4.0 Environmental Effects 

4.1 Analysis Assumptions and Guidelines 

Assumptions

1. OPPC construction and operation methods and environmental protection measures are contained in 

the Biological Resources Protection Plan, the Environmental Protection Plan, and other plans 

provided in the draft POD (CH2MHill 2008). These measures would be implemented on federal 

lands, and similar procedures would be used on non-federal lands. Individual landowners may 

include specific construction and reclamation requirements in ROW agreements with OPPC. These 

requirements could result in similar or less environmental impacts than discussed in this chapter. 

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

operate the OPPC Piceance Basin NGL Lateral system (not including powerlines, which would be 

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

permits and approvals are listed in this document. 

Guidelines

1. Activities in the “construction phase” would include the surface-disturbing activities needed to 

construct the pipeline, lateral, pump station, meter stations, pigging facilities, valves, and permanent 

access roads so that the entire pipeline system can be placed into service. It also would include 

reclamation activities for areas where the surface has been disturbed. 

2. Activities in the “operation phase” would include transportation of NGLs in the Overland Pass Pipeline 

system. This definition also includes normal operations, routine pipeline ground and aerial 

inspections, emergency response activities, future routine internal and external integrity inspections 

and repairs along short segments of the entire pipeline, and future remedial restoration activities such 

as reseeding and repair of erosion control structures. 

3. OPPC committed environmental protection measures included in the draft POD were used to 

evaluate environmental impacts. The specific plans are not attached but are referenced in this 

document and can be found on the BLM website as technical reference reports http://www.blm.gov/ 

co/st/en/BLM_Programs/land_use_planning/EA/overland_pipeline.html. The draft POD is currently a 

draft document that will be finalized by OPPC and submitted to BLM for review and approval after 

completion of a Final EA. 

4.1-1 September 2008
4.2-1 September 2008

4.2 Air Quality 

4.2.1 Proposed Action 

Construction Phase

Issues 

• Generation of fugitive dust from construction 

• Combustion emissions from construction equipment 

Analysis 

Construction of the proposed Project would result in intermittent and short-term fugitive emissions. These 

emissions would include fugitive dust from soil disruption, and combustion emissions from construction 

equipment and construction worker commuter vehicles. 

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

would be disturbed, along with the frequency and duration of precipitation events. Fugitive dust emissions 

during construction would be restricted to the brief construction period along each segment of the proposed 

pipeline route, with construction impacts diminishing once construction activities end and after disturbed areas 

are reclaimed. Fugitive particulate emissions from roadways consist of heavier particles and tend to settle out 

of the atmosphere within a few hundred yards. Therefore, fugitive particulate emissions would be limited to the 

immediate vicinity of the proposed Project and the surrounding region would not be significantly impacted. 

Combustion emissions from construction equipment would be minimized because the engines would meet the 

standards for mobile sources established by the USEPA mobile source emission regulations (40 CFR 85). In 

addition, the USEPA required that the maximum sulfur content of diesel fuel for on-road vehicles be reduced 

from 500 parts per million by weight (ppmw) to 15 ppmw as of mid-2006. The USEPA is requiring the sulfur 

content of non-road diesel to be reduced to 15 ppmw as well, reducing SO2 and particulate emissions from 

diesel combustion. CO2 is a naturally occurring gas whose presence in the atmosphere is necessary for all life. 

While areas near the construction of the pipeline may briefly experience slightly higher CO2 concentrations as 

a result of construction vehicular traffic, these concentrations, if measureable, would not cause localized 

adverse human health or ecological impacts. 

CDPHE air quality regulations for fugitive dust emissions applies to construction activities and clearing of land. 

Colorado Regulation No. 1 requires that a fugitive dust control plan be submitted by applicants whose 

source/activity results in fugitive dust emissions. The control plan must enable the source to minimize 

emissions of fugitive dust to a level that is technologically feasible and economically reasonable. 

In addition, opacity from fugitive dust sources cannot equal or exceed 20 percent. During drier periods, dust 

suppression techniques such as the use of water or chemicals to control dust may be used in construction 

zones to minimize fugitive dust impacts, along with covering open-bodied trucks while transporting materials 

that would be likely to produce airborne dusts. 

Colorado Air Pollution Control Division regulations identify certain activities that are exempt from the 

requirement to file an Air Pollutant Emission Notice (APEN) because by themselves, or cumulatively as a 

category, they are deemed to have a negligible impact on air quality. Included in the exempted categories is 

the disturbance of surface areas for purposes of land development that do not exceed 25 contiguous acres, 

and that do not exceed 6 months in duration. If these exemption thresholds are exceeded, an APEN must be 

submitted to the CDPHE. A land development APEN would be submitted for the pipeline construction if the 

exemption thresholds were exceeded. A fugitive dust control plan for land development activities would be 

included with the land development APEN. 
4.2-2 September 2008 

OPPC also would implement dust control measures during certain construction activities such as blasting, 

trenching, and/or use of access roads. These dust control measures, as stated in the Transportation 

Management Plan and the Fugitive Dust Control Plan for the Project include the application of water or, if 

necessary, a non-toxic, biochemical dust suppressant, possibly in combination with mulches applied to the 

areas of disturbances. Other more long-term methods of controlling fugitive dust could include the use of wind 

fences, temporary seeding of spoil piles, gravel, and/or geotechnical matting. 

If OPPC complies with Colorado and Wyoming regulations concerning the mitigation of fugitive dust 

emissions, the proposed Project would incorporate sufficient measures to ensure adequate levels of air quality 

during construction of the pipeline. Air pollutants from construction equipment internal combustion engines 

would be limited to the close proximity of the proposed Project area. Impacts would be short-term and long 

range transport would not occur, resulting in no significant impact on air quality. 

Conclusion 

The procedures proposed by OPPC would be sufficient to minimize impacts to air resources. 

Operational Phase

Issues 

• Operational Emissions 

Analysis 

Although the midpoint pump station is not currently proposed to be constructed, if it is installed in the future the 

only anticipated impacts to air quality would be from an emergency flare that may be located at the pump 

station and from blow downs of the pipeline. Emissions from a blow down of the pipeline would occur in 

emergency situations, and as part of periodic maintenance when pipeline pigging is conducted. Such a blow 

down would generate emissions of hydrocarbons and volatile organic compounds (VOCs). Due to the 

infrequent occurrence, there would be no significant air quality impacts from emergency flaring or blow downs 

from pipeline pigging activities. 

If the pump station would be constructed, operational impacts would be mitigated, as needed, through the 

state permitting process. Air pollutant emissions would likely be below permitting threshold levels and, hence, 

there would be no significant adverse impacts on local or regional air quality. 

Conclusion 

Operational impacts to air quality resources are not expected. 

4.2.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. As a result, the associated 

impacts to air quality would not occur. 
4.2-3 September 2008

4.2.3 GRP Land Re-route Alternative 

The GRP Land Re-route Alternative would be approximately 1.3 miles longer than the Proposed Action. There 

would be no additional pumps or pump stations constructed along this alternative route. As a result of the 

additional length, there would be a slight increase in the emissions and fugitive dust associated with 

construction activities. However, the overall change in the length represents less than a 1 percent change for 

the entire route and therefore would not result in significant overall differences in impacts between the 

alternatives. 
4.3-1 September 2008

4.3 Geology, Minerals, and Paleontological Resources 

4.3.1 Proposed Action 

4.3.1.1 Physiography and Geology 

Construction Phase

Issues 

• Disturbances to topography resulting in disruption of drainage 

Analysis 

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

aboveground facilities due to grading and trenching activities. Upon completion of construction, OPPC would 

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

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

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

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

or hammering with a trackhoe-mounted hydraulic hammer followed by excavation. According to OPPC, 

blasting is not anticipated because the largely sandstone-composed formations can be disaggregated by using 

hydraulic hammers. However, in the event blasting is necessary, OPPC has prepared a Blasting Plan for the 

Project. 

Conclusion 

The construction techniques proposed by OPPC are sufficient to minimize impacts and restore surface 

contours. 

Operation Phase

Issues 

• No issues associated with geological resources were identified with operation 

Analysis 

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

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

Conclusion 

No significant adverse impacts to geological resources would be anticipated due to operations. 

4.3.1.2 Mineral Resources 

Construction Phase

Issues 

• Potential interference with existing mining or oil and gas operations 
4.3-2 September 2008 

Analysis 

As shown in Table 3.2-2, the proposed pipeline route crosses numerous oil and gas fields. In addition, the 

proposed route may cross aggregate resources in alluvial valleys and river terraces. Nevertheless, 

construction would have very minor and short-term impact on current mineral extraction activities due to the 

temporary and localized nature of pipeline construction activities. 

Several oil and gas wells were identified within or close to the proposed pipeline construction ROW 

(Table 3.2-3). Construction activities potentially could damage wells, associated underground fluid lines and 

pipelines, and disrupt normal operations and routine maintenance. Also, damage to oil and gas facilities, if they 

should occur, could present severe health and safety and contamination hazards. Abandoned wells also could 

be impacted since construction potentially could remove existing abandoned well markers and damage nearsurface cement plugs. Because oil and gas are produced from depths of more than 1,000 feet, construction of 

the pipeline would not be expected to affect the oil and natural gas producing formations. Rather, any 

construction-related impacts would be limited to surface or near-surface components of the wells and 

gathering systems, which would temporarily disrupt production until repairs are made. Prior to construction, 

OPPC would identify the exact locations of active, shut-in, and abandoned wells and any associated 

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

such facilities. OPPC also would abide by utility locate rules in the respective states and conduct due diligence 

to identify and contact all oil and gas well operators and pipeline gathering system owners prior to construction 

activities. 

Conclusion 

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

during construction and would be minimized by OPPC working with the owners and/or operators of oil and gas 

facilities during ROW negotiations and facilities construction. Because construction of the pipeline would be 

limited to near-surface disturbance, the proposed Project would not impact oil and gas production. 

Operation Phase

Issues 

• Potential for reduced access to underlying minerals 

• Potential interference with future mining operations 

• Potential subsidence over underground mined-out voids leading to loss of ground support and 

damage or breakage of pipe 

Analysis 

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

route would be in an existing pipeline corridor and would not hinder access to mineral resources. The 

proposed ROW corridor does not pose a hindrance to access to oil and gas resources. Although the proposed 

route is in an area of potential exploitable minerals (coal and oil shale), no current plans to mine such 

resources were identified. No active or abandoned underground mine workings were identified along the 

proposed route, therefore, ground subsidence issues associated with underground mining are not a concern. 

Conclusion 

Operation of the proposed Project would not have a significant added impact on current or future mineral 

recovery operations in the area because most of the proposed pipeline route would follow existing ROWs that 

have already precluded mineral development through the corridor. Additionally, impacts on future mineral 

development would not constitute a significant loss of mineral resource or mineral availability because of the 
4.3-3 September 2008

narrow, linear nature of the pipeline ROW relative to the expanse of areas with mineral resource potential. It is 

anticipated that the pipeline trench would be backfilled with materials derived from the trench excavation, and it 

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

use as pipe padding, road base, or surface facility pads. These demands for sand and gravel would not 

substantially affect the long-term availability of construction materials in the area. 

4.3.1.3 Geological Hazards 

Construction Phase

Issues 

• Potential damage to the pipeline and the safety of the workers due to geologic hazards encountered 

during construction 

Analysis 

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

construction on steep slopes resulting in instability that would lead to landslides. When selecting the proposed 

pipeline route, OPPC attempted to minimize the amount of steep slopes crossed by the pipeline. Special 

pipeline construction practices described in the POD (CH2MHill 2008) would minimize slope stability concerns 

during construction. Implementation of the Environmental Protection Plan and Blasting Plan would reduce the 

potential for construction-related activities to trigger landslides or other slope failures. 

Conclusion 

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

conditions or worsen existing unfavorable geologic conditions in the area. 

Operation Phase

Issues 

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

subsidence) and fault displacement 

• Potential damage to the pipeline from flood scour 

Analysis 

Seismicity

Seismic hazards to Project facilities would include strong ground shaking, surface faulting, or secondary 

ground deformation such as liquefaction and flow failure. Pipelines and aboveground facilities are capable of 

withstanding substantial ground motion. The proposed Project would be in an area where the probability of a 

strong earthquake is low. Since ground motion hazard probability is low, there would be a low risk of related 

hazards of earthquake induced landslides. The proposed Project does not cross identified active faults so 

ground displacement due to fault movement is not a concern. 

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

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

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

or faulting could have on the proposed Project facilities. 
4.3-4 September 2008 

Flooding and Scour

Flooding hazards to Project facilities would include inundating surface facilities, causing debris flows, or 

scouring stream beds at the point of the pipeline crossing. Severe scouring often leaves unsupported spans of 

pipe exposed. In general, seasonal flooding hazards exist where the proposed pipeline route would cross 

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

watersheds. The proposed pipeline route would cross perennial and ephemeral streams as identified in 

Appendix A. All these crossings are potential seasonal or flash flooding locations. Though flooding in and of 

itself does not represent a significant risk to buried pipelines, stream scour and mud/debris flows often 

accompanying flooding can impact pipelines by exposing and leaving unsupported spans of pipe. To minimize 

these effects, the proposed pipeline would be buried at a sufficient depth to avoid possible scour at waterbody 

crossings. In addition, regular visual inspection of the proposed pipeline route would be used to identify areas 

that would be potentially exposed after flood events. The aboveground facilities are not located within areas 

susceptible to flooding. 

Conclusion 

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

conditions in the proposed Project area. Due to the proposed pipeline routing and design, it is unlikely that the 

proposed pipeline facilities would suffer significant damage from geologic hazards or other naturally occurring 

events during operation. Further, operation of the proposed Project and facilities would not worsen unfavorable 

geologic conditions in the area. 

4.3.1.4 Paleontological Resources 

Construction Phase

Issues 

• Potential damage and loss of scientifically important fossils from ROW clearing, grading, trench 

excavation, and construction of other pipeline facilities 

Analysis 

Potential impacts to fossil localities during construction would be both direct and indirect. Direct impacts to or 

destruction of fossils would occur from trenching or facility construction activities conducted through significant 

fossil beds. Indirect impacts during construction would include erosion of fossil beds due to slope regrading 

and vegetation clearing or the unauthorized collection of scientifically important fossils by construction workers 

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

To manage impacts to fossil localities, OPPC would implement the measures in the Paleontological Resources 

Protection Plan (Paleo Plan) to protect fossil resources on federal lands encountered during proposed Project 

construction, including the resources identified during the field survey. Paleontological resource monitoring 

would be conducted by Paleontological Monitors to ensure that fossils are preserved and to ascertain whether 

construction may continue after the unexpected discovery of any vertebrate fossils. Work conducted under the 

Paleo Plan would be performed by qualified paleontologists with trained assistants. 

Paleontological Monitors would monitor construction as defined in the Paleo Plan. The construction contractor 

would be responsible for notifying a Project Environmental Inspector at least 72 hours in advance of 

construction in areas requiring monitoring, so that Paleontological Monitors can be deployed where required. 

The construction contractor would be responsible for all construction delays due to insufficient notification. 

Areas requiring paleontological monitoring also are included in Attachment 1 of the Paleo Plan. 
4.3-5 September 2008

The Paleontological Monitor would follow the trenching equipment at a cautionary distance, allowing time for 

construction dust to settle and for visible detection of fossils. Paleontological monitoring also would involve 

periodic spot-checking of the trench prior to backfill activities. 

Paleontological Monitors would document daily monitoring activities on daily monitoring report forms that 

would be delivered to the Environmental Inspector on a daily basis. Paleontological monitoring results would 

be reported on a bi-weekly basis to the BLM Authorized Officer in a short letter report. 

If fossils are discovered during construction, the Contractor would immediately stop all work near the 

discovery. The following steps would be implemented when fossils are discovered: 

• Cease all earth disturbing activity within 100 feet of the discovery. 

• Contact the BLM Authorized Officer, Environmental Inspector, and Paleontological Monitor 

immediately. The Paleontological Monitor would assess the nature of the discovery and determine the 

necessary course of action. If necessary, the Paleontological Monitor would mark the area and 

recommend procedures to be implemented to avoid further site damage. OPPC would protect the 

discovery until removed. 

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

without the written consent of the landowners. 

Conclusion 

Adherence to the Paleo Plan would minimize adverse impacts to scientifically important paleontological 

resources on federal lands. Important paleontological resources on non-federal lands may be recovered only 

with approval of the landowners, and therefore, may be unavailable for scientific curation. 

Operation Phase

Issues 

• Potential damage and loss of scientifically important fossils from maintenance activities 

Analysis 

Any potential effects to fossils from maintenance activities would be isolated due to the probable dispersed 

nature of maintenance activities. Also, potential impact during operations and maintenance would be minimal 

since activity would occur on previously disturbed ROW. 

Conclusion 

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

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

within the ROW that was previously disturbed during construction. Since no new disturbances would be 

anticipated from routine maintenance activities (i.e., maintenance activities would occur within the ROW), 

impacts to paleontological resources would be negligible. However, it is possible that certain types of 

maintenance or repair may require a work space beyond the previously disturbed working ROW. In that case, 

the protection measures will be implemented on federal lands as outlined in the Paleo Plan. 

4.3.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. As a result, none of the 

associated impacts to geologic or mineral resources would occur. 
4.3-6 September 2008 

4.3.3 GRP Land Re-route Alternative 

Potential impacts to geology, mineral resources, and paleontological resources along the GRP Land Re-route 

Alternative would be same as the Proposed Action except for the presence of 5 additional drainage crossings, 

which would somewhat increase the flood hazard potential beyond that of the Proposed Action. However, 

since the upgradient watersheds are small (generally less than one square mile) the overall difference in flood 

hazard between this alternative and the Proposed Action is not significant. Methods to reduce the potential 

effects of flood scour would be the same as for the proposed route. According to the Paleo Plan, monitoring for 

paleontologic resources in this area would consist of spot inspections after trenching but prior to the pipe being 

lowered into the trench. 
4.4-1 September 2008

4.4 Soils 

4.4.1 Proposed Action 

Construction Phase

Issues 

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

construction 

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

• Pre-existing soil contamination or contamination from construction operations 

• Potential for unsuccessful reclamation and establishment of vegetation similar to undisturbed adjacent 

lands 

Analysis 

Soils data were grouped and evaluated according to characteristics that would affect construction or increase 

the potential for soil impacts. These sensitive soil characteristics include: highly erodible soils; prime farmland 

and hydric soils; compaction-prone soils; stony/rocky soils and shallow bedrock; and droughty soils. Additional 

soil-related issues considered in the analysis include revegetation and soil contamination. 

Acres of disturbed soils along the proposed pipeline route are summarized by state and according to the 

previously described soil characteristics that influence the magnitude of construction impacts (Tables 4.4-1 

and 4.4-2). 

Erosion by Water and Wind

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

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

potential may also be influenced by increases in the length of time the soils are bare, and by disruption of 

drainage and erosion control structures. Erosion resulting from water occurs primarily on loose, non-cohesive 

soils on moderate to steep slopes, particularly during high intensity storm events. Wind-induced erosion often 

occurs on dry, fine sandy soils where vegetation cover is sparse and strong winds are prevalent. 

The proposed pipeline route in Colorado would cross moderate to steeply sloping woodlands in Rio Blanco 

County. In Moffat County, the proposed route would cross river basins and dissected, moderately sloping hills 

in the south and gently rolling shrublands to the north. 

The majority of the proposed pipeline route in Wyoming would cross shrublands on gently rolling to moderately 

steep slopes that are moderately to highly erodible if disturbed. Approximately half of the soils that would be 

affected by the proposed pipeline construction are considered highly erodible by wind and water. 

Approximately 167 acres of the soils along the proposed pipeline route in Colorado are highly erodible by wind 

while 46 acres are prone to wind erosion in Wyoming. Approximately 605 acres of soils highly susceptible to 

erosion by water would be crossed in Colorado and 202 acres would be crossed in Wyoming. 

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

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

of parent materials. Although accelerated erosion due to construction-related soil disturbance would potentially 
4.4-2 

Table 4.4-1 Soil Characteristics Along Proposed Pipeline Route in Colorado (acres) 

Proposed Action County 

Wind 

Erosion1

Water 

Erosion2

Compaction 

Prone3 Hydric4

Shallow 

Bedrock5

Prime 

Farmland 

Permanent Easement Rio Blanco 7.1 115.2 117.4 0.4 78.2 37.6 Temporary Easement Rio Blanco 3.6 58.2 58.6 0.2 39.2 18.5 TWAs Rio Blanco 2.3 33.3 25.0 0.8 26.6 5.5 Permanent Easement Moffat 90.1 230.6 216.9 0.1 14.0 84.6 Temporary Easement Moffat 53.1 125.7 111.7 0.1 7.1 44.3 TWAs Moffat 10.4 42.4 42.3 0.1 7.1 16.5 Total8 166.6 605.4 571.9 1.7 172.2 207.0 1Includes soils in wind erodibility groups 1 and 2. 2Includes soils with water erodibility factor for whole soil (kW) >0.22 and Slope Percentage > 8, also includes denuded slopes percentages >30. 3Includes soils that have clay loam or finer texture. 4As designated by the NRCS (2006b). 5Shallow bedrock includes soils with lithic bedrock 60 inches or less from the soil surface. 6Includes soils that have either: a cobbly, stony, bouldery, gravelly, channery, or flaggy modifier to the textural class. 7Includes coarse-textured soils (sandy loams and coarser) that are moderately well to excessively drained. 8Does not include 51.6 acres for off-ROW existing contractor/pipe yard or 5.5 acres for new and potentially widened access roads. Discrepancies in acreage total
4.4-3 

Table 4.4-2 Soil Characteristics Along Proposed Pipeline Route in Wyoming (acres) 

Proposed Action County 

Wind 

Erosion1

Water 

Erosion2

Compaction 

Prone3 Hydric4

Shallow 

Bedrock5

Prime 

Farmland 

Permanent Easement Sweetwater 19.1 114.1 144.5 0.9 15.8 0.0 Temporary Easement Sweetwater 9.4 57.1 72.2 0.4 7.9 0.0 TWAs Sweetwater 3.7 28.7 27.5 0.4 4.0 0.0 Permanent Easement Carbon 8.5 1.0 16.9 0.0 0.0 0.0 Temporary Easement Carbon 4.2 0.5 8.5 0.0 0.0 0.0 TWAs Carbon 1.4 0.2 2.8 0.0 0.0 0.0 Total8 46.3 201.6 272.4 1.7 27.7 0.0 1Includes soils in wind erodibility groups 1 and 2. 2Includes soils with a Kw >0.22 and Slope Percentage > 8, also includes denuded slopes percentages >30. 3Includes soils that have clay loam or finer texture. 4As designated by the NRCS (2006b). 5Shallow bedrock includes soils with lithic bedrock 60 inches or less from the soil surface. 6Includes soils that have either: a cobbly, stony, bouldery, gravelly, channery, or flaggy modifier to the textural class. 7Includes coarse-textured soils (sandy loams and coarser) that are moderately well to excessively drained. 8Does not include 0.8 acre for potential widening of existing access roads. Discrepancies in acreage totals are due to rounding.
4.4-4 September 2008 

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

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

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

left unvegetated or inadequately reclaimed, it would result in increased erosion. 

Soil Productivity

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

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

productive subsoil, thus, impacting revegetation success. Segregation of topsoil helps to mitigate these effects. 

Reclamation would be difficult if topsoil were lost because it may take hundreds to thousands of years for a 

topsoil horizon to form naturally. 

Approximately 52 percent of the soils affected by the proposed Project would have less than 6 inches of 

topsoil. Erosion, rutting, and the mixing of topsoil and subsoil horizons is of particular concern in areas with thin 

topsoil horizons because soil productivity can be drastically decreased if topsoil is mixed with subsoil or topsoil 

is lost to erosion. Approximately 14 percent of the proposed Project would affect soils with greater than 

12 inches of topsoil. Summaries of acres of various topsoil depths along the proposed ROW are located in 

Tables 3.3-1 and 3.3-2. 

On federal lands managed by the BLM, approximately 4 to 12 inches of topsoil would be salvaged from the 

trench line and the working side of the ROW. Prior to construction, OPPC, with the help of a Soil Scientist, 

would identify the depths of topsoil that would be salvaged. These areas would be identified on the 

construction alignment sheets. In areas where more than 6 inches of topsoil would be removed, TWAs may be 

required to stockpile the additional soil. 

On private lands, topsoil would be stripped up to a depth of 6 inches from the trench line; however, at the 

private landowner's request, more than 6 inches of topsoil may be salvaged and/or topsoil would be salvaged 

across the full-width of the ROW or a portion thereof. Up to 12 inches of topsoil would be stripped across the 

trench line or construction ROW on irrigated agricultural lands. However, on any lands that would require 

grading, topsoil would be stripped from the entire portion of the ROW that requires grading. Topsoil would be 

stockpiled separately from subsoil and would not be used to pad the trench or construct trench breakers. 

On private lands, OPPC would chip or shred any brush and other materials cleared from the ROW and 

incorporate into the topsoil. The temporary effects of wood chip additions (at a 3-inch depth) on the soil 

resource would include: increased soil temperature in the winter, moderate increase in soil moisture, and 

substantial decrease in soil nitrogen supply and understory vegetation. The increase in soil temperature and 

soil moisture would have relatively minor ecological effects. However, reductions in the soil nitrogen supply 

may temporarily reduce productivity of the soil and affect revegetation rates (Binkley et al. 2003). With 

increasing depth of mulch, these impacts would increase in magnitude and duration. 

Prime Farmland 

Soils along the proposed ROW are classified as prime farmland if irrigated, irrigated and drained, irrigated and 

reclaimed of excess salts and sodium, irrigated and protected from flooding, or not frequently flooded during 

growing season. Loss or mixing of the topsoil during construction activities would lead to a long-term loss of 

soil productivity on prime farmlands. 

Overall site productivity is primarily a vegetation measure. Productivity varies with vegetation community, but 

more importantly, with land management objectives as they relate to which vegetation types are desirable or 

productive. In contrast, soil quality is an inherent soil resource characteristic involving aeration, permeability, 

texture, salinity and alkalinity, microbial populations, fertility, and other physical and chemical characteristics 

that are accepted as beneficial to overall plant growth and establishment. Based on this concept, there could 
be impacts to the existing quality of native soils from proposed Project-related disturbance. Topsoil excavation 

and redistribution would modify existing soil structure, which would affect aeration and permeability. It is likely 

that some mixing of textural zones would occur, as well as mixing of saline and/or alkaline materials with 

relatively salt-free materials, which would impact soil quality for seedbeds. 

Erosion of the topsoil spoil pile during construction would lead to a decreased amount of topsoil to be placed 

back on the surface, potentially affecting nutrient cycling and long-term soil productivity. The proposed Project 

would disturb approximately 207 acres of prime farmland or potential prime farmland in Colorado. Protecting 

topsoil spoil piles from wind and water erosion is essential in these areas. Prime farmland would not be 

affected in Wyoming. 

Soil Compaction and Rutting

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

construction ROW and on temporary access roads. The degree of compaction would depend on the moisture 

content and texture of the soil at the time of construction. Compaction would be most severe where heavy 

equipment operates on moist to wet soils with high clay contents. Detrimental compaction also could occur on 

soils of various textures and moisture contents if multiple passes are made by high ground-weight equipment. 

Where trenchline only topsoil removal has occurred, moist or wet topsoil would adhere to tires and/or tracked 

vehicles and be carried away. Rutting would occur when the soil strength is not sufficient to support the 

applied load from vehicle traffic. Rutting would impact the surface hydrology of a site as well as the rooting 

environment by physically severing roots and reducing the aeration and infiltration of the soil. Rutting also 

would disrupt natural surface water hydrology by damming surface water flows, creating increased soil 

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

locations with thin topsoils, rutting could mix the topsoil with the subsoil, thereby reducing soil productivity. 

Rutting most likely would occur on moist or wet fine textured soils, such as the Bulkley or the Canburn Series, 

but also could occur on dry sandy soils due to low soil strength. Sandy soils commonly occur along the 

proposed route in Colorado and include soils such as Maybell sands that occur on old dunes, hills, and breaks. 

Soil rutting would be an important indication that other physical soil impacts could be occurring on a site. 

Rutting restrictions would help to mitigate these concerns. 

Approximately 572 acres along the proposed pipeline route in Colorado and 272 acres in Wyoming contain 

soils that are compaction prone. Compaction would damage soil structure and reduce pore space, which 

would impede the movement of air and water to plant roots and could result in lower growth rates and hinder 

revegetation. Compaction would reduce infiltration resulting in excessive surface runoff, erosion, nutrient loss, 

and potential water-quality problems. To minimize such impacts, OPPC would rip all compacted areas to the 

depth of compaction prior to topsoil replacement. 

