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88066295 


RECORD OF DECISION 


Environmental Impact Statement for the 
Atlantic Rim Natural Gas Field 
Development Project 

Carbon County, Wyoming 


TN 

880.2 
. A52 
2007 


rch 2007 


MISSION STATEMENT 

It is the mission of the Bureau of Land Management to sustain the health, diversity 
and productivity of the public lands for the use and enjoyment of present and 
future generations. 


BLM/WY/PL-07/011+1310 


RECORD OF DECISION 


ENVIRONMENTAL IMPACT STATEMENT FOR THE 
ATLANTIC RIM NATURAL GAS FIELD DEVELOPMENT PROJECT 

CARBON COUNTY, WYOMING 


U.S. Department of the Interior 
Bureau of Land Management 
Wyoming State Office 
Cheyenne, Wyoming 


March 2007 




RECORD OF DECISION 


ENVIRONMENTAL IMPACT STATEMENT FOR THE 
ATLANTIC RIM NATURAL GAS FIELD DEVELOPMENT PROJECT 

CARBON COUNTY, WYOMING 
Table of Contents 

SUMMARY . 1 

DECISION 1 

REASONS FOR THE DECISION 4 

SUMMARY OF PROPOSED ACTION AND ALTERNATIVES 11 

Alternatives Considered in Detail 11 

Proposed Action 11 

Alternative A: No Action 12 

Alternative C: Special Protection of Sensitive Resources 12 

Alternative D: Natural Gas Development with Disturbance Limitations (Agency 
Preferred Alternative) 12 

ALTERNATIVES CONSIDERED AND ELIMINATED FROM DETAILED ANALYSIS... .14 

DEIS Alternatives Not Carried Forward for Final Analysis 14 

OTHER ALTERNATIVES CONSIDERED AND ELIMINATED FROM DETAILED 
ANALYSIS 14 

3,880 Natural Gas Wells from 3,880 Well Locations 14 

Directional Drilling 14 

Produced Water Disposal and Treatment Options 15 

ENVIRONMENTALLY PREFERRED ALTERNATIVE 16 

PLAN, REVIEW, AND APPROVAL PROCESS 16 

PERFORMANCE REQUIREMENTS 21 

PUBLIC INVOLVEMENT 21 

APPEAL PROCESS 22 

ERRATA 23 


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List of Figures 

1. Atlantic Rim Project Location, Carbon County, Wyoming 2 

2. Category A Mitigation Areas 1 3 

3. Atlantic Rim Oil and Gas Development Proposal Submittal — Approval — Implementation 

Process 17 


List of Appendices 

A. Atlantic Rim Natural Gas Project Reclamation Plan 

B. Atlantic Rim Natural Gas Project Performance-Based Monitoring and Best Management 
Practices 

C. Operator-Committed Practices 

D. Formal and Informal Consultation for the Atlantic Rim Natural Gas Field Development 
Project 

E. Summary of Public Comments on the Atlantic Rim Natural Gas Project Final Environmental 
Impact Statement 


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Record of Decision for the Atlantic Rim Natural Gas Project 


RECORD OF DECISION 


Environmental Impact Statement for the 
Atlantic Rim Natural Gas Field Development Project 

Carbon County, Wyoming 


SUMMARY 

This Record of Decision (ROD) documents the Wyoming State Director’s decision to approve 
the preferred alternative as described in the Atlantic Rim Natural Gas Field Development Project 
(ARNG) Final Environmental Impact Statement (FEIS). The ARNG FEIS analyzes various 
options for oil and gas recovery and resource mitigation. The decision emphasizes limiting 
surface disturbance and performing interim reclamation, cooperative air quality monitoring with 
the state of Wyoming, and continued resource monitoring and consultation with federal and 
state agencies. The ROD provides the plan for future management of the federal surface and 
mineral estate in the Atlantic Rim Project Area (ARPA). The ARPA comprises approximately 
270,080 acres, of which 173,672 acres are federal surface estate (64 percent of the ARPA), 
14,060 acres are state surface estate (5 percent), and 82,348 acres are private surface estate 
(31 percent). The Bureau of Land Management (BLM) Rawlins Field Office (RFO) manages 
more mineral estate than surface estate within the ARPA: 179,438 acres federal mineral estate 
(66 percent), 12,384 acres state mineral estate (5 percent), and 78,258 private mineral estates 
(29 percent). Figure 1 shows the location of the ARPA. The findings in the ARNG FEIS and 
decisions of this ROD are based upon an open and collaborative public process. The state of 
Wyoming, Carbon County, individuals, stakeholders, and institutions shared their knowledge 
and insights about the proposed oil and gas field development with the BLM. Public involvement 
was solicited, and the BLM’s analysis of major issues from public comments on the FEIS is 
presented in appendix E. 

The ARNG project is consistent with the President’s National Energy Policy and the Energy 
Policy Act of 2005 by increasing domestic energy supply and helping to reduce the country’s 
dependence on foreign sources of oil and gas. The proposed project is expected to produce 
nearly 1,350 billion cubic feet (BCF) of natural gas, providing enough natural gas to heat 
19.3 million homes for one year and generating approximately $958 million in total taxes and 
royalties. 

DECISION 

The BLM selects Alternative D the agency’s Preferred Alternative with modifications for the 
development of natural gas resources in the ARPA, as described in the FEIS. Modifications to 
Alternative D include use of Performance Goals as described elsewhere in this Decision, and 
the option to consider protective measures described in Alternative C that are not in conflict with 
this Decision. Alternative D involves drilling of approximately 2,000 gas wells within the ARPA 
to recover energy resources, while limiting total new surface disturbance from the drilling 
program across the ARPA (federal, state and fee minerals) to a maximum of 7,600 acres, at any 
given time, and a 6.5-acre/well site short-term (less than 6 years) disturbance goal. The 
estimated number of gas wells is not a cap or limitation, but an approximation to help establish 


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Figure 1. Atlantic Rim Project Location, Carbon County, Wyoming, 2006. 



the surface disturbance limit. The 7,600-acre disturbance cap will be allocated to Operators 
on a prorated mineral leasehold basis. Natural gas development is limited to eight well sites per 
640-acre section, which includes coalbed natural gas (CBNG), conventional, and injection wells. 
Operators may install multiple wellbores (e.g., CBNG, conventional, or injection) on a well site. 


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Operators will be required to initiate reclamation after completion of the drilling activities and 
before the next growing season. During the life of the project (30-50 years), total disturbance 
from natural gas development activities in the ARPA is estimated to be 13,600 acres. This 
includes acres of disturbance from existing wells and infrastructure added to the proposed new 
activities. 

Disturbance acreage will be monitored using geospatial tracking methods. As detailed in 
appendix B, Operators are required to provide the BLM, within 30 days of approval of this ROD, 
a map of existing disturbance associated with activities authorized during the period of time 
when the interim drilling policy was in effect. In addition, “as-built” disturbance will be measured 
and reported and subsequent reclamation efforts will be monitored, documented, and provided 
annually to the BLM RFO Authorized Officer (AO). Adaptive management techniques will be 
used to correct any deficiencies and modify reclamation criteria as is necessary (Reclamation 
Plan, appendix A). When a site attains the interim reclamation vegetation cover and soil 
stability standards detailed in “Criteria for Reclamation Success” in the Reclamation Plan 
(appendix A), the reclaimed acreage will be deducted from an Operator’s disturbance cap 
allocation and additional disturbance on federal lands leased for oil and gas development in the 
ARPA will be permitted by BLM. In the event an Operator reaches its disturbance cap 
allocation, further disturbance on federal minerals will not be permitted. 

Drilling development and reclamation activities in the ARPA will be managed through a 
performance-based, adaptive management process as described in appendix B. The process 
includes a requirement for Operators to submit an annual operating plan to the BLM RFO AO. 
The overall purpose of this process is to meet resource management objectives and ensure 
Performance Goals are achieved to the greatest extent possible. A monitoring and mitigation 
process will be required, and its development will begin within 30 days of the effective date of 
the ROD. This process will be developed by the Review Team (BLM, cooperating and 
interested agencies, and Operators) and will provide quantifiable criteria to identify trends 
associated with the Performance Goals. The process will include the types of mitigation 
responses that will be considered in the event that monitoring data indicate a downward trend 
relative to the Performance Goals. Throughout the life of the project, monitoring data will be 
reviewed to determine if mitigation measures are effective and leading to the achievement of 
reclamation and Performance Goals. The monitoring data will be evaluated on a regular basis 
(at least annually) and best management practices (BMPs), conditions of approval (COAs), 
protective measures, reclamation criteria, and mitigation measures may be modified, as 
appropriate, based on the monitoring results. Target dates for annual plans and reclamation 
reporting may vary as needed and approved by the RFO AO. 

Operators are responsible for demonstrating successful achievement of Performance Goals. 
Eariy efforts are to be made to collect or consolidate resource data to form a baseline against 
which future monitoring efforts and data would be compared to indicate trends. In the absence 
of sufficient data illustrating Operator achievement of Performance Goals, the BLM will use a 
conservative approach when considering additional approvals. 

This decision is not the final review or approval for actions associated with ARNG development. 
The AO will review and consider each component of the project that involves federal lands or 
minerals on a site-specific basis. Other reviews or decision points include, but are not limited to, 
the review of annual or multi-year development plans (including transportation plans), 
Applications for Permit to Drill (APD), right-of-way (ROW) grants, Sundry Notices, or 
applications for Special Use Permits. To avoid duplicative installations, the transportation plan 
is required to include the location and size of power lines. All distribution power lines 12.5 kV or 


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lower will be buried. The appropriate level of environmental review would be conducted prior to 
authorizing any of these applications or permits. 

Consistent with 43 CFR Part 3160, this decision will be in full force and effect commencing with 
the date it is signed by the AO. 

REASONS FOR THE DECISION 

The ARNG EIS was prepared in response to leaseholders’ requests to exercise the terms and 
conditions of their respective oil and gas leases in the project area. The environmental impacts 
of this decision are fully disclosed in the FEIS for the project. The decision to approve natural 
gas development as described by Alternative D with modifications is in conformance with the 
Great Divide Resource Management Plan for the Rawlins Field Office. 

The Performance Goals and Requirements included in this ROD are designed to minimize 
surface disturbance while optimizing natural gas recovery. A performance-based management 
approach is being employed to ensure Performance Goals are achieved to the greatest extent 
possible. These Performance Goals and Requirements, in conjunction with the monitoring and 
mitigation process, will further assure that the intent of the performance-based management 
approach is achieved, and also allow flexibility to achieve these goals at a site-specific level. 
Implementation of this decision will result in production of nationally significant natural gas 
resources consistent with The National Energy Policy (May 2001) and the National Energy 
Policy Act of 2005. The proposed development and activities in Alternative D require 
surface-disturbing activities that are likely to result in major adverse impacts to certain resource 
values, as outlined in the FEIS. While the development is expected to adversely impact certain 
resource values and limit opportunities for other uses in the short-term, the long-term goal is to 
return these lands to a condition approximate to that which existed before developments 
proposed in Alternative D were implemented. 

In reaching this decision, the following key issues, impacts as described in the FEIS, and the 
concerns and comments submitted during the EIS process were considered. Rationale for 
mitigation and actions to address each issue and reduce effects are presented below. 

Surface Disturbance 

The total area and distribution of surface disturbance associated with further development of the 
ARPA affects many resources (e.g., soils, vegetation, wildlife and wildlife habitat, and cultural 
resources). The extent and duration of surface disturbance can adversely affect management of 
these resources. 

• Alternative D limits new, unreclaimed surface disturbance within the ARPA to 
7,600 acres at any time to minimize resource impacts from surface disturbance. 
Disturbance limits encourage development and implementation of state-of-the-art 
technologies for both operational and reclamation activities. 

• Alternative D was developed in response to comments received on the Draft EIS 
(DEIS). The BLM recognized that resource impacts can be reduced by limiting the 
amount of initial disturbance (goal of 6.5 acres/well site) combined with timely 
reclamation. The BLM’s evaluation of exploratory activities that have occurred over 
the past 5 years determined that average initial and long-term disturbance could 
be reduced by approximately 18 percent from the Proposed Action (e.g., 60- vs. 


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80-foot-wide roads) if Alternative D were implemented. While a conservative 
analysis of Alternative D and the Proposed Action indicates similar levels of impacts, 
the reduced initial surface disturbance, reduced disturbance at any time, and lower 
long-term disturbance outlined in Alternative D (See summary table below) provides 
the most practical alternative for mitigating environmental impacts while maximizing 
natural gas recovery (Purpose and Need for the Project). 

• Managing the amount of allowable surface disturbance on a field-wide basis and 
requiring successful interim reclamation in exchange for allowing additional 
disturbance provides a strong incentive for Operators to employ new development 
and reclamation technologies while still reaching their total oil and gas resource 
recovery objectives. Reducing the operational footprint creates less overall 
disturbance, and accelerated reclamation would ensure vegetation is reestablished 
in the shortest time possible. The disturbance management philosophy of limiting the 
number of roads by transportation planning, smaller operational footprints, and 
accelerated reclamation efforts also benefits wildlife by limiting habitat fragmentation, 
reducing habitat loss, and returning habitat function in the shortest possible time. 


Issue 

Proposed 

Action 

Alternative C 

Alternative D 

Disturbance 

Total acres of surface disturbance 

16,400 

13,886 

13,600 

Total acres disturbance at any given 
time 

16,400 

13,886 

7,600 

New long-term surface disturbance 

6,200 

6,200 

5,000 

Livestock Management 

Initial loss - animal unit months (AUMs) 

2,026 

1,703 

1,667 

Loss from dust and weeds (AUMs) 

3,588-5,588 

3,000-6,000 

3,588-5,588 

Temporary non-use permits (AUMs) 

20,000 

5-10,000 

20,000 

Mineral Resource Recovery 

Natural gas (BCF) 

1,350 

87 / 850 / 1.100 1 ’ 2 ' 3 

1,350 


1. Alternative C assumes successful development on federal minerals at 160-acre spacing. IDP data and 
evaluations by petroleum reservoir professionals indicate that economic gas volumes may not be recoverable 
at 160-acre spacing and that 80-acre spacing at the reservoir level is required. 


2. For comparison purposes, gas recovery under Alternative C assumes 670 CBNG wells on federal minerals at 
160-acre spacing with 50 percent of the recovered gas volume compared to 80-acre spacing. Also see Note 
#1 (Max. state/fee minerals: 141 sections x 8 wells per 640-acre section = 1,130 wells; 1,800 CBNG Wells- 
1, 130 state/fee = 670 CBNG well on federal minerals). 

3. Alternative C recovery, tax, and royalties estimates include (1) IDP production only, (2) development on 
state/fee minerals only (1,130 well or 63 percent of the 1,800 CBNG wells included in the Proposed Action), 
and (3) 1,130 wells on state/fee minerals at 80-acre spacing and 670 CBNG wells on federal minerals at 
160-acre spacing. 


• The environmental analysis of Alternative D presented in the FEIS and the decisions 
made in this ROD are based on these disturbance limits applied across the ARPA. 
The BLM has approval authority over actions on federal minerals and lands. When 
evaluating development applications for affected federal minerals and lands, the 


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BLM will consider impacts and surface disturbance that occur on private and/or state 
lands relative to an Operator’s disturbance cap allocation. 

• The review and approval process prior to allowing a federal leaseholder to extract 
federal minerals will be subject to further environmental review. In some instances, 
further National Environmental Policy Act (NEPA) documentation will be prepared. 

In other instances, where certain criteria are met, the action may be categorically 
excluded from the requirements of NEPA and will be approved under the provisions 
of Section 390 of the Energy Policy Act of 2005. In all cases, the action will be 
subject to on-site investigation, cultural reviews, T&E consultation, and 
environmental reviews. In cases where development to access privately owned 
minerals is proposed on private or state lands, and access across public lands is 
requested, the BLM will conduct the appropriate level of NEPA analysis prior to 
granting a ROW. Environmental documents prepared under NEPA will consider 
cumulative impacts that may result from the private actions within the ARPA. Prior to 
approval of all oil-and-gas-related activities in the ARPA, the BLM will consider 
surface-disturbing activities associated with natural gas development that occur on 
private lands and include that information when estimating the acreage towards the 
7,600 acres cap. 

• Surface-disturbance impacts on cultural resources are mitigated through avoidance. 
Where avoidance is not possible, recovery of the cultural resource prior to allowing 
disturbance activities to occur will be considered on a site-specific basis 
(FEIS, appendix I). 

Socioeconomic Effects 

Another issue of concern is the influx of transient workers (those workers not maintaining 
permanent residence) and the ability of local government agencies to address infrastructure 
shortfalls, such as community support facilities, hospitals, medical clinics, emergency services, 
housing, and roads. Gas field employees express the desire to maintain permanent residence 
in the area, but are concerned about continued employment opportunities in the ARPA. Both 
the project proponents and local government agencies have identified potential revenues from 
taxes, royalties, higher employment and increased economic activity, and benefits associated 
with the proposed project to state, county, and local communities. 

• The FEIS contains extensive analysis of potential socioeconomic impacts. To assist 
local government agencies in planning, BLM will provide relevant portions of the 
Operator’s current and multi-year development plans to local government agencies 
to use in their community, county, and state planning efforts. 

Air Quality 

Concerns over potential adverse impacts to air quality from natural gas development and 
production operations were expressed during the EIS process. Specific interest in potential 
emissions from drilling rigs, ozone production, and the amount of dust and other particulate 
matter that might be generated by increased vehicle traffic and other surface-disturbing 
activities was identified. 

Air quality continues to be of concern to Wyoming residents, cooperating agencies, and other 
interested parties. To address these concerns, the BLM, in cooperation with the United States 


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Environmental Protection Agency (USEPA), Wyoming Department of Environmental Quality-Air 
Quality Division (WDEQ-AQD), and United States Department of Agriculture-Forest Service 
(USDA-FS), conducted extensive analyses and reached conclusions as described below. 
Alternative D best addresses air quality concerns by including performance goals and mitigation 
measures. Diligent monitoring of several components that contribute to determining the quality 
of the air is essential. Because monitoring activities are integral to Alternative D, this alternative 
is most likely to ensure that Performance Goals will be met and the effectiveness of mitigation 
and BMPs measured. 

