1-1 September 2008

1.0 Introduction 

On June 20, 2007, Overland Pass Pipeline Company (OPPC), a subsidiary of ONEOK, Inc. and Williams Field 

Service Company, LLC (Williams), filed an application with the Bureau of Land Management (BLM) to 

construct, own, and operate a 152-mile-long, 14-inch-diameter, buried steel natural gas liquids (NGL) pipeline 

and related facilities that would connect NGL production from the Piceance Basin in Colorado to the OPPC 

Overland Pass Pipeline in southern Wyoming. 

The proposed Overland Pass Pipeline Piceance Basin Lateral NGL Project (Project) would include a 

2,000-foot, 6-inch-diameter lateral, manual shut-off valves at regular intervals, pigging facilities, and 2 meter 

stations. Figure 1.1-1 depicts the Project location. The pipeline would transport a total of 100,000 barrels of 

Y-grade NGL per day. Initially, 20,000 to 30,000 barrels per day (bpd) would be transported; however, the pipe 

would be designed to hold more NGL as the need increases. Should volumes of NGL increase above 

approximately 70,000 bpd, a pump station would be constructed at the approximate midpoint of the pipeline 

route near milepost (MP) 82.4. With the pump station installed, the capacity of the pipeline would be 

100,000 bpd. 

1.1 Purpose and Need for the Proposed Project 

NGL are hydrocarbon liquids associated with the production and processing of natural gas. When natural gas 

is removed from the ground, it is compositionally different than what is transported through natural gas 

transmission systems and ultimately used by the public for such things as home heating and cooking. When 

removed from the ground, the mixture is predominately methane, but also includes heavier hydrocarbons and 

inert gases. Although the mixture can vary greatly, a typical stream may include 85 percent methane, 

10 percent heavier hydrocarbons (NGL), and 5 percent inert gases. The NGL and inert gases must be 

removed to make the natural gas salable and transportable. 

Once removed from the natural gas, the NGL must be transported under pressure by alternate pipelines to 

fractionators. The fractionators separate the NGL into purity products such as ethane, propane, and butane, 

which are used in the petrochemical, petroleum refining, and agricultural industries. Gas processing plants are 

much smaller, simpler facilities than fractionators and are more commonly located very near the natural gas 

drilling areas. Fractionators, on the other hand, are very complex facilities that are located in areas of the 

country with ready access to delivery markets and, typically, underground storage facilities. 

As natural gas production increases typical NGL production also increases. Increased drilling activity and 

natural gas production in the Rocky Mountain region, and particularly in the Piceance Basin, are creating a 

corresponding increase in the amount of NGL that need to be carried out of the area to existing fractionators in 

the Midwest and Gulf Coast regions. An underground NGL pipeline located largely in existing pipeline 

rights-of-way (ROWs) would have considerable environmental and safety advantages over alternative means 

of transporting NGL out of the Piceance Basin, such as trucking or rail transport. Currently, existing NGL 

pipelines are operating at or near capacity. The proposed Project would address the needs of producers in 

Colorado by providing additional NGL pipeline capacity out of the Piceance Basin to fractionation facilities in 

Bushton and Conway, Kansas. Downstream customers would thereby gain access to the Piceance Basin 

supply. In summary, approval of the Project would meet the mutual needs of producers and downstream 

customers, and would further federal policy regarding the development of pipeline infrastructure in the Rocky 

Mountain region. 

In addition to being necessary, the removal of NGL from the natural gas stream also can enhance the value of 

the components removed. Although only 10 percent of the stream by weight, the NGL can contribute 

approximately 15 percent of the energy of the stream. 
MP 5

MP 95

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Moffat

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Wyoming

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Piceance Creek

Dry Fork

Piceance Creek

Yampa River

Yampa River

Spring Creek

White River

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Sand Creek

CO UT

WY

Figure 1.1-1

Project Location Map

0 4 8 16

Scale in Miles

Overland Pass Pipeline 

Piceance Basin Lateral EA

City or Town

Milepost

Proposed Pipeline

Named Streams and Rivers

Interstate Highway

Other Highways

Other Roads

County Boundary

State Boundary

1-2
1-3 September 2008

Since NGL must be removed up to a certain level and are often removed in greater quantities for economic 

purposes, regional NGL production quantities track with regional natural gas production quantities. Specifically 

in the Rocky Mountain region of the United States (U.S.), as natural gas production grows, NGL production 

also grows. 

