Draft EIS analyzes NPL alternatives

SUBLETTE COUNTY – Six years after the public scoping process, the Normally Pressured Lance (NPL) project proposal and development scenarios are explored in the draft environmental impact statement (DEIS).

The Bureau of Land Management’s (BLM) regional High Desert District Office released the long awaited DEIS on July 7. It analyzes Jonah Energy’s natural-gas development proposal for 3,500 wells adjacent of the existing Jonah Field or Infill, where Jonah Energy is also the majority owner.

In the BLM’s original National Environmental Protection Act (NEPA) process, the 2006 Record of Decision (ROD) allows 3,500 wells from 245 well pads.

Jonah Energy’s “proposed action” seeks a 10-year schedule with 350 directionally drilled wells annually from 24 well pads in about 141,000 acres. The company recently bought out LINN Energy’s holdings, gaining more than 1,200 wells more than 27,000 acres that are 80-percent undeveloped. In 2014, Jonah Energy bought Encana, then the NPL’s major player.

The BLM’s “preferred” Alternative B calls for phased development with varying densities to protect other natural resources while permitting 3,500 wells allowed under the 2006 ROD.

The new DEIS summarizes the proposal and three alternatives including the required “no action” option.

Note: Last year the BLM approved year-round drilling for a Jonah Energy project in the Jonah Infill –a completely separate action from. While this NPL project has year-round restrictions in some areas, it has few in others. It is adjacent to the Jonah Infill.

Encana holdings brought more than 1,600 producing wells on more than 100,000 undeveloped acres. The transactions’ past and future development potential make Jonah Energy LLC by far the most influential operator there.

Jonah Energy estimates 5.25 trillion cubic feet of natural gas lay underground. Above is a wealth of greater sage-grouse winter populations of about 2,000 birds, big-game winter ranges and big-game migration routes.


Other options

  • The BLM’s first option is the required “No Action Alternative.”
  • “Development and production would continue at the rate that has been seen in the Project Area since 1997 – drilling and completion of approximately three new wells and ancillary facilities per year for a 10-year development period,” the DEIS says.
  • Next, Alternative A calls for “three geographically defined phases” developed sequentially over 10.4 years.
  • “Additional resource protection measures and density limitations would be applied in delineated wildlife habitats to protect sensitive wildlife resources,” it says.
  • “The maximum allowable density of development areas (DAs) would be largely driven by the presence or absence of delineated wildlife habitats in a given DA and the expense of those habitats, if present,” it states. “The BLM would apply additional resource protection measures for wildlife species within delineated habitats of DAs where species are considered a focus species.”
  • Phased development in the sage-grouse priority habitat management area (PHMA) would come with three DAs.
  • “Preferred” Alternative B calls for three phased DAs with reduced density in the northwestern NPL “due to the range of resources present in that area … including wildlife resources, visual resources, paleontological resources, surface water features, identified lands with wilderness characteristics and other resources.”

It calls for centralized facilities and buried pipelines from sage-grouse wintering areas and the PHMA to outside gathering facilities.


Looking back

  • In its June 2011 NPL scoping process report, the Pinedale Field Office (PFO) discussed then-owner Encana’s identical proposal.

“Each multi‐well pad would average 18 acres per location,” it states. “The wells, along with associated infrastructure, would be constructed over a 10‐year period at a rate of up to 350 wells per year based on an average of 10 drill rigs working at any one time, or until the resource base is fully developed. Encana predicts an average life of 40 years per well.”

Public comments then involved air quality, cultural and visual resources, wildlife, health and safety, livestock grazing, land use, reclamation, species status, social and economic, wild horses and more.


Air, cultural impacts

In the short term, NPL would disturb about 6,340 new acres in the proposed action, 6,748 in Alternative A and 5,874 in the Alternative B.

“Environmental consequences” show potential problems for the Upper Green River Basin in years 2 through 10 to meet nitrogen oxides emissions limits of 100 tons per year, it states.

Alternative A would have minor net reductions of criteria pollutants due to the slightly longer schedule.

Estimated greenhouse gas emissions (GHG) “would contribute to the regional and global GHGs in the atmosphere, and could contribute to climate change effects,” the DEIS states, adding it isn’t possible now to predict what the actual GHG effects would be for NPL.

“Potential adverse impacts” in the 3-mile viewshed of the historic Sublette Cutoff and North Sublette Meadow Spring Variant trails and within the Teakettle Dune Field would result from proposed and preferred options are “fewer” in Alternative A but “similar” for potential eligible or undiscovered sites.

For all, “appropriate mitigation, agreement documents and other considerations” would

reduce potential impacts, it adds.


Livestock grazing

Under “no action,” livestock grazing would lose 25 animal-unit months (AUM) short-term and long-term, nine AUMs with no forage loss.

Under the proposed action and Alternative A, short-term AUM loss would be 780 and 1,770 respectively and long-term, 232 and 222 respectively. In Alternative B, the number is 727 short-term and 215 long-term AUMs lost.

“Other potential impacts would include reduced forage availability, changes in vegetative composition due to establishment and spread of invasive plants/noxious weeds, potential for collisions with vehicles, decreased forage palatability resulting from fugitive dust, and collisions with vehicles” under the proposed action.

“Noise” holds consequences, especially for greater sage-grouse – “the primary sensitive receptor on the NPL Project Area” – under any scenario except “no action.” The BLM would increase ambient noise monitoring and review new research.

Proposed activity “could exceed the 10 dBa noise increase threshold (if) within distance of the identified noise contours” at lek perimeters. Under Alternative A, noise would be reduced “due to a phased development pattern in Sage-Grouse PHMA, a reduced density of development in sage- grouse winter concentration areas, surface disturbance thresholds in delineated habitats for focus species that overlap or occur in close proximity to leks and other habitat, and prohibition of RGFs and overhead powerlines in certain areas…”

Under Alternative B, pipelines and centralized facilities plus increased monitoring would shift or reduce noise impacts.



The BLM announced July 7 the NPL “could unlock 5.25 trillion cubic feet of natural gas, providing a reliable, long-term energy source for the nation and creating more than 700 full-time jobs and stable employment opportunities for southwestern Wyoming (and) could also create $2.2 billion in royalties, half of which would go to the state of Wyoming.”

The DEIS shows employment and many more breakdowns in Chapter 2 – Alternatives.

Jonah Energy proposes full-time jobs on a year-round basis, depending on project phases. Jonah estimates would have 954 jobs in the first 10 years, with 228 for years 11 through 40.

Alternative A shows about 921 jobs for the first 10 years and 195 for production, “assuming that development and associated jobs (are) 100 percent of the proposed action.”

For Alternative B, “Similar to the proposed action … the existing Jonah Energy workforce facility would be utilized to house workers to the extent possible. Total jobs are the same as the proposed action at 726 positions for the first 10 years and 228 after.



Public meetings will be held Tuesday, July 25, 4:30-7:30 p.m. at the Pinedale Field Office and July 26, 4:30-7:30 p.m. at the BLM High Desert District Office in Rock Springs.

Submit comments through Aug. 21 for the Naturally Pressured Lance (NPL) draft EIS and can be emailed to [email protected].

The DEIS and NEPA documents are available at http://tinyurl.com/hloulms or the Pinedale Field Office.


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