When considered in the context of the state of Wyoming and its other natural gas fields where 
oil and gas development and production activities are more concentrated geographically and 
geologically, adverse impacts associated with implementation of Alternative D are expected to 
be short-term and minor. Any long-term change in air quality or visibility impairment is not likely 
to be significant. 

The following is a summary of air quality analysis efforts and conclusions: 

• Modeling predicts no significant impacts to public health for the air quality pollutants 
modeled. Worker health falls within the purview of the Occupational Safety and 
Health Administration. 

• Potential air quality impacts from the Atlantic Rim project were estimated to be below 
applicable air quality standards. Potential 0 3 concentrations were estimated by the 
Scheffe method, which was considered by the inter-agency air quality team to be a 
reasonable tool and an acceptable ozone estimation method at the time the air 
quality analysis was conducted. 

• WDEQ established an air quality monitoring station near Wamsutter, Wyoming, in 
March 2006 to monitor concentrations of NOx, 0 3 , PM 10 , and S0 2 . In cooperation 
with WDEQ, the Operators will finance and operate additional air quality 
concentration monitoring, including 0 3 monitoring, in the Rawlins Field Office (RFO) 
management area. The BLM will work cooperatively with WDEQ, USEPA, and the 
Operators to maintain and enhance concentration monitoring in the RFO 
management area, including monitoring required to represent impacts due to 
emissions from the Atlantic Rim field. 

• If, in the future, air monitoring were to show 0 3 exceedences that were attributable at 
least in part to sources in the Atlantic Rim field, the BLM would consult with WDEQ 
and USEPA to determine whether adaptive management is needed to mitigate 
impacts. 

Wildlife 

Issues focused on three areas: (1) potential impacts to sensitive wildlife species including fish, 
(2) potential impacts to listed threatened and endangered plant and wildlife species and those 
proposed for listing, and (3) impacts to wildlife habitat including big game crucial winter range 
and sage-grouse nesting and brood rearing habitat. Based on the significance criteria identified 
in section 4 of the FEIS, implementation of the ARNG project may result in adverse effects to 
pronghorn antelope, mule deer, elk, sage-grouse, Columbian sharp-tailed grouse, sagebrush- 
obligate songbirds, roundtail chub, bluehead suckers, and flannelmouth suckers. The overall 
wildlife mitigation strategy for the ARNG project is discussed below. 


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• The Wyoming Game and Fish Department (WGFD) “Recommendations for 
Development of Oil and Gas Resources within Crucial and Important Wildlife 
Habitats” (December 6, 2004) makes some prediction of effects to wildlife 
populations from oil and gas development in Wyoming and provides some mitigation 
measures WGFD believes could reduce these effects. The BLM considered the 
WGFD report and recommendations during development of the FEIS and ROD. 

• To address impacts within the ARPA, this decision implements four strategies as 
evaluated for Alternative D: (1) reduce the initial disturbance footprint as much as 
possible, (2) restore habitat function in the shortest time possible, (3) perform timely 
site reclamation and limit unreclaimed surface disturbance, and (4) institute a 
monitoring and adaptive management process to ensure reclamation and mitigation 
measures are effective and initiate corrective action when it is not. 

• To restore habitat function as soon as possible, this decision implements a 
performance-based management approach that provides an incentive for rapid 
on-site interim and final reclamation while simultaneously allowing maximum 
flexibility in field development. As detailed in the Reclamation Plan (appendix A), the 
Operators will monitor and evaluate reclamation effectiveness and provide annual 
adaptive management recommendations as appropriate to the BLM for 
consideration. 

Threatened and Endangered Species 

Implementation of Alternative D would result in direct loss of habitat from surface disturbance 
associated with the construction of well sites, related facilities, access roads, and pipelines. In 
addition, some wildlife species would be indirectly impacted by displacement from habitats in 
the vicinity of the project area due to the presence of human activities associated with the 
construction and operation of wells. Small portions of potential black-footed ferret habitat may 
be disturbed. The potential for collisions between bald eagles and motor vehicles would also 
increase due to the construction of new roads and increased traffic levels on existing roads. 
The primary source of potential risks to the fish species is an increase in suspended sediments 
and sedimentation from land disturbance associated with project activities. 

• The intensity of these impacts may decrease with the completion of the construction 
phase and with the onset of reclamation efforts on disturbed areas. 

• None of the threatened and endangered species found downstream of the ARPA 
within the Colorado River system are known to occur in the ARPA; therefore, there 
would be no direct impacts to these species. Implementation of all mitigation 
measures for water and soils may reduce potential adverse impacts. No produced 
water from the ARPA would be discharged to the Little Snake River drainage; 
therefore, produced water discharges do not pose a risk to the species there. 

• Any water depletion within the Colorado River system results in a “may affect, likely 
to adversely affect” determination for threatened and endangered species found in 
and along this river. Therefore, the BLM would initiate formal consultation with the 
United States Department of the Interior, Fish and Wildlife Service (USDI-FWS) for 
those species when an applicable proposal is received, and prior to approval. 


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• If any threatened or endangered fish species are identified within the ARPA, the BLM 
would consult with the USDI-FWS and develop a protection plan for the fish when an 
applicable proposal is received, and prior to approval. 

Big Game Crucial Winter Range 

Areas of overlapping big game crucial winter range are important because they provide crucial 
habitat for more than one species of big game. There are several areas of overlapping big 
game crucial winter range located within the ARPA. The combinations of overlapping big game 
crucial winter range include the following: elk/mule deer, 3,038 acres and mule deer/antelope, 
22,637 acres. Forty percent of this habitat occurs on private and state lands where there are no 
protections against disturbance of animals during crucial time periods (See Surface Disturbance 
discussion for a description of surface disturbance management practices that may mitigate the 
impact to this habitat and BLM-sensitive species). 

Wildlife Habitat 

Implementation of the ARPA project would have adverse impact to suitable habitat for many 
wildlife species (e.g., BLM-sensitive species and sagebrush-obligate songbirds). Habitat loss 
was attributed to direct loss through surface disturbance, indirect loss through animal avoidance 
of areas near developments, and habitat fragmentation when habitat is no longer suitable for 
species dependent on intact habitat patches larger than what would be remaining if the project 
were constructed. 

• The FEIS acknowledged that habitat impacts (big game crucial winter range and 
general wildlife habitat) would be significant due to ARPA field development. The 
mitigation strategy for limiting the allowable surface disturbance, accelerated 
reclamation by the Operators, remote monitoring (telemetry), timing stipulations, and 
other BMPs will reduce direct and indirect disturbance to wildlife, facilitating the 
long-term return of habitat function. 

Rangeland and Grazing 

Issues regarding rangeland and grazing that were identified by cooperators, grazing permit 
holders, and other respondents included: direct loss of livestock forage; the potential for a 
reduction in permitted livestock numbers; water quality impairment at existing livestock watering 
sources; livestock movement restrictions/alterations due to pipeline trenches, roads, and fences; 
livestock management problems associated with the inability to access required area two-track 
routes from project-developed roads; vehicle collisions; entrapment in pipeline trenches; and the 
increase in fugitive dust emissions potentially causing dust-induced pneumonia in livestock. 
Alternative D best resolves these issues for the following reasons: 

• Though the project results in the loss of available livestock forage, any loss of animal 
unit months (AUMs) will be determined through rangeland monitoring and, if 
necessary, addressed through the adaptive management process. As discussed in 
the FEIS, other potential impacts (e.g., traffic, roads, and open trenches) on grazing 
operations can be predicted but not accurately quantified at this level of evaluation. 
The BLM assumes that some conflicts may continue to occur or may not be 
completely resolved or mitigated. Solutions to and mitigation of such conflicts will be 
addressed as they arise. 


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• The selected alternative has the lowest level of initial and long-term disturbance and 
corresponding lowest initial loss of AUMs (See table above). 

• The Operators must coordinate annually, or more often as necessary, with affected 
livestock operators to discuss: (1) problems encountered during the past grazing 
season, (2) agreed-upon corrective actions, and (3) planned energy development 
and operations during the next grazing season. The BLM and Wyoming Department 
of Agriculture will participate as appropriate. 

Cultural 

Once implemented, some specific development and operation activities associated with 
Alternative D are likely to result in an adverse effect determination from the Wyoming State 
Historic Preservation Officer (SHPO). The potential for adverse impacts to historic properties, 
such as the Overland Trail and their settings, was identified in the FEIS and considered by the 
BLM. To mitigate these potential adverse effects, the BLM has worked closely with SHPO to 
develop protocols, as described below, to be followed over the course of the project. 

• As prescribed in the Wyoming State Protocol between the Wyoming BLM and the 
SHPO, Memoranda of Agreements (MOAs) are required between SHPO, BLM, the 
proponent, and interested parties as part of the Section 106 of the National Historic 
Preservation Act (NHPA) consultation process when there are anticipated adverse 
effects to historic properties. Given the number of site-specific projects needed to 
implement Alternative D, handling the Section 106 consultation process through one 
programmatic agreement (PA) is preferable to multiple, individual MOAs when 
adverse effect situations are anticipated or multiple consultations when no adverse 
effect situations are expected. 

• The Wyoming State Protocol provides the direction by which BLM will meet its 
responsibilities under Sections 106, 110 (f) and 111 (a) of the NHPA, rather than 
following the procedure set forth in the Advisory Council on Historic Preservation 
(ACHP) regulations (36 CFR part 800). Therefore, the BLM will pursue a 
programmatic agreement for this project prior to commencement of site-specific 
development activities that may result in “adverse” or “no adverse effects” 
determinations. 

Maximize Natural Gas Recovery 

Alternatives in the FEIS were developed to analyze a balance between development well 
spacing to effectively recover natural gas resources and protecting other resource values. 

• To ensure effective recovery of natural gas and maximize protection of other 
resource values, natural gas development, as described for Alternative D with 
modifications, is limited to eight well sites per 640-acre section, which includes 
CBNG, conventional, and injection wells. Operators may install multiple wellbores 
(e.g., CBNG, conventional, or injection) on a well site. No more than 7,600 acres 
(2.8 percent) of the project area will be disturbed by oil and gas development at any 
time. For the overall Atlantic Rim area, there is a 6.5-acre/well site short-term 
disturbance goal. The BLM believes Alternative D provides a good balance between 
oil and gas recovery and resource protection and provides for long-term reclamation 
and re-establishment of native vegetation and wildlife communities. 


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• Alternative C was prepared to evaluate natural gas resource development while 
aggressively mitigating impacts to sensitive resource values using additional 
development protection measures (DPMs). Public comments received on the DEIS, 
results of interim exploration, and technical evaluations by the BLM Reservoir 
Management Group all indicated drilling on 160-acre spacing would not achieve 
maximum recovery of natural gas resources, was likely not economically feasible, 
and was likely an inefficient recovery of the natural gas resource in the ARPA. In 
addition, displacement of disturbance from federal lands to state and fee lands due 
to these aggressive protective measures may result in higher initial disturbance, 
disturbance at any time, and long-term disturbance compared to Alternative D (See 
summary table above), with uneconomical and inefficient natural gas recovery. 

Alternative D increases domestic energy supplies and reduces the United States’ dependence 
on foreign sources of energy, one of the primary goals of the President’s National Energy Policy 
and the National Energy Policy Act of 2005. Development of these federal resources satisfies 
requirements of FLPMA and the Mineral Leasing Act. The leasing and subsequent production 
of federal oil and gas resources provides the United States, the state of Wyoming, and affected 
local counties with income in the form of lease royalty payments. Alternative D best meets the 
goals of the National Energy Policy and achieves the objectives of the federal oil and gas 
leasing program managed by the BLM. The State of Wyoming is satisfied that Alternative D 
meets its goals and objectives for oil and gas development and that it would best contribute to 
the state and local economies. The project will provide 1,350 BCF of natural gas for the 
country, sufficient to heat 19.3 million homes for a year. 

This decision is made in full consideration of the public, local, state, and other federal agency 
input. No substantial issues raised by government agencies, industry, groups, or individuals 
within the scope of this proposal and FEIS remain unresolved. 


SUMMARY OF PROPOSED ACTION AND ALTERNATIVES 

Alternatives Considered in Detail 

The ARNG Project FEIS analyzed four alternatives. They were: 

1 . Proposed Action 

2. Alternative A: No Action 

3. Alternative C: Special Protection of Sensitive Resources 

4. Alternative D: Natural Gas Development with Disturbance Limitations 

(BLM Preferred Alternative) 

Proposed Action 

The Operators proposed to drill and develop up to 2,000 new natural gas wells. Approximately 
1,800 wells would be drilled to coals within the Mesaverde Group to develop CBNG resources. 
An additional 200 wells would be drilled to access conventional natural gas found in other 
formations, generally expected to be deeper than the Mesaverde coals. The 2,000 proposed 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page 1 1 


RECORD OF DECISION 


new natural gas wells would be in addition to the 116 ARPA interim exploration wells already 
drilled during the interim drilling period. 

Proposed well spacing would be 8 well sites per 640-acre section (80-acre spacing) throughout 
the project area, but may be reduced to four well sites per 640-acre section (160-acre spacing) 
depending on the geology and ability of the Operators to recover the gas resource. 
Development and drilling would begin in 2007 and continue for approximately 20 years, with a 
life of project of 30-50 years. Various drilling and production related facilities (e.g., roads, 
pipelines, water wells, disposal wells, compressor stations, and gas processing facilities) would 
also be constructed within the ARPA. 

Alternative A: No Action 

NEPA regulations require that EIS alternative analyses “include the alternative of no action” 
(40 CFR 1502.14(d)). For this analysis, “no action” means that the BLM would reject the 
proponents’ proposal and the proposed activity would not take place. Development activities 
and operations approved under EAs during the interim drilling period would continue as 
approved. 

Alternative C: Special Protection of Sensitive Resources 

Under Alternative C the Operators would be approved to develop natural gas resources from 
the desired target formations but operations would be subject to DPMs in those areas with 
sensitive or crucial resource values (as detailed in FEIS appendix L), likely resulting in fewer 
acres of disturbance and reduced road density on federal lands. Generally DPMs focus on 
surface disturbance limits; selection of facility locations; drilling; construction practices; and, in 
some cases, no surface occupancy. Examples of such areas where DPMs would be applied 
are wildlife and fish habitat and areas with sensitive soils. Geographic information system (GIS) 
layers would be available to Operators for development of site-specific proposals for their 
planning of the annual program. 

Alternative D: Natural Gas Development with Disturbance Limitations 
(Agency Preferred Alternative) 

The goal of this alternative is to minimize surface disturbance while optimizing natural gas 
recovery. Annual planning between the Operators and the BLM would be a key component of 
this alternative. The annual planning would require the Operators to submit to the BLM their 
proposed plan of operation for the forthcoming year. The BLM would then work with the 
Operators at a site-specific level to minimize surface disturbance by applying the appropriate 
lease stipulations, conditions of approval, BMPs, and any other measures deemed necessary to 
minimize surface disturbance and still allow for the recovery of natural gas. 

Coalbed and conventional natural gas resources would be developed, while reclamation 
activities would stabilize disturbed soils and vegetation communities. For the overall ARPA, no 
more than 7,600 acres (2.8 percent) of the project area would be disturbed by oil and gas 
development activities approved under this ROD and unsuccessfully reclaimed at any time. For 
the overall ARPA, there would be a 6.5-acre/well site short-term disturbance goal. Those areas 
designated as “Category A” in the FEIS would have a short-term disturbance goal of less than 
6.5 acres per well pad. Category A, as depicted on figure 2, includes areas with sensitive 
fish populations, crucial wildlife habitats, and unique vegetation communities, and is about 
72,200 acres in extent. 


Page 12 


Record of Decision for the Atlantic Rim Natural Gas Project 


RECORD OF DECISION 


Figure 2. Category A Mitigation Areas. 



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Record of Decision for the Atlantic Rim Natural Gas Project 


Page 13 


RECORD OF DECISION 


ALTERNATIVES CONSIDERED AND ELIMINATED FROM 
DETAILED ANALYSIS 

DEIS Alternatives Not Carried Forward for Final Analysis 

In the DEIS, Alternative B proposed that natural gas development activities would be restricted 
to one of three zones within the ARPA boundary at any one time. Each zone would be open to 
construction and development of natural gas removal and processing facilities for seven years, 
at which time construction and development activities would cease. Gas extraction and 
processing would continue (i.e., operational activities), while construction and development 
activities would move to another zone. The intent of the alternative was to focus disturbance 
activities into a smaller area while the remainder of the project area would be less disturbed and 
less impacted than under the proposed action. 

Major adverse effects were expected under this alternative upon several resources including 
wildlife, soils, and range. Comments received from the companies objected to the extended 
delay on their ability to develop their leases in those areas not open to development activities for 
7 to 14 years. In addition, comments pointed out the implication that BLM would not approve 
ROW proposals for the development of private and state oil and gas development within the 
closed areas. Such an action conflicts with BLM policy (BLM Manual, Part 2800.06 “Policy” (D)) 
to allow owners of non-federal lands surrounded by public lands reasonable access to their 
holdings. A large portion of the project area is located in a so-called “checkerboard” ownership 
pattern of alternating federal and private/state lands where access to such lands requires 
federal ROW approval. 

Alternative B was eliminated from further detailed study in the FEIS based on comments 
received on the DEIS, the effects of long delays to allowable oil and gas development on 
leaseholders and mineral rights, and the policy that the BLM will allow reasonable access 
across federal lands for mineral development on private and state lands. 

OTHER ALTERNATIVES CONSIDERED AND ELIMINATED 
FROM DETAILED ANALYSIS 

Three alternatives were considered and eliminated from detailed study. The alternatives and 
the reasons for eliminating them are described below. 