According to the Environmental Assessment (EA) for the Mid-America Pipeline Company, LLC (MAPL) 

Western Expansion Project (BLM 2005), the Rocky Mountain region is a significant contributor to the supply of 

natural gas in the U.S., producing approximately 25 percent of the U.S. natural gas. Natural gas production in 

the Rocky Mountains increased 56 percent between 1999 and 2003. Some experts predict that the Rocky 

Mountain region’s gas production could increase from 3.3 trillion cubic feet per year (tcfy) in 2002 to 4.6 tcfy in 

2010 and 6.3 tcfy in 2025 (U.S. Department of Energy 2004). Notwithstanding the variance in supply 

predictions, industry experts agree that production from the Rocky Mountain region would be critical to serving 

the country’s increasing energy needs. Using typical average NGL content (2 gallons per thousand cubic feet) 

and an average NGL recovery factor (50 percent), this increase in natural gas production would produce a 

substantial increase in NGL that would need to be moved. 

The proposed Project is in the national interest in that it is a major energy facility that would provide significant 

and much needed NGL transmission capacity out of the Piceance Basin to the Overland Pass Pipeline. The 

Project would increase the flexibility and reliability of the interstate NGL grid by offering greater access to NGL 

supply sources and increased availability of NGL for anticipated projects. 

1.2 Relationship to Policies, Plans, and Programs 

The proposed Project would cross federal lands managed by the BLM as well as state lands in Colorado and 

Wyoming. The BLM is the lead federal agency for the Project. The proposed Project would affect public land 

administered by the BLM White River Field Office (WRFO) in Meeker, Colorado; the Little Snake Field Office 

(LSFO) in Craig, Colorado; and the Rawlins Field Office (RFO) in Rawlins, Wyoming. 

Consistent with federal regulations found in 43 Code of Federal Regulations (CFR) 2804.25, the BLM is 

required to complete a National Environmental Policy Act (NEPA) analysis before issuing a ROW grant. Due to 

the nature and scope of the proposed Project, the BLM decided to prepare an EA to assess potential impacts. 

The controlling guidance and source documents for preparation of this EA include: 1) the Council on 

Environmental Quality (CEQ) regulations for implementing NEPA (40 CFR Parts 1500-1508); 2) the BLM 

NEPA Handbook H-1790-1 (BLM 2008); 3) the Resource Management Plans (RMPs) for the three regional 

BLM field offices; and 4) OPPC Plan of Development (POD) (CH2M Hill Trigon, Inc. 2008), which describes 

how and where the Project would be constructed and operated and how the ROW would be reclaimed. 

1.2.1 BLM Authorizing Actions and Conformance to Land Use Plans 

The BLM is responsible for issuing ROW grants across federal lands in accordance with 43 CFR 2880. 

Specifically, 43 CFR 2881.11 requires a BLM ROW grant for any oil or gas pipeline or related facility that 

crosses federal land under BLM jurisdiction or under the jurisdiction of two or more federal agencies. 

Subpart 2884 describes the application filing, content, processing, and decision steps in granting a ROW 

under these regulations. 

The BLM has the authority and responsibility under the Mineral Leasing Act (MLA) of 1920, as amended 

(30 United States Code [USC] Section 185) to grant ROWs for pipelines and is responsible for imposing 

stipulations and regulations, as needed, to protect public safety and the environment. OPPC-committed 

environmental protection measures specific to BLM-administered federal lands are presented in this EA. As 

such, in order to obtain a ROW grant and temporary use authorization from the BLM, OPPC would be subject 

to terms of use that are specific to federal lands managed by BLM. OPPC-committed environmental protection 

measures were based on common pipeline best management practices (BMPs) recently used on other 
1-4 September 2008 

regional pipeline projects, such as the Wyoming Interstate Company, Ltd. (WIC) Piceance Basin Project. 

These measures, where applicable, also would be implemented during construction and operation on private 

lands. 

BLM would prepare a Decision Record (DR) to document its decision to either approve or not approve the 

proposed Project. If approved, any necessary and applicable documentation regarding environmental 

protection measures, additional mitigation measures, or permit conditions required by the BLM would be 

included in the DR. A concurrence letter or Biological Opinion (BO) from the U.S. Fish and Wildlife Service 

(USFWS); and concurrence letters with the proposed treatment of cultural resources from the Wyoming and 

Colorado State Historic Preservation Officers (SHPOs) also would be taken into account when preparing the 

DR. 