Fragile and Low Reclamation Potential Soils

Approximately 0.5 acre of soils, near MP 34.9, are considered landslide prone. These soils may be prone to 

slumping and mass movement. OPPC has committed to not constructing surface structures within 0.5 mile of 

MP 34.9 without geotechnical determination of adequate stability at the site. Approximately 26 acres of fragile 

soils would occur along the proposed pipeline route on lands managed by the WRFO. The majority of these 

(24 acres) would be on slopes greater than 35 percent and the remaining 2 acres would be on saline soils. 

Approximately 27 acres of soils are considered fragile as identified by the LSFO. Temporary and permanent 

erosion control measures would be installed to control erosion and transport of sediment. Selection of 

appropriate erosion controls would be based on soil properties, steepness of the slope, and anticipated 

surface flow or runoff. Erosion control measures would include sediment barriers, waterbars, erosion control 

fabric, geotechnical matting, and vegetative and rock mulch. 

Low reclamation potential soils have chemical or physical properties that limit revegetation following 

disturbance. Such chemical and physical properties include salinity, sodicity, highly acidic or alkaline soils, 

4.4-5 September 2008
4.4-6 September 2008 

heavy clays, and droughty sands. According to data provided by the BLM RFO, approximately 233 acres of 

soils in Wyoming have a poor topsoil rating due to high clay content or excess salt. Salts in the soil stress the 

vegetation by making water uptake more difficult, which would impact revegetation success in these areas. 

Reseeding with a salt-tolerant seed mix in these locations would minimize impacts associated with disturbance 

in these areas. Seed mixes are provided as an appendix to the Environmental Protection Plan. High clay 

content soils are prone to compaction and ripping to relieve compaction may be necessary for successful 

reclamation. 

Stony/Rocky Soils and Shallow-to-Bedrock Soils

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

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

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

Approximately 305 acres of the proposed pipeline route contain soils with substantial rocks and stones in the 

surface horizons. The majority of stony/rocky soils occur in steeper segments of the proposed route, with 

233 acres located in Colorado and 72 acres in Wyoming. Summaries of acres in stony-rocky classes are 

provided in Tables 4.4-1 and 4.4-2. 

Approximately 200 acres of soils that would be disturbed by the proposed Project contain shallow hard 

bedrock. The majority of soils containing shallow bedrock would be located in Colorado (172 acres), with an 

additional 28 acres in Wyoming. Approximately 144 acres of shallow-to-bedrock soils would be located in Rio 

Blanco County, Colorado. Summaries of acres in shallow bedrock classes are provided in Tables 4.4-1 and 

4.4-2. 

Sandy Soils

Revegetation success within the construction ROW would be a concern on sandy, droughty soils. Coarsetextured soils in moderately well drained or drier drainage classes would be particularly susceptible to drought. 

Revegetation success on droughty soils would be compromised if seeding and revegetation efforts were to 

occur during dry periods. 

Approximately 446 acres of soils that would be disturbed by the proposed Project are inherently droughty. The 

majority of droughty soils would be located in Colorado (381 acres), with an additional 65 acres in Wyoming. 

Summaries of acres in droughty soil-classes are listed in Tables 4.4-1 and 4.4-2. 

Where sandy soils would be encountered, ROW widths may be increased for safety concerns due to trench 

instability. This would result in additional disturbance in sandy soils along the proposed corridor, particularly 

between MP 52.1 and MP 59.1. 

Drain Tiles and Irrigation Systems

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

generally indicate areas that require drain tiles for crop production. The proposed Project would impact 

approximately 3.4 acres (less than 1 percent of total area) of hydric soils. This represents a small percentage 

of the total acreage that would be impacted, and few, if any, drain tiles would likely be encountered. 

Grading, trenching, and backfilling could disrupt water flow to irrigation systems. OPPC has committed to 

maintain flow and repair irrigation systems to at least pre-construction conditions. Temporary measures would 

be provided, as agreed with the landowner or land management agency, for any facilities disrupted during the 

construction or reclamation process. 
Soil Contamination

Material spills during construction and trench excavation through pre-existing contaminated areas would result 

in soil contamination along the proposed pipeline route. These impacts typically would be minor because of the 

low frequency and volumes of these occurrences. However, if large spills were to occur, they would result in 

the removal and disposal of large amounts of soil. Saturated soils, such as those near and through wetlands 

and waterbodies, have the potential to diffuse contaminants. OPPC would fuel and service construction 

vehicles and stationary equipment only in upland areas at least 100 feet from wetlands and waterbodies. 

Within the Rawlins Resource Area, the setback would be 500 feet from all permanent waters, wells, springs, 

wetlands, and riparian areas, as well as 100 feet from the inner gorge of ephemeral stream channels. All 

stationary equipment would be provided with secondary containment. These measures would avoid or 

minimize potential impacts to saturated soils. 

Roads

Access to the Project would primarily be via existing public roads and dirt roads, such as BLM access roads 

and two-track trails. As described in the Transportation Management Plan, existing access roads could 

require upgrading to allow vehicle and equipment traffic during and after construction. Where grading or 

resurfacing would be required, there would be a short-term increase in erosion and sedimentation to 

connected waterways and the potential for soil mixing. Further upgrades could include straightening, 

widening, adding drainage controls, adding culverts, and constructing cuts-and-fills. These activities could 

result in an increase in compaction, runoff, erosion, and soil mixing, which increases the potential of long-term 

impacts to soil quality. Erosion and drainage controls would be implemented and maintained where such road 

improvements occur. Rutting restrictions on BLM lands would reduce the potential for soil mixing. A maximum 

of 4 inches of rutting for 50 feet would be allowed. No road maintenance or improvements would be 

conducted unless approved by the administering agency or landowner. 

OPPC anticipates the construction of one new road and potential widening of existing roads that would impact 

a maximum of 6.3 acres of land. An increase in runoff, erosion, and sedimentation would occur as soils are 

disturbed and compacted. Indirect effects could include landslides, gullies, and the generation of loose side 

cast material. 

Road embankments would be seeded and mulched as specified in the Environmental Protection Plan. 

Successful implementation and maintenance of erosion and drainage controls along access roads would 

reduce the potential for erosion and sedimentation. If revegetation efforts are delayed or are unsuccessful, 

additional runoff and accelerated erosion from upland sites would occur. Proposed revegetation and erosion 

control programs, as well as subsequent monitoring and maintenance, would minimize the potential for these 

impacts on soil resources. Further discussions of these issues are presented in Section 3.4, Vegetation, and 

Section 4.5.1, Surface Water. 

Impacts associated with trespass by off-highway vehicles (OHV) could include compaction, runoff, erosion, 

and a reduction in reclamation potential, leading to long-term soil quality impacts. Measures would be 

provided to control the use of the proposed ROW and prevent unauthorized travel by OHV’s. Measures would 

include leaving the ROW in a roughened state and scattering vegetative debris across the surface; placing dirt 

berms, rock, or vegetative barriers at intersections with existing roads; and randomly placing boulders, logs 

and stumps across the ROW to discourage OHV use. 

Conclusion 

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

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

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

adverse impacts on the soil resources. However, these impacts would be minimized or avoided by the 

4.4-7 September 2008
4.4-8 September 2008 

implementation of applicant-committed environmental protection measures as stated in the POD (including the 

Environmental Protection Plan). Measures to minimize soil impacts include erosion control measures, topsoil 

separation, and handling procedures, as detailed in the previous paragraphs. Soils impact anticipated from 

pipeline construction include the possibility of reduction of soil quality by topsoil loss or mixing with subsoils, 

and compaction. 

Operation Phase

Issues 

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

maintenance activities 

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

• Soil contamination from pipeline leaks, particularly in prime farmland 

Analysis 

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

ROW. These activities would be dispersed along the length of the proposed pipeline route and would occur 

intermittently. There is a small probability of a pipeline leak, releasing NGL into the environment 

(Section 4.12). NGL primarily consist of gas that is liquefied by pressure (e.g., propane). Consequently, in the 

unlikely event of a pipeline release, NGL components would rapidly volatilize, thereby resulting in minimal 

impacts to soil resources. 

Conclusion 

Maintenance activities would result in localized impacts of short duration and these impacts would be 

dispersed along the entire route. Impacts such as soil mixing and compaction could result from vehicular 

traffic on the ROW. Increased compaction would result in decreased soil infiltration and an increase in runoff 

and erosion. Wind erosion could increase with travel along the corridor. If NGL were accidentally released 

into the environment, impacts to soil resources would be negligible. 

4.4.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. As a result, the related 

impacts to soils would not occur. 

4.4.3 GRP Land Re-route Alternative 

Potential impacts to soils along the GRP Land Re-route Alternative would be similar to the Proposed Action 

except that approximately 11.9 additional acres would be disturbed (30.9 acres along the re-route versus 

19.0 acres along the bypassed section of the Proposed Action). Soil types crossed by the alternative route 

would be similar to those along corresponding segments of the Proposed Action route. However, 

characteristics of those soils vary and due to the additional length, construction of the alternative would result 

in disturbance of 13.4 more acres of wind erodible soils (18.8 acres versus. 5.4 acres), 10.9 more acres of 

water erodible soils (23.6 acres versus 12.7 acres), and 13.1 more acres of droughty soils (23.5 acres versus 

10.4 acres) relative to the Proposed Action. 

Impacts to soils with topsoil depths greater than 12 inches along the GRP Land Re-route Alternative would be 

comparable to the corresponding segment of the proposed pipeline route. However, the re-route would affect 

approximately 11.9 additional acres of soils with topsoil depths less than 12 inches. The overall change in the 
4.4-9 September 2008

length represents less than a 1 percent change for the entire route and therefore would not result in significant 

overall differences in impacts between the alternatives. 
4.5-1 September 2008

4.5 Water Resources 

4.5.1 Proposed Action 

4.5.1.1 Surface Water 

Construction Phase

Issues 

• Increased turbidity and sediment transport in streams resulting from construction of waterbody 

crossings 

• Channel and bank modifications that affect channel geomorphology 

• Increased turbidity, sediment transport, or chemical contamination in streams resulting from runoff and 

erosion from upland sources, including access roads and ditches 

• Risk of spills or leaks of fuel, solvents, wash water, or hazardous materials, or of storm water and 

trench dewatering discharges into waterbodies 

• Flow reductions where withdrawals are pumped from surface water sources for pressure testing or 

dust control 

• Accelerated erosion, turbidity, and sediment transport or other water quality degradation from 

discharges of pressure test water 

• Potential transmittal of nuisance aquatic organisms in pressure test water discharges 

Analysis 

Waterbody Crossings

The Environmental Protection Plan describes the methods that would be used for crossing dry drainages and 

flowing stream channels. Typically, the smaller, dry channels would be crossed by open-cut techniques as 

used for upland construction. Except for the larger rivers, flowing or wet channels would be crossed with 

flumes or other open-cut techniques. All waterbodies that would be crossed and the proposed crossing 

methods for each are listed in Appendix A. 

Where flowing streams are crossed by wet open-cut methods, temporary increases in flow turbidity and 

sediment transport would occur. Increased turbidity and sedimentation would create temporary adverse 

impacts to water quality from such sites. In some cases, modifications of stream geometry at open-cut 

crossings may change flow velocities or depths in ways that encourage further erosion and sedimentation over 

time. Such changes also may adversely affect the habitat and movement of aquatic species. Refer to 

Section 4.7.1.2 for potential impacts to aquatic species. 

The sections describing erosion control measures and wetland and waterbody construction methods in the 

Environmental Protection Plan further identify procedures and practices that would be applied to avoid or 

minimize impacts to surface water resources. A number of BMPs are proposed in these sections that would 

control erosion and minimize the movement of sediment into waterbodies or dry stream channels. The 

potential for adverse impacts to surface water resources would be minimized by the successful implementation 

of these practices. 

Proposed site stabilization practices that would reduce the potential for impacts to surface water resources 

include sediment barriers, waterbars, trench breakers, and the use of mulches and/or erosion control netting in 

combination with revegetation efforts. Sediment barriers typically would consist of anchored straw bales, 
4.5-2 September 2008 

excelsior logs (“coir logs”), silt fences, or sandbags. Waterbars would be placed on slopes susceptible to 

erosion and near the base of slopes adjacent to wetlands, riparian areas, and watercourses. Berms would be 

made from disturbed soil materials within the construction ROW. Both temporary and permanent waterbars 

would be constructed in accordance with the phase of construction. Waterbar spacing would vary with slope; 

they would be spaced at closer intervals on steeper slopes. 

Trench breakers made of polyurethane foam or sandbags would be installed around the pipe in the trench to 

restrict or slow groundwater flow along the trench. These installations would be completed before trench 

backfilling on steep slopes and on slopes adjacent to waterbodies and wetlands. 

Any necessary trench dewatering would comply with applicable permit requirements. Dewatering discharges 

would be directed at a controlled rate onto a stable surface and would employ a section of geotextile fabric, a 

siltation bag, straw bale structure, or a similar erosion control practice to prevent scouring during discharge. 

Further descriptions of mulching, the use of erosion control fabrics, and revegetation practices are presented 

in the POD (CH2M Hill Trigon, Inc. 2008) and in the Soils and Vegetation sections of this EA (Sections 4.4 and 

4.6, respectively). 

Monitoring of erosion control practices would occur during construction through environmental inspections 

conducted by OPPC, agency staff, and third-party personnel. Post-construction monitoring and maintenance 

of erosion control practices are proposed as part of the Environmental Protection Plan. 

As described in the POD (CH2M Hill Trigon, Inc. 2008), vehicles and equipment would cross waterbodies and 

wetlands as necessary on various types of equipment bridges or mats. Excavated spoil would be stored at 

least 10 feet from the water’s edge or above the ordinary high water mark, and would be isolated from the 

waterbody by sediment containment features. Streambanks would be returned to their original contour, or 

returned to a more stable configuration, and stabilized. In cases where over-steepened or undercut banks 

currently occur, beneficial effects would result from recontouring and stabilizing the crossing site. 

Waterbody crossing impacts also would be limited by the implementation of proposed sediment control 

practices. Sediment barriers would be used at these crossings to minimize the transfer of sediment and 

excavated spoil. Bed materials would be replaced to restore the channel to pre-disturbance conditions. With 

successful controls, impacts would be minimized and would be limited to within several hundred feet of the 

crossing. Most crossing activities would be completed within 24 hours. As a result, both the extent and 

duration of impacts would be minimal. With proposed bank restoration, long-term adverse impacts from 

channel geometry modifications are not anticipated. Care must be taken with the use of rip-rap, timbers, or 

other “hard engineering” practices if pipeline crossings are located on stream bends or meander loops. 

Anchoring such a channel location would promote more pronounced changes in stream planform elsewhere in 

the vicinity. Adverse impacts, such as bank caving, potentially would result from such geomorphic responses. 

These proposed practices also would limit the potential for adverse impacts on floodplains as delineated by 

FEMA in Rio Blanco County, and elsewhere at proposed waterbody crossings where floodplains may exist. 

Since the proposed pipeline would be buried and no buildings that could affect floodwater elevations or 

velocities are proposed in floodplains, no impacts from floodway constrictions would occur. The successful 

implementation of proposed topsoil and spoil handling, erosion control and backfill practices, trench 

dewatering guidelines, restoration of irrigation systems, and the application of revegetation practices would 

further mitigate potential impacts to floodplains. 

Site-specific crossing plans would be provided as attachments to appendices of the final POD. HDD plans for 

the White, Yampa, and Little Snake rivers would be provided, as would plans for the crossings at Piceance 

Creek, Dry Fork, Willow Creek, and Sand Creek. These plans would be referenced from the general POD text. 

The larger waterbodies, specifically the White, Yampa, and Little Snake rivers, would be crossed by the HDD 

method. Assuming a successful HDD crossing is constructed at each of these rivers, only minor turbidity 

impacts would be anticipated from light disturbance associated with the preliminary crossing set-up. If it 
4.5-3 September 2008

occurred, an inadvertent release of drilling fluids (a “frac-out”) would degrade water quality during HDD 

activities where this water crossing method is proposed. 

In the unlikely event of a frac-out of drilling fluids, drilling activities would cease and countermeasures would be 

implemented. In such cases, turbidity and sedimentation impacts, as well as minor amounts of chemical 

constituents, would adversely affect the waterbody for some distance downstream. Due to mud flocculation 

and settling, such effects would probably occur within 0.5-mile or so of the HDD site. Major factors in reducing 

the potential for drilling fluid releases at HDD crossings include the type of soil and rock material and the depth 

of cover material. Cohesive soils, such as clays, dense sands, and competent rock are preferred materials for 

horizontal drilling. The depth of these overburden materials also is a consideration. The overburden materials 

and profiles for the proposed crossings minimize the potential for releases of drilling fluids, by employing 

smooth and gradual vertical curves in favorable materials for successful HDD completion. 

HDD activities constantly would be monitored on this Project. The Drill Fluid Contingency Plan describes 

monitoring measures that would be used to determine if an inadvertent release were to occur. This plan also 

describes notification, containment, and cleanup procedures and practices that would be used in the event of a 

drilling fluid release. Based on the measures presented in this plan, the potential for impacts to surface water 

quality and related habitats would be minimized. 

Runoff and Water Quality Effects from Disturbed Upland Sources

Surface water quality impacts may result from increased runoff, erosion, and sediment yield from upland 

excavation and along access roads and ditches. As described in the Transportation Management Plan, 

existing access roads may require upgrading to allow vehicle and equipment traffic during and after 

construction. Where necessary, such upgrades may include grading, straightening, widening, adding drainage 

controls, adding culverts, constructing cuts-and-fills, and resurfacing. The potential for ongoing erosion and 

sedimentation from these activities presents the potential for long-term and extensive impacts to surface water 

quality, stream channel conditions, and associated aquatic habitats. Erosion and drainage controls would be 

implemented and maintained where such road improvements occur. No road maintenance or improvements 

would be conducted unless approved by the administering agency or landowner. 

OPPC does not expect to construct new roads across lands managed by the BLM. However, if new road 

construction were to become necessary on lands managed by federal, state, or county agencies, OPPC would 

acquire all necessary permits, clearances, and authorizations. Waterbars, culverts, ditches, and drainage 

installations would be constructed of stable materials and maintained to agency and landowner standards. 

Road embankments would be seeded and mulched as specified in the Environmental Protection Plan. 

Successful implementation and maintenance of erosion and drainage controls along access roads would 

reduce the potential for site instabilities along streams and for impacts to surface water quality. 

If large amounts of herbicides or pesticides entered stream courses during or after revegetation efforts, 

substantial water quality impacts would occur. In addition, if revegetation efforts are delayed or are 

unsuccessful, additional runoff and accelerated erosion from upland sites would contribute to increases in 

streamflow, turbidity, and sediment loading. These would be indirect effects on surface water from direct 

impacts related to vegetation and soils. Proposed revegetation and erosion control programs, as well as 

subsequent monitoring and maintenance, would minimize the potential for these indirect impacts on surface 

water resources. Further discussions of these issues are presented in Section 4.4, Soils, and Section 4.6, 

Vegetation. 

Spills or Leaks

Other surface water quality impacts could result from spills of fuel, solvents, cleaning fluids, or hazardous 

materials. The risk or volume that could be involved in such an event have not been quantified, but are 

anticipated to be low. OPPC proposes to isolate hazardous materials in contractor yards with adequate 
4.5-4 September 2008 

containment as required by material storage regulations. Further details of hazardous materials management 

and spill prevention, control, and countermeasures, are described in the Hazardous Materials Management 

and Spill Prevention, Containment, and Countermeasures Plan and in the Environmental Protection Plan. 

According to these plans, construction vehicles (e.g., trucks, bulldozers, etc.) and stationary equipment 

(e.g., pumps, generators, etc.) would be fueled and serviced in upland areas at least 100 feet from 

waterbodies and wetlands. Within the Rawlins Resource Area, the set back would be 500 feet from all 

permanent waters, wells, springs, wetlands, and riparian areas, as well as 100 feet from the inner gorge of 

ephemeral stream channels. All stationary equipment (such as pumps and generators) would be provided with 

secondary containment structures to prevent the spill or release of hazardous materials into waterways. 

Refueling areas generally would be flat to minimize the chance of any spilled substances reaching 

waterbodies. Based on implementation of these procedures, impacts to surface water quality from these 

activities would be avoided or minimized. 

Storm Water and Trench Dewatering

The Storm Water Management Plan (attachment to the Environmental Protection Plan) identifies the methods 

of construction, site stabilization, trench dewatering, and erosion controls that would be used to avoid or 

minimize the potential for impacts to surface water quality from grading and excavation. Good housekeeping, 

site inspections, structural and nonstructural practices to control erosion, and avoidance of discharging 

silt-laden trench water into streams are set forth in this plan. Temporary and permanent stabilization measures 

are defined. With successful implementation of the Storm Water Management Plan, impacts to surface water 

quality from storm drainage and trench dewatering would be reduced. 

Withdrawals and Discharges for Hydrostatic Testing and Dust Control

Plans and procedures set forth in the POD (CH2M Hill Trigon, Inc. 2008) describe the proposed approaches to 

water withdrawals, discharges, and related water quality considerations during construction and operation of 

the proposed Project. With respect to potential water quantity impacts, the Hydrostatic Test Plan specifies that: 

• Test water would be withdrawn from approved/permitted sources. 

• Water used for test purposes would be sampled and analyzed as required (during appropriation and 

discharge). 

• Screens would be used on the intakes from surface water sources to prevent the entrainment of fish 

or other aquatic species. 

• Withdrawal rates would be monitored to ensure that adequate downstream flow is maintained to 

support aquatic life. 

The Hydrostatic Test Plan identifies the water sources and withdrawals that would be used for testing the 

integrity of the proposed pipeline during construction. Water sources for this purpose would be withdrawn from 

the White and Yampa rivers, and possibly from the Little Snake River. It is anticipated that additional water 

withdrawals for dust control and equipment washing also would occur from these same locations. 

Existing surface water rights would be used for obtaining water needed for construction. Withdrawal volumes 

would be obtained and source locations identified in accordance with temporary appropriation procedures 

through the Colorado Division of Water Resources. As described in the Hydrostatic Test Plan, approximately 

3.6 million gallons of water (about 11 acre-feet) would be needed for hydrostatic testing overall. Approximately 

860,000 gallons (2.6 acre-feet) would be withdrawn from the White River, and approximately 1.15 million 

gallons (3.5 acre-feet) would be withdrawn from the Yampa River. An additional 1.6 million gallons 

(approximately 4.9 acre-feet) would be withdrawn from the Little Snake River, if supplies are available. If 

conditions in the Little Snake River do not allow for this amount of withdrawal, additional water would be used 

from the Yampa River. Under such circumstances, withdrawals from the Yampa River may be up to 
4.5-5 September 2008

approximately 2.75 million gallons (about 8.4 acre-feet). Water from each source would be used for 

approximately 8 to 10 days before being returned to the original source at the uptake location. 

Currently, OPPC plans to withdraw at rates of approximately 500 to 1,000 gallons per minute (about 1.1 to 

2.2 cfs) through screened intakes to prevent the entrapment of fish or other aquatic species. Based on 

historical gaging records, average monthly flows from July through March on the White River below Meeker 

(USGS Station 09304800) range from about 330 to 710 cfs. Average monthly flows from July through March 

on the Yampa River near Maybell (USGS Station 09251000) range from about 240 to 1,340 cfs. Average 

monthly flows from July through March on the Little Snake River near Slater (USGS Station 09251000) range 

from about 30 to 150 cfs. Flows in the Little Snake River at a withdrawal site near the proposed ROW may 

vary from these averages due to irrigation withdrawals and releases from High Savery Dam upstream. In any 

case, the proposed withdrawals for hydrostatic testing represent a minimal portion of the average monthly 

flows in these rivers. Since supplies would be obtained in accordance with existing water rights, impacts to 

surface water quantities are anticipated to be small. Effects from construction withdrawls would be similar to 

those from existing withdrawals made in accordance with existing water rights. Any impacts to water resources 

would be isolated and short-term. Refer to Section 4.7.1.2, Aquatic Resources, for a further discussion on 

potential impacts on aquatic species, particularly endangered fish, and related agency considerations. 

After testing, water would be discharged in accordance with Project permits and other measures as needed. 

In addition, energy-dissipating devices and/or filter bags would be used to prevent scour, erosion, suspension 

of sediment, and damage to vegetation. Discharge rates would be monitored to ensure effectiveness of the 

energy-dissipating devices. 

Potential impacts from test water discharges would include releases of small concentrations of solvents or 

particulates carried from the discharge to receiving streams; erosion and sedimentation from upland discharge 

sites or within nearby channels; and the potential for transfer of parasites or nuisance aquatic organisms from 

one waterbody to another. The severity of these impacts would vary according to the water source, the nature 

of the pipe, the discharge sites, and controls on the rate and migration of discharges. 

If required in state discharge permits, OPPC would test the quality of the test water prior to discharge. 

Frequently, such permits call for testing of a grab sample for iron, total suspended solids, sheen from oil and 

grease, and pH. The construction contractor would use an energy-dissipation structure (such as a straw-bale 

barrier) to prevent scour, erosion, and vegetation damage during discharge. OPPC has committed to 

implementing good engineering judgment during discharges, so that all federal, state, and local environmental 

requirements would be met. 

Potential impacts from discharges of test water directly into a stream or river include a decrease of the 

dissolved oxygen content within the zone of mixing between the discharge and the streamflow and erosion of 

the bed or banks resulting in increased turbidity and sedimentation downstream of the discharge. Both of these 

effects would create adverse impacts on water quality for unknown distances downstream. Discharges at 

upland sites near the source, if used, may accelerate erosion due to concentrated overland flow. 

To reduce the potential for these impacts, OPPC has agreed to discharge water used for hydrostatic testing 

back to the locations where the water was initially withdrawn. OPPC would use controlled discharge rates into 

straw bale/silt fence dewatering structure near the source riverbank. Discharge velocity would be controlled so 

as to maintain the integrity of the discharge structure and avoid impacts from erosion. The BLM WRFO would 

be contacted at least 1 day prior to discharging back to the White River. 

For purposes of this assessment, it is assumed that the water for dust control would be the same surface 

waterbody locations as those used for hydrostatic testing. Based on estimates from similar projects in the 

region, roughly 35 acre-feet of water may be needed for this purpose. Since water used for dust control would 

seep into the ground or evaporate, it would be entirely consumed. Such withdrawals, if assumed to originate 

from surface water resources, would represent depletions in surface water quantity. Dust control withdrawals 
4.5-6 September 2008 

would be made intermittently, on an as-needed basis, and would likely use streams with larger flows. OPPC 

would implement precautions for avoiding entrainment of fish or other aquatic species, or causing detrimental 

flow reductions downstream during dust control withdrawals from surface waters. OPPC would comply with 

agency compensation requirements for depletions, as further described in Section 4.7.1.2, Aquatic Resources. 

Conclusions 

Potential adverse impacts to surface water resources, including both to water quality and water quantity, could 

occur during construction due to withdrawals from rivers and streams. Surface water withdrawals would be 

needed for hydrostatic testing of the pipeline, dust control, and equipment washing. Potential impacts to 

surface water quality would result from spills or leaks of fuel or hazardous materials into watercourses, from 

erosion and sedimentation of disturbed streambeds and banks, from trench dewatering, or from discharges of 

hydrostatic testing water. Water and cleaning fluids draining from equipment wash stations would transport 

contaminants into waterbodies if these facilities were not adequately located or contained. Implementation of 

the proposed procedures and practices set forth in the POD (CH2M Hill Trigon, Inc. 2008) would avoid or 

reduce the potential for such impacts. 

Operations Phase

Issues 

• Pipeline ruptures or leaks could spill liquid products into waterbodies, degrading water quality 

• If revegetation, road and ditch stabilization, or other erosion control efforts were unsuccessful over the 

long term, adverse effects on channel morphology or surface water quantity and quality would result 

• Potential impacts on the proposed pipeline from flooding or channel scour also may occur 

Analysis 

If pipeline ruptures or leaks occurred during the life of the Project, surface water quality would be adversely 

affected if such events happened in proximity to waterbodies or watercourses. Since the pipeline would be 

buried, constantly monitored, and periodically inspected and maintained, the potential for spills from pipeline 

failures is limited. In addition, shutoff and check valves would be located at larger stream crossings, including 

the White, Yampa, and Little Snake rivers. Other valves would be located along upper Strawberry Creek, the 

headwaters of Deception Creek, and near upper Spring Creek in Moffat County, as shown on Figure 2.1-2. 

Pipeline controls also would be located at the Willow Creek Gas Plant near Piceance Creek. 