3,880 Natural Gas Wells from 3,880 Well Locations 

During the scoping process, the Operators estimated that a maximum of 3,880 gas wells from 
3,880 well locations would be required to fully develop the ARPA. Based on the exploration and 
development activities permitted between 2001 and 2006, the Operators have revised their 
original estimate of needing 3,880 gas wells to maximize the economic recovery of the natural 
gas resource to the current proposed number of wells. 

Directional Drilling 

Mandatory use of directional drilling was suggested in comments during the scoping process as 
a way to reduce habitat loss and wildlife disturbance by reducing the numbers of well pads and 
corresponding roads, pipelines, and infrastructure. In memoranda dated June 2005 and 
August 2006, the Reservoir Management Group of the Wyoming BLM stated that extensive 


Page 14 


Record of Decision for the Atlantic Rim Natural Gas Project 


RECORD OF DECISION 


directional drilling did not appear to be a viable technical or economic alternative for natural gas 
extraction in the ARPA. 

Requiring the Operators to use directional drilling for all wells regardless of surface conditions, 
topography, or subsurface geology would not be reasonable. Using such a technique without 
regard for local conditions may deter or preclude an Operator from maximizing the recovery of 
the gas resource in the most economical and efficient manner. However, directional drilling is 
an option that can be considered by the BLM and the Operators where surface conditions and 
resource constraints make it reasonable to consider. 

Produced Water Disposal and Treatment Options 

The Operators proposed re-injecting wastewater produced during development and operation of 
each gas well. Some of the produced water would be discharged in regulated tanks for use by 
wildlife and livestock. Several alternatives to re-injecting water were considered: 

• Water treatment with discharge onto land surface, 

• Surface discharge without treatment, 

• Storage in evaporation/infiltration ponds, and 

• Transmission of produced water by pipeline from the Colorado River watershed to 
either the Great Divide Basin or North Platte River watershed with discharge onto 
land surfaces. 

Produced wastewater has varying concentrations of minerals and salts, and usually needs 
treatment to make it usable or to meet water quality standards. For example, under a policy 
adopted on October 30, 2002, by the Colorado River Basin Salinity Control Forum, entitled 
"Policy for Implementation of Colorado River Salinity Standards through the NPDES Permit 
Program 1," water discharged within the watershed must not add more than 1 ton per day or 
366 tons per year of salts to the Colorado River system. The preferred method of disposal 
would be re-injecting the produced water back into other geologic formations adjacent to or near 
the producing formation in places where the local geology lends itself to this method. Other 
methods of disposal, especially when the wastewater must be treated, transported, or both, tend 
to be more costly and might have inherent logistical and engineering problems. For these 
reasons, other wastewater disposal alternatives were eliminated from detailed study. 

The Proposed Action includes re-injection of produced water, with the exception of limited 
closed water discharge into regulated troughs or tanks for livestock and wildlife drinking water, 
and a limited surface discharge under existing state of Wyoming permits. Re-injection of 
produced water removes the water from coal seams and places it into geologic formations as 
permitted by the state of Wyoming. Re-injection avoids surface impacts from the produced 
water including erosion, changes to vegetation communities, and salinity issues relating to water 
release within the Colorado River Basin. Additional uses of ARPA-produced water, while not 
identified or proposed at this time, may develop or arise in the future. When and if such 
proposals are made, state of Wyoming approval under the state’s various permitting authorities 
would be required. In addition, the BLM would review and approve or disapprove any such 
proposal based on the specifics of the proposal and the BLM’s authorities and responsibilities 
under NEPA and FLPMA. 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page 15 


RECORD OF DECISION 


ENVIRONMENTALLY PREFERRED ALTERNATIVE 

In accordance with Council on Environmental Quality (CEQ) regulations (40 CFR 1505.2(b)), 
the environmentally preferred alternative must be identified in the ROD. BLM considers the 
environmentally preferred alternative for the ARNG Development Project to be the No Action 
Alternative, Alternative A. This alternative would result in the least amount of impact to a 
majority of resources within the ARPA. However, the No Action Alternative would also fail to 
effectively recover known oil and gas resources. 

Comments from gas development companies suggest that the effect of Alternative C was the 
same as the No Action Alternative. The goal for Alternative C is to protect wildlife and other 
natural resources while allowing for the extraction of natural gas resources. Under 
Alternative C, the Operators’ activities would be subject to resource development and protection 
measures intended to maintain or enhance resource values. Approximately 95 percent of the 
federal lands within the project area would be assigned one or more resource protection 
measures to be applied based on the site-specific locations of the activity. Comments from gas 
development companies highlighted the cost of implementing resource protection measures and 
the infeasibility of recovering natural gas resources at four well sites per section. Comments 
received from the BLM's Reservoir Management Group indicated that maximum recovery of 
natural gas resources was not feasible under Alternative C, resulting in the alternative not being 
responsive to the Purpose and Need for Action for this project. In addition, Alternative C 
predicted significant effects on natural resources within the ARPA including big game, greater 
sage-grouse, and recreation. Due in part to the adverse effects to natural resources from 
Alternative C, the BLM’s Environmentally Preferred Alternative is the No Action Alternative. 
However, the No Action Alternative would also fail to effectively recover known oil and gas 
resources. Therefore, the Agency Preferred Alternative was selected. 

PLAN, REVIEW, AND APPROVAL PROCESS 

The planning, review, and approval process for project implementation is described below. This 
process will typically be initiated by the Operators through an annual planning meeting with the 
Rawlins Field Office Manager, where they will outline detailed development plans for the 
upcoming year and a conceptual multi-year plan. The BLM (including interdisciplinary team 
members), cooperating and interested agencies, and the Operators will make up a Review 
Team to evaluate annual and site-specific development proposals and monitoring reports. The 
review and approval process will include a site-specific visit by the Review Team, applicable 
environmental review and establishing required BMPs, conditions of approval, or other 
protective measures to mitigate potential environmental impacts. The review and approval 
process is illustrated on figure 3. 

The Annual Planning Process 

The April 1 st date, as proposed by the Operators is open to modification based on results 
observed and problems encountered. Changes to the date may be proposed by any party, 
reviewed and commented upon by the companies and cooperators, and approved by the AO. 
Any date changes will not be effective until approved in writing by the AO. While described as 
an “annual” planning process, this concept is adaptive and open for modification and 
improvement, including more frequent planning meetings if necessary. The intent of the 
process is to have future, site-specific development plans for Atlantic Rim be 


Page 16 


Record of Decision for the Atlantic Rim Natural Gas Project 


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Record of Decision for the Atlantic Rim Natural Gas Project 


RECORD OF DECISION 


submitted to the BLM for review in a manner that will allow the BLM to capture economies of 
scale in planning, processing, approving, and involving other cooperating agencies. By 
receiving development proposals in groups, the Review Team will be able to develop a more 
holistic view of future development and reclamation progress and success, and more effectively 
apply mitigations and BMPs to reduce development effects. Proposals should span several 
years or stages of development and must include the entire proposal including well sites, 
compressor stations, utility and pipeline corridors, roads, status and success of reclamation 
efforts for a specific area, and any other disturbances planned and their timing. 

This decision includes an unreclaimed disturbance cap of 7,600 acres at any time. All 
Operators must submit to the BLM within 30 days of the effective date of this decision a 
summary of their lease holdings and associated mineral acreage. The 7,600-acre disturbance 
cap will be allocated to Operators on a prorated, mineral leasehold basis. Existing surface 
disturbance from activities approved under the IDP will count against each Operator’s 
disturbance cap allocation. Past oil and gas development surface disturbance within the ARPA 
will not count against the disturbance cap. Only new disturbance proposed by the ARPA lease 
holders or disturbance under the IDP would be eligible for disturbance cap allocation. Only 
successfully reclaimed acreage (See ROD appendix A, Criteria for Reclamation Success) that 
was disturbed during the implementation of activities associated with this decision or the IDP will 
be allocated back to the Operator based on their prorated disturbance cap. Regardless of the 
number of Operators within the ARPA, the total of all prorated disturbance cap allocations may 
not exceed 7,600 acres. 

Cooperating Agencies and Interested Stakeholders 

The Review Team members will be invited to participate in the annual planning process and 
site-specific review process based on their interest, time, and availability. Review Team 
member participation would be in addition to their separate and independent permitting and 
approval responsibilities under any other authorities. The BLM is the final decision authority and 
will set the schedule for meetings, site visits, review periods, etc. When appropriate, 
Memoranda of Understanding (MOUs) or other applicable inter-agency agreements may be 
prepared and utilized between the parties to document the extent of participation in the annual 
planning and site-specific review processes. 

Site-Specific Reviews with Interagency and Operator Participation 

Once the development plan is received, the BLM will schedule an “on-site” visit to review the 
areas included in the proposal for development. The purpose of the review is to familiarize the 
Review Team with the proposal; the location of disturbance; and the extent, timing, and other 
relevant factors. Generally there would be one team visit that may be followed up with 
individual reviews by team members, as necessary. Based on the site conditions found in the 
area, the BLM, in collaboration with cooperating agencies, will determine the necessary 
mitigation measures, BMPs, and conditions of approval necessary for processing the proposal. 
During its review of the proposal, BLM, in consultation with the Operator making the proposal, 
may require the submittal of additional information to address application deficiencies, 
application of BMPs and mitigation, site relocation, and other changes in the proposal. 
Modifications to a proposal will be based on site-specific factors, such as lek locations, raptor 
nests, crucial winter range, or any other relevant issues. 


Page 18 


Record of Decision for the Atlantic Rim Natural Gas Project 


RECORD OF DECISION 


NEPA Review, Categorical Exclusion and Proposal Approval Process 

The approval process will be conducted consistent with NEPA. When appropriate, 
environmental documents prepared under NEPA may be processed by the BLM, or a third-party 
contractor funded by the Operator may assist the BLM in meeting its NEPA requirements. The 
AO, in consultation with Operators, will determine the manner in which the BLM meets its NEPA 
obligations including determining whether a categorical exclusion pursuant to Section 390 of the 
Energy Policy Act of 2005 applies. The environmental document and its related decision 
document will specify required BMPs, COAs, or other protective measures as detailed in the 
paragraph above to be included in the authorization. 

The BLM will use a performance-based management approach as part of the adaptive 
management process, which includes four primary elements. 

1. Performance Goals: describes the conditions that the BLM and Operators will 

attempt to achieve (See Performance Goals in the following section). 

2. Performance Requirements: an extensive array of BMPs (ROD, appendix B), COAs, 
and protective measures used to help achieve the Performance Goals. 

3. Performance-Based Monitoring: monitoring efforts to measure the degree of 

success the Performance Requirements have in achieving Performance Goals (See 
Monitoring, Reporting and Adaptive Management). 

4. Adaptive Management: additional mitigation or adaptive techniques to help achieve 
Performance Goals. 

Performance Goals 

The BLM will attempt to achieve the following Performance Goals in collaboration with other 
state and other federal agencies: 


Item 

Performance Goal 

Migration Routes 

maintain functional migration routes through or around development 
areas 

Big Game Crucial 
Winter Range 

provide an adequate amount of suitable, undisturbed crucial winter 
range for big game animals 

Sage and Sharp- 
Tailed Grouse 

provide well-dispersed sage-grouse breeding, nesting, brood 
rearing, and winter habitat 

Muddy Creek 
Sensitive Fish 

maintain adequate water quality, water quantity, species distribution, 
and aquatic habitat components 

Shrub-Dependent 
Song Birds 

assure occupied habitat for shrub-dependent song birds is well 
distributed throughout the project area 

Riparian 

ensure no net loss of native riparian habitat/vegetation 

Grazing 

maintain adequate and sustainable food and habitat for domestic 
animals 

Range Condition 

maintain range condition or improve range condition towards 
potential for the ecological site 

Livestock Safety 

minimize deaths and injuries of livestock due to development and 
operational activities 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page 19 


RECORD OF DECISION 


Item 

Performance Goal 

Range 

Improvements 

minimize damage to range improvements, gates, cattle guards, 
water sources, and other livestock grazing management 
improvements 

Standards and 
Guidelines 

manage to meet Wyoming Healthy Rangeland Standards 

Sites 

maintain viable, site-stabilizing native plant growth 

Species 

Composition 

maintain a range of species composition, diversity, cover, and 
production equal to pre-disturbance levels 

Weeds 

maintain weed-free sites 


Operators are responsible for demonstrating successful achievement of Performance Goals. 
Early efforts are to be made to collect or consolidate resource data to form a baseline against 
which future monitoring efforts and data would be compared to indicate trends. In the absence 
of sufficient data illustrating Operator achievement of Performance Goals, the BLM will use a 
conservative approach when considering additional approvals. 

Monitoring, Reporting, and Adaptive Management 

The monitoring, reporting, and adaptive management processes made part of this decision are 
its key components. As part of the annual planning process, a monitoring and mitigation 
process will be required, and its development will begin within 30 days of the effective date of 
the ROD. This information should be reviewed at least annually with development plans 
modified based on trends. The purpose of monitoring is to assess the status of the 
Performance Goals, measure and detect trends, or detect any other undesired effects. 
Monitoring will also be used to assess the effectiveness of reclamation efforts and any approved 
mitigation measures. 

The adaptive management process is iterative and can be summarized as: 

• Disturbance Action 

o monitoring for trend and effectiveness 
o identification of areas requiring modification 
o implementation of adapted techniques and/or mitigation 
o repeat process 

In most cases, monitoring must occur for several years to detect trends and establish that 
successful mitigation has occurred. Identification of areas requiring additional work can occur 
anytime during the monitoring and mitigation process. To ensure success, any change in or 
addition of mitigation measures should be adapted to address the conditions or resolve 
problems observed during monitoring. If additional mitigation measures do not produce the 
desired effects or conditions, continued monitoring and data collection may be used to further 
identify or clarify the problem. As a result, further adaptation of mitigation techniques would be 
tested and monitored for success. 


Funding for wildlife and habitat monitoring may be obtained from BLM appropriations, in 
collaboration with cooperating or interested agencies, from the voluntary participation of the 
Operators, or from outside sources that may have an interest or desire to participate or 
contribute, or from a combination of these sources. As noted above in Monitoring, Reporting, 
and Adaptive Management, Operators are responsible for demonstrating successful 


Page 20 


Record of Decision for the Atlantic Rim Natural Gas Project 


RECORD OF DECISION 


achievement of Performance Goals. The Review Team, the BLM, or both, will identify the level 
of effort required for performance-based monitoring and develop associated monitoring plans. 

The Operators are responsible for reclamation monitoring and reporting costs. 

PERFORMANCE REQUIREMENTS 

The FEIS lists an extensive array of possible BMPs and protective measures that may be 
required by the BLM to mitigate the effects of a proposal. Protective measures summarized in 
appendix L of the FEIS will be considered based on site-specific conditions, where such 
measures are not in conflict with this decision. Consistent with its responsibilities under FLPMA 
and with the authority found in the mineral lease, including stipulations, the BLM will, as 
necessary and appropriate, work with the Operators and cooperating or interested agencies to 
determine any actions that need to be taken to approve the proposal. The formulation and 
application of mitigation measures and BMPs will be based on the site-specific conditions found 
at the areas for which disturbance is proposed at the time the proposal is submitted or 
authorization requested and the rationale for their application clearly disclosed. 

Appendix B of this decision presents performance-based requirements and monitoring that will 
be considered during site-specific, environmental review. Operator-committed practices, which 
become mandatory requirements with publication of this decision, are included in appendix C. 

This decision incorporates a requirement for Operators to prepare development plans as 
outlined in the Reclamation Plan (appendix A). These development plans must include a 
Transportation Plan, Reclamation Plan, and a Hazardous Materials Management Summary. 
Monitoring to evaluate compliance with Performance Requirements and achieving Performance 
Goals will be as outlined above. 

PUBLIC INVOLVEMENT 

The BLM announced its intent to prepare an EIS for this project in the Federal Register on 
June 26, 2001, and initiated scoping. The state of Wyoming, federal agencies, state and local 
government representatives, municipalities, Native American Tribes, grazing permittees, lease 
and ROW holders, landowners within the ARPA, local media, and other agencies, industry 
representatives, individuals, and organizations were sent a scoping notice and other information 
by mail. Two public meetings were held in July 2001 at Baggs and Rawlins, Wyoming. 
Fifty-seven comments were received in the form of letters, emails, and faxes from the public 
including citizens; interested federal, state, and local agencies; advocacy groups; and various 
corporations. These comments were used to identify key issues, potential resource conflicts 
and concerns, possible alternatives, and the scope of the analysis. Interested agencies were 
invited to participate as cooperating agencies. The state of Wyoming, Little Snake Conservation 
District, and the Carbon County Commissioners requested and received Cooperating Agency 
status. 

The Draft Atlantic Rim EIS was released in December 2005. The 60-day comment period 
resulted in over 59,400 individual responses, including approximately 59,100 electronic 
messages and 300 hard copy comments. Comments were received from state, federal, and 
local agencies; environmental advocacy groups; landowners; leaseholders; oil and gas 
companies; and the general public. All responses were reviewed for content. The BLM 
identified substantive comments and developed responses. A detailed description of the 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page 21 


RECORD OF DECISION 


comments made on the DEIS and the process by which they were analyzed by BLM is included 
with the FEIS. 

Comments were used to develop Alternative D and to modify, clarify, and correct the FEIS, as 
appropriate. 

The FEIS was released to the public and a Notice of Availability (NOA) published in the 
Federal Register on November 30, 2006. Comments were accepted on the FEIS through 
January 4, 2007. Approximately 85 responses, including those from cooperating agencies and 
interested parties, were received by BLM. Some comments on the ARPA FEIS raised specific 
concerns regarding use of mitigation measures; avoidance of cultural sites; groundwater and 
wildlife impact analysis; wildlife, habitat and reclamation monitoring; rationale for selection of the 
preferred alternative; opportunities for future public input; surface disturbance reclamation; air 
quality analysis; and paleontological condition and classification. A summary of these concerns 
and comments and BLM’s responses are contained in appendix E of this ROD. 


