The flannelmouth sucker and roundtail chub are species of special concern and residents of the Green and 

Colorado River systems (Baxter and Simon 1970; Lee et al. 1980). As with the endangered fish species 

described in Section 5.4.1, declines in populations of these species are attributable to stream and river 

degradation from impoundment and diversion projects within the Green and Colorado River systems. 

Both species occur in the Little Snake River south and east of the CD/WIIPA (Baxter and Simon 1970; 

Johnson and Oberholtzer 1987; WNDDB 1995). Flannelmouth sucker and roundtail chub have also been 

observed in Muddy Creek in the southeastern portion of the GCIAA (Johnson and Oberholtzer 1987; WNDDB 

1995). 
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Record of Decision, Continental Divide/Wamsutter II 10 

E-5.4.2.2 Potential Effects 

No effect to these downstream fish species from the Proposed Action or alternatives is anticipated because of 

the mitigation measures described in Chapter E-4.0 of this BA (see item 13). 

E-5.5 PLANTS 

All 11 species of the TEC&SC plants presented below are species of special concern, and Ute ladies' tresses 

is also listed as threatened by the USFWS. Five species could occur within the CD/WIIPA due to habitat 

preference or observation: Cedar Rim thistle, large_fruited bladderpod, mystery wormwood, opal phlox, and 

Wyoming tansymustard. The other six species (Devil*s gate twinpod, Gibben*s beardtongue, Big Piney 

milkvetch, tufted twinpod, Utes ladies' tresses, and Ownbey*s thistle) are unlikely to occur within the 

CD/WIIPA. 

Potential impacts (including cumulative impacts) to these plant species are unlikely to jeopardize regional 

populations, especially given adherence to mitigation measures. Mitigation measures for TEC&SC plant 

species will include, but are not be limited to: 

• surveying areas to be disturbed prior to disturbance; 

• avoiding known TEC&SC plant populations; and

• other mitigation approved by the USFWS and the BLM if avoidance is not feasible.

A brief description of the habitats of occurrence and known locations of the 11 species of special concern is 

presented below. 

E-5.5.1 Big Piney Milkvetch 

The Big Piney milkvetch, also called Bastard draba milkvetch, is a mat-forming perennial herb with flowering 

stems less than 2.5 cm high. This plant is characterized by pink-purple flowers less than 7 mm long and 

spoon-shaped to linear leaves (5-25 mm) that are covered with silvery hairs. The mature fruits, which are 

keeled and grooved, are required to distinguish this plant from similar species (A.spatulatus). While endemic 

to the Green River Basin, Wyoming, it has not been documented in the CD/WIIPA. It has been found 

flowering in May_July in sagebrush and cushion plant communities in Sublette County, Wyoming. It prefers 

sandstone, stony clay, badlands, and barren clay slopes and ridges at elevations of 6,900-7,200 ft above sea 

level (Fertig et al. 1994). 

E-5.5.2 Cedar Rim Thistle 

This spiny perennial forb with lavender flowers usually grows no taller than 12 inches (Fertig et al. 1994). It is 

endemic to the Wind River and Green River basins of central Wyoming (i.e., Fremont and Sublette Counties) 

and is generally found on barren chalky hills, gravelly slopes, and fine-textured sandy_shaley draws at 

elevations between 6,700 and 7,200 ft (Dorn 1992; Fertig et al. 1994). 

Cedar Rim thistle has not been observed within the CD/WIIPA. The closest observation was about 10 mi 

west-northwest of the CD/WIIPA (WNDDB 1995); the thistles were in a barren steep draw of sandy clay 

within a dense hillside community of antelope bitterbrush (Purshia tridentata), rabbitbrush (Chrysothamnus), 

and mountain mahogany (Cercocarpus montanus). 
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Record of Decision, Continental Divide/Wamsutter II 10 

E-5.5.3 Devil*s Gate Twinpod 

This prostrate perennial herb has whitish or pale yellow flowers and two-lobed inflated fruits that extend out 

from the main body of the plant on short stems (Fertig etal. 1994). This plant has been seen within cushion 

plant communities on calcareous ridges, eroded sandstone or limestone, or in soil_filled crevices in granite 

outcrops (Dorn 1992; Fertig et al. 1994). Devil*s gate twinpod is endemic to the Sweetwater and Platte River 

basins in central Wyoming (Carbon, Fremont, and Natrona Counties). Devil*s gate twinpod has not been 

observed within the CD/WIIPA; however, it has been observed along the northern and northeastern border of 

the GCIAA on wind-swept ridges (WNDDB 1995). 

E-5.5.4 Gibben*s Beardtongue 

This species favors exposed outcrops of shale and sandstone with slopes of 20 to 30E on poorly developed 

soils. Gibben's beardtongue is subject to minimal competition from other plants (Dorn 1990; BLM 1992). 

Dorn (1990) found that populations of Gibben's beardtongue were stable and recommended that the status of 

this plant be downgraded due to the lack of potential threats. Gibben*s beardtongue has not been observed 

within the CD/WIIPA; the closest populations of the plant occur within the GCIAA along the 

Wyoming-Colorado border (WNDDB 1995). 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 10 

E-5.5.5 Large-fruited Bladderpod 

The large-fruited bladderpod is a perennial forb with recumbent stems up to 12 inches long (Fertig et al. 1994). 

The flowers are tiny and yellow, and the fruit is inflated and slightly hairy. This plant is found at elevations 

between 7,200 and 7,700 ft on gypsum-clay hills (barren), benches, and clay flats along the western edge of 

the Great Divide Basin (Dorn 1992; Fertig et al. 1994). 

Although the large-fruited bladderpod has been observed within the GCIAA (WNDDB 1995), it has not been 

observed within the CD/WIIPA. The closest observation was about 8 mi northwest of the CD/WIIPA; the 

plants were located on a barren clay knob (WNDDB 1995). 

E-5.5.6 Mystery Wormwood 

Mystery wormwood is a biennial forb with 12-inch stems that branch from the base (Fertig et al. 1994). The 

inflorescence is dense and spike-like, and the flower heads are small and numerous. Mystery wormwood is 

endemic to Sweetwater County and has been observed on clay flats and playas at about 6,500 ft in elevation 

(Dorn 1992; Fertig et al. 1994). Mystery wormwood has not been observed in the CD/WIIPA; the closest 

known population of these plants is on a clay flat about 6 mi west of the CD/WIIPA (WNDDB 1995). 

E-5.5.7 Opal Phlox 

Opal phlox is a low-growing perennial herb 7 cm or less in height; stems are loosely matted. Flowers are white 

or pink and appear from May through June. It prefers clay slopes and ridges at elevations from 6,700 to 6,900 

ft. Associated vegetation includes Artemisia pedatifida, Eriogonum spp., Arenaria hookeri, Atriplex gardneri, 

and Sphaeromeria argentea. Endemic to southwest Wyoming (Lincoln, Sweetwater, and Uinta Counties), it 

has not been found in the CD/WIIPA, but habitat is present support this plant (Fertig 1996; Fertig et al. 1994). 

E-5.5.8 Ownbey*s Thistle 

This spiny perennial forb grows to about 28 inches in height and possesses terminal flower heads that are white 

to rose-pink (Dorn 1992; Fertig et al. 1994). Ownbey*s thistle is endemic to northeastern Utah, northwestern 

Colorado, and southwestern Wyoming (Sweetwater County). In Wyoming, it has been found on sparsely 

vegetated shaley slopes in juniper (Juniperus), sagebrush (Artemisia), and riparian communities along the 

Wyoming-Colorado border (Fertig et al. 1994). Ownbey*s thistle has not been observed in either the 

CD/WIIPA or the GCIAA (WNDDB 1995). 

E-5.5.9 Tufted Twinpod 

Tufted twinpod is a perennial herb growing to 8 cm high on sparsely vegetated shale slopes and ridges from 

6,500 to 7,000 ft in elevation. It has not been document in the CD/WIIPA but is endemic to southwestern 

Wyoming (Lincoln, Sublette, and Uinta Counties). A member of the mustard family, it is characterized by 

bright yellow flowers (4-7 mm long), basal silvery pubescent leaves, and inflated deeply lobed fruits. Mature 

fruits are required for positive identification (Fertig et al. 1994). 

E-5.5.10 Utes Ladies* Tresses 

Ute ladies* tresses is a perennial terrestrial orchid 20 to 50 cm in height with narrow leaves and small white or 

ivory flowers clustered into a spike arrangement. This orchid is endemic to moist soils near wetland meadows, 

springs, lakes, and perennial streams from 4,200 to 7,000 ft above sea level. Utes ladies* tresses colonize 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 34 

early successional riparian habitats such as point bars, sandbars, and low-lying gravelly, sandy, or cobbly 

edges and persist in those areas that are provided with perennial moisture. They are intolerant of shade and 

usually occur as small scattered groups (USFWS 1997). 

The Ute ladies* tresses orchid is not known to occur in the CD/WIIPA; however, populations occur in 

Colorado along the Front Range, in Utah on the south side of the Uinta Mountains, and in the Niobrara, 

Cheyenne, and North Platte river drainages in Wyoming. It is possible that this orchid could be discovered in 

the project cumulative impact areas (USFWS 1997); however, with the implementation of proposed mitigation 

measures, the proposed project and associated cumulative impacts are unlikely to affect the species. 

E-5.5.11 Wyoming Tansymustard 

The Wyoming tansymustard is a tiny biennial or short-lived forb with multiple stems; stem height rarely 

exceeds 6 inches (Fertig et al. 1994). The flowers of this plant are tiny (1.5mm long) and yellow, and the 

fruits are linear and hairy. TheWyoming tansymustard has been observed at elevations between 8,300 

and 10,000 ft on sparsely vegetated sandy slopes at the base of volcanic breccia or sandstone cliffs (Fertig et 

al. 1994). The species is endemic to the Absaroka Mountains and the Rock Springs Uplift in Wyoming 

(including Fremont and Sweetwater Counties). 

The Wyoming tansymustard has not been observed within the CD/WIIPA. The closest observation of this 

species was about 3 mi west of the CD/WIIPA along the base of a sandstone cliff with miner's candle 

(Cryptantha), phacelia (Phacelia), sandwort (Arenaria), and tufted evening primrose (Oenothera caespitosa) 

(WNDDB 1995). 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 34 

E-6.0 LITERATURE CITED 

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Bailey, A.M., and R.J. Niedrach. 1965. Birds of Colorado. Volume 1. Denver Museum of Natural History, 

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Baxter, G.T., and M.D. Stone. 1985. Amphibians and Reptiles of Wyoming. Second edition. Wyoming Game 

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Bureau of Land Management. 1992. Monitoring/evaluation report on Penstemon gibbensii. U.S. Department 

of the Interior, Bureau of Land Management, Great Divide Resource Area, Rawlins, Wyoming, and 

Gary Holsan, Environmental Planning, Thayne, Wyoming. 

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migratory bird species of high federal interest, J.S. Armbruster, (editor), pages 301-310. Department of 

the Interior, U.S. Fish and Wildlife Service, FWS/OBS-83/85. 348 pp. 

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the Interior, Bureau of Land Management, Technical Note No.316. 115 pp. 

Call, M.W., and J.R. Tigner. 1991. Artificial nesting structures for ferruginous hawks (Buteo regalis) in 

Wyoming. Paper presented November 6-10, 1991, at Raptor Research Foundation annual meeting. 

Campbell, T.M., III, T.W. Clark, and C.R. Groves. 1982. First record of pygmy rabbits (Brachylagus 

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Clark, T.W., and M.R. Stromberg. 1987. Mammals in Wyoming. University of Kansas, Museum of Natural 

History, Public Education Series No. 10. 314 pp. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 34 

Colorado Natural Heritage Program. 1995. Letter from Katherine E. Pague (CNHP) to F. Russell Pickering 

(TRC Mariah Associates Inc.) in response to a request for sensitive species and community 

information pertaining to the proposed Continental Divide Natural Gas Project. June 20, 1995. On file 

at TRC Mariah Associates Inc., Laramie, Wyoming. 

Craig, R.B. 1978. An analysis of the predatory behavior of the loggerhead shrike. Auk 95(2):221-234. 

Dinsmore, J.J. 1983. Mountain plover (Charadrius montanus). In Impacts of coal surface mining on 25 

migratory bird species of high federal interest, J.S. Armbruster, (editor), pages 185-196. Department of 

the Interior, U.S. Fish and Wildlife Service, FWS/OBS-83/85. 348 pp. 

Dorn, R.D. 1990. Report on the status of Penstemon gibbensii, a candidate threatened species. Prepared for 

the U.S. Fish and Wildlife Service, Cheyenne, Wyoming, by Mountain West Environmental Services, 

Cheyenne, Wyoming. 19 pp. + append. 

. 1992. Vascular Plants of Wyoming. Second edition. Mountain West Publishing, Cheyenne, 

Wyoming. 340 pp. 

Dorn, J.L., and R.D. Dorn. 1990. Wyoming Birds. Mountain West Publishing, Cheyenne, Wyoming. 138 pp. 

Edwards, C.C. 1969. Winter behavior and population dynamics of American eagles in Utah. Ph.D. 

dissertation, Brigham Young University, Provo, Utah. 156 pp. 

Ehrlich, P.R., D.S. Dobkin, and D. Wheye. 1988. The Birder*s Handbook: A Field Guide to the Natural 

History of North American Birds, Including All Species that Regularly Breed North of Mexico. Simon 

and Schuster, Inc. New York, New York. 785 pp. 

Erwin, R.M. 1983. White-faced ibis (Plegadis chihi). In Impacts of coal surface mining on 25 migratory bird 

species of high federal interest. J.S. Armbruster, (editor), pages40_56. Department of the Interior, 

U.S. Fish and Wildlife Service, FWS/OBS_83/85. 348 pp. 

Evans, D.L. 1983. Ferruginous hawk (Buteo regalis). In Impacts of coal surface mining on 25 migratory bird 

species of high federal interest, J.S. Armbruster, (editor), pages109-123. Department of the Interior, 

U.S. Fish and Wildlife Service, FWS/OBS-83/85. 348 pp. 

Fertig, W. 1996. Wyoming Plants Species of Special Concern 1996 edition. Wyoming Natural Diversity 

Database, 1604 Grand Ave., Laramie, WY 82070. 33 pp. 

Fertig, W., C. Refsdal, and J. Whipple. 1994. Wyoming Rare Plant Field Guide. Wyoming Rare Plant 

Technical Committee, Cheyenne, Wyoming. 

Forrest, S.C., T.W. Clark, L. Richardson, and T.M. Campbell III. 1985. Black-footed ferret habitat: some 

management and reintroduction considerations. Wyoming Bureau of Land Management Wildlife 

Technical Bulletin No. 2. 49 pp. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 34 

Graber, R.R., J.W. Graber, and E.L. Kirk. 1973. Illinois birds: Laniidae. Illinois Natural History Survey, 

Biological Notes 93. 18 pp. 

Graul, W.D., and L.E. Webster. 1976. Breeding status of the mountain plover. Condor 78:265-267. 

Hall, E.R. 1981. The Mammals of North America. Volume I. Second edition. John Wiley & Sons, New 

York. 690 pp. 

Johnson, K., and M. Oberholtzer. 1987. Investigation into the possible occurrence of Colorado Squawfish 

(Ptchocheilus lucius) and other federally threatened or endangered fish species in the Lower Green 

River drainage and the Little Snake River drainage of Wyoming. Wyoming Game and Fish 

Department, Fish Division, Administrative Report. 12 pp. 

Klipple, G.E., and D.F. Costello. 1960. Vegetation and cattle responses to different intensities of grazing on 

short-grass ranges on the central Great Plains. U.S.Department of Agriculture Technical Bulletin 1216. 

82 pp. 

Klott, J. n.d. Habitat needs and development for sharp-tailed grouse. Habitat Extension Bulletin No. 25. 

Habitat Extension Services, Wyoming Game and Fish Department, Cheyenne, Wyoming. 6 pp. 

Knopf, F.L. 1994. Avian assemblages on altered grasslands. Studies in Avian Biology 15:247-257. 

. 1996. Mountain Plover. Birds of North America, No. 211. 

Lee, D.S., C.R. Gilbert, C.H. Hocutt, R.E. Jenkins, D.E. McAllister, and J.R. Stauffer, Jr. 1980. Atlas of North 

American Freshwater Fishes. North Carolina State Museum of Natural History. 

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Parrish, T.L., S.H. Anderson, and W.F. Oelklaus. 1993. Mountain plover habitat selection in the Powder River 

Basin, Wyoming. Prairie Naturalist 25(3):219-226. 

Peterson, A. 1986. Habitat suitability index models: Bald eagle (breeding season). U.S.Fish and Wildlife 

Service Biological Report 82(10.126). 25 pp. 

Scott, S.L. (editor). 1987. Field Guide to the Birds of North America. Second edition. National Geographic 

Society, Washington, D.C. 464 pp. 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 34 

Sheets, R.G., R.L. Linder, and R.B. Dahlgren. 1972. Food habits of two litters of black_footed ferrets in South 

Dakota. American Midland Naturalist 87:249-251. 

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Bureau of Land Management, Technical Note No. 167. 35 pp. 

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River, Colorado. U.S. Department of the Interior, Fish and Wildlife Service, Biological Report 

89(14). 27 pp. 

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the Upper Colorado River Basin. U.S. Department of the Interior, Fish and Wildlife Service, Region 

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append. 

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Consultations and Conferences. U.S. Department of the Interior, U.S. Fish and Wildlife Service, 

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Inc., Laramie, Wyoming. 

. 1995b. Letter from Charles P. Davis (Field Supervisor, USFWS) to Peter J. Guernsey (TRC Mariah 

Associates Inc.) in response to a request for threatened and endangered species information pertaining 
______________________________________________________________________________ 

Record of Decision, Continental Divide/Wamsutter II 34 

to the proposed Continental Divide Natural Gas Project. USFWS letter No. ES-61411 mlj/W.02 

(contin.spl). May 8, 1995. On file at TRC Mariah Associates Inc., Laramie, Wyoming. 

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Laramie, Wyoming. 

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Conservancy, Laramie, Wyoming. 
APPENDIX F: 

ENVIRONMENTAL STANDARDS, PROCEDURES, AND REQUIREMENTS FOR

IMPLEMENTATION OF THE CONTINENTAL DIVIDE/WAMSUTTER II

NATURAL GAS PROJECT
1 

ABBREVIATIONS AND ACRONYMS 

APD Application for Permit to Drill 

ATVs All_terrain vehicles 

bbls Barrels of condensate 

bcpd Barrels of condensate per day 

BLM Bureau of Land Management 

CD/WII Continental Divide/Wamsutter II 

CD/WIIPA Continental Divide/Wamsutter II Project Area 

C.F.R. Code of Federal Regulations 

CO2 Carbon dioxide 

COE U.S. Army Corps of Engineers 

DEIS Draft Environmental Impact Statement 

DOT U.S. Department of Transportation 

EA Environmental Assessment 

EIS Environmental Impact Statement 

H2S Hydrogen sulfide 

hp Horsepower 

IDT Interdisciplinary Team 

LOP Life-of-Project 

mmcf million cubic feet 

mmcfd million cubic feet per day 

mph Miles per hour 

MSDS Material Safety Data Sheet 

N2 Nitrogen 

NAAQS National Ambient Air Quality Standards 

NCPA National Cultural Programmatic Agreement 

NEPA National Environmental Policy Act 

NPDES National Pollutant Discharge Elimination System 

NOS Notice of Staking 

OSHA Occupational Safety and Health Administration 

RCRA Resource Conservation and Recovery Act of 1976 

RMP Resource Management Plan 

ROD Record of Decision 

ROW Right-of-way 

SARA Superfund Amendments and Reauthorization Act 

SHPO State Historic Preservation Office 

SN Sundry Notice 

SPCC Spill Prevention Control and Countermeasure 

SWPP Stormwater Pollution Prevention 

T&E Threatened and endangered 

TP Transportation Plan 

TPQ Threshold Planning Quantity 

TPTSD Transportation Planning Technical Support Document 

USDI U.S. Department of Interior 

USFWS U.S. Fish and Wildlife Service 

WAAQS Wyoming Ambient Air Quality Standards 

WDEQ-AQD Wyoming Department of Environmental Quality-Air Quality Division 

WDEQ-LQD Wyoming Department of Environmental Quality-Land Quality Division 

WDEQ-WQD Wyoming Department of Environmental Quality-Water Quality Division 

WDOT Wyoming Department of Transportation 

WGFD Wyoming Game and Fish Department 

WOGCC Wyoming Oil and Gas Conservation Commission 

WSEO Wyoming State Engineer's Office 

WSP Wyoming State Protocol 
Record of Decision, Continental Divide/Wamsutter II 2 

F-1.0 ENVIRONMENTAL STANDARDS, PROCEDURES, AND

REQUIREMENTS FOR IMPLEMENTATION OF THE

CONTINENTAL DIVIDE/WAMSUTTER II

NATURAL GAS PROJECT

The environmental standards, procedures, mitigations, and monitoring measures presented herein were 

proposed by Operators as components of the proposed project and/or were developed in response to identified 

impacts and measures proposed during the scoping process and from findings of the environmental impact 

statement (EIS) analysis. These measures describe how project activities will be implemented to assure 

compliance with resource management goals and objectives for the Continental Divide/Wamsutter II 

(CD/WII) project area (CD/WIIPA), applicable lease stipulations, and additional environmental protection 

goals identified from the EIS analyses. All measures identified in this appendix will become components of 

the modified Proposed Action, unless otherwise indicated. 
Record of Decision, Continental Divide/Wamsutter II 3 

F-2.0 PROJECT-WIDE DEVELOPMENT SPECIFICATIONS 

The Bureau of Land Management (BLM) will implement the planning and environmental protection measures 

identified in the Reclamation Plan (see Record of Decision [ROD] AppendixA), Transportation Plan (TP) (see 

ROD AppendixB) and associated Transportation Planning Technical Support Document (TPTSD), and 

Wildlife Protection Plan (see ROD AppendixD) for this project. All lease terms, resource management plan 

(RMP) mandates, and federal, state, and local laws, rules, and regulations will be adhered to. 

Design, construction, operation, and reclamation practices may be modified by the Operators and/or the BLM 

as more site_specific economic, engineering, and environmental information becomes available. Site_specific 

development plans, including National Environmental Policy Act (NEPA)_mandated environmental analyses 

on all Applications for Permits to Drill (APDs), right-of-way (ROW) applications, and Sundry Notices (SNs), 

will be prepared for each proposed well, road, pipeline, or ancillary facility constructed on federal land. 

Pursuant to Onshore Oil and Gas Order Nos. 1 and2, each proposed well on federal land will require BLM 

approval of an APD prior to any surface disturbance. Each APD will include site_specific information 

regarding all facets of well development, including mitigation measures required to minimize adverse 

environmental impacts. Roads, pipelines, and ancillary facilities on BLM lands constructed in association 

with this project will require BLM ROW authorizations and/or SNs which could include additional mitigation 

to further minimize environmental impacts. Wells proposed on private and state lands will require approval by 

the Wyoming Oil and Gas Conservation Commission (WOGCC), and roads, pipelines, and/or ancillary 

facilities on these lands will require private landowner or state approval prior to construction. 

Construction, operation, and reclamation of well locations, access roads, pipelines, and all other 

surface_disturbing activities will comply with BLM mitigation guidelines and best management practices as 

presented in the applicant-committed measures (see below) and in the Reclamation Plan for this project 

(ROD AppendixA). Road construction will adhere to specifications in the BLM Roads Standards Manual, 

Section 9113 and the TP for this project (ROD AppendixB). 

F-2.1 PROJECT_WIDE DEVELOPMENT SPECIFICATIONS 

The following project_wide development specifications apply to the Proposed Action. All lease terms, RMP 

mandates, and federal, state, and local laws, rules, and regulations will be adhered to. 

Design, construction, operation, and reclamation practices may be modified by the Operators and/or the BLM 

as more site_specific economic, engineering, and environmental information becomes available. Site_specific 

development plans, including NEPA_mandated environmental analyses on all APDs, ROW applications, and 

Sundry Notices, will be prepared for each proposed well, road, pipeline, or ancillary facility constructed on 

federal land. Pursuant to Onshore Oil and Gas Order Nos. 1 and2, each proposed well on federal land will 

require BLM approval of an APD prior to any surface disturbance. Each APD will include site_specific 

information regarding all facets of well development, including mitigation measures required to minimize 

adverse environmental impacts. Roads, pipelines, and ancillary facilities on BLM lands constructed in 

association with this project will require BLM ROW authorizations and/or Sundry Notices which may include 

additional mitigation to further minimize environmental impacts. Wells proposed on private and state lands 

will require approval by the WOGCC, and roads, pipelines, and/or ancillary facilities on these lands will 

require private landowner or state approval prior to construction. 

Whereas project components may undergo revision during agency reviews of individual APDs and ROW 

applications, these revisions will not substantially alter acreage requirements or general reclamation practices 

and will therefore be consistent with the environmental analysis presented in the EIS. Regardless, more 
Record of Decision, Continental Divide/Wamsutter II 3 

detailed site_specific analysis will be required prior to development activities, and any changes will be 

addressed in subsequent analyses. 

Construction, operation, and reclamation of well locations, access roads, pipelines, and all other 

surface_disturbing activities will comply with BLM mitigation guidelines and best management practices. 

Road construction will adhere to specifications in the BLM Roads Standards Manual, Section 9113 (BLM 

1985, 1991a) and the TP for this project (AppendixB). 

Operators will follow the procedures outlined below to gain BLM approval for proposed activities on federal 

lands within the CD/WIIPA. Permitting procedures on State of Wyoming and private lands will adhere to 

WOGCC rules and regulations (WOGCC 1998) and be subject to individual landowner preferences for 

development, operation, and reclamation practices. Since the BLM has limited authority to regulate 

developments on private and state lands, procedural modifications, (including alternate construction, 

operation, mitigation, and reclamation) could occur. 

