United States 

Department of

Agriculture

Forest 

Service

Southwestern

Region

MB-R3-10-17

November 2012

Final Supplement to the 

Final Environmental 

Impact Statement for OilGas Leasing

Santa Fe National Forest, Rio 

Arriba and Sandoval Counties, 

New Mexico
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Printed on recycled paper – November 2012
Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF i

Final Supplement 

to the 

Final Environmental Impact Statement for 

Oil-Gas Leasing

Santa Fe National Forest, 

Rio Arriba and Sandoval Counties, New Mexico

Lead Agency: U.S. Forest Service

Responsible Official: Maria T. Garcia, Forest Supervisor

11 Forest Lane

Santa Fe, NM 87508

For Information Contact: Jennifer Cramer, Forest Planner

11 Forest Lane

Santa Fe, NM 87508

(505) 438-5449

or

Julie Bain, NEPA Coordinator

11 Forest Lane

Santa Fe, NM 87508

(505) 438-5448

or

Larry Gore, Forest Geologist

P.O. Box 130

Cuba, NM 87018

(575) 289-3264

Abstract: The Santa Fe National Forest has prepared this ―Final Supplement to the Final 

Environmental Impact Statement for Oil-Gas Leasing.‖ Originally published as the ―Draft 

Supplement to the Final Environmental Impact Statement for Oil-Gas Leasing‖ in August 2010, 

this document supplements the ―Environmental Impact Statement for Oil-Gas Leasing and Roads 

Management‖ published in June 2008. The EIS was divided into two parts: the first a 

programmatic analysis of a proposed forest plan amendment that would establish stipulations on 

new oil and gas leases to protect wildlife and National Forest System (NFS) lands and surface 

resources in the portion of the San Juan Basin within the Santa Fe National Forest; the second a 

site-specific analysis of a proposed roads closure and decommissioning project on the Cuba 

Ranger District.
ii Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

This final supplement is specific to oil and gas leasing and analyzes new information pertaining 

to consistency of the proposed action (Forest Plan amendment) with the ―Regionwide 

Programmatic Land and Resource Management Plan Biological Opinion‖ issued by the U.S. Fish 

and Wildlife Service on June 10, 2005 (Consultation No. 2-22-03-F-366). It also analyzes air 

quality data for the period 2006 to 2011, and includes data from the new Navajo Lake monitoring 

station. The final supplement also includes the 2011 interagency air quality memorandum of 

understanding.

The oil-gas leasing Proposed Action would amend the Forest Plan oil and gas leasing availability 

with stipulations that provide direction pertinent to timing limitations for certain wildlife species 

and for surface occupancy or use specific to sensitive NFS lands and resources, their purpose, 

locations, and/or conditions under which they apply, and exceptions.

The final EIS notice of availability was published in the Federal Register on September 26, 2008 

(73 FR 55843). The final EIS is available on the Santa Fe National Forest Web site at 

http://www.fs.fed.us/r3/sfe/projects/projects/index.html.
Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF iii

Contents

Background.....................................................................................................................................1

Supplemental Pages................................................................................................................................1

Air Quality Replacement Pages ....................................................................................................3

The following pages replace the “Air Quality” section beginning on page 84 and 

continuing through page 94 in chapter 3 of the “Final Environmental Impact Statement 

for Oil-Gas Leasing and Roads Management” .......................................................................................3

Air Quality..............................................................................................................................................4

Introduction ........................................................................................................................................4

Affected Environment ........................................................................................................................5

Regulatory Setting..............................................................................................................................5

Region of Influence ............................................................................................................................9

Baseline Air Quality...........................................................................................................................9

Visibility Trends...............................................................................................................................14

Regional Air Emissions....................................................................................................................15

Environmental Consequences ..........................................................................................................18

Effects ..............................................................................................................................................19

Cumulative Impacts..........................................................................................................................23

Hazardous Air Pollutants (HAPs) ....................................................................................................25

Greenhouse Gases ............................................................................................................................25

Mitigation.........................................................................................................................................26

Timing Stipulation Amendment Page ........................................................................................29

The following replaces the “Resource: Mexican Spotted Owl Timing Stipulation” 

Section on page 33 in the “Final Environmental Impact Statement for Oil-Gas 

Leasing and Roads Management” ........................................................................................................29

Threatened, Endangered, and Sensitive Species Replacement Pages.....................................31

The following pages replace the “Threatened, Endangered, and Sensitive Species” section 

beginning on page 144 and continuing through page 145 in chapter 3 of the “Final 

Environmental Impact Statement for Oil-Gas Leasing and Roads Management”................................31

Threatened, Endangered, and Sensitive Species...................................................................................32

Affected Environment and Environmental Consequences...............................................................32

Mexican Spotted Owl Replacement Pages ................................................................................35

The following pages replace the “Mexican Spotted Owl” section beginning on 

page 148 and continuing through page 150 in chapter 3 of the “Final Environmental 

Impact Statement for Oil-Gas Leasing and Roads Management” ........................................................35

Mexican Spotted Owl (Strix occidentalis lucida).................................................................................36

Affected Environment ......................................................................................................................36

Environmental Consequences ..........................................................................................................36

Cumulative Impacts..........................................................................................................................41

Conclusions......................................................................................................................................42

Supplemental Consultation and Coordination ..........................................................................43

Preparers and Contributors...................................................................................................................43

Interdisciplinary Team Members .....................................................................................................43

Persons, Organizations and Agencies that Were Sent Copies or Notified 

of the Availability of the Final Supplement to the FEIS ..................................................................43

Literature Cited............................................................................................................................45

Appendix

A. MOU................................................................................................................................................49

The following pages contain the Memorandum of Understanding Among the U.S. 

Department of Agriculture, U.S. Department of the Interior, and U.S. EPA Regarding 
Contents

iv Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Air Quality Analysis and Mitigation for Federal Oil and Gas Decisions Through the 

National Environmental Policy Act Process (June 23, 2011)

B. Public Comments.............................................................................................................................79

Air Quality........................................................................................................................................80

Soils..................................................................................................................................................82

T&E Species.....................................................................................................................................82

Forest Planning.................................................................................................................................84

Alternatives ......................................................................................................................................85

List of Figures

Figure OGS-1. Visibility trends on the 20 percent best days 

at San Pedro Parks Wilderness....................................................................................14

Figure OGS-2. Visibility trends on the 20 percent worst days 

at San Pedro Parks Wilderness....................................................................................15

Figure OGS-3. Mexican spotted owl protected activity centers, designated 

critical habitat, and locations and acreages in the study area.......................................38

Figure OGS-4 Mexican spotted owl protected activity centers and 

designated critical habitat in the study area .................................................................40

List of Tables

Table OGS-1. National and New Mexico ambient air quality standards............................................5

Table OGS-2. Applicable prevention of significant deterioration increment values ..........................7

Table OGS-3a. Maximum pollutant concentrations (Ozone and PM10) 

monitored near the study area, 2006-2011.................................................................11

Table OGS-3b. Maximum pollutant concentrations (PM2.5) 

monitored near the study area, 2006-2011.................................................................11

Table OGS-3c. Maximum pollutant concentrations (NO2) 

monitored near the study area, 2006-2011.................................................................12

Table OGS-3d. Maximum pollutant concentrations (SO2) 

monitored near the study area, 2006-2011.................................................................12

Table OGS-3e. Maximum pollutant concentrations (SO2) 

monitored near the study area, 2009-2011.................................................................13

Table OGS-4. Summary of 2008 annual emissions by source 

category for Rio Arriba County (in tons per year).....................................................16

Table OGS-5. Summary of 2008 annual emissions by source 

category for Sandoval County (tons per year) ...........................................................16

Table OGS-6. Number of wells in the South San Juan Basin ...........................................................17

Table OGS-7. WRAP Phase III baseline 2006 oil and gas emissions by county..............................17

Table OGS-8. WRAP Phase III projected 2012 oil and gas emissions by county ............................18

Table OGS-9. Emissions estimated for 20 new wells (tons per year)...............................................21

Table OGS-10. Construction emissions (20 wells) compared to WRAP 2006 and 2012 

estimates for Rio Arriba County for NOx, CO, SO2, and VOCs (tons per year).......21

Table OGS-11. Construction emissions (20 wells) compared to EPA 2008 

estimates for Rio Arriba County for PM10 (tons per year).........................................22

Table OGS-12. Hazardous air pollutant emissions 2008 by county....................................................25

Table OGS-13. Threatened, endangered, and sensitive species occurring on or near the Santa Fe 

National Forest, with potential of occurrence in the study area.................................32

Table OGS-14. Existing Forest Plan oil-gas lease standards and 

guidelines within MSO PACs and critical habitat .....................................................36

Table OGS-15. Proposed oil-gas lease stipulations within MSO 

areas under the action alternatives.............................................................................41
Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 1

Background

The Santa Fe National Forest (Forest) is located in north-central New Mexico, approximately 40 

miles north of Albuquerque. Approximately 198,794 acres of the Forest is within the easternmost 

part of the San Juan Basin but is outside the basin’s most productive oil and gas formations. As of 

September 29, 2011, approximately 69,067 acres of Santa Fe National Forest System lands are 

under 192 oil-gas leases. 

In 2003, the Bureau of Land Management (BLM) issued a final EIS and record of decision 

(ROD) for the BLM-Farmington Resource Area Management Plan revision. The EIS addressed 

management of Federal minerals within the New Mexico portion of the San Juan Basin. Although 

the EIS considered the potential for development within the Forest, it was not adequate to meet 

Forest Service National Environmental Policy Act (NEPA) requirements.

The Santa Fe National Forest Plan, 1987 as amended (Forest Plan) provides broad direction 

regarding leasing and the management of oil and gas development on National Forest System 

land. However, the Forest Plan and its analysis final EIS did not address the potential 

environmental effects of future oil-gas leasing and development on the Forest sufficiently enough 

to make new lease issuance decisions. 

In September 2004, the Forest published a notice of intent in the Federal Register initiating 

development of an environmental impact statement (EIS) for oil-gas leasing on the Forest. A draft 

EIS was released in March 2006 that proposed to amend the Forest Plan with a suite of 

stipulations designed to protect or minimize impacts to NFS lands and resources in the study area.

The final EIS and ROD for oil and gas leasing were issued in September 2008. 

Additional background information for this draft supplement can be found on the Santa Fe 

National Forest Web site http://www.fs.usda.gov/projects/santafe/landmanagement/projects under 

Current Projects, Oil-Gas Leasing & Roads Management ROD & FEIS.

Supplemental Pages 

This ―Final Supplement to the Final Environmental Impact Statement for Oil-Gas Leasing‖ 

contains replacement pages for chapter 3 of the ―Final Environmental Impact Statement for OilGas Leasing and Roads Management‖ as follows: the ―Air Quality‖ section, pages 84 through 92; 

the ―Mexican Spotted Owl Timing Limitation Stipulation,‖ page 33; The ―Threatened, 

Endangered, and Sensitive Species‖ section, pages 144 and 145; and the ―Mexican Spotted Owl‖

subsection, pages 148 through 150. Tables and figures appearing in the supplement are numbered 

with the ―OGS‖ prefix (oil-gas supplement) to denote they are added.

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 3

Air Quality Replacement Pages

The following pages replace the “Air Quality” 

section beginning on page 84 and continuing 

through page 94 in chapter 3 of the “Final 

Environmental Impact Statement for Oil-Gas 

Leasing and Roads Management”
Air Quality Replacement Pages

4 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Air Quality

Introduction

The primary goal of air quality management is to protect air quality within and adjacent to the 

SFNF. The management objectives related to this goal are to:

Ensure that the air quality within the SFNF meets State and Federal air quality standards 

and regulations; and

Protect visibility at Class 1 areas and at scenic and important vistas.

Under the Federal Land Policy and Management Act of 1976 (FLPMA) and the Clean Air Act, 

the U.S. Forest Service cannot conduct or authorize any activity that does not conform to all 

applicable local, county, state, Native American tribal, and other Federal air quality laws, statutes, 

regulations, standards, and implementation plans. The air quality effects analysis examines 

monitored data and modeled impacts based on atmospheric dispersion modeling to assess 

potential impacts.

The SFNF includes the San Pedro Parks Wilderness Class 1 area, and is adjacent to the Bandelier 

National Monument Class 1 area. Class 1 areas have been designated within the Clean Air Act as 

deserving the highest level of air quality protection. Congress designated (42 U.S.C. 7472)(CAA 

162) 158 areas as Class 1, including national parks larger than 6,000 acres and national 

wilderness areas larger than 5,000 acres, in existence on August 7, 1977. These ―mandatory‖ 

Class 1 areas may not be re-designated to a less protective classification. As air quality protection 

is legally mandated for Class 1 areas, the impact analysis focuses on potential changes to the 

adjacent San Pedro Parks Wilderness Class 1 area. 

Under all alternatives considered in this NEPA analysis, including Alternative 1, the No Action 

Alternative, there is a potential for an additional 20 wells to be developed. As indicated 

previously, under Alternative 1, the No Action Alternative, lands would still be available for 

leasing according to the stipulations specified in the Forest Plan (1987 as amended). Under 

Alternative 2, specific stipulations would be applied to protect surface resources. Alternative 3 is 

similar to Alternative 2 but provides for further acreage of no surface occupancy lease 

stipulations. As stated previously, it has been determined that the Forest Plan and its analysis 

(final EIS) did not address the potential environmental effects of future leasing and development 

on the SFNF sufficiently enough to make new lease issuance decisions. As a result, this analysis 

assumes that all of the alternatives have the potential for an additional 20 wells over the next 20 

years. The actual effects of these wells would only occur once they have been analyzed and 

authorized through a site-specific NEPA decision at the time of application to drill. The SFNF 

includes the southeastern edge of the San Juan Basin and since 1998 only four new wells have 

been constructed on the SFNF. This analysis examines the maximum development case of 20 

wells being developed.

The record of decision will not authorize specific, surface-disturbing activities. The record of 

decision will only make a decision about which lands would be available for oil and gas leasing 

and what conditions and stipulations would apply to any oil and gas leases offered in the future. 

Environmental impacts of future oil and gas exploration and development activities would 

undergo future, project-specific environmental analyses.
Air Quality Replacement Pages

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 5

Affected Environment

This section describes the existing air resource for the study area and applicable air quality 

regulations. At the present time, the project region attains all national and New Mexico ambient 

air quality standards. However, the Navajo Lake monitor—approximately 50 miles northwest of 

the project area—has recently come very close to the National Ambient Air Quality Standard 

(NAAQS) for ozone and may exceed the 2008 standard at some time in the future. It is also 

possible that future revisions to the ozone standard will lower it even further, in which case the 

area may fall into nonattainment.

Air quality in a given location is defined by pollutant concentrations in the atmosphere and is 

generally expressed in units of parts per million (ppm) or micrograms per cubic meter (μg/m3). 