This decision may be appealed to the Interior Board of Land Appeals, Office of the Secretary, in 
accordance with the regulations contained in 43 CFR 3165.4. If an appeal is filed, your notice of 
appeal must be filed in this office (Bureau of Land Management, State Director, P.O. Box 1828, 
Cheyenne, Wyoming 82003) within 30 days of the date BLM publishes its notice of the decision 
in the Federal Register. The appellant has the burden of showing that the decision appealed 
from is in error. 

If you wish to file a petition pursuant to 43 CFR 3165.4(c) for a stay (suspension) of the 
effectiveness of this decision during the time that your appeal is being reviewed by the Board, 
the petition for a stay must accompany your notice of appeal. A petition for a stay is required to 
show sufficient justification based on the standards listed in 43 CFR 3165.4(c). If you request a 
stay, you have the burden of proof to demonstrate that a stay should be granted. Copies of the 
notice of appeal and petition for a stay must also be submitted to the Interior Board of Land 
Appeals and to the Rocky Mountain Regional Office of the Solicitor at the same time the original 
documents are filed with this office. 


APPEAL PROCESS 


AUTHORIZED OFFICER: 




Robert A. Bennett 
Wyoming State Director 


Page 22 


Record of Decision for the Atlantic Rim Natural Gas Project 


RECORD OF DECISION 


ERRATA 

Modifications and Corrections to the 
Final Environmental Impact Statement for the 
Atlantic Rim Natural Gas Field Development Project 


The section describes changes to the FEIS to correct errors or omissions and identify 
modifications. 

Modifications 


1. Appendix H, title, delete the word “Required” from the title of appendix H. The revised 
title is R e qu i r e d “Best Management Practices”. 

2. Appendix H, page 1, first paragraph, the words “as appropriate” have been added and 
the text now states, “These Best Management Practices (BMPs) will be applied, as 
appropriate , under all alternatives as Conditions of Approval where proposals result in 
conflicts with identified resources”. 

3. Appendix H, page 1, insert the following text as a fifth bullet under “Additional mitigation 
measures are also identified in:”. 

• “The most current version of Onshore Oil and Gas Operations Orders 1 - 7 (Code of 
Federal Regulations 43 CFR 3160).” 

4. Appendix H, page H-4, Reducing Impacts from Fluid Mineral Construction, Operation, 
and Reclamation; delete items #1 and #2 ( 1) D i r e ct i on al Dr illi ng; (2) Dr ill mu l t i p le w ell s 
from - -a -si ng le pad) . These items are deleted to reflect that these measures are not 
required Best Management Practices. However, these measures can be used at the 
discretion of the Operators with BLM approval. 

5. Appendix H, page H-6, under Protection Measure, numbers two and three, the word 
“primary” has been deleted and replaced with state, county or BLM”. The revised text 
states, 

“2.) Avoid locating pads in areas visible from pr i m a ry state, county or BLM roads.” 
and 

“3.) Avoid locating facilities on or near ridgelines - use subsurface or low-profile 
facilities to prevent protrusion above horizon line when viewed from any pr i m a ry 
state, county or BLM roads.” 

6. Appendix H, page H-6, under Protection Measure, item numbers ten and eleven have 
been deleted. The revised Protection Measure has thirteen items. The deleted items 
were; 

“ 10.) D e s i gn a nd con s truct a ll n e w roads to a s a f e a nd appropr ia t e st a ndard, “no 
h i gh e r th a n n e c essar y^ - accommodat e th ei r i nt e nd e d us e .” and 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page 23 


RECORD OF DECISION 


“11.) Loc a t e- ro a ds far e nough off th e b a ck of r i dg eli n e s so th e y ar e n't v i s i b le from 
st a t e , county or BLM roads.” 

7. Appendix H, page H-7, Avoidance Areas, under Protection Measure, number one, 
second bullet, the word “water” has been added and the text now states, “Areas within 
500 — feet from perennial waters, springs, water wells and wetland riparian areas; and,”. 

8. Appendix H, page H-12, Water Used for Construction, Maintenance, and Drilling 
Activities, under Protection Measure, number one, the revised text states “1) All water 
used for drilling, completion and testing activities will be free of hydrocarbons and come 
from e x is tin g CBNG wells^ or be re-used from other drilling sites, and/or come from 
sources approved by the BLM and T subject to state permitting requirements . Only fresh 
water would be allowed for drilling to surface casing setting depth. New water sources 
would be considered for potential depletions to the Platte or Colorado River Basins as 
necessary .” The modified text is necessary to conform to drilling regulations. 

9. Appendix O, page 0-243, response to comment #671-73-1; delete the following phrase 
from the response: “ Non e ar e known to outcrop i n th e ARPA .” This correction is made 
to remove a statement erroneously included in the FEIS. 


Page 24 


Record of Decision for the Atlantic Rim Natural Gas Project 


Appendix A 


Atlantic Rim Natural Gas Project 

Reclamation Plan 



APPENDIX A 


ATLANTIC RIM NATURAL GAS PROJECT 
RECLAMATION PLAN 

TABLE OF CONTENTS 

1 Reclamation A-1 

1.1 Management of Soil for Restoration A-2 

1.2 Seed Mixtures A-2 

1 .3 Reclamation Standards and Principles A-3 

1.3.1 At Any Time A-3 

1 .3.2 First Growing Season A-4 

1.4 Monitoring and Reporting Disturbed Sites A-5 

2 Criteria for Reclamation Success A-6 

3 References Cited A-8 


LIST OF TABLES 

Table A-1. Reclamation Monitoring Reporting Data A-7 


LIST OF ATTACHMENTS 

Attachment A-1 . Standard Seed Mixtures A-9 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page A-i 





APPENDIX A 

ATLANTIC RIM NATURAL GAS PROJECT 
RECLAMATION PLAN 


This appendix presents a programmatic reclamation plan for the Atlantic Rim Natural Gas 
Project Area (ARPA). It gives general guidelines for completing reclamation in lieu of specific 
actions to take at each disturbance. Current Bureau of Land Management (BLM) policy 
recognizes that there might be more than one correct way to achieve successful reclamation. A 
variety of methods may be appropriate to varying circumstances. BLM will continue to 
encourage Operators to use their expertise in recommending and implementing reclamation 
projects. However, the Operators are responsible for attaining final reclamation standards of 
performance as outlined in the USDI-BLM (1990a) reclamation policy. All reclamation must 
conform to BLM reclamation policy (USDI-BLM 1990a). Further guidance for reclamation can 
be found in the BLM/Forest Service “Surface Operating Standards and Guidelines for Oil and 
Gas Exploration and Development” (Gold Book) found at: 

http://www.blm.gov/bmp/gold%20book/FinalGoldBook%20-%202006%20Edition.pdf 

1 Reclamation 

BLM reclamation goals emphasize ecosystem reconstruction, which means returning the land to 
a condition approximate to or better than that which existed before it was disturbed. Final 
reclamation measures are used to achieve this goal. BLM reclamation goals also include the 
short-term goal of quickly stabilizing disturbed areas to protect both disturbed and adjacent 
undisturbed areas from unnecessary degradation. Interim reclamation measures are used to 
achieve this short-term goal. As such, two types of reclamation are envisioned at the ARPA: 

1. Interim Reclamation. Stabilization of soil by revegetation on sites that will likely be 
further disturbed in the future. This includes sites where re-contouring is needed 
where periodic disturbance may occur due to operation and maintenance activities. 

2. Final Reclamation. Reclamation of an area that is not planned for further 
disturbance including re-contouring, stabilization of soil by revegetation, and 
restoring the ecosystem function originally found at the site. 

Among items to be emphasized in achieving these goals are: 

• Stabilization of disturbed soils until the first growing season; 

• Soil stabilization through establishment of a vegetative ground cover on disturbed 
sites during the first growing season following disturbance; 

• Restoration of the native plant community disturbed or removed, or restoration of an 
alternate vegetative regime in consultation with and approval by the BLM’s Rawlins 
Field Office (RFO); 

• Minimal disturbance of the existing environment and avoidance of riparian areas; 


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APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


• Annual monitoring and control of invasive and noxious weeds beginning the first 
season of disturbance; 

• Monitoring and management of reclamation sites to evaluate weed populations, 
reclamation success, and to plan and report on the program annually; and 

• Affirmative efforts to resist the spread of weeds including refraining from cleaning out 
equipment including filters on the site, and power washing machinery and equipment 
between work sites consistent with the Rawlins Weed Prevention Plan 
(USDI-BLM 1999). 

1.1 Management of Soil for Restoration 

Topsoil should be handled separately from subsoil materials. At all construction sites, topsoil 
should be stripped to provide for sufficient quantities to be re-spread to a depth of at least 4 to 
6 inches over the disturbed areas during reclamation. In areas where deep soils exist (such as 
floodplains and drainage channel terraces), at least 12 inches of topsoil should be salvaged. 
Where soils are shallow or where subsoil is stony, as much topsoil should be salvaged as 
possible. 

Topsoil should be stockpiled separately from subsoil materials. Topsoil salvaged from drill sites 
and stored for more than 1 year should be bladed to a specified location, seeded with a 
prescribed seed mixture, and covered with mulch for protection from wind and water erosion 
and to discourage the invasion of weeds. Topsoil stockpiles anticipated to be stored for more 
than 1 year will be re-spread so as not to exceed a depth of 2 feet. Topsoil should be stockpiled 
separately from other earth materials to preclude contamination or mixing, marked with signs, 
and identified on construction and design plans. Runoff should be diverted around topsoil 
stockpiles to minimize erosion of topsoil materials. 

In most cases, disturbances will be reclaimed within 1 year. Therefore, it is unlikely that topsoil 
stockpiling for more than 1 year will be required. Salvaged topsoil from roads and drill sites will 
be respread over cut-and-fill surfaces not actively used during the production phase. Upon final 
reclamation, topsoil spread on these surfaces will be used for the overall reclamation effort. 

1.2 Seed Mixtures 

On all areas to be reclaimed, seed mixtures are required to be free of noxious weeds, 
composed of the same native species as were disturbed, and required to include 
species-promoting soil stability. A predisturbance species composition list must be developed 
for each site if the project encompasses an area where there are several different plant 
communities present. Livestock palatability and wildlife habitat needs must be considered in 
seed mix formulation. Variation of seed mixtures can be proposed and approved based on 
availability, climatic conditions, or variables. BLM guidance for native seed use is the BLM 
Manual 1745 (USDI-BLM 1992) and Executive Order 13112 (Invasive Species, 64 Federal 
Register 6183). 

Alternate Seed Mixtures. The seed mixtures identified in attachment A-1 may vary on a 
site-specific basis. Variations may be proposed and approved by the BLM before final 
reclamation. An example for the ARPA would be the addition of green needlegrass 


Page A-2 


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APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


( Stipa viridula var. Lodorm ) on clayey sites associated with the southern portion of the ARPA 
(e.g., Muddy Mountain area). 

Temporary Seed Mixtures. Depending on BLM authorization, the following seed mixtures may 
be considered for erosion and weed control on sites that will be disturbed again before final 
reclamation. Seed mixtures contain annual cereal grasses that are not suitable for establishing 
a reclaimed vegetative community, but offer a temporary option to prevent halogeton invasion 
and establishment. 

Seed should be broadcast at a rate necessary to reestablish vegetation equivalent to the 
surrounding areas. Another viable option is the use of a sterile triticale hybrid such as 
Quickguard® (Granite Seed) to stabilize the disturbed area. The use of a non-sterile plant 
species such as wheat is not recommended as a cover crop because of its ability to reseed 
itself. 

During reclamation within areas of important wildlife habitat (crucial winter range, sage-grouse 
nesting habitat, etc.), consideration shall be given for the restoration of native shrubs and forb 
species. Follow-up seeding or corrective erosion control measures will be required on areas of 
surface disturbance that fail to meet reclamation success standards. 

Any mulch used must be certified free from mold, fungi, or noxious or invasive weed seeds. 
Mulch may include hay, small-grain straw, wood fiber, live mulch, cotton, jute, or synthetic 
netting. Straw mulch should contain fibers long enough to facilitate crimping and provide the 
greatest cover. 

1.3 Reclamation Standards and Principles 

One of the most important principles for successful restoration is to limit initial disturbance 
through the use of planning, construction control, and adaptive management . Restoration 
planning should start before disturbance and be an integral part of the operational plan. 
Consideration of the processes necessary for successful reclamation is important. Pre- 
disturbance surveys, site stabilization, weed control, and maintenance of healthy soils are 
important considerations. Revegetation that considers vegetative succession to pre-disturbance 
vegetative conditions, with annual monitoring and reporting, will allow tracking of success and 
adaptive management of problem areas. Annual monitoring and reporting, will allow tracking of 
success and adaptive management of problem areas. 

1.3.1 At Any Time 

For each discrete site where ground-disturbing activities are planned or occur under the 
Operators’ activities, a site-specific reclamation plan shall be prepared, submitted, and 
approved by the BLM before the Operators disturb the environment. Guidance and 
requirements for this plan can be found in program-specific direction (USDI-BLM 1983). A 
project-wide reclamation plan may be considered if it addresses discrete site disturbances 
individually. The collection of photo reference points is essential. 

With the exception of active work areas, disturbed areas anticipated to be left bare and exposed 
will be stabilized to prevent soil erosion. In addition, mulch, silt fencing, waddles, hay bales, and 
other erosion control devices will be used on areas at risk to soil movement away from disturbed 


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APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


areas including fill slopes. Variation and use of the cover percentage and the use of other 
stabilizing materials can be proposed and used with BLM approval consistent with the relevant 
site-specific reclamation plan. For areas anticipated for further disturbance, use of the seed 
mixtures detailed in Temporary Seed Mixes on page A-3 would be acceptable in the interim. 

1.3.2 First Growing Season 

Reclamation actions will be implemented before the first growing season following disturbance 
with the goal of returning the land to a condition approximate to or more productive than that 
which existed before disturbance or to a stable and productive condition compatible with that 
described in the land use plan (USDI-BLM 1990b). One strategy could include consideration of 
using all grasses for the first seeding so that it survives any weed-controls used. Subsequent 
seeding will be required to promote the establishment of desired shrubs and forbs. 

Consistent with the reclamation plan, the operator will ensure the following during the first 
growing season: 

1 . Prior to the beginning of the growing season, 

• Stabilize disturbed site soils until they are revegetated with no hindrance to 
germination and growth of seed and 

• Properly prepare the site by 

o Recontouring for permanent reclamation; 

o Completing soil preparation activities, such as ripping and straw 
crimping/seedbed preparation for planting including drilling and broadcast 
methods; 

o Planting the approved seedling/seed mixtures using site-specific methods for 
successful revegetation with locally adapted species; and 

o Ensuring that weed treatments are compatible with seed mixtures and 
plantings. 

2. Starting the first growing season, 

• Monitor germination and growth of plants in the area being reclaimed; 

• Work with the BLM and surface leasees to detect and control weeds in all areas; 

• Use adaptive management to correct establishment and growth problems; 

• Put up temporary fencing to avoid adverse effects to reclamation; 

• Build snow fencing, if requested, to increase the capture of precipitation and aid 
in the re-establishment of vegetation and control wind scour. 


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APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


3. Following each growing season, 

• Review and complete a site-specific vegetation monitoring report for areas being 
reclaimed (table A-1) and 

• As necessary, prepare a written, site-specific prescription for actions to be 
implemented, which might include: 

o Reseeding areas not attaining reclamation success, 
o Soil stabilization, 
o Weed control needs, and 

o Mulching/fertilization or other practices prescribed for the following season. 

If the treatment area is found to be successfully reclaimed, the site will be checked for 
reclamation success at least annually for at least five seasons. The site will also be checked for 
additional management needs including weed infestations and control needs. 

If the treatment area is not successfully reclaimed or otherwise requires further management 
activities, the actions prescribed will be implemented as planned and further monitoring will 
occur as detailed beginning with item 1 above. 

1.4 Monitoring and Reporting Disturbed Sites 

The operator will provide the BLM with an annual report before December 1st for all sites 
disturbed. The report will include: 

• Copies of the completed individual site review forms or a BLM-approved electronic 
report. 

• A summary of monitoring data and results that include: 
o Identification of monitoring by year; 

o Individual site reclamation monitoring reporting data (table A-1 ); 

o Identification of sites successfully reclaimed by reclamation years (starting with 
the first growing season); 

o Identification of sites needing additional work/more reclamation activities; 

o Sites proposed for the end of monitoring, i.e., sites that were successfully 
reclaimed. 

• A BLM-useable shapefile(s) or Geographic Information System (GIS) layer(s) that 
details location, name, type, and extent of: 

o New disturbances, 

o Unreclaimed disturbances, 


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APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


o New reclamation, 

o Failed or unsuccessful reclamation, 

o Locations of noxious/invasive weed infestation, and 

o Further vegetation treatments planned (e.g., mulching, matting, and weed 
control). 

On these shapefiles or GIS layers, location shall be given as the legal location and geo- 
referenced location of the site; name, as the BLM Application for Permit to Drill (APD), lease, or 
other BLM file name for the site; and extent, as the amount of area and location of the item. 

2 Criteria for Reclamation Success 

Reclamation will be considered successful if the following Interim Reclamation criteria are met. 

• 80 percent of predisturbance ground cover, 

• 90 percent dominant species*, 

• No noxious weeds present in the seeding, and 

• Erosion features equal to or less than the surrounding area. 

*The vegetation will consist of species included in the seed mix and/or occurring in the 
surrounding natural vegetation or as deemed desirable by the BLM in review and 
approval of the reclamation plan. The goal is no single species will account for more 
than 30 percent total vegetative composition. Vegetation canopy cover production and 
species diversity shall approximate the surrounding undisturbed area. 

Section 1.3.1 of this appendix indicates that reclamation success will be tracked by each 
discrete site for which an individual reclamation plan was prepared. A site can be nominated for 
successful reclamation status by the Operators or the BLM any time it meets the criteria for 
reclamation success as outlined above. A site will be considered reclaimed and the Atlantic 
Rim disturbance acreage count reduced by the extent of the reclaimed acreage when a BLM 
authorized officer accepts the written nomination. Partially reclaimed discrete sites will not have 
any reclaimed acreage subtracted from the disturbance acreage count. The Atlantic Rim 
disturbance cap is 7,600 acres at any one time. 