F-2.2 PRECONSTRUCTION PLANNING AND 

SITE LAYOUT 

Prior to the start of construction activities, Operators will submit a Notice of Staking (NOS)/APD/SN/ROW 

Application to the BLM with a map showing the specific location of the proposed activity (e.g., specific well 

location, road or pipeline route, or other facility site), as well as site_specific construction plans. Proposed 

development sites will be staked by the applicant and inspected by the BLM to ensure consistency with the 

application. An environmental assessment (EA) will be prepared to ensure all site_specific resources are 

evaluated and proposed operations comply with RMP and ROD decisions. Applications will be revised as 

necessary per negotiations with the BLM. The BLM will either deny or approve specific proposals and attach 

terms and conditions of approval to the permit. Upon receipt of BLM approval, the applicant may commence 

with proposed activities. 

F-2.3 ROAD CONSTRUCTION AND USE 

F-2.3.1 Road Construction and Maintenance 

Access to the CD/WIIPA will be from I_80, Wyoming Highway 789, Sweetwater County Roads4_23 and 4_19, 

and other existing and newly constructed or upgraded roads in the CD/WIIPA. To access new well locations 

and facility sites, new roads will be constructed and existing roads may be improved. Site_specific analyses 

would be conducted on new and improved roads, and proper authorizations (i.e., ROW permits, APDs) would 

be obtained prior to construction. Road authorization, use, and maintenance responsibilities would be 

coordinated with area users, and roads on federal lands will be constructed following guidelines in the BLM 

road standards manual, Section9113 (BLM 1985, 1991a). Roads will be built and maintained to provide 

year_round access. 

The exact location of proposed roads within the CD/WIIPA is not known; however, specific access road 

construction will be in accordance with the BLM_approved TP (AppendixB) and the associated TPTSD for 

this project (BLM 1999a). New roads will be located to minimize disturbance, utilize existing disturbed areas 

(e.g., existing roads and pipeline corridors), avoid sensitive resources (e.g., raptor nests, cultural resource 

sites), and maximize transportation efficiency. Since much of the CD/WIIPA presently has only limited 

access by vehicles, it is estimated that 0.5_1.5 mi of new or upgraded road will be needed to access each well 

location or facilities site. Approximately 1.5 mi of new or upgraded road will be required for each well 

location or facilities site during exploration and initial development; however, in developed areas and as field 

development proceeds in other areas, it is estimated that an average of 0.5 mi or less of road will be required 

for each location. 
Record of Decision, Continental Divide/Wamsutter II 3 

Figure F-2.1 illustrates a typical road cross section with a parallel pipeline ROW. Surface disturbance will be 

contained within approved ROWs and will average 52 ft for collector roads (60-ft ROW), 48ft for local roads 

(55-ft ROW), and 42ft for resource roads (50-ft ROW). Disturbance width may increase in areas of rugged 

topography due to the necessity for cuts and fills. 

Road classification is the process of grouping roads having like characteristics into distinct categories and, for 

the CD/WIIPA, defines the administrative and jurisdictional characteristics of each road classification. This 

classification will help identify road types and jurisdictional responsibilities by defining public roads, 

administered by the state and county agencies, and management roads, administered and controlled by the 

private and public land managers. 

The following functional classifications are based on BLM Manual Section 9113 (BLM 1985) and Federal 

Highway Administration classifications (U.S. Department of Transportation [DOT] Federal Highway 

Administration 1992). 

Arterial (Public Roads). Arterial roads serve large areas and are considered to be public roads. Arterial roads 

within the CD/WIIPA include Wyoming state highways and Sweetwater and Carbon County roads. These 

roads are heavily traveled routes connecting developed areas of the CD/WIIPA to I_80, railroad crossings, 

industrial developments, services, and residential areas. These roads can be considered all_weather roads, and 

use of these roads is controlled by the Wyoming Department of Transportation (WDOT) or the respective 

county commissioners. 

Arterial roads will be double-lane roads with shoulders and will be designed and constructed according to 

applicable state or county standards. 

Collector (Management Roads). Collector roads serve smaller areas than arterial roads and may be divided 

into major and minor categories. Collectors channel moderate to heavy traffic to and from the arterial system. 

Major and minor collector roads within the CD/WIIPA are defined as follows. 

• Major Collector. Developed roads with recorded easements that provides public and industry access 

to the CD/WIIPA will be are classified as a major collector road. Commonly, major collector roads 

will be BLM roads that are not a permanent part of the BLM road system, but are managed by BLM. 

A county road will be classified as a major collector if it supports only occasional use. 

• Minor Collector. Developed roads with authorized ROWs issued by private landowners, BLM, or 

other land managers are classified as minor collector roads. These roads may include public_use 

rights, but use of these roads is at the discretion of the landowners and agencies. Portions of minor 

collector roads may have specific enforceable access restrictions. 

Collector road maintenance objectives include the maintenance and improvement of drainage, road surfacing, 

and road grading to a smooth compact surface. 

Collector roads will be double-lane roads and will be 24 ft wide after surfacing, with 4:1 ditches a minimum of 

1 ft deep. These roads will have a gravel surface designed to support highway loads and provide a smooth 

compact road surface (without washboarding). Dust control may be required to retain the fines in the gravel. 

Collector roads will be designed for a minimum travel speed of 35miles per hour (mph). 

Local (Management Roads). Local roads normally serve smaller areas than collector roads, channeling light 

to moderate traffic to a collector or arterial system. Local roads may support very heavy off_highway loads. 
Record of Decision, Continental Divide/Wamsutter II 3 

Authorization for use of local roads is at the discretion of the landowner or agencies. Local roads within the 

CD/WIIPA will serve specific groups of wells, services, or support facilities, and these roads may become a 

permanent part of a larger road system. Maintenance objectives will include maintaining drainage, surfacing 

selected segments, or road surface grading. 

Local roads will be either double lane (20_24 ft wide after surfacing) or single lane (14_16ft wide after 

surfacing) with turnouts and will have 4:1 ditches a minimum of 1 ft deep. Gravel surfaces will be designed to 

support heavy loads in excess of standard highway loads. Depending on the length of the road, smoothness of 

the surface may be less important than the ability of the surface to support heavy loads. Local roads will be 

designed for speeds of 20_30mph. 

Resource (Management Roads). A resource road will serve a specific destination and connect to local, 

collector, or arterial road systems. They may dead_end at single well/service facilities or serve small numbers 

of wells or facilities. Depending on the level of activity, a resource road could serve light traffic and very 

heavy loads. Authorization and use of resource roads are at the discretion of the landowner or agencies. The 

maintenance objective for resource roads will be to minimize resource damage. A resource road will be 

abandoned and reclaimed when the road is no longer needed. Occasionally a resource road could be stabilized 

and allowed to revert to a two_track trail. 

Resource roads will be single lane roads with turnouts (14-16 ft wide after surfacing) with 4:1 ditches a 

minimum of 1 ft deep. Gravel, if needed, will be of sufficient quality to support heavy loads for short 

durations. The surface of a resource road is not required to be smooth. Resource roads will be designed for 

speeds of 15-30 mph. 

Arterial collector, local, and resource roads in producing fields will be appropriately surfaced (e.g., aggregate, 

crushed rock) immediately following construction. Resource roads to exploratory well sites will be surfaced 

only after the well has been determined to be productive, unless otherwise directed by the BLM. Surfacing 

materials will be obtained from existing or newly constructed aggregate source pits located on federal, state, 

and/or private lands in or near the CD/WIIPA. 

Roads across federal lands will be designed by a licensed professional engineer, as deemed appropriate by the 

BLM, and all roads will be constructed with adequate drainage and erosion control structures (e.g., relief 

culverts, drainage culverts, wing ditches, water bars). To further decrease potential impacts, the number and 

miles of roads will be limited by discouraging development of looped roads and by accessing well locations 

from short spurs off existing, local, and/or collector roads, where feasible. Roads will be closed and reclaimed 

by the operators when they are no longer required for the project unless otherwise directed by the BLM. 

Approximately four people (i.e., road construction crews which are usually locally contracted by the operator) 

will be required for construction of each road, and each mile of road will require 3days to complete 

(TableF-2.1). During operations, roads will be maintained for year_round access. Road maintenance will 

typically include the application of surface materials, grading during the summer and fall months, and snow 

removal during the winter. Further details on road construction and maintenance specifications are provided in 

the TP (AppendixB) and the TPTSD (BLM 1999a) for this project. 

Available topsoil will be removed during road construction and placed on the backslope area of borrow ditches 

within road ROWs. Topsoil will be respread on approximately 11.5 ft of both sides of all roads and reseeded as 

soon as possible and within 2 years after production testing indicates the well will be a producer and pipelines 

are installed. The entire road ROW to unproductive wells and the entire well location will be reclaimed as 

soon as practical, and reclamation activities will normally be completed within 2 years using stockpiled 

topsoil and BLM_approved seeding techniques. All newly developed roads will be reclaimed upon project 
Record of Decision, Continental Divide/Wamsutter II 3

abandonment unless otherwise directed by the BLM in consultation with private landowners, county agencies, 

and other entities as necessary. Further road reclamation guidelines are provided in AppendixA. 

F-2.3.2 Road Use 

Estimated traffic requirements for the proposed project are presented in TableF-2.2. 
Record of Decision, Continental Divide/Wamsutter II 3 

Table F-2.1 Estimated Employment Requirements, Continental Divide/Wamsutter II Natural Gas Project, 

Sweetwater and Carbon Counties, Wyoming, 1999. 

Employment Category No. Personnel for Maximum No. Total No. Total No. Person-years1 

Each Well/ Simultaneously Individuals 

Active Crews Required for Maximum 

Operation Crew Development 

Well 

Construction/Development 

Access road and well pad 4 3 12 231

construction

(5 days/location)

Rig transport and rig_up operations 15 15 225 692 

(4days/well) 

Drilling (20 days/well) 21 15 315 4,846 

Completion/testing 11 15 165 1,904 

(15 days/well)2 

Pipeline and ancillary facility 6 6 36 831

installation

(12 days/location)

Operations/Maintenance 

(30 years/well) 

Production (LOP)3 11 48 58 2,050 

Workovers/abandonment (10 days 7 7 49 2,423 

every 10years/well)4 

Reclamation 3 1 3 104 

(3 days/location) 

Total -- -- 863 13,081 

1 Assumes all wells are drilled and completed as producers, is based on 260 workdays per year, and 

assumes a well life of 30 years and a LOP of 50 years. 

2 Eight to 15 people are required during fracturing only; assumes only one fracturing crew will be used. 

3 Includes three production foreman, 35 pumpers (30 years), three hauler crews, and three field clerks 

(1_person crews), two rig service crews (3_person crews), and two roustabout crews (4-person crews). 

Each well location will be visited twice per week on average, and 15-20 wells/locations could be visited 

daily by a single employee. 

4 The third workover will generally be for casing and plugging operations associated with well abandonment. 
Record of Decision, Continental Divide/Wamsutter II 3 

Table F-2.2 Estimated Traffic Requirements1, Continental Divide/Wamsutter II Natural Gas Project, 

Sweetwater and Carbon Counties, Wyoming, 1999. 

Type of Traffic Round Trips per LOP Round Trips Required 

Well/Location for Maximum Development 

(x 1,000) 

Well Construction/Development 

Access road and well pad construction 50 150 

(5 days/location) 

Gravel hauling 33 99

Rig transport and rig-up operations 60 180

(4 days/well)

Drilling activities (20 days/well) 133 399

Completion/testing (15 days/well) 145 435

Pipeline and ancillary facility installation (12 48 144

days/location) 

Total Well Construction/Development 469 1,407

(56days/location)

ADT2 8 0.3

Operations/Maintenance 

Operations (LOP)3 3,120 468

Workovers (10 days every 10years/well) 90 270

Total Operations/Maintenance 3,210 738

ADT2 0.4 0.1

Total Reclamation (3 days/location) 9 27

GRAND TOTAL 3,688 2,172

ADT2 0.3 0.2 

1 Assumes all wells are drilled and completed as producers, wells produce every day, well life is 30 years, 

and the LOP is 50 years. 

2 ADT = average daily traffic. 

3 Each well location will be visited twice a week on average, and approximately 15_20well locations could 

be visited daily by a single employee. 
Record of Decision, Continental Divide/Wamsutter II 3 

Crews will use a crew vehicle or car pool. Approximately eight round trips per day will be required to each 

well during construction, drilling, completion, and testing phases (i.e.,approximately the first 56 days of 

development at each well and including ancillary facilities). During production, wells will be visited twice a 

week on average. An additional three round trips per well per day for a 10-day period every 10years will 

generally be required for workovers and well abandonment. Three round trips per day for 3 days will be 

required for reclamation of each well location. 

Project_related traffic will be restricted to I-80, Wyoming Highway 789, Sweetwater County Roads 4_23 and 

4_19, other county roads, other improved existing roads in the CD/WIIPA, and newly constructed or upgraded 

roads developed for the project. Use of unimproved roads will be allowed only in emergency situations. 

Operators will instruct project personnel and contractors to adhere to speed limits commensurate with road 

type, traffic volume, vehicle type, and site_specific condition to assure safe and efficient traffic flow. Signs 

will be placed along roads as directed by the BLM for travel restrictions and other standard traffic control 

information. All equipment and roads will be maintained to minimize impacts to air quality and noise and to 

ensure human safety. 

F-2.4 WELL PAD CONSTRUCTION 

The typical well pad during drilling operations (for vertical, directional, and horizontal drilling operations) will 

be approximately 2.6 acres (FigureF-2.2). Components of the well pad include a reserve pit to contain drilling 

fluids, cuttings, and water produced during drilling and a flare pit to be used during testing. All reserve pits 

will be constructed per BLM and/or WOGCC requirements to protect surface and ground water resources. 

Site_specific analyses conducted by the BLM during the APD process will determine whether lining of reserve 

pits with a synthetic liner will be necessary. 

Well locations will be cleared of vegetation and topsoil, and these materials will be stockpiled together for 

future use in reclamation. The well location will be leveled using standard cut_and_fill construction 

techniques and machinery. At locations with level ground where minimal cut_and_fill is needed and/or where 

topsoil is saline and/or alkaline and its removal could create depressions capable of retaining water, the 

topsoil will be stripped only from the pit and spoil stockpile areas to facilitate future reclamation. In areas of 

rough terrain or where significant erosion/construction hazards exist, detailed engineering designs will be 

developed by a licensed professional engineer, and construction will be monitored as determined by the BLM. 

Well pad construction will require approximately 2 days per location, and approximately 20 round trips per 

location will be needed. Well pad construction crews will usually be contracted locally by the Operators. 

Erosion control will be maintained through prompt revegetation and by constructing surface water drainage 

controls such as berms, diversion ditches, and sediment ponds as necessary at each well location. SWPP 

Plans will be prepared for all well locations, access roads, and other development sites that disturb more than 

5acres. In some cases, SWPP Plans may be prepared for groups of 20 or more wells. 

F-2.5 DRILLING OPERATIONS 

Following access road and well pad construction, a rotary drilling rig will be moved to each location and 

erected on_site. Rig transport and on_site assembly will be completed in approximately 4 days, will involve 

approximately 15 people per site (TableF-2.1), and will require approximately 60 round trips per site (Table 

F-2.2). 

An estimated maximum of 15 drilling rigs rated to accommodate anticipated final well depths of 

approximately 7,000 to 11,000 ft will be utilized. Some wells may be drilled to depths greater than 11,000 ft. 

Whereas vertical drilling will be the principle method employed, directional and/or horizontal drilling methods 

may be used to augment gas recovery or minimize surface disturbance in areas with sensitive environmental 

resources. However, directional and horizontal drilling have a greater risk and therefore a lower chance of 

economic success when compared to vertical drilling. Much of the CD/WIIPA is not well-suited for 

directional drilling. All drilling operations and other well site activities will be conducted in compliance with 

applicable BLM, WOGCC, WDEQ, and other relevant federal, state, and county rules and regulations. Most 
Record of Decision, Continental Divide/Wamsutter II 3 

wells will be completed in the Almond Formation (Mesa Verde Group); however, secondary reserves may be 

encountered in other formations (e.g., Lewis). Drilling will occur commensurate with new discoveries coupled 

with anticipated development costs and gas prices. 

Drilling will begin in 1999, subsequent to the release of the ROD for this project, and continue until all 

proposed wells are drilled. Operators propose to drill throughout the year. Drilling each well will take 

approximately 20 days (some additional time may be required for directional/horizontal wells or wells drilled 

deeper than 10,000 ft) and will require approximately 21 individuals, including three 5_person rig operations 

crews necessary to conduct drilling throughout the entire 24-hr day (TableF_2.1). Most project personnel will 

be hired locally, and all project_required personnel will likely reside in Rock Springs, Wamsutter, or Rawlins. 

No mancamps or other temporary housing is proposed within the CD/WIIPA. Approximately 133 round trips to 

each well location will be required during drilling operations. 

Directional drilling provides for construction of one well location to accommodate as many as five wells. 

These multiple wells can be serviced by one access road and gathering system pipeline, as well as a single 

separation, dehydration, and storage facility. Use of multi_well directional drilling techniques will be 

contingent upon economic, technical feasibility, and environmental considerations. 

Horizontal drilling involves drilling a curved section from the bottom of a vertical hole, followed by drilling 

horizontally in the productive formation. Horizontal drilling could increase gas flows, has been successfully 

utilized in other gas projects in Wyoming to improve the productivity of marginal wells, and may be 

applicable in portions of the CD/WIIPA. 

Fresh water will be used for drilling the first 5,000 to 7,000ft of each well, and water_based muds will be used 

for the remainder of the drilling operation. Drilling muds, cuttings, and water will be stored in the reserve pit 

(FigureF-2.2). The reserve pit will be fenced on the three nonworking sides during drilling, and within 24 hrs 

after drilling is completed and the rig substructure is removed, the fourth side will be fenced to protect wildlife 

and livestock until the pit is reclaimed. Reserve pits will be lined to protect surface and ground water 

resources as directed by the BLM and/or WOGCC during the APD process. In compliance with BLM 

Informational Bulletin No. WY_93_054, netting (1_inch mesh) will be placed over reserve pits containing oil 

or other substances toxic to wildlife. 

Approximately 630,000 gal of water will be used during the drilling of each well. This water will be obtained 

primarily from existing and newly drilled water supply wells in the CD/WIIPA. Approximately 50 new water 

supply wells will be drilled at natural gas well locations, and each water well will require approximately 0.5 

acres of long_term (life_of_well) disturbance. Water wells generally will be located one per township, and 

disturbance associated with water wells will occur within the 2.6-acre initial disturbance area of natural gas 

well locations. All water supply wells will be permitted with the WSEO and will likely be drilled to depths of 

less than 1,000ft. 

Water will be trucked or piped to individual well locations, depending upon site_specific conditions, 

disturbance requirements, and time of year. Water pipelines will be temporary and will consist of either 

standard 3-to6_inch diameter aluminum sections or polypipe which will be laid on the surface within road 

ROWs and will be removed upon completion of drilling and completion/testing operations. 

When the reserve pit is no longer required, water will be evaporated; however, in some instances, pit contents 

may be mixed with suitable solid materials and the pit backfilled, as approved by the BLM or private entity. 

Prior to the mixing of reserve pit contents with approved stabilizing materials, appropriate closure permits will 

be obtained from the WOGCC/WDEQ. If necessary, reserve pit contents will be removed and disposed of at 

an approved disposal facility in a manner commensurate with all relevant county, state, and federal 

regulations and stipulations. The reserve pit area will be recontoured and reseeded as soon as possible (i.e., 

first appropriate season), but no later than 2 years after completion of drilling and testing operations. Further 

details on reserve pit reclamation are provided in AppendixA. 
Record of Decision, Continental Divide/Wamsutter II 3 

Human waste generated at well locations will be collected in standard portable chemical toilets or service 

trailers and regularly transported off_site to a county_ and state_approved disposal site (e.g., Rawlins or Rock 

Springs wastewater treatment plants) or otherwise collected and disposed of as authorized by WDEQ. Each 

well location will be provided with one or more such facilities during drilling and completion operations 

lasting more than 3 days. A septic system will not be required. Nonhuman waste will be collected in enclosed 

containers and disposed of at state_approved sites (e.g., Wamsutter landfill). 

F-2.6 COMPLETION AND TESTING OPERATIONS 

Well completion and testing operations entail: • isolating near_surface fresh water aquifers with surface casing set at the start of drilling operations; • casing and cementing various segments of the wellbore to protect fresh water aquifers by running steel

pipe into the open borehole and cementing the pipe into place (Figure F-2.3); • perforating the casing adjacent to the target formation; • fracture stimulating (fracturing or fracing) the target formation; and 

• conducting postfracturing flow tests and cleanup. 

Once drilling has been completed, the well will be logged and production casing set to prevent condensates, 

gas, and/or water movement from reservoir to reservoir and to isolate producing zones, thereby protecting all 

other zones penetrated by the well. Casing also prevents drill hole cave_in, confines production to the 

wellbore, and provides a means of controlling pressure to facilitate installation of surface and subsurface well 

equipment. All well casing and cementing operations on federal minerals will be conducted as directed by the 

BLM in compliance with BLM Onshore Oil and Gas Order No. 2. Well casing and cementing on state and 

patented minerals will be as directed by the WOGCC. Completion and testing operations will be similar for 

all wells, but may require additional time for directional and horizontal wells. 

When casing and cementing have been completed, the well casing will be perforated in the producing 

formation (usually the Almond Formation) to allow the flow of hydrocarbons to the wellbore. Most 

completions in the CD/WIIPA and adjacent areas insert a string of tubing into the casing to the top of the 

perforated productive zone to allow gas, condensate, and water to flow to the surface where it is collected, 

measured, and contained. 

After perforation, the well will be flowed an estimated 1-15 days to evaluate well performance. During testing, 

flows from the well, including gas and minor amounts of hydrocarbon liquids (condensates), will be flared to 

the flare pit pursuant to BLM/WOGCC rules and regulations (NTL_4A). Depending on the rates of these flow 

tests, the formation will be further evaluated for fracture stimulation. Flaring will also occur during flowback 

operations following fracturing. 

Hydraulic fracturing is expected to be performed on most wells to increase gas flow rates by increasing the 

relative formation permeability. Nitrogen (N2) or carbon dioxide (CO2), water_based fluids, and proppants 

(i.e., granular materials such as sand) are pumped down the wellbore under high pressure and through 

perforations in the casing into the target formation. The pressurized fluid induces hydraulic fractures in the 

formation and, when the pressure is released, fluids return to the surface and the fractures partially close on the 

proppants, leaving channels for gas and liquids to flow into the wellbore. Fracturing fluids returned to the 

surface will be captured in temporary storage tanks or BLM_approved earthen pits. Fluids will either be 

evaporated on_site, hauled away from the location for reuse, or disposed of at an authorized facility. 

Decisions regarding the appropriate handling of fracturing fluids will be made by the BLM and/or WOGCC on 

a case_by_case basis. 

Approximately 138,000 gal (0.42 acre_ft) of water per well will be needed for completion and testing 

operations. The total per well water requirement for all drilling, completion, and testing operations will be 

approximately 768,000 gal (2.4 acre_ft). Maximum LOP water requirements will be 2,304 million gal (7,072 

acre_ft). 

Estimated employment and traffic requirements necessary for completion and testing operations are presented in Tables 

F-2.1 and F-2.2, respectively. Typical completion and testing operations will take approximately 15 days per well and 
Record of Decision, Continental Divide/Wamsutter II 3 

require a daily average of 11individuals. Total round trips per well required for completion and testing operations are

estimated at 145.

F-2.7 PRODUCTION FACILITIES 

Once a well has been tested and deemed to be commercially productive, it will be equipped for production. Figure 

F-2.4 shows a typical single well location production facility. Reclamation of areas unnecessary for production 

operations--approximately 1.8 acres at each well location--will be completed, reducing disturbance at each location to 

approximately 0.8 acres for the LOP. Multiple well location production facilities will not vary substantially in size 

from a single well facility; however, locations with water wells will have approximately 1.3 acres of disturbance for the 

LOP. All aboveground production facilities at each location will be painted with standard environmental colors (e.g., 

Carlsbad Canyon) that blend with the surrounding landscape. 

A series of valves designed to control pressures and regulate flows from the well (i.e., the christmas tree) will be 

installed at the well head. Flows from the wellbore will pass through the christmas tree to a separator where the gas 

will be separated from the condensates and water in the gas stream. Liquids will be diverted to storage tanks. Water 

remaining in the natural gas stream will be removed with a skid_mounted glycol dehydration system (i.e., dehydrator) 

and routed to an appropriately protected collection container. Natural gas will be directed to a collection or gathering 

system pipeline. 

Natural gas production from wells in the CD/WIIPA is expected to range from approximately 0.25 to greater than 3.5

million cubic feet (mmcf) per day (mmcfd). TableF-2.3 shows the typical content of gas produced from the Almond

Formation in fields adjacent to the CD/WIIPA. No hydrogen sulfide (H2S) is known from this formation, and none is

expected to be encountered during project operations. 

From less than 5 to 350 barrels (bbls) of condensate per day (bcpd) are expected to be produced from each well. 

Condensates consist primarily of long chain hydrocarbon liquids (e.g., pentanes, hexanes, heptanes, octanes) and will 

be stored in tanks at well locations (FigureF-2.4). In compliance with 43C.F.R. 3262 and 40 C.F.R. 112.7, all tank 

batteries will be bermed to contain the volume of the largest tank plus sufficient freeboard ($1ft) to handle 

precipitation. Condensates will be periodically removed from storage tanks and transported by truck for sale to 

refineries or piped to central processing facilities. Condensate will be transported from locations as necessary based 

upon production rates. It is anticipated that on average condensates will be transported from locations twice a month. 
1 

Record of Decision, Continental Divide/Wamsutter II 3 

Table F-2.3 Typical Gas Composition from the Almond Formation in Fields in and Adjacent to the 

Continental Divide/Wamsutter II Natural Gas Project, Sweetwater and Carbon Counties, 

Wyoming, 1999. 