One aspect of air quality significance is a pollutant’s concentration in comparison to the national 

and/or state ambient air quality standards. These standards represent the maximum allowable 

atmospheric concentrations that may occur and still protect public health and welfare, and include 

a reasonable margin of safety to protect the more sensitive individuals in the population. State 

standards, established by the New Mexico Environmental Improvement Board (EIB) and 

enforced by the New Mexico Environment Department, Air Quality Bureau (NMED-AQB), are 

termed the New Mexico Ambient Air Quality Standards (NMAAQS). The NMAAQS must be at 

least as restrictive as the National Ambient Air Quality Standards (NAAQS). NMAAQS also 

include standards for total suspended particulate matter (TSP), hydrogen sulfide, and total 

reduced sulfur for which there are no national standards. Table OGS-1 presents the national and 

State ambient air quality standards.

The pollutants of primary concern considered in this air quality analysis include volatile organic 

compounds (VOCs), nitrogen oxides (NOx), nitrogen dioxide (NO2), ozone (O3), particulate 

matter less than 10 microns in diameter (PM10), particulate matter less than 2.5 microns in 

diameter (PM2.5), and hazardous air pollutants (HAPs). Although VOCs and NOx (other than 

nitrogen dioxide) have no established ambient standards, they are important as precursors to 

ozone formation. Additionally, greenhouse gas emissions are also of concern.

Regulatory Setting 

The New Mexico Environment Department - Air Quality Bureau (NMED-AQB) enforces air 

pollution regulations and sets guidelines to attain and maintain the national and State ambient air 

quality standards within the State of New Mexico, except for tribal lands and Bernalillo County 

which maintain separate jurisdictions. The NMED-AQB guidelines are found in the ―New 

Mexico State Implementation Plan‖ (SIP). The following is a summary of Federal and State air 

quality rules and regulations that may apply to emission sources associated with the alternatives.

Table OGS-1. National and New Mexico ambient air quality standards

Pollutant Averaging Time New Mexico

Standards

National Standards (a)

Primary (b,c) Secondary (b,d)

Ozone 8-hour — 0.075 ppm Same as primary

Carbon monoxide 8-hour 8.7 ppm 9 ppm —

1-hour 13.1 ppm 35 ppm —
Air Quality Replacement Pages

6 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Pollutant Averaging Time New Mexico

Standards

National Standards (a)

Primary (b,c) Secondary (b,d)

Nitrogen dioxide Annual 0.05 ppm 0.053 ppm Same as primary

24-hour 0.10 ppm — —

1-hour 0.1 ppm —

Sulfur dioxide Annual 0.02 ppm 0.03 ppm —

24-hour 0.10 ppm 0.14 ppm —

3-hour — — 0.5 ppm

1-hour 0.75 ppm —

Hydrogen sulfide 1-hour 0.010 ppm — —

Total Reduced 

Sulfur

1⁄2-hour 0.003 ppm — —

PM10 24-hour Same as Federal 150 μg/m3Same as primary

PM2.5 Annual

(arithmetic mean)

Same as Federal 15 μg/m3Same as primary

24-hour Same as Federal 35 μg/m3Same as primary

Total Suspended 

Particulates (TSP)

Annual

(geometric mean)

60 μg/m3 — —

30-day Average 90 μg/m3 — —

7-day 110 μg/m3 — —

24-hour 150 μg/m3 — —

Lead Quarterly Average — 1.5 μg/m3Same as primary

Notes: (a) Standards other than the 1-hour ozone, 24-hour PM10, and those based on annual averages are not to be 

exceeded more than once a year.

(b) To attain the 8-hour ozone standard, the 3-year average of the fourth highest daily maximum 8-hour 

average ozone concentrations measured at each monitor within an area over each year must not exceed 

0.075 ppm.

(c) Concentrations are expressed in units in which they were promulgated: μg/m3= micrograms per cubic 

meter and ppm = parts per million. Units shown as μg/m3are based upon a reference temperature of 25 oC 

and a reference pressure of 760 mm of mercury.

(d) Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the 

public health.

(e) Secondary Standards: The levels of air quality necessary to protect the public welfare from any known 

or anticipated adverse effects of a pollutant.

μg/m3= micrograms per cubic meter; ppm = parts per million

Federal Regulations

The Federal Clean Air Act (CAA) of 1970 and its subsequent amendments established air quality 

regulations and authorized the Environmental Protection Agency (EPA) to develop NAAQS for 

several criteria pollutants known to be a threat to human health and welfare. Enforcement of these 

standards has been delegated to the states.
Air Quality Replacement Pages

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 7

The EPA announced revised standards for ozone on March 12, 2008, of 0.075 ppm for the annual 

fourth highest daily maximum 8-hour concentration average over 3 years. With these new 

standards, some areas in northwestern New Mexico that had been in attainment under the old 

standards are very close to nonattainment under the new standards (NMED, 2009).

In 2004, EPA adopted a comprehensive national program to reduce emissions from future 

nonroad diesel engines by integrating engine and fuel controls together. These standards will 

substantially control sulfur, NOx and PM emissions. Fuel standards became effective in 2010 and 

the final Tier IV engine standards became effective in 2008 and will be fully phased in by 2014 

for new engines that meet certain requirements.

EPA is under a court ordered deadline to complete a suite of regulations reducing emissions from 

the oil and gas industry by April 3, 2012. In July 2011, the EPA proposed a suite of standards to 

reduce emissions of smog-forming volatile organic compounds (VOCs) and air toxics from the 

oil and natural gas industry. The proposed rules also would significantly reduce methane, a potent 

greenhouse gas.

Any sources that have the potential to emit more than 250 tons of any criteria pollutant per year 

(or certain listed sources that have the potential to emit more than 100 tons per year) are required 

to submit a preconstruction Prevention of Significant Deterioration (PSD) Permit Application, 

including a regulatory PSD Increment Consumption Analysis under the Federal New Source 

Review permitting regulations. However, individual oil and gas well developments typically fall 

below these levels and are not subject to PSD analysis or regulation. PSD Class I increment 

thresholds are shown in table OGS-2.

Table OGS-2. Applicable prevention of significant deterioration increment values

Pollutant Averaging 

Time

PSD Class I 

Increments (μg/m3)

PSD Class II Increments 

(μg/m3)

Nitrogen Dioxide Annual 2.5 25

PM10 24-hour 8 30

Annual 4 17

Sulfur Dioxide 3-hour 25 512

24-hour 5 91

Annual 2 20

Mandatory Federal Class I areas were designated by the U.S. Congress in the Clean Air Act 

Amendments of 1977. Wilderness areas greater than 5,000 acres and national parks greater than 

6,000 acres which were in existence at that time are considered Class I under the Clean Air Act 

and receive the highest level of protection. All other Federal land in the country is designated as 

Class II areas with less stringent requirements, though Federal land managers are also responsible 

for protecting air quality related values (AQRVs) in these areas as well (tables OGS-3a through 

3e). Sources subject to the PSD permit review procedures are required to demonstrate that 

impacts to AQRV in Class I areas will be below Federal Land Managers’ Air Quality Related 

Values Workgroup (FLAG) ―Limits of Acceptable Change‖ (FLAG 2000). 
Air Quality Replacement Pages

8 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

San Pedro Parks Wilderness, adjacent to the project area, was established in 1964 and is a 

mandatory Class I area. Under the Clean Air Act, Federal land managers (in this case the forest 

supervisor of the Santa Fe National Forest and the Southwestern Regional Forester) are charged 

with ―... an affirmative responsibility to protect the air quality related values (including visibility) 

of any such lands within a Class I area...‖ 

New Mexico Rules and Regulations 

The NMED-AQB enforces national and State ambient air quality standards by developing rules to 

regulate and permit stationary sources of air pollutant emissions. The New Mexico air quality 

regulations are found in the New Mexico Administrative Code (NMAC) Title 20, Chapter 2. Any 

new emission source proposed for the Santa Fe National Forest would have to comply with the 

NMED-AQB regulations and ambient air quality standards. The following summarizes the more 

pertinent State air quality regulations that could apply to project emission sources. 

20.2.33 NMAC—Gas Burning Equipment—NO2. New/existing natural gas 

burning equipment that has a heat input of greater than 1 million British Thermal 

Units (BTUs) per hour shall not produce NO2 emissions that exceed 0.2/0.3 

pounds per million BTUs of heat input. 

20.2.35 NMAC—Natural Gas Processing Plant - Sulfur. Part 35 regulates sulfur 

emissions from existing/new gas processing facilities. 

20.2.60 NMAC—Open Burning. Part 60 outlines the requirements for burning 

small amounts of clean vegetative material. Part 60 allows the open burning of 

natural gas at gas plants and compressor stations and when used or produced in 

drilling, completion, and workover operations on oil and gas wells, when 

necessary to avoid serious hazard to safety.

20.2.70 NMAC—Operating Permits. Part 70 provides permitting requirements 

for stationary sources that exceed 100 tons per year (TPY) of a regulated 

pollutant, 10 TPY of a hazardous air pollutant (HAP), or 25 TPY of combined 

HAPs. Requirements include emission calculations, dispersion modeling 

analyses to ensure that the proposed source does not exceed any ambient air 

quality standard, and annual reporting. 

20.2.72 NMAC—Construction Permits. Part 72 applies to new or modified 

stationary sources that (1) have a potential emission rate greater than 10 pounds 

per hour or 25 TPY of any air pollutant for which there is a national or State 

ambient air quality standard or (2) exceed hourly HAPs emission levels outlined 

in Section 20.2.72.502 NMAC. Requirements of Part 72 may include: (1) 

emission calculations; (2) dispersion modeling analyses to demonstrate that the 

proposed source would not contribute to an exceedance of an ambient air quality 

standard or Prevention of Significant Deterioration increment; (3) a 

determination that the proposed source would not significantly impact air quality 

within pristine Federal Class I areas (such as national parks greater than 6,000 

acres or wilderness areas greater than 5,000 acres); and (4) public notifications. 

20.2.73 NMAC—Notice of Intent and Emissions Inventory Requirements. Part 73 

requires new or modified stationary sources that have potential emission rates 
Air Quality Replacement Pages

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 9

greater than 10 TPY of any regulated air contaminant or one TPY of lead, but less 

than the emission rates that would require a permit under 20.2.72 NMAC, to file 

a Notice of Intent prior to construction. Annual emission inventories are required 

of sources subject to 20.2.70 NMAC; the NMED-AQB may also require smaller 

sources to submit emission inventories. 

20.2.74 NMAC—Permits—Prevention of Significant Deterioration (PSD). The 

PSD requirements apply to: (1) 28 identified stationary source types that emit or 

have the potential to emit more than 100 TPY of any pollutant for which there is 

a national ambient air quality standard; (2) any other stationary source that emits 

or has the potential to emit 250 TPY or more of any pollutant for which there is a 

national ambient air quality standard; or (3) a stationary source that emits or has 

the potential to emit 100,000 tons per year of CO2 equivalent as of July 1, 2011. 

Requirements include air monitoring, emission calculations, dispersion modeling 

analyses, implementation of best available control technologies (BACT), and a 

determination that the proposed source will not significantly impact air quality 

within pristine Federal Class I areas. Within the project region of influence, these 

areas could include the Mesa Verde National Park and Weminuche Wilderness in 

Colorado, and the San Pedro Parks Wilderness and Bandelier National 

Monument in New Mexico. 

In 2009, the New Mexico legislature enacted legislation which allows the Environmental 

Improvement Board to develop regulations to control emissions in areas which are within 95

percent of the national ozone standard. Monitors in San Juan County are under this level.

Region of Influence

Identifying the region of influence for air quality effects requires knowledge of the types of 

pollutants being emitted, pollutant emission rates, topography, and meteorological conditions. 

The region of influence for inert pollutants (pollutants other than ozone and its precursors) is 

generally limited to a few miles downwind from a source, though there are cases when PM10 and 

PM 2.5 are transported much further.

The region of influence for ozone can extend much farther downwind than for inert pollutants. 

Ozone is a secondary pollutant formed in the atmosphere by photochemical reactions of primary 

pollutants or precursors (i.e., VOCs and NOx). In the presence of solar radiation, the maximum 

effect of VOCs and NOx emissions on ozone levels usually occurs several hours after they are 

emitted and many miles from the source. Therefore, the region of influence for ozone may 

include much of the north-central portion of New Mexico and southern portion of Colorado.

Baseline Air Quality 

The EPA has designated all areas of the United States as having air quality better than 

(attainment) or worse than (nonattainment) the NAAQS. A nonattainment designation generally 

means that a primary NAAQS standard has been exceeded more than once per year in a given 

area though the standards for some pollutants, such as ozone, are more complex and may require 

multiple year averages to exceed a certain level. Areas without sufficient data to determine the 

attainment/nonattainment status are designated as ―unclassified.‖ At the present time, the entire 

study area (and all of Rio Arriba County and Sandoval County) is in attainment or unclassified for 
Air Quality Replacement Pages

10 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

all national and State ambient air quality standards. EPA evaluated monitoring data from 2008 

through 2010 and determined that all areas of New Mexico are in attainment of the standard (EPA 

2012). 

In general, concentrations of ozone (O3) are highest during the summer months and coincide with 

the season of maximum sun angle which results in the strongest solar radiation reaching the 

earth’s surface. While winter ozone events have occurred in areas of oil and gas development in 

Wyoming and Colorado, no such events have been observed in New Mexico.

Inert pollutant concentrations tend to be the greatest during periods of light winds, stable 

atmospheric conditions, and surface-based temperature inversions. These conditions limit 

atmospheric dispersion. However, in the case of PM10 concentrations from fugitive dust episodes, 

maximum impacts within the study area often occur during high wind events and/or in proximity 

to manmade ground-disturbing activities, such as agricultural tilling, vehicular activities on 

unpaved surfaces, and mining operations. 

Presently, there is one monitoring station within the study area. The Interagency Monitoring for 

Protection of Visual Environments (IMPROVE) aerosol station on Eureka Mesa is maintained by 

the Santa Fe National Forest to monitor pollutants contributing to visibility reduction in San 

Pedro Parks Wilderness. Trends in visibility are presented below. Although there are no other air 

quality monitoring stations in Rio Arriba County or the study area, the overall air quality of the 

region can be conservatively represented by data measured at the Bloomfield, Navajo Lake, and 

Farmington stations in nearby San Juan County to the west, as well as by data from monitoring 

stations located in southeast Sandoval County (tables OGS-3a, 3b, 3c, 3d, and 3e).