During operations, if a pipeline leak or rupture were to occur near a waterbody, or if runoff from contaminated 

soils were to enter a waterbody, short-term impacts on surface water quality would occur. Since NGL are 

liquified under pressure, they would rapidly volatilize and evaporate when released into the environment. NGL 

are minimally water-soluble, so impacts on water resources from a leak or rupture would be localized. The 

installation of valves near waterbody crossings and the nature of NGL would reduce the potential for impacts 

to surface water quality from any pipeline ruptures. Additional pipeline materials specifications, monitoring 

systems, and measures that would decrease the potential for surface water impacts from pipeline ruptures or 

leaks are described in Section 4.12, Public Health and Safety. As a result of these pipeline management 

procedures and practices, there is a very low risk of surface water impacts from a rupture or leak. 

Potential impacts on surface water from delays or unsuccessful revegetation and erosion control efforts are 

discussed under the construction impacts. Other discussions of these issues are presented in the Soils and 

the Vegetation assessments in Sections 4.4 and 4.6, respectively. Potential impacts on the proposed pipeline 

from flooding or channel scour are discussed in the Geology assessment in Section 4.3. 
4.5-7 September 2008

Conclusion 

Assuming that pipeline infrastructure and monitoring practices successfully manage the transport of liquid 

products, the risk of surface water quality impacts from pipeline ruptures or leaks would be small. In the highly 

unlikely event that a rupture or leak occurred, spill response and countermeasures combined with rapid 

volatilization of the product would minimize the impacts to surface water quality. 

4.5.1.2 Groundwater 

Construction Phase

Issues 

• Contamination of near-surface groundwater as a result of spills during refueling or storage and 

handling of lubricants, solvents, or other materials 

• Interference with existing groundwater movement and supply in areas of shallow groundwater or 

springs, as a result of trenching or blasting 

Analysis 

No public water supply wells or wellhead protection areas are known to be located within 400 feet of the 

proposed pipeline route. Only one private well, near MP 138, would be located within 150 feet of the proposed 

centerline. This well would be approximately 95 feet from the centerline. 

OPPC has no plans to use groundwater during construction or operation; consequently, impacts to 

groundwater quantity would be limited to those caused by the physical disturbance of the overlying soils and 

runoff during grading, trenching, and blasting. 

Impacts to groundwater resources would be minimized or avoided by the use of standard construction best 

practices. Ground disturbance associated with typical pipeline construction primarily would be limited to 10 feet 

or less below the existing ground surface, which is above most surficial aquifers and wells that might be 

completed in a shallow aquifer. Nevertheless, construction activities such as trenching, blasting, dewatering, 

and backfilling could encounter shallow alluvial aquifers and cause minor fluctuations in shallow groundwater 

levels and/or increased turbidity within the aquifer immediately adjacent to the activity. Impacts to deeper 

aquifers would not be anticipated. Since most shallow alluvial aquifers exhibit rapid recharge and groundwater 

movement, shallow aquifers would likely quickly reestablish equilibrium if disturbed and turbidity levels would 

rapidly subside. Therefore, the effects of construction would be short-term. 

A potential hazard of long-term groundwater contamination exists from vehicle refueling and maintenance, 

from hazardous material spills that occur during construction, or from the disturbance of contaminated soils. 

Spills or leaks of fuels or other hazardous liquids would affect groundwater quality, and dispersal of pollutants 

from affected soils potentially would be a continuing source of aquifer contamination. The deterioration of 

groundwater quality by such factors would adversely affect groundwater uses. These impacts would be 

avoided or minimized by restricting the locations of parking, refueling, and storage areas and by implementing 

procedures to prevent and respond to spills or leaks of hazardous materials. 

In the event that contaminated soil and/or groundwater contamination would occur during construction, OPPC 

would notify the affected landowner and coordinate with the appropriate federal and state agencies as 

mandated by notification requirements. Pipeline construction may involve disposal of groundwater 

encountered during trench excavation. If the disposal structures are located outside the cleared disturbed 

area, prior approval from the landowner and federal and state agencies would be required. By law, OPPC is 

required to apply to the states for temporary groundwater disposal permits, and comply with permit stipulations 
4.5-8 September 2008 

as well as erosion control/revegetation. It is expected that such regulatory compliance would avoid or minimize 

potential groundwater impacts from trench dewatering. 

Procedures to address prevention of spills, as well as preparedness for rapid containment and prompt and 

effective cleanup of spills are described in the Hazardous Materials Management and Spill Prevention, 

Containment, and Countermeasures Plan. This plan: 

• Identifies preventative measures to avoid hazardous material spills or leaks; 

• Provides for vehicle and equipment inspection and maintenance; 

• Defines proper storage and handling of fuels, lubricants, and hazardous materials; 

• Identifies immediate spill response procedures for uplands, wetlands, or waterbodies; and 

• Establishes reporting and notification protocols. 

Conclusion 

Implementation of the measures and the procedures contained in the Hazardous Materials Management and 

Spill Prevention, Containment, and Countermeasures Plan for the proposed Project would avoid or minimize 

potential impacts associated with vehicle and equipment refueling and lubricating activities, hazardous material 

storage and handling, and responses to spills or leaks of hazardous materials during construction of the 

proposed Project. 

Operation Phase

Issues 

• Potential reductions in groundwater quality from pipeline spills, leaks, or ruptures on shallow aquifers 

used for rural residential, livestock, and municipal water supplies 

Analysis 

If a pipeline leak would occur, released NGL would vaporize. Limited NGL able to instantaneously soak into 

the soil would quickly evaporate, then percolate up through the soil and sediments, and dissipate into the 

atmosphere. Most, if not all, of the NGL components would evaporate on the land surface or within the vadose 

(unsaturated) zone above the water table. Only approximately 2 to 4 percent of the NGL components would 

not readily volatilize at atmospheric pressure. A small portion of these could enter shallow groundwater 

depending on the location of the rupture or leak after eventually migrating through unsaturated materials. 

Because of their slight solubility in water, contamination from NGL components would be limited to a few ppm. 

These concentrations would be further reduced by diffusion and natural attenuation, which would further 

reduce the risk to potential receptors (BLM 2005). 

Conclusion 

During future operation and maintenance activities, OPPC would continue to adhere to standards within the 

Project-specific plans as outlined in the POD (CH2M Hill Trigon, Inc. 2008) to prevent contamination of 

groundwater resources from potential spills of hazardous materials. In the event of a pipeline rupture or spill, 

groundwater impacts from pipeline operation would be unlikely because of the marginal solubility of NGL in 

water and their rapid volatilization once released from pressure. Overall, construction and operation of the 

proposed Project would not significantly impact groundwater resources. 
4.5-9 September 2008

4.5.1.3 Wetlands 

Construction Phase

Issues 

• Potential modifications in wetland productivity due to modifications in surface and subsurface flow 

patterns 

• Modifications in wetland vegetation community composition and structure from construction clearing 

Analysis 

Construction in wetlands primarily would result in temporary effects including the temporary loss of wetland 

vegetation, soil disturbance, and temporary increases in turbidity and fluctuations in wetland hydrology. To 

minimize these impacts on wetlands, OPPC would overlap its construction ROW along previously disturbed 

corridors for approximately 95 percent of the proposed pipeline route. No aboveground facilities would be 

located within wetlands. 

Based on wetland field survey data and a proposed 75-foot-wide construction ROW, the proposed pipeline 

route would temporarily affect 7.7 acres of wetlands. 

To minimize environmental impacts to floodplains, wetlands, and riparian areas during the construction phase 

of the proposed Project, OPPC would implement the construction and environmental protection measures 

provided in the Environmental Protection Plan, which include topsoil salvage and replacement, grading the 

construction ROW to restore pre-construction contours and drainage patterns, and limiting human 

disturbance/access. 

In dry wetlands, prior to trenching, topsoil up to 12 inches in depth would be stripped from over the trench line. 

For wetlands located on side hills, topsoil would be stripped from the entire area being graded. Topsoil would 

be stockpiled in a location where it would not be mixed with any upland soils or wetland subsoil. Care would be 

taken to ensure that the area stripped over the trench line is wide enough to include topsoil over trench 

sidewalls that may slough off due to high groundwater. For wetlands with standing water or saturated soils, 

every attempt would be made to remove and stockpile topsoil up to 12 inches in depth. 

Topsoil would be stockpiled separate from subsoil and would not be used to pad the trench or construct trench 

breakers. Dry drainages or washes that cross the proposed ROW would not be blocked with topsoil or subsoil 

piles. Topsoil and subsoil would be placed on the banks of the drainage. Topsoil would be stripped from the 

stream banks along the trench line and stockpiled at least 10 feet from water's edge behind sediment barriers 

or other containment structures. Gaps would be left periodically in the topsoil and subsoil windrow to avoid 

ponding and excess diversion of natural runoff during storm events. Stockpiled topsoil would be contained 

within the proposed ROW or TWAs. On steeper side sloping situations requiring cutting into the slope to 

achieve a level trench area, topsoil would be placed upslope, above the cut. 

Following these construction procedures and environmental protection measures would greatly increase the 

probability that palustrine emergent (PEM) wetland communities would revegetate rapidly (within 3 years) (Van 

Dyke 1994; FERC 2004). It is anticipated that shrub rootstocks would resprout. Wetland shrubs would likely 

require 5 years or more to recover to their former height and density. Pipeline construction in wetlands would 

temporarily alter wetland surface and subsurface water flow patterns through trenching activities. This 

hydrologic impact would be localized and temporary until permanent trench breakers were installed and the 

trench was backfilled. 
4.5-10 September 2008 

Conclusion 

Wetland herbaceous vegetation generally would begin to reestablish along the proposed ROW within 2 to 

3 years post-construction. Impacts on wetland and riparian communities would depend on the individual 

vegetation community and site-specific soil conditions and moisture received post-construction. Wetland 

surface and subsurface water flow patterns would be temporarily impacted during trenching until permanent 

trench breakers were installed and the trench backfilled. 

Operation Phase

Issues 

• Modifications in wetland and riparian vegetation community composition and structure from 

operational maintenance 

• Potential for spills to adversely impact wetlands 

Analysis 

Following construction, wetland and riparian vegetation would be allowed to regenerate to the original cover 

type. Wetland vegetation would be lost temporarily during construction; however, with the exception of 

scrub-shrub that would be maintained in an herbaceous state, all wetland vegetation would be reestablished 

within 3 years following construction. The success of wetland revegetation would be monitored for the first 

5 years after construction (in July, during the first, third, and fifth growing seasons) or until wetland 

revegetation is successful. No aboveground facilities would be located in wetlands or floodplains. In the 

unlikely event of a pipeline release in a wetland or riparian area, NGL components would rapidly volatilize, 

thereby posing minimal impacts, if any. 

Conclusion 

Pipeline operational ROW maintenance activities in wetlands and riparian areas would result in localized, 

short-term impacts as a result of periodic clearing of woody vegetation over the pipeline centerline. If NGL 

were accidentally released into the environment, minimal impacts, if any, would be expected to wetland and 

riparian resources. 

4.5.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. The impacts to surface water 

quantity, groundwater quality, and wetlands described for the Proposed Action would not occur. Impacts to 

water resources would continue at present levels as a result of natural conditions and existing development in 

the proposed Project area, including cumulative surface water quality impacts from past construction activities 

along or near the proposed Project ROW. Such impacts may include accelerated erosion and sediment 

transport, primarily resulting from previous ROW disturbance and unsuccessful site revegetation and 

stabilization efforts from other pipeline companies. As ongoing inspections and corrective actions occur, these 

impacts are likely to decrease. 

4.5.3 GRP Land Re-route Alternative 

Impacts to water resource along the GRP Land Re-route Alternative would be similar to those described for 

the Proposed Action. Six ephemeral stream channels would be crossed by the alternative route; 5 more than 

would be crossed by the corresponding portion of the Proposed Action route that would be avoided by this 

alternative. These six channels are all small headwater tributaries to Bighole Gulch, and flow only in response 

to snowmelt or heavy rainfall. Crossing techniques and site stabilization practices as described in the 
4.5-11 September 2008

Environmental Protection Plan would be the same as those described for the Proposed Action. Potential 

impacts to water resources for this alternative would be the same as those described for the Proposed Action. 

The GRP Land Re-route Alternative would be approximately 1.3 miles longer than the Proposed Action and 

lies within approximately 1.1 miles of the Proposed Action. The overall change in the length and location of the 

ROW therefore would not result in significant overall differences between the alternatives or impacts to 

groundwater resources. 
4.6-1 September 2008

4.6 Vegetation 

4.6.1 Proposed Action 

4.6.1.1 Vegetation Communities 

Construction Phase

Issues 

• Vegetation removal for facility construction with consequent increased risk of soil erosion 

• Permanent vegetation changes in the ROW and areas of aboveground facilities 

Analysis 

Construction activities would affect vegetation communities in a variety of ways, from temporary herbaceous 

trampling and partial removal of aboveground plant cover to permanent vegetation removal. Clearing, 

trenching, grubbing, blading, and herbaceous vegetation trampling would occur within the proposed Project 

areas. Temporary impacts to vegetative communities would occur within the 75-foot temporary ROW, which 

would be reclaimed immediately following construction and vegetation re-established within 3 to 5 years 

following construction. Long-term impacts (greater than 5 years) would be restricted to primarily shrubland and 

forestland vegetation communities. 

Construction of the proposed Project would involve vegetation removal from approximately 82 acres of 

grasslands; 1,137 acres of shrublands; 111 acres of agricultural land; 248 acres of forested areas; and 

21 acres of wetland vegetation. Following restoration of the 75-foot construction ROW and TWAs, OPPC 

would retain a 50-foot operational ROW that would recover to herbaceous and shrubland vegetation 

communities. The permanent 50-foot ROW would be located on approximately 716 acres of shrublands, and 

136 acres of forestlands. These acreage estimates were calculated using GAP Land Cover descriptions 

(CDOW 1998; WY GAP 1996), which differ slightly in terms of wetland impacts from the NWI classifications 

and actual wetland survey data (WWE 2008) used for the wetlands analysis in Sections 3.4.3 and 4.5.3. 

To minimize environmental impacts and ensure site stabilization and revegetation, OPPC would follow 

construction procedures detailed in the POD (CH2M Hill Trigon, Inc. 2008), particularly those included in the 

Environmental Protection Plan. The Environmental Protection Plan describes measures that would be 

implemented to stabilize disturbed sites by reducing runoff and erosion; to reestablish a vegetation condition 

comparable to preconstruction conditions; to restore functional qualities of the area including wildlife habitat 

and livestock forage; and to prevent degradation of areas off the construction ROW. Additionally, OPPC would 

follow the measures outlined in the Environmental Protection Plan to minimize potential impacts on wetlands. 

Timely stabilization of the construction ROW and reseeding with an appropriate seed mix would minimize the 

duration of vegetation disturbance. The ROW would be monitored on federal lands for a minimum of 5 years to 

ensure compliance with revegetation standards established in the POD. 

Long-term impacts would occur on the sagebrush steppe sub-community of the shrub-scrub vegetation cover 

type and other shrublands within the 75-foot construction ROW. Reclamation efforts would re-establish 

herbaceous vegetation within the construction ROW within 3 to 5 years, but full recovery of these habitats 

would take 20 to 30 years in sagebrush communities, due to poor soil and low moisture conditions. It is 

anticipated that native shrub species would re-sprout from intact roots, reestablish from reapplied topsoil, or 

establish from applied revegetation seed mixtures over the long term. 
4.6-2 September 2008 

Clearing of woodland vegetation within the 50-foot permanent ROW would result in a long-term environmental 

change. Over time, natural establishment of woodland species through succession would restore the 

unmaintained portions of the temporary construction ROW back to a woodland community. The rate of forest 

reestablishment would depend upon the type of vegetation, the length of growing season, and the natural 

fertility of the soils. Regrowth to the sapling young tree stage would take 15 to 30 years, while regrowth of 

forests to mature conditions would likely take between 50 to 100+ years depending on the species (i.e., 200 to 

500 years for piñon-juniper forests). No trees would be removed by ROW maintenance and operation unless 

the trees obscure the ground during aerial ROW inspections. 

Impacts on agricultural vegetation communities would be temporary, as the vegetation would generally be 

reestablished within 2 years of restoration depending on climatic conditions. OPPC would not reseed cultivated 

agricultural areas unless requested by the landowner. 

OPPC has committed to limiting construction within wetlands to that which is essential for ROW clearing, 

trench excavation, pipe fabrication and installation, backfilling, and ROW restoration. In areas where there is 

no reasonable access to the ROW except through wetlands, non-essential equipment would be allowed to 

travel through wetlands only if the ground is firm enough or has been stabilized to avoid creating ruts. Foreign 

material (upland soil, rock, tree stumps, etc.) would not be imported into the wetland to stabilize the working 

area. If standing water or saturated soils are present, equipment would work from and gain access across 

timber equipment mats. If the wetland is dry, equipment would use the ROW for access on an as-needed 

basis with as much traffic as possible routed around the wetland. 

Clearing of vegetation in wetlands would be limited to trees and shrubs, which would be cut flush with the 

surface of the ground and removed from the wetland. To avoid excessive disruption of wetland soils and the 

native seed and rootstock within the wetland soils, stump removal, grading, topsoil segregation, and 

excavation would be limited to the area immediately over the trench line. A limited amount of stump removal 

and grading may be conducted in other areas if dictated by safety-related concerns. 

Wetland vegetation would be removed during construction. Herbaceous wetland vegetation would be 

anticipated to be reestablished within 3 years following construction. It is anticipated that shrub rootstocks 

would resprout. Wetland shrubs would likely require 5 years or more to recover to their former height and 

density. Permanent vegetation removal would occur in areas where aboveground facilities are constructed. A 

pump station may be constructed in the future at MP 82.4 that would remove approximately 1.8 acres of 

scrub-shrub. 

Direct spills of fuels, drilling fluids, or other hazardous materials would saturate soils and adversely affect 

vegetation resources. To minimize the potential for spills, OPPC would implement the Hazardous Materials 

Management and Spill Prevention, Containment, and Countermeasures Plan. This plan specifies preventive 

measures such as personnel training, equipment inspection, and refueling procedures to reduce the likelihood 

of spills, as well as environmental protection measures such as containment and cleanup to minimize potential 

impacts should a spill occur. This plan restricts the location of fuel storage, fueling activities, and construction 

equipment maintenance along the construction ROW and provides procedures for these activities. Training 

and lines of communication to facilitate the prevention, response, containment, and cleanup of spills during 

construction activities also are described in the Hazardous Materials Management and Spill Prevention, 

Containment, and Countermeasures Plan. 

Conclusion 

Herbaceous cover generally would begin to be reestablished along the ROW within 2 years post-construction. 

However, full recovery of shrubland and woodland communities would require 20 to 30 years and 50 to 

100+ years, respectively, while recovery of agricultural and herbaceous wetland communities would be 

expected more quickly. Impacts on vegetation communities would depend on the individual vegetation 

community, site-specific soil conditions, and precipitation events following construction. 
4.6-3 September 2008

Operation Phase

Issues 

• Maintenance operations along pipeline ROW may affect vegetation communities 

• Potential for spills to adversely affect vegetation, particularly threatened and endangered plant species 

Analysis 

Impacts to vegetation from pipeline operations would be limited to vegetation communities located entirely 

within the 50-foot permanent ROW, which were previously disturbed during construction. Maintenance 

activities (e.g., pipeline repairs, soil stabilization, weed control) along the proposed pipeline route would result 

in localized impacts of short duration (less than 14 days in most cases) and these impacts would be dispersed 

along the entire proposed pipeline route. 

Woody species would be allowed to reinvade the 50-foot-wide permanent ROW corridor in woodland and 

scrub-shrub areas. Woody plants would be removed only to facilitate aerial observation of the ROW. 

In the unlikely event of a leak or rupture of the pipeline in upland areas during operations, NGL components 

would rapidly volatilize, thereby posing minimal impacts to vegetation. Accidental ignition of released pipeline 

products would cause wild fires that could spread over a large area, depending upon the seasonal conditions 

at the time of the release. 

Conclusion 

Operation impacts on vegetation would be limited to areas required for operation of aboveground facilities. 

Maintenance activities along the proposed pipeline route would result in localized impacts of short duration 

(less than 14 days in most cases) and these impacts would be dispersed along the entire proposed pipeline 

route. 

4.6.1.2 Noxious Weeds and Invasive Plant Species 

Construction Phase

Issues 

• Potential expansion of noxious weeds and invasive plant populations within and adjacent to the 

proposed pipeline ROW 

Analysis 

The prevention of the spread of noxious weeds is a high priority throughout Wyoming and Colorado. 

Vegetation removal and soil disturbance during construction creates optimal conditions for the establishment 

of invasive, non-native species. 

To control the spread of noxious and invasive weeds along the proposed pipeline route and access roads, 

weed control measures would be implemented in accordance with existing regulations, jurisdictional land 

management agency or landowner agreements, and the Weed Management Plan. Applicant-committed 

environmental protection measures discussed in the POD (CH2M Hill Trigon, Inc. 2008) include, but are not 

limited to, preconstruction surveys, pre-construction weed treatment, vehicle cleaning stations, use of certified 

weed-free straw bales, and the use of certified weed-free seed mixes for restoration. 
4.6-4 September 2008 

In order to accomplish weed prevention and control in the most appropriate and effective manner, OPPC 

would monitor noxious weeds annually for the life of the proposed Project. Post-construction weed control 

measures may include the application of herbicide or mechanical, and/or alternative methods. Additionally, 

revegetation of the disturbed ROW with desirable plant species would serve to hinder the establishment of 

undesirable weed species. The weed control measure chosen would be the best method available for the time, 

place, and species of weed defined in the Weed Management Plan. 

Landowners would be consulted regarding weed control status and implementation measures and encouraged 

to report concerns to OPPC. In the event noxious weed species become established in the ROW, OPPC 

would take appropriate actions to eradicate weeds in the ROW and to work with adjacent landowners to 

prevent the spread of the species to adjacent lands. OPPC would submit the appropriate Pesticide Use 

Proposals for herbicide application on federal lands managed by the BLM. Furthermore, OPPC would submit 

annual pesticide use reports to the BLM for any treatment of weeds on federal lands. 

OPPC would continue to work with the adjacent pipeline companies to monitor the distribution and density of 

noxious weeds on the ROW for the life of the Project. Surveys would be conducted concurrently with 

reclamation monitoring and would occur as early in the year as feasible to identify and control noxious weeds 

before they produce seed. Monitoring data to be collected would include the noxious weed species, location, 

and extent of infestation. The data would be included in the Annual Monitoring Report, as well as the following 

information: 

• A summary of the general vegetative state of the ROW including vegetative cover and diversity of 

plant species as compared to areas off ROW; 

• Assessment of the general condition of the seeded areas; 

• Photographs; 

• Identification of areas where additional weed control is needed; and 

• Monitoring forms. 

At locations where new populations have been identified or pre-existing populations expanded, OPPC would 

take action to eradicate the population or control their spread. The selection of control methods would be 

based on the available technology and information of the weed species. 

Noxious weed problems identified after meeting reclamation criteria as listed in the Environmental Protection 

Plan would be addressed in a joint endeavor between OPPC, the fee landowner, adjacent pipeline owner, 

BLM, and the local weed control district. Weed management coordination would commence following 

reclamation completion. 

Conclusion 

Despite efforts to prevent the spread of noxious weeds, it is possible that pipeline construction would increase 

the prevalence of noxious and invasive weeds along the proposed ROW or that weeds would be transported 

into areas that were relatively weed-free. Implementation of measures in the Weed Management Plan for the 

Project would minimize the spread of undesirable weed species. 

Operation Phase

Issues 

• Future maintenance activities may cause the same effects discussed for construction 
4.6-5 September 2008

Analysis 

The potential impacts would be the same as discussed for construction, but would pertain only to the 

aboveground facility areas and the permanent ROW. OPPC would continue to monitor and control the spread 

of invasive plant species and noxious weeds along the proposed ROW for the life of the Project. 

Conclusion 

Despite efforts to prevent the spread of noxious weeds, it is possible that pipeline maintenance activities would 

increase the prevalence of noxious and invasive weeds along the proposed ROW or that weeds would be 

transported into areas that were relatively weed-free. Implementation of measures in the Weed Management 

Plan would minimize the spread of undesirable weed species from operational impacts. 

4.6.1.3 Special Status Plant Species 

Project development could result in direct and indirect impacts to sensitive plant species. Disturbances within 

or near habitats for sensitive plants could subject these species to: 1) introduction of plant species that would 

compete with desired species for available habitat; 2) accidental burial; and 3) destruction of individual plants 

or populations from herbicide applications. 

Construction Phase

Issues 

• Cutting, clearing, and/or removal of existing vegetation within the construction work area 

• Direct disturbance and loss of individuals from construction activities along the proposed ROW and 

access roads 

Analysis 

Potential impacts on sensitive plant species from surface-disturbing activities would include the loss of 

individuals as a result of crushing from construction vehicles and equipment, as well as the incremental 

long-term disturbance of habitat for these species along portions of the proposed Project route and at ancillary 

facilities. Appendix D identifies 12 special status plant species as occurring within the proposed Project area. 

Species-specific impact summaries and applicant-committed environmental protection measures for the 

protection of these plants are presented below. 

Federally Listed Plants

Dudley Bluffs Bladderpod, Dudley Bluffs Twinpod (also known as Piceance Twinpod), and Ute ladies’- 

tresses. The Dudley Bluffs bladderpod and Dudley Bluffs twinpod are found on the Thirteen Mile tongue 

portion of the Parachute Creek Member of the Green River Formation. The Green River Formation occupies 

approximately 94 acres along the proposed ROW, with the Parachute Creek Member occurring on 

approximately 33 acres of the proposed ROW. However, the Thirteen Mile Tongue of the Parachute Creek 

Member would not underlie the proposed ROW (see Table 3.2-1). Potential habitat within the Green River 

Formation was surveyed for Dudley Bluffs bladderpod and Dudley Bluffs twinpod within the proposed Project 

ROW. Ute ladies’-tresses are known to occur in moist soils near wetland meadows, springs, lakes, and 

perennial streams between 4,200 and 7,000 feet elevation. Potential habitat for Ute ladies’-tresses was 

observed at several locations along riparian and wetland areas in Colorado. None of these federally listed 

plant species were observed along the proposed pipeline ROW during surveys conducted by OPPC in 2007 

and 2008 (WWE 2008). OPPC has committed to conducting pre-construction surveys for these plant species 

in potential habitat. 
4.6-6 September 2008 

OPPC has committed to avoiding any TESS plants that occur along the outside edge of the proposed ROW 

and install exclusion fencing to prevent disturbance from construction activities. In conjunction with the BLM 

and other jurisdictional agencies as appropriate, the proposed route would be evaluated for realignment in 

areas where plants occur within or across the proposed ROW. The potential for a reroute would depend on 

constructability and site-specific conditions such as rugged terrain and slope steepness. 

During the 2007 and 2008 survey effort (WWE 2008), OPPC identified 13 potential habitat locations for Dudley 

Bluffs bladderpod, Dudley Bluffs twinpod, and Ute ladies-tresses within four areas along the proposed route; 

PL Gulch, Dry Fork of Piceance Creek, Hay Gulch south of White River and the north side of the Little Snake 

River. These areas have habitat that could support these species; however, it is unlikely that Dudley Bluffs 

bladderpod would be found anywhere other than the Green River Formation in Rio Blanco County. To date 

this species have only been found within Rio Blanco County. OPPC observed only potential habitat for the 

Green River Formation TESS plants and did not observe any individuals of these species during the survey. 

Furthermore, OPPC did not observe any Ute ladies’-tresses along the proposed pipeline ROW. 

BLM Sensitive Plant Species

OPPC identified potential sensitive plant habitats of BLM sensitive plant species within the proposed Project 

vicinity. Each location varies in size and proximity to the centerline. OPPC identified two populations of the 

Piceance bladderpod along the ROW on CDOW property in Hay gulch. A reroute avoiding these populations 

was evaluated and agreed on with BLM and CDOW consultation. The reroute moved the proposed centerline 

approximately 75 feet away from the original location avoiding impacts to the exposed shale outcropping that 

contains the populations. OPPC did not observe any Rollins cryptantha, many-stemmed spider-flower, 

persistent Sepal yellowcress, Owenby’s thistle, Nelson milkvetch, Gibben’s penstemon, or contracted Indian 

ricegrass (WWE 2008). The 2007 and 2008 summer surveys were conducted during the flowering period or 

soon enough after the flowering period for reasonably accurate field detection and identification. While no 

individuals of these plants were observed, field observations confirm that habitat for these plants exist within 

the proposed Project area in some of the riparian, semi-moist areas or sagebrush and pinyon-juniper plant 

communities. 