Component Creston/Blue Gap (%) Greater Wamsutter 

Analysis Area (%) 

Methane 85.98 81.54 

Ethane 6.94 8.42 

Carbon dioxide 3.15 3.24 

Propane 2.40 4.16 

Butane 0.52 0.84 

Isobutane 0.46 0.87 

Nitrogen 0.25 0.25 

Isopentane 0.14 0.22 

Pentane 0.13 0.17 

Hexanes 0.03 0.18 

Heptanes 0.00 0.08 

Octanes 0.00 0.03 

Total 100.00 100.00 

Adapted from BLM (1994a, 1995a). 
Record of Decision, Continental Divide/Wamsutter II 3 

The volume of water produced at each well is expected to be less than 20 bbls per day and will average 

approximately 6 bbls per day. Water initially removed from the gas stream will be stored in a tank at the well 

location. The quality of this water will be variable. Water will be removed as necessary from the tank and 

transported by vacuum truck for disposal in permitted facilities according to WDEQ rules and regulations and 

BLM Onshore Oil and Gas Order No. 7. 

All producing wells will be visited from one to five times each week for routine well operations. On average, 

each well location will be visited twice a week. The estimated employment requirements for well operations 

are presented in Table F-2.1 and traffic requirements are presented in Table F-2.2. The productive life of wells 

in the CD/WIIPA is expected to be from 5 to 30years. 

F-2.8 PIPELINES 

Most gas produced from wells will be transported from each location through newly constructed underground 

gathering system pipelines. These lines will be linked to larger existing interstate gas transportation pipelines 

in the CD/WIIPA. At present, it is assumed that existing interstate pipeline capacity will be adequate for the 

gas transportation needs required for this project. In the event that additional interstate pipelines become 

necessary, additional NEPA analyses will be conducted. 

The exact location of newly proposed pipelines cannot be determined at present; however, industry standard 

pipeline equipment, materials, techniques, and procedures in conformance with all applicable regulatory 

requirements will be employed during construction, testing, operation, and maintenance of pipelines to ensure 

the safety and efficiency of pipelines in the CD/WIIPA. Depending upon the location of acceptable pipeline 

tie_ins, pipeline ROWS will be located adjacent to roads to minimize surface disturbance and maximize 

construction and gas transport efficiency (FigureF_2.1). However, pipelines may not follow roads based on 

environmental and/or economic considerations. 

Pipeline ROW widths generally will be 50 ft, and an estimated 0.5-1.5 mi of pipeline will be required for each 

well on the CD/WIIPA. An average of approximately 1.5mi of new pipeline will be required for each well 

during initial field development; however, in developed areas and as development proceeds in other areas, it is 

estimated that on average only 0.5 mi of pipeline will be required per well. New gas pipelines generally will 

be 3_6inches in diameter and buried to depths of 4_6 ft. To provide additional protection of visual, habitat, 

and/or subsurface resources and to minimize surface disturbance, pipelines may be located aboveground in 

some areas. 

Sufficient topsoil to facilitate reclamation will be removed from pipeline ROWs before construction. Where 

ROWs do not require major excavation, vegetation may be stripped to ground level (scalping) using 

mechanical treatments, leaving topsoil intact and minimizing disturbance to plant root systems, thereby 

facilitating vegetation reestablishment. All pipeline ROW reclamation will be initiated as soon as practical 

following disturbance, but will be completed within 2 years. 

Hydrostatic testing will be utilized to ensure the integrity of newly constructed pipelines. This testing consists 

of filling pipeline segments with water and pressurizing the segments to levels exceeding operating pressures. 

If leaks or ruptures occur, they will be repaired and testing will be repeated until successful. Water used for 

hydrostatic testing will either be produced water or water acquired from WSEO_permitted ground water wells. 

After testing, this water will be pumped into tank trucks and reused for drilling or further pipeline testing, 

thereby avoiding the discharge of water on the ground surface. In some instances, produced water used for 

testing may be hauled to existing approved disposal facilities. 

Pipeline construction crews of approximately six persons will install an average of 850 ft of line per day 

(Table F-2.1), and a 1.0 mi pipeline segment will require 6-7 days to complete. Approximately 3.0 acres of 

short_term disturbance will be required per mile of pipeline. 
Record of Decision, Continental Divide/Wamsutter II 3 

F-2.9 ANCILLARY FACILITIES 

The proposed project will utilize existing compression, processing, water disposal, water well, and power line 

facilities to the maximum extent possible. Up to five compressor stations, one gas processing plant, 10 water 

evaporation ponds, fivewater disposal wells, and 50 water wells may be required as the field is developed. 

The exact locations of these facilities has not been determined; however, they will be situated and designed to 

minimize environmental impacts and maximize operations efficiency. Total maximum surface disturbance 

from ancillary facilities would be 144 acres for the LOP. 

Compression facilities will require a maximum of 4.0 acres each, and a maximum of five facilities will be 

required. Engines on the compressors will be fueled by natural gas and designed to minimize emissions, and 

typical stack height will be 24 ft. A total of 70,000horsepower (hp) of compression may be required at four 

compression facilities spaced throughout the CD/WIIPA and at a facility located with the gas processing 

facility. Compression facilities will not be manned but will be lighted 24hrs per day. 

One natural gas processing facility may be required, or an expansion to an existing processing facility may 

occur. The processing plant will be permitted and constructed by gas gathering companies and will be 

designed for dehydration, CO2 removal, condensate removal, and cryogenic natural gas liquid 

condensation/extraction. A typical processing plant and associated ROWs will require approximately 30 acres. 

During initial development, existing processing at Wamsutter will be utilized and no new processing plants 

will be required; however, under maximum development (3,000 well locations), a new gas processing facility 

will be necessary. 

Additional water disposal facilities may include a maximum of 10 evaporation ponds (3.4acres surface 

disturbance per pond and 34acres total surface disturbance) and fivedisposal wells (7 acres surface disturbance 

per disposal well and 35 acres total surface disturbance). Approximately 50% of water disposal will be by 

evaporation ponds and 50% by disposal wells. The exact location of these facilities has not been determined; 

however, evaporation ponds will be located off federal surface, will be permitted by WDEQ, and will be 

designed to minimize adverse environmental impacts and maximize operation efficiency. Evaporation ponds 

will generally consist of a 6-ft deep, 3.0-acre pit (350 x 350 ft), bermed to allow 3 ft of freeboard with an 

associated bermed tank farm. Pits will be clay-, clay/bentonite-, or geomembrane_lined and will have a leak 

detection system. Disposal wells will be 4,000-12,000ft deep (Fox Hills and Almond Formations) and will be 

permitted by the WSEO, WOGCC, and/or WDEQ. 

Fifty new water wells may be drilled to provide water for drilling. Water wells will be approximately 400to 

1,000 ft deep and will be situated at gas well locations, and each well will result in an additional 0.5 acres of 

LOP disturbance at natural gas well locations. Each water well will be permitted by the WSEO. After drilling 

is completed, water wells could be: 1) left for the landowner to file a water right; 2) capped for future use by 

Operators; or 3) plugged and abandoned. 

Aggregates to be used for road and well location construction will be acquired from suitable areas on federal, 

state, and private lands on and adjacent to the CD/WIIPA. Prior to aggregate extraction, appropriate permits 

will be obtained from the WDEQ_Land Quality Division (LQD) and federal sources as necessary. 

Site_specific NEPA documents will be required for aggregate extraction operations on federal lands. Further 

detail on the location of potential aggregate sources and the need for these materials is provided in the TPTSD 

for this project (BLM 1999a). 

F-2.10 GEOPHYSICAL OPERATIONS 

Geophysical operations (i.e., seismic surveys), including 3_D surveys, velocity surveys, normal incident 

vertical seismic profiles, and/or offset vertical seismic profiles may be required during the LOP as drilling 

activity increases into areas of the CD/WIIPA with marginal or unknown gas reserves. The majority of these 

surveys will likely utilize 3_D seismic techniques and employ vibrator trucks or shothole methods. These 

surveys will be subject to separate environmental analyses for compliance with NEPA and are expected to 

cause minimal surface disturbance. Cultural resource inventories and other surveys for sensitive environmental 
Record of Decision, Continental Divide/Wamsutter II 3 

resources will be conducted prior to implementation as directed by the BLM. Any geophysical operations 

conducted as a result of the project will be implemented using procedures specified in the BLM's GDRA and 

GRRA RMPs after receipt of BLM and/or WOGCC approval. 

Geophysical exploration generally involves the use of an energy source (i.e., vibrator trucks or shotholes), 

geophones/receivers (listening devices), and computer processing equipment (recorder truck). Receivers are 

arranged in a grid pattern, with receiver line spacing usually 0.25 mi apart and geophone spacing at 220_ft 

intervals along the line. Energy source lines are generally 0.5 mi apart, with vibrating or shothole points at 

220_ft intervals along the line. Shotholes are usually less than 250 ft deep, with diameters of 3.5_8.4inches. 

Trucks ranging in size from the 26-ton vibrator trucks to 1-ton pickups will access lines using existing roads 

and cross_country travel. Backtracking will be kept to a minimum, and all_terrain vehicles (ATVs) and/or 

helicopters will be used to transport personnel and equipment in difficult terrain or areas designated as 

sensitive to vehicular traffic. Observation of recent 3_D geophysical operations conducted in similar areas 

show no long_term damage to vegetation and soils. 

F-2.11 HAZARDOUS MATERIALS 

The Operators have reviewed the EPA's Consolidated List of Chemicals Subject to Reporting Under Title III of 

the Superfund Amendments and Reauthorization Act of 1986 (SARA) (as amended) to identify any hazardous 

substances proposed for production, use, storage, transport, or disposal by this project, as well as the EPA's 

List of Extremely Hazardous Substances as defined in 40 C.F.R. 355 (as amended), and have determined that 

materials listed as hazardous and/or extremely hazardous will be used or generated by this project (see 

AppendixC). 

Hazardous materials anticipated to be used or produced during the implementation of the proposed project 

generally can be included in the following categories: drilling materials, casing and cementing materials, 

fracturing materials, production products, fuels, combustion emissions, and miscellaneous materials. 

Operators and their contractors/subcontractors will comply with all applicable hazardous material laws and 

regulations and will locate, handle, and store hazardous substances in an appropriate manner to prevent them 

from contaminating sensitive resources. 

Notice of any spill or leakage, as defined in BLM NTL 3A, will be immediately reported by the Operator to 

the BLM and other federal and state officials (e.g., WDEQ) as required by law. Incidents requiring verbal 

notification by regulation will be given as soon as possible, but no later than 24 hrs after the discovery of the 

incident. Verbal notification will be confirmed in writing within 15 days or other such time required by the 

appropriate regulatory agency. Any release of hazardous substances (leaks, spills, etc.) in excess of the 

reportable quantity, as established by 40 C.F.R. 117, will be reported as required by the Comprehensive 

Environmental Response, Compensation, and Liability Act of 1980, (CERCLA) as amended (42U.S.C.9601 et 

seq.). If the release of a hazardous substance in a reportable quantity does occur, a copy of the report will be 

furnished to the BLM and all other appropriate federal and state agencies. 

Each Operator will also prepare and implement, as necessary, the following plans and/or policies: 

• pursuant to 40 C.F.R. 112, Spill Prevention, Control, and Countermeasure (SPCC) Plans prepared for 

those sites where SPCC Plans are applicable; 

• Spill Response Plans (oil/condensate); 

• plans and inventories of hazardous chemical categories pursuant to Section312 of SARA, as amended; 

and 

• Emergency Response Plans. 

Copies will be maintained with the Operators, as required by regulation, and will be made available for review 

upon request. 
Record of Decision, Continental Divide/Wamsutter II 3 

F-2.12 OPERATIONS AND MAINTENANCE 

F-2.12.1 Maintenance 

All roads, wells, pipelines, and ancillary facilities will be operated in a safe and efficient manner according to 

industry standards. Routine maintenance of producing wells will be necessary to maximize performance and 

detect potential difficulties. Typically, each well location will be visited once or twice a week to ensure 

operations are proceeding efficiently. All roads and well locations will be inspected periodically by the BLM 

and maintained by Operators to minimize erosion and assure safe operating conditions. Work force and traffic 

requirements for project operations are presented in Tables F-2.1 and F-2.2, respectively. 

F-2.12.2 Workovers 

Approximately once every 10 years, each well will require a workover to change or replace tubing, re_fracture 

producing formations, clear water and other debris from the wellbore and perforations, and/or recomplete the 

well in another potentially productive zone not completed at the time the well was first drilled. While some 

wells may never require workovers and others may need workovers more than once every 10 years, wells will 

generally require three workovers each, and the third workover will be conducted at well abandonment. On 

average, workovers will require a crew of seven workers for 10 days (Table F-2.1) and approximately 30 round 

trips (Table F-2.2). Workovers will be conducted primarily during daylight hours, and the BLM will be 

consulted prior to initiating workovers (e.g., Sundry Notice) on federal lands in crucial wildlife areas during 

critical periods. 

F-2.13 RECLAMATION AND ABANDONMENT 

Reclamation will be conducted on all disturbed lands in compliance with BLM's Wyoming Policy on 

Reclamation (BLM 1990b), and the reclamation guidelines presented in AppendixA. Erosion control, 

restoration, and revegetation plans will be prepared by Operators on a site_specific basis during the APD and 

ROW application process, and these plans will be approved by the BLM prior to site 
Record of Decision, Continental Divide/Wamsutter II 21 

disturbance. The short_term reclamation goal will be to stabilize disturbed areas as rapidly as possible, 

whereas the long_term goal will be to return the land to conditions approximating those which existed prior to 

disturbance. 

Reclamation will occur during two phases. After production facilities are installed, reclamation will be 

initiated on unnecessary portions of productive well locations (approximately 1.8 acres/location) and road 

ROWs to these locations (approximately 11.5ft along each side of the road). Reclamation of all disturbed 

surface areas along pipeline ROWs will also be initiated. These reclamation activities will begin as soon as 

practical following disturbance (e.g., the first appropriate season), and reclamation, including grading, ripping, 

retopsoiling, and reseeding, will be completed within 2 years. This initial reclamation will reduce the amount 

of disturbed area to that necessary for production operations. 

When an Operator is ready to abandon a well, an abandonment plan will be submitted to BLM, and if 

acceptable, the BLM will approve and authorize activities through a Sundry Notice. The well will be plugged 

according to BLM Onshore Oil and Gas Order No. 2 or WOGCC rules and regulations (WOGCC 1998). Figure 

F-2.3 shows a typical plugged and abandoned wellbore schematic. Reclamation for all abandoned or shut_in 

well locations and access roads will be initiated as soon as practical, according to BLM specifications, and 

reclamation activities will be completed within 2years. This reclamation will include leveling and 

recontouring of disturbed areas, soil ripping, redistribution of topsoil over disturbed areas, installation of water 

diversion and/or erosion control devices, and reseeding. Reclamation will follow guidelines presented in 

AppendixA and specified in APD Surface Use Plans and/or ROW Plans of Development. 

At the end of the project's useful life (estimated at 30_50 years), Operators will obtain all necessary 

authorizations from the appropriate regulatory agencies and/or landowners to abandon facilities. All 

aboveground facilities will be removed, and all unsalvageable materials will be disposed of at authorized sites. 

Wells will be permanently or temporarily plugged or shut_in, according to BLM and/or WOGCC 

recommendations (Figure F-2.3). Pipelines will be purged of combustible materials and abandoned in place or 

removed, based on authorizing agency or landowner specifications. The well pad will be reclaimed and 

revegetated as outlined in AppendixA and site_specific APD Surface Use Plans. Roads will be reclaimed 

according to procedures identified in AppendixA and/or ROW Plans of Development, unless they are 

determined to be left in place by the authorizing agency or private landowner. Any excess topsoil from roads 

that will not be reclaimed will be used to reclaim well pads. Regrading, ripping (12 to 18 inches), topsoiling, 

and revegetation will be completed. Proposed seed mixtures (AppendixA), as approved by the BLM, will be 

broadcast or drill seeded. Reclaimed and abandoned locations and ROWs will revert to appropriate agency or 

landowner control. 
Record of Decision, Continental Divide/Wamsutter II 22 

F-3.0 APPLICANT-COMMITTED MITIGATION/ 

ENVIRONMENTAL PROTECTION MEASURES

The following applicant_committed mitigation measures, design features, and procedures will be implemented 

by Operators to minimize impacts to the environment. Each mitigation measure is listed only once, under the 

first resource where it applies; however, many mitigation measures apply to several resources and will help 

reduce impacts to each. Mitigation measures may be waived when deemed inappropriate by the BLM if a 

thorough analysis determines that the resource(s) for which the measure was developed will not be impacted. 

Further site_specific mitigation measures will be identified during APD and ROW application review 

processes. To assure compliance with mitigation measures, each Operator will provide a qualified individual 

on-site during construction/drilling operations. This individual will consult with the BLM on a case_by_case 

basis as necessary during field development. 

All of the proposed applicant_committed mitigation/ environmental protection measures identified in this 

section will be implemented on all federal lands in the CD/WIIPA. Implementation of these measures on state 

and private lands will be subject to state or landowner preferences and agreements with individual Operators, 

and where these measures are not implemented, additional impacts may occur. Development activities on all 

lands will be conducted in accordance with all appropriate federal, state, and county laws, rules, and 

regulations. 

F-3.1 PRECONSTRUCTION PLANNING AND

 DESIGN MEASURES 

1. Operators and the BLM will conduct on_site interdisciplinary team (IDT) inspections of each

proposed disturbance site (e.g., well sites, roads, pipelines, etc.) to develop site_specific

recommendations and mitigation measures.

2. Operators will adhere to the specifications, guidelines, and development protocol identified in the TP 

for this project (ROD AppendixB). Annual updates to the TPTSD will be prepared by Operators and 

approved by the BLM prior to the initiation of any road improvement/ construction (see ROD 

AppendixB and BLM 1999). The road construction and maintenance agenda and the responsible 

Operators will be updated annually in the TPTSD to accommodate tentative developments proposed 

for the next calendar year. Proposed maintenance and development plans will be reviewed annually 

by the BLM, Operators, landowners, and the Carbon County and Sweetwater County Road 

Departments. Roads on federal lands required for the proposed project will be constructed in 

accordance with BLM Manual 9113 guidelines (BLM 1985, 1991). 

3. Operators will prepare and submit individual drill-site design plans to the BLM for approval prior to 

initiation of construction. These plans will show the layout of the well location over the existing 

topography, dimensions of the pad, volumes and cross sections of cut_and_fill, location and 

dimensions of reserve and flare pits, and access road design. 

4. Prior to construction, operators will submit a Surface Use Plan or a Plan of Development for each well 

site, pipeline segment, and access road project. These plans will detail the measures and techniques 

to be used for erosion control, revegetation, and restoration and will adhere to reclamation guidelines 

presented in ROD AppendixA. The plan will provide specific detail on project administration, time 

frames, responsible parties, objectives, characteristics of site predisturbance conditions, topsoil 

removal, storage and handling, runoff and erosion control, seed bed preparation, seed mixes, seed 

application, fertilization, mulching, site protection, weed and livestock or other herbivore control, and 

monitoring and maintenance. 

5. Detailed engineering will be conducted for construction activities on steep and/or unstable slopes 

when required by the BLM and will receive approval by the BLM prior to initiating construction. 

6. Operators will identify aggregate and other surfacing material sources, for use in drill site and road 
Record of Decision, Continental Divide/Wamsutter II 22 

construction, in annual updates to the TPTSD (BLM 1999). The appropriate surface management 

agency (usually the State of Wyoming) will approve these sources, including timing for extraction, 

prior to use. 

F-3.2 AIR QUALITY 

1. All BLM conducted or authorized activities (including natural gas development alternatives) must 

comply with applicable ambient air quality regulations and standards. Operators will adhere to all 

applicable Wyoming Ambient Air Quality Standards (WAAQS), National Ambient Air Quality 

Standards (NAAQS), and permit requirements (including preconstruction, testing, and operating 

permits), motorized equipment and other regulations, as required by the Wyoming Department of 

Environmental Quality (WDEQ)_Air Quality Division (AQD). 

2. Operators will not allow open burning of garbage or refuse at well locations or other facilities in the 

CD/WIIPA. Any other open burning will be conducted under the permitting provisions of Section 13 

of the Wyoming Air Quality Standards and Regulations (WDEQ-AQD 1989). 

3. On federal land and during times of high use (i.e., construction, drilling, and workover operations), 

Operators will initiate immediate abatement of fugitive dust (by application of water, chemical dust 

suppressants, or other measures) when air quality, soil loss, or safety concerns are identified by the 

BLM or the WDEQ_AQD. These concerns include but are not limited to potential exceedances of 

applicable air quality standards. The BLM will approve control measures, locations, and application 

rates. If watering is the approved control measure, Operators will obtain the water from 

state_approved sources. 

F-3.3 TOPOGRAPHY AND PHYSIOGRAPHY 

1. Operators will incorporate in their Surface Use Plans and Plans of Development the reclamation 

procedures and specifications contained in Standard Practices Applied to Surface_Disturbing 

Activities (BLM 1992:Appendix7_2), the Reclamation Plan for this project (ROD AppendixA), and 

guidelines for road construction contained in BLM Manual, Section 9113 (BLM 1985, 1991), TP 

(ROD AppendixB), and TPTSD (BLM 1999). 

2. Areas with high erosion potential and/or rugged topography (i.e., steep slopes [>25%], stabilized sand 

dunes, flood plains, erosive and sandy soils) will be avoided where possible, or specialized mitigation 

measures to control erosion will be applied. 

3. Upon completion of construction and/or production activities, Operators will restore the topography to 

near pre_existing contours at well sites, access roads, pipelines, and other facility sites. 

F-3.4 GEOLOGICAL/PALEONTOLOGICAL

 RESOURCES 

1. Geologic risks will be minimized by implementing site_specific alignment variations for roads, 

pipelines, and drill pads to avoid and/or minimize disturbances to unstable areas. 

2. BLM/WOGCC casing and cementing criteria will be followed to protect all subsurface mineral- and 

water_bearing zones. 

3. If paleontological resources are discovered by Operators or any person working on their behalf, at any 

time during construction, construction activities that could potentially disturb these resources will 

cease and the BLM will be notified immediately. In compliance with paleontological resource 

management guidelines (BLM 1998a, 1998b), the BLM will arrange for a determination of 

significance and, if necessary, recommend a recovery or avoidance plan. Mitigation of 

paleontological resources will be on a case_by_case basis, and the Operator will incur all costs. 

Surface_disturbing activity will not resume until a Notice to Proceed is issued by the BLM. 
Record of Decision, Continental Divide/Wamsutter II 22 

F-3.5 SOILS 

1. Prior to commencement of well location construction, all available topsoil (up to 12inches) will be 

stripped from cut, fill, stockpile, and pit areas, and salvaged topsoil will be stockpiled for future 

reclamation operations. 

2. Operators will keep the area of disturbance to the minimum necessary for drilling activities and 

subsequent production activities while providing for safety. 

3. Operators will restrict off_road vehicle activity by employees and contract workers. 

4. Operators will restrict project_related travel during periods when soils are saturated and excessive 

rutting (e.g., >4 inches) could occur. 

5. Where feasible, Operators will locate pipelines immediately adjacent to roads or other pipelines to 

avoid creating separate areas of disturbance. 

6. Operators will minimize construction activities in areas of steep slopes (e.g., >25%) and sand dunes 

and will apply special slope-stabilizing structures and techniques in accordance with applicable 

geotechnical data (e.g., mulch, revegetation) if construction cannot be avoided in these areas. 

7. Operators will not conduct construction activities using frozen or saturated soils, unless an adequate 

plan is submitted and approved by the BLM that demonstrates potential impacts will be mitigated. 

8. Operators will minimize disturbance to vegetated cuts-and-fills on new and existing roads. 

9. Runoff and erosion control measures such as water bars, berms, and interceptor ditches will be 

installed as necessary (see ROD AppendixA). 

10. All drainage crossing structures will be designed to carry at least a 10_year/24_hr storm event, 

pursuant to guidelines in BLM Manual, Section 9113 (BLM 1985, 1991). 

11. Operators will replace topsoil or suitable growth materials over all disturbed surfaces prior to

revegetation.

12. Operators will revegetate all disturbed sites as soon as practical following disturbance (see ROD 

AppendixA). 

F-3.6 WATER RESOURCES 

1. Construction at drainage crossings will be limited to periods of low or no flow. 

2. Operators will follow all practical alternatives and designs to limit disturbance within drainage 

channels, including ephemeral and intermittent draws. 

3. Channel crossings by pipelines will be constructed so that the pipe is buried at least 4 ft below the 

channel bottom. 

4. Channel crossings by roads and pipelines will be constructed perpendicular to flow. 

5. Disturbed channel beds will be reshaped to their approximate original configuration. 

6. All disturbances to wetlands and/or waters of the U.S. will be coordinated with the U.S. Army Corps of 

Engineers (COE), and Section 404 permits will be secured as necessary prior to disturbance. 

7. A 500_ft wide buffer area of undisturbed land will be left between construction sites and perennial 

channels or open water areas. 

8. A 100_ft wide buffer area of undisturbed land will be left between construction sites and ephemeral 

and intermittent channels. 

9. All reserve pits will be constructed in cut or stabilized fill material. 

10. Subsurface material at all reserve pits will be inspected by BLM as deemed necessary during 

construction to assess stability and permeability to determine the need for pit reinforcement or lining. 

If directed by the BLM and/or the WOGCC, a synthetic liner will be installed. 