The Bloomfield station is located within the highly industrialized Bloomfield gas corridor and the 

NMED-AQB uses this station to monitor ambient pollutant levels from oil and gas sources and 

power plants in the Four Corners area (NMAQB 2001a). Monitors in southeast Sandoval County 

may be influenced by automobile traffic in this rapidly developing area. Tables OGS-3a through 

3e present the maximum pollutant levels monitored at the stations located in San Juan and 

Sandoval Counties from 2006 through 2011, however, the data from 2011 has not yet been 

through quality assurance (EPA, 2009). Note that the 8-hour ozone standard applies to the 3-year 

average of the fourth highest value, not the individual annual maximum values.
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Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 11

Table OGS-3a. Maximum pollutant concentrations (Ozone and PM10) monitored near the study area, 2006-2011

Year

Ozone

8 Hour (ppm) (4th highest) Standard = 0.075 ppm

PM10

24 Hour (ug/m3) Standard = 150 ug/m3

Bloomfield San Juan 

Substation

Navajo 

Lake

Rio 

Rancho

Near 

Bernalillo

Jemez 

Pueblo Bloomfield San Juan Substation

Navajo 

Lake Bernalillo Jemez Pueblo

Crownpoint, 

NM, Navajo 

Nation

200610.063 0.071 0.079 0.074 0.064 0.072 ND 41 ND 33 233 ND

2007 0.069 0.073 0.079 0.071 0.063 0.067 ND 31 ND 30 251 ND

200820.063 0.069 0.069 0.065 0.057 0.065 ND 116 ND 31 145 105

2009 0.052 0.059 0.061 0.063 0.062 0.061 ND 73 ND 45 82 138

2010 0.065 0.063 0.069 ND 0.062 0.063 ND 22 ND 22 84 33

201130.066 0.068 0.074 ND 0.061 0.064 ND 38 ND 62 ND 37

Notes: San Juan Substation is located in Waterflow, NM, west of Farmington, NM.

Navajo Lake data is not reported to EPA, since the monitor is not a Federal Reference Monitor (FRM) nor a Federal Equivalent Monitor (FEM).

1

 PM10 regulation effective (This standard is not to be exceeded more than once per year on average over 3 years)

2

 Ozone regulation effective (This standard is calculated as the 3-year average, of the fourth-highest daily maximum 8-hr concentration) 

3

 Data for year 2011 are incomplete but represent the latest available through Dec. 2, 2011, though they have not yet been QA/QC’d.

Key: ND = No Data; ug/m3 = micrograms per cubic meter; ppm = parts per million

Table OGS-3b. Maximum pollutant concentrations (PM2.5) monitored near the study area, 2006-2011

Year

24 Hour (ug/m3) Standard (98th percentile) = 35 ug/m3 Annual Mean (ug/m3) Standard = 15 ug/m3

Bloomfield San Juan 

Substation

Navajo 

Lake

Rio 

Rancho

Jemez 

Pueblo

Zia 

Pueblo Bloomfield San Juan Substation

Navajo 

Lake

Rio 

Rancho

Zia 

Pueblo

Jemez 

Pueblo

20061 ND 13.0 ND 13.6 42.7 18.1 ND 6.06 ND 5.23 7.72 10.39

2007 ND 17.4 ND 22 19.2 14.2 ND 5.96 ND 5.03 7.59 7.70

2008 ND 14.4 ND 10.1 72.4 ND ND 5.91 ND 4.32 ND ND

2009 ND 10.4 ND 10.0 32.4 ND ND 4.42 ND 3.75 ND ND

2010 ND 18.0 ND ND 19.2 ND ND 5.02 ND ND ND ND

20112 ND 12.5 ND ND ND ND ND 4.30 ND ND ND ND

Notes: San Juan Substation is located in Waterflow, NM, west of Farmington, NM.

Navajo Lake data is not reported to EPA, since the monitor is not a Federal Reference Monitor (FRM) nor a Federal Equivalent Monitor (FEM).

1

 PM2.5 regulation effective (The 24-hour standard is calculated as the annual mean, averaged over 3 years. The annual standard is this calculated as the 98th percentile, averaged 

over 3 years)

2

 Data for year 2011 are incomplete but represent the latest available through Dec. 2, 2011, though they have not yet been QA/QC’d.

Key: ND = No Data; ug/m3 = micrograms per cubic meter; ppm = parts per million
12 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Air Quality Replacement Pages 

Table OGS-3c. Maximum pollutant concentrations (NO2) monitored near the study area, 2006-2011

Year

24 Hour (ppm) Standard = 0.10 ppm Annual Mean (ppm) Standard = 0.50 ppm 1 Hour (ppm) Standard = 0.10 ppm (3 yr 

average of 98th percentile)

Bloomfield San Juan 

Substation

Navajo 

Lake

Rio 

Rancho Bloomfield San Juan Substation

Navajo 

Lake

Rio 

Rancho Bloomfield San Juan Substation Navajo Lake

200610.029 0.049 0.033 0.027 0.013 0.012 0.01 0.01 ND ND ND

2007 0.035 0.037 0.030 0.026 0.015 0.010 0.01 0.008 ND ND ND

2008 0.033 0.027 0.024 0.026 0.015 0.006 0.009 0.007 0.046 0.035 0.039

2009 0.030 0.030 0.030 ND 0.021 0.006 0.008 0.022 0.034 0.035 0.040

201020.028 0.038 0.030 ND 0.012 0.009 0.009 ND 0.041 (0.040) 0.041 (0.037) 0.037 (0.039)

201130.035 0.023 0.032 ND 0.012 0.011 0.008 ND 0.045 0.035 0.040

(Data from NMED, 2011)

Notes: San Juan Substation is located in Waterflow, NM, west of Farmington, NM.

1

 24-hour nitrogen dioxide concentrations were conservatively estimated as one half the maximum 1-hour concentration and became effective in 2006. 

2

 NO2 1 hour regulation effective. It is calculated based on the 3-year average of the 98th percentile of the yearly distribution of 1-hour daily maximum concentrations.

3

 Data for year 2011 are incomplete but represent data through June 30, 2011, though they have not yet been QA/QC’d

Key: ND = No Data; ug/m3 = micrograms per cubic meter; ppm = parts per million

Table OGS-3d. Maximum pollutant concentrations (SO2) monitored near the study area, 2006-2011

Year

New Mexico 24 Hour (ppm) Standard = 0.10 ppm New Mexico Annual Mean (ppm) Standard = 0.02 ppm

Bloomfield San Juan 

Substation

Navajo 

Lake

Rio 

Rancho

Near 

Bernalillo Bloomfield San Juan Substation

Navajo 

Lake

Rio 

Rancho

Near 

Bernalillo

2006 0.003 0.013 ND ND ND 0.001 0.002 ND ND ND

2007 0.002 0.013 ND ND ND 0.001 0.002 ND ND ND

2008 0.002 0.004 ND ND ND 0.001 0.001 ND ND ND

2009 0.003 0.005 ND ND ND 0.002 0.003 ND ND ND

201010.002 0.002 ND ND ND 0.001 0.002 ND ND ND

201120.003 0.003 ND ND ND 0.002 0.003 ND ND ND

Notes: San Juan Substation is located in Waterflow, NM, west of Farmington, NM.

1

 SO2 NAAQS regulations effective. It is calculated based on the 99th percentile of 1-hour daily maximum concentrations, averaged over 3 years.

2

 Data for year 2011 are incomplete but represent the latest available through Dec. 2, 2011, though they have not yet been QA/QC’d.

Key: ND = No Data; ug/m3 = micrograms per cubic meter; ppm = parts per million
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Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 13

Table OGS-3e. Maximum pollutant concentrations (SO2) monitored near the study area, 2009-2011

Year

National 3 Hour (ppm) Standard = 0.5 ppm National 1 Hour (ppm) Standard = 0.075 ppm

Bloomfield San Juan 

Substation

Navajo 

Lake

Rio 

Rancho

Near 

Bernalillo Bloomfield San Juan Substation

Navajo 

Lake

Rio 

Rancho

Near

Bernalillo

2009 0.005 0.020 ND ND ND 0.005 0.025 ND ND ND

201010.004 0.010 ND ND ND 0.006 0.014 ND ND ND

201120.004 0.010 ND ND ND 0.009 0.017 ND ND ND

Notes: San Juan Substation is located in Waterflow, NM, west of Farmington, NM.

1

 SO2 NAAQS regulations effective. It is calculated based on the 99th percentile of 1-hour daily maximum concentrations, averaged over 3 years.

2

 Data for year 2011 are incomplete but represent the latest available through Dec. 2, 2011, though they have not yet been QA/QC’d.

Key: ND = No Data; ug/m3 = micrograms per cubic meter; ppm = parts per million
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14 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Visibility Trends 

The San Pedro Parks Wilderness, a mandatory Class 1 area for air quality, is directly adjacent to 

the project area. An IMPROVE monitoring site was established on Eureka Mesa near the 

southern boundary of the wilderness and within the project area in August of 2000. 

Figure OGS-1 shows visibility trends on the best 20 percent of days in San Pedro Parks 

Wilderness from 2001 to 2009 (note that a downward trend indicates improving visibility). Also 

shown are baselines established for 2000 to 2004, a baseline for 2005 to 2009, as well as 

monitored data from 2001 through 2009. Also included are projections for 2018, based on a 2005 

emissions inventory of the South San Juan Basin, assuming projected development and the 

regulatory requirements in 2005. The most recent data from 2009 and the current trend based on 

the monitored data is less than the 2018 projection. Lastly, the visibility improvements required to 

meet national visibility goals by 2064 are included. In this case, when measured in deciviews 

(dv)—an index in which one unit is equivalent to the change in visibility noticeable by the human 

eye—visibility on the best days already exceeds the 2064 goal. When measured in light 

extinction, the current readings are ahead of the glide path (the rate at which improvements must 

occur in order to meet the 2064 goal) but some further improvement is needed.

(VIEWS, 2011)

Figure OGS-1. Visibility trends on the 20 percent best days at San Pedro Parks Wilderness 

Figure OGS-2 shows the visibility trends at San Pedro Parks Wilderness on the 20 percent worst 

days. The baselines and projections are based on the same assumptions as in figure OGS-1, 

except they are based on the 20 percent worst days at San Pedro Parks Wilderness. Additionally, 

the glide path necessary to meet the 2064 visibility goals is included. The monitored data and 

current trend based on this data are below the current glide path and the 2018 projections.

However, some improvements will be required in order to meet the 2064 visibility goal at San 

Pedro Parks Wilderness, whether measured in deciviews or light extinction.
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Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 15

(VIEWS, 2011)

Figure OGS-2. Visibility trends on the 20 percent worst days at San Pedro Parks 

Wilderness

Visibility impacts are generally assessed in terms of ―natural background‖ or the expected 

visibility in the absence of human emission sources. The Federal land managers responsible for 

Class I areas have developed natural background visibility estimates for Class I areas (FLAG, 

2000). This document suggests natural background visibility ranges, for light extinction, should 

be between 15.6 to 18 Mm-1 for Class I areas in the western United States. At San Pedro Parks 

Wilderness, monitored data in 2009 (14.91 Mm-1) for the 20 percent worst visibility days was 

degraded when compared to the natural background visibility (10.16 Mm-1). 

The Reasonably Foreseeable Development Scenario (RFDS) (USFS 2004a) does not identify any 

areas adjacent to San Pedro Parks Wilderness as likely for new well development. The closest 

area where new wells are expected is approximately 10 miles northwest of the wilderness 

boundary. 

Visibility trends in San Pedro Parks Wilderness are not solely dependent on oil and gas 

development but are also impacted by point sources such as the San Juan Generating Station and 

Four Corners Power Plant which will be required to reduce emissions contributing to visibility 

reduction under the Regional Haze rule. Population increases which result in higher emissions 

from vehicular traffic can also impact air quality related values. Although extensive oil and gas 

development has occurred in the San Juan Basin in recent years, and natural background visibility 

is currently degraded, the trends in visibility have been improving and do not indicate any 

significant deterioration in visibility has occurred over the last decade. 

Regional Air Emissions

The NMED-AQB compiles countywide emission inventories for stationary sources that are 

subject to 20.2.70 NMAC. Additionally, the EPA estimates point, area, and mobile source 

emissions, which are part of their National Emission Trends database. Table OGS-4 summarizes 

the mobile and stationary source emissions that occurred in Rio Arriba County during 2008 (EPA 

2011a). 
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16 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Table OGS-4. Summary of 2008 annual emissions by source category for Rio Arriba 

County (in tons per year)

Source Category VOC CO NOx SOx PM10

Fuel Combustion—Electric Utilities 1.3 18.6 36 — 0.18

Fuel Combustion—Industrial 656 2,182 1,656 — 15.9

Fuel Combustion—Other 70.4 400 55.8 1.5 55.2

Petroleum and Related Industries 133 1.07 4.05 9.31 0.2

Solvent Utilization 313 — — — —

Storage and Transport 984 — — — —

Other Industrial Processes 1.47 3.87 — — 10.4

Waste Disposal and Recycling 32.7 348 17.6 2.2 95.7

Highway Vehicles 892 10,802 1,131 10.3 33.5

Off-Highway Vehicles 605 2,419 209 3.2 21.9

Miscellaneous — — — — 46,824

Total Source Emissions 3,689 16,174 3,111 26.6 47,057

Source: EPA 2011a

Natural gas production and transmission (―Petroleum and Related Industries,‖ table OGS-4

above) has the greatest number of stationary sources in the project region yet produces low 

emissions compared to other stationary sources. Fugitive dust from area sources produces the 

majority of PM10 in the region. On-road vehicles (a mobile source) produce a large percentage of 

combustion emissions in the region and are the main source of carbon monoxide. Table OGS-5

provides similar information for Sandoval County. 

In addition to the official emissions inventory data available from EPA presented in tables OGS-4

and 5, an inventory was conducted for the New Mexico Environment Department for ozone 

precursors in Rio Arriba and San Juan Counties for 2002 (Environ, 2006). This report indicates 

Table OGS-5. Summary of 2008 annual emissions by source category for Sandoval County

(tons per year)

Source Category VOC CO NO2 SO2 PM10

Fuel Combustion – Industrial 18.5 196 138 2.74 32.8

Fuel Combustion – Other 205 1,151 117 3.8 161

Petroleum and Related Industries 10.4 — — — —

Solvent Utilization 814 — — — —

Storage and Transport 628 4.0

Other Industrial Processes 5.5 28.7 20.4 0.12 36.4

Waste Disposal and Recycling 303 4,254 136 2.6 505

Highway Vehicles 1,845 21,888 2,430 26.2 70.6

Off-Highway Vehicles 341 2,635 359 6.7 30.3

Miscellaneous — — — — 36,199

Total Source Emissions 4,170 30,153 3,200 42.2 37,039

Source: EPA 2011a
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Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 17

that VOC and NOx emissions from sources like the petroleum industry in Rio Arriba County may 

be significantly underestimated. Historically, emissions from large stationary sources related to 

oil and gas processing are regulated through existing permitting programs, while smaller sources 

(compressor engines, drill rigs, heaters, dehydrators, tank vents, flares, etc.) fell below permitting 

thresholds. Individually, emissions from these smaller sources could be considered minor. 

However, increasing energy demands and continuing oil and gas field development make the 

cumulative effect of emissions from these smaller sources a significant issue, and were generally 

incompletely quantified. 