The BLM RFO will maintain a running count of the extent of surface disturbance acres based on 
the “as built” geo-spatial monitoring data submitted by the companies annually for the 
preceding year in December after construction. An annual summary report of the disturbance 
acreage count will be available to the companies and the public upon written request. For a 
project-wide-type reclamation plan (per section 1.3.1 of this appendix), each individual site 
disturbance included in the plan will be managed as a discrete site and disturbance acreage will 
be tracked as detailed above. 

When determining the extent of successful reclamation, a site covered under an individual 
reclamation plan will be evaluated as follows. If, for example a site is determined to have 
4.2 acres of total disturbance based on the “As-Built” survey, the disturbance acreage count for 
that discrete site will be 4.2 acres. However, if one-half acre remains disturbed in the long-term 


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Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


(e.g., roadway) then the disturbance count for that site would be reduced by 3.7 acres when 
accepted as successfully reclaimed by the BLM. It should be noted that “partial credit” would 
not be given until all of the 3.7-acre portion is successfully reclaimed and accepted. 

Table A-1. Reclamation Monitoring Reporting Data. 


General 

WYW# (Oil & Gas Lease or Right-of-Way) 

Project Name 

Project Type (Well, Access Road, Pipeline, Facility, etc.) 
Qtr/Qtr Sec, T, R, County, State 

Disturbance 

Disturbance Dates 
Start-End 

Reclamation 

Reclamation Type (Interim/Final) 
Earthwork Contractor Name 
Earthwork & Topsoil Completion Date 
Soil Preparation Ripping Depth 
Area (Acres or Square Feet (Sq. Ft.)) 

Seeding 

Seeding Contractor Name 
Seeding Date 

Seedbed Preparation Methods (Disc, Harrow, Depths) 
Seeding Method (Drill, Broadcast, Depths) 

Copy of Seed Tag (Species%, Purity%, Germination%) 
Actual Seeding Rate Lbs/Acre 
Area Seeded (Acres or Sq Ft) 

Other 

Soil Amendments Used (Describe) 
Mulching/Erosion Netting/T ackifier 
Fenced Location 
Snow Fencing 

Weeds 

Type(s) of Weeds Treated 
Weed Contractor Name 
Contractor License # 

Weed Treatment Date 

Weed Treatment Type (Chemical, Mechanical) 

Chemicals Used and Rates Applied 

Area Treated (Acres or Sq Ft) (GIS Extent and Location) 

Inspection 

Inspector’s name, Company, ID 
Inspection Date 
Time after Seeding 
Seedlings/Sq. Ft Growing 
% and Extent of Bare Soil 
% Ground Cover (Describe) 

% Desirable Species (Describe) 

% Noxious/Invasive Weeds (Describe) 
Erosion Features Present? (Describe) 
Evidence of Livestock Grazing (Describe) 
Reclamation Successful (Yes/No) 

Reporting 

Completed Spreadsheet or Database 

GIS Layer with Attribute Table with Site Data as Detailed 

Detail Disturbance Extent and Location 

Monitoring 

Permanent Reference Point 
Reference Photos 
Close-up Photos 


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APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


Table A-1. Reclamation Monitoring Reporting Data. 


Future Management 

Reseeding 

Prescription 

Weed Control Needed 


Erosion Control Needed 


Grazing / Predation Issues 


Other Cultural or Mechanical Needs 


3 References Cited 

USDI-BLM 1983. Onshore Oil and Gas Order No. 1: Approval of Operations on Onshore 
Federal and Indian Oil and Gas Leases, Section lll(G)(10). 43 CFR 3160. United States 
Department of Interior, Bureau of Land Management. October 1983. 

USDI-BLM 1990a. Wyoming Policy on Reclamation. Cheyenne, Wyoming: United States 
Department of Interior, Bureau of Land Management, Wyoming State Office. Instruction 
Memorandum No. WY-90-231. February 1990. 

USDI-BLM 1990b. Great Divide Resource Area Record of Decision and Approved Resource 
Management Plan. Rawlins, Wyoming: United States Department of the Interior, Bureau 
of Land Management, Rawlins District Office, Great Divide Resource Area. 74 pp. 

USDI-BLM 1992. Introduction, Transplant, Augmentation, and Reestablishment of Fish, 
Wildlife, and Plants, BLM Manual 1745. United States Department of the Interior, Bureau 
of Land Management. March 1992. 

USDI-BLM 1999. Rawlins Field Office Noxious Week Prevention Plan, Rawlins, WY. United 
States Department of the Interior, Bureau of Land Management. April 1999. 


Page A-8 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


ATTACHMENT A-1 

STANDARD SEED MIXTURES 
RAWLINS FIELD OFFICE 

The following list contains seed mixes recommended by resource specialists with years of local 
knowledge. Care and planning must be taken to choose mixes and amounts that will benefit under site- 
specific conditions. Planning and thought must also go into selecting successful planting and site 
preparation techniques. All sites must be planted with a diverse mix of grasses, forbs, and shrubs to be 
considered successful. Industry is ultimately responsible for successful restoration of disturbed sites. 
Alternate seed mixes can be proposed by industry to the BLM for approval prior to use. The final goal is 
to restore disturbed sites so that they closely resemble pre-disturbance native plant communities. 


DRY LOAMY/CLAY SITES - characterized as a sagebrush/wheatgrass community with less than 
10 inches precipitation 


Species of Seed 

Grasses 

Variety 

Lbs. PLS* 

Stream bank wheatgrass ( Elymus lanceolatus) 

Sodar 

1 

Thickspike wheatgrass ( Elymus macrourus )) 

Critana (Bannock) 

1 

Western wheatgrass ( Agropyron smithii) 

Rosana 

1 

Indian ricegrass ( Oryzopsis hymenoides) 

Rimrock (Nez Par) 

2 

Bottlebrush squirreltail ( Elymus elymoides) 

Sand Hollow 

2 

Slender wheatgrass ( Elymus trachycaulus ) 

Pyror (San Luis) 

4 

Little bluegrass “Sandbergh” (Poa secunda) 

High plains 

0.5 

*Bluebunch wheatgrass ( Pseudoroegneria spicata) 

Secor 

2 

Shrubs 

*Big sagebrush ( Artemisia tridentata wyomingensis) 


0.5 

‘Gardner's saltbush ( Atriplex gardneri) 


1 

‘Fourwing saltbush ( Atriplex canescens) 

Wytana 

1 

* Shadescale ( Atriplex confertifolia) 


0.5 

‘Rubber rabbitbrush ( Ericamerica nauseosas) "green” 

Chrysothamnus 
viscid iflorus “Gray” 

1 

*W interfat ( Krascheninnikovia lanata) 

Open Range 

0.5 

Forbs 

‘Scarlet globemallow ( Sphaeralcea coccinea) 


0.5+ 

‘Lewis' flax ( Linum lewsii) 

Appar 

0.5+ 

‘Rocky Mountain beeplant ( Cleome serrulata) 


0.5+ 

‘Western yarrow ( Achillea millefolium L. var. occidentalis) 

Yakima 

0.5 

‘Firecracker Penstemon (Penstemon eatonii) 

Richfield 

1 

DRY SANDY SITES - characterized as a sagebrush/bunchgrass community with less than 10 inches 
precipitation 

Species of Seed 

Grasses 

Variety 

Lbs. PLS* 

Indian ricegrass ( Achnatherum hymenoides ) 

Rimrock (Nez Par) 

3 

Needleandthread needlegrass ( Stipa comata) 


4 

Slender wheatgrass ( Agropyron trachycaulum) 

Prior 

4 

‘Sandhill muhly ( Muhlenbergia pungens) 


0.5 

Western wheatgrass ( Agropyron smithii) 

Rosana 

1 

‘Threadleaf sedge ( Carex filafolia) 


2 


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Page A-9 


APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


Species of Seed Variety Lbs. PLS* 

Shrubs 

‘Rubber rabbitbrush ( Ericamerica nauseosas) “green” Chrysothamnus 1 

viscidiflorus “Gray" 

‘Wyoming Big sagebrush ( Artemisia tridentata wyomingensis) 0.5 

‘Spiny hopsage ( Atriplex spinosa) 1 

‘Fourwing saltbush ( Atriplex canescens) Wytana 1 

‘Winterfat (Krascheninnikovia lanata) Open Range 0.5 

Forbs 

‘Scarlet globemallow ( Sphaeralcea coccinea) 0.5+ 

‘Lewis' flax ( Linum lewsii) Appar 0.5+ 

‘Rocky Mountain beeplant ( Cleome serrulata) 0.5+ 

LOAMY/CLAY-LOAM SITES - characterized as a sagebrush/wheatgrass community with 10 inches or 
greater precipitation 

Species of Seed Variety Lbs. PLS* 

Grasses 

Western wheatgrass ( Agropyron smithii) Rosana 1 

Thickspike wheatgrass ( Elymus macrourus) Critana 1 

Indian ricegrass ( Oryzopsis hymenoides) Rimrock (Nez Par) 1 

Green needlegrass ( Stipa viridula) Lordon 3 

Prairie Junegrass (Koeleria cristata) 1 

Bottlebrush squirreltail ( Sitanion hystrix) Sand Hollow 1 

Mutton bluegrass (Poa fendleriana) 0.5 

Stream bank wheatgrass (Elymus lanceolatus) Sodar 1 

Bluebunch wheatgrass ( Pseudoroegneria spicata) Secor 2 

Basin wildrye Trailhead 2 

Shrubs 

‘Big sagebrush ( Artemisia tridentata wyomingensis) 0.5 

‘Big sagebrush ( Artemisia tridentata vaseyana) at sites above 7,000' 0.5 

‘Fourwing saltbush ( Atriplex canescens) Wytana 1 

‘Antelope bitterbrush ( Purshia tridentata) Maybell 1 

‘Snowberry ( Symphoricarpos oreophilus) and/or ( Sym . Albus) 1 

*Winterfat ( Krascheninnikovia lanata) Open Range 0.5 

Forbs 

‘Lewis’ flax ( Linum lewsii) Appar 0.5+ 

‘Scarlet globemallow ( Sphaeralcea coccinea) 0.5+ 

‘American vetch ( Vicia americana) 0.5+ 

‘Lupine ( Lupinus sericeus) 0.5+ 

‘Blanketflower ( Gaillardia aristata) 0.5+ 

‘Western yarrow (Achillea millefolium L. var. occidentalis). Yakima 0.5+ 

‘Firecracker Penstemon ( Penstemon eatonii) Richfield 0.5+ 

‘White sage atrtemesia ludiciciana 0.5 

SANDY SITES - characterized as a sagebrush/bunchgrass community with 10 inches or greater 
precipitation. 

Species of Seed Variety Lbs. PLS* 

Grasses 

Western wheatgrass ( Agropyron smithii) Rosana 1 

Indian ricegrass ( Oryzopsis hymenoides) Rimrock (Nez Par) 2 

Green needlegrass ( Stipa viridula) 3 

Needleandthread ( Stipa comata) 2 

Slender wheatgrass ( Agropyron trachycaulum) Prior (Revenue) 2 


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APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


Species of Seed 

Grasses (cont. from previous pane) 

Variety 

Lbs. PLS* 

Mutton bluegrass (Poa fendleriana) 


0.5 

Sand dropseed ( Sporobolus cryptandrus) 

Borden County 

0.5 

Canby Bluegrass ( Poa Secunda) 

Canbar 

0.5 

Shrubs 

‘Silver sagebrush ( Artemisia cana) 


0.5 

‘Fourwing saltbush ( Atriplex canescens) 


1 

‘Antelope bitterbrush ( Purshia tridentata) 


1 

‘Winterfat ( Krascheninnikovia lanata) 

Open Range 

0.5 

‘White sage ( atrtemesia ludiciciana) 

Forbs 

‘Firecracker Penstemon ( Penstemon eatonii) 


0.5 

‘Lewis’ flax ( Linum lewsii) 

Appar 

0.5+ 

‘Rocky Mountain beeplant ( Cleome serrulata) 


0.5+ 

* Western yarrow (Achillea millefolium L. var. occidentalis DC.) 


0.5+ 

WET ALKALINE/SALINE SITES - characterized as a oreasewood community in a lowland location 

Species of seed 

Grasses 

Variety 

Lbs. PLS“ 

Western wheatgrass {Agropyron smithii) 

Rosana 

3 

Slender wheatgrass ( Agropyron trachycaulum) 

Pryor (Revenue) 

4 

Alkali sacaton ( Sporobolus airoides) 


0.5 

Inland saltgrass ( Distichlis spicata) 


2 

Basin wildrye ( Leymus cinereus) 

Trailhead 

2 

Shrubs 

‘Fourwing saltbush ( Atriplex canescens ) 

Wytana 

1 

Greasewood ( Sarcobatus vermiculatus) 


0.5 

MOUNTAIN SHRUB SITES - characterized as shrub community with deep loamy soils and qreater than 
14 inches of precipitation 

Species of Seed 

Grasses 

Variety 

Lbs. PLS“ 

Idaho fescue ( Festuca idahoensis) 


2 

Green needlegrass ( Stipa viridula) 


4 

Mountain brome ( Bromus carinatus) 

Garnet 

2 

‘Oniongrass ( Melica bulbosa) 


2 

Basin wildrye ( Leymus cinereus) 

Trailhead 

2 

Bluebunch wheatgrass ( Pseudoroegneria spicata) 

Goldar, Secor 

2 

Shrubs 

‘Wyoming Big sagebrush ( Artemisia tridentata wyomingensis) 


0.5 

* Mountain Big sagebrush ( Artemisia tridentata vaseyana) at sites above 7,000’ 

0.5 

* Silver sage (Artemisia cana) 


0.5 

‘Antelope bitterbrush ( Purshia tridentata) 

Maybell 

1 

‘Serviceberry ( Amelanchier alnifolia) 


1 

‘Chokecherry ( Prunus virginianna) 


1 

‘Winterfat ( Krascheninnikovia lanata) 

Forbs 

‘Arrowleaf balsamroot (Balsamhoriza sagittata) 

Open Range 

0.5 

‘Lewis’ flax ( Linum lewsii) 

Appar 

0.5+ 

‘Scarlet globemallow ( Sphaeralcea coccinea) 


0.5+ 

‘American vetch ( Vicia americana) 


0.5+ 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page A-1 1 


APPENDIX A. 

ATLANTIC RIM NATURAL GAS PROJECT RECLAMATION PLAN 


Species of Seed 

Variety 

Lbs. PLS** 

Forbs (cont. from previous paqe) 



*Lupine ( Lupinus sericeus) 


0.5+ 

*Blanketflower ( Gaillardia aristata) 


0.5+ 

* Western yarrow (Achillea millefolium L. var. occidentalis). 

Yakima 

0.5+ 

‘Firecracker Penstemon (Penstemon eatonii) 

Richfield 

0.5+ 


Notes: 

Total Lbs. PLS - Seed mixtures should total approximately 12-14 lbs. of pure live seed. 

** Pure Live Seed, drill seeded. For broadcast seeding, double the above rates. 

* These species can be used as alternatives to fulfill shrub and forb requirements, site-specific choices, or species 
required to fulfill a particular value (e.g., critical wildlife habitat). 


Page A-12 


Record of Decision for the Atlantic Rim Natural Gas Project 


Appendix B 


Atlantic Rim Natural Gas Project 
Performance-Based Monitoring 
and Best Management Practices 



APPENDIX B. 

PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


This appendix to the Atlantic Rim Record of Decision (ROD) lists the requirements that will be 
imposed, as appropriate, by the Bureau of Land Management (BLM), Rawlins Field Office 
(RFO) on all oil and gas development actions approved on federal lands and minerals within the 
Atlantic Rim Project Area (ARPA). These requirements include mitigation identified in specific 
resource mitigation subsections of chapter 4 of the Final Environmental Impact Statement 
(FEIS) for the ARPA. Other conditional requirements may also be imposed by the BLM pending 
site-specific review and may include Conditions of Approval (COAs), administrative 
requirements, and mitigation requirements found in the following appendices in the FEIS for the 
ARPA: 




Appendix B 
Appendix C 
Appendix E 
Appendix H 
Appendix I 
Appendix J 
Appendix K 


Reclamation Plan 

Hazardous Materials Management Plan 
Wildlife Monitoring and Protection Plan 
Best Management Practices 
Cultural Resources Management 

Best Management Practices for Reducing Non-Point Source Pollution 

Plan of Development / Detailed Proposed Action (See section K.1.3.7, 
Applicant Voluntarily Committed Measures) 


These appendices to the FEIS contain the tools available to the BLM for mitigating impacts of 
the development in the ARPA. These tools will be applied, as appropriate, upon approval of 
Applications for Permits to Drill (APDs) and based on site-specific review. Protective measures 
summarized in appendix L of the FEIS will be considered based on site-specific conditions, 
where such measures are not otherwise in conflict with this ROD. The remainder of this 
appendix to the ROD contains those requirements that will be imposed on APDs on federal 
lands and minerals within the ARPA. 


Authorizing Actions 

ARPA Operators are responsible for adhering to all applicable federal, state, and local laws and 
regulations and for obtaining all necessary federal, state, and county permits. Absent specific 
revisions in this ROD, Operators will comply with the management objectives, COAs, and 
mitigation measures identified in the BLM Great Divide Resource Management Plan (RMP) 
ROD (USDI-BLM 1990) to the extent feasible and practicable. 

Performance-Based Management 

The Atlantic Rim project will use a performance-based management approach that includes four 
primary elements, as outlined below: 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


1. Performance Goals: describes the conditions that the BLM and Operators will 

attempt to achieve. 

2. Performance Requirements: an extensive array of best management practices 

(BMPs), COAs and protective measures that may be used to achieve the 
Performance Goals. 

3. Performance-Based Monitoring: monitoring efforts to measure the degree of 

success the performance requirements have in achieving Performance Goals. 