11. Reserve pits that contain materials potentially hazardous to the environment (see ROD AppendixC 

and BLM [1998c]) will be lined if they are located at sites where ground water occurs within 20 ft of 

the surface or where potential ground or surface water could be contaminated. 
Record of Decision, Continental Divide/Wamsutter II 22 

12. If reserve pit leakage is detected, reserve pit use at the site will be curtailed, as directed by the BLM, 

until the leakage is corrected. 

13. All reserve pits will be designed with at least 1.0-ft of free board. 

14. All water used in association with this project will be obtained from Wyoming State Engineer's Office 

(WSEO)_permitted ground water wells. 

15. The discharge of all water (storm water, produced water) will be done in conformance with 

WDEQ_Water Quality Division (WQD), BLM, and WOGCC rules and regulations (WDEQ 1978; 

BLM Onshore Oil and Gas Order No. 7). 

16. Concentrated water flows within access road ROWs will be managed utilizing best management 

practices as described in ROD AppendixA. 

17. Operators will prepare SWPP Plans for all disturbances greater than 5acres in size as required by 

WDEQ National Pollutant Discharge Elimination System (NPDES) permit requirements. In some 

instances, SWPP Plans for groups of wells may be developed. 

18. Operators will implement Spill Prevention Control and Countermeasure (SPCC) Plans, where

applicable, in accordance with 40Code of Federal Regulations (C.F.R.) 112.

19. BLM/WOGCC casing and cementing criteria will be followed to protect all subsurface mineral- and 

water_bearing zones. 

F-3.7 NOISE AND ODOR 

Operators will ensure that all motorized equipment is muffled and maintained. 

F-3.8 VEGETATION 

1. Operators will finance site_specific surveys for federally listed threatened and endangered (T&E), 

candidate, and proposed plant species and plant species of special concern (former U.S. Fish and 

Wildlife Service (USFWS) Category 2 candidate species) prior to any surface disturbance in areas 

determined by the BLM to contain potential habitat for such species (BLM Directive U.S. Department 

of Interior [USDI]_BLM 6840). These surveys will be completed by a qualified botanist as authorized 

by the BLM, and this botanist will be subject to BLM's special status plant survey policy 

requirements. Data from these surveys will be provided to the BLM, and if any T&E, candidate, 

proposed, or special status plant species or their habitats are found, BLM recommendations for 

avoidance or mitigation will be implemented. Minor relocation of project facilities will be made to 

avoid these species and/or their habitat. If avoidance is not possible, informal consultation with the 

USFWS will be initiated, as necessary. 

2. Herbicide applications will be kept at least 500 ft from known special status plant populations. 

3. Removal or disturbance of vegetation will be kept to a minimum through construction site 

management (e.g., by utilizing previously disturbed areas, using existing ROWs, designating limited 

equipment/ materials storage yards and staging areas, scalping, etc.). 

4. Operators will seed and stabilize disturbed areas in accordance with the reclamation guidelines 

presented in ROD AppendixA. 

5. Operators will monitor for noxious weeds and will apply BLM_approved weed control techniques (e.g., 

soil sterilants, biological controls), as necessary. 

6. Operators will evaluate all project facility sites for occurrence of waters of the U.S., special aquatic 

sites, and wetlands, per COE requirements. All project activities will be located outside of these 

sensitive areas, where practical. 

7. Where wetlands, riparian areas, streams, and ephemeral/intermittent stream channels must be 

disturbed, COE Section404 permits will be obtained as necessary, and the following measures will be 

employed. 
Record of Decision, Continental Divide/Wamsutter II 22 

a. Wetland areas will be crossed during dry conditions (i.e., late summer, fall, or dry winters); winter 

construction activities will occur only prior to soil freezing or after soils have thawed. 

b. Streams, wetlands, and riparian areas disturbed during project construction will be restored to 

pre_project conditions, and if impermeable soils contributed to wetland formation, soils will be 

compacted to reestablish impermeability. 

c. Wetland topsoil will be selectively handled. 

d. Recontouring and BLM_approved species will be used for reclamation. 

e. Reclamation activities will begin on disturbed wetland areas immediately after completion of 

project activities. 

F-3.9 WILDLIFE AND FISHERIES 

1. Operators will support and implement activities as defined in the Wildlife Protection Plan for this 

project (see ROD AppendixD). 

2. Operators will not perform construction activities in big game crucial winter ranges from November 15 

to April 30, unless specifically allowed by the BLM. 

3. Wildlife_proof fencing will be constructed around areas that could be potentially hazardous to wildlife 

(e.g., reserve pits, toxic material storage locations) as deemed necessary by the BLM. 
Record of Decision, Continental Divide/Wamsutter II 22 

4. Wildlife_proof fencing will be utilized on reclaimed areas if it is determined that wildlife species are 

impeding successful vegetation establishment. 

5. Reserve, workover, and evaporation/ production pits potentially hazardous to wildlife will be 

adequately protected (e.g., fenced, netted) to prohibit wildlife access as directed by the BLM and to 

ensure protection of migratory birds and other wildlife. 

6. ROW fencing associated with this project will be kept to a minimum, and if necessary, fences will 

meet BLM and Wyoming Game and Fish Department (WGFD) approval for facilitating wildlife 

movement. 

7. Operators will implement policies designed to control poaching and littering and will notify all 

employees (contract and company) that conviction of a major game violation could result in 

disciplinary action. Contractors will be informed that any intentional poaching or littering within the 

CD/WIIPA could result in dismissal. 

8. Operators will internally enforce existing drug, alcohol, and firearms policies. 

9. Any power line construction will follow recommendations by the Avian Power Line Interaction 

Committee (APLIC) (1994, 1996) and Olendorff et al. (1981) to avoid collisions and electrocution of 

raptors and other avifauna. 

10. USFWS and WGFD consultation and coordination will be conducted as necessary for all mitigation 

activities related to raptors and T&E species (and their habitats), and all permits required for 

movement, removal, and/or establishment of raptor nests will be obtained. 

11. Proposed disturbance within 1.0 mi of identified raptor nests will be surveyed by a qualified biologist 

to determine activity status prior to commencement of drilling and construction during raptor nesting 

periods. If an active raptor nest is identified within 0.25to 1.0 mi (depending upon species and line of 

sight) of a proposed site, Operators will restrict construction during the critical nesting season for that 

species. 

12. Operators will not conduct surface-disturbing activities within 0.25 mi of active sage grouse leks. 

13. Operators will limit construction activities between March 1 and June 30 within a 2.0_mi radius of 

active sage grouse leks on suitable sage grouse nesting habitat as determined during on_site reviews 

of proposed development areas. 

14. Site_specific surveys for federally listed T&E, candidate, and proposed animal species and animal 

species of special concern will be conducted prior to surface disturbance in areas determined by the 

BLM to contain potential habitat for such species. These surveys will be completed by a qualified 

biologist as authorized by the BLM. Data from these surveys will be provided to the BLM, and if any 

T&E, candidate, proposed, or special status animal species or their habitats are found, BLM 

recommendations for avoidance or mitigation will be implemented. Minor relocation of project 

facilities will be made to avoid these species and/or their habitats. If avoidance is not possible, 

informal consultation with the USFWS will be initiated, as necessary. 

15. Mountain plover habitats (e.g., cushion plant communities, playa lakes, areas with vegetation <4 

inches in height) will be avoided where practical, and where these habitats will be disturbed, 

reclamation will utilize procedures designed to re-establish suitable plover habitat as directed by the 

BLM. Furthermore, mountain plover surveys will be conducted within suitable plover habitat on the 

CD/WIIPA by a qualified biologist in accordance with USFWS guidelines and as directed by the 

BLM. The survey procedures will include the following. 

• Visual observation of areas within 656ft (200 m) of proposed disturbance will be made from 

stationary vehicles and/or all-terrain vehicles (ATVs) to detect the presence of plovers. All 

plovers located will be observed long enough to determine if a nest is present. 

• Surveys will be conducted no more than 14 days prior to the date actual ground_disturbing 

activities begins. If two surveys are required, they will be made at least 14 days apart, with the 

last survey no more than 14 days prior to the start_up date. 
Record of Decision, Continental Divide/Wamsutter II 29 

• Surveys will be required by the BLM to clear an action for mountain plovers prior to beginning a 

planned activity, and surveys will be conducted during the period of April 15-June 30 for 

development activities planned during this period. 

• If an active plover nest is found in the survey area, the planned activity will be delayed at least 

37 days or 1 week post_hatching. If a brood of flightless chicks is observed, activities will be 

delayed at least 7days. 

• Road construction and maintenance (i.e., grading) activities will be minimized from May 25 to 

June 30. 

• Where practical, no new surface_disturbing activities will be conducted from April 1 to June 30 

within 656 ft of identified mountain plover concentration areas (i.e., areas where broods and/or 

adults have been observed in the current year or documented in at least 2 of the past 3years). 

• Where access roads and/or well locations have been constructed prior to the mountain plover 

nesting season and use of these areas has not been initiated for development actions, the BLM 

will require site investigations of these disturbed areas prior to use to determine whether mountain 

plover are present. In the event mountain plover nesting is occurring, the BLM may require 

delays in development activities until nesting is complete. 

16. Where prairie dog colonies will be disturbed, operators will consult with the USFWS and/or the BLM 

and BLM will initiate informal consultation with the USFWS to determine if black_footed ferret 

searches are required. When ferret searches are required, they will be conducted in accordance with 

USFWS guidelines (USFWS 1989). 

17. Where possible, proposed disturbance areas will avoid prairie dog colonies which meet black_footed 

ferret habitat size and burrow density criteria (USFWS 1989). 

18. No surface water or shallow ground waters in connection with live surface waters will be utilized for 

the proposed project. 

19. Pursuant to the Endangered Species Act, Operators will adhere to all survey, mitigation, and 

monitoring requirements identified in the Biological Assessment (BA) for this project (see ROD 

AppendixE). 

F-3.10 CULTURAL AND HISTORIC RESOURCES 

1. Operators will adhere to the Section 106 compliance process (36C.F.R.800) or National Cultural 

Programmatic Agreement (NCPA) and Wyoming State Protocol (WSP) prior to any surface-disturbing 

activity. 

2. Operators will halt construction activities in potentially affected areas if previously undetected 

cultural resource properties are discovered during construction. The BLM will be immediately 

notified, consultation with the Wyoming State Historic Preservation Office (SHPO) and Advisory 

Council will be initiated as necessary, and proper mitigation measures will be developed pursuant to 

the WSP under the NCPA, or 36C.F.R.800.11. Construction will not resume until a Notice to Proceed 

is issued by the BLM. 
Record of Decision, Continental Divide/Wamsutter II 29 

3. Provisions similar to those of the Oregon/Mormon Pioneer National Historic Trails Management Plan 

(BLM 1986) or newly developed cultural resource management plans will be followed for any actions 

potentially affecting the Overland Trail, Cherokee Trail, and/or Lincoln Highway. 

4. Operators will pay the costs of BLM_required mitigation for cultural resources. 

F-3.11 SOCIOECONOMICS 

Operators will implement hiring policies that encourage the use of local or regional workers. 

F-3.12 LIVESTOCK/GRAZING MANAGEMENT 

1. Operators will coordinate project activities with ranching operations to minimize conflicts with 

livestock movement or other ranch operations. 

2. Operators will maintain all fences, cattle guards, and other livestock-related structures required for 

their transportation network. 

3. In areas of high livestock use, reclaimed area fencing will be utilized as necessary to ensure

successful vegetation establishment.

F-3.13 LAND STATUS/USE 

Roads, power lines, and pipelines will be located adjacent to existing compatible linear facilities 

wherever possible. 

F-3.14 RECREATION 

1. Operators will post appropriate warning signs and require project vehicles to adhere to appropriate 

speed limits on project_required roads. 

2. Operators will inform their employees, contractors, and subcontractors that long_term camping 

(greater than 14 days) on federal lands or at federal recreation sites is prohibited. 

3. Operators will direct their employees, contractors, and subcontractors to abide by all state and federal 

laws and regulations regarding hunting and artifact collecting. 

F-3.15 TRANSPORTATION 

1. Detailed practices and procedures as specified in the TP for this project (ROD AppendixB) will be 

followed. Annual TPTSD updates (BLM 1999) will be developed and will identify the minimum road 

network required to support annually proposed project activities, as well as construction and 

maintenance responsibilities of the Operators. Annual TPTSD updates will also identify dust 

abatement, road construction, and surfacing requirements. 

2. Existing roads will be used to the maximum extent possible and upgraded as necessary. 

3. All Operator_constructed roads not required for routine operation and maintenance of producing wells 

or ancillary facilities will be reclaimed as directed by the BLM, Wyoming State Land Board, or 

private landowner. As necessary, these roads will be permanently blocked, recontoured, reclaimed, 

and revegetated by Operators, as will disturbed areas associated with permanently plugged and 

abandoned wells. 

4. Where required by the BLM, site_specific centerline surveys and/or detailed construction designs will 

be submitted to and approved by the BLM prior to road construction. 

5. Operators will comply with existing federal, state, and county requirements and restrictions to protect 

road networks and the traveling public. 

6. Special arrangements will be made with the WDOT to transport oversize loads to the CD/WIIPA. 
Record of Decision, Continental Divide/Wamsutter II 29 

Otherwise, load limits will be observed at all times to prevent damage to existing road surfaces. 

7. All development activities along approved ROWs will be restricted to areas authorized in the

approved ROW.

8. Operators will be responsible for maintenance of roads in the project area and for closure of roads 

following production activities. 

9. Where proposed roads will follow existing roads, those portions of existing roads not included in the 

new ROW will be reclaimed and revegetated by the Operator. 

10. Available topsoil (up to 12 inches) will be stripped from all road corridors prior to commencement of 

construction activities and will be redistributed and reseeded on back slope areas of the borrow ditch 

after completion of road construction activities. Borrow ditches will be reseeded in the first 

appropriate season after initial disturbance. 

F-3.16 VISUAL RESOURCES 

1. Operators will utilize existing topography to screen roads, pipeline corridors, drill rigs, wells, and 

production facilities from view where possible. 

2. Operators will paint all aboveground production facilities with appropriate colors (e.g., Carlsbad 

Canyon or Desert Brown) to blend with the adjacent terrain, except for structures that require safety 

coloration in accordance with Occupational Safety and Health Administration (OSHA) requirements. 

F-3.17 HEALTH AND SAFETY/HAZARDOUS MATERIALS 

1. Operators will utilize WDEQ_approved portable sanitation facilities at drill sites. 

2. Operators will place warning signs near potentially hazardous areas (e.g., well locations, ancillary 

facilities) and along roadways. 

3. Operators will place appropriate dumpsters at each construction site to collect and store garbage and 

refuse. 

4. Operators will ensure that all refuse and garbage is transported to a State of Wyoming_approved 

sanitary landfill for disposal. 

5. Each operator will institute a Hazard Communication Program for its employees and will require 

subcontractor programs in accordance with OSHA (29 C.F.R. 1910.1200). 

6. Operators will keep on file, at the field office, a Material Safety Data Sheet (MSDS) for every 

chemical or hazardous material that is brought on_site in accordance with 29C.F.R. 1910.1200. 

7. SPCC Plans will be written and implemented where applicable in accordance with 40 C.F.R. 112. 

8. Chemical and hazardous materials will be inventoried and reported in accordance with the regulations 

for implementing the SARA Title III (40 C.F.R. 335). If quantities exceeding 10,000 pounds or the 

threshold planning quantity (TPQ) are to be produced or stored, the appropriate Section311 and 312 

forms will be submitted at the required times to the State and County Emergency Management 

Coordinators and the local fire departments. 

9. Any hazardous wastes, as defined by the Resource Conservation and Recovery Act of 1976, (RCRA) 

as amended, will be transported and/or disposed of in accordance with all applicable federal, state, 

and local regulations. 
Record of Decision, Continental Divide/Wamsutter II 34 

F-4.0 ADDITIONAL BLM MITIGATION AND/OR 

MONITORING REQUIREMENTS

The following mitigation and/or monitoring requirements were identified in EIS, Chapter 4.0, and have been 

added to help further reduce impacts to certain resources. The resource values listed below were identified in 

the EIS under the Proposed Action as likely to be significantly impacted. These additional 

mitigation/monitoring requirements are intended to protect and further decrease the impacts to the resource; 

however, they are not expected to decrease impacts to a level of no significant impact. 

F-4.1 SOILS 

Operators will be required to conduct regular monitoring of erosion control structures within the CD/WIIPA to 

ensure maintenance of the operating integrity of these structures. Monitoring procedures and schedules will be 

specified in APDs or ROW applications and will comply with specifications contained in ROD Appendix A. 

Appropriate remedial action will be taken by Operators to correct non-functioning structures. 

F-4.2 WATER RESOURCES 

Additional monitoring and erosion and runoff control measures will be applied on disturbed areas in the 

Antelope/Bitter Creek drainage to ensure no further degradation of stream channels. 

F-4.3 NOISE AND ODOR 

Noise mitigations (e.g., equipment housing) will be applied at well locations, as determined necessary on a 

case_by_case basis by the BLM. Construction, drilling, completion, testing, and production facility 

installation activities will be limited within 0.25 mi or other distance of occupied residences. 

F-4.4 LAND USE 

To provide additional environmental protection for area residents, the BLM will require that well locations and 

associated production equipment be situated 350 ft or greater distance from residences. (This is in 

conformance with rules and regulations of the WOGCC). Furthermore, the BLM will consult with community 

and county governments/organizations to obtain input and advice regarding the protection of public health and 

safety in and proximal to rural residential areas. 

F-4.5 RATIONALE FOR EXCLUSION OF

 ADDITIONAL MITIGATIONS 

Additional potential BLM environmental protection and mitigation and monitoring measures as identified in 

EIS Chapter 4.0 that are not included as requirements for this project were not adopted for one or more of the 

following reasons: 

• the measure is not the responsibility of the BLM and therefore cannot be required (i.e., another agency 

is responsible for authorization); 

• the measure is not necessary for protection from undue and unncessary environmental degradation; 

• analyses revealed that the measure was not necessary for adequate environmental protection (e.g., 

impacts without the measure were less than significant); 

• the measure is already included as a component of the Proposed Action; and/or 

• the measure would result in unreasonable restriction on leased lands. 
Record of Decision, Continental Divide/Wamsutter II 34 

F-5.0 REFERENCES 

Avian Power Line Interaction Committee. 1994. Mitigating bird collisions with power lines: The state of the art in 1994. Edison Electric 

Institute, Washington, D.C. 78 pp. + append. 

. 1996. Suggested practices for raptor protection on power lines: The state of the art in 1996. Edison Electric Institute/Raptor Research 

Foundation. Washington, D.C. 

Bureau of Land Management. 1985. Manual 9113: Roads. Engineering, Rel. 9-247. U.S. Department of the Interior, Bureau of Land 

Management. 

. 1986. Oregon/Mormon Pioneer National Historic Trails management plan. U.S. Department of the Interior, Bureau of Land 

Management. BLM-WY-86-007-4333. 244 pp. 

. 1991. Wyoming supplement to the Bureau 9113 Manual. U.S. Department of the Interior, Bureau of Land Management, Wyoming 

State Office, Cheyenne, Wyoming. 16 pp. 

. 1992. Green River Resource Area management plan and draft environmental impact statement. U.S. Department of the Interior, 

Bureau of Land Management, Rock Springs District, Rock Springs, Wyoming, BLM-WY-ES-92-019-4410. 901 pp. 

. 1998a. 8270-paleontological resource management. U.S. Department of Interior, Bureau of Land Management. Release 8-68. 6pp. 

. 1998b. H-8270-1 - General procedural guidance for paleontological resource management. U.S. Department of Interior, Bureau of 

Land Management. Release8-69. 21pp. 

. 1998c. Hazardous materials summary for the Continental Divide/Wamsutter II Project. Prepared for Bureau of Land Management, 

Great Divide Resource Area, Rawlins District, Rawlins, Wyoming, and Green River Resource Area, Rock Springs District, Rock Springs, 

Wyoming, by TRC Mariah Associates Inc., Laramie, Wyoming. 

. 1999. Transportation planning technical support document, Continental Divide/ Wamsutter II environmental impact statement project. 

Prepared for Bureau of Land Management, Great Divide Resource Area, Rawlins, Wyoming, and Green River Resource Area, Rock 

Springs, Wyoming, by TRC Mariah Associates Inc., Laramie, Wyoming, and Uintah Engineering and Land Surveying, Vernal, Utah. 

Olendorff, R.R., A.D. Miller, and R.M. Lehman. 1981. Suggested practices for raptor protection on power lines: The state of the art in 1981. 

Raptor Research Report No. 4, Raptor Research Foundation, Inc., University of Minnesota, St. Paul. 111 pp. 

U.S. Fish and Wildlife Service. 1989. Black-footed ferret survey guidelines for compliance with the Endangered Species Act. U.S. Fish and 

Wildlife Service, Denver, Colorado, and Albuquerque, New Mexico. 10pp. + append. 

Wyoming Department of Environmental Quality. 1978. Water quality rules and regulations. Chapter VII: Surface discharge of water 

associated with the production of oil and gas. Wyoming Department of Environmental Quality, Water Quality Division, Cheyenne, 

Wyoming. 6pp. 

. 1989. Wyoming air quality standards and regulations. Wyoming Department of Environmental Quality, Air Quality Division, 

Cheyenne, Wyoming. 88Pp. 
APPENDEX G: 

U.S. FISH AND WILDLIFE SERVICE

BIOLOGICAL OPINION
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 2 

Ecological Services 

4000 Airport Parkway 

Cheyenne, Wyoming 82001 

ES-61411 June 21, 2000 

W.02 (BIO-OPIN.WPD) 

Memorandum 

To: Field Manager, Rawlins Field Office, Bureau of Land Management 

From: Field Supervisor, Ecological Services, Cheyenne, Wyoming 

Subject: Final Biological and Conference Opinions for the Proposed Continental Divide/Wamsutter II 

Natural Gas Project, Sweetwater and Carbon Counties, Wyoming 

This document transmits the U.S. Fish and Wildlife Service’s (Service) final biological and conference 

opinions based on our review of the proposed Continental Divide/Wamsutter II Natural Gas Project (project), 

in Sweetwater and Carbon counties, Wyoming, and its effects on federally listed and proposed species in 

accordance with section 7 of the Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 et seq.). 

Your November 12, 1999, request for formal consultation was received on November 15, 1999. 

These biological and conference opinions are based on information provided in the Bureau of Land 

Management’s (BLM) draft (BLM 1999a) and final (BLM 1999b) environmental impact statements (EIS); 

attached biological assessment (BA) including a description of the project proposal; meetings of November 

20, 1998, October 12, November 8, December 16, 1999 and March 7, 2000; memoranda of July 10, 1998, and 

February 23, 1999; letter of January 20, 2000 (Michael J. Brennan, Holland and Hart, Attorneys at Law); and 

numerous telephone conversations. A complete administrative record of this consultation is on file at the 

Service’s Wyoming Field Office. 

This office has been working with BLM, Rawlins Field Office staff, representatives of the major natural gas 

lease holders on the EIS analysis area (hereafter ‘Operators’), and staff of TRC Mariah, the consultant 

preparing the EIS, since May 30, 1997, to minimize or avoid impacts to federally listed species. This work 

has included development of the Wildlife Protection Plan (Appendix D of the draft EIS), review of the draft 

EIS and several preliminary drafts of the BA. 

In our memorandum of July 23, 1999, we recommended the BLM initiate formal conference for the proposed 

threatened mountain plover to avoid possible project delays in the future should the species be listed. In our 

memorandum of October 25, 1999, we reiterated this point and further recommended that, if the project could 

not be modified to explicitly avoid disturbance to prairie dog towns in which bla 

ck-footed ferrets are discovered, then the Service would be unable to concur with a “not likely to adversely 

affect” determination for the black-footed ferret and BLM should initiate formal consultation. In response to 

this and the meeting of November 8, 1999, between Service and BLM staff, you requested initiation of formal 

conference on the mountain plover, and formal consultation on the black-footed ferret in your memorandum of 

November 12, 1999. In our memorandum of March 22, 2000, the Service requested an extension until April 

21, to respond to BLM and applicant comments. In your memorandum of March 24, BLM approved this 

request. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 3 

BIOLOGICAL AND CONFERENCE OPINIONS 

Description of Proposed Action 

In the EIS for the project, the BLM described the proposed action as the continued issuance of permits on 

Federal lands necessary for the exploration and development of natural gas reserves in portions of Sweetwater 

and Carbon counties, Wyoming. Operators propose to construct, operate, and reclaim a maximum of 3,000 

new well locations (2.6 acres per location) 1,500 miles of new or upgraded roads (3.3 acres per location), 

1,500 miles of new pipelines (1.5 acres per location), 5 compressor stations (20 total acres, 4 acres per 

station), 1 gas processing facility (30 acres), 10 evaporation ponds (34 acres), 5 disposal wells (35 acres), and 

50 water wells (25 total acres, 0.5 acre per well). Total maximum initial ground disturbance is estimated at 

22,400 acres with disturbance of 15,900 acres continuing through the project life. This development will be 

divided roughly 50% on Federal and 50% on non-Federal surface ownership. Construction is expected to occur 

over 10-20 years with operation and reclamation continuing over a 30-50 year project life. During construction, 

approximately 150-300 wells would be drilled per year. 

The proposed action includes implementation of a reclamation plan, travel management plan, and wildlife 

monitoring/protection plan (appendices A, B, and D of the EIS, respectively). One purpose of these plans is to 

minimize impacts to sensitive resources, including federally listed and proposed species, by reviewing the 

effects of ongoing actions and modifying future development accordingly. The reclamation plan is designed to 

provide guidance to achieve successful reclamation while permitting flexibility in site-specific reclamation 

activities. The transportation plan is intended to provide a means for public involvement in ongoing review 

and planning of the developing road system. It will help to identify and avoid or minimize conflicts between 

sensitive resources, including federally listed and candidate species, and the developing transportation system. 