OPPC would avoid any federally listed sensitive plants that are identified in the pre-construction surveys by the 

use of fencing or a reroute. The following protection measures would be included in the BLM Decision Record 

and ROW Grant for federal lands: 

• OPPC shall coordinate with the BLM to determine if additional mitigation measures or other 

appropriate actions shall be required to reduce potential impacts to the population. OPPC shall not be 

authorized to proceed with construction until any BLM required mitigation has been implemented in 

accordance with the BLM ROW Grant. 

• OPPC shall commit to the reclamation of any waterbody/wetland crossing to the original meanders, 

profiles, other contours of waterbodies, and 25 feet up each waterbody bank (as measured from 

water's edge). Any material that has accumulated in an intermittent/ephemeral stream shall be 

removed and the stream shall be returned to pre-construction form. 

Conclusion 

To complete ESA Section 7 obligations, if a federally listed plant species is found during the pre-construction 

surveys, OPPC would notify the BLM (for plants found on BLM-managed lands) before commencing any 

Project construction activity. This notification would contain an evaluation of whether or not the plant(s) could 

be avoided by fencing, reroute, or by the use of a horizontal bore. The BLM and USFWS would consult to 

determine the best approach for avoiding or reducing impacts to individual plants or populations. 
4.6-7 September 2008

Operation Phase

Issues 

• The issues associated with operations would be similar to the issues described for wildlife, aquatic, 

and vegetation resources 

• Potential noxious weed invasion into sensitive plant habitats 

Analysis 

All noxious weeds that become established within the areas of direct and indirect disturbance would be 

managed in close consultation with the field office threatened, endangered, and sensitive plant specialist and 

the USFWS. Methods and materials used in noxious weed management would be approved by and conducted 

with BLM and USFWS prior approval to ensure that weed management actions do not impact Dudley Bluffs 

bladderpod populations. To protect pollinator species foraging in the area of the proposed Project, herbicide 

application would be relegated to spot application only after the determination has been made that mechanical 

or manual means would not be effective for weed management and that weed establishment would threaten 

the integrity of occupied plant habitat. 

Conclusion 

Impacts to sensitive plant species from pipeline operations would not include any additional disturbance to 

sensitive plant habitats as all aboveground facilities would be located entirely within the 50-foot-wide 

permanent ROW. Losses of sensitive or listed plants from weed control measures during ROW maintenance 

would be avoided by consultation between the sensitive species specialist and the weed control teams. 

4.6.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. As a result, none of the 

associated impacts to vegetation would occur. 

4.6.3 GRP Land Re-route Alternative 

Impacts to vegetation associated with the GRP Land Re-route Alternative would be generally similar to those 

described for the Proposed Action except that the approximately 1.3 miles of additional length would result in 

disturbance of an additional 11.9 acres of previously undisturbed shrubland vegetation during construction. 

The Proposed Action would occur in a previous pipeline corridor that has already been subject to prior 

disturbance and revegetation efforts. Alternatively, the disturbance associated with the GRP Land Re-route 

Alternative would impact an area that has not been recently disturbed by prior construction activities. 

No special status plant species were observed along the alternative route during the biological surveys 

conducted in 2008. The presence of sparse cheatgrass in the vicinity is common throughout the landscape 

and is likely to occur in the re-route area. This invasive annual plant can quickly dominate disturbed areas and 

if not already present, construction along the re-route alternative would open a new area for this species to 

gain a foothold, thus increasing the potential for spread by noxious weeds in the landscape associated with 

this pipeline corridor. 

As discussed under the Proposed Action, long-term impacts could occur as a result of disturbance to 

shrubland communities. Reclamation efforts as described under the Proposed Action would re-establish 

vegetation along the ROW within 2 growing seasons, but full recovery of these habitats could take a minimum 

of 5 to 7 years, or as long as 20-30 years in sagebrush communities due to poor soils and low moisture 

conditions. Given that the overall change in the length and additional acres of impact associated with the GRP 
4.6-8 September 2008 

Land Re-route Alternative represents less than a 1 percent change for the entire project, any additional 

impacts associated with this alternative would not result in significant overall differences in impacts when 

compared to the Proposed Action. 
4.7-1 September 2008

4.7 Wildlife, Aquatic Resources, and Special Status Species 

4.7.1 Proposed Action 

4.7.1.1 Wildlife 

Construction Phase

Issues 

• Habitat reductions and fragmentation from construction clearing 

• Direct disturbance and loss of individuals from construction activities along the ROW and access 

roads 

• Indirect effects consisting of displacement of individuals and loss of breeding success from exposure 

to construction noise and from higher levels of human activity 

Analysis 

Construction activities would result in the temporary disturbance of approximately 1,599 acres of wildlife 

habitat including 82 acres of grasslands; 1,137 acres of shrub-scrub; 111 acres of agricultural land; 248 acres 

of woodlands; and 21 acres of wetlands. 

Potential impacts to terrestrial wildlife species from the proposed Project can be classified as short-term, 

long-term, and permanent. Short-term impacts consist of activities associated with Project construction and 

changes in wildlife habitats lasting less than 5 years. This would include impacts to species dependent on 

herbaceous habitats. Long-term impacts would consist of changes to wildlife habitats lasting 5 years or more 

and would include species dependent on habitats with woody species components. Permanent impacts would 

result from construction of aboveground facilities that convert natural habitat to an industrial site. The severity 

of both short- and long-term impacts would depend on factors such as the sensitivity of the species impacted, 

seasonal use patterns, type and timing of Project activities, and physical parameters (e.g., topography, cover, 

forage, and climate). 

Less mobile or burrowing species may be killed as a result of crushing from construction vehicles and 

equipment. Other potential impacts include habitat loss or alteration, habitat fragmentation, and animal 

displacement. Individuals may be permanently displaced and perish due to increased competition or other 

effects of being forced into sub-optimal habitat. Indirect impacts from increased noise and additional human 

presence also could lead to displacement and lowered fitness. Although the habitat adjacent to the 

construction zone may support some displaced animals, any species that is at or near its carrying capacity 

could exhibit increased localized mortality. 

Habitat fragmentation is frequently a concern when clearing ROWs. In general, fragmentation results in an 

altered wildlife community as species more adaptable to edge habitats establish themselves, while species 

requiring undisturbed habitats are subject to more negative effects. These effects would result in overall 

changes in habitat quality, habitat loss, increased animal displacement, reductions in local wildlife and 

migratory bird numbers, and changes in species composition. However, the severity of these effects on 

migratory birds depends on factors such as sensitivity of the species, seasonal use, type and timing of Project 

activities, and physical parameters (e.g., topography, cover, forage, and climate). Approximately 96 percent of 

the proposed pipeline ROW would parallel existing pipeline and powerline easements. The 4 percent where 

the proposed Project would not parallel existing ROW would consist primarily of shrubland and woodland 

habitats. Fragmentation disturbance to wildlife and wildlife habitats from the proposed Project is not expected 

to be significant because a majority of the construction would be adjacent to or overlap an existing cleared 

pipeline ROW. Thus, new edge habitat would replace existing edge habitat. 
4.7-2 September 2008 

Trenching activities could hinder the movement of livestock, horses, and/or wildlife. As stated in the Biological 

Resources Protection Plan, OPPC has committed to placing earthen trench plugs, with ramps on either side, 

at a maximum of 1-mile intervals along the trench as well as at well-defined livestock and wildlife trails 

intersected by the trench to minimize potential impacts to wildlife, horses, and livestock. OPPC would consult 

with the BLM regarding specific placement of trench plugs and ramps on lands managed by the BLM. 

To mitigate impacts to big game, greater sage-grouse, migratory birds, and white-tailed prairie dogs, OPPC 

has committed to the seasonal timing restrictions and buffers presented in Table 4.7-1. No construction 

activities would be allowed during the seasonal timing restriction within each buffer without approval from the 

BLM and CDOW or WGFD. Locations for big game and sage-grouse seasonal ranges were determined using 

data received from CDOW and WGFD. Locations for white-tailed prairie dog colonies were provided based on 

2007 and 2008 field surveys conducted by OPPC (WWE 2008). 

To mitigate vegetation/habitat loss, OPPC has committed to redistributing large, woody material salvaged 

during clearing operations on BLM-administered lands within the White River Resource Management Area in 

those areas where the proposed pipeline deviates from an existing ROW or corridor. Materials would be 

dispersed over the portion of the ROW from which the trees and brush were originally removed to meet fire 

management objectives and to provide wildlife habitat, seedling protection, and a deterrent to vehicular traffic. 

Woody materials dispersed across the ROW would not exceed 3 to 5 tons/acre. 

Big Game

As presented in Table 4.7-2, construction impacts to big game species (elk, mule deer, and pronghorn) would 

include the incremental loss of potential forage and would result in an incremental increase in habitat 

fragmentation within the proposed surface disturbance areas. However, as noted above, this removal of 

vegetation would represent only a small percent of the overall available habitat within the broader Project 

region. The loss of shrubland vegetation would be long-term (greater than 5 years and, in some cases, more 

than 20 years). In the interim, herbaceous species may become established within 3 to 5 years, depending on 

future weather conditions and grazing management practices that would affect reclamation success in the 

Project region. In most instances, suitable habitat adjacent to the disturbed areas would be available for wildlife 

species until grasses and woody vegetation were reestablished within the disturbance areas. Locations for big 

game seasonal ranges were determined using data received from CDOW and WGFD. 

Indirect impacts would result from increased noise levels and human presence during surface disturbance 

activities. Big game animals (especially pronghorn and mule deer) would decrease their use within 0.5 mile of 

surface disturbance activities due to increased noise levels (Ward et al. 1980; Ward 1976). This displacement 

would be short term and animals would return to the disturbance area following construction activities. 

However, assuming the adjacent habitats are at or near carrying capacity, displacement of wildlife species 

(e.g., big game) as a result of construction would cause some unquantifiable reduction in wildlife numbers. 

OPPC would minimize potential human presence impacts on wildlife by adhering to sensitive big game habitat 

timing restrictions and coordinating with the appropriate agency (local BLM Field Offices, CDOW, and WGFD) 

prior to construction. 

In accordance with BLM and CDOW recommendations, OPPC would avoid severe winter range for elk, mule 

deer, and pronghorn in Colorado between December 1 and April 30. OPPC would not be authorized to 

construct in a CDOW or BLM No Activity location during restricted dates without approval from the CDOW and 

BLM. 
4.7-3 September 2008

Table 4.7-1 Seasonal Timing Restrictions and Buffers for Big Game, Greater Sage-grouse, Migratory 

Birds, and White-tailed Prairie Dogs for the Project (Proposed Action Only) 

Wildlife Species / Habitat Type MP Locations 

Buffer 

(miles)1 Seasonal Timing 

Restrictions1

Colorado 

Elk Severe Winter Range 49.0 – 78.4 NA December 1 to April 30 

0.0 – 4.2 

12.3 – 14.0 

19.6 – 20.0 

20.1 – 27.4 

55.3 – 64.6 

Mule Deer Severe Winter Range 

93.6 – 94.7 

NA December 1 to April 30 

51.6 – 53.3 

57.2 – 59.0 

63.2 – 70.4 

Pronghorn Severe Winter Range 

92.7 – 94.3 

NA December 1 to April 30 

Greater Sage-grouse Active Lek 66.5 – 67.8 

68.9 – 69.4 

0.602,4 March 1 to May 15 

1.8 – 9.8 4.02 April 15 to July 7 

45.9 – 55.7 

62.9 – 91.1 

Greater Sage-grouse Nesting Habitat (within 

4 miles of an active lek)

91.1 – 94.7 

4.02 March 1 to June 30 

Migratory Birds (protected under the MBTA), 

excluding raptors (refer to Table 4.7-3, 

Seasonal Timing Restrictions and Buffers for 

Raptors for the Project)3

Entire ROW As deemed 

appropriate by 

the applicable 

BLM FO and 

USFWS. 

April 15 to July 15 

White-tailed Prairie Dog (Active Colonies) No active 

colonies on 

federal or 

state land in 

Colorado 

NA WRFO - April 1 to July 15 

LSFO - April 1 to June 15 

Wyoming 

Mule Deer Crucial Winter/Yearlong Range 94.8 – 98.3 NA November 15 to April 30 

Pronghorn Crucial Winter/Yearlong Range 94.8 – 99.3 NA November 15 to April 30 

Greater Sage-grouse Occupied Lek No occupied 

leks within 

0.25 mile of 

ROW 

0.25 March 1 to May 20 
4.7-4 September 2008 

Table 4.7-1 Seasonal Timing Restrictions and Buffers for Big Game, Greater Sage-grouse, Migratory 

Birds, and White-tailed Prairie Dogs for the Project (Proposed Action Only) 

Wildlife Species / Habitat Type MP Locations 

Buffer 

(miles)1 Seasonal Timing Restrictions1

Greater Sage-grouse Nesting Habitat (within 118.1 – 121.7 

2 miles of an occupied lek) 151.9 – 152.1 

2.0 March 1 to July 15 

Migratory Birds (protected under the MBTA), 

excluding raptors (refer to Table 4.7-3, 

Seasonal Timing Restrictions and Buffers for 

Raptors for the Project)3

Entire ROW As deemed 

appropriate by 

the RFO and 

USFWS. 

April 15 to July 15 

White-tailed Prairie Dog (Active Colonies) 98.6 

98.8 

111.3 

116.7 

117.9 

118.8 

119.0 

119.4 

121.3 

121.4 

121.6 

121.8 

129.0 

134.3 

134.4 

135.6 

135.9 

137.0 

137.2 

NA Year-round5

1

Sources: White River RMP (BLM 1997); Little Snake RMP Oil and Gas Amendment (BLM 1991); Rawlins RMP and Final EIS 

(BLM 2008a), unless indicated otherwise. 

2

Source: Colorado Greater Sage-grouse Conservation Plan (CDOW 2008c). 

3

Source: MBTA (FR 2001). 

4

For pipelines this includes no permanent above ground facilities (no surface occupancy) year-round and no surface disturbing activities. 

5

Timing restriction is year-round to avoid potential impacts to black-footed ferrets in non-block cleared areas; if construction were to occur in 

active white-tailed prairie dog colonies of suitable density (i.e., burrow density of 8 burrows or greater per acre) in non-block cleared blackfooted ferret areas, ferret surveys may be required as determined by the USFWS (USFWS 1989). 
4.7-5 September 2008

Table 4.7-2 Crucial Big Game Ranges Potentially Affected by the Proposed Project 

State / Habitat Type MP Locations 

Total Length 

Crossed 

(miles) 

Acreage Affected 

During 

Construction 

Colorado 

Elk Severe Winter Range 49.0 – 78.4 29.4 310.2 

0.0 – 4.2 4.2 

12.3 – 14.0 1.7 

19.6 – 20.0 0.4 

20.1 – 27.4 7.3 

55.3 – 64.6 9.3 

Mule Deer Severe Winter Range 

93.6 – 94.7 1.1 

272.4 

51.6 – 53.3 1.7 

57.2 – 59.0 1.8 

63.2 – 70.4 7.2 

Pronghorn Severe Winter Range 

92.7 – 94.3 1.6 

127.3 

Wyoming 

Mule Deer Crucial Winter/Yearlong Range 94.8 – 98.3 3.5 41.8 

Pronghorn Crucial Winter/Yearlong Range 94.8 – 99.3 4.5 53.2 

In accordance with the recommendations of the BLM RFO and WGFD, OPPC would avoid crucial big game 

winter habitat in Wyoming between November 15 and April 30. OPPC would not be authorized to construct 

within the exclusion window in crucial winter habitat without approval from the WGFD and BLM. 

Small Game Species

A variety of small game species (e.g., greater sage-grouse, mourning dove, white-tailed jackrabbit) have been 

identified as potentially occurring along the proposed Project route. Potential impacts on small game from the 

proposed Project would result in the direct loss of habitat and increased habitat fragmentation until reclamation 

has been completed and native vegetation is reestablished. Potential direct impacts on small game species 

would include nest or burrow abandonment or loss of eggs or young. Indirect impacts could include the 

temporary displacement of small game from the disturbance areas as a result of increased noise and human 

presence. Displacement of small game animals from disturbance areas would be short term and animals 

would be expected to return to the disturbance areas following construction activities. Potential impacts to 

greater sage-grouse are discussed under Special Status Wildlife Species (Section 4.7.1.3). 

Nongame Species

Potential impacts to nongame species (e.g., small mammals, amphibians, reptiles) would parallel those 

described above for small game species. However, potential impacts to these species would be minimized 

through mitigation measures identified below. If necessary, additional site-specific mitigation for sensitive 

species would be developed before construction commences. 
4.7-6 September 2008 

Raptors and Other Migratory Birds

General impacts to migratory birds and the OPPC proposed measures to minimize such impacts are 

discussed below. Federally listed and other sensitive bird species are discussed under Special Status Wildlife 

Species (Section 4.7.1.3). 

Because a majority of the construction would be adjacent to or overlap an existing ROW, new edge habitat 

would replace existing edge habitat. In addition, most of the pipeline would cross relatively open habitat types 

(e.g., grassland, agriculture, and shrubland) rather than fragmenting dense woodland habitat. Therefore, 

impacts to migratory bird species including raptors associated with forest habitats would be minimal. Impacts 

to migratory bird species including raptors associated with relatively open habitats is expected to be minimal 

based on the likelihood that populations in the vicinity of existing ROWs occur at lower densities due to 

existing disturbance. Additionally, open habitats will recover to pre-disturbance conditions at a rate much faster 

than forest habitats. Forested habitats regrowth to the sapling-young tree stage would likely take 15 to 

30 years, while regrowth of forests to mature conditions would likely take between 50 to 100+ years depending 

on the species (i.e., 200 to 500 years for piñon-juniper forests). 

OPPC does not currently propose to construct the proposed Project within the buffer zones prescribed for 

raptors during the raptor nesting season (typically from mid-February through mid-August), so no direct effects 

to nesting raptors would be anticipated. Should construction extend into the raptor nesting season, OPPC has 

committed to conducting additional pre-construction raptor nest surveys in accordance with agency (BLM, 

state wildlife agency, and USFWS) approved protocols. Results of the raptor nest surveys would be reported 

to the appropriate BLM field office, state wildlife agency, and USFWS Western Colorado Field Office for review 

and reconsideration of appropriate protective buffers. OPPC has committed to the following protection 

measures for active raptor nests presented in Table 4.7-3. Construction activities would not occur within the 

appropriate timing restriction and applicable buffers around each active nest unless approved by the BLM and 

CDOW or WGFD. An active nest is one that has evidence of current breeding activities including nest building, 

fresh lining material, egg laying, incubating/brooding, or nestlings during the current breeding season (Cornell 

Lab of Ornithology 2008). 

Likewise, any construction that would have extended into spring would overlap the start of the breeding 

season for other migratory birds (typically April 15 to July 15). Depending on the specific habitat, birds of 

several species (e.g., loggerhead shrike, sage thrasher, sage sparrow, pinyon jay, among others) could be 

directly affected by construction of the proposed Project. OPPC has committed to the following protection 

measures for migratory birds. 

• Conduct pre-construction migratory bird surveys each spring prior to construction to identify nests 

occupied at the time of construction within the proposed Project area should construction occur during 

the nesting season. BLM-approved biologists would be required to meet with BLM biologists prior to 

initiating surveys and would conduct the surveys using BLM protocols. 

• Develop nest avoidance, timing restrictions, and/or additional mitigation measures for nests located on 

or within 100 feet of the proposed ROW. USFWS would be consulted with if any special status 

species’ nest were discovered on or adjacent to the proposed ROW. 

The removal of suitable foraging and nesting habitat can be considered a type of direct impact on migratory 

birds. This type of impact cannot be avoided altogether during construction; however, OPPC has proposed 

measures that would minimize it to the extent practicable. This EA discusses several OPPC plans 

(e.g., Biological Resources Protection Plan; Hazardous Materials Management and Spill Prevention, 

Containment, and Countermeasures Plan) containing measures that would reduce the extent and duration of 
4.7-7 September 2008

Table 4.7-3 Seasonal Timing Restrictions and Buffers for Raptor Nests 

BLM Field Office Raptor Species Timing Restriction1 Buffer (miles)1

Bald eagle November 15 to July 15 0.5 

Golden eagle February 1 to August 15 0.5 

Ferruginous hawk February 1 to August 15 1.0 

Northern goshawk February 1 to August 15 0.25 

White River 

All other species February 1 to August 15 0.125 

Bald eagle November 15 to July 31 0.5 

Golden eagle February 1 to August 15 0.5 

Ferruginous hawk February 1 to August 15 1.0 

Little Snake 

All other species February 1 to August 15 0.25 

Bald eagle February 1 to July 31 Up to 2.5 2

Golden eagle February 1 to July 31 1.0 

Ferruginous hawk February 1 to July 31 1.0 

Rawlins 

All other species February 1 to July 31 0.75 

1

Sources: BLM 2008a,c 1997, 1991. 

2

Buffer is site-specific based on topography, line of sight, and current disturbance levels in the vicinity of the nest. 

impacts on migratory bird habitat, actively and naturally allow a great majority of the construction ROW to 

return to pre-construction condition, and limit the potential effects from spills or environmental contamination. 

For example, OPPC has committed to restoring wetland and upland vegetation habitats (e.g., shrubland, 

woodland, grassland) in the construction ROW to preconstruction conditions. 

EO 13186 requires federal agencies to avoid or minimize negative impact to migratory bird populations. The 

EO also requires the federal agency to identify where unintentional “take” is likely to have a measurable 

negative effect on migratory bird populations. Effects to non-sensitive ground-nesting birds (which do not have 

significantly reduced populations) would not result in long-term or significant population-level effects, given the 

stability of local populations and the abundance of available habitat outside of the proposed ROW, and the 

linear nature of the Project over a large geographic range. 

Conclusion 

Construction of the proposed Project would disturb wildlife habitat, displace individual animals, and contribute 

to habitat fragmentation by expanding approximately 152 miles of existing pipeline/transmission line corridors. 

Impacts to wildlife would be mitigated by implementation of applicant-committed environmental protection 

measures contained in the POD (CH2M Hill Trigon, Inc. 2008), including the Biological Resources Protection 

Plan; Environmental Protection Plan; Hazardous Materials Management and Spill Prevention, Containment, 

and Countermeasures Plan; Transportation Management Plan; and Weed Management Plan. Measures to 

minimize impacts to wildlife include co-location of the pipeline with existing utility corridors where possible, use 

of a minimum construction ROW width and work space areas to reduce impacts to wildlife habitat, the use of 

trench plugs on all lands at 1-mile maximum intervals and at game trail crossings, limiting the amount of time 

and distance of open trench, avoidance of construction activities in big game wintering areas during seasonal 
4.7-8 September 2008 

closure periods, adherence to spatial and timing buffers for active raptor nests and other migratory birds, and 

reclamation of disturbed areas. 

Operation Phase

Issues 

• Habitat reductions and fragmentation from ROW maintenance during operations 

• Indirect effects consisting of displacement of individuals, and loss of breeding success from exposure 

to higher levels of human activity related to maintenance activities 

• Potential loss of individuals from exposures to spills 

• Potential direct mortalities to amphibians from vehicle traffic 

Analysis 

Direct impacts to wildlife species from maintenance activities associated with the proposed Project would be 

the same as discussed above for construction, and those discussed for vegetation (Section 4.6). 

Operation of the pipeline also would result in future surface disturbance activities due to maintenance of the 

pipe (e.g., pothole inspections, repair of pipe, replacement of rectifier beds). As a result, approximately 

852 acres of wildlife habitat would experience incremental long-term reduction until the shrub and tree 

component recovers. OPPC would follow the plans contained in the POD (CH2M Hill Trigon, Inc. 2008) and 

implement measures referenced in this EA to minimize impacts to wildlife and their habitats during pipeline 

operation. 

Operation of the proposed pipeline would allow recovery and reestablishment of shrubs and small trees across 

the construction ROW. Approximately 0.2 acre associated with proposed aboveground pipeline facilities (at the 

Willow Creek meter station) would be permanently converted for pipeline operations 

Conclusion 

Impacts to wildlife from pipeline operations would include a total of less than 1 acre of additional disturbance to 

wildlife habitats beyond the 50-foot permanent ROW. Maintenance and operation of the pipeline would result 

in localized and temporary impacts to wildlife related to an increase in human-wildlife interactions and 

associated noise. 

4.7.1.2 Aquatic Resources 

Construction Phase

Issues 

• Direct loss of individuals or effects on habitat from short-term disturbance to stream channels from 

construction equipment and trench dewatering 

• Direct loss of individuals or effects on habitat from short-term increases in sedimentation from opencut pipeline crossings and erosion from adjacent disturbed lands 

• Potential fuel spills from equipment and toxicity to aquatic biota if fuel reached a waterbody 

• Local short-term reductions in habitat if surface water is affected by hydrostatic testing 
4.7-9 September 2008

• Potential loss of aquatic organisms during pumping for hydrostatic testing 

• Potential loss of individuals from disease or invasive species if contaminated water or mud is 

transferred between watersheds 

Analysis 

Construction-related impacts on fisheries would be primarily dependent on season of construction, duration of 

in-stream activities, and stream crossing methods. Construction activities at coldwater fisheries that occur from 

April 1 to June 15, and at warmwater fisheries from June 1 to November 30, could result in impacts to 

spawning fish. However, potential impacts to coldwater and warmwater fisheries would be minimized based on 

the applicant-committed environmental protection measures discussed below. 

OPPC would prohibit “in the water” construction activities at all coldwater fisheries (Piceance Creek, Dry Fork 

Piceance Creek, White River, and Little Snake River) from April 1 to June 15 and at all warmwater fisheries 

(Yampa River) from June 1 to November 30 unless approved by the CDOW and BLM. However, water 

withdrawals for HDD, dust control, and wash stations would be allowed during these time periods. 

The Little Snake, White, and Yampa rivers would be crossed by HDD. If successful, an HDD crossing would 

result in no impact on fisheries. However, a potential leak or rupture under these rivers during drilling could 

accidentally release muds (called a “frac-out”) or disturb bottom sediments in a localized area near the rupture 

site. The release of drilling muds (primarily bentonite and cellulose) could cause localized increases in 

sediment loads and could fill interstitial gaps in the streambed, smothering habitat for benthic invertebrates, 

larval fish, and eggs. The amount of area impacted by a release of drilling muds would be relatively small since 

the consistency of the drilling muds would limit widespread dispersal along the streambed. To reduce the 

impacts of a frac-out, OPPC prepared a Drill Fluid Contingency Plan that identifies detection and monitoring 

procedures, response equipment, notification procedures, and corrective actions. 

The Dry Fork of Piceance Creek would be crossed using a dry crossing technique or flumed crossing 

technique in accordance with construction procedures in the POD (CH2M Hill Trigon, Inc. 2008). In addition, 

OPPC would store trench spoil at least 10 feet from streambanks, use sediment barriers such as silt fence to 

prevent or significantly reduce runoff into streams, and complete construction as quickly as possible to shorten 

the duration of sedimentation and turbidity. Following completion of construction, OPPC would immediately 

stabilize the construction site, including the streambanks. If circumstances required a construction delay, 

OPPC would employ adequate site stabilization measures in accordance with its Procedures and permit 

conditions. 

Clearing and grading of vegetation within the construction ROW and additional TWAs during construction 

could increase erosion along streambanks and turbidity levels in the waterbodies, as well as cause localized 

changes in water temperature and light penetration, which could affect aquatic habitat, primary and secondary 

production, and fish use patterns. As stated in the POD (CH2M Hill Trigon, Inc. 2008), clearing of vegetation 

between extra work areas and the edge of waterbodies would be limited to the certificated ROW, and tree 

stump removal and grading activities would be limited to the trenchline only. Alteration of the natural drainages 

or compaction of soils by heavy equipment near streambanks during construction could accelerate erosion of 

the banks, runoff, and the transportation of sediment into waterbodies. The degree of impact on aquatic 

organisms due to erosion would depend on sediment loads, stream velocity, turbulence, streambank 

composition, and sediment particle size. Additionally, localized changes in water temperature and light 

penetration caused by the removal of boulders, woody debris, streambank vegetation, and undercut banks 

could temporarily displace fish that utilize these features for cover, nesting, and feeding. However, these 

impacts would be temporary and relatively minor due to the limited amount of total stream bank area affected 

per waterbody. 

To minimize impacts associated with streambank erosion during construction, OPPC would use equipment 

bridges, mats, and pads to support equipment across the waterbody or in saturated soils adjacent to the 
4.7-10 September 2008 

waterbody. In accordance with its Procedures and where topography allows, OPPC would locate additional 

TWAs at least 10 feet from the edge of flowing waterbodies, except where site-specific approval has been 

granted, and limit clearing of vegetation between additional TWAs and the edge of the waterbody to the 

certificated construction ROW. OPPC would implement erosion and sediment control measures (e.g., silt 

fence) to minimize erosion and prevent sediments from leaving the construction site and entering waterbodies. 