4. Adaptive Management: application of additional mitigation or adaptive techniques to 
help achieve Performance Goals where needed. 

Implementation of the performance-based approach is described below. The BLM will attempt 
to achieve the following Performance Goals in collaboration with other state and federal 
agencies: 


Item 

Performance Goal 

Migration Routes 

maintain functional migration routes through or around development 
areas 

Big Game Crucial 
Winter Range 

provide an adequate amount of suitable undisturbed crucial winter 
range for big game animals 

Sage and Sharp- 
Tailed Grouse 

provide well-dispersed sage-grouse breeding, nesting, brood 
rearing, and winter habitat 

Muddy Creek 
Sensitive Fish 

maintain adequate water quality, water quantity, species distribution, 
and aquatic habitat components 

Shrub-Dependent 
Song Birds 

assure occupied habitat for shrub-dependent song birds is well- 
distributed throughout the project area 

Riparian 

ensure no net loss of native riparian habitat/vegetation 

Grazing 

maintain adequate and sustainable food and habitat for domestic 
animals 

Range Condition 

maintain range condition or improve range condition towards 
potential for the ecological site 

Livestock Safety 

minimize deaths and injuries of livestock due to development and 
operational activities 

Range 

Improvements 

minimize damage to range improvements, gates, cattle guards, 
water sources, and other livestock grazing management 
improvements 

Standards and 
Guidelines 

manage to meet Wyoming Healthy Rangeland Standards 

Sites 

maintain viable site-stabilizing native plant growth 

Species 

Composition 

maintain a range of species composition, diversity, cover, and 
production equal to pre-disturbance levels 

Weeds 

maintain weed-free sites 


Adaptive Management 

The BLM will implement a performance-based, adaptive management process for the ARPA 
whereby incremental adjustments will be made to mitigation and management restrictions 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


based upon how the environment responds to future development and performance 
requirements. The potential value of adaptive management to the National Environmental 
Policy Act (NEPA) process is discussed by Carpenter (1997) and is strongly supported by a 
number of agencies at the national level, including BLM, United States Environmental Protection 
Agency (USEPA), and United States Department of Agriculture-Forest Service (USDA-FS). 
Carpenter summarized, “It is increasingly recognized that human interventions into natural 
systems seldom proceed as originally planned. Scientific uncertainties prevent environmental 
impacts from being reliably or precisely predicted. Thus, the style of management must provide 
for monitoring to guide mid-course corrections in adapting to inevitable surprises.” Council on 
Environmental Quality (CEQ) NEPA regulations require continual monitoring. 

Throughout the life of the project, monitoring data will be reviewed to determine if mitigation is 
leading to the achievement of reclamation and performance goals. The adaptive management 
process will use this data to enable the development of management changes. Following 
submission of development plans (APDs, Sundry notices, etc.) specific COAs, BMPs, and other 
mitigations will be determined and applied for each specific site during on-site reviews. These 
on-the-ground reviews offer BLM resource specialists the opportunity to anticipate the potential 
effects of development and apply those measures judged necessary to reduce the adverse 
effects of development at the site. The specific measures (COAs, BMPs, etc.) that are best 
suited for reducing adverse effects will vary by site, based on conditions found at the specific 
site, such as the presence of sensitive soils, wildlife issues, aspect, slope, nature of the specific 
action proposed, and many other factors. 

While the activities planned for the ARPA, including most mitigation measures, are common and 
their effects generally well known, variations in site and climatic conditions, unknown conditions, 
and other factors can result in variations in reclamation success. Therefore, new techniques 
and technology to reduce oil and gas development impacts can and will be implemented as they 
become available. For those sites where known mitigations are not as effective as desired, 
monitoring and application of adaptive management will be used to change the mitigation 
approach using different or new techniques that provide the BLM with a mechanism to increase 
the success of reclamation in the ARPA. 

As information is gained about how area resources are reacting to reclamation activities and 
mitigations, the adaptive management process allows for changes in management without 
further NEPA analysis, unless development thresholds, such as the number of wells and 
disturbance limits, are reached. The process enables managers to rapidly adjust mitigation and 
management restrictions for unanticipated impacts or reclamation successes. The adaptive 
management framework has several continuous, looping steps: 

• Implement the decision; 

• Monitor impacts; 

• Evaluate monitoring data; 

• Recommend modifications to mitigations or management restrictions based on 
monitoring data; 

• Develop and implement adaptive management decision; 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


• Monitor impacts of adaptive management decision and further evaluate monitoring 
data, etc. 

The overall purpose of this adaptive management process is to ensure that impacts of 
development and production are monitored, and the information from that monitoring is 
evaluated and incorporated, on a regular basis, into future mitigation and management 
decisions. Specific performance-based monitoring requirements and BMPs are summarized by 
discipline in the following sections. 

Land Use/Surface Disturbance 

1 . Surface disturbance in the ARPA is limited to 7,600 acres (2.8 percent of the project 
area) at any given time. Total surface disturbance through the life of the project is 
estimated to be 13,600 acres. Initial site disturbance from oil and gas development 
activities (resource roads, well sites, gas gathering pipelines, compressor stations, 
etc.) will be limited to a short-term disturbance goal of 6.5 acres per well site. In 
Category A areas (ROD, figure 2) initial site disturbance will be further limited to less 
that 6.5 acres per well site (FEIS, section 2.2.4). Well sites are defined as the 
relatively flat, contiguous work area containing equipment and facilities used to drill 
one or more wells used in oil and gas production. 

2. Once the surface disturbance limit is reached, further development will cease until 
disturbed land has been reclaimed according to the reclamation standards 
established by the BLM for the ARPA (appendix A, Reclamation Plan). 

3. Natural gas development is limited to eight well sites per 640-acre section. 
Operators can install multiple well-bores (e.g., coalbed natural gas (CBNG), 
conventional, or injection) on a single well site (FEIS, section 2.2.4). 

4. Operators will track surface disturbance acreage (including total disturbance and 
successful interim reclamation) and provide BLM with Federal Geographic Data 
Committee (FGDC)-compliant metadata and geographic information system/global 
positioning system (GIS)/(GPS) showing the “as-built” location data for all newly 
developed facilities and reclaimed areas annually no later than December of each 
year based upon successful reclamation (appendix A, Reclamation Plan). 

5. Within 30 days of approval of this ROD, Operators will provide BLM with a map of 
the existing disturbance associated with activities authorized as part of the interim 
drilling policy. This map will serve as the baseline level of disturbance and will be 
updated annually. 

6. By April 1 of each year, Operators will provide the BLM RFO annual operating plans 
for the following year that include the following information: 

a. All previous year activity to include number of wells drilled; total new surface 
disturbance by well pads, roads, and pipelines; and current status of all 
reclamation activity and 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


b. Plan of Development for the upcoming year, along with conceptual, multi-year 
development plans to include planned number of wells to be drilled and an 
estimate of new surface disturbance and reclamation activity. 

7. Operators will remove/vacuum fluids from reserve pits and complete backfill and 
reclamation within 180 days from well completion or they must notify the BLM’s 
Authorized Officer. In all cases, fluids will be removed as soon as practical. 

Paleontological Values 

1. Each proposed facility located in areas with known and/or potentially significant 
paleontological resources (Paleontology Condition 1 and 2 areas and Probable 
Fossil Yield Class 4 and 5 areas) will be surveyed by a BLM-approved paleontologist 
prior to surface disturbance (FEIS appendix H). 

2. Any significant fossils or localities previously known or discovered during the survey 
will be avoided by the permitted activity, or fully mitigated prior to allowing the activity 
to proceed (FEIS appendix H). 

3. If paleontological resources are discovered at any time during construction, all 
construction activities will halt and BLM personnel will be immediately notified. Work 
will not proceed until paleontological materials are properly evaluated by a qualified 
paleontologist. In addition, the site will be protected from further damage or looting 
(FEIS appendix H). 

Air Quality/Dust 

1. In cooperation with Wyoming Department of Environmental Quality, Air Quality 
Division (WDEQ-AQD), Operators will finance and operate air quality monitoring in 
the RFO area including NOx, 0 3 , PM 10 and S0 2 (FEIS, chapter 4). 

2. The BLM will work cooperatively with state and other federal agencies, and with 
industry, to track emissions in the BLM RFO area (FEIS, chapter 4). 

3. If future air monitoring shows ozone exceedances attributable at least in part to 
sources in the ARPA, BLM will consult with WDEQ-AQD, USEPA, USDA-FS, and 
NPS to determine whether adaptive management will be needed to mitigate impacts 
(FEIS, chapter 4). 

4. Operators may use any and all approved, practical, and effective methods to control 
fugitive dust. This may include, but is not limited to: 

• Operators may use water or chemicals to control dust in the demolition of 
structures, in construction operations, grading of roads, or clearing of land 
(FEIS appendix J). 

• Operators may use water for dust abatement on a case-by-case basis. The 
water should meet state standards for this use and be permitted by the state of 
Wyoming. Only the water needed for abating dust should be applied; this 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


method will not be used as a water disposal option under any circumstances. 
There will be no traces of oil or solvents in water used for dust abatement 
(FEIS appendix J). 

• Operators will use all-weather surfacing on roads (gravel or asphalt paving) and 
will apply water or suitable chemicals to keep dust in place on roads or material 
stockpiles (FEIS appendix J). 

• Operators will use appropriate road design including shape, drainage, and 
surface material to protect road bed from being eroded (FEIS appendix J). 

• When an air quality, soil loss, or safety problem is identified as a result of fugitive 
dust, Operators will initiate immediate abatement (FEIS appendix K). 

Soils/Water 

1 . The Atlantic Rim operator responsible for new development around existing pods will 

submit a Water Management Plan as part of the Annual Work Plan submittal in April. 

This plan will have the following information (FEIS appendix H): 

• 1 2-digit hydrologic unit code (HUC) number and name; 

• All GIS — compatible information included in the Annual Work Plan 
(FEIS appendix K); 

• Surface water assessment of the current road network in the area including 
future plans for maintenance; 

• Average daily water production per well at current pod wells; 

• Average daily injection volumes of current injection wells, by well; 

• Unused injection well capacity; 

• Estimated water production from proposed wells; 

• Location, name, and estimated capacity of new injection wells; 

• Special Protection Measure for each well location, if applicable; 

• Any water quality sampling results; and 

• Anticipated permit requirements, and copies of existing permits for water-related 
activities required from Army Corps of Engineers (ACOE), other federal 
agencies, and/or the state of Wyoming. 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


2. Plans should be submitted and approved by BLM for surface disturbance in areas 
with slopes greater than 25 percent. Only those areas that cannot be avoided could 
be approved (FEIS appendix H). 

3. Culverts or low-water crossings will be installed for all ephemeral and intermittent 
drainage crossings. All drainage crossing structures and culverts will be designed to 
pass, at a minimum, the 25-year discharge events, or as otherwise directed by the 
BLM. Downstream armoring will be installed when necessary (FEIS appendix H). 

4. The design of channel crossings will minimize changes in channel geometry and 
subsequent changes in flow hydraulics. Disturbed channel beds will be regraded to 
the original geometric configuration with the same or very similar bed material. 
Downstream armoring will be installed when necessary (FEIS appendix H). 

5. Construction of drainage crossings will be limited to no-flow periods or low-flow 
periods (FEIS appendix H). 

6. Channel crossings for buried pipelines will be constructed using trenching techniques 
such that the pipe is buried a minimum of 4 feet below the channel bottom. To 
stabilize stream banks, appropriate — sized riprap will be placed from the channel 
bottom to the top of the normal high water line at all stream crossings. When 
excavating the crossing, separate the top 1-foot of stream bottom substrate from 
deeper soil layers and reconstruct the original layers by replacing deeper substrate 
first (FEIS appendix H). 

7. Adequate drainage control devices and measures will be included in the road design 
and maintenance (e.g., road berms and drainage ditches, diversion ditches, cross 
drains, culverts, out-sloping, and energy dissipaters) at sufficient intervals and 
intensities to adequately control and direct surface runoff above, below, and within 
the road environment to avoid concentrated flows (FEIS appendix H). 

8. Locations for these features will be proposed in Annual APD approval master plans 
submitted by the operator and will be identified specifically in construction plans after 
BLM on-site inspections (FEIS appendix H). 

9. Erosion control devices will also be used in conjunction with the surface runoff and 
drainage control devices, such as temporary barriers, ditch blocks, erosion stops, 
mattes, mulches, and vegetative covers. A revegetation program will be 
implemented as soon as possible to re-establish the soil protection afforded by a 
vegetal cover (FEIS appendix H). 

10. When an existing road, improved for travel, will reduce environmental impacts 
compared with a new route, it will be used and identified during annual planning and 
on-site inspections (FEIS appendix H). 

11. Culverts should be installed in road crossings for small ephemeral channels. All 
drainage and erosion mitigation should be designed for at least the 25-year 
discharge events, and should use, at a minimum, 18-inch culverts (with armored 
entrances and exits as necessary). Waterbars, waddles or haybales, and silt fences 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


can be used as needed to reduce surface runoff velocity and deposit sediment in the 
uplands to protect riparian areas, wetlands, and surface waters (FEIS appendix H). 

12. All potentially affected landowners having properly permitted water wells with the 
Wyoming State Engineer’s Office (SEO) within each proposed well’s circle of 
influence (one-half mile radius) were offered a water well agreement. If a water well 
agreement is not reached with the landowner, the responsible Atlantic Rim Operator 
will mitigate the impacts in accordance with state of Wyoming water laws. Some 
examples of mitigation will be drilling an additional supply well or provide CBNG 
water as an offset (FEIS appendix H). 

13. Completely reclaim all disturbed areas not needed for production activities including 
(FEIS appendix H): 

• Pipeline right-of-way (ROW), 

• Portion of road ROW not needed in the function of the road, and 

• The portion of the drill pad not needed during production. 

Reclamation of disturbed areas is specified in the Reclamation Plan presented in 
appendix A. Reclamation may generally include (FEIS appendix H): 

• Completing cleanup of the disturbed areas; 

• Restoring of topographic contours that existed prior to construction; 

• Ripping disturbed areas to a depth of 12 to 18 inches; 

• Replacing of topsoil or suitable plant growth material over all disturbed surfaces; 

• Seeding reclaimed areas with the seed mixture prescribed in the Surface Use 
Plan or Plan of Development for the proposed development; and 

• Mulching or adding soil amendments, if considered necessary by the BLM officer. 

14. All water used for drilling, completion, and testing activities will be free of 
hydrocarbons and come from CBNG wells, be re-used from other drilling sites, 
and/or come from sources approved by the BLM and subject to state permitting 
requirements. Only fresh water would be allowed for drilling to surface casing setting 
depth. New water sources would be considered for potential depletions to the Platte 
or Colorado River Basins as necessary (FEIS appendix H). 

15. All water used for construction, dust abatement, or hydrostatic testing will come from 
CBNG wells or sources with sufficient quantities and through appropriation permits 
approved by the State of Wyoming. Surface water and shallow groundwater sources 
for these uses and located in the Colorado River Basin and has been consulted on 
with the Fish and Wildlife Service (See FEIS, appendix G). Under no circumstances 
are these methods to be used for water disposal, only volumes appropriate for the 
use will be approved (FEIS appendix H). 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


16. Hydrostatic test water will be discharged in a controlled manner onto an energy 
dissipater and within existing ROWs. The water is to be discharged onto undisturbed 
land that has vegetative cover and with energy dissipation such as using a rock 
armored apron or gated pipe. Prior to discharge, water should be tested and treated 
or filtered if necessary to reduce pollutant levels or to settle out suspended particles 
if necessary. Operators will coordinate all discharge of test water with the SEO, 
WDEQ, and the BLM (FEIS appendix H). 

17. Avoidance areas for surface-disturbing and disruptive activities and linear crossings 
include the following (FEIS appendix H): 

• Identified 100-year floodplains; 

• Areas within 500 feet from perennial waters, springs, water wells, and wetland 
riparian areas, and 

• Areas 1 00 feet from the inner gorge of ephemeral channels. 

18. To minimize long-term surface disturbances within the vegetated sand dunes or 
other sensitive soils, options such as directional drilling, smaller well pads, and 
surface lines should be considered. To enhance reclamation success through 
surface stability, techniques to reduce wind erosion should be considered. These 
methods could include snow fences, soil tackifiers, and erosion control matting 
(FEIS appendix J). 

19. Identification of critical erosion condition areas during site-specific project analysis, 
and activity plan development for the purpose of avoidance and special management 
(FEIS appendix J). 

20. Temporary disturbances which do not require major excavation (e.g., small pipelines 
and communication lines) may be stripped of vegetation to ground level using 
mechanical treatment, leaving topsoil intact and root mass relatively undisturbed 
(FEIS appendix J). 

21. The Operators will minimize construction activities in areas of steep slopes and other 
sensitive soils, and apply special slope stabilizing structures if construction cannot be 
avoided in these areas (FEIS appendix K). 

22. Design cut slopes in a manner that will allow retention of topsoil, surface treatment 
such as mulch, and subsequent revegetation (FEIS appendix K). 

23. Selectively strip and salvage topsoil or the best suitable medium for plant growth 
from all disturbed areas on all well pads (FEIS appendix K). 

24. Include adequate drainage control devices and measures in the road design 
(e.g., road berms and drainage ditches, diversion ditches, cross drains, culverts, 
out-sloping, and energy dissipaters) at sufficient intervals and intensities to 
adequately control and direct surface runoff above, below, and within the road 
environment to avoid erosive concentrated flows. In conjunction with surface runoff 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


or drainage control measures, use erosion control devices and measures such as 
temporary barriers, ditch blocks, erosion stops, mattes, mulches, and vegetative 
covers. Implement a revegetation program as soon as possible to re-establish the 
soil protection afforded by a vegetal cover (FEIS appendix K). 

25. Upon completion of construction activities, restore topography to near pre-existing 
contours at the well sites, along access roads and pipelines, and other facilities sites. 
Replace topsoil or suitable plant growth material over all disturbed surfaces, and 
apply fertilizer as needed, and seed (FEIS appendix K). 