The wildlife protection plan is intended to avoid or minimize project impacts to wildlife by monitoring 

population trends as the field develops, annually reviewing project activities and identified impacts, and 

modifying future development through an adaptive management process. 

The wildlife protection plan describes measures identical to the biological assessment to avoid or minimize 

impacts to any black-footed ferrets or mountain plovers which may be found. For the black-footed ferret, this 

includes avoidance of prairie dog towns were practical. Project-specific ferret surveys would be conducted if 

prairie dog towns are to be disturbed. If ferrets are found, the Service would be contacted for guidance prior to 

ground-disturbing activities. For the mountain plover, protective measures include surveys for nesting 

mountain plovers prior to ground-disturbing activities during the breeding season. If a plover is found nesting or 

attending a flightless brood in the area, ground-disturbing activities would be delayed long enough to avoid 

possible take (37 days, or one week post-hatch for nests; or 7 days for broods). 

The project analysis area lies in eastern Sweetwater County and southwestern Carbon County, Wyoming, in 

portions of Townships 15 through 23 North, Ranges 91 through 99 west. It extends over 1,061,200 acres, 

including 531,400 acres of Federal surface, 9,800 acres of State surface, and 520,000 acres of private surface 

interspersed in a “checkerboard” pattern, resulting from Federal land grants of the 19th Century. This highly 

interspersed surface ownership makes the analysis of the effects of any project-level Federal action difficult. 

There will be many actions on non-Federal surface that would not occur but for a Federal action. These 

actions must be considered inter-related or inter-dependent to the Federal action. New Federal rights-of-way 

(ROW) for access to non-Federal inholdings will commonly lead to inter-related and inter- dependent actions 

on non-Federal lands. While there is no specific analysis of the extent of the relationship between 

development on Federal and non-Federal surface in the EIS, it is reasonable to assume that the number of 

development actions entirely independent of a future Federal action will be very small. 

The analysis area currently contains a moderate level of gas field development as well as an existing network 

of roads and trails to support ongoing land management activities. Other development includes the I-80 

corridor, including the highway, rail lines, interstate pipelines and communications cables, and the 

communities of Creston, Wamsutter, Red Desert, and Tipton. 

The analysis area contains generally flat topography with elevations ranging from 6,500 to 7,500 feet above 

sea level. The climate is typical of the Great Basin ecoregion, with long, cold winters, high winds, and 

limited rainfall. Vegetation communities of the analysis area are also typical of Great Basin shrub-steppe 

grasslands, dominated by Wyoming big sagebrush (Artemisia tridentata wyomingensis), greasewood 

(Sarcobatus vermiculatus), mixed desert shrub species, or Gardner’s saltbush (Atriplex gardneri). Riparian 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 4 

habitat, dominated by willow (Salix spp.), basin big sagebrush (A. t. tridentata), and greasewood; unvegetated 

playas; wetlands; and short-or mixed- grass prairie are important wildlife habitats that cumulatively constitute 

less than 1% of the analysis area. Bare rock and soil comprises approximately 2.9% of the analysis area. 

White-tailed prairie dog (Cynomys leucurus) towns cover a significant portion of the analysis area They may 

be present on as many as 324 sections, as represented in Map 3.11 of the draft EIS (Appendix 1), though 

resolution and currency of the data are inadequate for a clear understanding of prairie dog abundance at this 

time. The habitat provided by prairie dog towns is important for a number of federally listed, proposed, and 

State sensitive species. 

Detailed descriptions of the proposed action and the environment of the analysis area are contained in the draft 

and final EIS’s (BLM 1999a and BLM 1999b) and included here by reference. 

Status of species 

LISTED SPECIES 

Black-footed Ferret 

Unless otherwise noted, information presented here is drawn from the Black-footed Ferret Recovery Plan (U.S. 

Fish and Wildlife Service 1988). 

Species Description 

The black-footed ferret is a small weasel-like carnivore within the Family Mustelidae (weasels, skunks, 

badgers, and otters) and is the only ferret native to North America. It is closely related to two Old World 

species, the Siberian and European polecats. Relatively small and long-bodied with short limbs, its overall 

pelage coloration is yellow-buff or tan, darker along the dorsum with a distinctive combination of black feet, 

tail tip, and forehead or broad facial mask. The body length averages 15-18 inches with a tail length of about 

5-6 inches. The body weight is approximately 2_ pounds. 

The species was thought to be extinct until a single surviving population was discovered near Meeteetse, 

Wyoming in 1981. Eighteen individuals from this single population (which once consisted of about 130 

animals) provided the source of all captive-bred and reintroduced ferret populations. Outbreaks of sylvatic 

plague and canine distemper at Meeteetse in 1985, led to severe population declines and concern for the 

continued existence of the species. In response, the surviving ferrets were removed from the wild for captive 

breeding, a process that was complete by 1987. 

The black-footed ferret was federally listed as endangered on March 11, 1967 (32 FR 4001). The species has 

been re-introduced to portions its former range in Montana, South Dakota, Wyoming, Utah, and Arizona. 

Re-introduced populations have been designated as "experimental non- essential" in accordance with section 

10(j) of the Act. Critical Habitat was not designated. 

A recovery plan was approved on June 14, 1978, and updated on August 8, 1988. The plan's criteria for 

downlisting to threatened call for: 1) increasing the captive population size to 200 breeding adults by 1991, 2) 

establishing a pre-breeding population of 1,500 free-ranging adult ferrets consisting of 10 or more populations 

(with no fewer than 30 breeding adults in each population) by the year 2010, and 3) promoting the widest 

distribution of ferret re-introductions. Downlisting to threatened is also contingent upon a net increase (5-year 

minimum trend) of ferret establishment in approximately one tenth of 1% of their former range (approximately 

185-250,000 acres). 

Life History 

Only two wild populations of black-footed ferrets have been studied in detail: one in Mellette County, South 

Dakota from 1964 through 1975; and one in Park County, Wyoming from 1981 through 1987. Additional 

information has begun to come from re-introduced populations. Therefore, many analyses and conclusions are 

based on limited observations, study of captive individuals, or inference from life history of congeners. 

The black-footed ferret is a secretive, mostly nocturnal, solitary predator of prairie dogs (Cynomys spp. - i.e., 

black-tailed, C. ludovicianus; Gunnison's, C. gunnisoni; and white-tailed, C. leucurus ), which constitute the 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 5 

main prey as well as providing the burrow systems required by the ferret for breeding and shelter. Though 

prairie dogs make up over 90% of its diet, the black- footed ferret also feeds on rabbits, mice, voles, ground 

squirrels, pocket gophers, birds, and insects. 

Ferrets normally occupy prairie dog burrows but may dig their own. The size and aggregation of these towns 

appear to be the most important factors comprising suitable habitat. Ferret densities are positively correlated 

with prairie dog densities. The smallest town known to support one adult ferret in one year is about 31 acres. 

Normally, ferrets are not found in prairie dog towns less than 100 acres. Current ferret re-introduction efforts 

are limited to complexes not less than 10,000 acres in area to ensure maintenance of self-sustaining 

populations (Michael Lockhart, pers. comm., March 28, 2000). 

Breeding takes place in March or April, and females produce litters of 2-5 kits after a 41-45 day gestation. 

Although the male may be nearby, the female cares for the kits alone. The young are born helpless and 

remain in the nest approximately 40 days from birth. By September they begin to disperse, late summer and 

fall constituting a period of increased observability. This period of dispersal also presents the greatest danger 

to young-of-year ferrets as many mortalities have been observed in the period of August through October. 

Predators include the great horned owl (Bubo virginianus), golden eagle (Aquila crysaetos), ferruginous hawk 

(Buteo regalis), badger (Taxidea taxus), and coyote (Canis latrans). Potential but undocumented predators 

may include the bobcat (Lynx rufus), fox (Vulpes spp.), and prairie falcon (Falco mexicanus). 

In Wyoming, disease has had a great influence on populations. The black-footed ferret has no natural 

resistence to canine distemper, and the disease may be up to 100% fatal to infected individuals. In 1985, it 

was estimated that the Meeteetse population was reduced 50% per month as the distemper outbreak 

progressed. Yersina pestis, the causative agent of sylvatic plague, may also have a significant impact on 

population stability, both directly through significant black- footed ferret mortality and reduction in prey 

abundance. Prairie dogs are highly susceptible to this disease, quickly reducing prairie dog numbers in an 

affected town by 20-80%. With prey populations so greatly reduced, black-footed ferrets have difficulty 

meeting their nutritional requirements and ferret populations decline or disappear. 

Population Dynamics 

Black-footed ferrets annually produce one litter of 2-5 kits (mean = 3.3). Females may breed in their second 

year. Highest population numbers at Meeteetse were observed during the summer, when approximately 70% 

of the population consisted of juvenile animals. 

While the sex ratio at birth is not different from 1:1, at Meeteetse adult females outnumbered males by 2:1. 

This is probably due to the larger home range of the adult male and longer dispersal movements of juvenile 

males, which exposes them to higher predation than females. Mortality of males in the first year was 

estimated to be between 56 and 81%. Life expectancy for black-footed ferrets in the wild is about 5 years. 

Because of the short life span of the black-footed ferret, any yet-to-be found remaining wild populations must 

be sustained by successful reproduction and high first-year survival, parameters largely dependent upon an 

adequate density and distribution of their main prey, the prairie dog. Because of the ferret’s almost complete 

dependence on the prairie dog, large fluctuations in prairie dog abundance due to outbreaks of sylvatic plague 

or poisoning may cause exaggerated fluctuations in black-footed ferret abundance, in some cases leading to 

local extirpation. 

Status and Distribution 

Historically, black-footed ferrets ranged widely within the Great Plains including areas within Arizona, 

Colorado, Kansas, Montana, Nebraska, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, Utah, 

Wyoming, and the Canadian Provinces of Alberta and Saskatchewan. The historical range is nearly identical 

to that of the black-tailed, white-tailed and Gunnison’s prairie dogs. Widespread control or eradication of the 

prairie dog in the 20th Century, conversion of native prairie to tilled agriculture, and the introduction of 

sylvatic plague have resulted in the endangerment of the black-footed ferret. Ferret declines have been shown 

to correlate to decreases in area of prairie dog towns in a linear fashion. Fragmentation of remaining towns 

presents additional problems. Increasing isolation of towns inhibits the movement of ferrets within populations 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 6 

and mortality associated with dispersal movements probably increases. This further decreases the likelihood of 

recolonization of the remaining small amount of unoccupied but otherwise suitable habitat. 

In Wyoming, black-footed ferrets formerly occurred in all non-mountainous areas of the State (Clark and 

Stromberg 1987). No wild ferrets have been found since the loss of the Meeteetse population in 1987. 

Currently, there are no known naturally occurring ferret populations within the historical range of the species. 

Because there are remote areas with large acreages of un- surveyed prairie dog towns and because the ferret’s 

fossorial and nocturnal habits make it difficult to detect, wild populations of ferrets could remain in 

un-surveyed prairie dog towns. Several re- introduced populations have been established with varying success. 

Re-introduction has occurred in the Shirley Basin/Medicine Bow Management area (east-central Wyoming), 

Conata Basin/Badlands Reintroduction Area (southwestern South Dakota), North-Central Montana 

Reintroduction Area (north-central Montana), Aubrey Valley (northwestern Arizona), and the Coyote Basin in 

north-eastern Utah. 

Analysis of the Species Likely to Be Affected 

According the Service’s Black-footed ferret survey guidelines (U.S. Fish and Wildlife Service 1989, hereafter, 

‘Ferret Guidelines’), “Any actions that kill prairie dogs or alter their habitat could prove detrimental to ferrets 

occupying the affected prairie dog town(s).” The current definition of black-footed ferret habitat in the Ferret 

Guidelines states that towns or complexes of white-tailed prairie dogs must exceed 200 acres in extent to meet 

the energetic demands of a black-footed ferret. According the Ferret Guidelines, a town or colony is defined 

as a group of burrows whose density meets or exceeds 8 burrows per acre and a complex is defined as two or 

more towns each within 4.34 miles of each other. 

These criteria are based on the minimum energetic requirements of a reproducing female ferret (Biggins et al. 

1993). Due to their 3-5 year life span, the long-term persistence of black-footed ferrets is dependent on 

reproduction and recruitment adequate to maintain a population. The likelihood of finding a lone ferret not 

associated with a population is extremely remote. New information from the study of re-introduced ferrets 

suggests that a ferret population may need considerably higher quality habitat to persist for more than a few 

generations. Ferrets were found on white-tailed prairie dog colonies exceeding 27 active burrows per acre in 

Shirley Basin, rather than on adjacent lower-density habitat (R. Luce, pers. comm., March 28, 2000). Also, 

the most consistently used colonies at Meeteetse were located within 0.9 mile of one another (D. Biggins, 

pers. comm., March 28, 2000). Finally, population monitoring at re-introduction sites suggests that prairie dog 

complexes as large as 10,000 acres may be necessary to maintain a ferret population, though evidence to 

support a specific minimum size criteria is currently lacking (M. Lockhart, pers. comm. March 28, 2000). 

Because the Ferret Guidelines focus on the needs of individual ferrets rather than populations, it is apparent 

that use of the criteria in the Ferret Guidelines sometimes requires surveys in areas that are unlikely to support 

a population of black-footed ferrets over the long term. The Ferret Guidelines are designed for application on 

often small projects, where requirements to quantify ferret habitat over an area large enough to maintain a 

population would be excessively onerous. Therefore, for projects affecting small areas, they minimize the risk 

of taking ferrets without excessively burdening project proponents. Because the Continental Divide/Wamsutter 

II analysis area is large enough to contain one or more entire prairie dog complexes, habitat criteria and survey 

requirements differing from the Ferret Guidelines may be warranted if coordinated with efforts to identify 

complexes having a reasonable chance to maintain a viable or even residual population. 

Therefore, in this analysis suitable habitat for black-footed ferrets will be defined differently than in the Ferret 

Guidelines. For the purposes of this document, suitable habitat will consist of colonies having a mean active 

burrow density of 27 burrows per acre, and a minimum area of 1,000 acres or be part of a complex with a 

minimum area of 1,000 acres. A complex is defined as a group of colonies individually having mean active 

burrow densities of 27 burrows per acre and occurring within 0.9 mile of one another, as delineated by Biggins 

et al. (1993). This definition updates and supercedes the criteria set in the Ferret Guidelines for this project. 

Hereafter, the term ‘suitable habitat’ (for black-footed ferrets) will refer to this definition. The Service expects 

that the black-footed ferret may be adversely affected if project activities will disturb portions of colonies or 

complexes meeting these criteria for suitable habitat. 

The proposed action describes measures to be taken if a prairie dog town or complex meeting the size and 

density criteria in the Ferret Guidelines will be disturbed, but does not preclude such disturbance (BLM 1999a, 

Appendix E). Because disturbance to a town occupied by a black- footed ferret may cause take through direct 

mortality, harm or harassment, the Service could not concur with the BLM’s finding that “the proposed project 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 7 

is unlikely to adversely affect” the black-footed ferret (BLM 1999b). The Service disagrees with the 

conclusion that the species is unlikely to occur there because previous observations of black-footed ferrets 

exist from the analysis area. No data are presented to show that suitable habitat does not occur in the analysis 

area, and little organized black-footed ferret survey effort has occurred in the analysis area to date. Therefore, 

until the analysis area has been surveyed to locate suitable habitat and unless black-footed ferret surveys in 

all suitable habitat within the analysis area fail to find evidence of extant ferrets, the Service believes that the 

proposed action, as described, is likely to adversely affect the black-footed ferret. 

PROPOSED SPECIES 

Mountain Plover 

Unless otherwise noted, the information provided here was drawn from proposed rule to list the mountain 

plover as threatened under the Act (64 FR 7587-7601). 

Species Description 

The mountain plover is a small bird, about the size of a killdeer (Charadrius vociferus) in the plover family 

(Family Charadriidae). The type specimen was collected in 1837 by J. K. Townsend on the Sweetwater River 

of Wyoming. It is light brown above with paler underparts, lacking the contrasting dark breast bands typical of 

many other plover species. Breeding plumage differs only be the addition of a dark line between the bill and 

eyes contrasting with a pale forehead. The bill is black and the legs are gray. The sexes are alike. 

The mountain plover was designated a category 2 candidate species on December 30, 1982 (47 FR 58458), 

meaning that the species may be declining but more information was needed. The Service elevated its status 

to category 1 candidate in the 1994 Animal Candidate Notice of Review (59 FR 58982). In 1996, the Service 

did away with candidate categories 2 and 3, redefining candidate species to include only former category 1 

candidate species (61 FR 64481). The mountain plover was retained as a candidate species in the 1997 status 

review (62 FR 49298). The species was petitioned for listing as threatened on July 7, 1997. Due to its 

candidate status, no 90-day finding was required in response to this petition. On February 16, 1999, the 

Service gave notice of a proposal to list the mountain plover as a threatened species pursuant to the Act (64 

FR 7587). A final listing decision on this species is pending. 

Life History 

The mountain plover is a migratory species of the shortgrass prairie and shrub-steppe eco-regions of the arid 

West. The universal characteristics of mountain plover habitat on both the breeding and wintering grounds are 

short vegetation, bare ground, and flat topography. They are found associated with plains, alkali flats, 

agricultural lands, cultivated lands, sod farms, prairie dog towns, and low shrubs at both breeding and 

wintering locales. Unlike other plovers, they are rarely associated with water. 

Nesting has been reported from Colorado, Montana, Wyoming, New Mexico, Arizona, Nebraska, Utah, 

Kansas, Oklahoma, Texas, and Canada, and is suspected in Mexico. Mountain plovers occupy breeding 

habitat from late March through July. Flocks may form as early as mid-June prior to migration to wintering 

habitats in August through October. Wintering areas are concentrated in the Central and Imperial valleys of 

California, Texas and Mexico. There are no wintering areas in Wyoming. 

The nest of the mountain plover is a simple scrape on the ground, which may be lined with debris. Nests are 

usually placed in areas where vegetation is less than 4 inches in height, the amount of bare ground in the area 

exceeds 30%, and near a conspicuous object such as a manure piles or rocky area. In shortgrass prairie 

habitat, vegetation associated with nest sites includes blue grama (Bouteloua gracilis), buffalo grass (Buchloe 

dactyloides) and prickly pear cactus (Opuntia spp.). In shrub-steppe grasslands, vegetation around nests 

includes low-growing shrubs such as black sage (Artemisia nova) and Gardner saltbush (Atriplex gardneri) 

(Day 1994, Knopf 1996). Topography is typically flat or gently rolling. Hereafter in this document, “suitable 

mountain plover habitat” will refer to areas containing these characteristics: low relief, vegetation generally 

less than 4 inches in height, and bare ground present and at least locally exceeding 30% coverage. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 8 

The breeding season begins soon after birds arrive in late March or early April. Breeding season displays 

involve different calls and flight displays, including “falling leaf” and pursuit flights to advertize territory 

occupancy and define boundaries between territories. Territories in Colorado were about 40 acres, and 

adjacent territories may overlap significantly along boundaries. Breeding plovers show close site fidelity, 

often returning to the same territory in subsequent years. Territories tend to be aggregated with several 

breeding pairs occurring within a few square miles surrounded by empty but apparently suitable habitat (Knopf 

1996). 

Nests may be initiated 1-2 weeks after arrival on the breeding grounds and the clutch of 3 eggs may take 3-12 

days to complete. Incubation lasts approximately 29 days. In Colorado, egg- laying began April 15, 

continuing through mid-June, with one late nest observed June 23. Adults were found to incubate or attend 

nests with increasing frequency and duration as the incubation period continued. Nest attendance in Wyoming 

increased from approximately 50% of daylight hours early in incubation to approximately 100% within days of 

hatching (Laun 1957). Eggs appear highly resistant to chilling but susceptible to overheating in the sun due to 

their dark coloration (Knopf 1996). 

Chicks leave the nest soon after the last egg hatches. Chicks are usually attended by one adult, brooded about 

one third of the time for the first day. Daily movements of the broods may be extensive, with broods ranging 

over as much as 200 acres between hatch and fledging. Chicks fledge approximately 33 days post-hatch 

(Knopf 1996). 

Known predators of adult mountain plovers are few. Kit fox (Vulpes macrotis) and prairie falcon (Falco 

mexicanus) are the only documented predators of adults. However, their ground nests are vulnerable to 

mammalian predators including the thirteen-lined ground squirrel (Spermophilus tridecemlineatus), swift fox, 

badger, and coyote, and possibly corvids (crows, ravens and magpies). Ground squirrels, coyotes, Swainson’s 

hawks (Buteo swainsonii), prairie falcons, and loggerhead shrikes (Lanius ludovicianus) have been observed 

taking flightless young (Knopf 1996). 

Population Dynamics 

Species in the shorebird family are generally long-lived, with low annual reproductive rates and small clutch 

sizes. Available information on the mountain plover conforms to this pattern. Annual survival estimates for 

this species are unavailable, though over-winter survival is high, estimated at 0.9474 from a sample of 44 birds 

(Knopf 1996). Few data exist on the life span of the mountain plover, though one banded bird was recovered 

after 6 years. 

Mountain plovers probably start breeding in their second year of life. Normal clutch size is 3, very rarely 4. 

Two-egg clutches probably result from predation of individual eggs. Birds are largely monogamous, though the 

pair bond is only maintained for a short period during breeding. There is some evidence that at least some 

females lay two clutches, one brooded by the male and the other by the female, a reproductive strategy not 

uncommon among the shorebirds (Knopf 1996). 

Nest success has been estimated to vary from 26-65% between years and may be influenced by rainfall. 

Mountain plovers in Weld County, Colorado fledged an estimated 0.26 and 1.4 young per nest in different 

studies between 1969 and 1974, though the higher estimate is believed to be biased by the exclusion of nests 

which totally failed (Knopf 1996). 

Status and Distribution 

Historically, the mountain plover was considered numerous on breeding grounds in western and central Kansas 

and Oklahoma, western Nebraska and South Dakota, and eastern Colorado, Montana, and Wyoming. The 

eastern extent of the range has been greatly reduced, possibly due to conversion of native prairie to cultivated 

agriculture as well as control of burrowing rodents. Mountain plovers are no longer known to breed in Canada 

or South Dakota. 

Approximately 1,500 birds are estimated to occur in Wyoming. Birds have been observed during the breeding 

season over much of the shortgrass prairie of the eastern parts of the State, with high densities reported in the 

Laramie Plains of northern Albany County and eastern Carbon County (Laun 1957, WEST, Inc. 1998), 

Converse County (Parrish 1989), Laramie County (Graul 1975), and Park County (BLM 1988). 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 9 

Available data indicate that population numbers of mountain plovers have declined range-wide by more than 

50 percent since 1966 to fewer than 10,000 birds. Identified or suspected reasons for decline include 

conversion of shortgrass and shrub steppe habitats, changes in range management to emphasize uniform grass 

cover, declines in native ungulates and burrowing animals, and possibly population sinks created by certain 

agricultural practices. A population ‘sink’ (Pulliam 1988) is an area within the breeding range of a species or 

population where reproduction is not adequate to balance mortality, but population levels are maintained by 

immigration of breeders produced in a nearby ‘source’ area. 

Analysis of the Species Likely to Be Affected 

The mountain plover is known to breed in the analysis area. The proposal to list the species (64 FR 7587) 

describes the possible adverse effects of oil and gas development within the breeding range of the species, and 

identifies the possibility of take of mountain plovers from a number of activities included in the proposed 

action. Therefore, the Service concurs with BLM’s determination that the proposed action is likely to 

adversely affect the species. 

Environmental Baseline 

LISTED SPECIES 

Black-footed Ferret 

Status of the Species within the Action Area 

Wyoming is relatively unique in the coterminous United States in retaining vegetation and wildlife 

communities largely unchanged from pre-settlement times (Knight 1994). Extensive areas of sage-brush 

steppe still occur across the southern portion of the State, home to large white-tailed prairie dog towns and 

complexes. Some of these are large enough, according to the best currently available information, to maintain 

one or more extant populations of black-footed ferrets. The area roughly bounded by Rawlins, Wyoming west 

to Kemmerer, Wyoming and south to the Wyoming border holds the highest potential within the historical 

range of the species for such a discovery (R. Luce, pers. comm., December 1999). 

The analysis area is within this region of abundant white-tailed prairie dogs and relatively little human 

activity. Map 3.11 in the draft EIS (Appendix 1, this document) identifies 1-square-mile areas in the analysis 

area with current and historical records of prairie dog towns, illustrating the possibility of potential 

black-footed ferret habitat occurring in the analysis area. However, information used to develop this map is 

neither current enough or of a large enough scale to allow an accurate assessment of suitable black-footed 

ferret habitat. 

The BA provides the following records of ferret sightings in the analysis area (certainty unknown): two 

juvenile ferrets seen 5 miles south of I-80 in the central portion of the analysis area, July 1972; one ferret 

observed in the northern portion of the analysis area in 1975; and a partially buried, weathered ferret skull 

found on the northeastern edge of the analysis area, August 1981 (T22,R93, S33,NWNW). In addition, 14 

sightings of varying certainty have been recorded on or within 10 km of the analysis area between 1969 and 

1989: T22, R97, S26 on August 14, 1975; T23, R101,S18 on June 28, 1976, and T19, R100,S5 on November 

12, 1981 (WGFD WOS 1998); T18, R93,S21, in 1969; 10 miles west of Rawlins near UPRR tracks in 1971; 

T17, R95,S30 in September 1985; T17, R99,S2 in September 1974; T18, R93,S14 in August 1989; T18, R95 

in July 1985; T19, R94 in the summer of 1977 or 78; T19, R96,S17 in September 1985; T19, R97,S7 in July 

1983; T23, R98 in May 1983; and T24, R93,S15 in 1984 (Kinter and Martin 1992). 