In 2009, the Western Regional Air Partnership (WRAP) completed their Phase III Emissions 

Inventory for the South San Juan Basin, which includes San Juan, Rio Arriba, Sandoval, and 

McKinley Counties. This emissions inventory is much more representative of the emissions in 

this region from oil and gas in that it includes emissions from smaller sources. It does not,

however, include PM emissions from fugitive dust related to construction and traffic on dirt roads 

in the area. The WRAP Phase III emissions inventory includes emissions for 2006 and projects 

emissions into 2012 from the oil and gas industry in the South San Juan Basin. Table OGS-6

presents the total number of wells in this basin. The total number of wells includes both 

conventional oil and gas wells as well as coal bed methane wells. Overall, the total number of 

wells is expected to increase in the entire basin by about 12 percent from 2006 to 2012.

Table OGS-6. Number of wells in the South San Juan Basin

Year

Well Count

Total

2006 20,649

2012 (projected) 23,119

(Environ, 2009 b&c)

Notes: South San Juan Basin includes San Juan, Rio Arriba, Sandoval, and 

McKinley Counties. Total wells include both conventional oil and gas wells 

and coal bed methane.

Tables OGS-7 and 8 present emissions from 2006 and projected emissions for 2012 for NOx, 

VOCs, CO, SOx and PM for the four counties in the South San Juan Basin. While emissions 

based on the WRAP Phase III are far greater than what has been reported to EPA for major 

sources, all monitoring sites currently show the area to be in attainment of the NAAQS. 

Table OGS-7. WRAP Phase III baseline 2006 oil and gas emissions by county

County/Basin

Emissions (tons per year)

NOx VOC CO SOx PM

McKinley 911 88 179 1 6

Rio Arriba 13,453 27,248 8,510 69 157

San Juan 27,517 32,685 14,611 231 405

Sandoval 194 676 170 3 5

South San Juan Basin 42,075 60,697 23,471 305 574

(Environ, 2009b)
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18 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Table OGS-8. WRAP Phase III projected 2012 oil and gas emissions by county 

County/Basin

Emissions (tons per year)

NOx VOC CO SOx PM

McKinley 873 73 171 1 6

Rio Arriba 13,858 24,875 9,378 7 141

San Juan 28,134 30,174 15,705 124 372

Sandoval 185 584 167 0 3

South San Juan Basin 43,050 55,705 25,421 132 523

(Environ, 2009c)

The 2012 projections assume growth in development of oil and gas wells based on recent 

trajectories and applies ―on the books‖ regulations and control measures as of 2006. The ―on the 

books‖ regulations affecting oil and gas include: a predicted fleet mix of engines, from baseline 

uncontrolled engines to Tier IV engines based on typical fleet turnover for drilling rigs and 

workover rigs; nonroad diesel sulfur standards phased in in 2010 with a 15 ppm sulfur limit for 

nonroad diesel fuel; NSPS regulations covering new stationary, spark-ignited engines of various 

horsepower classes; and BLM COA after 2005, requirements for new or relocated wellhead 

compressor engines to meet a 2.0 g/hp-hr NOx emission standard.

While wells in the basin are expected to increase by 12 percent from 2006 to 2012, emissions for 

each of the pollutants listed in tables OGS-7 and 8 are not projected to increase at this rate.

Emissions of NOx and CO are expected to increase the most, approximately 2 and 8 percent

respectively. Emissions of VOCs, PM from engines, and SOx are expected to decrease over this 

same period, 8, 8, and 56 percent respectively, as a result of new regulations that were on the 

books at the time of the modeling but became effective after 2006.

Environmental Consequences

As of 2008, there were 21,725 active oil and gas wells existing in the San Juan and Rio Arriba 

Counties (Environ, 2009). At the current time the area meets all State and Federal air quality 

standards, though the monitored values at Navajo Lake have come close in the last few years to 

exceeding the NAAQS for ozone.

In 2001, the BLM’s Farmington Field Office prepared a Reasonable Foreseeable Development 

(RFDS) scenario for the San Juan Basin (Engler, et al., 2001). Gore (USFS 2004a) extracted the 

portion of the San Juan Basin which occurred on the Santa Fe National Forest from the Engler 

report to create the 20-Year RFDS for the Santa Fe National Forest. As of April 2011, this 

analysis was still valid and projects 11 new gas wells in the Pictured Cliffs sandstone formation 

and 9 new oil and gas wells in the Mancos shale formation. Since 2005, two new Mancos wells 

have been drilled, and two more are proposed. Production is occurring from the Pictured Cliffs

formation, but no new wells have been drilled or proposed. There has not been any industry 

interest in the Nacimiento, Fruitland Coal, or Entrada Formations.

When new wells are constructed, there are short-term impacts to air quality associated with 

developing roads, pipelines, wells pads, drilling wells, and any completion fracturing and flaring 

that could occur when developing a well. Also included are emissions from construction vehicles 

as well as fugitive dust associated with driving on unpaved roads. Typically, the initial 
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Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 19

construction associated with developing an individual well produces the greatest amount of 

emissions, when compared to either the annual emissions for general maintenance or when wells 

need to be ―worked over‖ to maintain or enhance production. While well development may 

produce the greatest amount of emissions at any given time, these impacts to air quality only 

occur for 1 to 2 months. 

Once a well has been developed, emissions from day-to-day operations will result in impacts to 

air quality. On an annual basis, these emissions are not as great as those associated with 

developing wells, but they may last for years, or as long as the well is productive. Emissions from 

day-to-day operations can include those from production traffic and the associated fugitive dust, 

well head separator/tank flashing, dehydrators, compression stations, well head engines, heaters,

and fugitive VOCs from pits.

Based on the location of the oil or gas in a given formation, there will be differences in how a 

well would be developed and also in the day-to-day operations of the well, which will affect the 

magnitude of impacts to air quality. For example, the Pictured Cliffs wells are gas wells that are 

generally completed to be free flowing, so no artificial lift is needed. Therefore, no small engines 

are required to pump gas to the surface and no well head compression is used. Based on the 

current level of industry interest and the density of development in the area, no additional 

compressors are expected to be needed for these projected wells. Alternatively, the Mancos wells

are usually shallow (less than 4,000 feet deep) and produce a combination of oil, natural gas, and 

water. In most cases, a pumping unit (pump jack) is needed to lift the oil and water to the surface.

Pump jacks are commonly powered by a single cylinder engine powered by natural gas produced 

at the site. The engines range from 12 horsepower (hp) to 27 hp, with an estimated average of 20 

hp. Separator units are used at most of these wells to separate the production stream into oil, 

natural gas, and water. The separator units are heated by natural gas burners to facilitate this 

separation. At these wells, the oil and natural gas are generally transported by pipelines, but the

produced water is stored in onsite tanks and hauled from the site in tanker trucks. The amount of 

water produced is highly variable, but hauling one tanker a month is reasonable. For wells in 

either the Pictured Cliffs or Mancos formation, periodic visits by company personnel are 

required, but the use of radio frequency reporting technology means these visits only occur two or 

three times a week.

Since 1998, only 4 wells have been developed on the Santa Fe National Forest and if this trend 

continues, it is unlikely that 20 wells would be developed in the next 20 years. However, this 

analysis assumes that 20 wells will be developed in this time period as projected in the RFDS 

(USFS 2004a).

Effects 

Under Alternative 1, the No Action Alternative, lands would still be available for leasing but 

leases would be issued with stipulations specified in the Forest Plan (1987 as amended). Under 

Alternative 2 specific stipulations would be applied to protect surface resources. Alternative 3 is 

similar to Alternative 2, but provides for further acreage of no surface occupancy lease 

stipulations. As projected by the RFDS prepared for the Santa Fe National Forest (SFNF) (USFS 

2004a), all of the alternatives have the potential for an additional 20 wells over the next 20 years.

While there are no expected differences to impacts to air quality between the three alternatives, it 

has been determined that the Forest Plan and its analysis (Final EIS) did not address the potential 

environmental effects of future leasing and development on the SFNF sufficiently enough to 
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20 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

make new lease issuance decisions. As a result, this analysis examines the effects to air quality of 

developing 20 new wells over the next 20 years. The actual effects of these wells would only 

occur once they have been analyzed and authorized through a site-specific NEPA decision at the 

time of application to drill. 

This analysis compares an emissions inventory developed for 20 wells on the SFNF, to current 

estimates for emissions in the South San Juan Basin. Current monitored data is also considered to 

assess potential effects to air quality if 20 wells were developed on the SFNF. Lastly, existing 

modeling studies were analyzed for potential impacts. Due to the small number of wells that may 

be developed on the Santa Fe National Forest, it was impractical to directly model the emissions 

of 20 new wells due to the economic cost of this analysis. In addition, the results from such an 

analysis would likely be within the uncertainty of the models due to the small number of wells 

that could potentially be developed, relative to the amount of current production already ongoing 

in the basin.

For this analysis, an emissions inventory used in the upper San Juan Basin, originally developed 

for the supplemental draft EIS for the San Juan Plan Revision was modified to better represent the 

RFDS for the SFNF (Hall, 2011). Construction emissions included for this analysis are those 

associated with developing roads, pipelines, wells pads, drilling wells, and any completion 

fracturing and flaring that could occur when developing a well. Also included are emissions from 

construction vehicles as well as fugitive dust associated with driving on unpaved roads.

Emissions from day-to-day operations were also calculated, including production traffic and the 

associated fugitive dust, well head separator/tank flashing, dehydrators, well head engines, and 

heaters. Based on the current level of industry interest and density of development in the area, no 

additional compressors are expected to be needed for these projected wells and, therefore, the 

associated emissions were not included.

While there are expected differences in the types of production necessary at wells associated with 

each formation, a conservative approach was taken, which assumed that artificial lifts, separators, 

and well head heaters were used at all wells. In addition, it was assumed all wells would be 

developed individually and there would not be multiple wells per pad. Most significantly, the 

2010 nonroad diesel sulfur standards with a 15 ppm sulfur limit were not included in the 

emissions estimates, which assumed the previous standard of 500 ppm sulfur content.

Additionally, the emissions inventory assumes no new regulations would occur in the next 20 

years, which may limit emissions. 

Table OGS-9 presents estimated emissions for criteria pollutants associated with oil and gas 

development and VOCs. The maximum development scenario assumed that 20 wells would be 

developed in a single year and represents the upper limit of emissions that could result in air 

quality impacts. The last column represents emissions that would occur on an annual basis from 

production, assuming that all 20 wells were developed. While this is still a conservative estimate, 

as it assumes that 20 wells will be developed, it represents the lower limit of emissions in this 

analysis. Well head work-overs were not included in this analysis as they would be expected to 

fall somewhere in between the upper and lower bounds, presented.
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Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 21

Table OGS-9. Emissions estimated for 20 new wells (tons per year)

Pollutant

Construction Emissions 

Maximum Development 

(tpy)

Production Emissions, 

Maximum Development per 

Year (tpy)

NOx 21.2 7.3

CO 30.8 16.3

SO2 7.7 0.0

PM10 30.5 2.4

PM2.5 10.4 0.9

VOC 11.2 4.9

Table OGS-10 compares the estimates of emissions for the maximum development scenario of 

constructing 20 wells in a year for NOx, CO, SO2, and VOCs to the total emissions estimates 

from oil and gas development in Rio Arriba County based on the 2006 and 2012 WRAP 

emissions inventories (tables OGS-7 and 8) (Environ, 2009 b & c). With the exception of 

estimated SO2 emissions, the emissions from NOx, CO, and VOCs are less than 1 percent of the 

estimated emissions from the oil and gas industry in the county based on WRAP estimates. SO2

emissions estimates from construction of 20 new wells are greater than WRAP’s estimated 

emissions of SO2 in Rio Arriba County by over 11 percent in 2006 and more than double 

WRAP’s emissions estimates for 2012. However, there are two key factors to consider. First, the 

calculated emissions for the 20 well scenario do not consider the current nonroad diesel 

standards, with a 15 ppm sulfur limit, which is factored into the 2012 WRAP estimate; rather, it 

calculates SO2 emissions assuming diesel fuel with 500 ppm sulfur content. Second, the 20 wells 

have not been constructed and the measured values of SO2 in New Mexico in 2006 were far 

below the NAAQS. Even if the SO2 emissions were twice the estimated 7 tons in 2012, this 

would be approximately 21 percent of the estimated emissions for 2006 from this industry, due to 

new regulations that are currently on the books.

Table OGS-10. Construction emissions (20 wells) compared to WRAP 2006 and 2012 

estimates for Rio Arriba County for NOx, CO, SO2, and VOCs (tons per year)

(Environ, 2009 b & c)

Table OGS-11 compares the estimates of emissions for the maximum development scenario of 

constructing 20 wells in a year for PM10 to the total emissions estimates from oil and gas 

development in Rio Arriba County based on what was reported to EPA in 2008 (table OG-21) 

(EPA 2011a). These estimates were considered rather than the WRAP estimates because the EPA 

values include estimates of fugitive dust associated with driving on nonpaved surfaces, while the 

WRAP study does not. Since fugitive dust from driving on nonpaved surfaces was calculated for 

the construction emissions from 20 wells on the SFNF, this is a more appropriate comparison.

Pollutant

Construction Emissions 

Maximum Development 

Including Flaring (tpy)

WRAP 2006 

Rio Arriba

Construction 

Emissions as 

Percent of Total

WRAP 

2012 Rio 

Arriba

Construction 

Emissions as 

Percent of Total

NOx 21.2 13,453 0.2% 13,858 0.2%

CO 30.8 8,510 0.5% 9,378 0.4%

SO2 7.7 69 11.1% 7 109.8%

VOC 11.2 27,248 0.2% 24,875 0.3%
Air Quality Replacement Pages

22 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Based on this comparison, estimated PM10 emissions from constructing 20 new wells in 1 year 

results in less than 1 percent of the total PM10 emissions reported to EPA for 2008.

Table OGS-11. Construction emissions (20 wells) compared to EPA 2008 

estimates for Rio Arriba County for PM10 (tons per year)

Construction Emissions 

Maximum Development 

Including Flaring (tpy)

EPA 2008 

Emissions All 

Sectors

Construction 

Emissions as Percent

of Total

30.5 47,057 0.06%

(EPA 2011a)

As stated previously, New Mexico typically has very good air quality. Over the last several years,

air quality in the Four Corners region—as demonstrated in the ―Baseline Air Quality‖ section—is 

usually far below NAAQS and New Mexico standards. One exception has been ozone which has 

recently approached levels near the NAAQS.

Ozone forms when two pollutants—NOx and VOCs—react with sunlight. While the EPA did not 

lower the ozone NAAQS from 0.075 ppm in 2011, they have indicated that this standard will be 

reviewed in 2013. The ozone NAAQS is calculated as the average of 3 consecutive years of the 

fourth highest 8-hour average. The monitoring station located at Navajo Lake has had the highest 

measured levels of ozone in northern New Mexico. From 2008 to 2010, the official 3-year 

averages have been 0.075, 0.069, and 0.066 ppm respectively. Unofficially, the average ending in 

2011 was 0.068. It is unlikely that NOx and VOC emissions from 20 wells, which make up less 

than 1 percent of the emissions estimated from oil and gas in Rio Arriba County, would have a 

significant effect of contributing to an exceedance of the current national or New Mexico air 

quality standards, due to their small contribution and location in the basin.