OPPC anticipates completing in-stream construction activities for waterbody crossings within 48 hours, further 

minimizing sedimentation and channel instability impacts to fishes and their habitats. 

As discussed in Section 4.5, Water Resources, as much as 46 acre-feet of water potentially would be 

withdrawn from the Upper Colorado River Basin for hydrostatic testing, dust control, HDD use, and equipment 

washing. Approximately 11 acre-feet of this would be temporary withdrawals for hydrostatic testing that would 

be discharged back to the original withdrawal locations once testing was complete. The remaining 35 acre-feet 

potentially needed for other construction activities would be considered consumptive use. OPPC has identified 

the Yampa River (MP 59.53), White River (MP 19.3), and Little Snake River (MP 93.6) as the sources for 

these withdrawals. The approximate water volumes that would be required for hydrostatic testing, the rate of 

withdrawal, and the duration of the use are summarized in Table 4.7-4. The remaining withdrawal volumes for 

construction activities also would be distributed between these three locations. Procedures to minimize 

impacts such as using screens on intakes to avoid uptake of organic debris or entrainment of aquatic species 

during water withdrawals and monitoring withdrawal rates to ensure adequate downstream flow to support 

aquatic life, are discussed in the Hydrostatic Test Plan. OPPC would not use chemical additives during 

hydrostatic testing and proposes to return hydrostatic test water to the withdrawal point for discharge. Further 

discussion of hydrostatic test water withdrawals and associated impacts on special status species is included 

under Section 4.7.1.3. 

Table 4.7-4 Water Withdrawals for Hydrostatic Testing 

Waterbody 

Volume 

(gallons) 

Volume 

(acre-feet) 

Fill Rate 

(gpm) 

Fill Time 

(hours) 

White River 858,000 2.63 1,000 12 

Yampa River 1,147,000 3.52 1,000 17 

Little Snake River1 1,594,000 4.91 500 47 

1

If water is not available from the Little Snake River then water will be withdrawn from the Yampa River. 

Direct spills of fuel, drilling fluids, or other hazardous materials into a waterbody would adversely affect aquatic 

resources. To minimize the potential for spills, OPPC would implement measures in the Hazardous Materials 

Management and Spill Prevention, Containment, and Countermeasures Plan, which specifies preventive 

measures such as personnel training, equipment inspection, and refueling procedures to reduce the likelihood 

of spills, as well as environmental protection measures, such as containment and cleanup, to minimize 

potential impacts should a spill occur. This plan restricts the location of fuel storage, fueling activities, and 

construction equipment maintenance along the construction ROW and provides procedures for these 

activities. It also describes training and lines of communication to facilitate the prevention, response, 

containment, and cleanup of spills during construction activities. 

Adherence to the Hazardous Materials Management and Spill Prevention, Containment, and Countermeasures Plan would prevent spills from occurring near surface waters because construction vehicles (e.g., 

trucks, bulldozers, etc.) and stationary equipment (e.g., pumps, generators, etc.) would be fueled and serviced 

in upland areas at least 100 feet from waterbodies and wetlands. Within the Rawlins Resource Area, the set 

back would be 500 feet from all permanent waters, wells, springs, wetlands, and riparian areas, as well as 

100 feet from the inner gorge of ephemeral stream channels. All stationary equipment (such as pumps and 

generators) would be provided with secondary containment structures to prevent the spill or release of 
4.7-11 September 2008

hazardous materials into waterways. Refueling areas generally would be flat to minimize the chance of any 

spilled substances reaching waterbodies. Based on implementation of these procedures, impacts to surface 

water quality from these activities would be avoided or minimized. 

Conclusion 

Aquatic resource impacts anticipated from pipeline construction at most stream crossings include a temporary 

increase in sedimentation to waterbodies crossed by the flumed crossing method; short-term disturbance to 

stream channels, aquatic habitat, bank cover, and spawning sites; potential short-term reductions in habitat 

from water withdrawals for hydrostatic testing and dust control; potential loss of aquatic organisms during 

pumping for hydrostatic testing; potential loss of individuals from invasive species or disease if contaminated 

water is transferred between watersheds; and potential fuel spills from construction equipment and toxicity to 

aquatic organisms if the fuel spill reached a waterbody. These impacts would be minimized or avoided by the 

implementation of measures in the Environmental Protection Plan, Hazardous Materials Management and 

Spill Prevention, Containment, and Countermeasures Plan, various site-specific waterbody crossing plans 

(designated for environmentally sensitive waterbody crossings), and other aspects of the POD (CH2M Hill 

Trigon, Inc. 2008). Measures to minimize aquatic resource impacts include erosion control and streambank 

stabilization measures, reducing the amount of time conducting instream construction activities, and 

workspace and refueling setbacks from waterbodies. OPPC would avoid bank and channel disturbance to the 

White, Yampa, and Little Snake rivers by using the HDD crossing method. The remaining streams would be 

crossed using the flumed crossing method in accordance with the procedures outlined in the POD (CH2M Hill 

Trigon, Inc. 2008). OPPC has committed to avoiding construction at crossings during state agency designated 

coldwater and warmwater fisheries spawning periods (April 1 to June 15) and (June 1 to November 30), 

respectively, unless approved by the CDOW and BLM. However, this does not include water withdrawals for 

HDD, dust control, and wash stations. Flumed crossings would cause short-term and temporary (usually 

2 days or less) suspended sediment increases in stream and river channels. 

Operation Phase

Issues 

• Potential localized sedimentation and disturbance to habitat if maintenance activities were required at 

a stream crossing (i.e., excavating pipe located under the stream) 

Analysis 

Vegetation removal adjacent to waterbodies would be limited to a 25-foot-wide riparian strip, as measured 

from the waterbody’s mean high water mark. As a result, maintenance activities would not affect aquatic biota 

or their habitat. 

Information on the fate of the NGL and potential toxicity is provided in Section 4.5, Surface Water. Further 

information can be found in the risk assessment conducted for the Overland Pass Pipeline EIS completed in 

2007 (BLM 2007a), entitled “Environmental Fate and Effects of Natural Gas Liquid Releases.” If a rupture were 

to occur at a stream crossing, impacts would include the mortalities of fish species and macroinvertebrates 

present instream at the rupture point only due to the rapid dissipation of NGL. However, fish are expected to 

move away from the rupture area and potential impacts would generally be low in magnitude due to the 

localized extent of the affected area. 

Conclusion 

Routine operation and maintenance activities would have minor effects on aquatic resources. Minimal impacts, 

if any, would be expected to aquatic biota if NGL were accidentally released into waterbodies as aquatic 
4.7-12 September 2008 

species are expected to move away from the rupture point and contamination would be localized and rapidly 

dissipated. 

4.7.1.3 Special Status Species 

Construction Phase

Issues 

• The construction issues for special status wildlife species are the same as listed for wildlife resources 

• The construction issues for special status fish species are the same as listed for aquatic resources. 

Hydrostatic testing is an issue for federally listed species that occur in downstream portions of the 

Colorado River basin. The USFWS requires consultation for any water withdrawals in these basins 

that could affect surface water quantity and the resulting impacts on listed species. 

Analysis 

The construction impact analysis for special status wildlife species focuses on those species that were 

identified as potentially occurring along the proposed Project route only. All special status wildlife species 

originally considered for the proposed Project are presented in Appendix D. It was determined that some of 

these species are highly unlikely to occur along the proposed Project route and would otherwise not be 

affected by the Proposed Action. Comments on these species are included in Appendix D and are not 

discussed further. Species which are likely to occur along the proposed Project route are discussed below. 

Applicant-committed protection measures that have been developed for the proposed Project to prevent or 

minimize direct impacts on special status species are included in the Biological Resources Protection Plan. 

The Biological Resources Protection Plan contains the proposed measures that would be implemented if 

federally listed species or species of concern were identified along the proposed pipeline route during 

Project-specific or species-specific surveys. These measures would reduce Project-related impacts on special 

status species. Additional recommendations are presented below, where necessary, to ensure that impacts on 

special status species are minimized to the greatest extent practicable. 

Terrestrial Wildlife Species

Potential impacts to special status species from surface disturbance activities would include the loss 

(short-term, long-term, or permanent), alteration, or fragmentation of potential breeding and/or foraging 

habitats, mortalities of less mobile or burrowing species as a result of crushing by vehicles and equipment, 

abandonment of a nest site or territory, and the loss of eggs or young. Other impacts would include short-term 

displacement of some of the more mobile species from the disturbance areas as a result of increased noise 

and human presence. 

Mammals

Spotted Bat, Townsend’s Big-eared Bat, Fringed Myotis, Yuma Myotis, Long-eared Myotis. No historic 

communal bat roost sites (e.g., hibernacula, nursery colonies, bachelor roosts) have been recorded along the 

proposed Project route. Much of the proposed Project route would occur adjacent to or within previously 

disturbed ROW, thus direct impacts to communal roosts are not anticipated. Potential direct impacts to 

individual bats could occur as a result of crushing by vehicles and equipment during ROW clearing and other 

Project-related construction. Impacts also would result from the incremental long-term reduction of potential 

foraging habitat (approximately 248 acres) including habitat fragmentation until reclamation is completed and 

native vegetation has become reestablished. Indirect impacts could result from increased noise levels and 

human presence. The proposed Project may impact individuals but is not likely to cause a trend to federal 

listing or loss of viability of these bat species. 
4.7-13 September 2008

Black-footed Ferret. According to surveys conducted in the summer of 2007 and spring of 2008, 

approximately 29 white-tailed prairie dog colonies that meet the burrow density set forth in the 1989 

Black-footed Ferret Survey Guidelines (USFWS 1989) occur along the proposed Project ROW (WWE 2008). If 

ferrets were present in prairie dog colonies along the proposed Project route, direct impacts would include 

increased habitat loss and fragmentation from the disturbance of prairie dog colonies or complexes along the 

proposed Project route. Impacts also could result in direct mortalities of black-footed ferrets as a result of 

crushing from surface disturbance, vehicles, and heavy equipment. Indirect impacts to black-footed ferrets 

would include increased habitat fragmentation effects as a result of increased noise levels and human 

presence, dispersal of noxious and invasive weed species, and dust effects from unpaved road traffic. Indirect 

effects also could result in a reduction in habitat quality from the spread of infectious diseases (e.g., plague) 

within otherwise healthy prairie dog colony complexes. 

In Wyoming, black-footed ferret surveys are no longer recommended in black-tailed prairie dog towns or in 

white-tailed prairie dog towns except those noted in a February 2, 2004, letter from the USFWS (USFWS 

2004). It is assumed that areas that do not require surveys do not have the potential to support black-footed 

ferrets. The white-tailed prairie dog towns found in T13N to T20N, R94W in Sweetwater and Carbon counties, 

Wyoming, have not been cleared and would have to be surveyed. Some prairie dog towns along the front 

range of Colorado and eastern Colorado have been block cleared and surveys for ferrets are no longer 

recommended. No block clearances of white-tailed prairie dogs are in place in western Colorado. However, 

the USFWS has designated prairie dog towns in Moffat County, Colorado, and Rio Blanco County, Colorado, 

west of highway 13 as experimental populations. Ferrets have been released at one location (Wolf Creek) on 

federal lands approximately 20 miles west of the Project route. These populations are considered low 

probability of ferret occurrence and are designated as potential ferret introduction sites. These areas do not 

require ferret searches. The USFWS encourages Project applicants to protect all prairie dog towns for their 

value to the prairie ecosystem and the myriad of species that rely on them. Based on 1) the implementation of 

measures listed in the Biological Resources Protection Plan (including conducting surveys); 2) the USFWS 

determination of Moffat and Rio Blance counties as experimental population areas for black-footed ferret; and 

3) the low probability of occurrence in the vicinity of the proposed Project route, it is anticipated that the 

proposed Project would have a low impact on black-footed ferrets 

White-tailed Prairie Dog. As discussed above, white-tailed prairie dogs occur along the proposed Project 

route. The potential effects of construction through a prairie dog colony include temporary loss of forage and 

shelter due to vegetation clearing, collapsing of burrows, and temporary disruption of foraging and resting 

activities due to disturbance associated with construction equipment. Direct mortality of prairie dogs could 

result if active burrows are occupied at the time of construction. If construction occurs later in the prairie dog 

reproductive season (late May to early June), most prairie dogs would be mobile and able to avoid 

construction traffic; however, some individual prairie dogs may be injured or killed during construction. In 

addition, there is a potential for destroying active dens with young if construction occurs during the 

reproductive season. If OPPC proposes construction in an active prairie dog colony during the white-tailed 

prairie dog’s reproductive season, there would be a construction timing restriction on federal land within the 

WRFO from April 1 to July 15, and within the LSFO from April 1 to June 15. The RFO does not impose a 

timing restriction for white-tailed prairie dogs but rather encourages limited disturbance within active colonies. 

Following construction and restoration, the revegetated ROW would provide foraging habitat for prairie dogs, 

and the unconsolidated soils along the trench would likely provide a good substrate for burrowing. The 

proposed Project may impact individuals but would not likely to cause a trend to federal listing or loss of 

viability to white-tailed prairie dogs. 

Wyoming Pocket Gopher. Potential impacts on the Wyoming pocket gopher from construction of the 

proposed Project would be minimal because its range is limited to the southeastern corner of Sweetwater 

County; however, a small amount of potentially suitable habitat could occur along the proposed Project route. 

The highest possibility for direct impact would occur during clearing if heavy equipment collapses dens and 

tunnels while navigating the ROW, or during the trenching process. Once operational, the pipeline corridor 

would provide loose soil for dens and rodent burrows, plus forbs, grasses and seeds for rodent forage. During 
4.7-14 September 2008 

reclamation, the proposed pipeline ROW would be reseeded with BLM- and NRCS-approved seed mixes 

appropriate to soil and range conditions for the area. The proposed Project may impact individual pocket 

gophers but would not likely cause a trend to federal listing or loss of viability to this species. 

Pygmy Rabbit. The USFWS received a petition (April 21, 2003) to list the pygmy rabbit under the ESA. A 

90-day finding on the petition was published on May 20, 2005, in which the USFWS determined that the 

petition does not provide substantial information indicating the listing may be warranted. This finding was 

recently remanded by the Court to another 90-day review to be completed by December 31, 2007. Field 

surveys conducted in 2007 found no evidence of pygmy rabbits in the Colorado or Wyoming portion of the 

proposed Project route (WWE 2008). However, since suitable habitat (i.e., dense stands of big sagebrush) is 

present along the proposed Project route, potential impacts could occur as a result of the proposed Project 

and would be similar to those discussed for small non-game species. 

Because a majority of the construction would be adjacent to or overlap an existing ROW, impacts to large 

tracts of undisturbed pygmy rabbit habitat would be minimized. As part of the proposed Project planning 

measures, approximately 96 percent of the proposed pipeline ROW parallels existing pipeline and powerline 

easements. As such, habitat fragmentation and loss of sagebrush habitat would be minimized and would not 

pose a significant impact on pygmy rabbits. The proposed Project may impact individual pygmy rabbits but 

would not likely cause a trend to federal listing or loss of viability of this species. 

Birds

White-faced Ibis, Barrow’s Goldeneye, Black Tern, Long-billed Curlew. Potential impacts to these 

migratory bird species would be the same as discussed for other migratory bird species in the Raptors and 

Other Migratory Birds section. 

Northern Goshawk. No northern goshawk nests have been identified along the proposed pipeline route; 

however, suitable foraging habitat and marginal nesting habitat (i.e., pinyon-juniper woodlands) does occur 

along the proposed Project route. Direct impacts would include the long-term reduction of approximately 

248 acres of potential foraging habitat and 248 acres of potential breeding habitat, until reclamation has been 

completed and vegetation reestablished. However, this impact would be considered negligible based on the 

low probability of nesting birds along the proposed route. Indirect impacts would result from constructionrelated noise and human presence. With the implementation of biological protection measures outlined in the 

POD (CH2M Hill Trigon, Inc. 2008) such as conducting preconstruction surveys for active nests, and 

implementation of seasonal timing restrictions and buffers as listed in Table 4.7-3, potential impacts to this 

species as a result of the proposed Project would be low. 

Bald Eagle. Two bald eagle nest sites and winter roost areas occur within 1-mile of the proposed Project route 

along the White, Yampa, and Little Snake rivers. Impacts would include the long-term reduction of 

approximately 1,599 acres of potential foraging habitat and 269 acres of potential breeding habitat, until 

reclamation has been completed and vegetation reestablished. Indirect impacts associated with constructionrelated noise and human presence would increase and therefore, could impact breeding/wintering birds. With 

the implementation of biological protection measures outlined in the POD (CH2M Hill Trigon, Inc. 2008), 

conducting preconstruction surveys for active nests, and implementation of seasonal timing restrictions and 

buffers as listed in Table 4.7-3, potential impacts to this species as a result of the proposed Project would be 

low. 

Swainson’s Hawk. One active Swainson’s hawk nest has been identified along the proposed Project route 

and suitable nesting habitat (i.e., trees, large shrubs, cliffs) occurs along the proposed Project route. Direct 

impacts would include the long-term reduction of approximately 1,599 acres of potential foraging habitat and 

1,517 acres of potential breeding habitat, until reclamation has been completed and vegetation reestablished. 

However, this impact would be considered negligible based on the overall availability of suitable foraging 

habitat in the vicinity of the Project route. Indirect impacts would result from construction-related noise and 
4.7-15 September 2008

human presence. With the implementation of biological protection measures outlined in the POD (CH2M Hill 

Trigon, Inc. 2008), conducting preconstruction surveys for active nests, and implementation of seasonal timing 

restrictions and buffers as listed in Table 4.7-3, potential impacts to this species as a result of the proposed 

Project would be low. 

Ferruginous Hawk. No active ferruginous hawk nests have been identified along the proposed Project route; 

however, several inactive nest sites occur in Wyoming and suitable nesting and foraging habitat is found along 

the entire proposed Project route. Direct impacts would include the long-term reduction of approximately 

1,467 acres of potential foraging habitat and 1,219 acres of potential breeding habitat, until reclamation has 

been completed and vegetation reestablished. However, this impact would be considered negligible based on 

the overall availability of suitable foraging habitat in the vicinity of the proposed Project route. Indirect impacts 

would be the same as described above for northern goshawk. With the implementation of biological protection 

measures outlined in the POD (CH2M Hill Trigon, Inc. 2008), conducting preconstruction surveys for active 

nests, and implementation of seasonal timing restrictions and buffers as listed in Table 4.7-3, potential impacts 

to this species as a result of the proposed Project would be low. 

Golden Eagle. Two active golden eagle nests have been identified along the proposed Project route: one 

located on a high voltage tower in Moffat County, Colorado, and the other in a tree in Sweetwater County, 

Wyoming. Direct impacts would include the long-term reduction of approximately 1,599 acres of potential 

foraging habitat and 1,467 acres of potential breeding habitat, until reclamation has been completed and 

vegetation reestablished. However, this impact would be considered negligible based on the overall availability 

of suitable foraging habitat in the vicinity of the proposed Project route. Indirect impacts would be the same as 

discussed above for northern goshawk. With the implementation of biological protection measures outlined in 

the POD (CH2M Hill Trigon, Inc. 2008), conducting preconstruction surveys for active nests, and 

implementation of seasonal timing restrictions and buffers as listed in Table 4.7-3, potential impacts to this 

species as a result of the proposed Project would be low. 

Prairie Falcon. A single prairie falcon nest site has been documented along the proposed Project route in 

Sweetwater County, Wyoming. However, this nest was found to be inactive in 2007 and 2008. Direct impacts 

would include the long-term reduction of approximately 1,599 acres of potential foraging habitat and 

1,467 acres of potential breeding habitat, until reclamation has been completed and vegetation reestablished. 

However, this impact would be considered negligible based on the overall availability of suitable foraging 

habitat in the vicinity of the proposed Project. Indirect impacts would be the same as discussed above for 

northern goshawk. With the implementation of biological protection measures outlined in the POD (CH2M Hill 

Trigon, Inc. 2008), conducting preconstruction surveys for active nests, and implementation of seasonal timing 

restrictions and buffers as listed on Table 4.7-3, potential impacts to this species as a result of the proposed 

Project would be low. 

Greater Sage-Grouse. The greater sage-grouse is designated as a sensitive species by the states of 

Colorado and Wyoming as well as the BLM and has been petitioned for federal listing consideration. In April 

2004, the USFWS determined that listing the sage-grouse under the ESA may be warranted and initiated a 

status review. However, based on a 12-month finding for petitions to list the greater sage-grouse as threatened 

or endangered, the USFWS has subsequently determined that the listing is not warranted (70 FR 2244). 

Recently, the USFWS has reopened a 90-day status review to determine whether or not listing under the ESA 

is warranted. 

In Colorado, the BLM WRFO and LSFO are implementing their respective RMPs seasonal training restriction 

dates for greater sage-grouse. The BLM WRFO and LSFO have adopted the Colorado Greater Sage-grouse 

Conservation Plan’s (CDOW 2008c) guidelines and recommendations for implementing buffers. This 

conservation plan was signed in January 2008 by the CDOW, BLM, USFS, USFWS, and NRCS to facilitate 

the conservation of greater sage-grouse and their habitats in Colorado. This plan establishes that: 
4.7-16 September 2008 

• There should be no surface occupancy (NSO) within a 0.6-mile radius of an active lek; and 

• Surface disturbing activities should be avoided, to the extent possible, within suitable nesting habitat 

within a 4-mile radius of an active lek. 

Potential direct impacts of construction on sage-grouse may include the loss of lekking grounds and other 

sage-grouse habitat (e.g., winter range, brooding habitat). Acres of sage-grouse habitat that would be 

impacted by the proposed Project are presented in Table 4.7-5. 

Table 4.7-5 Greater Sage-grouse Habitat Impacted by the Proposed Project 

BLM Field Office Habitat Type 

Acres Impacted During 

Construction1

Brooding Areas 39.0 

Production Areas 29.9 

Winter Range 39.0 

White River2

Severe Winter Range 0.00 

Brooding Areas 108.5 

Production Areas 303.8 

Winter Range 424.8 

Little Snake2

Severe Winter Range 32.4 

Rawlins Overall Range 598.2 3

Nesting Habitat 78.1 

1

Some habitats may overlap (e.g., winter range includes severe winter range, overall range include nesting habitat). 

2

From BLM WRFO and LSFO have adopted CDOW greater sage-grouse habitat mapping data. 

3

From BLM RFO has adopted WGFD greater sage-grouse habitat mapping data. The WGFD designates greater sage-grouse habitat into 

two categories and does not classify brooding areas, production areas, winter range, or severe winter range. 

Although the proposed Project would not result in a permanent loss of habitat along the pipeline ROW, the 

regeneration of sagebrush would likely be slow. A 30-year interval represents the approximate recovery period 

for a stand of Wyoming big sagebrush. A 20-year interval represents the approximate recovery time for a stand 

of mountain sagebrush (Connelly et al. 2000). However, potential impacts on sage-grouse habitat would be 

minimized by locating the proposed ROW within previously disturbed areas (i.e., adjacent to existing pipelines 

and/or roads) to the extent possible. Given the abundant suitable habitat in the general area, it is not likely that 

the minor, yet long-term loss of habitat along the pipeline ROW would affect sage-grouse populations in the 

vicinity of the proposed Project. 

Depending on the timing of construction, the proposed Project could potentially impact sage-grouse during 

lekking activities or brood rearing, and could cause displacement, injury, or direct mortality of individuals. 

Sage-grouse are particularly sensitive to disturbances while they gather on lekking grounds each morning and 

evening from early March to early May. Construction activities and associated noise occurring in early morning 

and late evening in the vicinity of lekking grounds could disrupt and potentially displace sage-grouse that have 

gathered for breeding activities. In addition, once breeding activities have concluded, sage-grouse hens create 
4.7-17 September 2008

their nests on the ground underneath sagebrush plants in proximity to the lekking grounds. The proposed 

Project could potentially impact nesting sage-grouse by destroying nests, causing nest abandonment, or 

causing injury or direct mortality to the young. 

Based on CDOW and WGFD breeding season surveys and historic data, a total of 6 active sage-grouse lek 

sites have been identified as occurring within 4 miles of the proposed Project in Colorado, and 2 active leks as 

occur within 2 miles of the proposed Project in Wyoming. 

Table 4.7-6 summarizes the following sage-grouse protection measures OPPC has committed to in order to 

limit impacts to greater sage-grouse. 

• Conduct sage-grouse presence surveys, habitat assessment, and review of historical lek sites each 

spring prior to construction. Biologists would meet with the BLM prior to initiating surveys and would 

conduct the surveys using BLM-approved protocols. 

• Prohibit permanent aboveground facilities within a 0.6-mile radius of all active leks on lands 

administered by the BLM WRFO, BLM LSFO, and CDOW, and within a 0.25-mile radius of all 

occupied leks on land administered by the BLM RFO unless approved by the BLM and CDOW or 

WGFD. The RFO has adopted the WGFD definitions of an occupied versus unoccupied lek: a lek is 

deemed occupied until it is inactive 6 out of 10 years. 

• Prohibit surface disturbing activities within 0.6 mile of an active lek on lands administered by the BLM 

WRFO, BLM LSFO, and CDOW from March 1 to May 15 and within 0.25 mile of an occupied lek on 

lands administered by the BLM RFO from March 1 to May 20 unless approved by the BLM and 

CDOW or WGFD. 

• Prohibit surface disturbing activities within a 4-mile radius of an active lek (within suitable nesting 

habitat) at the time of construction between April 15 and July 7 on land administered by the BLM 

WRFO and between March 1 and June 30 on land administered by the BLM LSFO in Colorado unless 

approved by the CDOW and BLM. Some allowances may be made based upon site-specific 

consultations with the jurisdicting agency. 

• Prohibit surface disturbing activities within a 2-mile radius of an occupied lek (within suitable nesting 

habitat) at the time of construction from March 1 to July 15 on land administered by the BLM RFO 

unless approved by the WGFD and BLM. Some allowances may be made based upon site-specific 

consultations with the jurisdicting agency. 

To minimize impacts on sage-grouse habitat, OPPC has committed to restricting broadcast spraying of 

herbicides for noxious weed control in sage-grouse habitat unless approved by the BLM Authorized Officer or 

field representative. All weed control programs in sage-grouse habitat would use integrated weed 

management techniques to reduce the area of treatment and minimize adverse side effects. Additionally, 

OPPC would seed all disturbed areas with a mix designed to reestablish sagebrush and forb species. Seed 

mixes are provided as appendices to the Environmental Protection Plan. Sagebrush seed used for reseeding 

would be from local species and varieties. Distribution of sagebrush would be dependent upon range site (i.e., 

Artemesia tridentata vaseyana and A. tridentata wyomingensis). Reclamation on these sites would use seed 

mixes and seeding methods that include and promote successful establishment of the full compliment of 

grasses and desirable native forbs. 
4.7-18 September 2008 

Table 4.7-6 Seasonal Timing Restrictions and Buffers for Greater Sage-grouse 

State/Habitat Type 

Milepost 

Locations 

Buffer 

(miles)1

Seasonal Timing 

Restriction2

Colorado

Greater Sage-grouse Active Lek 66.5 to 67.8 

68.9 to 69.4 

0.603 March 1 to May 15 

1.8 to 9.8 4.0 April 15 to July 7 

45.9 to 55.7 

62.9 to 91.1 

Greater Sage-grouse Nesting Habitat (within 

4 miles of an active lek) 

91.1 to 96.5 

4.0 March 1 to June 30 

Wyoming

Greater Sage-grouse Occupied Lek No occupied leks 

within 0.25 mile of 

ROW 

0.253 March 1 to May 20 

Greater Sage-grouse Nesting Habitat (within 118.1 to 121.7 

2 miles of an occupied lek) 151.9 to 152.1 

2.0 March 1 to July 15 

1

Sources: Colorado Greater Sage-grouse Conservation Plan (CDOW 2008b) and Rawlins FEIS and RMP 2008 (BLM 2008a). 

2

Sources: White River RMP (BLM 1997), Little Snake RMP Oil and Gas Amendment (BLM 1991), and Rawlins FEIS and RMP 2008 

(BLM 2008a). 

3

For pipelines this includes no permanent aboveground facilities (no surface occupancy) year-round and no surface disturbing activities.