The proposed Project and alternatives presented in this EA are consistent with the management decisions in 

the White River RMP (BLM 1997), the Little Snake RMP (BLM 1989), the Oil and Gas Amendment to the Little 

Snake RMP (BLM 1991), and the Rawlins RMP and Final EIS (BLM 2008a). The management goals for oil 

and gas minerals management for the three BLM resource areas as stated in their respective RMPs include: 

• White River RMP – to make federal oil and gas resources available for leasing and development in a 

manner that provides reasonable protection for other resource values. 

• Little Snake RMP – to maximize the availability of the federal oil and gas estate for exploration and 

development, and to facilitate orderly, economic, and environmentally sound exploration and 

development of oil and gas resources using balanced multiple-use management. 

• Rawlins RMP – to manage mineral resources from available BLM-administered public lands and 

federal minerals while minimizing the impacts to the environment, public health and safety, and other 

resource values and uses. 

Additionally, the White River RMP and Rawlins RMP identify existing ROW corridors as the likely location for 

placement and development of new delivery pipelines for oil and gas. The proposed Project generally follows 

these existing ROW corridors. Therefore, development of the proposed Project would be in conformance with 

the management directives identified in the RMPs for oil and gas minerals management and utility ROW 

development. 

1.2.2 Permits and Relationship to Non-federal Policies, Plans, and Programs 

Key federal, state, or local agencies that have permit, approval, or consultation authority for portions of the 

Project are identified in Table 1.2-1. Tribal governments that were consulted under Section 106 of the National 

Historic Preservation Act of 1966 as amended (NHPA) also are included in the table. Individual road crossing 

and road use permits have not been included in this table, since such permits would be a standard 

requirement in all counties crossed. 

Table 1.2-1 Major Permits, Approvals, and Consultations for the Project 

Agency Permit/Approval/Consultations Agency Action 

Federal1

ROW Grant for the pipeline and all 

related facilities located on federal 

land under the authority of the MLA 

Consider issuance of a ROW Grant for 

the portion of the Project on federal 

land. 

BLM 

Temporary Use Permit for temporary 

workspace areas and temporary 

access roads under the authority of 

the MLA 

Consider the issuance of a Temporary 

Use Permit for the portion of the 

Project on federal land. 
1-5 September 2008

Table 1.2-1 Major Permits, Approvals, and Consultations for the Project 

Agency Permit/Approval/Consultations Agency Action 

USFWS Section 7 Consultation under the 

Endangered Species Act (ESA) 

Consider lead agency finding of 

impact on federally listed or proposed 

species. Provide BO if the Project is 

likely to adversely affect federally 

listed or proposed species, or their 

habitats. 

Natural Resource Conservation 

Service (NRCS) Wyoming and 

Colorado 

Consultation Consultation regarding erosion control 

recommendations, revegetation 

specifications, and identification of 

Conservation Reserve Program lands. 

U.S. Army Corps of Engineers 

(USACE) –Sacramento District 

(Colorado) and Omaha District 

(Wyoming) 

Section 404, Clean Water Act (CWA) Consider issuance of Section 404 

permits for working in navigable 

waters of the U.S. and the placement 

of dredge or fill material into all waters 

of the U.S., including wetlands. 

Advisory Council on Historic 

Preservation (ACHP) 

Section 106 Consultation, NHPA Has the opportunity to comment on 

the undertaking. 

Section 401, CWA, Water Quality 

Certification 

In conjunction with states, consider 

issuance of water use and water 

crossing permits. 

Section 402, CWA, National Pollutant 

Discharge Elimination System 

(NPDES) 

In conjunction with states, review and 

issue NPDES permit for discharge of 

hydrostatic test water and discharge of 

groundwater associated with 

construction activities. 

Section 404, CWA (veto power for 

wetland permits issued by the 

USACE) 

Review CWA, Section 404 wetland 

dredge-and-fill applications for the 

USACE with Section 404 veto power 

for permits issued by the USACE. 

U.S. Environmental Protection Agency 

(USEPA) Region 8 

Storm Water Discharge Permit In conjunction with states, review and 

issue storm water permit for activities 

associated with pipeline and 

aboveground facilities construction. 