26. In accordance with the monitoring requirements for rangeland heath, depletions to 
the Colorado River Basin, and methane seep detection (section 4.4.5), the following 
shall be required in addition to initial drilling obligations and before any CBNG wells 
can be drilled in the unit/POD. The Unit Operator shall be responsible for drilling, 
completing, and equipping one set of three shallow groundwater-monitoring wells 
completed in water-bearing sandstone units stratigraphically above the principle 
producing coal beds in the upper Mesaverde Group. Specific surface locations, 
depths, and completion zones for each of the three groundwater monitoring wells in 
the set shall be determined in consultation with the RFO AO, and may only be drilled 
at a location where the oil and gas mineral estate is owned by the Federal 
Government. The groundwater monitoring well requirements are summarized as 
follows: 

a. Each well in the three well set will be completed in a stratigraphically different 
water-bearing sandstone. The sandstone strata should be a minimum of 10 feet 
thick. 

b. For each well in the three well set, the sandstone strata in which it is completed 
will typically be above the principal coal-bearing strata of the upper Mesaverde 
(e.g., typically above the coal-bearing strata of the Pine Ridge Sandstone). 

c. Completion interval(s) in the water-bearing sandstone units for each well will be 
identified by the RFO Authorized Officer (AO) in consultation with the Unit 
Operator from wireline logs for each well in the set. 

d. The minimum acceptable wire-line log suite for this purpose shall consist of 
calibrated and properly scaled (according to industry standards) high-resolution 
resistivity with spontaneous potential, gamma-ray curves, a high-resolution 
neutron density with photoelectric, and caliper curves. The density curve logging 
speed through the coals shall be no greater than 30 feet per minute. Digital las 
format logs shall be submitted to the WSO-RMG and the RFO; paper copies 
shall be submitted to the RFO. 

e. Each groundwater monitoring well shall be drilled, cased, and completed in 
accordance to BLM RFO specifications. 

f. Because the pressure gradient may be greater than 0.433 psia per foot and the 
rocks penetrated may contain natural gas, the Unit Operator shall drill the 
groundwater monitoring wells in accordance to Onshore Order #2 and all 
applicable regulations in a manner to prevent the possibility of a blowout. 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


g. The groundwater monitoring wells shall be equipped with the appropriate 
monitoring equipment and shelters approved by the RFO’s AO in consultation 
with the Unit Operator before any CBNG wells can be produced in the unit/POD. 

h. Additional information regarding the drilling and completion of the groundwater 
monitoring wells, the standard equipment required for the completed 
groundwater monitoring wells, and information on additional requirements for the 
groundwater monitoring wells can be obtained from the AO, Rawlins Field Office, 
Rawlins, Wyoming. 

Reclamation 

BLM reclamation goals emphasize eventual ecosystem reconstruction, which means returning 
the land to a condition approximate to or better than that which existed before it was disturbed. 
Final reclamation measures are used to achieve this goal. Interim reclamation measures are 
used to achieve the short-term goal of quickly stabilizing disturbed areas to protect both 
disturbed and adjacent undisturbed areas from unnecessary degradation. Specific guidance on 
reclamation within the ARPA is presented in appendix A. The following sections summarize the 
key goals and requirements for reclamation activity within the ARPA: 

1. One of the most important principles for successful restoration is to limit initial 
disturbance. Restoration planning should start before disturbance and be an integral 
part of the operational plan. Consideration of the processes necessary for 
successful reclamation is important. Pre-disturbance surveys, site stabilization, 
weed control, and maintenance and health of soils are important considerations. 
Revegetation that considers vegetative succession to pre-disturbance vegetative 
conditions, with annual monitoring and reporting, will allow tracking of success and 
adaptive management of problem areas (appendix A). The Operators are 
responsible for reclamation monitoring and reporting costs. 

2. For each discrete site where ground-disturbing activities are planned or occur under 
the Operators, a site-specific reclamation plan shall be prepared, submitted, and 
approved by the BLM before the Operators disturb the environment. Guidance and 
requirements for this plan can be found in program-specific direction 
(USDI-BLM 1983). A project-wide reclamation plan may be considered if it 
addresses discrete site disturbances individually (appendix A). 

3. With the exception of active work areas, disturbed areas anticipated to be left bare 
and exposed will be stabilized to prevent soil erosion. In addition to mulch, silt 
fencing, waddles, hay bales, and other erosion control devices will be used on areas 
at risk to soil movement away from disturbed areas including fill slopes (appendix A). 

4. Reclamation actions will be implemented before the first growing season following 
disturbance with the goal of returning the land to a condition approximate to or more 
productive than that which existed before disturbance or to a stable and productive 
condition compatible with that described in the land use plan. During subsequent 
seeding for final vegetation reclamation, the project shall consider using desired 
shrubs and forbs. The reclamation plan will specify steps to be taken by the 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
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Operators prior to the beginning of the growing season, during the first growing 
season, and following each growing season (appendix A). 

• If the treatment area is found to be successfully reclaimed, the site will be 
checked for reclamation success at least annually after the growing season for at 
least five seasons. The site will also be checked for additional management 
needs including weed infestations/control needs. 

• If the reclamation area is not successfully reclaimed or otherwise requires further 
management activities to establish vegetation, the actions prescribed above will 
be implemented with appropriate modifications and further monitoring will occur 
until reclamation is found to be successful. 

5. The Operators will provide BLM with an annual report before January 31 st for all sites 
disturbed which will include copies of the completed individual site review forms or a 
BLM-approved electronic report, a summary of monitoring data and results, a BLM 
useable shapefile(s) or GIS layer(s) that details location, name, type, and extent of 
(appendix A): 

• New disturbances, 

• Unreclaimed disturbance, 

• New reclamation, 

• Failed or unsuccessful reclamation, 

• Locations of noxious/invasive weed infestation, and 

• Further vegetation treatments planned (e.g., mulching, matting, and weed 
control). 

6. Reclamation will be considered successful if the following Interim Reclamation 
criteria are met (appendix A): 

• 80 percent of predisturbance ground cover, 

• 90 percent dominant species*, 

• No noxious weeds present in the seeding, and 

• Erosion features equal to or less than surrounding area. 

*The vegetation will consist of species included in the seed mix, and/or occurring in 
the surrounding natural vegetation or as deemed desirable by the BLM in review and 
approval of the reclamation plan. The goal is no single species will account for more 
than 30 percent total vegetative composition. Vegetation canopy cover production 
and species diversity shall approximate the surrounding undisturbed area. 

Livestock Grazing/Range Management 

1 . Operators and their contractors will observe and promote adherence to speed limits 
in the project area, and erect signs in lambing/calving areas, shipping pastures, or 
adjacent to working corrals to warn vehicle Operators (FEIS, section 4.6. 5.4). 

2. The Operators will coordinate annually or more often when necessary with affected 
livestock operators to discuss (1) problems encountered during the past grazing 


Page B-12 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


season, (2) agreed-upon corrective actions, and (3) planned energy development 
and operations during the next grazing season. This meeting needs to occur on a 
date early enough to allow grazing permittees sufficient time to make decisions and 
allocate their resources for the upcoming grazing season (FEIS, section 4.6. 5. 4). 

3. The Operators will report damage to livestock and livestock facilities as quickly as 
possible to BLM and affected livestock operators (FEIS, section 4.6. 5.4). 

4. Operators will develop and employ prevention measures to avoid damaging fences, 
gates, and cattleguards (FEIS appendix H). 

5. Operators will report and correct any damage that occurs to rangeland improvement 
projects (FEIS appendix H). 

6. Prior to drilling, Operators will upgrade cattleguard gate width and load-bearing 
requirements to meet BLM Road Standards (BLM Manual 9113) (FEIS appendix H). 

7. For the protection of livestock, all pits and open cellars shall be fenced. Fencing 
shall be in accordance with BLM specifications (BLM Handbook 1741-1) 
(FEIS appendix H). 

Wildlife 

The Review Team (defined in the ROD as comprised of BLM (including interdisciplinary team 
members), cooperating and interested agencies, and the Operators) or BLM will identify the 
level of effort required for performance-based monitoring and develop a wildlife monitoring and 
protection plan (FEIS appendix E) for development in the ARPA. The goal of the plan is to 
avoid and/or minimize adverse impacts to wildlife by monitoring wildlife population trends and 
developing appropriate mitigation during the course of project development and operation. 
Implementation of the plan will allow land managers and project personnel opportunities to 
achieve and maintain desired levels of wildlife productivity and populations in the ARPA (e.g., at 
pre-project levels) by minimizing and/or avoiding potential adverse impacts to wildlife species. 
In addition, the implementation of this plan will facilitate the maintenance of a diverse 
assemblage of wildlife populations in the ARPA simultaneously with development of natural gas 
reserves. 

Funding for wildlife and habitat monitoring may be obtained from BLM internal sources, in 
collaboration with cooperating / interested agencies, from the voluntary participation of the 
Operators, or from outside sources that may have an interest or desire to participate and/or 
contribute, or from a combination of these sources. Operators are responsible for 
demonstrating successful achievement of Performance Goals. Early efforts are to be made to 
collect or consolidate resource data to form a baseline against which future monitoring efforts 
and data would be used to indicate trends. In the absence of sufficient data illustrating operator 
achievement of performance-based goals, the BLM will use a conservative approach when 
considering additional approvals. The following sections summarize the key requirements to 
monitor and protect wildlife in the ARPA from FEIS appendix E: 

1. In part to meet their responsibility to demonstrate achievement of Performance 
Goals, Operators will compile all resource data collected under the wildlife monitoring 
and protection plan (FEIS appendix E) and submit this data to the Review Team by 
October 15 of each calendar year. 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page B-13 


APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


2. Operators will complete draft annual reports for submittal to the Review Team by 
November 15 of each year. Annual reports will summarize annual wildlife inventory 
and monitoring results, note any trends across years, identify and assess protection 
measures implemented during past years, specify monitoring and protection 
measures proposed for the upcoming year, recommend modifications to the existing 
wildlife monitoring/protection plan based on the successes and/or failures of past 
years, and identify additional species/categories to be monitored. 

3. Operators will issue a final annual report to all potentially affected individuals and 
groups by early February of each year. 

4. A one day meeting will be organized by the Review Team and held in December (or 
as determined by the Review Team) of each year to discuss and modify, as 
necessary, proposed wildlife inventory, monitoring, and protection protocol for the 
subsequent year. 

Inventory & Monitoring 

Inventory and monitoring for wildlife and plant species within the ARPA will be conducted at a 
frequency dependent upon the level of development activity with increased frequency generally 
associated with increased levels of development. The following species or categories of 
species will be inventoried and monitored in the ARPA (FEIS appendix E): 

1 . Black-Footed Ferret: BLM biologists will determine the presence/absence of prairie 
dog colonies at each proposed development site during APD and ROW application 
field reviews. Prairie dog colonies in the project area will be mapped and burrow 
densities determined by a BLM-approved, operator-financed biologist, as necessary 
and in association with proposed development plans. Colonies that meet the United 
States Department of the Interior, Fish and Wildlife Service (USDI-FWS) criteria as 
potential black-footed ferret habitat (USDI-FWS 1989) in non-block cleared areas will 
be surveyed for black-footed ferrets by a USDI-FWS-certified, operator-financed 
surveyor prior to BLM authorizing disturbance of these colonies. 

2. Bald Eagle, Peregrine Falcon, and Ferruginous Hawk: Inventory and monitoring 
protocol for bald eagle, peregrine falcon, and ferruginous hawk will be as described 
for raptors. 

3. Greater Sage-Grouse & Columbian Sharp-Tailed Grouse: Greater sage- 
grouse/Columbian sharp-tailed grouse lek inventories will be conducted by the BLM 
and Wyoming Game and Fish Department (WGFD) or by a BLM-approved 
operator-financed biologist on the project area and a two mile/one mile buffer to 
determine lek locations every 5 years, or as deemed appropriate by the BLM. 

4. Mountain Plover: Mountain plover habitat will be mapped within proposed 
disturbance areas (as identified in annual reports) prior to development of these 
areas by the BLM or a BLM-approved operator-financed biologist. In addition, these 
areas will be surveyed annually by the BLM or a BLM-approved operator-financed 
biologist to detect the presence of plovers. 


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APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


5. Western Burrowing Owl: Prairie dog colonies and other suitable burrowing owl 
nesting areas on and within 0.75 miles of existing and proposed disturbance areas 
will be searched for western burrowing owls by the BLM or a BLM-approved, 
operator-financed biologist or during June through August to determine the presence 
or absence of nesting owls. 

6. Other TEC&SC Species: Surveys for other threatened, endangered, candidate, and 
other species of concern (TEC&SC) species will be conducted by the BLM or a 
BLM-approved, operator-financed biologist/botanist in areas of potential habitat 
within one-half mile of proposed disturbance sites prior to disturbance. 

7. Raptors: Raptor inventories will be conducted by the BLM or a BLM-approved, 
operator-financed biologist at least every five years or prior to development 
of proposed disturbance areas (as identified in annual reports) to determine the 
location of raptor nests. Raptor nest monitoring will be conducted by the BLM or a 
BLM-approved, operator-financed biologist annually at known nest locations between 
April and July in order to ascertain nest activity status. 

8. Big Game Crucial Winter Range: Data on big game use of crucial winter ranges 
on the project area and an adjacent one-mile buffer will be requested annually by the 
BLM from the WGFD, as deemed necessary by the BLM. 

9. Other Inventory and Monitoring Measures: Additional inventory and monitoring 
measures may be applied for other wildlife and plant species as specified in annual 
reports. Surveys will be conducted in adherence with protocols to be established by 
the BLM, other agencies, and Operators. Operators may provide financial 
assistance for these investigations. 

10. General Wildlife: BLM staff will be responsible for maintaining records of selected 
wildlife species observed during the course of their activities on the project area. 

Wildlife Protection Measures 

Wildlife protection measures were developed from past measures identified for oil and gas 
developments in Wyoming. Additional measures may be included and/or existing measures 
may be modified in any given year as allowable and as deemed appropriate by BLM in 
consultation with other agencies, Operators, and interested parties (FEIS appendix E). 

1 . Black-Footed Ferret: In general, all prairie dog colonies on the project area will be 
avoided, where practical. If prairie dog colonies, in non-block-cleared areas of 
sufficient size and burrow density for black-footed ferrets are scheduled to be 
disturbed, black-footed ferret surveys of these colonies will be conducted pursuant to 
BLM and/or USDI-FWS decisions made during informal consultations. 

• If black-footed ferrets are found on the project area, the USDI-FWS will be 
notified immediately and formal consultations will be initiated to develop 
strategies that ensure no adverse effects to the species. 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page B-15 


APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


• Before ground-disturbing activities are initiated in black-footed ferret habitat, 
authorizations to proceed must be received from the BLM, in consultation with 
the USDI-FWS. 

2. Bald Eagle, Peregrine Falcon, and Ferruginous Hawk: Protection protocol for 
these species will be the same as described for raptors. 

3. Greater Sage-Grouse & Columbian Sharp-Tailed Grouse: 

• Surface disturbance or occupancy will be prohibited within one-quarter mile of 
the perimeter of occupied leks; 

• Human activity will be avoided between 6:00 p.m. and 9:00 a.m. from March 1 to 
May 20 within one-quarter mile of the perimeter of occupied leks; 

• Surface disturbance and other actions that create permanent and high-profile 
structures, such as buildings, storage tanks, and overhead power lines, will not 
be constructed within 0.25 to 1.0 mile of the perimeter of leks, as determined on 
a case-by-case basis; 

• Surface disturbing and disruptive activities will not be allowed within two miles of 
an occupied greater sage-grouse lek or in nesting and early brood-rearing habitat 
associated with individual leks (when identified and delineated) from March 1 to 
July 15; 

• Surface disturbing and disruptive activities will not be allowed within one mile of 
an occupied Columbian sharp-tailed grouse lek or in nesting and early brood- 
rearing habitat associated with individual leks (when identified and delineated), 
from March 1 to July 15; 

• Surface disturbing and disruptive activities will not be allowed between 
November 15 and March 14 in delineated winter concentration areas. In order to 
minimize noise disturbances to strutting or dancing grouse, compressor stations 
and generators will be muffled with hospital-style mufflers. 

4. Mountain Plover: 

• Mountain plover habitat will be avoided where practical. 

• All surface-disturbing activities will be restricted from April 10 to July 10 in 
mountain plover habitat. 

5. Western Burrowing Owl: Protection protocol for this species will be as described 
for raptors as well as avoidance of prairie dog colonies, where practical. 

6. TEC&SC Species: If crucial features for any TEC&SC species are found during 
surveys of areas within one-half mile of proposed disturbance sites, avoidance of 
these features will be accomplished in consultation and coordination with the BLM, 
USDI-FWS, and WGFD. 


Page B-16 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


7. Raptors: The primary protection measure for raptor species on the project area will 

be avoidance of nest locations during the breeding season. 

• All surface-disturbing activities will be restricted from February 1 through July 31 
within a 0.75 to 1.0 mile radius of raptor nests, depending upon the species. In 
addition, well locations, roads, ancillary facilities, and other surface structures 
requiring a repeated human presence will not be constructed within 825 feet of 
raptor nests, except ferruginous hawk, where the restriction will be 1,200 feet 
(restrictions will generally exclude surface disturbance). 

• Operators will notify the BLM immediately if raptors are found nesting on or within 
1 ,200 feet of project facilities and assist the BLM as necessary in erecting 
artificial nesting structures (ANSs), as appropriate. The use of ANSs will be 
considered as a last resort for raptor protection. If nest manipulation or a 
situation requiring a "taking" of a raptor nest becomes necessary, a special 
permit will be obtained from the Denver USDI-FWS Office, Permit Section, and 
will be initiated with sufficient lead time to allow for development of mitigation. 
Required corresponding permits will be obtained from the WGFD in Cheyenne. 
Consultation and coordination with the USDI-FWS and WGFD will be conducted 
for all protection activities relating to raptors. 