While some black-footed ferret surveys have been conducted in this area (Cerovski et al. 1992), there has 

been little coordinated, large-scale mapping of prairie dog complexes and no complexes have been cleared of 

ferrets in accordance with the Ferret Guidelines. Therefore, according to the best available information, the 

presence of an undiscovered ferret population in this area cannot be ruled out. 

Factors Affecting the Species within the Action Area 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 10 

The EIS describes the existing condition of oil and gas development within the action area. Current 

development includes approximately 720 authorized, active, or un-reclaimed well locations, 1,800 miles of oil 

and gas field roads, 280 miles of un-reclaimed pipelines, several gravel pits, pumping stations, and staging 

areas, totaling approximately 18,400 acres on Federal, State, and private surface. No estimate is available of 

the amount of prairie dog towns disturbed by the existing developments. However, approximately half of the 

analysis area is on Federal surface, and BLM has a long-standing policy to avoid disturbance in prairie dog 

towns where possible. Therefore, it is possible that at least half of this development has not disturbed prairie 

dog towns to a significant degree. 

Development unrelated to oil and gas development includes county, State and Federal highways (2,300 

acres), railroads (1,100 acres), and residential and urban development, cultivated areas, utility lines and other 

non-project development (1,800 acres), totaling 5,200 acres. It is unclear how much of this development has 

disturbed prairie dog towns. 

PROPOSED SPECIES 

Mountain Plover 

Status of the Species within the Action Area 

Areas meeting our current understanding of suitable breeding habitat for the mountain plover, consisting of 

areas of short vegetation, bare soil, and level or gently rolling topography, are widely distributed in the 

analysis area. Virtually none of this area has received coordinated surveys for the species, however. Research 

from Colorado (Graul 1975) and Utah (Ellison 1998) suggests that the occurrence of breeding plovers may be 

distributed more in relation to other breeding plovers (aggregation of nest sites), rather than apparently suitable 

habitat. This suggests that either research has not yet adequately described suitable habitat, or the species is 

not currently limited by the availability of suitable habitat but is tied to historically used breeding areas. 

Combined with known high site fidelity, this suggests that these historically used nest site aggregations may 

be an important unit of conservation. 

There are 10 observations of mountain plovers within the analysis area from the breeding season and an 

additional 23 observations within 20 miles of the analysis area (Appendix 2). There has been no organized 

survey effort for the species other than Breeding Bird Survey (BBS), a general survey for all breeding species. 

The Wamsutter BBS route, the only one entirely within the analysis area, has not recorded the species. 

Factors Affecting the Species with in the Action Area 

The EIS describes the existing condition of oil and gas development within the action area. Current 

development includes approximately 720 authorized, active, or un-reclaimed well locations, 1,800 miles of oil 

and gas field roads, 280 miles of un-reclaimed pipelines, several gravel pits, pumping stations, and staging 

areas, totaling approximately 18,400 acres on Federal, State, and private surface. No data exist on the extent 

to which this development may have affected breeding mountain plovers or historically used breeding 

concentration areas. 

Development unrelated to oil and gas development includes county, State and Federal highways (2,300 

acres), railroads (1,100 acres), and residential and urban development, cultivated areas, utility lines and other 

non-project development (1,800 acres), totaling 5,200 acres. Again, it is unclear if or to what extent this 

development has disturbed breeding mountain plovers or historically used breeding concentration areas. 

Effects of the Action 

LISTED SPECIES 

Black-footed Ferret 

Activities associated with exploration and development of gas reserves may not be entirely incompatible with 

the continued existence of a black-footed ferret population. At Meeteetse, Wyoming, a producing field 

coexisted with the ferret population there since 1948 with no evidence that production activities caused any 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 11 

losses of ferrets (Forrest et al. 1985). However, no information is available to determine if the original 

development of the field adversely affected the ferrets at Meeteetse. There are many aspects of field 

development, operation, reclamation and abandonment that, if not properly regulated, could lead to 

unnecessary harm or even lethal take of individuals that may be present, in violation of section 9 of the Act. 

The Service believes that because of the dependence of the ferret on the prairie dog, any development which 

disturbs a prairie dog town constituting suitable ferret habitat may adversely affect the black-footed ferret 

unless surveys are completed and find no ferrets within the town prior to ground-disturbing activities. 

A significant mitigating feature of the project is the dispersed nature of proposed disturbance. Given that 

average project-related disturbance is estimated at 3.6 acres per well location (including necessary roads and 

pipelines but not ancillary facilities; draft EIS, Table 2.1) and the proposed level of development is 4 well 

locations per section, impacts will be dispersed (no more than 2.25% of any section disturbed). Because of 

this, destruction or degradation of an individual ferret’s habitat through development would rarely be intensive 

enough to cause death, though may be intense enough to cause injury. 

Exploration: Geophysical exploration involving shot-hole or surface shot techniques may destroy vegetation 

and disturb prairie dogs and ferrets. In using the shot-hole method, some vegetation is crushed in lanes 10-12 

feet wide and hundreds of yards long over a grid pattern. Drilling shot- holes may destroy vegetation and 

prairie dog burrows. Detonation of explosives within the holes causes vibrations and excessive noise that may 

destroy burrows or disturb ferrets sufficiently that they leave the area. Surface shot techniques are similar 

except that explosives are detonated on the surface, exacerbating the impacts of vibration and noise on burrow 

systems and ferrets. 

Development: When conducted in suitable ferret habitat, any ground disturbing activities may result in 

mortality to black-footed ferrets due to soil compaction or excavation. In addition, activities described below 

may produce direct and indirect impacts to ferrets. Increased traffic could result in direct take of ferrets 

through vehicle collisions and noise and activity may displace ferrets. Increased human activities may promote 

the transmission of distemper or sylvatic plague carried by employees’ pets. 

Access to the well pad will require construction of roads using standard techniques. In active prairie dog towns 

constituting suitable ferret habitat, direct take of black-footed ferrets may result due to soil compaction and 

earth-moving activities if occupied by ferrets. Loss of suitable ferret habitat may result from the destruction of 

prairie dog burrows within the road right-of-way (ROW), an approximately 42-52 feet wide disturbance area. 

Increased traffic is expected. Indirect effects to ferrets could result from alteration of surface drainage and 

flooding burrows. Finally, roads will allow increased recreational activity including prairie dog shooting, 

which may reduce prey availability, and increased likelihood of introducing diseases such as sylvatic plague 

and distemper. Pipeline construction differs from road construction in having very short-term impacts to 

habitat, and not resulting in increased traffic. However, direct take due to soil compaction and earth-moving 

activities in occupied suitable ferret habitat is still a possibility. 

Well pad construction requires creation of a level pad and excavation of a reserve pit to hold drilling fluids, 

using earth-moving equipment. The process takes about 2 days per pad. In occupied suitable ferret habitat this 

may result direct take as well as initial loss of approximately 1.8 acres of ferret habitat per pad, prior to partial 

reclamation to approximately 0.8 acres of disturbance. Indirect impacts would involve increased traffic (up to 

20 trips per day at each pad), noise and human activity during the construction period. Alteration of surface 

drainage may flood burrows. 

Drilling operations require the installation and operation of a drilling rig on-site, requiring 3 crews of 7 working 

around the clock for approximately 20 days. This level of activity is likely to displace ferrets some distance 

from the pad, making additional prairie dog habitat unsuitable for some distance around the drill rig. 

Displacing females during the early breeding season could cause reproductive failure due to abandonment of 

kits, or increased exposure to predators while moving the litter. Traffic and its associated risks will increase 

during drilling. Completion and testing operations, and installation of production facilities involve no new 

surface disturbance, but would require human activity and traffic for an additional 15 days. 

Construction of ancillary facilities, including compressor stations, processing plants, evaporation ponds, and 

wells, will involve varying amounts of surface disturbance, which, if carried out in prairie dog towns, may 

result in mortality or disturbance to black-footed ferrets. Permanent structures that provide perch or nest sites 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 12 

for avian predators or den sites for terrestrial predators (e.g., buildings, tanks, and power poles) may indirectly 

increase the incidence of predation on black-footed ferrets. 

Operation: Though traffic will greatly decrease after initial construction, operating wells will still require 

periodic maintenance and visits to remove produced condensate, maintaining low levels of impact associated 

with traffic and human activity. Elevated structures on the well pad, especially condensate tanks, will provide 

new nest and perch sites for birds of prey, including ferruginous hawks, golden eagles, and great horned owls. 

Presence of these known or suspected predators of black-footed ferrets will increase the likelihood of ferret 

mortality. Work-over of producing wells will occasionally produce levels of traffic, noise, and human 

activities that could lead to direct take of ferrets or displacement from the vicinity of the well pad. Use of the 

new road system by recreationists will increase traffic and human activity. 

Abandonment and Reclamation: Reclamation of drill pads, roads, and pipelines will involve a small increase 

in traffic, noise, and human activity from operation-level activities, possibly leading to direct take as well as 

disturbance and displacement of ferrets in the area. Final reclamation of well pads will increase activity and 

disturbance to ferrets around the pad. Placement of a marker to identify plugged wells may provide a 

permanent hunting perch for avian predators, increasing mortality risk to black-footed ferrets. 

Inter-related and Inter-dependent Effects: The highly interspersed checkerboard ownership on the analysis area 

creates many challenges for protection of black-footed ferrets and their habitat. There will be many actions on 

non-Federal surface that would not occur but for a Federal action (i.e., they are inter-related or inter-dependent 

to the Federal action). ROW’s for access to non- Federal inholdings will be a common Federal action leading 

to inter-related and inter-dependent actions on non-Federal lands. Where a Federal action or its inter-related 

or inter-dependent actions will lead to any of the effects described above on the non-Federal lands, the BLM 

will be responsible for additional assessment of such impacts to black-footed ferrets once site-specific 

information becomes available. The BLM has acknowledged this responsibility in their informational 

memorandum of February 23, 1999 (Appendix 3). 

PROPOSED SPECIES 

Mountain Plover 

Disturbance leading to loss of reproductive potential may occur in several ways. Different effects to nesting 

plovers are likely depending on the onset, duration, and frequency of human disturbance. Aside from direct 

take of nests, chicks, and adults through vehicle collision, human disturbance may cause direct loss of eggs or 

chicks if attending mountain plover adults are displaced long enough to expose the eggs or chicks to excessive 

heating, chilling, or risk of predation. 

If disturbance occurs more frequently than weekly through the breeding season, nesting birds may be displaced 

and may initiate nests a secure distance from the disturbed area. While this may reduce the amount of nest 

failure from disturbance, it may nonetheless result in reduced plover reproduction if plovers are displaced to 

less suitable nesting areas. Indeed, significant amounts of previously occupied habitat may be made 

unavailable in this way. Preliminary data from the Foote Creek Rim suggest that breeding plovers may be 

displaced from areas of high human activity (WEST, Inc. 1999). If nesting birds are displaced to nest in less 

suitable habitat where nesting success is lower, this would result in lost breeding potential. 

If disturbance begins after the onset of nesting or occurs at intervals greater than 2 weeks apart, birds may 

have already initiated nesting within the disturbance area. Then, human activity causing displacement of 

incubating adults from active nests may result in addling eggs due to extremes of temperature or destruction of 

eggs by predators. During incubation, the mountain plover is fairly insensitive to human disturbance from 

vehicles as close as 3 meters but may be displaced from the nest by a human on foot at a much greater 

distance. Eggs or newly hatched chicks may also be crushed by vehicle traffic at any speed. 

Human disturbance is especially problematic where human activity has created disturbed areas attractive to 

nesting mountain plovers. In Utah, mountain plovers have been found to nest as close as 6 m from open roads 

or operating oil well pads (Ellison et al. 1999), presumably attracted by the abundance of bare soil. Creation 

of apparently suitable habitat with high levels of human disturbance may actually attract breeding plovers to 

an ‘ecological trap’ (Pulliam 1988) where nests are initiated but fail due to disturbance and reproductive effort 

is wasted. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 13 

Mountain plovers are known to lead broods onto roads to forage at night (Laun 1957, Ellison et al. 1999). 

Direct loss of chicks or even adults to vehicle collisions may increase where increasing traffic volumes or 

travel speeds correspond with concentrations of nesting and brood-rearing activity. 

In addition to activities that may lead to direct mortality of adults or young, and reduce production, several 

factors may lead to indirect mortality. The eggs and young, and to a lesser extent adults, are susceptible to a 

number of avian and mammalian predators. These include corvids (ravens, magpies, crows), birds of prey 

(hawks and owls), coyotes, badgers, weasels, and foxes. These predators may benefit from human activities in 

a number of ways. Power poles, fence posts, condensate tanks, and other elevated structures may provide new 

hunting perches and nest sites for avian predators, increasing their hunting effectiveness and range. Buildings, 

trailers, and other permanent structures may provide safe den sites for mammalian predators. Research on the 

more well-studied sage grouse (Centrocercus urophasianus) has demonstrated that birds avoid elevated perch 

sites, including powerlines and fence posts by as much as _ mile (Braun 1998). Mountain plover adults, 

chicks, and eggs live in the same environment and suffer the same predators, therefore these structures may 

adversely affect their habitat and behavior similarly. 

Finally, an increase in road-killed animals due to more roads, heavier traffic, and higher travel speeds may 

provide a new food supply for both avian and mammalian predators, most of which are also scavengers. This 

new food source may increase predator population size and may also extend their range into previously 

uninhabited areas, leading to higher rates of predation on mountain plover eggs, chicks, and even adults. Such 

an ecological relationship has been demonstrated in the Mojave Desert of California. Increases in roads and 

traffic have extended the range of avian predators (common raven and red-tailed hawk) exposing young desert 

tortoises (Gopherus agassizii) to much higher rates of predation than before development (Knight et al. 1993, 

Knight and Kawashima 1993). 

Mountain plovers show high site fidelity to breeding territories between years and the persistence of breeding 

concentrations may be more important than mere availability of apparently suitable habitat for the persistence 

of the mountain plover. The necessity of social facilitation for effective breeding has been demonstrated in a 

number of avian species. Habitat degradation occurring outside of the breeding season may cause take in the 

form of harm by causing abandonment of historically used breeding areas, though no direct take of plovers, 

eggs, or chicks occurs. Harm would result if removal or degradation of nesting habitat on historically used 

sites resulted in loss of breeding capability upon the birds’ return, and/or resulted in loss of the pair for lack of 

available feeding or nesting habitat. Development activities, including construction of roads, well pads, and 

ancillary facilities that degrade habitat in historically used breeding areas could have this effect, whether or 

not they occur during the breeding season. Human activity associated with project development and operation 

in historically used breeding areas may harass nesting birds enough to cause them to abandon the breeding 

area, particularly if disturbance extends over more than one breeding season. Again, this could constitute take. 

The key issue is whether or not birds displaced by project activities will move to new areas and successfully 

breed. Currently, information is inadequate to answer this question. While unoccupied areas meeting our 

understanding of suitable habitat exist, this could mean either that science has not accurately described 

suitable plover breeding habitat and these areas are not actually suitable, or that they are suitable and the 

mountain plover is currently not limited by availability of breeding habitat. Until the question is resolved the 

prudent management approach must be to identify and protect all breeding concentrations of the species. 

Specific phases of gas development and the specific activities that may cause take are outlined below. 

Exploration: Seismic survey work during the breeding season has the potential to cause direct take of adults, 

eggs, or chicks through vehicle collision or crushing. Increased human activity in the area may cause take of 

chicks or eggs through displacement of attendant adults. 

Development: Given BLM’s existing commitment to implement the Service’s Mountain Plover Survey 

Guidelines (1999; Appendix 4, hereafter ‘Plover Guidelines’) and re-schedule work to avoid the breeding 

season if any mountain plover nests or broods are found, the likelihood of ground-disturbing activities, 

including construction of roads, well pads, pipelines, ancillary facilities, causing direct lethal take of plovers 

is discountable. However, increased traffic to and from construction sites may cause direct take through 

collisions with vehicles, and indirectly cause take by increasing predator numbers (by providing road-killed 

animals), thereby possibly increasing predation on adults, eggs, or chicks. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 14 

Drilling operations require the installation and operation of a drilling rig on-site, requiring 3 crews of 7 working 

around the clock for approximately 20 days. This level of activity is likely to displace breeding mountain 

plovers some distance from the pad, making additional nesting habitat unsuitable for some distance around the 

drill rig, and may constitute harassment. Traffic and risks of vehicle collision will greatly increase during 

drilling. Any of these factors that incrementally reduce the habitat quality leading to abandonment of a 

previously used breeding area may constitute take in the form of harm. 

Operation: Though traffic will greatly decrease after construction, operating wells will still require periodic 

maintenance and visits to remove produced condensate, thereby maintaining low levels of impact associated 

with traffic and human activity. Elevated structures on the well pad, especially condensate tanks, will provide 

new nest and perch sites for corvids (i.e., common raven and black-billed magpie) and birds of prey, including 

ferruginous hawks, golden eagles, great horned owls, and loggerhead shrikes. Presence of these known or 

suspected predators of mountain plovers and their eggs and chicks will increase the likelihood of mortality. 

Work-over of producing wells during the breeding season will occasionally produce levels of traffic, noise, and 

human activities that could lead to direct take of mountain plovers or displacement from the vicinity of the 

well pad. Recreational use of the new road system will cause increased disturbance and risk of vehicle 

collisions. 

Permanent structures that provide perch or nest sites for avian predators or den sites for terrestrial predators 

(e.g., buildings, tanks, and power poles) will indirectly increase the incidence of predation on mountain 

plovers. Any of these factors that incrementally reduce the habitat quality leading to abandonment of a 

previously used breeding area would constitute take in the form of harm. 

Abandonment and Reclamation: Reclamation of drill pads, roads, and pipelines will involve a small increase 

in traffic, noise, and human activity from operation-level activities, possibly leading to take as well as 

disturbance and displacement of nesting plovers in the area. Reclamation activities initiated during the 

breeding season, unless meeting BLM’s survey requirements, may crush eggs or chicks or lead to nest failure 

by displacing attendant adults. Placement of a marker to identify plugged wells may provide a permanent 

hunting perch for avian predators, increasing mortality risk to mountain plovers or displacing breeding birds 

from suitable habitat. Reclamation with plant species that produce a long-lasting stand of tall, dense 

vegetation will preclude nesting by mountain plovers as long as that vegetation persists. 

Inter-related and Inter-dependent Effects: The highly interspersed checkerboard ownership on the analysis 

area creates the same challenges for protection of mountain plovers as for black- footed ferrets. Much of the 

discussion of inter-related and inter-dependent actions and their impacts on black-footed ferrets applies here. 

Development actions on non-Federal lands occurring as a result of a BLM action would have the same effects 

on nesting plovers or historically used breeding areas as such development will have on Federal surface, 

described above. To the extent that these actions are inter-related or inter-dependent to a Federal action, any 

effects to mountain plovers on non-Federal surface must be considered prior to permit issuance or other 

authorization by BLM. 

Finally, activities occurring on Federal surface near boundaries with non-Federal surface may displace plovers 

nesting on adjacent non-Federal surface. Activities on non-Federal surface, including construction activities 

during the breeding season may cause direct take of eggs or newly-hatched chicks by displacing adults; 

construction, by enhancing predator habitat, may indirectly cause take, and construction, operation, or 

reclamation may cause abandonment of previously occupied breeding areas, constituting take in the form of 

harm. 

Cumulative Effects 

Cumulative effects include the effects of future State, tribal, local or non-Federal actions that are reasonably 

certain to occur in the action area considered in this biological and conference opinion. Future Federal 

actions that are unrelated to the proposed action are not considered in this section because they require 

separate consultation pursuant to section 7 of the Act. 

The cumulative effects of the proposed project are difficult to quantify for several reasons. Because half of 

the analysis area is State and private surface, as many as 1,500 well pads, 750 miles of new or improved 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 15 

roads, and 750 miles of pipelines are reasonably certain to occur on State or private surface. However, many 

of the gas development activities on non-Federal land will require grants of ROW from the BLM for access 

and are therefore inter-related and inter- dependent to the ROW grants. The ROW grants and inter-related and 

inter-dependent actions constitute Federal actions subject to review under section 7 of the Act and therefore 

are not considered under cumulative effects. 

Some amount of non-Federal land will be developed through county and State roads with no future Federal 

action, and therefore constitute cumulative effects. No analysis has yet quantified the extent of possible 

development on non-Federal lands where access is now available, and any such analysis would be 

labor-intensive and somewhat speculative. However, every other section is under Federal ownership and 

access to non-Federal surface will usually require a Federal action (i.e., ROW permit), therefore the amount of 

development requiring no future Federal oversight (i.e., cumulative effects) will be small relative to the 

overall project. 

Finally, the data presented are not adequate to determine the distribution and abundance of the black-footed 

ferret or mountain plover on State and private lands in the analysis area. Likewise, there are no accurate 

estimates of suitable habitat for these species on State and private lands, though such habitat may occur in the 

analysis area. For this reason, the extent of cumulative effects to the species is difficult to quantify. However, 

because of the relatively small number of actions involving no future Federal nexus, the Service believes that 

cumulative effects to the black-footed ferret or mountain plover are likely to be small. Therefore, for purposes 

of this analysis, we assume that cumulative effects comprise a small number of gas development activities on 

State and private lands. 

Conclusion 

LISTED SPECIES 

After reviewing the current status of the black-footed ferret, the environmental baseline for the action area, the 

effects of the proposed gas development, and the cumulative effects from oil and gas wells and associated 

facilities, roads, railroads, livestock grazing, and towns, it is the Service’s biological opinion that the 

Continental Divide/Wamsutter II Natural Gas project, as proposed, is not likely to jeopardize the continued 

existence of the black-footed ferret. No critical habitat has been designated for this species, therefore, none 

will be affected. 

No wild, non-reintroduced populations of black-footed ferrets are currently known, therefore the recovery of the 

black-footed ferret is now assumed to be entirely dependent on the captive breeding program and the resulting 

re-introduced populations. Because of the extremely low number of founders in the captive breeding program, 

any addition of new genetic material would appreciably increase the recovery potential of the species. 

Therefore, loss of a previously undocumented ferret population to provide this new genetic material would 

significantly decrease the chances for this species’ survival and recovery. Given the short life-span of ferrets 

and their dependence on continued recruitment to maintain a population, it is likely that any black-footed 

ferret found would be part of a remnant population. Moreover, while loss of such a population would 

jeopardize the species, loss of one individual would not. 

A large portion of the analysis area now contains prairie dog towns, some of which may provide suitable ferret 

habitat. Black-footed ferrets and their remains have been observed on or near the analysis area in the past. 

However, there have been no recorded observations in the last 11 years, suggesting that if the species still 

occurs in the area, it occurs in low abundance or in particularly remote or un-surveyed portions of the analysis 

area. 

Proposed exploration and development of natural gas resources is not likely to have major, long- term effects 

to the existing ferret habitat on the analysis area. Only a small acreage of prairie dog towns is likely to be 

disturbed, and prairie dogs quickly recolonize disturbed areas. Furthermore, black-footed ferrets at Meeteetse 

coexisted with an operating oil field, suggesting that effects to ferrets from gas field operation are unlikely to 

jeopardize a population. However, if black-footed ferrets are on the analysis area, the likelihood that project 

development will directly cause the lethal take of a black-footed ferret cannot be discounted. The proposed 

project may harm or harass black-footed ferrets if occupied ferret habitat is disturbed. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 16 

The cumulative effects of the project involve a relatively small but unquantified number of actions occurring 

on non-Federal land where legal access currently exists. The effects of these actions will be similar to those 

on Federal land, but there will be far fewer of them. 

Based on the status of the species, environmental baseline on the analysis area, effects of the action, and 

cumulative effects, we conclude that the project, as described, may lead to some disturbance of individuals 

and a chance for lethal take. However, these effects will not rise to the level of jeopardizing the continued 

existence of the species. 

PROPOSED SPECIES 

After reviewing the current status of the mountain plover, the environmental baseline for the action area, the 

effects of the proposed project and the cumulative effects, it is the Service’s conference opinion that the 

Continental Divide/Wamsutter II Natural Gas project, as proposed, is not likely to jeopardize the continued 

existence of the proposed mountain plover. No critical habitat has been proposed for this species, therefore 

none will be affected. 

Range-wide, population numbers of mountain plovers are believed to have declined to fewer than 10,000 birds. 

An estimated 1,500 mountain plovers, or about 15% of the total population, breed in Wyoming. This estimate 

in Wyoming is based predominantly on counts from known breeding concentrations outside of the analysis 

area. 

None of Wyoming’s documented mountain plover concentration areas are contained in the analysis area, 

though individual birds have been observed during the breeding season. This suggests that the project is 

unlikely to affect a large portion of the population in Wyoming or range-wide. 

The effects of gas development on breeding mountain plovers are not known. Some lethal take of the species 

may occur on the analysis area as breeding birds are displaced from eggs or newly- hatched chicks, through 

vehicle collision, or as a result of increased predation. While the proposed project will affect areas of suitable 

habitat and may affect occupied habitat, nowhere will development be intensive. Therefore, effects to the 

plover are not expected to be severe. 

Cumulative effects to the mountain plover involve the small number of projects without Federal oversight on 

the analysis area. Furthermore, individual actions will have only a local effect, adversely affecting a few 

breeding plovers at most. Coupled with the apparent low abundance of the species, the cumulative effects of 

this small number of these projects on the mountain plover will likely affect a fraction of a percent of the 

entire population. 

Based on the known distribution of the species, the probable effects of gas development on breeding plovers 

from the proposed action, and the small amount of cumulative effects on the analysis area, the project is likely 

to cause some lethal take, but will not be extensive enough to jeopardize the species. 