State - Colorado 

State Listed Species Consultation Review and comment on activities 

potentially affecting listed state 

species. 

Temporary Use Permit Consider issuance of a Temporary 

Use Permit to conduct environmental 

and engineering surveys. 

Colorado Department of Natural 

Resources 

 - Division of Wildlife 

Long-term Use Permit Consider the issuance of a Long-term 

Use Permit for the portion of the 

Project on state land. 

 - State Land Board Trust Land Permit Consider issuance of permit to occupy 

state-owned land. 
1-6 September 2008 

Table 1.2-1 Major Permits, Approvals, and Consultations for the Project 

Agency Permit/Approval/Consultations Agency Action 

Colorado Department of Public Health 

and Environment (CDPHE) 

 - Air Quality Control Division 

Air Pollution Emission Notice Consider issuance of a permit to 

construct with the potential for fugitive 

dust. 

Section 401, CWA, Water Quality 

Certification 

Consider issuance of a permit for 

stream and wetland crossings 

(blanketed under USACE Section 404 

permits). 

Construction Storm Water Discharge 

Permit 

Consider issuance of a permit 

regulating discharge of storm water 

from the construction work area. 

Construction Dewatering Wastewater 

Discharge 

Consider issuance of a permit 

regulating dewatering of groundwater 

from the construction work area. 

 - Division of Water Resources 

 - Water Quality Control Division 

Hydrostatic Test Water Discharge 

Permit 

Consider issuance of a permit 

regulating hydrostatic test water 

discharge, and construction 

dewatering to waters of the state. 

Colorado State Engineers Office Consultation on Surface Water Rights Consider use of surface waters for 

appropriations required for hydrostatic 

testing. 

Colorado Historical Society SHPO Consultation under Section 106 of the 

NHPA 

Review and comment on activities 

potentially affecting cultural resources. 

State - Wyoming 

NPDES Storm Water Permit Program 

- General Permit for Construction 

Storm Water Discharge 

Consider issuance of a permit 

regulating discharge of storm water 

from the construction work area. 

Department of Environmental Quality 

(WDEQ) 

 - Water Quality Division 

Water and Wastewater Program - 

General Permit for Temporary 

Discharge 

Consider issuance of a permit 

regulating temporary discharges of 

wastewaters to surface waters of the 

state associated with hydrostatic 

testing of pipes, tanks, or other similar 

vessels; construction dewatering; 

other. 

Temporary Turbidity Increase Permit Consider issuance of a permit for 

temporary increases in turbidity as a 

result of construction activities. 

 - Watershed Management Section 

Section 401 Certification Consider issuance of a permit for 

stream and wetland crossings 

(blanketed under USACE Section 404 

authorization). 

Wyoming Department of State Parks 

and Cultural Resources 

 - SHPO 

Consultation under Section 106 of the 

NHPA 

Review and comment on activities 

potentially affecting cultural resources. 

 - Wyoming Game and Fish (WGFD) Consultations Consultations regarding listed state 

species. 
1-7 September 2008

Table 1.2-1 Major Permits, Approvals, and Consultations for the Project 

Agency Permit/Approval/Consultations Agency Action 

Tribal Governments

Eastern Shoshone Consultation under Section 106 of the 

NHPA 

Review and comment on activities 

potentially affecting cultural resources. 

Northern Arapaho Consultation under Section 106 of the 

NHPA 

Review and comment on activities 

potentially affecting cultural resources. 

Northern Ute Consultation under Section 106 of the 

NHPA 

Review and comment on activities 

potentially affecting cultural resources. 

Shoshone Bannock Consultation under Section 106 of the 

NHPA 

Review and comment on activities 

potentially affecting cultural resources. 

Southern Ute Consultation under Section 106 of the 

NHPA 

Review and comment on activities 

potentially affecting cultural resources. 

Ute Mountain Ute Consultation under Section 106 of the 

NHPA 

Review and comment on activities 

potentially affecting cultural resources. 

1

Federal agencies also must review the proposed Project for consistency with the following federal Executive Orders (EO): Invasive 

Species (Federal Register [FR] 1999) and Migratory Birds (FR 2001). 

1.3 Scoping and Public Involvement 

Scoping is a process of actively acquiring initial input from the public and other interested federal, state, tribal, 

and local agencies to determine the scope of issues to be addressed. It is used to identify key issues related to 

a proposed project. Information gained during scoping assists the lead agency in identifying potential 

environmental issues, alternatives, and mitigation measures associated with development of the proposed 

Project. The process provides a mechanism for narrowing the scope of issues so that the EA can focus the 

analysis on areas of high interest and concern. 

