Clark Resource Council: Issues

Responsible Energy Development

National treasure or just another industrial sacrifice zone?

Doing It Right! Wells, pipelines, compressor stations, gas plants, roads, and associated infrastructure need serious forethought to avoid impacts that could destroy the special place we call the Front Range of the Beartooths.

The proposed 75 square mile area currently under consideration for gas development encompasses National Forest (13,440 acres), Bureau of Land Management (14,720 acres), Wyoming State Lands (2,112acres) and Private Land (17,728 acres). With this mix of stewardship and associated responsibilities, communication and planning become critical. The BLM has assumed the role of lead agency in this development process and is being asked by the Clark Resource Council to "do it right."

Split Estate lands (lands where the surface owner doesn't own the underlying mineral interest) are another area where communication between Industry and Residents are critical. The need for good Surface Use Agreements that incorporate Best Management Practices (BMP's) to minimize impact is paramount.

Energy development can have a place along the Beartooth Front, but industry must "do it right" and carefully balance the significant non-energy resources with gas extraction. This process will require: 1) Implementation of "best management practices," 2) Designation of areas for no leasing and "no surface occupancy," and 3) Adherance to key principles.

1. Best Management Practices (BMP's):

Clustered development and directional drilling: Directional drilling accomodates numerous wells on a single pad and recovers gas under sensitive areas without disturbing them. Infrastructure is consolidated dramatically minimizing land disturbance, and associated truck traffic.

Unobtrusive Well Sites: The value of scenic viewshed should be considered when siting well pads and constucting roads. It is no longer acceptable to scrape away the sides of mountains for well pads. Well plans and infrastructure sites should be respectful of the numerous Native American sites, historical sites, and historic trails. Well site equipment and tanks should be painted to blend with the environment.

Surface Protection: The BLM and State of Wyoming should limit post-drilling well-pad size to less than 2 acres, require half-mile setbacks from houses, require reclamation and proper disposal of wastewater. Wastewater and wasteproduct pits must be lined and be sited appropriately, respecting sensitive areas, and not in natural drainages. Pits must be tested for contaminants and closed following guidelines specified by the Wyoming Oil and Gas Conservation Commission. Closed-loop drilling systems, especially those using water-based fluids, minimize the possibility of groundwater contamination Fracing of wells should use only environmentally friendly substances. Flaring of wells should be eliminated where possible. Reclamation should begin within six months of a well site's abandonment with the use of native seed. Original topography should be restored as much as possible.

Private Property Rights. Industry must negotiate with surface owners over the placement of roads, wells, pipelines and compressor stations. Operators should restore the water and soil they damage, and the BLM should give property owners 60 days advance notice of leasing and exploration of the mineral estate under their land.

Air Quality and Noise Standards. Best available control technology (BACT) should be applied to all well operations. Stringent dust-control measures should be pursued, along with industrial processes that reduce emissions of hazardous pollutants.

Watershed Protection. No exploration or development should occur in aquifer recharge zones, on grades exceeding 25 percent, within 1320 ft of riparian areas or when or where soil is saturated.

Monitoring. The BLM, State of Wyoming and USFS should establish a water quality monitoring network around the entire resource area and help fund ongoing wildlife studies. Additionally, stations to monitor ambient air quality should be established throughout the resource area if gas development proceeds.

Wildlife and Habitat Protection. Utility lines should be buried, preferably along roads, rather than cross country. Waste water pits should be covered and fenced to prevent toxic exposure. Pipelines should be utilized by industry to avoid trucking of hydrocarbon products from well sites. Infrastructure should be consolidated in corridors to minimize surface impacts.

Waivers and Exceptions. Exploration, leasing and drilling stipulations, such as seasonal closures and buffer zones around sensitive habitat, will only protect wildlife if they are enforced. These rules should only be waived under rare circumstances and only after industry provides compelling scientific evidence that the waiver is necessary and not harmful to wildlife.

2. Proposed Areas for No Leasing and No Surface Occupancy
The spectacular Beartooth Front has places that deserve the BLM designation of "Areas of Critical Environmental Concern" (ACEC) or the state of Wyoming's designation of "Rare and Uncommon". These designations prevent irreparable damage to important historical, cultural, wildlife or scenic resources. Specific areas worthy of no-drilling/no leasing protection are as follows.

Wyoming State Lands
1. State Section 16 (Resurvey Tract 77) T56N R103 W at the mouth of the Clarks Fork Canyon is situated on both sides of the Clarks Fork River (Wyoming's only Wild and Scenic River), posesses spectacular scenery, is sensitive and crucial elk wintering and calving range, contains a significantly representative population of Wyoming wildlife, is a popular recreational site for fishermen and is the main embarking site for rafters and kayakers. Additionally, the section contains unique geologic features, which are viewed by students from numerous geology educational institutions.

2. State Section 36 T57N R103W lies on both sides of the Park County road leading into the Clark's Fork Canyon and is bisected by Lake Creek. The section is part of the immediate viewshed of the spectacular Clark's Fork Canyon mouth. The historic Nez Perce Trail also crosses this section.

Forest Service Lands
The project area encompasses an 18 square mile (2x9) area of the Shoshone Forest. Extending from the Montana State line south to Bald Ridge, the Forest Sevice land marks the transition from high mountain desert/prairie to treeline and provides a north-south corridor and habitat for many species of Wyoming's wildlife. Two trailheads- Little Rock Creek and Line Creek provide access. Cottonwood riparian habitat characterizes Little Rock Creek, Bennett Creek and Line Creek with their abundant native Cutthroat trout populations and varied wildlife. Fed by winter snowmelt, the headwaters of these creeks reside on the very tops of the Beartooths and flow cold and clear year round. No oil and gas activity should be allowed on Forest Service Lands. The Shoshone Forest is under planning revision.

BLM Lands
Bald Ridge Seasonal Closure Area and Critical Elk and Mule Deer Winter and Calving Range comprises approximately eight sections of land along Bald Ridge. This is a roadless area and is accessible by the Hogan Trailhead beginning at the Hogan Reservoir Recreational Area on its southern border. It is bordered on the north by the Clarks Fork River. The area is also habitat for Mountain Plover, Long Billed Curlew, Sage Grouse, Peregrine Falcon, Bald and Golden Eagles, osprey, grizzlies, black bear, mountain lion, wolves, moose, badger, porcupine, and beaver. Newmeyer Creek , which flows through the area, is a major game corridor for wildlife moving from Sunlight Basin down off of Bald Ridge. Pre-Columbian National Historic Register eligible sites are present in this area This is pristine, scenic country that is valued by recreationists and wildlife and should have a no leasing and no surface occupancy protection.

3. Principles Behind Responsible Energy Development

Observe the mandates of multiple use and sustained yield.
Protect key areas by designating them "areas of critical environmental concern" or "rare and uncommon."
Weigh long-term benefits and costs to the public, against short-term gains to industry.
Consider the cumulative effects of drilling in the region, taking into consideration development on public and private lands.
Environmentally sensitive state-of-the-art management practices should be required to protect water, air and wildlife.

4. Conclusion
Responsible energy development strikes a balance between industry's needs and those of the community and environment. With a commitment to "Do It Right" principles from industry coupled with prudent review and involvement of State and Federal Agencies, the rare and special qualities that Wyoming citizens cherish can be preserved. Our vision accommodates energy development while protecting the area's water, wildlife, air quality, private land values, recreational opportunities and agricultural heritage.