Modeling of NOx for 694 wells on the Jicarilla Ranger District of the Carson National Forest—

which is less than 20 miles from the area of the Santa Fe National Forest where the most 

development is expected to occur according to the RFDS—showed that concentrations at Class 1 

areas in northern New Mexico and southern Colorado would be significantly less than the 

allowable PSD increments (USFS 2008), even with cumulative effects considered. It can, 

therefore, be concluded that impacts from 20 wells would be less than significant even at nearby 

San Pedro Parks Wilderness.

Additional modeling was completed as part of the work of the Four Corners Air Quality Task 

Force (Environ, 2009). This project models the air quality impacts of applying mitigation 

strategies for reduction of emissions from power plants and oil and gas development. The base 

case modeling for 2005 shows ozone levels in the vicinity of San Pedro Parks Wilderness to be 

between 0.065 and 0.069 ppm compared with the NAAQS for ozone of 0.075 ppm. The modeling 

study also shows virtually no change in the level of ozone between 2005 and 2018 base case 

(without mitigations) despite extensive oil and gas development in the region. The study analyzed 

the predicted sources of both ozone and PM in 2018 in the Four Corners area. These results 

showed that local oil and gas and electric generating units (EGUs) sources are the biggest 

contributors to ozone and PM concentration in the Four Corners area after contributions from 

outside the region. EGU and oil and gas together account for 75 percent of NOx emissions (oil 

and gas alone accounts for 37 percent NOx emissions) and 33 percent of VOC emissions in the 

2018 base case inventory. The study examined the potential effectiveness of various reductions to 

PM and ozone forming precursors (NOx and VOCs) that could be achieved through various 
Air Quality Replacement Pages

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 23

mitigation strategies applied to EGUs and the oil and gas industry. The scenario which applied the 

most stringent NOx and VOC emissions required EGU and the oil and gas industry to reduce NOx

and VOCs by 50 and 16 percent respectively. This mitigation scenario resulted in predicted ozone 

changes generally limited to less than about 5 ppb. However, as ozone standards are lowered, this 

reduction could be significant to ensuring continued attainment. In addition, oil and gas 

mitigations examined in this study did not have any significant visibility impacts, to Class 1 

areas, generally less than 0.5 dV. However, when added to other area source impacts, this could 

be significant in improving visibility.

On June 23, 2011, the U.S. Department of Agriculture (USDA), U.S. Department of the Interior 

(DOI), and U.S. Environmental Protection Agency (EPA) signed a memorandum of 

understanding (MOU) (OGS Appendix A) committing to a clearly defined approach for air 

quality analyses in NEPA analyses for oil and gas development on Federal lands. Agencies can 

consider applying the MOU to ongoing NEPA analyses, where commenters have questioned the 

adequacy of air quality analysis, if such analysis can be accomplished in a cost effective and 

timely manner.

Due to the small number of wells that may be developed on the Santa Fe National Forest, it was 

impractical to directly model the emissions of 20 new wells due to the cost of such an analysis. In 

addition, the results from such an analysis would likely be within the uncertainty of the models 

due to the small number of wells that could potentially be developed, relative to the amount of 

current production already ongoing in the basin. For example, the emission inventory produced 

for this analysis showed less than a 1 percent increase in all pollutants except SO2, when 

compared to the most current data available. Yet a 50 percent reduction in NOx and a 16 percent

reduction in VOCs in the 2009 ENVIRON modeling show a less than a 5 ppb reduction to 

predicted ozone levels. While this was the most effective scenario at reducing ozone 

concentrations, it applied reductions to both electric generating units (EGUs) as well as the oil 

and gas industry. As stated previously, both EGUs and the oil and gas industry in the region make 

up approximately 75 percent of the NOx emissions (33 percent of the VOC emissions), of which, 

the more than 20,000 wells and associated infrastructure make up about half of these emissions.

Lastly, both the ozone and visibility modeling done in ENVIRON’s 2009 study demonstrated 

virtually no change in the level of ozone between 2005 and 2018 despite extensive oil and gas 

development in the region and under various emissions reduction scenarios.

Cumulative Impacts

The development of 20 new locations is projected by the RFDS (USFS 2004a) to be reasonably 

foreseeable in the study area. Impacts associated with this well development would be adverse,

but less than significant, in that their development would not result in exceedences of State or 

Federal air quality standards, nor increases in visibility degradation at nearby Class I areas.

However, emissions from these wells would be in addition to those from the 21,725 active oil and 

gas wells existing in San Juan and Rio Arriba Counties in 2008 (Environ 2009) and any additional 

new development in the area. 

Modeling performed for a high density well development scenario for the ―Surface Management 

of Gas Leasing and Development, Jicarilla Ranger District, Carson National Forest‖ (USFS 2008) 

indicated that (1) maximum modeled impact concentrations would be less than the national or 

New Mexico ambient air quality standards and (2) risks from exposure to hazardous air pollutants 

would be less than significant, in that they are not expected to result in increased risk based on 
Air Quality Replacement Pages

24 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

EPA’s National Air Toxics Assessment (see next section). Impacts for well development in the 

San Juan Basin on the Santa Fe National Forest would be even less because there are no high 

density well areas (up to eight wells per square mile) as there are on the Carson National Forest. 

Furthermore, the Carson National Forest modeling analysis included a large 10,000-hp central 

compressor station that would not be needed for the lower density well operations in the San Juan 

Basin. 

Air quality impacts would occur during both well construction (due to surface disturbance by 

earth-moving equipment, vehicle traffic fugitive dust, well testing, and drilling rig and vehicle 

engine exhaust) and well production (including natural gas separation and dehydration heaters, 

compressors, and small well head engine exhausts). The maximum predicted ―near field‖ air 

pollutant concentrations associated with well development and production would occur close to 

the actual well location; so close that adding additional wells in other field locations would not 

increase the maximum predicted ―near field‖ concentrations (BLM 2002). 

Emissions from oil and gas well operation sources could disperse for long distances downwind 

and contribute to cumulative visibility impacts in PSD Class I areas and/or ozone impacts in areas 

nearing ozone nonattainment. Even though the contribution of impacts from this project is small 

and less than significant within the study area, the impact could become significant on a 

cumulative basis if it would cause or add to a new or existing problem of visibility degradation or 

ozone nonattainment. If the ozone NAAQS were to be lowered at any time in the next 20 years, 

any additional contribution of these pollutants could become a significant impact. Cumulative 

impacts could be reduced with application of recommended mitigation measures, but these would 

be far more effective if applied across the basin.

Modeling performed for the Four Corners area (Environ, 2009) shows virtually no change in 

ozone levels from 2005 to 2018 in the project area due to the application of emission controls on 

future developments. The study also indicated that much of the pollution contributing to high 

ozone levels is transported from outside the region. 

Other foreseeable future Santa Fe National Forest projects planned in or near the study area that 

may affect air quality—in combination with current and projected oil or gas well construction and 

production—are those that would result in surface disturbance, causing temporary decreases in air 

quality by increasing particulates. Projects 2, 3, 4, 6, 7, and 8 listed in table OG-15 (FEIS, chapter 

3, pages 75–76; www.fs.fed.us/r3/sfe/) are likely to result in short-term particulate matter (PM) 

sources that would add to those emissions projected from local and regional oil and gas 

development. Due to the temporary nature of air quality impacts from these Forest Service 

projects, the cumulative effects would not be significant over the long term.

Visibility trends in the San Pedro Parks Wilderness are not solely dependent on oil and gas 

development but are also impacted by point sources such as the San Juan Generating Station and 

Four Corners Power Plant which will be required to reduce emissions contributing to visibility 

reduction under the Regional Haze rule. Population increases which result in higher emissions 

from vehicular traffic can also impact air quality related values. Although extensive oil and gas 

development has occurred in the San Juan Basin in recent years, and natural background visibility 

is currently degraded, the trends in visibility have been improving and do not indicate any 

significant deterioration in visibility has occurred over the last decade. 
Air Quality Replacement Pages

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 25

Hazardous Air Pollutants (HAPs)

Hazardous air pollutants are those pollutants that cause or may cause cancer or other serious 

health effects—such as reproductive effects or birth defects—or adverse environmental and 

ecological effects. NMED is required to control 187 hazardous air pollutants, some of which are 

emitted by the oil and gas industry. NMED collects emissions data from major point sources and 

provides this to the EPA. Table OGS-12 lists the total amount of HAPs emitted from the oil and 

gas production, industrial process sector, for each county in the South San Juan Basin. Not 

included in this summary are HAPs emitted from mobile sources, such as trucks transporting 

people, equipment, and waste to and from wells, nonroad diesel engines related to this sector, 

storage and transport of product from the well sites, nor venting or flaring related to this sector.

HAPs reported to the EPA for this sector include: Benzene, Hexane, Toluene, Xylenes (Mixed 

Isomers), Ethylene Glycol, Formaldehyde, Ethyl Benzene, Styrene, 2,2,4-Trimethylpentane, 

Methanol, Acetaldehyde, Toluene-2, 4-Diamine, and Hydrogen Fluoride.

Table OGS-12. Hazardous air pollutant emissions 

2008 by county

Industrial Processes - Oil and Gas Production Total

County Emission (lbs) Emissions (tons)

Rio Arriba 41,640 20.8

San Juan 112,990 56.5

McKinley 11,172 5.6

Sandoval No data No data

(EPA, 2011a)

On March 11, 2011, the EPA released the ―National Air Toxics Assessment‖ (EPA 2011b) that 

identifies the health risks from breathing HAPs in various geographic areas. The assessment 

included emissions from stationary and mobile sources, as well as background concentrations 

from long-range transports and natural emissions, and from secondary formation from pollutants 

formed from other pollutants. The assessment looked at both cancer risks and noncancer related 

risks. The risks from HAPs in the counties in the South San Juan Basin were generally low for 

both cancer and other health risks associated with HAPs. The highest risks were for cancer in part 

of San Juan County near Farmington and Bloomfield which had cancer risks as high as 34 out of 

1 million individuals. Parts of Rio Arriba County north of Cuba, west of the Continental Divide 

had risks as high as 27 out of 1 million. The rest of the area typically had risks for cancer from 

HAPs at less than 20 out of 1 million. EPA considers these levels of risk from HAPs as 

acceptable. Based on this data, and the fact that no high density development is predicted on the 

Santa Fe National Forest, the risks from exposure to hazardous air pollutants would be less than 

significant in that emissions from the development of 20 wells are not expected to result in 

increased risk based on EPA’s ―National Air Toxics Assessment.‖

Greenhouse Gases

The assessment of greenhouse gas emissions and climate change is in its formative phase;

therefore, it is not yet possible to know with confidence the net impact to climate. However, the

Intergovernmental Panel on Climate Change (IPCC 2007) has concluded that—warming of the 

climate system is unequivocal and—most of the observed increase in globally average 

temperatures since the mid-20th century is very likely due to the observed increase in 
Air Quality Replacement Pages

26 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

anthropogenic (manmade) greenhouse gas concentrations. The lack of scientific tools designed to 

predict climate change on regional or local scales limits the ability to quantify potential future 

impacts. Potential impacts to air quality due to climate change are likely to be varied and 

dependent on which climate scenario plays out.

Oil and gas development activities on the SFNF are predicted to produce greenhouse gas 

emissions. The amount of carbon dioxide (CO2) and methane (CH4) emissions associated with 

well development for the RFDS were estimated for well drilling, well completion, and gas 

production. While emission inventories are continually being improved, estimates of greenhouse 

gas emissions for oil and gas activities were calculated using assumptions from EPA AP-42 tables 

for different engines used for oil and gas drilling and production, following the methodology used 

in the ―San Juan Public Lands Supplemental Draft EIS for Air Quality‖ (SJPL, 2011a) (Palmer, 

2010).

A very conservative estimate that assumes that 20 wells would be developed in a single year

estimates a total of 3,350 metric tons per year of greenhouse gases measured in carbon dioxide 

equivalent (CO2e ) which accounts for differences in warming potential. By comparison, the 

greenhouse gas emissions of Rio Arriba County for 2008 were estimated to be 396,000 metric 

tons CO2e (NMED, 2010). While this is very likely an overestimate, it results in less than 1

percent of the total CO2e emissions in Rio Arriba County.

Mitigation

The air quality impact analysis indicated that while there are adverse impacts to air quality, it is 

unlikely that significant environmental effects would occur. At this time, the SFNF does not 

require specific mitigation measures to reduce potential impacts to air quality. Under all 

alternatives considered in this NEPA analysis, there is a potential for an additional 20 wells to be 

developed. Some alternatives have specific stipulations that would be applied to protect surface 

resources. The actual effects of these wells to air quality would only occur once they have been 

analyzed and authorized through a site-specific NEPA decision at the time of application for 

permit to drill (APD). Based upon the analysis results, mitigation options could be considered in 

more detail.

The Forest Service and Bureau of Land Management (BLM) have been participants in the Four 

Corners Air Quality Group (formerly task force). This group has identified numerous potential 

mitigation strategies (FCAQTF 2007). The ―EPA Gas Star Program‖ (EPA 2011c) and the

―Emission Reduction Techniques for Oil and Gas Activities‖ (USFS 2011) have also identified 

other mitigation strategies to reduce air pollution from oil and gas development. These mitigation 

measures must be applied on a case-by-case basis and evaluated in the APD NEPA analysis rather 

than in this programmatic document. Cumulative impacts could be reduced with application of 

recommended mitigation measures, but these would be more effective if applied across the basin.

The Forest Service is committed to working with the BLM to ensure reduction of emissions 

which contribute to ozone formation and could potentially impact air quality values in San Pedro 

Parks Wilderness and other nearby Class 1 areas. 

The ―Air Quality Modeling Study for the Four Corners Area‖ (Environ, 2009) demonstrates that 

ozone reductions and improvement to visibility are possible if high level controls are 

implemented for both oil and gas operations and power plants throughout the Four Corners 

Region. The controls considered in detail for the oil and gas sector were VOC control for 
Air Quality Replacement Pages

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 27

pneumatic devices, flaring, and venting. The controls considered for NOx were emission 

reductions on existing engines. The SFNF will consider these findings when developing air 

quality mitigation measures for potential future oil and gas development on the SFNF. Many 

guidelines and mitigation measures focus on the VOC and NOx controls developed by the Four 

Corners Air Quality Task Force as a result of the ―Air Quality Modeling Study for the Four 

Corners Area.‖ This study also concluded that mitigation strategies that reduce both NOx and 

VOCs across the region for both power plants and oil and gas development to be most effective at 

reducing ozone. 

Methane gas emission reduction measures could also be considered to minimize the production of 

greenhouse gases related to management activities on the SFNF, such as green completions.