From February 22 to March 14, 2008, the BLM published a scoping notice on their website describing the 

proposed Project and providing information on deadlines and contact information for comment submittal. The 

BLM also issued a press release on February 26, 2008, which appeared in three local newspapers: the Craig 

Daily Press, the Rio Blanco Herald Times, and the Rawlins Daily Times. Additionally, a postcard was mailed to 

700 parties of interest announcing the proposed Project, providing instructions on how to submit comments, 

and directing the recipients to the BLM website for further information. This postcard was distributed to various 

federal, state, and local agencies; elected officials; tribes; landowners; media outlets and libraries throughout 

the Project area; other non-government agencies; and other individuals that have expressed interest in 

NEPA-related projects in the three BLM field offices. Two scoping comment submittals (e.g., letter, email) were 

received: one letter from a landowner in Sweetwater County, Wyoming, and one from the WGFD. 

An interagency meeting was held on February 27, 2008, in Craig, Colorado, to identify potential issues and key 

concerns along the proposed pipeline route. Attendance to this meeting included representatives from each of 

the three BLM Field Offices (WRFO, LSFO, and RFO), USFWS, USACE, Colorado Division of Wildlife 

(CDOW), and the Colorado State Land Board. The WGFD was invited, but did not attend. 
1-8 September 2008 

1.4 Issues 

Based on comments received during scoping and from various agencies, as well as information gathered from 

the two projects recently constructed in the area (Entrega and WIC Piceance), the following key issues and 

concerns associated with the proposed Project have been identified: 

• Reclamation and revegetation in the existing pipeline corridor; 

− Reclamation, particularly reseeding of the ROW, was conducted at the wrong time of year on WIC 

Piceance and Entrega. Lessons learned from these two projects should be incorporated into the 

proposed reclamation plan. 

− Post-construction monitoring reports should be completed for at least 5 years or until ROW native 

cover is reestablished. 

− Cooperation between all companies in the pipeline corridor should be considered to address 

reclamation of the entire corridor. 

− Wash stations need to be located at access points to control the spread of noxious weeds. 

− Compaction and reclamation of silty soils north of Maybell needs to be addressed. 

− Reestablishment of critical forage species (i.e., bitter brush plant in the Bitter Brush State Wildlife 

Area [SWA]) following construction of the previous two pipelines has not been successful. 

• Impacts to fish habitat, surface water quality, and bank stabilization; 

− Depletions in the Colorado Basin would have downstream native fish implications, particularly 

regarding threatened and endangered fish in the Yampa River. 

− Water bar spacing should be minimal to prevent erosion on steep slopes. 

− New roads are impacting water quality in upland areas. 

• Impacts to threatened, endangered, and special status species and habitat; 

− Within non-block cleared areas in the Rawlins RMP Planning Area, white-tailed prairie dog towns 

that qualify as black-footed ferret habitat need to be mapped and surveyed as necessary. 

− There are at least 6 greater sage-grouse leks within 0.5 mile of the Project in the LSFO. 

− Land bridges and escape ramps need to be used in Big Game Winter Range areas and along 

migration routes. 

− There are historical mountain plover sightings along the Little Snake River. 

− Greater sage-grouse, raptor nesting, big game crucial winter range, mountain plover (potential 

and occupied habitat) would occur along Project and would require seasonal stipulations. 

− Avoid (not transplant) sensitive plant species populations. 

• Impacts to local and regional infrastructure including transportation networks, available housing, and 

emergency services; and 

− Heavy traffic on roads not designed for that use (particularly County Road 5/Piceance Creek 

Road) needs to be addressed. It would be preferred to have no new roads and to have widened 

roads reclaimed back to original width/condition. 

− Civil surveys need to stay on existing roads and trails; if not, personnel need to go out and back 

on foot. 

− Trash left by work crews needs to be cleaned up. 
1-9 September 2008

− There is limited housing supply for construction workers. 

− Availability and impact on emergency services needs to be addressed. 

− Economic impacts to hunters and outfitters needs to be addressed. 

− Cattle guards and fences must be restored after construction. 

• Winter Construction. 

− Snow removal damage to adjacent areas needs to be addressed.