INCIDENTAL TAKE STATEMENT 

Introduction 

Section 9 of the Act and Federal regulation pursuant to section 4(d) of the Act prohibit the take of endangered 

and threatened species, respectively, without special exemption. Take is defined as to harass, harm, pursue, 

hunt, shoot, wound, kill trap, capture or collect, or to attempt to engage in any such conduct. Harm is further 

defined by the Service to include significant habitat modification or degradation that results in death or injury 

to listed species by significantly impairing essential behavioral patterns, including breeding, feeding, or 

sheltering. Harass is defined by the Service as intentional or negligent actions that create the likelihood of 

injury to listed species to such an extent as to significantly disrupt normal behavior patterns which include, but 

are not limited to, breeding, feeding or sheltering. Incidental take is defined as take that is incidental to, and 

not the purpose of, the carrying out of an otherwise lawful activity. Under the terms of section 7(b)(4) and 

section 7(o)(2), taking that is incidental to and not intended as part of the agency action is not considered to 

be prohibited taking under the Act provided that such taking is in compliance with the terms and conditions of 

this Incidental Take Statement. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 17 

The measures described below are non-discretionary, and must be undertaken by the Bureau of Land 

Management so that they become binding conditions of any grant or permit issued to the operators, as 

appropriate, for the exemption in section 7(o)(2) to apply. The Bureau has a continuing duty to regulate the 

activity covered by this incidental take statement. If the Bureau (1) fails to assume and implement the terms 

and conditions or (2) fails to require the applicant to adhere to the terms and conditions of the incidental take 

statement through enforceable terms that are added to resulting permit or grant documents, the protective 

coverage of section 7(o)(2) may lapse. In order to monitor the impact of incidental take, the Bureau must 

report the progress of the action and its impact on the species to the Service as specified in the incidental take 

statement. [50 CFR 402.14(i)(3)]. 

Amount or extent of take anticipated 

LISTED SPECIES 

Direct mortality of ferrets could result from vehicle collision due to increased traffic and new roads, or 

destruction of occupied dens during any ground-disturbing activities in occupied habitat. Indirect mortality 

could result from introduction of canine distemper or enhancement of predator habitat (e.g., creation of new 

perch or nest sites). Therefore, direct lethal take during the life of the project is anticipated. 

No up-to-date information is available on the current status of the species or the extent of suitable habitat on 

the analysis area. Furthermore, actual site-specific details of development activities are not part of the project 

description. Given this lack of information, it is impossible to determine the extent to which development 

activities may cause direct lethal take, therefore the amount of direct lethal take cannot be quantified at this 

time. Rather, direct lethal take will be quantified on an individual project-specific basis once BLM has 

identified specific projects proposed for occupied black-footed ferret habitat. 

Take in the form of harm due to degradation of occupied habitat or harassment due to human activities in 

occupied habitat may occur during the life-of-project. Take in the form of harm could result from any 

construction activity that reduces the abundance of prairie dogs in occupied habitat, even if reductions are 

only temporary. Take in the form of harassment could result from any human activities associated with 

construction, operation, or reclamation that disturb black- footed ferrets enough to displace them from their 

home range. Though the proposed project, as described, outlines measures to avoid ferret habitat (i.e., prairie 

dog towns), and requires surveys for ferrets where avoidance is not possible, the possibility of harm or 

harassment to black-footed ferrets remains if occupied habitat must be disturbed. Therefore, incidental take in 

the form of harm or harassment due to disturbance of occupied, suitable black-footed ferret habitat is 

anticipated. 

Given the limited information available on suitable ferret habitat on the analysis area, a worst case scenario of 

habitat impacts (i.e., take in the form of ‘harm and harass’) can be developed. Available information on the 

distribution of black-footed ferret habitat on the analysis area is limited to present/absence by 1-square mile 

units (BLM 1999a, Map 3.11; also Appendix 1). This source shows that 324 sections may contain prairie dog 

towns. Lacking site-specific information on project impacts, a reasonable worst-case estimate of harm and 

harassment must assume that the entire surface of these 324 sections contains suitable ferret habitat and each 

of the 324 sections will be developed. Given that average project-related disturbance is estimated at 3.6 acres 

per well location (including necessary roads and pipelines but not ancillary facilities; draft EIS, Table 2.1) and 

the proposed level of development is 4 well locations per section, a maximum of 4,666 acres of potentially 

suitable black-footed ferret habitat could be disturbed. Because impacts will be dispersed (no more than 

2.25% of any section disturbed), destruction or degradation an individual ferret’s habitat would rarely be 

intensive enough to cause death, though injury would still be likely. 

More accurate and up-to-date mapping of suitable ferret habitat will likely find less of the 4,666 acres actually 

provide suitable habitat, thereby reducing the probability of realizing this worst-case scenario. Measures in the 

BA and described in the proposed project, designed to avoid of suitable habitat, will likely further decrease the 

amount of suitable habitat disturbed. Finally, disturbance of suitable habitat that is found, through adequate 

ferret survey effort, to support no population of black-footed ferrets will not harm or harass black-footed ferrets. 

Based on these facts, while it is likely that some incidental take in the form of harm or harassment will occur, 

an accurate estimate of the amount of habitat degradation causing harm or human activities causing 

harassment cannot be quantified at this time. Rather, take in the form of harm or harassment will be 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 18 

quantified on an individual project-specific basis once BLM has identified specific projects proposed for 

occupied black-footed ferret habitat. 

A goal of this incidental take statement is to develop methods to determine the extent of suitable ferret habitat 

on the analysis area, so that it will be possible to quantify the potential impacts of site-specific actions within 

identified areas of suitable habitat, determine the necessity of black- footed ferret surveys, quantify take, and 

identify necessary protective measures. 

PROPOSED SPECIES 

Direct lethal take of adult mountain plovers or chicks may occur through vehicle collision. The likelihood of 

vehicle collision is highest during development but remains elevated through operation and abandonment. 

Destruction of nests could result from vehicle traffic on an infrequent basis. Displacement of adults from nests 

or broods long enough to cause take of eggs or chicks through exposure to the elements or predators may 

occur, especially if people will be nearby on foot for many hours. 

Indirect lethal take, especially of eggs and chicks, may occur through increases in predator abundance due to 

project features providing increased perch and nest sites around plover nesting areas and new food sources in 

the form of carrion caused by vehicle collisions. 

The Service anticipates such lethal take of the mountain plover will be difficult to detect due to the cryptic 

nature of eggs and chicks, the dispersed nature of breeding birds, the lack of current distribution data on the 

analysis area, the rapidity with which carcasses are scavenged, and difficulty of measuring increased mortality 

of adults, eggs or chicks due to indirect project effects on predator abundance. 

Information on the distribution and abundance of the mountain plover on the analysis area is currently 

inadequate to determine the number of birds that may be affected by the proposed project. Furthermore, actual 

site-specific details of development activities are not provided in the project description. Given this lack of 

information, it is impossible to determine the extent to which development activities may cause lethal take, 

therefore the amount of direct lethal take cannot be quantified at this time. Rather, direct lethal take will be 

quantified on an individual project-specific basis once BLM has identified specific projects proposed for 

occupied mountain plover habitat. 

Displacement of breeding birds from known nesting areas to less suitable nesting habitat may occur due to 

habitat alteration (harm) and human activity (harassment) associated with project development and ongoing 

operation. Where development increases predator abundance or hunting efficiency, nesting plovers may be 

displaced to nest in less suitable habitat. Abandonment of previously occupied breeding aggregation areas due 

to habitat degradation may result. Loss of such a formerly used site would constitute take in the form of harm 

or harassment and must be anticipated. 

Data on the current distribution on and use of the analysis area by breeding mountain plovers are sparse and 

inadequate to reasonably estimate potential project impacts. Furthermore, actual site- specific details of 

development activities are not provided in the project description. Given this lack of information, it is 

impossible to determine the extent to which development activities may cause take through harm or 

harassment, therefore the amount of such take cannot be quantified at this time. Rather, harm and harassment 

will be quantified on an individual project-specific basis once BLM has identified specific projects proposed 

for occupied mountain plover habitat. 

Apparently suitable but unoccupied mountain plover habitat is distributed across the analysis area and 

therefore disturbance to suitable habitat is a poor indicator of the likelihood of direct lethal take and provides 

no measure of incidental take in the form of harm or harassment. Until surveys document the distribution of 

the species on the analysis area, suitable habitat may potentially harbor breeding mountain plovers. To begin 

to gather the data necessary to quantify the possible project impacts to breeding mountain plovers, this 

incidental take statement is designed to identify areas of suitable habitat and to promote surveys to determine 

use by nesting plovers. Once surveys have been conducted and if no mountain plovers are found, areas of 

apparently suitable but unoccupied habitat will receive no protection. Conversely, if the birds are found to use 

the area, potential impacts and the amount of incidental take can then be quantified. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 19 

Effect of the take 

In the accompanying biological and conference opinions, the Service determined that this level of anticipated 

take is not likely to result in jeopardy to the species. 

Reasonable and prudent measures 

LISTED SPECIES 

The distribution and abundance of the black-footed ferret on the analysis area remain unknown. Due to their 

extreme rarity and nocturnal, fossorial habits, observations will be difficult under the best of circumstances. 

The amount of suitable habitat is unknown at this time but suitable habitat likely occurs on the analysis area. 

Therefore, these reasonable and prudent measures and their implementing terms and conditions are designed 

to: 1) identify and quantify suitable habitat, 2) minimize disturbance of suitable habitat, 3) identify occupied 

habitat prior to disturbance, 4) minimize disturbance to occupied habitat when unavoidable, and 5) avoid or 

minimize take of any ferrets found to be present. 

The Service believes the following reasonable and prudent measures are necessary and appropriate to 

minimize take of the black-footed ferret. Due to the programmatic nature of this consultation, one or more of 

the following reasonable and prudent measures may be modified or waived by the Service based upon review 

of information on site-specific project activities. 

• BLM employees, Operators’ employees, and contractors shall be educated on the natural history of 

the black-footed ferret, identification of ferrets and their sign, activities that may affect ferret behavior 

and ways to minimize these effects. 

• Because domestic dogs may serve as a vector for canine distemper, BLM, Operators, and 

sub-contractors shall establish policies that no dogs will be on sites during working hours. 

• Observations of black-footed ferrets, their sign, or carcasses shall be promptly reported to the BLM, 

Rawlins or Rock Springs Field Offices and the Service, Wyoming Field Office. 

• To minimize possible direct take of black-footed ferrets, suitable ferret habitat (as defined in this 

biological opinion) must be mapped and activities in suitable habitat must be preceded by ferret 

surveys following the methods in Ferret Guidelines. 

• Should surveys or any incidental observations find black-footed ferrets or their sign within a prairie 

dog town or complex for which project-related activities are proposed, the BLM shall initiate section 

7 consultation with the Service on the proposed action. If any black- footed ferrets or their sign are 

found within a prairie dog town or complex previously determined to be unsuitable for, or free of, 

ferrets, all previously authorized project-related activities on-going in such towns or complexes shall 

be suspended immediately and section 7 consultation initiated with the Service. 

PROPOSED SPECIES 

The Service believes the following reasonable and prudent measures are necessary and appropriate to 

minimize take of the mountain plover. The prohibitions against taking the species found in section 9 of the 

Act do not apply unless the species is listed. However, the Service advises the BLM to consider 

implementing the following reasonable and prudent measures even prior to listing. If this conference opinion is 

adopted as a biological opinion following a listing or designation, these measures, with their implementing 

terms and conditions, will be nondiscretionary. Due to the programmatic nature of this consultation, any of the 

following reasonable and prudent measures may be modified or waived by the Service upon review of details 

of future site-specific project activities, should the mountain plover be listed. 

Protection of nesting and brood-rearing plovers should minimize the likelihood of take without unnecessarily 

inhibiting development activities on unoccupied sites. While there are several records of mountain plovers on 

the analysis area during the breeding season, there have been no systematic surveys to quantify their 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 20 

distribution and abundance there. Available natural history information shows that breeding plovers show high 

nest site fidelity between years. They also tend to nest in loose associations, or nesting aggregation areas, of 

densities as high as 80 nests per square mile over a few square miles, surrounded by apparently suitable but 

unoccupied habitat (Graul 1975). Therefore, a reasonable means of extending protection should involve 

identification of occupied habitat, including nesting aggregations where some protective restrictions on project 

activities shall apply while relaxing or waiving protective measures in areas where plovers have not been 

observed once surveys have been completed. Breeding aggregations are defined here as two or more 

observations, within 2 miles of each other during one breeding season, of one of the following: territorial 

adults, nests, adult distraction displays, or broods. This is consistent with spatial scale of breeding 

aggregations in Utah (Ellis 1998) and Colorado (Knopf 1996). 

The following reasonable and prudent measures are designed first to avoid direct impacts to nesting mountain 

plovers through activity-specific searches for nests, and second, to avoid or minimizing impacts to known 

nesting aggregations by 1) identifying aggregations on the analysis area prior to development, 2) avoiding or 

minimizing direct or indirect take of adults, eggs, or chicks on these areas, and 3) avoiding the abandonment 

of nesting aggregation areas. 

• Operators and BLM employees shall be shown how to identify the mountain plover and provided 

information about its habitat requirements, natural history, status, threats, and possible impacts of gas 

development activities. Incidental observation of mountain plovers shall be solicited from all field 

personnel. 

• No ground-disturbing activities shall occur in suitable breeding habitat during the breeding season 

prior to compliance with the Service’s Mountain Plover Survey Guidelines (Appendix 4), or other 

Service-approved survey method. 

• Use (or lack thereof) of areas of suitable habitat by breeding mountain plovers must be determined 

prior to site disturbance, regardless of the timing of disturbance. The Wildlife Protection Plan 

provides a useful mechanism to carry out broad-scale surveys for mountain plover breeding activity, 

focusing on areas of high development potential and historical sightings of plovers during the breeding 

season. Site-specific surveys as outlined in the Plover Guidelines are not necessary for this purpose. 

Broader scale, less intensive surveys should be done. While these will not locate every nest or brood, 

they will identify aggregations of plover breeding activity. 

• Once occupied habitat (including breeding aggregations) is located, the BLM shall initiate section 7 

consultation with the Service on any project-related activities proposed for such habitat, with the 

exception of geophysical exploration activities (i.e., use of shot-hole, surface shot, or vibro-seismic 

techniques) conducted outside the breeding season for plovers (April 10 to July 10). 

Terms and conditions 

LISTED SPECIES 

In order to be exempt from the prohibitions of section 9 of the Act, the BLM must comply with the following 

terms and conditions, which implement the reasonable and prudent measures described above and outline 

required reporting/monitoring requirements. These terms and conditions are non-discretionary. However, due 

to the programmatic nature of this consultation, any of the following terms and conditions may be modified or 

waived by the Service as a result of future details of site-specific project activities. 

Black-footed Ferret 

1) Operators and BLM shall be provided by the Service with fact sheets and these materials shall be posted in 

common areas and circulated in a memorandum among all employees and service providers. Fact sheets shall 

illustrate the black-footed ferret and its sign; describe morphology, tracks, scat, skull, habitat characteristics, 

behavior, current status, and causes of decline; and the relationship between gas field development and 

impacts to black-footed ferret, especially regarding canine distemper. 

2) BLM and Operators shall conduct educational outreach to employees regarding the nature, hosts, and 

symptoms of canine distemper, and its effects on black-footed ferrets, focusing attention on why employees 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 21 

should not have pets on work sites during or after hours. BLM shall require Operators to develop policies to 

prohibit dogs from operation sites during work hours. 

3) All suspected observations of black-footed ferrets, their sign, or carcasses on the analysis area, however 

obtained, shall be promptly reported to: 

Wildlife Biologists, BLM, 

Mary Read, (307) 328-4255 

Larry Apple, (307) 328-4204 

Rawlins Field Office 

P.O. Box 2407 

1300 North 3rd Street 

Rawlins, WY 82301 

Field Supervisor or Designee, U.S.F.W.S. 

(307) 772-2374 

Wyoming Field Office, 

4000 Airport Parkway, 

Cheyenne, WY 82001 

Wildlife Biologist, BLM, 

Jim Dunder, (307) 352-0315 

Rock Springs Field Office 

280 Highway 191 

Rock Springs, WY 82901 

Observations shall include a description including what was seen, time, date, exact location, and observer’s 

name, address, and telephone number. Carcasses or other suspected ferret remains shall be collected by BLM 

or Service employees and deposited with the Service, Wyoming Field Office. 

4) All prairie dog towns entirely or partially on the analysis area shall be mapped. Mapping may occur from 

aircraft. Surveys from aircraft must be followed by ground surveys when prairie dog town boundaries cannot be 

accurately determined from the aerial survey. It is essential that mapping occur over the entire analysis area, 

regardless of surface ownership. Then, the sizes of mapped towns and complexes shall be calculated to 

determine which towns/complexes are at least 1,000 acres in size. Finally, density of active burrows shall be 

estimated only on any towns or complexes found to exceed 1,000 acres to determine the extent of suitable 

black-footed ferret habitat. All steps shall follow the methodology of Biggins et al. (1993; Appendix 5) with 

the exception that the definition of suitable habitat and a complex shall be consistent with this biological 

opinion. 

By October 15, 2002, all prairie dog towns shall be mapped on the analysis area. Density estimation, where 

necessary (i.e., on those towns or complexes exceeding 1,000 acres), shall focus on the areas of highest 

potential gas development (approximately 1/3 of the analysis area) consisting of those townships entirely or 

partially east of the town of Red Desert. Additional thirds shall be covered by mapping and density estimation 

no later than the end of years 2001, and 2002 until completion. Methods and results of mapping and burrow 

density estimation completed in 2000 shall be provided with a report to the Service's Wyoming Field Office 

no later than October 15, 2000, with additional results provided annually on October 15, 2001, and 2002, until 

complete. 

Until mapping is completed over the entire analysis area, any prairie dog towns proposed for disturbance prior 

to inclusion in the mapping effort must be cleared consistent with the 1989 Black-footed Ferret Survey 

Guidelines. Burrow density of 8 burrows per acre and 200 acre areal extent of towns and complexes (as 

defined in the 1989 Ferret Guidelines) shall require surveys prior to disturbance, following the 1989 guidelines. 

Because these guidelines were developed to address section 7 compliance on a case-by-case basis they are 

more appropriate where towns have not yet been included in the area-wide mapping effort. 

5) No ground-disturbing activities may occur within 50 m of prairie dog towns prior to detailed mapping of the 

spatial extent of the town(s) to be affected in accordance with Term and Condition 5 of this biological opinion. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 22 

Existing prairie dog maps of the Wamsutter NEPA analysis area (Hayden-Wing 1995) may serve this purpose 

on an interim basis for calendar year 2000. Activities outside the Wamsutter analysis area but within the 

CD/WII analysis area in 2000 will require town-by-town mapping as project locations are identified. 

Because of the age of the data used and questions about the methodology used for the Hayden-Wing (1995) 

report, an adequate random sample of towns in the Wamsutter NEPA document shall be re-mapped and 

densities estimated using the Biggins et al. (1993) methods during the 2000 field season. If the existing maps 

are shown to provide area and active burrow density estimates within 10% of the re-survey, the Wamsutter 

maps may continue to serve for describing suitable ferret habitat, otherwise all towns in the Wamsutter NEPA 

analysis area shall be re-mapped and densities re-estimated using the new methodology. 

6) Once the town or towns to be affected has been mapped and suitable habitat identified, no ground-disturbing 

activities shall occur within suitable habitat until all identified suitable habitat within the affected town and 

that portion of any town or towns constituting suitable habitat within _ -mile of the project boundary has 

received a black-footed ferret survey, consistent with the 1989 Ferret Guidelines or other methods upon 

Service review and approval. Consistent with this document, no surveys will be required on towns or 

complexes that fail to meet the definition of suitable habitat provided in the Status of the Species section as 

long as they have been included in the area-wide mapping effort. Otherwise, the 1989 Ferret Survey 

Guidelines shall apply. 

Should surveys find no ferrets or sign, ground-disturbing activities may occur within 1 year of the date of 

survey completion within the town surveyed. However, surveys should be completed as close to the date of 

project initiation as possible to avoid the possibility of a ferret moving into the area after surveys have cleared 

the area. Alternatively, all suitable habitat within the entire complex in which the town is located may be 

surveyed and if no ferrets or sign are found the complex will be designated "ferret-free" and no further section 7 

review for the black-footed ferret will be required for activities occurring within any prairie dog town within the 

complex. Future observations of ferrets or their sign shall, however, require re-initiation of section 7 

consultation. 

Results of all surveys shall be reported to the Service's Wyoming Field Office, including maps of areas 

surveyed, surveyor qualifications, method of survey, length of survey, date, weather, snow cover, survey 

results, and copies of field data sheets. 

7) Should surveys or any incidental observations find black-footed ferrets or their sign within a prairie dog town 

or complex for which project-related activities are proposed, the BLM shall initiate section 7 consultation with 

the Service on the proposed action. If any black-footed ferrets or their sign are found within a prairie dog town 

or complex previously determined to be unsuitable for, or free of, ferrets, all previously authorized 

project-related activities on-going in such towns or complexes shall be suspended immediately and section 7 

consultation initiated with the Service. 

8) BLM, Wyoming Game and Fish Department, Operators, Service and any other involved parties shall meet 

annually to discuss progress, effectiveness, and any necessary modifications to these terms and conditions. 

Meetings shall be scheduled to coincide with annual meetings for the Wildlife Protection Plan, as described in 

Appendix D of the EIS. 

PROPOSED SPECIES 

The prohibitions against taking the species found in section 9 of the Act do not apply unless the species is 

listed. However, the Service advises the BLM to consider implementing the following terms and conditions 

even prior to listing. If this conference opinion is adopted as a biological opinion following a listing or 

designation, in order to be exempt from the prohibitions of section 9 of the Act, the BLM must comply with 

the following terms and conditions, which implement the reasonable and prudent measures described above 

and outline required reporting/monitoring requirements. At that time, these terms and conditions will become 

nondiscretionary. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 23 

Mountain Plover 

Due to the programmatic nature of this consultation, any of the following terms and conditions may be 

modified or waived by the Service as a result of future details of site-specific project activities, should the 

mountain plover be listed. 

9) Operators and BLM shall be provided by the Service 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 with requirements that these material be posted in common areas and 

circulated in a memorandum among all employees and service providers. 

10) All suspected observations of mountain plover adults, eggs, chicks, or carcasses on the analysis area, 

however obtained, shall be promptly reported to: 

Wildlife Biologists, BLM, 

Mary Read, (307) 328-4255 

Larry Apple, (307) 328-4204 

Rawlins Field Office 

P.O. Box 2407 

1300 North 3rd Street 

Rawlins, WY 82301 

Field Supervisor or Designee, U.S.F.W.S. 

(307) 772-2374 

Wyoming Field Office, 

4000 Airport Parkway, 

Cheyenne, WY 82001 

Wildlife Biologist, BLM, 

Jim Dunder, (307) 352-0315 

Rock Springs Field Office 

280 Highway 191 

Rock Springs, WY 82901 

Observations shall include a description including what was seen, time, date, exact location, and observer’s 

name, address, and telephone number. Carcasses or other suspected plover remains shall be collected by 

BLM or Service employees and deposited with the Service’s Wyoming Field Office. 

11) Between April 10 and July 10, travel in vehicles over 1,000 pounds shall be restricted to existing roads, 

trails, and well pads, unless first cleared by surveys consistent with the Plover Guidelines, or another 

Service-reviewed and approved survey method. Results of all plover surveys shall be reported to the Service’s 

Wyoming Field Office. 

12) Geophysical exploration involving shot-hole, surface shot, or vibro-seismic techniques may destroy plover 

nests and displace incubating or brooding plovers. To minimize destruction or failure of nests, no geophysical 

exploration shall occur from April 10 to July 10 prior to clearance consistent with the Plover Guidelines or 

other Service-approved method. If mountain plovers are found, exploration work will be re-scheduled until 

after the nest becomes inactive. Results of all plover surveys shall be reported to the Service’s Wyoming 

Field Office. 

13) Broad-scale mountain plover surveys shall be conducted using techniques reviewed and approved by the 

Service to identify occupied mountain plover habitat, including breeding aggregations. Breeding aggregations 

are defined here as two or more observations, within 2 miles of each other during one breeding season, of any 

of the following: territorial adults, nests, adult distraction displays, or broods. Techniques shall be designed to 

document the occurrence of breeding plovers within 2 miles of historical and current locations, and if possible 

estimate abundance (see example, Appendix 6). The survey method would likely consist of a BBS-style 

survey, conducted early (April 15 - May 7) and late (June 7 - July 10) during the breeding season, involving 

50-75, 5-minute stops per survey route. This would amount to 4-5 person-days per route. Should proposed 

development or BLM’s workload increase, some additional assistance from operators may be necessary, not to 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 24 

exceed an estimated 3 person-days per township proposed for development. The details of this survey 

technique, or any alternate technique that may be proposed by BLM, shall be reviewed and approved by the 

Service prior to implementation. 

Survey effort shall focus first on locations of past sightings within areas likely to be developed at greater than 

1 well per section in 2000 and 2001. Survey effort shall then continue, maintaining a 1-year lead on 

development proposed to exceed one well per section. BLM shall require operators to submit detailed 

development plans for the coming year to them by March 15 annually so survey effort can be planned. Results 

shall be provided to the Service’s Wyoming Field Office including surveyor qualifications, date, exact 

location and survey effort for all surveys, locations of all plovers observed, nests or young observed, behaviors 

observed, and copies of field data sheets. 

14) Once occupied habitat (including breeding concentrations) is located, the BLM shall initiate section 7 

consultation with the Service on any project-related activities proposed for such habitat. 

15) BLM, Wyoming Game and Fish Department, operators, Service and any other involved parties shall meet 

annually to discuss progress, effectiveness, and any necessary modifications to these terms and conditions. 

Meetings shall be scheduled to coincide with annual meetings for the Wildlife Protection Plan, as described 

in Appendix D of the EIS. 