The only current emission control standard, required by the BLM on their COA is for compressor 

engines 300 horsepower or less used during well production. These engines must be rated by the 

manufacturer as emitting NOx at 2 grams per horsepower hour or less to comply with the NMEDAQB’s guidance.

As mentioned previously, EPA is currently under a court ordered deadline to finalize four rules to 

reduce air pollution from the oil and gas industry by April 3, 2012. The current proposal includes 

a new source performance standard for VOCs; a new source performance standard for sulfur 

dioxide; an air toxics standard for oil and natural gas production; and an air toxics standard for 

natural gas transmission and storage. The proposed rules would rely on proven technologies and 

best practices that are currently in use and could reduce VOCs, HAPs, GHG, and criteria 

pollutants significantly. 

The Santa Fe National Forest and New Mexico Environment Department will begin operating an 

ozone monitor in 2012 near San Pedro Parks Wilderness to ensure no negative impacts to 

visibility in this Class 1 area and no violation of ambient air quality standards for ozone occur. In 

addition, the WRAP is in the process of conducting high resolution modeling using the Phase III 

emissions inventory cited in this document. Both the monitoring data and the results of this 

assessment will be considered at the time of new applications to drill as part of a site-specific 

NEPA decision in the near term.

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 29

Timing Stipulation 

Replacement Page

The following page replaces the “Resource: 

Mexican Spotted Owl Timing Stipulation” 

section on page 33 in chapter 2 of the “Final 

Environmental Impact Statement for Oil-Gas 

Leasing and Roads Management”
Timing Stipulation Replacement Page

30 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Resource: Mexican Spotted Owl 

Stipulation: Timing limitation on drilling operations and construction activities: March 1 to 

August 31 

Location: Currently there are four designated protected activity centers (PACs) ranging in 

size from 365 to 610 acres. Would apply wherever there is a designated PAC. 

Purpose: To protect and limit disturbance from drilling and construction activities within 

Mexican spotted owl PACs (nesting/fledgling areas) to minimize risks to 

reproductive and post-fledgling success of Mexican spotted owls during the 

critical nesting/breeding period defined in the recovery plan for this federally 

listed threatened species as well as the Forest Plan (Appendix D, pg. 2). Would 

not apply to daily operations and maintenance of producing wells. 

Exception: An exception, modification, or waiver to the timing limitation may be granted if 

site-specific surface use plan of operations demonstrates that adverse effects to 

threatened and endangered species can be avoided, effects are documented in a 

biological assessment, and concurrence from the U.S. Fish and Wildlife Service 

is obtained. A public notice and comment period is required prior to waiver, 

exception, or modification of this stipulation.
Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 31

Threatened, Endangered, and 

Sensitive Species Replacement Pages

The following pages replace the

“Threatened, Endangered, and Sensitive

Species” section beginning on page 144 

and continuing through page 145 in chapter 

3 of the “Final Environmental Impact 

Statement for Oil-Gas Leasing and Roads 

Management”
Threatened, Endangered, and Sensitive Species

Replacement Pages

32 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Threatened, Endangered, and Sensitive Species

Affected Environment and Environmental Consequences

Special status wildlife, fish, and plants discussed in this section include species that are listed as 

threatened or endangered (T&E) under the Federal Endangered Species Act (ESA), Forest 

Service Region 3 sensitive species, or other species of special concern. 

The Forest Service has adopted policies to ensure that Agency actions do not result in the decline 

of species and the subsequent listing under the ESA. Those plants and animals listed as sensitive 

with the Forest Service have been identified by the Regional Forester for which population 

viability is a concern as evidenced by significant or predicted downward trends in either 

population or habitat capability (CNHP 1999).

Table OGS-9 lists threatened, endangered, and sensitive species occurring on the Santa Fe 

National Forest or in the Rio Grande, with information on status and likelihood of occurrence in 

the study area (NMDGF 2002; NMRPTC 2002).

Ten of the 21 species listed in table OGS-9 are known to occur or may occur in the study area. 

The other 15 species are highly unlikely to occur in the study area based on their known 

distribution or due to a lack of suitable habitat, and would not be affected by Forest Service 

actions within the study area.

Table OGS-13. Threatened, endangered, and sensitive species occurring on or near the 

Santa Fe National Forest, with potential of occurrence in the study area

Common Name Scientific Name Status1Potential to Occur in the Study Area

Goat peak pika Ochotona princeps 

nigrescens

FS Does not occur in the study area based on species 

habitat and distribution.

New Mexican (meadow) 

jumping mouse

Zapus hudsonius 

luteus

FS May occur in riparian, mesic grass areas.

Swift fox Vulpes velox FS Does not occur in the study area based on species 

habitat and distribution.

Bald eagle Haliaeetus 

leucocephalus

FS Adjacent Chama River corridor overwintering 

(Nov. 1 to Mar. 1) area. Incidental in the study area 

only in winter.

American peregrine 

falcon

Falco peregrinus 

anatum

FS One known nest site, a portion of outer (D) zone of 

another nest site, and 1 to 3 potential cliff nest sites 

within or bordering the north part of the study area.

Northern goshawk Accipiter gentilis FS Habitat present and two PFAs (post-fledgling 

areas) in northeastern part of the study area.

Boreal owl Aegolius funereus FS May occur in high elevation spruce-fir forest in the 

study area.

Mexican spotted owl Strix occidentalis 

lucida

T All or parts of four designated PACs (nest sites) 

and 6,736 acres critical habitat in the study area.

Southwestern willow 

flycatcher

Empidonax traillii 

extimus

E Does not occur in study area based on species 

habitat and distribution.

Western yellow-billed 

cuckoo

Coccyzus 

americanus 

occidentalis

FS Does not occur in the study area based on species 

habitat and distribution.

White-tailed ptarmigan Lagopus leucurus FS Does not occur in the study area based on species 

habitat and distribution.
Threatened, Endangered, and Sensitive Species

Replacement Pages

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 33

Common Name Scientific Name Status1Potential to Occur in the Study Area

Jemez Mountains 

salamander

Plethodon 

neomexicanus

FS Does not occur in the study area based on species 

habitat and distribution.

Northern leopard frog Rana pipiens FS May occur in riparian, mesic grass areas.

Rio Grande silvery 

minnow

Hybognathus 

amarus

E Does not occur in the study area; species restricted 

to the middle Rio Grande, downstream from 

watersheds of the forest.

Rio Grande chub Gila Pandora FS Found in segments of Clear Creek.

Rio Grande cutthroat 

trout

Oncorhynchus 

clarki virginalis

FS Found in segments of Clear Creek, San Jose Creek, 

Cecilia Creek, La Jara Creek, Rito de los Piños, Rio 

Capulin, and Rio Puerco del Grande in the study 

area.

Blue-black silverspot 

butterfly

Speyeria Nokomis 

Nokomis

FS Not recorded in Sandoval and Rio Arriba Counties.

Holy ghost ipomopsis Ipomopsis sanctispiritusE Does not occur in the study area based on species 

habitat and distribution; known only in one canyon 

in the southern Sangre de Cristo Mountains.

Hairless fleabane Erigeron 

subglaber

FS Does not occur in the study area based on species 

habitat and distribution.

Chiricahua (bloomer’s) 

dock

Rumex 

orthoneurus

FS Does not occur in the study area based on species 

habitat and distribution.

Arizona willow Salix arizonica FS Does not occur in the study area based on species 

habitat and distribution.

1 FS = Forest Service Region 3 Sensitive Species

 E = Endangered Species (USFWS)

 T = Threatened Species (USFWS)

The biological assessment for this project (SAIC, 2006) states the ―Proposed action does not 

include any conditions of approval (COA) or mitigation measures, which are developed and 

applied during second level NEPA site-specific analysis of the application for permit to drill 

(APD).‖ 

The biological assessment for this project determined that the action alternatives would not 

adversely affect listed, proposed, or candidate threatened or endangered species, and/or 

designated or proposed critical habitats.

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 35

Mexican Spotted Owl 

Replacement Pages

The following pages replace the “Mexican 

Spotted Owl” section beginning on page 148 

and continuing through page 150 in chapter 3 

of the “Final Environmental Impact Statement

for Oil-Gas Leasing and Roads Management”
Mexican Spotted Owl Replacement Pages

36 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Mexican Spotted Owl (Strix occidentalis lucida)

Affected Environment

The Mexican spotted owl (MSO) occurs in Rio Arriba County (NMDGF 2003), with nesting 

documented in the study area; however, no nesting pair has been found in the study area in recent 

years. There are four designated MSO protected activity centers (PACs) shown on figure OGS-3

with the designated critical habitat in the study area. A summary of current Forest Plan lease 

standards and guidelines overlapping MSO PACs and critical habitat are shown in table OGS-14. 

Table OGS-14. Existing Forest Plan oil-gas lease standards and guidelines 

within MSO PACs and critical habitat

Area Standard Lease Terms 

and Conditions (acres)

Limited Surface 

Use (acres)

MSO PACs 2,035 0

MSO critical habitat 6,736 0

MSO critical habitat outside PACs 5,345 0

The MSOs habitat is characterized by high structural complexity and canopy closure (Stacey and 

Hodgson 1999). It prefers unevenaged, multilayered old growth or mature mixed conifer forests 

(with large diameter trees, snags, and logs); stands of ponderosa pine-oak woodlands with a welldeveloped understory of Gambel oak; and steep canyons and shady canyon bottoms where a 

variety of deciduous and coniferous trees form multiple vegetation layers (USFWS 1995, Stacey 

and Hodgson 1999). Currently there four MSO PACs totaling 2,035 acres and an additional 6,736 

acres of designated MSO critical habitat within the study area (figure OGS-3).

Environmental Consequences

The MSO is vulnerable to habitat loss or alteration of mature mixed conifer forest. Critical habitat 

for MSO exists in the southern portion of the study area. Activities that fragment mature mixed 

conifer forest, such as construction and oil-gas well development and maintenance, would be 

potentially detrimental to the MSO. A summary of proposed lease stipulations1 MSO areas are 

shown in table OGS-15. The oil-gas leasing decision to be made in this EIS would have no direct, 

on-the-ground effects on habitat or wildlife populations, but may affect future oil-gas 

development through stipulations on development under new leases. All reasonably foreseeable 

development is projected to occur on existing leases under standard terms and conditions. Sitespecific NEPA analysis would involve the selection of conditions of approval developed during 

the APD process and would take into account the existence of threatened, endangered, and 

sensitive species according to required protocols.

Alternative 1—No Action

Under the No Action Alternative, leasing would continue under standard terms and conditions, 

except for limited surface use in management areas D and L that emphasize visual 

quality/developed recreation and semiprimitive, nonmotorized recreation, respectively. ESA 

 

1

Stipulation is common oil-gas leasing terminology; once codified into the Forest Plan, the stipulations would be 

referred to as a standard and guideline.
Mexican Spotted Owl Replacement Pages

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 37

consultation on the Forest Plan is current; therefore, no re-initiation of consultation would be 

required because the Forest Plan would not be changed or amended under this alternative. There 

would be no change in effects to MSO, MSO PACs, or their critical habitat from new oil-gas 

leases because the lease would be subject to applicable laws and regulations. Furthermore, 

Section 6 of the USDI Bureau of Land Management Oil and Gas Lease (Form 3100-11) requires 

that lessees conduct operations to minimize impacts to biological resources, which may include 

modification to siting or design of facilities, and timing of operations; and if a threatened or 

endangered species is observed during operations, lessee must cease operations that would result 

in the destruction of such species.

Alternative 2—Proposed Action

The Proposed Action would have more stringent restrictions to protect MSO PACs and critical 

habitat than the No Action Alternative through the establishment of a timing limitation stipulation 

on new oil-gas leases. Because no surface-disturbing activities would occur within the study area 

as a direct result of implementing the Proposed Action, the new lease stipulations would not 

affect MSOs or their critical habitat. Within the four MSO PACs wholly or partially within the 

study area, the proposed ―timing limitation‖ (TL) stipulation would apply to all 2,035 PAC acres. 

The proposed ―no surface occupancy‖ (NSO) stipulation would apply to 642 PAC acres, and the 

proposed ―controlled surface use‖ (CSU) stipulation would apply to PAC 17 acres; the NSO and 

CSU stipulations overlap the TL stipulation. Within MSO critical habitat but outside the PACs, 

the TL stipulation would not apply; however, the NSO stipulation would apply to 349 acres of 

critical habitat, and the CSU stipulation would apply to 52 acres of critical habitat. The NSO 

stipulation would provide protection because it would apply to slopes ≥40 percent, areas that 

MSO generally prefer. 

The biological assessment for this project determined that the action alternatives would not 

adversely affect the MSO or other listed, proposed, or candidate threatened or endangered 

species, and/or designated or proposed critical habitats. Although the 2005 consultation on Forest

Plan amendments resulted in a ―may affect, likely to adversely affect‖ determination for the 

MSO, it was not based on oil-gas activities. 

The MSO PAC timing limitation stipulation allows for granting of an exception, modification, or 

waiver of the timing limitation if surveys according to protocol are conducted and the PAC is not 

used for nesting. This allowance would not invalidate the ―no effect‖ determination for the 

Proposed Action for the following reasons. None of the designated MSO PACs in the study area 

are within areas currently under lease and a request for an exception, modification or waiver of 

the timing limitation would accompany the oil-gas leaseholder’s application for permit to drill 

(APD) and, therefore, would be included in the site-specific NEPA analysis of the APD. Should a 

request be submitted after the NEPA process for the APD has been completed and the APD 

approved, the timing limitation stipulation would require a 30- to 90-day public review period (36 

CFR 219.8) that includes appropriate NEPA analysis, consultation with the U.S. Fish and Wildlife 

Service, and Endangered Species Act and Forest Plan compliance. The NEPA and ESA 

compliance requirement would also apply if, at a future date, a MSO PAC was established on an 

existing lease as described under the No Action Alternative.
Mexican Spotted Owl Replacement Pages

38 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Figure OGS-3. Mexican spotted owl protected activity centers, designated critical habitat, 

and locations and acreages in the study area
Mexican Spotted Owl Replacement Pages

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 39

There are 6,736 acres of MSO critical habitat in the southeastern end of the study area. One 

designated MSO PAC and portions of two other PACs totaling 1,391 acres are located within 

MSO critical habitat. MSO critical habitat and PAC locations would be available to perspective 

oil-gas lessees, information that would help them make informed decisions about oil-gas leasing. 

If leased, MSO surveys to protocol in the critical habitat would be required at the APD stage, and 

depending on survey results, a timing limitation may be imposed as a COA during the sitespecific NEPA analysis.