Columbian Sharp-tailed Grouse. Potential impacts on the Columbian sharp-tailed grouse from construction 

of the proposed Project would be minimal because its range is limited in southern Moffat County; however, a 

small amount of potentially suitable habitat could occur along the proposed Project route. Potential direct 

impacts of construction on this species include the temporary loss of habitat (e.g., winter range, brooding 

habitat). Although the proposed Project would not result in a permanent loss of habitat along the proposed 

pipeline route, the regeneration of shrubs would likely be slow. Potential impacts on Columbian sharp-tailed 

grouse habitat would be minimized by locating the proposed ROW within previously disturbed areas 

(i.e., adjacent to existing pipelines and/or roads) to the extent possible. Given the abundant suitable habitat in 

the general area, it is not likely that the minor, yet long-term loss of habitat along the proposed pipeline ROW 

would affect Columbian sharp-tailed grouse populations in the vicinity of the proposed Project. Therefore, the 

proposed Project may impact individual Columbian sharp-tailed grouse but would not likely cause a trend to 

federal listing or loss of viability to this species. 

Mountain Plover. The primary mountain plover nesting period along the proposed Project route is from 

May 1 through June 15. Young chicks commonly stay on the nest or freeze in place to avoid detection from 

about June 15 through July 10, resulting in a higher potential for losses from excavation equipment traversing 

over nest sites during this time period. After July 10, the chicks are usually sufficiently mobile to move away 

from construction equipment. 

The proposed Project route crosses approximately 11.7 miles of mountain plover habitat in Wyoming 

(BLM 2008a). Additional habitat for mountain plover is found within white-tailed prairie dog colonies along the 

proposed Project route. If construction were to begin in or extend into the breeding season (mid-April through 
4.7-19 September 2008

early July), direct (e.g., ground disturbance) or indirect (e.g., noise, human presence) impacts to nesting 

mountain plover could result in abandonment of breeding territory or a nest site, or the loss of eggs or young. 

OPPC has committed to avoiding construction activities in suitable mountain plover habitat between April 10 

and July 10. Based on proposed construction outside the nesting season, the proposed Project may impact 

individuals but would not likely cause a trend to federal listing or loss of viability. 

Western Burrowing Owl. Burrowing owls typically use burrows made by prairie dogs and other small 

mammals. Destruction of burrows could result in displacement of owls into less suitable habitats, potentially 

increasing susceptibility to predation, reducing cover or forage habitat, or reducing reproductive success. 

Displacement, injury, or direct mortality could result if active burrows are occupied at the time of destruction. 

Surveys conducted during the summer of 2007 found 2 active burrowing owl nests (WWE 2008). To avoid 

impacts on nesting owls, OPPC proposes to construct the pipeline outside the burrowing owl breeding season 

(February 1 to August 15 in Colorado). Should construction extend into the breeding season, OPPC would 

adhere to seasonal and spatial buffers for burrowing owls on federal land unless approved by the BLM and 

CDOW or WGFD. For example, the BLM RFO would typically require a 0.75-mile protection zone around an 

active nest between February 1 and July 31. To minimize potential impacts to the burrowing owl, OPPC has 

committed to adhering to the BLM requirements established for burrowing owls for the entire proposed Project, 

regardless of land ownership. Thus, the proposed Project may impact individual burrowing owls but would not 

likely cause a trend to federal listing or loss of viability to this species. 

Loggerhead Shrike, Sage Thrasher, Sage Sparrow, and Brewer’s Sparrow. Potential impacts to these 

migratory bird species would be the same as discussed for other migratory bird species under the Raptors and 

Other Migratory Birds section. 

Amphibians and Reptiles

Great Basin Spadefoot, Northern Leopard Frog, and Midget Faded Rattlesnake. Potential impacts to 

amphibian and reptile species include direct mortalities of individuals from construction activities, ground 

compaction, and vehicle traffic within suitable habitat. Impacts also would result from the incremental long-term 

reduction of potential habitat until reclamation is completed and vegetation reestablished. 

The potential for these species to occur within the proposed Project area is considered low. No further 

preconstruction surveys are proposed. The proposed Project may impact individual amphibians and reptiles 

but would not likely cause a trend to federal listing or loss of viability. These species have a broad geographic 

area and impacts would be considered negligible based on suitable habitat present in the proposed Project 

vicinity. 

Fish Species

The federally listed bonytail, humpback chub, and razorback sucker do not occur in the proposed Project area 

but are included in our detailed analysis based on the potential water depletion activities (i.e., hydrostatic 

testing) for the proposed Project in the Colorado River Drainage. The closest occupied or critical habitat for 

these three species is located at the following approximate distances downstream of the proposed crossings: 

30 to 40 river miles downstream of the Yampa River crossing (razorback sucker, humpback chub, and 

bonytail); 70 river miles downstream of the White River crossing (razorback sucker); and at least 30 river miles 

downstream of the Little Snake River crossing (razorback sucker) (USFWS 2004a). Consequently, proposed 

Project impacts to these fish species would be limited to potential water depletions from hydrostatic testing 

within the Colorado River drainage. 

The federally listed Colorado pikeminnow occurs approximately 10 river miles downstream of the proposed 

White River crossing and could be affected by water depletions (USFWS 2004a). This species also could 
4.7-20 September 2008 

occur at the location of the proposed Yampa River crossing (which also is designated as critical habitat for this 

species) (USFWS 2004a). Direct impacts to this species and its critical habitat are discussed below. 

The remaining five fishes (bluehead sucker, flannelmouth sucker, mountain sucker, Colorado River cutthroat 

trout, and roundtail chub) are either state sensitive species or BLM sensitive species that occur in the White 

River, Little Snake River, Yampa River, and Piceance Creek. 

An accidental release of drilling mud (called “frac-out”) and potential impacts of this release during the HDD 

crossings at the White, Little Snake, and Yampa rivers is discussed in Section 4.5, Surface Water. 

Bonytail, Humpback Chub, Razorback Sucker, Colorado Pikeminnow (impacts from water depletions). 

The USFWS has expressed concern about the potential downstream impacts on federally listed species 

resulting from hydrostatic test water withdrawals from the Upper Colorado River Basin. The federally 

endangered bonytail, humpback chub, razorback sucker, and Colorado pikeminnow are known to occur in 

downstream portions of the White, Yampa, and Little Snake rivers, which are part of the Upper Colorado River 

Basin. 

Water depletion impacts resulting from the withdrawal of up to 35 acre-feet of water for dust control, HDD use, 

and equipment washing and an additional 11 acre-feet for hydrostatic testing could include a slight temporary 

reduction of potential spawning and rearing habitat in the Upper Colorado River Basin due to changes in 

downstream water flow. No changes in water temperature or dissolved oxygen would be anticipated as a 

result of the relatively small water volume used for proposed Project activity. Potential impacts would be 

greatest during the spawning periods for these species in spring and early summer, which would be avoided 

based on OPPC proposed schedule. The USFWS defines “depletion” as consumptive loss plus evaporative 

loss of surface or groundwater within the affected basin. According to the USFWS, any water depletion would 

represent an adverse impact on the Colorado pikeminnow, razorback sucker, humpback chub, and bonytail, 

and would need to be considered under a programmatic biological opinion (BO). 

If water is returned to the source waterbody within a certain amount of time after withdrawal, the threshold for 

“depletion” and formal consultation would not be reached. Factors to consider in determining downstream 

impacts to listed fish species include the time of the year water is withdrawn, whether the water has been 

treated, other water uses at the time of withdrawal (cumulative impact), and how close to the withdrawal 

source the water is returned (i.e., a source location return versus a “basin return”). 

The Recovery Implementation Program for Endangered Fish Species in the Upper Colorado River Basin

(Recovery Plan) (USFWS 2008) was established in 1988 to mitigate for water depletion impacts to Colorado 

River federally endangered fish species. To ensure the survival and recovery of the listed species, water users 

are required to make a one-time payment to the Recovery Program. In 1995, an intra-USFWS Opinion 

determined that the fee for depletions less than 100 acre-feet (annual average) would no longer be required 

(USFWS 2004a). 

Water withdrawals for the proposed Project would include up to an estimated 35 acre-feet of water for 

consumptive water use (i.e., dust control, HDD use, and equipment washing) and an additional 11 acre-feet for 

hydrostatic testing. As presented in Table 4.7-4, the 11 acre-feet for hydrostatic testing would be comprised of 

approximately 3.5 acre-feet from one location along the Yampa River (MP 59.5), 2.6 acre-feet from one 

location along the White River (MP 19.3), and 4.9 acre-feet from one location along the Little Snake River 

(MP 93.6). Hydrostatic testing for the various test sections would occur over a multiple-day period. The actual 

duration of hydrostatic testing for a given test section would be dependent on the rate of withdrawal and the 

section of pipe that would be tested, but would not exceed 5 to 7 days. 

Hydrostatic test water withdrawn from surface waters would be discharged back to the uptake location after 

use. Discharges would be completed as quickly as possible, but would be governed by the volume of water in 

a test section and the discharge rate. The potential for bank erosion would be minimized by using energy-
4.7-21 September 2008

dissipating devices and appropriate dewatering structures that would disperse and slow the velocity of any 

discharges. The introduction of contaminants would not be anticipated because OPPC would test only new 

pipe and would not chemically treat the water. Due to this, water depletions from the Upper Colorado River 

Basin, according to the USFWS, the proposed Project may affect and is likely to adversely affect the four 

Colorado River endangered fish. 

Colorado Pikeminnow (impacts from waterbody crossings). Due to the location of drilling pad, drilling 

equipment, and pipe strings associated with the Yampa River HDD, surface disturbing activities would occur 

within the 100-year floodplain of the Yampa River. However, the HDD work areas would be located outside of 

the water level of the river, and thus would avoid instream impacts. Construction techniques and reclamation 

would be designed to minimize potential increased sedimentation during future high water events. Refueling 

and lubrication of drilling equipment would occur at the drilling site (inside of the 100-year floodplain); 

therefore, any fuel spills or leaks could affect the Colorado pikeminnow’s critical habitat at this location. 

Impacts to designated critical habitat for the Colorado pikeminnow in the White River, which is about 10 miles 

downstream from the proposed crossing location, is not anticipated. 

The proposed HDD crossings of the White and Yampa rivers would avoid instream impacts assuming a 

successful HDD crossing would be constructed at each of these locations; thus, there would be little to no 

effect on the Colorado pikeminnow or its designated critical habitat. Only minor turbidity impacts would be 

anticipated from light disturbance associated with the preliminary crossing set-up. In the unlikely event of an 

inadvertent release of drilling fluids (a “frac-out”), water quality would be degraded in the immediate vicinity of 

the crossing during HDD activities. If this were to occur, drilling activities would cease and countermeasures 

would be implemented according to the Drill Fluid Contingency Plan. In such a case, turbidity and 

sedimentation impacts, as well as minor amounts of chemical constituents, would adversely affect the 

waterbody for some distance downstream due to mud flocculation and settling. Such effects would probably 

occur within 0.5 mile or so of the HDD site. 

Successful implementation of the measures in the Drill Fluid Contingency Plan would minimize potential 

impacts to the Colorado pikeminnow and its critical habitat and would reduce them to short-term in duration. 

Bluehead Sucker, Flannelmouth Sucker, Mountain Sucker, Colorado River Cutthroat Trout, and 

Roundtail Chub. Since these species occur at and downstream of the proposed crossings, impacts of water 

withdrawal and stream crossing construction would be the same as described for the Colorado pikeminnow. 

The proposed Project may impact individual fish but would not likely cause a trend toward federal listing or loss 

of viability for these species. 

Conclusion 

Impacts to special status wildlife species would be avoided or minimized through implementation of 

applicant-committed environmental protection measures in the Environmental Protection Plan and Biological 

Resources Protection Plan, as well as the proposed construction schedule, which avoids critical nesting and 

spawning times of the year. These protective measures would prevent or minimize potential impacts to special 

status wildlife species such that the proposed Project would not be likely to result in a loss of viability, nor 

cause a trend toward federal listing or a loss of species viability rangewide. 

Impacts to special status fish species in five streams (Piceance Creek, Dry Fork Piceance Creek, White River, 

Yampa River, and Little Snake River) would be minimized through implementation of protection measures 

outlined in the Biological Resources Protection Plan; Environmental Protection Plans; Hazardous Materials 

Management and Spill Prevention, Containment, and Countermeasures Plan; Drill Fluid Contingency Plan;

and other POD-related plans, as discussed by species under analysis above. Implementation of practices in 

these plans would minimize effects on habitat for special status fish species through such measures as 

controlling sediment from disturbed areas, requiring bridges at all flowing stream crossings and establishing a 
4.7-22 September 2008 

setback distance from riparian vegetation, and reclaiming streambanks. Additional protection measures would 

include avoiding spawning periods for coldwater and warmwater fish. Collectively, these protection measures 

would minimize potential impacts to special status fish species such that the proposed Project likely would not 

result in a loss of viability, nor cause a trend toward federal listing or loss of species viability rangewide. 

Construction activity within the proposed ROW could directly affect special status amphibian species in flooded 

areas, wetlands, streams, or ponds in Wyoming and Colorado. Vehicles could cause mortalities or alter 

aquatic habitat used by these species. The proposed Project likely would not result in a loss of viability, nor 

cause a trend toward federal listing or loss of species viability rangewide. 

Operation Phase

Issues 

• The issues associated with operations would be similar to the issues described for wildlife, aquatic, 

and vegetation resources 

• Potential localized sedimentation and disturbance to habitat if maintenance activities were required at 

a stream crossing 

Analysis 

Both normal and abnormal (e.g., spill event and clean up) operations would have minimal effects on special 

status wildlife resources. Impacts to special status wildlife species from maintenance activities would be the 

same as those discussed during construction for general wildlife. Potential direct impacts include long-term 

habitat loss or alteration of potential breeding and/or foraging habitats until vegetation has been reestablished. 

Potential impacts also could result in mortalities of less mobile or burrowing species as a result of crushing by 

vehicles and equipment, and the potential abandonment of a nest site or territory, and the loss of eggs or 

young. Other potential impacts include short-term displacement of some of the more mobile species from the 

disturbance areas as a result of increased noise and human presence. If applicable, appropriate 

environmental protection measures identified for construction also would be implemented to minimize potential 

impacts to special status wildlife resources. 

Both normal and abnormal (e.g., spill event and clean up) operations would have minimal effects on special 

status aquatic resources. Impacts to special status aquatic species from maintenance activities would be the 

same as those discussed during construction for aquatic species. As a result, maintenance activities would not 

affect aquatic biota or their habitat. 

Information on the fate of the NGL and potential toxicity is provided in Section 4.5, Surface Water. Further 

information can be found in the risk assessment conducted for the Overland Pass Pipeline EIS completed in 

2007 (BLM 2007a), entitled “Environmental Fate and Effects of Natural Gas Liquid Releases.” If a rupture were 

to occur at a stream crossing, impacts could include the mortality of fish and macroinvertebrates in the stream 

at the rupture point. However, fish are expected to move away from the rupture area and potential impacts 

generally would be low in magnitude due to the localized extent of the affected area. 

Conclusion 

Routine maintenance and operation of the pipeline would result in minimal impact, if any, to special status 

species. Maintenance activities along the proposed Project route would result in localized, dispersed impacts 

of short duration. If NGL were accidentally released into uplands or waterbodies due to a pipeline leak, minimal 

impacts, if any, would be expected to special status species. 
4.7-23 September 2008

4.7.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. As a result, the associated 

impacts to wildlife, aquatic resources, and special status species would not occur. 

4.7.3 GRP Land Re-route Alternative 

Impacts to wildlife species (e.g., big game, small game, nongame), aquatic resources, and special status 

species would generally be the same as described under the Proposed Action, except for the disturbance of 

an additional 11.9 acres of previously undisturbed wildlife habitat and greater sage-grouse overall range, 

production area, and winter range. No additional waterbodies containing aquatic resources would be crossed 

by the GRP Land Re-route Alternative. 

For big game, small game, and nongame species, the loss of an additional 11.8 acres of habitat 

(approximately 62 percent greater than the area of the Proposed Action that would be avoided) would 

represent less than 1 percent of the overall available habitat within the broader Project region. In most 

instances, suitable habitat adjacent to the disturbed areas would be available for wildlife species until grasses 

and woody vegetation were reestablished within the disturbance areas. Additional edge habitat would be 

created as a result of the disturbance of the re-route area. 

The total area of two CDOW-designated sage-grouse core habitats that would be crossed in the proposed 

Project vicinity is approximately 647,900 acres. The Proposed Action construction would impact a total of 

approximately 421 acres (less than 0.07 percent) of that core habitat. The proposed re-route would impact an 

additional 11.8 acres of that core habitat. 

If construction activities were to take place during sage-grouse breeding or nesting season (March 1 to 

June 30), impacts to sage-grouse would include, but are not limited to, displacement into less suitable habitat, 

nest abandonment, destruction of nests and loss of habitat. 

Other impacts, such as habitat fragmentation and the spread of exotic plants can degrade sage-grouse 

habitat. Noise and increased human-related activity such as construction and maintenance of the pipeline can 

also disrupt breeding and nesting. Due to the close proximity of an active greater sage-grouse lek, it can be 

expected that male lek attendance would decline. This would likely result in decreased breeding success and 

an overall reduction in population over time (Connelly et al. 2004). 

If reclamation efforts are unsuccessful, the spread of exotic plants such as cheat grass in the area would 

reduce nesting habitat quality. This would likely impact nesting sage-grouse or nest success of nearby sagegrouse due to female site fidelity. This would create an “island” of intact habitat that may be deemed less 

effective of even avoided by future generations of sage-grouse due to surrounding disturbances. This island of 

avoided habitat would be approximately 900 acres. 

An active greater sage-grouse lek occurs within 0.6 mile of the alternative route between MP ALT-2.1 and 

ALT-3.0. As discussed under the Proposed Action, OPPC has committed to multiple protection measures for 

greater sage-grouse (Table 4.7-6), including: 

• No permanent aboveground facilities within a 0.6-mile radius of all active leks on lands administered 

by the BLM LSFO. 

• No surface disturbing activities within 0.6 mile of an active lek on lands administered by the BLM 

LSFO from March 1 to May 15. 

• No surface disturbing activities within a 4-mile radius of an active lek (within suitable nesting habitat) at 

the time of construction between March 1 and June 30 on land administered by the BLM LSFO in 

Colorado. Some allowances may be made based upon site-specific consultations with the 

jurisdictional agency. 
4.7-24 September 2008 

The above mitigation measures may be effective at protecting breeding and nesting activities during the 

planned project construction and maintenance. However, if emergency maintenance of the pipeline is needed 

during the life of the project, it is possible that disturbance of the lek site, breeding and nesting activities would 

be unavoidable. Additional minimization and/or mitigation measures that could be employed and may be 

effective include, but are not limited to, the following: 

• Use of enhanced seed mixtures, 

• Additional sagebrush plug plantings, 

• Reduced ROW width for construction, and 

• Topsoil segregation. 

Impacts to special status fish species would be the same as described under the Proposed Action, as no 

additional waterbodies containing aquatic resources would be crossed by the GRP Land Re-route Alternative. 
4.8-1 September 2008

4.8 Land Use, Recreation, and Visual Resources 

4.8.1 Proposed Action 

The proposed Project would require land for the construction ROW, permanent ROW, additional TWAs, 

access roads, and construction and operation of ancillary facilities. The construction ROW would have a 

nominal width of 75 feet and the permanent ROW for operations would be 50 feet wide. The permanent ROW 

would be maintained in an open condition (i.e., generally free of trees and aboveground structures) for the life 

of the pipeline facilities. 

To mitigate impacts to land use, recreation and visual resources during construction, OPPC would implement 

environmental protection measures described in the POD (CH2M Hill Trigon, Inc. 2008). Relevant plans 

attached as appendices include the Environmental Compliance Management Plan, Fugitive Dust Control Plan, 

Weed Management Plan, Transportation Management Plan, and Environmental Protection Plan. 

Environmental protection measures to be implemented include: 

• Hiring a third-party environmental inspector to observe and document environmental compliance, as 

well as actively identify and anticipate potential environmental compliance concerns ahead of 

construction. 

• Minimizing erosion through the implementation of erosion control measures in accordance with the 

Environmental Protection Plan, including limiting the number of cuts and fills, and keeping the period 

between construction and reclamation activities as short as possible. 

• Minimizing interference and damage to crop and rangelands and minimizing activities during 

construction and maintenance. This would include limiting disturbance during construction to the 

minimum necessary to efficiently complete construction activities, bracing and securing fences and 

gates, coordinating with landowners to install temporary fencing and/or cattle guards as needed, 

maintaining access through ROW for livestock and landowners, and maintaining access to water 

sources for livestock. 

• Keeping grazing allotment permittees on federal lands managed by the BLM and fee-land ranchers 

informed regarding schedules to allow them ample opportunity to move livestock away from the ROW. 

• Mitigating damage to agricultural lands and facilities from construction as soon as practical. This would 

include eliminating ruts; restoring ditches, cattle guards, fences, gates and artificial and natural 

livestock water sources to their original condition or better; and mitigating damage to pasture and 

grazing lands, including paying special attention to irrigated agricultural lands. 

• Minimizing and/or mitigating soil compaction within the construction area and along the ROW. Areas 

of soil compaction would be returned to approximate pre-construction conditions during reclamation. 

• Monitoring and controlling the spread of invasive plant species and noxious weeds along the ROW for 

the life of the Project. 

4.8.1.1 Land Use 

Construction Phase

Issues 

• Construction interference with planting and harvesting annual crop 

• Construction activities interfering with livestock management, such as blocking access to pasture and 

water 

• Temporary reduction in the carrying capacity of the federal and private grazing areas 
4.8-2 September 2008 

• Reduced crop productivity because of soil mixing and compaction (Section 4.4) 

• Clearing of forested lands/timber production areas during construction activities (Section 4.6) 

Analysis 

Rangeland areas would be the most predominant land use affected by the proposed Project (Table 4.8-1). In 

areas where rangeland is used for grazing, surface disturbances from construction activities would temporarily 

reduce the carrying capacity of BLM grazing allotment and privately held pastures, and temporarily would 

hinder the movement of livestock, horses, and/or wildlife across those allotments. To mitigate impacts to 

grazing management activities during construction, OPPC would implement environmental protection 

measures summarized above and described in the POD and associated appendices (CH2M Hill Trigon, Inc. 

2008). 

Table 4.8-1 Acres of Land Use Affected by Construction and Operation of the Proposed Project 

Forest Rangeland Agricultural Wetlands Total1

Colorado 

 Rio Blanco Permanent Easement 96.9 78.9 49.2 0.0 225.0 

Temporary Easement 48.6 39.8 24.4 0.0 112.8 

TWAs 34.3 13.2 14.6 0.0 62.1 

 Moffat Permanent Easement 30.7 297.7 13.8 9.0 351.2 

Temporary Easement 15.3 163.1 5.3 4.5 188.2 

TWAs 8.4 48.2 3.9 7.4 67.9 

 Subtotal1 234.2 640.9 111.2 20.9 1,007.2 

Wyoming 

 Sweetwater Permanent Easement 8.7 306.0 0.0 0.0 314.7 

Temporary Easement 4.1 153.3 0.0 0.0 157.4 

TWAs 1.2 62.4 0.0 0.0 63.6 

 Carbon Permanent Easement 0.0 33.9 0.0 0.0 33.9 

Temporary Easement 0.0 16.8 0.0 0.0 16.8 

TWAs 0.0 5.7 0.0 0.0 5.7 

 Subtotal1 14.0 578.1 0.0 0.0 592.1 

Project Total1 248.2 1,219.0 111.2 20.9 1,599.3 

1

Discrepancies in acreage totals are due to rounding; totals represent temporary impacts to ROW only and do not include 51.6 acres for 

use of existing off-ROW contractor/pipe yard, 0.7 acre for construction of one new access road, or 5.6 acres for potential widening of 

existing access roads. 

Surface disturbances associated with construction activities would reduce available forage for livestock in the 

proposed Project ROW. Given the narrow, linear nature of the ROW, livestock forage reductions would be 

minor in comparison to the total forage available on the large BLM allotments and private ranches crossed by 

the proposed route. In addition, any loss of forage would be temporary and BLM would not reduce the grazing 

preference or AUM on any BLM grazing permit because of the pipeline Project. OPPC would implement 
4.8-3 September 2008

measures outlined in the Environmental Protection Plan to ensure timely and appropriate revegetation. 

Herbaceous communities would reestablish within 3 to 5 years after construction. 

Construction activities would interfere with grazing management patterns and timing. To allow grazing 

allotment permittees on federal lands and fee-land ranchers the time to move livestock away from the ROW 

before construction begins, permittees and landowners would be kept informed of the construction schedule. 

Temporary gates and fences would be installed as necessary. 

Construction would block access to water and pasture sites. To maintain access to water and pasture sites for 

livestock and allow livestock to cross the ROW during construction hard or soft plugs would be left or installed 

at maximum 1-mile intervals. Additionally, ramps would be installed to allow for the escape of livestock should 

they fall into the trench. Once construction is complete any livestock facilities such as corrals, water sources, 

gates, and fences would be repaired or replaced if damaged during construction. These facilities would be left 

in as good or better condition than the pre-construction condition. Riparian areas on federal lands would be 

fenced until reclamation is successful. Fencing would be installed around the incised banks and channel with a 

sufficient gap to allow for passage of wildlife or livestock up or down the channel. These measures would 

reduce or eliminate potential impacts to livestock during pipeline construction. 

Agriculture lands only occur in the Colorado portion of the proposed pipeline route. The primary impacts on 

agriculture lands during construction would include the loss of crops within the work area and the potential for 

reduced yield of future crops. In the construction area, croplands would generally be taken out of production 

for one growing season. On irrigated agricultural lands, re-contouring and ripping to relieve compaction would 

be conducted to return fields to pre-construction conditions. If any irrigation systems are encountered along the 

proposed pipeline route, OPPC would replace/repair any irrigation systems damaged by construction activities. 

To prevent the introduction and/or establishment of noxious weeds, pre- and post-construction weed 

management programs would be implemented as described in the Weed Management Plan. Reseeding of 

disturbed areas would be conducted using mixtures approved by the BLM and state agencies. 

The construction techniques proposed by OPPC are largely sufficient to minimize impacts and restore surface 

contours. The majority of agricultural lands are on private land. While the BLM has no regulatory authority to 

require additional mitigation on private land, private landowners can request mitigation as part of their 

easement negotiations. 

The primary effect of construction on forested land would be the temporary removal of trees and shrubs from 

the construction ROW and TWAs, where required. The rate of forest reestablishment would vary depending on 

species and weather conditions. Regrowth to the sapling young tree stage would take 15 to 30 years, while 

regrowth of forests to mature conditions would likely take between 50 to 100 years depending on the species. 

Conclusion 

OPPC would implement measures described in the POD (CH2M Hill Trigon, Inc. 2008) to minimize and 

mitigate for impacts on rangeland and agricultural land affected by construction activities. Specific 

applicant-committed environmental protection measures to rangeland and agriculture are identified in the 

Environmental Compliance Management Plan, Weed Management Plan, and Environmental Protection Plan. 

Pre-construction activities would include measures to reduce or eliminate impacts to livestock exposed to open 

trenches and the introduction or spread of noxious weeds. Post-construction activities would include measures 

to re-contour agriculture lands, for revegetation of herbaceous and shrubland communities, and for continued 

control of noxious weeds. 

OPPC would be responsible for ensuring successful revegetation of soils disturbed by Project-related 

activities. Successful revegetation would be determined by evaluating the: 1) percent total adjacent 
4.8-4 September 2008 

herbaceous cover; 2) new or expanded populations of noxious weeds; and 3) species composition as 

compared to adjacent, off-ROW vegetation. Follow-up inspections would consist of intensive surveys the first 

growing season after construction and reclamation to assess revegetation success and determine the need for 

further reclamation. Routine monitoring throughout the life of the Project would take place to monitor long-term 

revegetation success. Revegetation would be considered successful when total herbaceous cover is at least 

70 percent of that on adjacent land, and species composition is comprised of a mix of seeded species and 

desirable volunteers from adjacent communities. In agricultural areas, revegetation would be considered 

successful if crop yields are similar to adjacent undisturbed portions of the same field. 

Operation Phase

Issues 

• Potential interference with farm field cultivation and harvest 

• Same issues identified for construction, but on a smaller scale 

• Permanent loss of forested areas on pipeline ROW for maintenance activities 

Analysis 

Following construction, rangeland uses would be allowed to continue within the permanent ROW. Temporary 

fences would be removed, the ROW restored to its pre-construction condition, and livestock would be able to 

graze and roam freely over the permanent ROW. No long-term impacts to rangeland are expected. Once 

construction was completed, the majority of agricultural land uses would be able to continue within the 

permanent, operational ROW. However, if aboveground facilities were sited on agricultural land, the land use 

would be permanently changed from agricultural to developed land. Some activities within the permanent 

ROW, such as planting of trees and shrubs would be prohibited. 

Following cleanup and reseeding of the construction ROW in agricultural areas, the affected areas would 

typically regenerate quickly. Herbaceous vegetation would generally be reestablished within 3 to 5 years of 

restoration, depending on climatic conditions. 