Conclusion 

The Service anticipates the proposed project will incidentally take an unquantifiable number of black-footed 

ferrets, in the form of direct mortality, and harm or harassment through disturbance of an unquantifiable 

amount of occupied suitable ferret habitat. The Service also anticipates the proposed project will incidentally 

take an unquantifiable number of: mountain plover nests through destruction or abandonment; mountain plover 

adults and chicks through direct lethal take; and an unquantifiable amount of breeding habitat in used breeding 

aggregation areas through harm or harassment. The reasonable and prudent measures, with their implementing 

terms and conditions, are designed to minimize the impact of incidental take that might otherwise result from 

the proposed action. If, during the course of the action, any incidental take is detected, such incidental take 

represents new information requiring re-initiation of consultation and review of the reasonable and prudent 

measures provided. The Federal agency must immediately provide an explanation of the causes of the taking 

and review with the Service the need for possible modification of the reasonable and prudent measures. 

Coordination of Incidental Take Statements with Other Laws, Regulations, and Policies 

If the mountain plover is listed pursuant to the Act, the Service will not refer the incidental take of mountain 

plovers for prosecution under the Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. 703-712), if such 

take is in compliance with the terms and conditions (including numbers 9-14) specified herein. 

CONSERVATION RECOMMENDATIONS 

Section 7(a)(1) of the Act directs Federal agencies to utilize their authorities to further the purposes of the Act 

by carrying out conservation programs for the benefit of endangered and threatened species. Conservation 

recommendations are discretionary agency activities to minimize or avoid adverse effects of a proposed action 

on listed species or critical habitat, to help implement recovery plans, or to develop information. 

1) Assist in developing partnerships and funding research to develop more efficient and effective black-footed 

ferret survey techniques. Item 332 from the Black-footed ferret recovery plan states, “Develop and improve 

survey techniques” and includes sub-item 3326, “Test use of dogs using scent combinations from captive 

ferrets and field trials” with the objective of developing a more reliable survey technique for locating new wild 

ferret populations. An improved survey technique will aid recovery of the black-footed ferret by increasing the 

probability of locating any remaining wild populations, in compliance with section 7(a)(1) of the Act. It will 

also provide for more efficient, reliable, and cost-effective clearance of prairie dog towns for identifying 

suitable re-introduction sites and the block-clearance and discontinuance of the need for project-level ferret 

surveys of prairie dog towns pursuant to section 7(a)(2) of the Act. See attached study proposal for possible 

funding (Appendix 7). 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 25 

2) Conduct block-clearance of all black-footed ferret habitat (consistent with the definition of suitable habitat 

in this document) within or contiguous with the analysis area. Future actions, including maintenance, 

work-over, and reclamation, within towns previously cleared of ferrets may require addition survey work unless 

the entire complex containing the towns has been cleared (block clearance). Such an effort would greatly 

facilitate future planning and work on the analysis area. Some terms and conditions in this biological opinion 

require mapping and estimating burrow densities of prairie dog complexes and provide the necessary first step 

in a possible block-clearance effort. This is an opportunity that could be easily extended into block-clearance 

and should be given serious consideration. The Service is very interested in working with BLM, operators, and 

other interested parties to pursue this work. 

3) Develop reclamation methods suitable to meet all requirements for soil stability and weed control while 

providing suitable breeding habitat for mountain plovers. Currently, the techniques for reclamation of disturbed 

sites produce tall and dense stands of species such as thick-spike wheatgrass (Elymus dasystachyum), 

unsuitable for nesting mountain plovers. BLM and operators should work together to develop cost-effective 

cultivation techniques for low-growing and vigorous species native to the analysis area that will quickly 

reproduce suitable habitat for breeding mountain plovers where it previously occurred. 

4) Conduct research to better understand the effects of oil and gas development on breeding mountain plovers. 

The focus of research should be to measure recruitment to the fall population, philopatry, and site fidelity 

between developed and undeveloped mountain plover breeding concentration areas on or near the analysis 

area. Terms and conditions outlined in this conference opinion will provide a useful starting point by 

identifying possible study sites currently under development, proposed for development, and not proposed for 

development. This effort would require close monitoring of a large sample of breeding adults, and possibly 

color-marking or radio-marking adults and juveniles. 

5) Working with industry representatives, develop a new design for condensate storage that is not suitable as a 

nest or perch site for birds of prey and corvids. The placement of large numbers of condensate tanks in areas 

where perches and nest sites are currently limited may greatly alter the composition and abundance of the 

avian predator community, reducing habitat suitability for many species in addition to the mountain plover and 

black-footed ferret. Re-designing condensate storage tanks will require understanding the nature of the existing 

design which lends itself to nest construction and useful perch sites, and understanding of the structural, 

functional, and human safety features necessary for a feasible new design. Thus, this effort should involve 

entities with expertise in engineering and gas field operations as well as entities with expertise in bird 

behavior. Because such expertise is currently available and organized in the parties cooperating on the 

Wildlife Protection Plan, the Service recommends that such an effort be developed through this ongoing effort. 

7) Roadside spotlight surveys have proved useful for surveying mountain plover broods in Utah. BLM or 

operators should conduct spot-light surveys after dark within _-mile of known concentration areas from June 15 

to July 15 to develop an index of brood size and abundance. 

In order for the Service to be kept informed of actions minimizing or avoiding adverse effects or benefitting 

listed species or their habitats, the Service requests notification of the implementation of any conservation 

recommendations, and receipt of any report developed as a result of their implementation. 

RE-INITIATION NOTICE 

This concludes formal consultation and conferencing on the proposed Continental Divide/Wamsutter II Natural 

Gas Project, Sweetwater and Carbon Counties, Wyoming, and the biological assessment submitted to the 

Service on December 7, 1999. As provided in 50 CFR 402.16, re-initiation of formal consultation is required 

where discretionary Federal agency involvement or control over the action has been retained (or is authorized 

by law) and if: (1) the amount or extent of incidental take is exceeded; (2) new information reveals effects of 

the agency action that may affect listed species or critical habitat in a manner or to an extent not considered 

in this opinion; (3) that agency action is subsequently modified in a manner that causes an effect to the listed 

species or critical habitat not considered in this opinion; or (4) a new species is listed or critical habitat 

designated that may be affected by the action. In instances where the amount or extent of incidental take is 

exceeded, any operations causing such take must cease pending re- initiation. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 26 

You may ask the Service to confirm the conference opinion as a biological opinion issued through formal 

consultation if the mountain plover is designated as threatened or endangered. The request must be in writing. 

If the Service reviews the proposed action and finds that there have been no significant changes in the action 

as planned or in the information used during the conference, the Service will confirm the conference opinion 

as the biological opinion on the project and no further section 7 consultation will be necessary. 

After listing of the mountain plover as endangered or threatened and/or designation of critical habitat for the 

mountain plover and any subsequent adoption of this conference opinion, the Federal agency shall request 

reinitiation of consultation if: (1) the amount or extent of incidental take is exceeded; (2) new information 

reveals effects of the agency action that may affect listed species or critical habitat in a manner or to an 

extent not considered in this conference opinion; (3) that agency action is subsequently modified in a manner 

that causes an effect to the listed species or critical habitat not considered in this conference opinion; or (4) a 

new species is listed or critical habitat designated that may be affected by the action. 

The incidental take statement provided in this conference opinion does not become effective until the species 

is listed and the conference opinion is adopted as the biological opinion issued through formal consultation. At 

that time, the project will be reviewed to determine whether any take of the mountain plover has occurred. 

Modifications of the opinion and incidental take statement may be appropriate to reflect that take. No take of 

the mountain plover may occur between the listing of the mountain plover and the adoption of the conference 

opinion through formal consultation, or the completion of a subsequent formal consultation. 

Thank you for you assistance in the conservation of endangered, and proposed species. If you have any 

questions or comments on this biological opinion, please contact David Felley at the letterhead address or by 

phone at (307) 772-2374, extension 23. 

Appendices (7) 

cc: State Director, BLM, Cheyenne, WY 

Acting GARD, No. Ecosystems, FWS, Denver, CO 

M. Brennan, Holland & Hart, Jackson, WY 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 27 

LITERATURE CITED 

Biggins, Dean E. Research Biologist, U.S.G.S, Mid-continental Ecological Science Center, Fort Collins, 

Colorado. Pers. Comm. March 28, 2000. 

Biggins, D.E., B.J. Miller, L.R. Hanebury, B. Oakleaf, A.H. Farmer, R. Crete, A. Dood. 1993. A technique for 

evaluating black-footed ferret habitat. In J.L. Oldmeyer, D.E. Biggins and B.J. Miller (Eds.) 

Proceedings of a symposium on the management of prairie dog complexes for the reintroduction of the 

black-footed ferret. U.S. Fish and Wildlife Service National Ecology Research Center, 4512 McMurry 

Avenue, Fort Collins, Colorado 80525. 96 pp. 

Bureau of Land Management. 1999a. Draft Environmental Impact Statement: Continental Divide/Wamsutter II 

Natural Gas Project, Sweetwater and Carbon Counties, Wyoming. Prepared by TRC Mariah 

Associates, Inc., for the Bureau of Land Management, Rawlins and Rock Springs Field Offices, 

Rawlins and Rock Springs, Wyoming. 

. 1999b. Final Environmental Impact Statement: Continental Divide/Wamsutter II Natural Gas Project, 

Sweetwater and Carbon Counties, Wyoming. Prepared by TRC Mariah Associates, Inc., for the 

Bureau of Land Management, Rawlins and Rock Springs Field Offices, Rawlins and Rock Springs, 

Wyoming. 

. 1988. Proposed Resource Management Plan/Final Environmental Impact Statement for the Cody 

Resource Area, Worland District, Wyoming. U.S. Department of the Interior, Bureau of Land 

Management, Worland, Wyoming. 

Braun, C.E. 1998. Sage grouse declines in western North America: what are the problems? Proc. Western 

Assoc. State Fish and Wildl. Agencies, in press. 

Cerovski, A., L. Kinter, and D. Martin. 1992. Black-footed ferret surveys in Wyoming: 1977- 1992. Wyoming 

Game and Fish Department, Nongame Branch, Lander. 

Clark, T.W. and M.R. Stromberg. 1987. Mammals in Wyoming. University of Kansas, Museum of Natural 

History, Public Education Series #10. 314 pp. 

Day, K.S. 1994. Observations on mountain plover (Charadrius montanus) breeding in Utah. Southwest 

Naturalist 39:298-300. 

Ellison, A., C.M. White, and W. Mendel. 1999. Mountain plover surveys on the Monument Butte Oil Field, 

April to August 1998. Report to the Bureau of Land Management and Utah Division of Wildlife 

Resources, Vernal Utah. 13 pp. 

Forrest, S.C., T.W. Clark, L. Richardson, and T.M. Campbell III. 1985. Black-footed ferret habitat: some 

management and reintroduction considerations. Wildlife Technical Bulletin No. 2, Bureau of Land 

Management, Wyoming State Office, Cheyenne. 49 pp. 

Graul, W.D. 1975. Breeding biology of the Mountain Plover. Wilson Bull. 87: 6-31. 

Kinter, L and D. Martin. 1992. Black-footed ferret sighting reports in Wyoming. Wyoming Game and Fish 

Department, unpublished report. Lander. 

Knight, D.H. 1994. Mountains and plains: the ecology of Wyoming landscapes. Yale University Press, New 

Haven and London. 338 pp. 

Knight R.L. and J. Kawashima.1993. Responses of raven and red-tailed hawk populations to linear 

right-of-ways. J. Wildl. Manage. 57:266-271. 

Knight R.L., H.L. Knight, and R.J. Camp. 1993. Raven populations and land-use patterns in the Mojave Desert, 

California. Wildl. Soc. Bull. 21:469-471. 
Continental Divide/Wamsutter II Gas Project Final Biological Opinion 28 

Knopf, F.L. 1996. Mountain Plover (Charadrius montanus). In The Birds of North America, No. 211 (A. Poole 

and F. Gill, eds.). The Academy of Natural Sciences, Philadelphia, PA, and the American 

Ornithologists’ Union, Washington, D.C. 

Laun, H.C. 1957. A life history study of the mountain plover, Eupoda montana, Townsend on the Laramie 

Plains, Albany County, Wyoming. M.S. Thesis, University of Wyoming. 67 pp. 

Lockhart, Michael. Black-footed Ferret Recovery Coordinator with the U.S. Fish and Wildlife Service, 

Laramie, Wyoming. Pers. comm., March, 28, 2000. 

. Pers. comm., March 2, 2000. 

Luce, Robert. Nongame mammal biologist with the Wyoming Game and Fish Department, Lander, Wyoming. 

Pers. comm. March 28, 2000. 

. Pers. comm. December, 1999. 

Parrish, T.L. 1988. Mountain Plover habitat selection in the Powder River basin, Wyoming. Master’s thesis, 

University of Wyoming, Laramie. 

Pulliam, H.R. 1988. Sources, sinks, and population regulation. American Naturalist 137(supplement):S50-66. 

U.S. Fish and Wildlife Service. 1988. Black-footed Ferret Recovery Plan. U.S. Fish and Wildlife Service, 

Denver, Colorado. 154 pp. 

. 1989. Black-footed ferret survey guidelines for compliance with the Endangered Species Act, April 

1989. U.S. Fish and Wildlife Service, Denver, Colorado and Albuquerque, New Mexico. 15 pp. 

WEST, Inc. 1999. Wildlife monitoring studies, Seawest Windpower Project, Carbon County, Wyoming, 

1995-1998, Draft report. WEST, Inc., 2003 Central Ave, Cheyenne, Wyoming 82001. 
APPENDIX 1

White-tailed Prairie Dog Distribution (presence/absence by section) 

on the Continental Divide/Wamsutter II Analysis Area 

from

Draft Environmental Impact Statement:

Continental Divide/Wamsutter II Natural Gas Project, 

Sweetwater and Carbon Counties, Wyoming. 

Prepared by TRC Mariah Associates, Inc. 

for the Bureau of Land Management, Rawlins and Rock Springs Field Offices, 

Rawlins and Rock Springs, Wyoming.
APPENDIX 2

Mountain Plover Observations 

in the Vicinity of the Continental Divide/Wamsutter II Analysis Area

Date Location Source 

06/27/91 T19N, R94W, S. 10, N1/2 Robert Dorn 

06/29/99 T16N, R93W, S. 20, SW1/4, SW1/4 BLM, Rawlins 

06/23/83 T22N, R95W, S. 2, NW1/4, NE 1/4 WOS 

05/02/87 T23N, R91W, S. 10, SW1/4, NE1/4 WOS 

05/26/86 T24N, R92W, S. 34 WOS 

06/25/91 T23N, R93W, S. 12, SW1/4, NE1/4 WOS 

08/16/96 T18N, R94W, S. 4, NW1/4 WOS 

06/24/81 T19N, R95W, S. 35 WOS 

06/23/81 T18N, R95W, S. 20 WOS 

04/17/92 T22N, R99W, S. 12, SE1/4, NE1/4 WOS 
APPENDIX 3

BLM Instruction Memorandum No. WY-99-24:

The Extent of Federal Authority over Actions Occurring on Private Lands

 - Plants & Wildlife
APPENDIX 4

Mountain Plover Survey Guidelines

U.S. Fish and Wildlife Service 1999 
APPENDIX 5

A Technique for Evaluating Black-footed Ferret Habitat
APPENDIX 6

Mountain Plover Study Proposal

Landscape-level Surveys in the Great Divide Basin

U.S. Fish and Wildlife Service 2000
APPENDIX 7 

Study Proposal for the Testing of Ferret-sniffing Dogs 

as an Improved Black-footed Ferret Survey Technique 
______________________________________________________________________________ 

___________________ 

Record of Decision, Continental Divide/Wamsutter II 1 

APPENDIX H: 

COMMENTS RECEIVED ON THE CONTINENTAL DIVIDE/WAMSUTTER II

 FINAL ENVIRONMENTAL IMPACT STATEMENT AND BLM RESPONSE
______________________________________________________________________________ 

___________________ 

Record of Decision, Continental Divide/Wamsutter II 2 

Comments Received on the Continental Divide/Wamsutter II

 Final Environmental Impact Statement 

The final environmental impact statement (FEIS) was issued December 10, 1999 for a 30 day 

comment period. Over 700 copies of the FEIS were distributed to the public for review and 

comment. In addition, media releases were sent to newspapers in Wyoming announcing the 

availability of the FEIS for public review. Only four comment letters were received. Three of 

the letters expressed some concerns about adding additionalmitigation and amending/revising the 

Great Divide Resource Management Plan (RMP) for the Rawlins Field Office (RF)O area; 

however, all four comment letters were generally in support of the analysis and/or proposed 

development. Comment letters and Bureau of Land Management (BLM) responses are presented 

on the following pages. 
______________________________________________________________________________ 

___________________ 

Record of Decision, Continental Divide/Wamsutter II 3 

Letter 1 - Gene R. George, Agent for Yates Petroleum Corp.; Response 

General Response; Entire Letter - Thank you for taking the time to review the FEIS and for 

providing your comments. The BLM considers all comments during preparation of an 

environmental impact statement (EIS). 

1. The BLM agrees applicant committedmitigation will provide adequate protection for most 

resources. However, the EIS revealed that some resources may still have significant impacts. BLM 

believes additionalmitigation identified in the EIS analysis for these resources may be necessary to 

further reduce orminimize the anticipated impacts. Through Application for Permit to Drill (APD)- and right-of-way (ROW)-level environmental analysis these additional requirements will be 

appropriately applied. In addition, the formal consultation/conference with the U.S. Fish and 

Wildlife Service (USFWS) revealed additional terms and conditions which must also be 

implemented to ensure certain wildlife species are not adversely affected. Many of these terms and 

conditions outlined in the USFWS Biological Opinion were not applicant committedmitigation as 

outlined in the draft or final EIS documents; and therefore, they need to be identified and carried 

forward as part of the Record of Decision (ROD). 

2. The BLM agrees there may be someminor gains in the reasonably foreseeable development 

(RFD) by restoring acreage from reclaimed plugged and abandoned wells. However, we do not 

believe there have been a sufficient number of plugged wells since the Great Divide RMP was 

approved November 8, 1990 to significantly increase the RFD acreage for future oil and gas 

development. In addition, wells drilled on private lands are part of the RFD projection analyzed in 

the RMP. Therefore, all wells whether on private or federal lands are counted against the RFD. 

Based on projected future oil and gas development, the BLM still anticipates a RMP review and 

possible modification. 

The BLM is alsomindful of the fact coal bed methane wells can require less disturbed area. As you 

are also aware, the depth of the wells may vary from one region to another and subsequently the 

surface disturbance can be similar to a shallow oil and gas well to half that acreage for shallower 

depths. In any event, we are interested in total surface disturbance and not just well numbers. The 

BLM will take this into account when analyzing future projects. 

3. The BLM agrees oil and gas development could increase vegetative habitat for plover. Because 

there is already considerable habitat in the project area and since studies seem to show plover 

concentrate in the same nesting areas each year, a banking or credit system for increasing habitat 

does not seem applicable for this species. The USFWS biological opinion (see ROD Appendix G) 

points out that it is not the amount of habitat available but the potential harm due to increased, 

long-term disturbance (i.e., human presence) near established nesting sites and therefore, the loss of 

nesting habitat in an established breeding concentration area. 
______________________________________________________________________________ 

___________________ 

Record of Decision, Continental Divide/Wamsutter II 3 

Letter 2 - Kirk Steinle, BP Amoco; Response 

General Response; Entire Letter - Thank you for taking the time to review the FEIS and for 

providing your comments. The BLM considers all comments during preparation of an EIS. 

1. BLM does not believe additionalmitigation identified in the EIS analysis for water resource will 

be necessary to further reduce orminimize the anticipated impacts. However, through APD and 

ROW level environmental analysis, additional requirements may be identified and if necessary will 

be appropriately applied. 

2. No "adaptive management program" specific to surface water resources is planned at this time. 

The BLM believes existing surface water protection measures coupled with transportation and 

reclamation planning as presented in the EIS will adequately protect this resource. Should a 

specific management program be developed in the future, all land uses will be evaluated to 

determined where additional protection measures are needed. 

3. The BLM concurs with your recommendation. 

4. Based on the Continental Divide/Wamsutter II (CD/WII) EIS air quality analysis, the BLM sees 

no need for an oxide of nitrogen (NOx) Tracking Agreement. Furthermore, the Wyoming 

Department of Environmental Quality-Air Quality Division (DEQ-AQD) has not requested that we 

have one. 

5. BLM agrees applicant avoidance of stabilized sand dunes is the best measure of protection. 

However, the analysis revealed this will not be possible in all cases and therefore there could be 

significant impacts to soils through activation of stabilized dunes. Even though Appendix A 

(Reclamation Plan) addresses some additional reclamation practices which will be used, BLM 

believes additionalmitigation identified in the EIS analysis for this resource may be necessary to 

further reduce orminimize the anticipated impacts. Through APD and ROW level environmental 

analysis these additional requirements will be appropriately applied. 

6. The BLM agrees the applicant committed Wildlife Protection Plan (ROD Appendix D) is a 

significant step in determining additionalmitigation needs, and the BLM intends to use this program 

to identify future needs. However, the EIS revealed that some indirect wildlife impacts (i.e., human 

disturbance of big game) may still result in significant impacts even without monitoring. BLM 

believes additionalmitigation identified in the EIS analysis for big game may be necessary to further 

reduce orminimize the anticipated impacts. Through APD and ROW level environmental analysis 

these additional requirements will be appropriately applied. In addition, the formal 

consultation/conference with the USFWS revealed additional terms and conditions which must also 

be implemented to ensure certain wildlife species are not adversely affected. Many of these terms 

and conditions outlined in the USFWS Biological Opinion were not applicant-committedmitigation 

as outlined in the draft or final EIS documents; and therefore, they need to be identified and carried 

forward as part of the ROD. 
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Record of Decision, Continental Divide/Wamsutter II 8 

7. Since Visual Resource Management (VRM) Class II areas are those which could incur 

significant impacts, the BLM agrees that additionalmitigation measures will most likely be applied 

to VRM Class II areas. Through APD and ROW level environmental analysis these additional 

requirements will be appropriately applied. Please understand that VRM Class III and IV areas 

also need a degree of protection. If for some reason applicant-committed measures are not adequate 

to reduce impacts, additionalmitigation measures may be used to reach the required standard. 

However, we anticipate this to be the exception and not the rule. 

8. The CD/WII EIS certainly provides some background information to help identify issues and 

potential impacts related to oil and gas resources. However, it does not follow the framework for 

completing a review of an existing RMP. The process is begun by issuing a public notice through 

the Federal Register. The BLM must also re_evaluate the RFD for oil and gas exploration and 

development activities in the Great Divide Resource Area(GDRA) RMP/EIS. In addition to the 

RFD for oil and gas exploration and development activities, the BLM must also review the 

reasonably foreseeable activities or actions involving other land use and resource management 

programs, like recreation, livestock grazing, wildlife habitat, etc. There may be direct or interrelated 

cause_and_effect relationships (other than just those related to oil and gas actions) among all of 

these activities or actions that could require amending RMP decisions. The BLM is anticipating the 

immediate review of the GDRA RMP/EIS. Pending receipt of adequate funding, it is hopeful the 

review will begin within the next year. 

9. Since completion of the CD/WII draft and final EIS documents, it has come to the BLM's 

attention that there could be proposals for two to three coal bed methane projects and one major 

deep gas project within the next year. Projected numbers could easily exceed 500 wells. It is not 

the BLM's intent to deny proponents of the CD/WII project their projected 3,000 well proposal 

without justification. As indicated in the draft and final EIS, no more than 1,655 wells could be 

allowed in the Rawlins Field Office area (formerly the GDRA) under the RFD assumptions for the 

GDRA RMP. This is assuming no other wells outside the project area are drilled. Since oil and 

gas development projects will likely continue on both private and public lands outside the project 

area before a RMP review can be completed, it seems only prudent that an additional but reasonable 

limitation be put on well numbers within the CD/WII project so that a RMP review can be 

completed without prohibiting this project and other proposed developments. Once a RMP review 

is completed, the CD/WII ROD could be re-evaluated against the revised RMP and an amended 

ROD could be issued to allow the additional wells analyzed in the CD/WII EIS. 
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Record of Decision, Continental Divide/Wamsutter II 9 

Letter 3 - Claire M. Moseley, Public Lands Advocacy; Response 

General Response; Entire Letter - Thank you for taking the time to review the FEIS and for 

providing your comments. The BLM considers all comments during preparation of an EIS. 

1. See response comments 8 and 9 to the Kirk Steinle, BP Amoco Letter 2. As you may be aware 

the GDRA RMP was a planning document projected to last 20 years through the year 2005. 

Reasonable foreseeable development for oil and gas was based on 1985-86 data; and at the time the 

projections for surface use seemed quite reasonable. It wasn't until recently these projections 

appeared to be inadequate. The BLM is now actively pursuing review of the RMP and hopes to 

conclude the review before 2005. In order to maintain some reasonable amount of development and 

remain within the planning decisions. It is imperative that some limitations be put on current 

development proposals until the RMP review is completed. 

2. See response comment 4 of the Kirk Steinle, BP Amoco Letter 2. 

3. See response comment 6 of the Kirk Steinle, BP Amoco Letter 2. 

4. The BLM initiated reviews with the USFWS on the draft Biological Assessment for the 

CD/WII project in October 1998. However, as time elapsed, new concerns were brought forward 

for black-footed ferret (listed species) and for mountain plover (proposed listed species) which 

eventually lead to formal consultation/conference. Based on USFWS reviews of other EIS projects 

recently approved in Wyoming, this formal consultation/conference was not anticipated. 

5. See response comment 7 of the Kirk Steinle, BP Amoco Letter 2. 

6. See response comment 5 of the Kirk Steinle, BP Amoco Letter 2. 
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Record of Decision, Continental Divide/Wamsutter II 9

Letter 4 - Cynthia G. Cody, U.S. Environmental Protection Agency; Response 

General Response; Entire Letter - Thank you for taking the time to review the FEIS and for 

providing your comments. The BLM considers all comments during preparation of an EIS.