The effects of the Proposed Action were reviewed in accordance with ―Determining the Need for 

ESA Section 7 Re-initiation of Consultation on proposed Forest Plan Amendments and Insuring 

Consistency with the Region-wide Programmatic Land and Resource Management Plan 

Biological Opinion‖ (USDA Forest Service, Southwestern Region, June 15, 2005). A plan 

amendment is consistent with the biological opinion (BO) if:

1. It results in effects (to species and/or designated critical habitat) that were analyzed in the 

BO;

2. It does not result in exceeding the amount of take issued in the BO;

3. It meets the assumptions stated in the BO; and,

4. It would result in continuing to implement the terms and conditions of the BO.

Although the Proposed Action would impose a timing limitation stipulation (i.e., Forest Plan 

standard and guideline (S&G)) on oil-gas exploration and development activities in MSO PACs 

within the study area, there would be no change in the effects to species and/or designated critical 

habitat analyzed in the biological opinion. This is because the stipulations/S&Gs clarify and 

establish locations where timing limitations for T&E and Forest Service sensitive species would 

apply. Furthermore, the Proposed Action would not change the types of oil-gas activities that may 

occur, and since the Forest Service has the ability to impose timing limitations for MSO under the 

existing Forest Plan, there would be no change in effects.

The Proposed Action does not result in exceeding the amount of take issued in the biological 

opinion because the stipulations/S&Gs would prohibit certain kinds of oil-gas activities during the 

timing limitation period that may have resulted in take; nor would it modify the rate of outputs for 

natural resource programs described in the Forest Plan.

The Proposed Action meets the assumptions stated in, and would continue to implement the terms 

and conditions for, MSO in the biological opinion because the timing limitation is designed to 

minimize adverse effects to reproductive and post-fledgling success during the March 1 to August 

31 critical MSO nesting/breeding period. Because the locations where MSO timing limitations 

would be made known prior to leasing, potential lessees would be able to make informed 

decisions about leasing and to adjust their oil-gas activities to where the effects of such activities 

would be beneficial, insignificant, or discountable within occupied MSO PACs. 

The Proposed Action is consistent with the regionwide programmatic LRMP biological opinion that 

the U.S. Fish and Wildlife Service issued on June 10, 2005 (Consultation No. 2-22-03-F-366); 

therefore, no re-initiation of consultation is needed on the Forest Plan as a result of this amendment.
Mexican Spotted Owl Replacement Pages

40 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Figure OGS-4 Mexican spotted owl protected activity centers and designated critical 

habitat in the study area
Mexican Spotted Owl Replacement Pages

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Table OGS-15. Proposed oil-gas lease stipulations within MSO areas under the action 

alternatives

MSO Area CSU (acres) NSO (acres)

Standard Lease 

Terms and Conditions 

(acres)

Timing 

Limitations 

(acres)

MSO PACs117 642 0 2,035

MSO critical habitat 

outside PACs 52 349 4,944 0

1 The acreage sum is greater than the total amount within the study area due to overlapping lease stipulations 

occurring within certain PACs.

Alternative 3

The additional NSO lease stipulations proposed under Alternative 3 would not occur in MSO 

PACs or critical habitat, so the effects to MSOs and designated critical habitat would be the same 

as those under the Proposed Action.

Although a MSO PAC timing limitation would be imposed under all alternatives, the difference 

between the no action and action alternatives is that in the No Action Alternative, the timing 

limitation would be imposed as a COA (mitigation measure) during the site-specific NEPA 

analysis of the APD because there is no MSO PAC timing limitation stipulation. Under both 

action alternatives, the timing limitation stipulation would be known at the expression of interest 

stage prior to leasing, a fact that may influence oil-gas operator’s leasing decisions.

Cumulative Impacts

The analysis area for cumulative effects on listed or proposed threatened and endangered species 

and critical habitats is the area in and adjacent to the oil-gas study area, and includes both Forest 

Service and non-Federal lands. In all alternatives, cumulative impacts to wildlife would stem 

from the combination of forest management activities, public land uses, and activities on other 

public and private lands.

Development of leases for oil and gas resources is a reasonably foreseeable action to be 

considered under the ―Cumulative Impacts‖ section. Through consultation with industry and 

constraints on oil-gas development, such as topography, the Forest Service projects mineral 

development over the next 20 years to be about 20 new well locations and almost 3 miles of 

associated roads within the study area. All of the projected development would occur in the 

northern portion of the study area. The majority of the projected wells would occur within piñonjuniper and ponderosa pine wildlife habitat (10 and 7 wells, respectively). The remaining three 

wells are projected to occur within grassland wildlife habitat. Associated new roads projected to 

be built with the projected new wells include about 1.3 miles of road within ponderosa pine 

wildlife habitat, 0.8 mile of road within piñon-juniper wildlife habitat, and 0.7 mile of road within 

grassland wildlife habitat. All of the projected wells and associated projected roads would occur 

within existing leases. Therefore, neither of the action alternatives would influence the 

development of the projected wells or roads, unless existing leases were relinquished and reissued 

under proposed lease stipulations. The potential oil-gas development would most likely occur 

under standard terms and conditions, providing minimal surface protection for vegetative 
Mexican Spotted Owl Replacement Pages

42 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

resources. The amount of projected development is minimal and, therefore, impacts to wildlife 

would likely be negligible.

Other foreseeable actions that may contribute to decreased wildlife habitat fragmentation and 

disruption are the proposed decommissioning of 773 miles of Forest Service roads within the 

Cuba and Coyote Ranger Districts, currently under consideration. The road decommissioning 

would reduce habitat fragmentation over the long term, while 639 miles of proposed road 

closures would reduce motorized vehicle traffic in the region and minimize wildlife disruption. 

Therefore, the combination of the effects of these future projects with the direct and indirect 

effects from this project would result in no cumulative effects to projected oil-gas development in 

the area. 

Conclusions

No direct or indirect impacts to the MSO PACs are anticipated under any alternative. Surfacedisturbing activities related to projected future oil-gas development would continue under 

standard terms and conditions within the study area. Avoidance of impacts to MSOs and 

designated critical habitat during development, in compliance with State and Federal laws and 

policy, would continue to result in no effect to MSOs and their designated critical habitat.
Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 43

Supplemental Consultation and Coordination

Preparers and Contributors 

Interdisciplinary Team Members 

Allen Fowler, Environmental Coordinator, Santa Fe National Forest, Santa Fe, NM

Charles Gobar, Forest Biologist, USDA Forest Service, Santa Fe National Forest, Santa Fe, 

NM 

Chris Napp, Environmental Coordinator, Santa Fe National Forest, Santa Fe, NM

Jeanne Hoadley, New Mexico Environmental Department Liaison, USDA Forest Service, 

Southwestern Region, Santa Fe National Forest, Santa Fe, NM

Joshua Hall, Air and Water Quality Specialist, Santa Fe National Forest, Santa Fe, NM

Raulin (William) Amy, Wildlife Program Manager, Santa Fe National Forest, Santa Fe, NM

Jennifer Cramer, Forest Planner, Santa Fe National Forest, Santa Fe, NM

Larry Gore, Geologist, Santa Fe National Forest, Santa Fe, NM

The Forest Service interdisciplinary team consulted the following individuals during preparation 

of this draft supplement to the Final EIS: 

Jackie Andrew, Regional Environmental Coordinator, USDA Forest Service, Southwestern 

Region, Albuquerque, NM 

Rita Skinner, Assistant Regional Environmental Coordinator, USDA Forest Service, 

Southwestern Region, Albuquerque, NM 

Constance Smith, Appeals Coordinator, USDA Forest Service, Southwestern Region, 

Albuquerque, NM 

Earnest Taylor, Regional Threatened and Endangered Species Program Coordinator, USDA 

Forest Service, Southwestern Region, Albuquerque, NM 

Persons, Organizations and Agencies that Were Sent Copies or 

Notified of the Availability of the Final Supplement to the FEIS

Persons, organizations, and agencies that received copies or otherwise requested notification of 

the availability of the March 2006 DEIS were sent copies or notified of the availability of this 

supplement, and includes Federal agencies for distribution of environmental impact statements.

Individuals and Organizations

Norman Elliott

Terry and Jenn Johnson

Carolyn Melgaard

Jason and Peggy Ohler 

Senator Jeff Bingaman 

Senator Tom Udall
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44 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Representative Ben R. Lujan

Audubon Society, Sangre de Cristo Chapter

Continental Divide Trail Alliance 

Henry Production, Inc. 

New Mexico Oil and Gas Association 

San Juan Citizens Alliance 

Sierra Club, Northern New Mexico Group 

WildEarth Guardians

State and Federal Agencies

New Mexico Department of Game and Fish 

New Mexico Environment Department, Water Quality Bureau 

New Mexico Environment Department, Air Quality Bureau

Advisory Council on Historic Preservation

Environmental Protection Agency, Region 6

Federal Aviation Administration, Southwest Region

Federal Highway Administration

NOAA National Marine Fisheries Service, Southwest Region

USDA APHIS

USDA National Agricultural Library

USDA Natural Resources Conservation Service - Albuquerque, NM

USDA Natural Resources Conservation Service - Washington, DC

USDI Bureau of Land Management - Farmington 

USDI Bureau of Land Management - Santa Fe 

USDI Fish and Wildlife Service - Albuquerque

USDI Office of Environmental Policy and Compliance

U.S. Army Engineer Division, South Pacific

U.S. Coast Guard

U.S. Department of Energy
Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 45

Literature Cited

BLM 2002. Bureau of Land Management, Bureau of Indian Affairs, and Southern Ute Indian 

Tribe (SUIT) Energy and Minerals Division. 2002. Oil and Gas Development on the 

Southern Ute Indian Reservation: Final Environmental Impact Statement. Department of 

the Interior, San Juan Public Lands Center. Durango, CO. July.

CNHP 1999. Colorado Natural Heritage Program. 1999. Statewide Species and Natural 

Community Tracking List. Fort Collins, CO. http://www.cnhp.colostate.edu/list.html.

Engler, et al. 2001. Engler, Thomas W., B.S. Brister, H.Y. Chen and L.W. Teufel. 2001. Oil and 

Gas Resource Development for San Juan Basin, New Mexico. New Mexico Institute of 

Mining and Technology. Socorro, NM. 

http://www.nm.blm.gov/ffo/ffo_p_rmp_feis/docs/RFD.pdf.

Environ. 2006. Ozone precursors emissions inventory for San Juan and Rio Arriba Counties, New 

Mexico. Final Report. http://www.nmenv.state.nm.us/aqb/4C/links.html

Environ 2009. Air Quality Modeling Study for the Four Corners Region: Revised Report –

August 2009. Web Site:

http://www.nmenv.state.nm.us/aqb/4C/Documents/FinalRepRev20090806.pdf

Environ 2009b. Western Regional Air Partnership Phase III Project, South San Juan Basin, 2006 

Baseline Technical Memo (11/25/09). Web Site: http://www.wrapair2.org/PhaseIII.aspx

Environ 2009c. Western Regional Air Partnership Phase III Project, South San Juan Basin, 2012 

Mid-Term Projection Technical Memo (12/08/09). Web Site: 

http://www.wrapair2.org/PhaseIII.aspx

EPA 2009. U.S. Environmental Protection Agency. AIRData Monitor Values Report. Web Site:

http://www.epa.gov/air/data/monvals.html?st~NM~New%20Mexico

EPA 2011. U.S. Environmental Protection Agency. Air Quality System Data Mart (internet 

database). Web Site: http://www.epa.gov/ttn/airs/aqsdatamart

EPA 2011a. U.S. Environmental Protection Agency. EPA AIRData Tier Emissions Report –

Criteria Air Pollutants. Web Site: http://www.epa.gov/ttn/chief/net/2008inventory.html 

EPA 2011b. U.S. Environmental Protection Agency. 2005 National-Scale Air Toxics Assessment.

Web Site: http://www.epa.gov/ttn/atw/nata2005/

EPA 2011c. U.S. Environmental Protection Agency. 2011. Natural Gas STAR Program. Web Site:

http://www.epa.gov/gasstar/tools/recommended.html

EPA 2012. U.S. Environmental Protection Agency. Currently Designated Nonattainment Areas 

for All Criteria Pollutants, as of March 30, 2012. Web Site: 

http://www.epa.gov/airquality/greenbook/ancl.html#NEW MEXICO

FCAQTF 2007. Four Corners Air Quality Task Force Report of Mitigation Options: Oil and Gas 

Section. 2007. Web Site: http://www.nmenv.state.nm.us/aqb/4C/TaskForceReport.html.

FLAG 2000. National Park Service, Air Resources Division, 2000. Federal Land Managers’ Air 

Quality Related Values Workshop (FLAG) – Phase I Report. National Park Service. 

Denver, CO. http://www2.nature.nps.gov/air/Permits/flag/flagfreeindex.htm.

Hall 2011. Santa Fe National Forest Emission Tables (Pictured Cliffs Sandstone-Mancos Shale). 

Excel Spreadsheet.
Literature Cited

46 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

IPCC 2007. Intergovernmental Panel on Climate Change, 2007. Climate Change 2007: Synthesis 

Report. Web Site: http://www.ipcc.ch/pdf/assessment-report/ar4/syr/ar4_syr.pdf

NMAQB 2001a. New Mexico Environment Department, Air Quality Bureau (NMED-AQB).

Personal communication between Mary Uhl, NMED and Steve Ziemer, Science 

Applications International Corporation. Santa Fe, NM. 

NMDGF 2002. New Mexico Department of Game and Fish, Bureau of Land Management, U.S. 

Fish and Wildlife Service, U.S. Bureau of Reclamation, U.S. Army Corps of Engineers, 

U.S. Forest Service, and the University of New Mexico. 2002. Biota Information System 

of New Mexico (BISON-M) database. http://nmnhp.unm.edu/bisonm/bisonquery.php.

NMDGF 2003. New Mexico Department of Game and Fish, Bureau of Land Management, U.S. 

Fish and Wildlife Service, U.S. Bureau of Reclamation, U.S. Army Corps of Engineers, 

U.S. Forest Service, and the University of New Mexico. 2003. Biota Information System 

of New Mexico (BISON-M) database. http://nmnhp.unm.edu/bisonm/bisonquery.php.

NMED 2010. New Mexico Environment Department, 2010, Testimony of Michael Schneider 

before the Environmental Improvement Board in the matter of proposed new regulation, 

20.2.350 NMAC- Greenhouse Gas Cap and Trade Provisions. 

NMED 2009. New Mexico Environment Department. 2009. New Mexico Recommended Area 

Designations for the 2008 Revised Ozone NAAQS. Appendix E.

http://www.nmenv.state.nm.us/aqb/OzoneRecommendation.htm.

New Mexico Rare Plant Technical Council, 1999 (updated: 22 January 2009), New Mexico Rare 

Plants, Albuquerque, NM: New Mexico Rare Plants Home Page.

http://nmrareplants.unm.edu/.

Palmer 2010. Greenhouse Gas Emission Calculations, Gothic Shale Gas, San Juan Plan Revision. 

Kelly Palmer, October 28, 2009, Revised 9/21/10.

SAIC 2006. Science Applications International Corporation. Biological Assessment and 

Evaluation for Oil and Gas Leasing Environmental Impact Statement, Santa Fe National 

Forest, New Mexico. July.