Following construction, trees and shrubs would be allowed to regenerate within the areas that would not be 

retained as part of the 50-foot-wide permanently maintained ROW. The permanent ROW would be maintained 

to support primarily herbaceous- or shrub-dominated communities. The rate of forest reestablishment would 

vary depending on species and weather conditions. Regrowth to the sapling young tree stage would take 15 to 

30 years, while regrowth of forests to mature conditions would likely take between 50 to 100 years depending 

on the species. 

Conclusion 

During operations, the ROW would revegetate and largely revert to former uses. Most agricultural crops would 

be permitted to grow in the ROW. With the exception of forest land removed from the permanent ROW and 

placement of aboveground facilities, the majority of previous land uses would continue unencumbered. 

4.8.1.2 Access Roads 

Construction Phase

Issues 

• Construction of temporary and permanent access roads in areas designated as Existing Roads and 

Trails 
4.8-5 September 2008

Analysis 

During construction, temporary access roads would be located on existing state, county, private, and BLM 

roads to gain access to the ROW. The existing roads were used on the recently constructed Entrega and WIC 

Piceance pipelines. The locations of all identified access roads and proposed modifications are listed in the 

Transportation Management Plan. Figures 2.1-2 and 2.1-3 show the access roads to be used in Colorado and 

Wyoming, respectively. State requirements would be followed when hauling equipment and materials on all of 

the access roads. 

One new 15-foot-wide by 0.4-mile-long access road is proposed to be built on fee land. Based on landowner 

request it would be located on the south side of the White River crossing. 

Some of the existing roads might require modifications, including grading, to make them usable for pipeline 

construction. OPPC would maintain the roads, which would include blading and widening throughout the 

construction period to keep roads level and not rutted. Table 2.1-2 shows all roads potentially needing 

widening; a maximum of 5.6 acres potentially would be impacted due to the widening of existing access roads. 

For those areas where improvements occurred outside of the pre-construction roadway, following the 

completion of construction, all areas of new impact would be reclaimed and reseeded using the reclamation 

techniques and seeding mixes proposed in the Environmental Protection Plan. 

Conclusion 

OPPC would implement the measures in the Transportation Management Plan to minimize impacts from 

temporary access road improvements and maintenance activities. With the exception of one new 0.4-mile-long 

access road to be built on private land, temporary access roads would consist of a combination of existing 

roadways including areas designated as Existing Roads and Trails. 

Operation Phase

Issues 

• Same issues as construction, but on a smaller scale 

Analysis 

During the life of the Project, operation and maintenance activities would require year-round access to the 

ROW. Surface travel would be limited to the ROW and would include activities such as surveys, inspections, 

maintenance and repairs. Impacts are expected to be minor and temporary. 

Conclusion 

OPPC would implement measures in the Transportation Management Plan to minimize impacts from ROW 

travel for operation and maintenance activities. 

4.8.1.3 Utilities 

Construction Phase

Issues 

• Buried utility crossings – water lines, fiber optic lines, natural gas and product lines 

• Offsets from other utilities (overhead electric transmission lines, other pipelines) 
4.8-6 September 2008 

Analysis 

The Proposed Action has been routed and designed to maximize co-location with existing utility ROWs and to 

minimize impacts to the environment, area residents, and local businesses. Where OPPC facilities would be 

co-located with an existing pipeline or powerline ROW, the proposed pipeline centerline generally would be 

located 50 feet from the existing utility centerline. In most cases, the proposed 75-foot-wide construction ROW 

would overlap an area recently disturbed by the previous construction of these existing pipelines. Co-locating 

the proposed pipeline ROW with existing ROWs would reduce the amount of new disturbance associated with 

the proposed Project. 

While co-location of utility ROWs reduces the amount of new disturbance, there are safety considerations that 

limit how close they may be constructed to one another. Depending on a number of factors, transmission 

pipelines generally are constructed between 25 to 60 feet apart. The proposed pipeline generally would be 

offset 50 feet from existing pipelines. To minimize potential hazards posed to existing utilities by outside forces 

such as bulldozers and backhoes during construction and maintenance, OPPC would participate in the “one 

call” system and follow the Project’s Emergency Response Plan, which is provided as an appendix to the 

POD. 

Conclusion 

The proposed pipeline centerline generally would be located 50 feet from existing pipeline centerlines, where 

possible. Potential impacts would be limited to construction and would be temporary and short-term. 

Operation Phase

Issues 

• Same issues as construction, but on a smaller scale 

Analysis 

Following construction, OPPC would maintain a 50-foot-wide permanent ROW for operation of the pipeline 

facilities. OPPC would participate in state one-call programs to ensure maintenance activities do not harm 

other underground utilities. 

Conclusion 

Co-location with existing pipeline ROWs would help consolidate and minimize impacts associated with utilities. 

4.8.1.4 Special Land Uses and Recreation Areas 

Construction Phase

Issues 

• Temporary impacts on recreational traffic and use patterns 

• Soil and vegetative disturbances in protected areas 

• Potential conflicts between recreation uses and construction 

Analysis 

The Natural Heritage Program (NHP) has identified three PCAs in the vicinity of the proposed Project 

containing sensitive plant and wildlife species. In 2007 and 2008, OPPC conducted surveys to identify 
4.8-7 September 2008

potential sensitive plant habitats and wildlife species identified by the BLM and the NHP within the proposed 

Project vicinity. Environmental protection measures that have been identified for these species are discussed 

in more detail in this EA under Special Status Plant Species in Section 4.6 and Special Status Wildlife Species 

in Section 4.7. 

The proposed pipeline route would cross 0.8 mile of GRP land at a location where it would parallel the existing 

pipeline corridor containing three other pipelines. OPPC and NRCS are currently working on a resolution in an 

attempt to allow the pipeline route to remain as proposed; parallel to the existing corridor. This would minimize 

impacts to resources associated with disturbing new greenfields, including visual impacts, soil destabilization, 

and habitat fragmentation. 

In addition, lease agreements between OPPC, the BLM, and state land managers would include measures to 

avoid and/or mitigate impacts to these areas, and ensure that the ecological functions of these areas are 

maintained. 

Pipeline construction would have temporary impacts on recreational traffic and use patterns. Sightseers, 

hikers, wildlife viewers, hunters, off-highway vehicle users, and mountain bikers would be displaced from the 

immediate area during construction. Issues in common to all these recreational and special interest areas 

include soil disturbance and revegetation, repair and maintenance of public access roads, and coordination 

with the agency managers to minimize conflicts between construction activities and the recreational uses for 

which these special areas were established. Lease agreements between OPPC and the BLM and state land 

managers would include measures that would avoid or minimize conflicts with recreational use. 

Conclusion 

By coordinating with agency managers, following lease agreements and implementing the environmental 

protection measures outlined in the POD (CH2M Hill Trigon, Inc. 2008), impacts to special land use and 

recreation areas would be minimized during construction activities. Following construction, cleanup and 

revegetation of the ROW would be conducted. In the disturbed areas, vegetation would generally regenerate 

quickly, with herbaceous vegetation reestablishing within 3 to 5 years of restoration, depending on climatic 

conditions. 

Operation Phase

Issues 

• Same issues identified for construction, but on a smaller scale 

• Permanent loss of forested areas on pipeline ROW for maintenance activities 

Analysis 

Operation and maintenance activities would be minimal and temporary in recreation and special land use 

areas. Implementation of environmental protection measures outlined in the POD (CH2M Hill Trigon, Inc. 

2008), including ripping of soils to relieve compaction, revegetation, and control of noxious weed species 

would minimize impacts from pipeline construction. Areas in the permanent ROW would revegetate quickly, 

except for forested areas. Forested areas would generally take 50 to 100 years to reestablish to mature forest 

conditions, depending on species. Within the 50-foot-wide permanent ROW, trees would be removed as part 

of maintenance activities. 
4.8-8 September 2008 

Conclusion 

After completion of construction, recreational use would be allowed to continue within the permanent ROW. 

Reclamation of special land use areas would be conducted to minimize impacts to vegetation communities 

and soils. 

4.8.1.5 Visual Resources 

Construction Phase 

Issues 

• Modification of existing natural and cultural landscapes viewed from special management areas, trails, 

roads, recreation areas and other public locations 

• Views from nearby residences 

Analysis 

Public lands that would be affected by the proposed Project consist predominantly of federal lands managed 

by the BLM, with some small areas of Colorado and Wyoming state-owned lands. As discussed in 

Section 3.7.1.4, the BLM has a VRM standard for each resource area that would be crossed by the proposed 

pipeline route. These lands are managed to ensure protection and maintenance of the quality of scenic and 

visual resources. OPPC would adhere to these BLM management requirements. The proposed Project would 

be constructed within 1.0 mile of VRM Class I lands and would cross 0.1 mile of VRM Class II lands 

(Figure 3.7-3). At these locations, the proposed Project would parallel and expand by 50 feet the existing WIC 

Piceance pipeline ROW disturbance and would be largely unnoticeable to the casual viewer. The proposed 

Project also would cross 87.2 miles of VRM Class III, and 35.8 miles of VRM Class IV lands. The remaining 

length of the proposed centerline would be situated on private or state lands. 

The proposed Project would cross the Cherokee Trail on VRM Class IV lands in southern Wyoming. Although 

the visual impact where the proposed pipeline would cross the trail is minimal, as there is an extensive visual 

footprint remaining from the previous pipeline construction, a section of the trail to the east of the crossing 

would suffer a moderate visual impact to the site setting due to the removal of patchy pinyon-juniper woodland 

that covers the short hills to the west of the trail. This would temporarily create a swath of leveled land through 

the rolling hills and cause a moderate to severe contrast with the current setting. To minimize the anticipated 

visual impacts at the Cherokee Trail crossing, OPPC has committed to the following protection measures in 

the vicinity of the trail as part of the Cultural Resources Protection Plan: 

• Blading and all ground disturbance would be reduced to the minimum width necessary to safely 

complete construction. 

• Grading and restructuring of the surface, where construction would alter small, low hills, would follow 

contours to minimize the land disturbance. 

• Protective matting would be installed along the working side of the construction corridor to minimize 

ground surface disturbance. 

• “Brush hogging” would be used for clearing vegetation to minimize ground disturbance. 

• Edges of tree clearings would be feathered and uneven to reduce the linear nature of the contrast. 

• Natural topsoils would be stockpiled and reused in ground surface restoration. 

• Ground surface would be recontoured following construction to match the original natural contours. 

• The area would be mulched and revegetated or reseeded in a manor that would approximate the 

current groundcover. 
4.8-9 September 2008

The landscape along the proposed pipeline route ranges from gently rolling landforms with vegetation limited 

to shrubs or grasses, to diverse riparian landscape, to steeply sided landforms with shrubs and coniferous 

vegetation. View distances range from foreground to middleground and background (more than 5 miles). 

Visual impacts caused by the construction ROW and additional TWAs would result from the removal of 

existing vegetation and the exposure of bare soils, as well as earthwork and grading impacts associated with 

heavy equipment tracks, trenching, blasting, rock formation alteration or removal, and machinery and tool 

storage. Other visual impacts would result from removal of the larger individual trees that have aesthetic value; 

the removal or alteration of vegetation that would otherwise provide a visual barrier; or landform changes that 

would introduce contrasts in visual scale, spatial characteristics, form, line, color, or texture. 

Visual impacts would be greatest where the proposed pipeline ROW would be seen by passing motorists or 

recreationalists and where the proposed pipeline route paralleled or crossed roads, trails, recreation areas, or 

prominent off-site observation points. The duration of visual impacts would depend on the type of vegetation or 

land formation that was cleared or altered. The duration of impact of vegetation clearing would be shortest on 

rangeland consisting of short grasses and hay fields, where the reestablishment of vegetation following 

construction would be relatively fast (generally 3 to 5 years). The duration of impact would be greater on shrub 

rangeland, which could take at least 5 years to regenerate, and could take up to 20 to 30 years to mature. The 

highest potential visual impact would result from the removal of large trees, which would take longer than other 

vegetation types to regenerate and would be prevented from reestablishing on the permanently maintained 

50-foot-wide ROW. Topographic alterations such as sidehill cuts, if necessary to construct the pipeline, would 

be restored to original grade during ROW restoration. The visibility of such alterations would diminish over time 

as the affected areas aged and blended with the surrounding landscape. 

To minimize construction impacts on visual resources, the proposed pipeline route would be aligned adjacent 

to existing pipeline ROWs or other transportation corridors where feasible. In areas where ROW co-location is 

not possible for engineering and/or construction reasons, the proposed pipeline route would be aligned to 

avoid aesthetic features to the extent possible. Visual impacts from the construction of the aboveground and 

belowground facilities would be low to moderate and, as such, less-than-significant. 

Conclusion 

The proposed pipeline would be buried, the vegetation reclaimed, and the topographical contours returned to 

their pre-construction condition. Therefore, visual impacts associated with construction and operation of the 

proposed pipeline facilities would be within BLM VRM management objectives. 

Operation Phase 

Issues 

• Modification of natural and cultural landscapes viewed from special management areas, trails, and 

public locations 

• Same issues as for construction 

• Operational views from nearby residences 

• Proximity of the pipeline to public gathering places 

Analysis 

The proposed Project would include the construction of meter stations, one potential future pump station, 

valves, and pigging facilities at various locations along the proposed pipeline route. These aboveground 

structures would be permanent and would remain in operation throughout the life of the Project. The impacts 

on visual resources from each individual facility would depend on the pre-construction condition and the 
4.8-10 September 2008 

visibility from the surrounding area. To the extent possible the pump station, if constructed, would be located 

adjacent to existing commercial/industrial facilities that already experience a visual impact, and the meter 

stations would be constructed in association with a pump station where applicable or placed within an area 

that minimizes visual impacts to the extent possible. 

The landscape of the proposed pipeline route ranges from gently rolling landforms with vegetation limited to 

shrubs or grasses, to diverse riparian landscape, to steeply sided landforms with shrubs and coniferous 

vegetation. View distances range from foreground, to middleground, and background (more than 5 miles). 

Long-term visual impacts as a result of aboveground facilities for the proposed Project would be caused by 

valves or pigging facilities. Successful revegetation would blend the belowground portions of the pipeline with 

its surroundings. Aboveground facilities would meet the operational requirements of the pipeline owners and 

operators and also would be compatible with the surrounding landscape. This would entail the selection of 

appropriate ground surfacing, building surfacing, fencing, signing, and color selection and finish. Visual 

impacts from the operation of the aboveground facilities would be low to moderate and, as such, less than 

significant. 

Conclusion 

Project design and applicant-committed environmental protection measures would minimize visual impacts by 

locating the proposed aboveground facilities in areas already used by other pipelines, minimizing unnecessary 

nighttime lighting, and by using agency-approved paint colors and materials. 

4.8.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. As a result, the associated 

impacts to land use, special recreation, and aesthetic resources would not occur. 

4.8.3 GRP Land Re-route Alternative 

Should the GRP Land Re-route Alternative be constructed, the total project length would increase by 1.3 miles 

to 153.5 miles. This additional mileage equates to an additional 11.9 acres of disturbance during construction 

to rangeland and BLM grazing allotments. Two BLM grazing allotments would be impacted by the re-route: an 

additional 12.0 acres of land would be disturbed within the Piskwik grazing allotment and approximately 

0.1 acre less would be disturbed within the Big Hole Gulch grazing allotment. As discussed under the 

Proposed Action, no long-term impacts to rangelands or BLM grazing allotments would be anticipated. The 

11.9 acres of additional disturbance associated with the GRP Land Re-route Alternative represents a change 

of less than 1 percent to impacts associated with the overall Project. 

No new access roads have been proposed along the GRP Land Re-route Alternative. If buried utilities are 

identified along the alternative route, impacts and mitigation would be similar as described in the Proposed 

Action. 

As there are no special land uses or recreation areas along the GRP Land Re-route Alternative, no impacts to 

special land uses or recreation areas would be anticipated. The GRP Land Re-route Alternative would be 

routed through VRM Class III landscape and there would be no new pumps or pump stations along the 

alternative route. Visual impacts would be the same as those described for the Proposed Action. 
4.9-1 September 2008

4.9 Cultural Resources 

4.9.1 Proposed Action 

Construction Phase

Issues 

• Potential impact on NRHP-eligible properties such as prehistoric or historic archaeological sites, 

districts, buildings, structures, and objects 

• Potential discovery and adverse affects on previously undiscovered cultural resources, including 

burials and associated funerary objects 

• Unauthorized artifact collection and vandalism 

• Introduction of visual or auditory elements that diminish the integrity of the property’s significant 

historic feature 

Analysis 

Section 106 of the NHPA requires that federal agencies take into account the effect of an undertaking on 

historic properties and provide the ACHP an opportunity to comment. Historic property, as defined by the 

regulations implementing Section 106, means “any prehistoric or historic district, site, building, structure, or 

object included in, or eligible for inclusion in, the NRHP maintained by the NPS.” The term includes 

properties of traditional religious and cultural importance to an Indian tribe or Native Hawaiian organization 

that meet the National Register criteria. Potential impacts to historic properties are assessed using the 

“criteria of adverse effect” (36 CFR 800.5[a][1]), as defined in the implementing regulations for the NHPA. 

“An adverse effect is found when an undertaking may alter, directly or indirectly, any of the characteristics of 

a historic property that qualify the property for inclusion in the National Register in a manner that would 

diminish the integrity of the property’s location, design, setting, materials, workmanship, feeling, or 

association.” The analysis of impacts using these criteria is limited to those resources that are listed on the 

NRHP or have been recommended as eligible. 

Those areas in which impacts are planned or are likely to occur are referred to as the “area of potential 

effect” or APE. Specifically, the APE is defined as the geographic area or areas within which an undertaking 

may directly or indirectly cause changes in the character or use of NRHP-eligible cultural resources, if any 

such resources exist. Additionally, the APE is influenced by the scale and nature of an undertaking and may 

be different for different kinds of effects caused by the undertaking (36 CFR 800.16[d]). 

The APE should include: 

• All alternative locations for all elements of the Proposed Action; 

• All locations where the Proposed Action may result in disturbance of the ground; 

• All locations from which elements of the Proposed Action (e.g., pump stations or land disturbance) 

may be visible or audible; 

• All locations where the Proposed Action may result in changes in traffic patterns, land use, public 

access, etc.; and 

• All areas where there may be indirect as well as direct effects. 

The APE for the proposed Project includes the 300-foot-wide survey corridor and, in some cases, an area 

extending up to 3 miles beyond the corridor to include any important historic sites within the viewshed of any 
4.9-2 September 2008 

aboveground facilities. Only those historic properties located in the APE were reviewed to determine if any 

would be subject to impacts that could affect their eligibility for the NRHP based on NRHP criteria for 

evaluation. 

Project effects include not only the physical disturbance of a historic property, but also may include the 

introduction, removal, or alteration of various visual or auditory elements, which could alter the traditional 

setting or ambience of the property. In consultation with Colorado and Wyoming SHPOs and Native 

American tribes, BLM would determine whether construction of the proposed Project would affect any 

properties listed on, or eligible for listing on, the NRHP. 

If a property would be adversely affected, mitigation would be proposed. Mitigation may include, but would 

not be limited to, one or more of the following measures: 1) avoidance through the use of realignment of the 

proposed pipeline route, relocation of temporary extra workspace, or changes in the construction and/or 

operational design; 2) data recovery, which may include the systematic professional excavation of an 

archaeological site; or 3) Historic American Buildings Survey (HABS)/Historic American Engineering Record 

(HAER) or other agreed upon historic recordation process. Avoidance through Project redesign is the 

preferred method of mitigation. However, when avoidance is not feasible, data recovery, HABS/HAER 

documentation, or any other agreed upon mitigation measure would be implemented prior to construction. 

Based on the Class III inventories in Wyoming and Colorado, the BLM determined that there would be 

adverse effects to historic properties as a result of the Proposed Action. 

In April 2008, the BLM visited the locations where the historic Overland and Cherokee trails would be 

crossed by the proposed pipeline. Based on the site visits, the BLM determined that visual impacts to the 

Overland Trail would not occur as a result of construction. Additionally, no traces of ruts or swales 

associated with the Trail were located within the proposed pipeline corridor. However, the BLM determined 

that visual impacts to the Cherokee Trail would occur as a result of construction and subsequently 

developed mitigation measures to reduce visual impacts to the Trail. Mitigation measures include 

site-specific construction techniques and methods and measures to be taken to minimize visual impacts at 

this proposed crossing. OPPC has committed to these measures as outlined in the Cultural Resources 

Protection Plan. Refer to Section 4.8.1.5 for further discussion of the visual impacts and associated 

protection measures at the Cherokee Trail. 

Increases in both surface activities and the number of workers during construction could increase the 

potential for indirect impacts at archaeological sites. Indirect impacts are difficult to quantify and control; 

however, they can include the loss of surface artifacts due to illegal collection and inadvertent destruction. 

To minimize indirect impacts to cultural resources from increased numbers of people in the area, 

Project-related personnel would be trained on site avoidance and protection measures, including information 

on the statutes protecting cultural resources. 

The potential for the discovery of unanticipated cultural resources during construction activities exists within 

the proposed disturbance areas and could result in adverse effects. Unanticipated discoveries would result 

in displacement or loss (either complete or partial) of the cultural resource involved. If any previously 

unknown cultural resources are discovered during construction, all construction activities would cease within 

100 feet of the discovery and the BLM Authorized Officer would be notified of the find. Any discovered 

cultural resources would be handled in accordance with the discovery requirements detailed in the POD 

(CH2M Hill Trigon, Inc. 2008). 

If construction or other Project personnel discover what may be human remains, funerary objects, or items of 

cultural patrimony on federal land, construction would cease within 100 feet of the discovery, and the BLM 

Authorized Officer would be notified of the find. Any discovered Native American human remains, funerary 

objects, or items of cultural patrimony found on federal land would be handled in accordance with the Native 

American grave Protection and Repatriation Act of 1990 and the procedures detailed in the POD (CH2M Hill 

Trigon, Inc. 2008). Non-Native American human remains would be handled in accordance with Colorado 
4.9-3 September 2008

and Wyoming law. Construction would not resume in the area of the discovery until the BLM Authorized 

Officer has issued a notice to proceed. 

If human remains and associated funerary objects are discovered on private land during construction 

activities, construction would cease within 100 feet of the discovery and the county coroner or sheriff would 

be notified of the find. Treatment of any discovered human remains and associated funerary objects found 

on private land would be handled in accordance with the provisions of applicable Colorado and Wyoming 

law. 

Conclusion 

Based on the Class III inventories for Wyoming and Colorado, there would be adverse effects to historic 

properties as a result of the Proposed Action. Mitigation procedures would be conducted for all historic 

properties located along the proposed Project corridor; however, the type of mitigation would vary. Extensive 

data recovery would be conducted at historic properties with the highest research potential. These properties 

would be selected by the BLM in consultation with the Colorado and Wyoming SHPOs, and interested 

Tribes. Those historic properties not selected for extensive data recovery would be monitored during the 

clearing of the ROW and would be subjected to open trench inspection. Formal treatment plans for those 

properties selected for extensive data recovery would be prepared in consultation with the Colorado and 

Wyoming SHPOs, and interested Tribes. Unanticipated discovery of historic properties during construction 

would be handled in accordance with the Unanticipated Discoveries Plan developed for the Project and 

attached to the POD (CH2M Hill Trigon, Inc. 2008). Therefore, any adverse effects to known historic 

properties, and to those historic properties that may be discovered during construction, would be mitigated. 

Operation Phase

Issues 

• Issues would be similar to those identified for construction 

Analysis 

Maintenance activities would result in localized impacts that would be dispersed along the entire proposed 

pipeline route. Maintenance activities would occur within areas previously disturbed by construction. 

Conclusion 

Potential adverse effects to identified historic properties would be mitigated prior to pipeline construction. 

Unanticipated discoveries of historic properties would be protected as described in the POD (CH2M Hill 

Trigon, Inc. 2008); therefore, any adverse effects to historic properties would be mitigated. 

4.9.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. As a result, none of the 

potential impacts to historic properties as identified for the Proposed Action would occur. However, 

additional knowledge of local or regional prehistory of the Project area that would have been obtained 

through data recovery would not be collected. 
4.9-4 September 2008 

4.9.3 GRP Land Re-route Alternative (Cultural) 

One prehistoric site and four isolated finds were located along the proposed GRP Land Re-route Alternative. 

The prehistoric site and all of the isolated finds are recommended as not eligible for the NRHP; no further 

work is recommended. As discussed under the Proposed Action, unanticipated discoveries would be 

protected as described in the POD. 
4.10-1 September 2008

4.10 Native American Traditional Values 

4.10.1 Proposed Action 

Construction Phase

Issues 

• Protection of sites with cultural, traditional, or religious importance to the tribes 

Analysis 

Native American consultation regarding the identification of traditional cultural properties (TCPs) or places of 

cultural, traditional, or religious importance that may be located in the proposed Project area currently is taking 

place between the BLM and tribal representatives. Potential impacts to identified TCPs or places of cultural, 

traditional, or religious importance to the tribes as a result of the Proposed Action would be the same as those 

described in Section 4.9, Cultural Resources. No surface disturbance would occur within or immediately 

adjacent to the boundary of any identified TCP or place of tribal importance prior to completion of all 

consultation required by law. If data recovery or other form of mitigation is required at a TCP or place of tribal 

importance, a data recovery or mitigation plan would be reviewed and approved by the BLM and SHPO. Tribal 

representatives would be asked to participate in the development of any such data recovery or mitigation plan. 

At this time, no TCP or place of cultural, traditional, or religious importance has been identified by the Tribes 

currently participating in Native American consultation. 

Conclusion 

If any TCP or place of cultural, traditional, or religious importance is identified in the proposed Project area, 

measures to minimize potential impacts to these resources would be developed in consultation with the Tribes 

currently participating in Native American consultation. Protection measures would be implemented prior to 

Project construction. 

The BLM intends to continue consultation throughout the environmental review and construction phase of the 

Proposed Action. Renewed contacts with some or all of the Tribes may result from unanticipated discoveries. 

Operation Phase

Issues 

• Issues would be related to maintenance activities and would be similar to those identified for 

construction 

Analysis 

Maintenance activities would result in localized impacts that would be dispersed along the entire proposed 

pipeline route. Maintenance activities would occur within areas previously disturbed by construction. 

Conclusion 

If any TCP or place of cultural, traditional, or religious importance is identified in the proposed Project area, 

measures to minimize potential impacts to these resources would be developed in consultation with the Tribes 

currently participating in Native American consultation. Protection measures would be implemented prior to 

Project construction. 
4.10-2 September 2008 

4.10.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. As a result, no potential 

impacts to any identified TCPs, or places of traditional, cultural, or religious importance to the tribes would 

occur. 

4.10.3 GRP Land Re-route Alternative 

Should the GRP Land Re-route Alternative be chosen, Native American consultation would follow the same 

protocol as the Proposed Action. Potential impacts to an identified TCP or places of traditional, cultural, or 

religious importance to the tribes, and measures to avoid or mitigate potential impacts would be addressed as 

described for the Proposed Action. 
4.11-1 September 2008

4.11 Socioeconomics 

4.11.1 Proposed Action 

4.11.1.1 Population, Employment, and Economics 

Issues 

• Changes in local population and employment during construction 

Analysis 

Short-term impacts to the existing socioeconomic environment of the proposed Project area would result 

primarily from the temporary influx of a relatively high number of construction workers. OPPC anticipates 

adding only one permanent position to its existing workforce, therefore, the proposed Project would have no 

long-term impact on the population in the Project area. 

OPPC has proposed to commence construction of the pipeline and metering stations in September 2008, and 

anticipates a peak of approximately 450 construction personnel employed on the Project during the latter 

months of 2008, potentially extending into 2009. The pipeline would be constructed in three spreads, 

constructed simultaneously with a maximum of 150 construction and inspection personnel associated with 

each spread (Table 4.11-1). Construction personnel would consist of OPPC employees, contractor 

employees, construction inspection staff, and environmental inspection staff. 

Table 4.11-1 Estimated Construction Workforce by Spread 

Spread 

Number MP Range 

Associated 

Aboveground 

Facilities Counties/State 

Estimated 

Workforce #

1 0-50 2 Meter Stations Rio Blanco and Moffat County, 

Colorado 

150 

2 50-93 NA Moffat County, Colorado 150 

3 93-152 NA Moffat County, Colorado and 

Sweetwater and Carbon County, 

Wyoming 

150 

Potential Future 82-83 1 Pump Station Moffatt, Colorado Unknown 

OPPC, through its construction contractors and subcontractors, would attempt to hire temporary construction 

staff from the local population (i.e., currently residing in nearby areas of Colorado and Wyoming) to minimize 

additional demands on housing. OPPC anticipates an estimated 75 percent of the total construction workforce 

would be hired locally. The remaining workers would be non-local personnel. Note that the local/non-local 

status would change for some workers as the specific location changes. For example, residents of Rawlins 

employed on Spread 2 may temporarily relocate to Craig, but then resume residency in Rawlins as Project 

construction moves northward. 

Environmental inspection staff would likely consist entirely of non-local employees based on the specialized 

skills and experience required for the job. 
4.11-2 September 2008 

Population impacts from the influx of construction and inspection personnel would be temporary and dispersed 

along the population centers near the proposed route. Due to the temporary and transitory nature of the work, 

most non-local workers would not be accompanied by spouses, other family members, or non-family partners. 

Nevertheless, the temporary population impacts in the smaller communities would be moderate. Any specific 

operation and maintenance task that could not be completed by OPPC staff would be completed on a 

contractual and as-needed basis. 

Given the small permanent workforce that would be needed for pipeline operation, secondary employment 

effects would be limited. Thus, the proposed Project would not have a significant long-term impact on the 

permanent population. 

Conclusion 

Construction of the proposed pipeline would temporarily increase the populations of the communities in the 

vicinity of the Project. Additionally, 75 percent of the construction workforce would be hired locally, providing 

jobs to the impacted communities. 

4.11.1.2 Infrastructure 

Issues 

• Increased demands on local infrastructure (e.g., housing, emergency and fire protection services, 

hospitals, transportation) during construction 

Analysis 

Housing

The construction period would be relatively short and most non-local workers likely would be unaccompanied 

during their work tenure on the proposed Project. Consequently, it is expected that most Project workers would 

use temporary housing, such as hotels/motels, RV parks, and campgrounds. Some workers would likely resort 

to renting furnished apartments and homes due to availability constraints of other accommodations, though 

this is generally less preferable due to landlord and property management company preferences for extended 

term commitments. Most temporary workers would seek housing in the more populated, service-oriented 

towns located within a reasonable commuting distance to the work site. Furthermore, some individuals would 

relocate during the term of the proposed Project as the active area in each spread moves along the proposed 

pipeline route. As the more convenient options fill, workers would drive further, seeking alternatives in smaller 

communities, even using campgrounds in the national forest or at state parks or camping on public lands 

despite the fact that those locations have 14-day stay limits. 

The net effect of these factors is that the temporary housing demand would be dynamic. Housing demand 

would be heaviest in Moffat and Rio Blanco counties, but only slightly lower in Carbon and Sweetwater 

counties. Availability constraints in the two former counties would likely result in commuting from nearby 

locations in Routt and Garfield counties. Consequently, for a relatively short duration, Craig, Meeker, and other 

communities potentially would experience tight market conditions for temporary housing. 

The temporary housing demands associated with the proposed Project would compete with summer tourism 

and fall hunting demands across much of the region, resulting in higher nightly lodging rates, more limited 

availability, and displacement of demand to other locations when local motels and RV campgrounds are full. 

To the extent that such displacement occurs, it would diminish the economic benefits associated with 

construction worker spending. 
4.11-3 September 2008

Housing requirements for the continuing operation and maintenance of the pipeline would be negligible to 

nonexistent. 

Public Services and Facilities

Construction of the pipeline would result in minor, temporary impacts on local facilities and services, including 

law enforcement, fire, and medical services. Lengthy emergency medical response times are of particular 

concern in the more remote stretches of the proposed pipeline route. To address these concerns, OPPC has 

drafted a Safety Plan. The Safety Plan would be provided to the BLM and Colorado and Wyoming 

Departments of Transportation. 

Other construction-related impacts on local services may include increased demand for permits for vehicle 

load and width limits and local police assistance during construction at road crossings to facilitate traffic flow. 

OPPC would work with the local law enforcement, fire departments, and emergency medical services to 

coordinate for effective emergency response. The degree of impact would vary from community to community 

depending on the number of non-local workers and accompanying family members that temporarily reside in 

each community, the duration of their stay, and the size of the community. Although these factors are too 

indeterminate and variable to accurately predict the magnitude of impact, the effects would be short-term and, 

therefore, are not expected to be significant. 

The limited number of permanent employees associated with the proposed Project would result in negligible 

long-term impacts on public services. 

Transportation

Construction across roads and highways would result in short-term impacts on public travel while construction 

activities pass through the Project area. OPPC has developed a Transportation Management Plan to assist in 

mitigating potential impacts of Project-related road use and construction activity. 

OPPC has stated that major paved roads and highways would generally be crossed by boring beneath the 

road. These crossings would require the approval and appropriate permits from state and local agencies. 

Boring typically requires TWAs on either side of the crossing for excavating bore pits to the depth of the 

pipeline while the roadway is allowed to remain open. There would be little or no disruption of traffic at road 

crossings that are bored. 

Smaller or unpaved roads would typically be open cut where permitted by local authorities or landowners. The 

open-cut crossing method may require temporary closure of a road and establishment of detours. If no 

reasonable detour is feasible, at least one lane of a road would be kept open to traffic, except for brief periods 

when it is essential to close the road to install the pipeline. OPPC would avoid closing roads during peak traffic 

hours. 

To maintain safe conditions, OPPC would direct its construction contractors to ensure enforcement of local 

weight restrictions and limitations by their vehicles and to remove any soil left on the road surface by the 

crossing of construction equipment. When it is necessary for equipment to cross roads, mats or other 

appropriate measures (e.g., sweeping) would be used to reduce deposition of mud. 

Movement of construction equipment, materials, and crew members would result in an additional short-term 

impact on the transportation network. Much of the proposed Project area is readily accessible by state primary 

and secondary highways, county roads, and private roads. Impacts on local traffic levels would be temporary 

given the linear and dispersed nature of the proposed Project as construction would move sequentially along 

the proposed pipeline route. Construction workers would commute to and from the proposed Project area from 

temporary housing in local towns and cities, although this would typically begin before sunrise and end after 
4.11-4 September 2008 

sunset, times of the day when daily local traffic tends to be light. Consequently, short duration congestion is 

likely to occur in some locations, affecting residents and other travelers as well. 

Minimal traffic is anticipated to be associated with operation and maintenance of the new pipeline as only one 

additional permanent worker would be required to operate the pipeline and ongoing contract maintenance 

would not generate substantial traffic on a consistent or long-term basis. Therefore, no impacts on 

transportation networks would be expected to occur during operation of the proposed pipeline. 

Conclusion 

There would be a temporary increase in local housing demand due to the construction of the proposed Project. 

Effects would be localized as construction crews moved along the length of each construction spread. A 

temporary increase in local traffic also would occur as construction commenced. 

4.11.1.3 Fiscal Relationships 

Issues 

• Long-term fiscal benefits (ad-valorem taxes) 

• Short-term fiscal benefits (local purchases and sales tax) 

• Monetary compensation for easement and damages to land and property 

Analysis 

During operation of the pipeline, OPPC would pay property/ad valorem taxes to local governments crossed by 

the proposed pipeline. In Wyoming, those payments would include taxes associated with a mandatory 

statewide levy to help support public education. Transmission lines are centrally assessed by the state, with 

the total valuation then allocated among the local counties based on their respective shares of the installed 

pipelines and facilities. Initially, the cost of construction provides a reasonable proxy for the market valuation of 

pipeline transmission systems. Over time, the assessment focuses more on the respective facility’s 

contribution to system-wide income and depreciated value, generally resulting in lower assessment. For this 

analysis, it is assumed that the long-term assessment would decline to 40 percent of the initial construction 

cost-based assessment. Table 4.11-2 summarizes the estimated assessed valuation and corresponding 

annual property taxes, by county, directly associated with the proposed Project. 

Estimated valuation for the proposed pipeline and additional pump station would be approximately 

$109.2 million. Of that sum, 38 percent would be in Wyoming and 62 percent in Colorado. Total annual 

property taxes levied on those assessments are estimated at approximately $2.36 million. Over time, the total 

assessed value is anticipated to decline to $43.7 million and annual property taxes paid would decline to 

$0.94 million. The ongoing revenues, given the relatively low demands on public services and facilities would 

represent a substantial economic benefit associated with the proposed Project. 

Property tax revenues are typically used by local and state governments for infrastructure improvements such 

as roads, schools, and health facilities and to meet other needs of the community. 

Local businesses would benefit from demands for goods and services generated by the temporary 

construction workforce. Benefits in the form of higher business volume would accrue to many retail, lodging, 

eating and drinking, convenience stores/fueling stations, and other business establishments across the entire 

proposed route and in nearby communities. Estimated spending for such goods and services, based on OPPC 

workforce estimates and daily spending assumptions, would total approximately $8.0 million during the 

construction period. 
4.11-5 September 2008

Table 4.11-2 Estimated Assessed Value and Annual Taxes, by County 

Assessed Valuation Annual Property Tax 

County 

Initial 

Construction1 Long-term2

Average Tax 

Mill Levy 

Initial 

Construction Long-term 

Rio Blanco, CO $25,500,000 $10,200,000 36.465 $371,943 $148,777 

Moffat, CO $42,500,000 $17,000,000 54.040 $918,680 $367,472 

Sweetwater, 

WY 

$37,000,000 $14,800,000 65.081 $963,199 $385,280 

Carbon, WY $4,200,000 $1,680,000 63.228 $106,223 $42,489 

Total $109,200,000 $43,680,000 $2,360,045 $944,018 

1

Initial valuations based on 11.5 percent assessment rate in Wyoming and 29 percent in Colorado. 

2

Assumes assessed valuation at 40 percent of construction cost after the pipeline has been operational for several years and is 

centrally assessed based on its contribution to annual corporate income. 

Source: Colorado Department of Local Affairs 2006; Wyoming Department of Revenue 2008. 

In addition, local Project-specific purchases for materials would be made. OPPC estimates that local 

purchases made by personnel associated with the construction of the proposed Project would primarily include 

consumables, fuel, and miscellaneous construction-related materials (e.g., office supplies). 

The economic stimulus provided by the proposed Project would result in temporary secondary impacts on 

employment as local establishments add staff or increase hours worked by existing staff to accommodate the 

increases in demand. Long-term construction projects typically generate between 0.7 and 1.1 additional jobs 

for each direct job associated with the proposed Project. However, given the temporary and rapidly moving 

pace of the proposed Project, the secondary impacts would be expected to be on the order of approximately 

0.35 jobs. 

Of greater significance to state and local revenues would be the sales or use taxes on pipe and other materials 

and installed equipment associated with the proposed Project. Such purchases are subject to sales tax if the 

items are manufactured in-state, or use tax when purchased outside the respective states and imported into 

the state. Typically, project owners and contractors are entitled to a credit for taxes paid in another jurisdiction 

(e.g., the point of purchase or manufacture), but generally have an option to specify the point of delivery as the 

location for purposes of taxation. Sweetwater and Carbon counties impose a use tax, as does Rio Blanco 

County. Moffat County does not impose a use tax. OPPC estimated sales/use tax obligation, based on current 

tax rates and assuming it exercises the option for local taxation, is $12.5 million in Wyoming and $20.6 million 

in Colorado. In Wyoming approximately 80 percent of the total would accrue to the state, the remainder 

distributed among the counties based on the value of installed materials and equipment. The distribution in 

Colorado would be approximately 75 percent to the state and 25 percent to Rio Blanco County. 

OPPC estimates total labor costs of $54 million during construction (approximately one-third in Wyoming and 

two-thirds in Colorado). Individual workers who are Colorado residents, or who work in Colorado on a 

temporary basis would incur an income tax liability on those earnings. This would temporarily increase the tax 

revenue for the state, although the increase would be relatively small. 

Long-term income associated with OPPC operations would be negligible due to the limited direct employment 

impact, although additional income may be realized by contractors servicing the pipeline. 
4.11-6 September 2008 

Property Values

The potential effect that a pipeline easement may have on private property values or property income is an 

issue that would be negotiated between the parties during the easement acquisition process. The easement 

acquisition process is designed to compensate a landowner for the right to use the property for pipeline 

construction and operation. The impact a pipeline may have on the value of a tract of land depends on many 

factors, including the size of the tract, the values of adjacent properties, the presence of other utilities, the 

current value of the land, and the current land use. Construction of the proposed pipeline would not change the 

general use of the land, but would preclude construction of aboveground structures on the permanent ROW 

and might interfere with other current uses (e.g., irrigation and raising crops) on a short-term or long-term 

basis, or the loss of non-renewable resources, or destruction of other improvements such as fences. Special 

permits would be obtained as needed for pipeline ROW through town, state, or federal lands. 

Prior to initiating any construction activities on non-federal lands, OPPC would pursue an easement to convey 

ROW from the landowner to the pipeline company. The easement negotiations between OPPC and the 

landowner also would include compensation for loss of use during construction, loss of non-renewable or other 

resources, damage done to property during construction, and allowable uses of the ROW after construction. 

If an easement could not be negotiated with the landowner, the property could be condemned. In this case, the 

property owner would still be compensated by OPPC, but the amount of compensation would be determined 

by the courts. OPPC has stated that they would make every effort to negotiate in good faith to avoid using this 

authority and would condemn only as a last resort. There are a number of options available, short of eminent 

domain, to secure the property: 

• Negotiate to buy the land; 

• Negotiate to lease the land; or 

• Negotiate a “restrictive easement” arrangement with the landowner. 

OPPC is currently working to obtain the necessary easements for the proposed facilities. Through negotiations 

with landowners, OPPC would be able to make minor route adjustments to accommodate landowner needs 

and requirements as long as those changes would not affect any environmentally sensitive areas, or affect 

other landowners without their approval. 

Conclusion 

OPPC would be required to pay property and ad valorem taxes to the state governments of Wyoming and 

Colorado. The states would then distribute those payments to counties based upon the number of miles 

crossed by the proposed pipeline route in each county. Additionally, the proposed Project would provide 

monetary benefits to local governments by generating payroll and sales taxes. 

4.11.1.4 Environmental Justice 

Issues 

• Potential for disproportionate impacts on low-income or minority populations 

Analysis 

The proposed pipeline route effectively bypasses all concentrations or clusters of residential and commercial 

development and, for the most part, is located on public lands and collocated with other utilities. Furthermore, 

no residential or commercial displacements are anticipated. Thus, the potential for adverse impacts on 

minorities or low-income populations, much less disproportionate impacts, is remote. 
4.11-7 September 2008

Conclusion 

The proposed Project would be expected to create economic benefits for local communities, regardless of 

race, by generating employment opportunities and local expenditures by workers. Completion of the proposed 

Project also would result in an increase of state and local property tax revenues that would benefit local 

communities. 

4.11.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. As a result, the associated 

socioeconomic impacts (including beneficial impacts) would not occur. 

4.11.3 GRP Land Re-route Alternative 

Impacts to socioeconomics associated with the GRP Land Re-route Alternative would be the same as those 

described for the Proposed Action. The alternative route would be approximately 1.1 miles to the west of the 

proposed route and would remain entirely within Moffat County, Colorado. There would be no additional 

access roads, pumps, or pump stations constructed along the alternative route. Therefore, no additional 

workforce would be needed for construction or operation of the pipeline, and there would be no additional 

impacts to access roads used during construction. 
4.12-1 September 2008

4.12 Public Health and Safety 

4.12.1 Proposed Action 

4.12.1.1 Hazardous Materials and Wastes 

Construction Phase

Issues 

• Storage and handling of hazardous materials 

• Previously contaminated sites 

Analysis 

OPPC would dispose of construction wastes in accordance with the OPPC Hazardous Materials Management 

and Spill Prevention, Containment, and Countermeasures Plan. Construction debris would not be placed in or 

adjacent to waterways and construction trash would be removed from the ROW each day. OPPC would 

comply with applicable state and local waste disposal, sanitary sewer, or septic system regulations. 

Soil contamination along the proposed pipeline route may result from at least two sources: material spills 

during construction and trench excavation through pre-existing contaminated areas. A variety of potentially 

hazardous chemicals associated with equipment operation, welding, and coating of pipe would be used during 

construction. Impacts from spills typically would be minor because of the low frequency and volumes of these 

occurrences. 

Pipeline construction would necessitate the storage and use of vehicle and equipment fuels, lubricants, and 

hazardous materials. The Hazardous Materials Management and Spill Prevention, Containment, and 

Countermeasures Plan addresses procedures to ensure the proper handling and storage of these materials. 

The plan also addresses inadvertent spills resulting from construction of the pipeline and lists federal and state 

emergency notification personnel that would be contacted in the unlikely event the proposed Project 

encounters previously unidentified contamination. Should a spill occur, OPPC would clean it up in accordance 

with the Hazardous Materials Management and Spill Prevention, Containment, and Countermeasures Plan. 

The proposed pipeline would not intercept any known areas of soil or groundwater contamination. A review of 

USEPA Region 8 Superfund Site Status Summaries for Wyoming and Colorado as well as the CERCLIS 

database shows no Superfund sites intersected by the proposed pipeline route (USEPA 2006). OPPC would 

cross waterbodies located in Wyoming and Colorado (Appendix A) using the conventional open-cut method 

and HDD, adhering to the measures contained in its Environmental Protection Plan. These measures include, 

but are not limited to, installing and maintaining sediment barriers to prevent silt-laden water from entering 

wetlands and waterbodies, restoring original contours, and revegetating disturbed areas. The proposed Project 

would cross the White River, Yampa River, and Little Snake River using the HDD method. 

The proposed Project could cross areas where groundwater quality has been impacted, but which were not 

identified in the regulatory review or which are not otherwise known. Because excavations associated with the 

proposed Project would be generally less than 10 feet deep, the potential to encounter groundwater in the 

pipeline trench is low, except where the pipeline crosses or approaches surface water bodies. Therefore, the 

potential to encounter pre-existing contaminated groundwater is low. 

If contaminated or suspect soils (e.g., hydrocarbon contamination) were identified during trenching operations, 

OPPC would suspend work in the area of the suspected contamination until the type and extent of the 
4.12-2 September 2008 

contamination was determined. The type and extent of contamination; the responsible party; and local, state, 

and federal regulations would determine the appropriate cleanup method(s) for these areas. 

Conclusion 

Contamination from spills or leaks of fuels, lubricants, coolants, and solvents from construction equipment 

could occur, but the impacts typically would be minor due to the low frequency and volumes of these 

occurrences. There are currently no known contaminated sites crossed by the proposed pipeline route or 

affected by aboveground facilities. If spills or unanticipated contaminated soils were encountered, OPPC would 

address the issue by adhering to the procedures identified in the Hazardous Materials Management and Spill 

Prevention, Containment, and Countermeasures Plan. 

Operation Phase

Issues 

• Potential for pipeline leak, fire, or explosion 

Analysis 

Potential for Leaks

The transportation of NGL by pipeline involves some risk to the public in the event of an accident and 

subsequent release of NGL. NGL consists primarily of ethane, butane, isobutene, and propane. These 

compounds are liquid when pressurized, but would immediately volatize if released from the pipeline. These 

compounds are relatively non-toxic, but are classified as simple asphyxiates, possessing a slight inhalation 

hazard. If inhaled in high concentrations, oxygen deficiency can result in serious injury or death. NGL are 

highly flammable but require an ignition source to ignite. NGL released into the environment would rapidly 

disperse in the air. 

The USDOT classifies NGL as a hazardous liquid. The pipeline and aboveground facilities associated with the 

pipeline must be designed, constructed, operated, and maintained in accordance with the USDOT Minimum 

Federal Safety Standards in 49 CFR Part 195. The regulations are intended to ensure adequate protection for 

the public and to prevent pipeline and facility accidents and failures. Part 195 specifies material selection and 

qualification, minimum design requirements, and protection from internal, external, and atmospheric corrosion. 

OPPC would design, construct, and operate the pipeline in accordance to federal regulations. Important 

features to ensure the safe operation of the pipeline include: 

• Hydrostatic testing to verify the pipeline’s integrity prior to operations; 

• Corrosion protection by using high integrity FBE coating and cathodic protection; 

• At least 1 pig launcher and receiver would be constructed for inspection of the pipe designed to detect 

irregularities on the internal and external surfaces of the pipe; 

• A meter station located at the origination of the pipeline to continuously monitor the pipeline and the 

pressure of its contents; 

• Participation in state “one call” programs; and 

• Use of block valves at key locations as required and as needed for use in maintenance and 

emergency services. 

Based on historical accident data gathered by the Office of Pipeline Safety (OPS) from 1987 to 2006, the 

leading causes of pipeline incidents are by outside forces, primarily the damage caused by mechanical 
4.12-3 September 2008

equipment, such as bulldozers and backhoes (Pipeline and Hazardous Material Safety Administration 

[PHMSA] 2008). To minimize the hazards posed by outside forces, the pipeline would be constructed in rural 

areas and OPPC would participate in the “one call” system. Although some localized areas of geological 

instability (e.g., landslides) occur along the proposed pipeline route, modern pipelines are fairly robust to these 

types of stressors and geological hazards are not expected to pose a major threat to the pipeline. The pipeline 

routinely would be inspected and if outside force damage were suspected (whether through outside force or 

ground movement), internal inspection tools (i.e., launcher pigs and receiver pigs) would be used to verify the 

pipeline integrity. 

Corrosion is another major factor that contributes to pipeline leaks. To minimize corrosion, the pipeline would 

be constructed with FBE coated pipe and cathodic protection would be installed. As required by federal 

regulations, the pipeline ROW would be routinely inspected with internal inspection tools to identify anomalies 

such as dents and scrapes caused by outside forces, deformities caused by earth movement, and internal and 

external corrosion. OPPC would ensure pipeline integrity and public safety by repairing pipeline damage as 

required by federal regulations. 

OPPC would use Supervisory Control and Data Acquisition and other monitoring systems to continuously 

monitor the pipeline for indications of abnormal events. In the unlikely event of a pipeline accident, OPPC 

would be able to remotely activate its motorized block valves, thereby isolating the affected segment within 

minutes of detection. OPPC would have local personnel available to respond immediately to an emergency 

and expects that these first responders would be on-site within a 1-hour timeframe. 

Prior to operating the pipeline, OPPC would develop an Emergency Response Plan that identifies emergency 

personnel and the logical sequence of actions that would be taken in the event of an emergency involving the 

OPPC system facilities. The Emergency Response Plan would establish emergency shutdown procedures, 

communication coordination, and clean-up responsibility to minimize hazards that could result from a NGL 

pipeline emergency, such as liquid leaks, explosions, and fires. Key elements of the plan would include 

procedures for: 

• Receiving, identifying, and classifying emergency events, gas leakage, fires, explosions, and natural 

disasters; 

• Establishing and maintaining communications with local fire, police, and public officials, and 

coordinating emergency response; 

• Emergency shutdown of systems and safe restoration of service; 

• Making personnel, equipment, tools, and materials available at the scene of an emergency; and 

• Protecting people first and then property, and making them safe from actual or potential hazards. 

The Emergency Response Plan would include incident and emergency notification lists; emergency 

communication procedures; emergency preparedness, such as training topics; and emergency response 

procedures associated with natural and construction-related hazards. 

OPPC has committed to enhance public safety at locations where existing cities and multiple homes are within 

500 feet of the proposed pipeline. Table 4.12-1 lists all structures currently identified within 500 feet of the 

proposed pipeline centerline. Upon obtaining the necessary permits for the proposed Project, finalizing the 

proposed pipeline route, and prior to construction, OPPC would determine if its proposed pipeline could affect 

these locations. If appropriate, these locations would be incorporated into an Integrity Management Plan

specific to OPPC as required by the USDOT to ensure pipeline safety. 
4.12-4 September 2008 

Table 4.12-1 Inhabited Residences and Commercial Buildings within 500 feet of the Proposed 

Pipeline 

Location1 MP Distance/Direction 

Guardhouse 0.46 100 feet east 

Compressor Station 5.45 400 feet west 

Residence 19.51 400 feet west 

Unidentified 26.84 450 feet west 

Unidentified 27.41 500 feet east 

Unidentified 28.05 500 feet east 

3 cabins 34.46 300 – 400 feet east 

Unidentified 38.96 100 feet east 

Compressor Station 107.88 200 feet west 

Compressor 110.41 200 feet west 

1

Structures called out as "unidentified" can be seen on aerial maps but do not exhibit the characteristics of regular habitation. Those 

locations would be ground verified for habitation following finalization of the proposed pipeline route. 

Fire, Explosion, Injuries, and Fatalities

As discussed in the Environmental Protection Plan, release of NGL into the environment does not pose a 

major threat to water quality or soil contamination. While the probability of an accident is low, there would be 

the potential for a fire if an accident resulted in the release of NGL from the pipeline. Based on OPS historical 

data (PHMSA 2008), less than 20 percent of NGL pipeline accidents have resulted in fires and 7 percent have 

resulted in explosions. Fires and explosions could result in property damage, injuries, and fatalities. The OPS 

data show an overall decreasing trend in the total number of significant accidents related to hazardous liquid 

pipelines since the early 1990s (PHMSA 2008). 

As part of its safety program, OPPC would consult with local responders regarding the potential hazards posed 

by the NGL pipeline; however, NGL do not pose a unique fire hazard and would not require specialized 

training. If a fire or explosion were to occur, OPPC local emergency responders and local fire departments 

likely would be among the first to respond. In many cases, firefighters may elect to allow the fire to extinguish 

itself, focusing on containment of the fire and protection of nearby property. 

Conclusion 

OPPC would comply with all federal pipeline safety regulations, including 49 CFR Part 195 and 43 CFR 

2886.10. Compliance with federal pipeline safety regulations would ensure that the OPPC pipeline was 

designed, constructed, operated, and maintained in a safe manner. 

The potential for a pipeline incident causing injuries, fires, and explosions along the pipeline would be low. The 

OPPC accident prevention program includes participation in one-call programs and corrosion protection 

measures. Use of monitoring systems would help to rapidly identify pipeline problems and minimize the 

potential for impacts. OPPC would finalize their Emergency Response Plan prior to operations. This 

Emergency Response Plan would define the steps to be taken in the event of a release, so that impacts to 

humans and the environment would be minimized. Additional mitigation at sensitive resource areas would not 

be necessary because of the rapid volatilization of NGL. 
4.12-5 September 2008

4.12.1.2 Emergency Response 

Construction Phase

Issues 

• Worker safety 

Analysis 

The hazards associated with pipeline construction would be typical of that on most construction sites where 

heavy equipment is operated. Hazards could include driving hazards (including winter conditions and big game 

collisions), explosives, fires, and natural disasters. Although accidents occasionally occur, most do not result in 

fatalities. As discussed earlier, third-party excavation damage is a leading cause of pipeline incidents. To 

prevent these types of accidents, pipeline operators participate in accident prevention programs, such as the 

one call programs, which identifies the location of underground utilities. To minimize risk to workers, OPPC 

would follow pipeline construction industry standard practices and BMPs to mitigate potential constructionrelated incidents. 

Conclusion 

Adherence to the environmental protection measures outlined in the POD (CH2M Hill Trigon, Inc. 2008), 

pipeline construction industry standard practices, and BMPs would minimize potential construction-related 

incidents. 

Operation Phase

Issues 

• Emergency response to a pipeline leak, fire, or explosion 

Analysis 

OPPC would meet or exceed federal pipeline safety requirements (49 CFR Part 195), and these procedures 

and programs would ensure public safety, maintain the integrity of the pipeline, and minimize the potential 

pipeline incidents related to third-party encroachments. 

As discussed above, the OPPC Emergency Response Plan would establish initial written emergency 

shutdown procedures, communication coordination, and clean-up responsibility to minimize hazards, such as 

liquid leaks, explosions, and fires. OPPC would provide the appropriate training to local emergency service 

personnel before the pipeline were placed in service. 

Once the pipeline was constructed and pipeline operations commence, OPPC would re-define its 

organizational management structure outlined in the Emergency Response Plan and amend the plan so that it 

would meet the minimum federal safety requirements. 

Conclusion 

OPPC anticipates a 1-hour response time in most instances with the assistance of local emergency response 

teams in the surrounding communities. Releases would be quickly contained by sectionalized block valves. 

NGL would quickly evaporate and dissipate into the atmosphere; however, any residual material would be 

cleaned up and the area remediated as soon as possible. The final Emergency Response Plan would identify 

the steps to be taken to protect health, property, and the environment. 
4.12-6 September 2008 

4.12.2 No Action Alternative 

Under the No Action Alternative, the proposed Project would not be constructed. Impacts to public safety 

would continue at current levels. 

4.12.3 GRP Land Re-route Alternative 

Impacts to public health and safety associated with the GRP Land Re-route Alternative would be the same as 

those described for the Proposed Action. The GRP Land Re-route Alternative would be approximately 

1.3 miles longer than the Proposed Action but would not require additional pumps or pump stations to be 

constructed.