SJPL 2011. San Juan Public Lands. 2011. San Juan Public Lands Supplemental Draft 

Environmental Impact Statement, Chapter 3.1 Air Quality. Web Site: 

http://ocs.fortlewis.edu/forestplan/supplement/chapter3.htm

SJPL 2011a. Air Quality Technical Support Document - Appendix A - Detailed Project Emission 

Calculation Tables. San Juan Public Lands. 2010.

Stacey and Hodgson 1999. Stacey, P.B. and A. Hodgson. 1999. Biological Diversity in Montane 

Riparian Ecosystems: the Case of the Mexican Spotted Owl, Rio Grande Ecosystems: 

Linking Land, Water, and People, USDA Forest Service, Rocky Mountain Research 

Station, Coyote, NM.

USDA Forest Service, Southwestern Region, June 15, 2005. Determining the Need for ESA 

Section 7 Re-initiation of Consultation on proposed Forest Plan Amendments and 

Insuring Consistency with the Region-wide Programmatic Land and Resource 

Management Plan Biological Opinion.
Literature Cited

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 47

USDI Fish and Wildlife Service, Regional Office, Region 2, Programmatic Biological and 

Conference Opinion, June 10, 2005. The Continued Implementation of the Land and 

Resource Management Plans for the Eleven National Forests and National Grasslands of 

the Southwestern Region, Cons. No. 2-22-03-F-366.

USFS 2004a. U.S. Forest Service. 2004. Gore, Larry. Reasonably Foreseeable Development 

Scenario, San Juan Basin Oil and Gas Planning Amendment EIS, USDA Forest Service, 

Santa Fe National Forest. Cuba, NM. 

USFS 2008. U.S. Forest Service 2008. Final Environmental Impact Statement. Surface 

Management of Natural Gas Resource Development on Jicarilla Ranger District, Carson 

National Forest, USDA Forest Service, Carson National Forest. Taos, NM.

USFS 2011. Emission Reduction Techniques for Oil and Gas Activities. U.S. Forest Service.

2011.

USFWS 1995. U.S. Fish and Wildlife Service. 1995. Recovery Plan for the Mexican Spotted Owl 

(Strix occidentalis lucida): Volume 1. Albuquerque, NM.

Visibility Information Exchange Web System. 2011. VIEWS. 

http://vista.cira.colostate.edu/TSS/Results/HazePlanning.aspx

Environ 2009b. Western Regional Air Partnership Phase III Project, South San Juan Basin, 2006 

Baseline Technical Memo (11/25/09). Web Site: http://www.wrapair2.org/PhaseIII.aspx

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 49

OGS Appendix A. MOU

The following pages contain the Memorandum of 

Understanding Among the U.S. Department of

Agriculture, U.S. Department of the Interior, and 

U.S. EPA Regarding Air Quality Analysis and 

Mitigation for Federal Oil and Gas Decisions 

Through the National Environmental Policy Act 

Process (June 23, 2011)
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OGS Appendix B. Public Comments

The following pages contain public comments 

on the draft supplement and Forest Service 

responses.
OGS Appendix B. Public Comments

78 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Air Quality

Comment 1

Future gas development in the Santa Fe National Forest should employ control technologies that 

reduce emissions of air pollutants.

Comment submitted by: New Mexico Environment Department Air Quality Bureau – Surface 

Water Quality Bureau (NMED – AQB-SWQB)

Response to Comment 1

The Forest will require future gas developments to employ control technologies that reduce air 

pollutants. As noted in the January 7, 2009, Appeal No. 09-03-00-0001-A217 Review Decision 

for Issue 2, Contention F, “[t]he FEIS appropriately defers discussion of specific mitigation 

measures to the second-level site-specific NEPA analysis.”

Comment 2

To further ensure air quality standards are met, applicable local or county regulations requiring 

noise and/or dust control must be followed. If none are in effect, controlling construction-related 

air quality impacts during projects should be considered to reduce the impact of fugitive dust 

and/or noise on community members.

Comment submitted by: NMED – AQB-SWQB

Response to Comment 2

Forest Service regulations and leases require that all applicable State and county regulations must 

be complied with.

Comment 3

Dust control measures should be taken to minimize the release of particulates due to vehicular 

traffic and construction.

Comment submitted by: NMED – AQB-SWQB

Response to Comment 3

The Forest agrees. See response to Comment 1.

Comment 4

All asphalt, concrete, quarrying, crushing, and screening facilities contracted in conjunction with 

the proposed project must have current and proper air quality permits. 

Comment submitted by: NMED – AQB-SWQB

Response to Comment 4

See response to Comment 2.
OGS Appendix B. Public Comments

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 79

Comment 5

The Final Supplemental EIS should explain that a draft memorandum of understanding (MOU) is 

now in preparation among the Department of the Interior, on behalf of the Bureau of Land 

Management (BLM), National Park Service (NPS), EPA, and Department of Agriculture 

addressing this concern. This MOU sets forth expectations and agreements among the 

participating agencies for addressing air quality impact analysis and mitigation through the NEPA 

process for all Federal decisions relating to oil and gas planning, leasing, or field development.

Once the MOU is signed, EPA asks that it be incorporated in the FSFEIS and assurances be given 

that air quality will be a major factor in the decision process for this region.

Comment submitted by: EPA Region 6

Response to Comment 5

The MOU signed on June 23, 2011, is included in the FSEIS as OGS Appendix A.

In accordance with Part X.C.3.of the MOU, the Forest determined the NEPA analysis was 

ongoing when the MOU was finalized, and the EIS could not be completed in a cost-effective or 

timely matter if the MOU were to be followed. However, the Forest did identify the reasonably 

foreseeable number of wells (page 19 of FSEIS) and prepared the emissions inventory (table OGS 

10) as called for in the MOU V.E. 1 and 2. Due to the small number of reasonably foreseeable 

wells, it was determined modeling would be ineffective because the results would fall within the 

range of uncertainty of the models.

Air quality analysis and mitigation will be developed in accordance with the MOU during the 

NEPA analysis for oil and gas developments proposed in the future as described in the FSEIS on 

pages 26 and 27.

Comment 6

The SDEIS and FEIS fail to adequately analyze and assess the direct, indirect, and cumulative air 

quality impacts of additional oil and gas leasing in accordance with 40 CFR §1502.16 and other 

CEQ NEPA regulations. Specifically, the SDEIS and FEIS fail to adequately analyze and assess 

impacts in regard to haze, or visibility, impacts to Class I areas, with regards to Prevention of 

Significant Deterioration (“PSD”) increment impacts, and with regards to ozone and nitrogen 

dioxide impacts.

Comment submitted by: WildEarth Guardians

Response to Comment 6

As noted in the January 7, 2009, Appeal No. 09-03-00-0001-A217 Review Decision for Issue 2, 

Contention D “PSD increment analysis is not a requirement for the project. The decision does not 

result in violation of Federal, state or local regulations, the Santa Fe National Forest Plan, or 

NFMA.”

Air quality analysis and assessments are described in the final supplement pages 4 through 27.
OGS Appendix B. Public Comments

80 Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF

Comment 7

In particular, it is not apparent that the Forest Service will ensure compliance with the following 

standards and guidelines:

• F04: Management activities will be planned so that air quality will meet applicable 

Federal, State, and local regulations; and

• Watershed & Air F01: In the Class I Air Quality Areas (Pecos Wilderness except 1980 

additions and San Pedro Parks) maintain high quality visual conditions...Impacts of air 

pollution generating activities will be predicted using current modeling techniques.

We are concerned that the Forest Service has not demonstrated that these standards and guidelines 

will be complied with. In particular, it is not apparent that air pollution impacts of oil and gas 

development in Class I Air Quality Areas has been predicted using current modeling techniques.

Comment submitted by: WildEarth Guardians

Response to Comment 7

The analysis described on page 23 of the FSEIS concluded the 20 wells projected would cause a

small increase in pollutants, but would not cause the levels to exceed State and Federal air quality 

standards; nor would they cause measurable visibility degradation in nearby Class I areas.

In addition, it was determined that it would be inappropriate to directly model the impacts to air 

quality from 20 wells due to the cost in both time and money using current modeling techniques; 

and that such results would fall within the range of uncertainty, due to the small number of 

potential wells. However, the most current modeling in the basin was considered as well as

analyses from the Jicarilla EIS and the Draft Supplemental EIS San Juan Plan Revision.

Soils

Comment 8

Areas disturbed by construction activities, within and adjacent to the project area should be 

reclaimed to avoid long-term problems with erosion and fugitive dust.

Comment submitted by: NMED – AQB-SWQB

Response to Comment 8

The Forest will require future development activities to reclaim project areas to avoid erosion and 

fugitive dust problems. As noted in the January 7, 2009, Appeal No. 09-03-00-0001-A217 

Review Decision for Issue 2, Contention F, “[t]he FEIS appropriately defers discussion of specific 

mitigation measures to the second-level site-specific NEPA analysis.”

T&E Species

Comment 9

The Draft Supplement to the Final EIS (FSFEIS) assesses the potential impact to the Mexican 

spotted owl (MSO) which is listed and has critical habitat occurring in Rio Arriba County.

Although the Forest Service has made its determination that the oil and gas development will 
OGS Appendix B. Public Comments

Final Supplement to the FEIS for Oil-Gas Leasing, Santa Fe NF 81

have no direct, indirect, or cumulative impact i.e., “no effect” to the MSO, EPA believes that the 

coordination letters from the U.S. Fish and Wildlife Service (USFWS) should be in the final 

supplement and referenced in the impact discussion. The USFWS’s coordination letters and 

biological opinion are required to verify proper Section 7 Consultation and to validate the “no 

effect” determination. Please incorporate the endangered species coordination correspondence in 

the FSFEIS.

Comment submitted by: EPA Region 6

Response to Comment 9

The findings of the biological assessment are found on page 33 of the final supplement pages.

The biological assessment and evaluation is part of the project record (PR Document 247).

Comment 10

Furthermore, the SDEIS and FEIS simply do not demonstrate that authorizing ramped up oil and 

gas leasing on the Santa Fe National Forest would comply with Section 7 of the Endangered 

Species Act, 16 USC § 1536.

Comment submitted by: WildEarth Guardians

Response to Comment 10

As specified in the FSEIS on page 33, conditions of approval and mitigations to protect 

threatened and endangered species will be developed in consultation with the U.S. Fish and 

Wildlife Service during the site-specific NEPA analysis of the application for permit to drill 

(APD) before ground-disturbing activities occur.

This comment appears to be premised upon two fallacies—the first is that the FSEIS is 

authorizing oil and gas leasing. That is incorrect, this EIS is analyzing what stipulations are 

appropriate to include in the Forest Plan amendment as stated on page 19 of the FEIS. Additional 

NEPA analysis will be done prior to leasing any land, and detailed NEPA analysis will be done if

a lease is issued and a proposal to develop the lease is submitted.

The second fallacy is the FSEIS “ramps up” leasing, presumably meaning increases the area 

available for leasing and/or decreases the amount of protection given an area. None of the 

alternatives described in the FEIS or the SFEIS increase the acreage available for oil and gas 

leasing. The preferred alternative imposes new restrictions on a substantial part of the area 

analyzed.

Existing Plan Proposed Action

No Surface Occupancy 0 Acres 30,400 Acres

Controlled Surface Use 16,500 Acres 29,100 Acres
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Forest Planning

Comment 11

In sum, the Forest Service cannot defer any site-specific analysis of the potentially significant 

environmental impacts of oil and gas development or defer requiring mitigation measures that 

would adequately protect natural resources and ensure compliance with relevant laws and 

regulations. The SDEIS and FEIS must fully analyze and assess the reasonably foreseeable 

impacts of oil and gas development and cannot defer the analysis.

Comment submitted by: WildEarth Guardians

Response to Comment 11

As noted in the January 7, 2009, Appeal No. 09-03-00-0001-A217 Review Decision Findings for 

Issue 1, “[m]itigation (stipulations) were developed which were appropriate to the leasing stage of 

analysis and decisionmaking. The ROD appropriately defers site-specific NEPA analysis with 

development of site-specific mitigation and monitoring requirements to the time when a sitespecific APD is received.”

Comment 12

The Forest Service is required to ensure its actions are consistent with the 1987 “Carson National 

Forest Land and Resource Management Plan” (LRMP), as amended. See USC § 1604(i).

Unfortunately, the Forest Service failed to do so with regards to protecting air quality.

Comment submitted by: WildEarth Guardians

Response to Comment 12

The analysis area is within the Santa Fe National Forest, so the 1987 “Carson National Forest 

Land and Resource Management Plan,” as amended, is not the governing document.

Comment 13

Furthermore, as already explained, the issuance of oil and gas leases is an irreversible 

commitment of resources that requires a detailed analysis of impacts. The Forest Service cannot 

defer consultation under the ESA at the leasing stage. 

Comment submitted by: WildEarth Guardians

Response to Comment 13

The FEIS and SFEIS analyze land classification for a Forest Plan amendment, and does not 

authorize issuing specific leases. Prior to authorizing a lease, additional NEPA documentation 

will be done as stated in the FEIS on pages 1 and 6. The resource is committed only after leasing.

Also, see response to Comment 11.
OGS Appendix B. Public Comments

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Alternatives

Comment 14

NEPA requires agencies to “study, develop, and describe appropriate alternatives to recommended 

courses of action in any proposal which involves unresolved conflicts concerning alternative uses 

of available resources.” 42 U.S.C. § 4332(2)(E). To achieve these ends, an EIS must “[r]igorously 

explore and objectively evaluate all reasonable alternatives.” 40 C.F.R. § 1502.14; Utahns for 

Better Transp., 305 F.3d at 1166 (emphasis added). This alternatives analysis is “the heart of the 

[EIS].” 40 CFR § 1502.14. Unfortunately, in the case of the SDEIS and FEIS, the Forest Service 

appears to have failed to analyze and consider in detail a range of reasonable leasing alternatives 

in accordance with 40 CFR § 1502.14. Of particular concern is that every action alternative 

considered by the Forest Service is virtually similar in amount of oil and gas leasing allowed and 

in the environmental impacts...Clearly a number of alternatives exist to address the air quality 

impacts of oil and gas development on the Santa Fe National Forest. We request the Forest 

Service analyze in detail such alternatives to ensure full protection of air quality.

Comment submitted by: WildEarth Guardians

Response to Comment 14

As discussed in the FEIS pages 23 through 41, three alternatives (including the No Action) were 

analyzed in detail and six additional alternatives were considered, but eliminated from detailed 

study. As stated in the January 7, 2009, Appeal No. 09-03-00-0001-A217 Review Decision 

Findings for Issue 1, “[m]itigation (stipulations) were developed which were appropriate to the 

leasing stage of analysis and decisionmaking. The ROD appropriately defers site-specific NEPA 

analysis with development of site-specific mitigation and monitoring requirements to the time 

when a site-specific APD is received.” As described on pages 26 and 27 of the SFEIS, mitigation 

measures for air quality will be developed during the site-specific NEPA analysis.
OGS Appendix B. Public Comments

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