• Any power line construction will follow the recommendations of the Avian Power 
Line Interaction Committee (APLIC 1994; 1996) and Olendorff et al. (1981) to 
avoid collisions and electrocution of raptors. 

8. Big Game Species: 

• No construction activities or prolonged maintenance actions will be conducted 
within big game crucial winter range during the crucial winter periods of 
November 1 5— April 30. 

• If ROW fencing is required, it will be kept to a minimum, and the fences will meet 
BLM/WGFD approval for facilitating wildlife movement. Wildlife-proof fencing will 
be used only to enclose areas that are potentially hazardous to wildlife species or 
reclaimed areas where it is determined that wildlife species are impeding 
successful vegetation establishment. 

• Snow fences, if used, will be limited to segments of one-quarter mile or less. In 
addition, escape openings will be provided along roads in big game crucial winter 
ranges, as designated by the BLM, to facilitate exit of big game animals from 
snowplowed roads. 

9. General Wildlife: Unless otherwise indicated, the following protection measures will 

be applied for all wildlife species: 

• All roads on and adjacent to the project area that are required for the proposed 
project will be appropriately constructed, improved, maintained, and signed to 
minimize potential wildlife/vehicle collisions and facilitate wildlife (most notably 
big game) movement through the project area. 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page B-17 


APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


• Appropriate speed limits will be adhered to on all project roads, and Operators 
will advise employees and contractors regarding these speed limits. 

• To protect important habitat in portions of the project area (i.e., ephemeral draws 
dominated by basin big sagebrush) areas with sagebrush greater than 3 feet tall 
will be avoided where possible. 

10. Additional non-species-specific wildlife mitigations include the following: 

• Reserve, work-over, flare pits, and other locations potentially hazardous to 
wildlife will be adequately protected by netting or fencing, as directed by the 
BLM, to prohibit wildlife access. 

• If dead or injured raptors, big game, migratory birds, or unusual wildlife are 
observed on the project area, operator personnel will contact the appropriate 
BLM and WGFD offices. Under no circumstances will dead or injured wildlife be 
approached or handled by operator personnel. 

• Employee and contractor education will be conducted regarding wildlife laws. If 
violations are discovered on the project area, Operators will immediately notify 
the appropriate agency. If the violation is committed by an employee or 
contractor, said employee or contractor will be disciplined and may be dismissed 
by the operator or prosecuted by the WGFD or USDI-FWS. 

Operators will implement policies designed to control off-site activities of operational personnel 
and littering, and will notify all employees (contract and company) that conviction of a violation 
can result in disciplinary action including dismissal. 

Visual Resource Management 

For areas within the ARPA that are visible from state, county, and BLM roads (Visual Resource 
Management (VRM) Class III) the following protection measures (FEIS appendix H) will be 
applied, as appropriate: 

1. Gravel road surfacing shall be similar in color to adjacent dominant soil colors. 

2. Avoid locating pads in areas visible from state, county or BLM roads. 

3. Avoid locating facilities on or near ridgelines - use subsurface or low-profile facilities 
to prevent protrusion above horizon line when viewed from any state, county or BLM 
road. 

4. Avoid routing well access roads directly from state, county, or BLM roads. 

5. Co-locate wells when possible. 

6. Locate facilities far enough from the cut and fill slopes to facilitate re-contouring for 
interim reclamation. 


Page B-18 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


7. Do not locate wells adjacent to prominent features such as rock outcrops. 

8. Repeat elements of form, line, color, and texture to blend facilities and access roads 
with the surrounding landscape. 

9. Complete annual transportation plan for the entire area before beginning 
construction — make layout that will minimize disturbance and visual impact. 

10. Use remote monitoring to reduce traffic and road requirements. 

1 1 . Remove unused equipment, trash, and junk immediately. 

12. Reclaim unnecessary access roads as soon as possible. 

13. All above-ground structures, production equipment, tanks, transformers, and 
insulators not subject to safety requirements shall be painted to blend with the 
natural color of the landscape (except for structures that require safety coloration in 
accordance with Occupational Safety and Health Administration (OSHA) 
requirements (FEIS appendix K)). The paint used shall be a non-reflective “Standard 
Environmental Color” approved by the BLM VRM specialist. 

14. Do not create unnecessary cut and fill. Design and construct all new roads to a safe 
and appropriate standard “no higher than necessary” to accommodate their intended 
use. 

Cultural/Historic Resources Protection 

The following mitigation measures will be incorporated into an agreement or agreements to be 
established under the Wyoming state cultural resources protocol between the BLM, the State 
Historic Preservation Office (SHPO), project proponents, and interested parties to address 
site-specific impacts and mitigation measures for all sites where setting contributes to National 
Register of Historic Places (NRHP) eligibility: 

1 . Brush hog all ROWs (FEIS chapter 4 and appendix H). 

2. Allow no surface disturbance within a quarter mile of contributing segments of 
historic trails or trail-associated sites (FEIS chapter 4 and appendix H). 

3. Limit trail crossings to existing disturbance corridors or non-contributing segments, 
unless otherwise determined by BLM in consultation with SHPO (FEIS chapter 4 and 
appendix H). 

4. Use matting on ROWs during construction to minimize surface disturbance and 
visibility (FEIS chapter 4 and appendix H). 

5. If a site is considered eligible for, or is already on the NRHP, avoidance is the 
preferred method for mitigating adverse effects to that property (FEIS appendix K). 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page B-19 


APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


FEIS appendix I, Cultural Resources Management, describes BLM’s program to inventory, 
evaluate, and manage cultural resources on BLM-administered public land and other areas of 
BLM responsibility. This appendix also includes further discussion of standard protective 
measures, BMPs, and mitigation for cultural resources sites. BLM’s program includes a specific 
requirement to conduct cultural resource inventories for actions with federal responsibility to 
identify cultural resources prior to any ground disturbing activity. 

Socioeconomic 

1. Coordinate project activities with ranching operations to minimize conflicts involving 
livestock movement or other ranch operations. This would include scheduling project 
activities to minimize potential disturbance of large-scale livestock movements. 
Establish effective and frequent communication with affected ranchers to monitor 
and correct problems and coordinate scheduling (FEIS appendix K). 

2. As part of the annual planning process, Operators will provide multi-year field 
development forecasts to the BLM. These forecasts will be made available to local 
government agencies to assist in local community/county/state planning efforts (FEIS 
section 2.2.4). 

Transportation 

A coordinated transportation plan will be developed for the ARPA as part of the annual planning 
process to minimize construction of new roads, foster proper sizing of roads, and assign road 
maintenance responsibilities. Transportation planning would continue to occur on an annual 
basis. 

1. Operator responsibilities for preventive and corrective maintenance of roads in the 
ARPA would extend throughout the duration of the project and include blading; 
cleaning ditches and drainage facilities; dust abatement; control of noxious and 
invasive species; maintenance of fences, gates, and cattle guards; and other 
requirements as directed by the BLM, Wyoming Department of Transportation 
(WYDOT), Carbon County, and private landowners (FEIS chapter 4). 

Noise 

1. In any area of operations where noise levels may exceed federal OSHA safe limits, 
the Operators and their contractors would provide and require the use of proper 
personnel protective equipment by employees (FEIS chapter 4). 


Page B-20 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX B. PERFORMANCE-BASED MONITORING 
AND BEST MANAGEMENT PRACTICES 


References 

APLIC 1994. Mitigating Bird Collisions with Power Lines: The State of the Art in 1994. Avian 
Power Line Interaction Committee. Edison Electric Institute, Washington, D.C. 78 pp. + 
appendices. 

APLIC 1996. Suggested Practices for Raptor Protection on Power Lines: The State of the Art 
in 1996. Avian Power Line Interaction Committee. Edison Electric Institute/Raptor 
Research Foundation, Washington, D.C. 125 pp. + appendices. 

Carpenter, R.A. 1997. “The Case for Continuous Monitoring and Adaptive Management Under 
NEPA.” In Environmental Policy and NEPA. R. Clark and L. Canter, eds. Boca 
Raton, FL: St. Lucie Press. 

Olendorff, R.R., A.D. Miller, and R.M. Lehman 1981. Suggested Practices for Raptor Protection 
on Power Lines: The State of the Art in 1981. 

USDI-BLM 1983. Onshore Oil and Gas Order No. 1: Approval of Operations on Onshore 
Federal and Indian Oil and Gas Leases, Section lll(G)(10). 43 CFR 3160. United States 
Department of Interior, Bureau of Land Management. October 1983. 

USDI-BLM 1990. Great Divide Resource Area Record of Decision and Approved Resource 
Management Plan. Rawlins, Wyoming: U.S. Department of the Interior, Bureau of Land 
Management, Rawlins District Office, Great Divide Resource Area. 74pp. 

USDI-BLM 2006. Final Environmental Impact Statement for the Atlantic Rim Natural Gas 
Development Project, Carbon County, Wyoming. U.S. Department of the Interior, 
Bureau of Land Management, Rawlins Field Office. November 2006. 

USDI-FWS 1989. Black-footed Ferret Survey Guidelines for Compliance with the Endangered 
Species Act. Denver, Colorado, and Albuquerque, New Mexico:U.S. Fish and Wildlife 
Service. April 1989. 10 pp. + appendices. 


Record of Decision for the Atlantic Rim Natural Gas Project 


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Appendix C 
Operator-Committed Practices 






APPENDIX C. OPERATOR-COMMITTED PRACTICES 


The Final EIS for the Atlantic Rim Natural Gas Project (ARNG) contains best 
management practices and other environmental protection measures that would be 
implemented to protect the environment during the development and operation of the 
Atlantic Rim Project Area (ARPA). Many of these environmental protection measures 
would be included as Conditions of Approval (COAs) in this ROD. However, by 
additionally including them as Operator-committed practices, the various Operators have 
made a commitment to implement them throughout the life-of-project (LOP), and the 
impact analyses provided in the Final EIS take into consideration the implementation of 
these measures based on this commitment. 

In addition to Operator-committed environmental protection practices, the various ARPA 
leases often contain one or more stipulations that obligate the leaseholder. These lease 
stipulations are mandatory and address a number of issues, and may include but not be 
limited to seasonal and area restrictions for raptor nests, greater sage-grouse leks and 
nesting habitat, unstable soils, steep slopes, and controlled surface occupancy. These 
lease-specific stipulations may be duplicated by the more general measures listed 
below. 

To assure compliance with the Operator-committed practices stipulated in the FEIS, this 
ROD, and in site-specific APDs and ROWs, each Operator will provide qualified 
individuals to oversee construction and drilling operations and to consult with the BLM 
on a case-by-case basis, as necessary, during field development. Development 
activities on all lands would be conducted in accordance with all appropriate federal, 
state, and county laws, rules, and regulations. 

PRECONSTRUCTION PLANNING AND SITE LAYOUT 

Development activities proposed on fee and State of Wyoming surface lands would be 
approved by the Wyoming Oil & Gas Conservation Commission (WOGCC). The 
WOGCC permitting procedures require filing an APD with the WOGCC and obtaining an 
ROW from the surface owner. 

The Operators would follow the procedures outlined below to gain approval for proposed 
activities on BLM-administered lands or minerals within the ARPA. The procedures 
described below are applicable to CBNG drilling and production activities (1,800-well 
program) and the deeper conventional natural gas drilling and production activities (200- 
well program) unless otherwise noted. 

• Annual work plans for each developing or operational POD will be used instead of 
piecemeal individual APD filings. Each year on April 1, the Operators will submit to 
the BLM Rawlins Field Office comprehensive annual work plans for the following 
year, including APD packages and other appropriate permit application materials for 
the construction and development activities. The BLM, in conjunction with the 
Operators, will perform the usual on-site reviews and perform the other tasks 
necessary to prepare the program of work for site specific analysis under NEPA and 
permitting approval prior to the next drilling season. This procedure will allow for 
economies of scale with the NEPA process and provide a more comprehensive 
appraisal of the proposed action and their effects on the environment. This program 
should also reduce processing time for APDs. The Operators and the BLM will also 
assess and decide the method of analysis, including how the NEPA related work will 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page C-1 


APPENDIX C. OPERATOR-COMMITTED PRACTICES 


be performed (either in-house or through third party contractors). Otherwise 
unplanned construction needs that arise during the course of the year and outside of 
the annual plan may be brought forward and proposed by operators and will be dealt 
with by the BLM appropriately, however the intent is to normally avoid individual APD 
submission and consideration. 

Annual work or site specific plans for developing or operational PODs will include 
geo-referenced information compatible with ArcMap that details pad and well 
locations; pipeline routes; water transfer stations; road locations (resource, collector 
or local); road construction techniques (including gravel type and source); wing ditch, 
water bar and culvert placement, any closed system livestock watering facilities, any 
potential fence modification or cattle guard installations, injection well locations; and 
any existing infrastructure (wells, roads, pipelines etc.) in the townships receiving 
new development. 

• The proposed facilities would be staked by the Operators and inspected by an 
interdisciplinary team and/or an official from the BLM to ensure consistency with the 
approved RMP and oil and gas lease stipulations. 

• More detailed descriptions of the proposed activity or construction plans would be 
submitted to the BLM by the Operators when required for the proposed development. 
The plans would address concerns that may exist concerning construction 
standards, required mitigation, etc. Negotiation of these plans between the 
Operators and the BLM, if necessary to resolve differences, would be based on field 
inspection findings and would take place either during or after the BLM onsite 
inspection. Submissions of maps will include the associated GIS geo-referenced 
information. 

• The Operators and/or their contractors would revise APD/ROWs, as necessary, per 
negotiations with the BLM. The BLM would complete a project-specific 
environmental analysis that incorporates agreed upon construction and mitigation 
standards as detailed above. The BLM would then approve the annual proposal and 
attach the Conditions of Approval to the permit. The Operators must then 
commence the proposed activity within one year. 

APPLICANT VOLUNTARY COMMITTED MEASURES 

Following are applicant committed measures to avoid or mitigate resource or other land 
use impacts. An exception to a mitigation measure and/or design feature may be 
approved on a case-by-case basis when deemed appropriate by the BLM or in 
conjunction with the surface owner. An exception would be approved only after a 
thorough, site-specific analysis determined that the resource or land use for which the 
measure was put in place is not present or would not be significantly impacted. The 
Operators committed to implementing resource-specific mitigation measures on all lands 
within the ARPA including federal, State and private (fee) surface ownership. 

PRECONSTRUCTION PLANNING AND DESIGN MEASURES 

The Operators and the BLM would make on-site Interdisciplinary (ID) reviews of each 
proposed and staked facility site (e.g., well sites), new access road, access road 


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APPENDIX C. OPERATOR-COMMITTED PRACTICES 


reconstruction, and pipeline alignment projects so that site-specific recommendations 
and mitigation measures can be developed. 

• New road construction and maintenance of existing roads in the ARPA 
would be accomplished in accordance with BLM Manual 9113 standards 
unless private landowners or the State of Wyoming specify otherwise on 
their lands. 

• Consistent with the annual work planning described in FEIS section K.1.1, The 
Operators would prepare and submit an APD for each drill site on federal leases 
to the BLM for approval prior to initiation of construction. Also prior to 
construction, the Operators or their contractors would submit a Sundry Notice 
and/or ROW application for each pipeline and access road segment on federal 
leases. The APD would include a Surface Use Plan that would show the layout 
of the drill pad over the existing topography, dimensions of the pad, volumes and 
cross sections of cut and fill, location and dimensions of reserve pit, and access 
road egress and ingress. The APD, Sundry Notice, and/or ROW application plan 
would also itemize project administration, time frame, and responsible parties. In 
addition, a reclamation plan would be developed by the operators for each facility 
in consultation with the BLM. APD packages would be submitted annually on 
April 1, including GIS data specified in FEIS section K.1.1, for planning and 
analysis for the upcoming work year. 

RESOURCE-SPECIFIC REQUIREMENTS 

GEOLOGY /MINERALS 

Mitigation measures presented in the Soils and Water Resources sections would avoid 
or minimize many of the potential impacts to the surface mineral resources. Protection 
of subsurface mineral resources from adverse impacts would be provided by the BLM 
and/or WOGCC casing and cementing policy. 

AIR QUALITY 

• The Operators would not burn garbage or refuse at the drill sites or other 
facilities. 

• When an air quality, soil loss, or safety problem is identified as a result of fugitive 
dust, immediate abatement would be initiated. 

SOILS and WATER RESOURCES 

• Reduce the area of disturbance to the absolute minimum necessary for 
construction and production operations while providing for the safety of 
personnel. The Operators would prohibit off-road vehicle activity. 

• Generally, buried pipelines would be located immediately adjacent to roads to 
avoid creating separate areas of disturbance and in order to reduce the total area 
of disturbance. 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page C-3 


APPENDIX C. OPERATOR-COMMITTED PRACTICES 


• The operators would avoid using frozen or saturated soils as construction 
material. 

• The operators would minimize construction activities in areas of steep slopes and 
other sensitive soils, and apply special slope stabilizing structures if construction 
cannot be avoided in these areas. 

• Design cut slopes in a manner that would allow retention of topsoil, surface 
treatment such as mulch, and subsequent revegetation. 

• Selectively strip and salvage topsoil or the best suitable medium for plant growth 
from all disturbed areas on all well pads. 

• Where possible, minimize disturbance to vegetated cuts and fills on existing 
roads that are improved. 

• Install runoff and erosion control measures such as water bars, berms, and 
interceptor ditches if needed. 

• Implement minor routing variations during access road layout to avoid steep 
slopes adjacent to ephemeral or intermittent drainage channels. Maintain a 
buffer strip of natural vegetation where possible (not including wetland 
vegetation) between all construction activities and ephemeral and intermittent 
drainage channels. 

• Include adequate drainage control devices and measures in the road design 
(e.g., road berms and drainage ditches, diversion ditches, cross drains, culverts, 
out-sloping, and energy dissipaters) at sufficient intervals and intensities to 
adequately control and direct surface runoff above, below, and within the road 
environment to avoid erosive concentrated flows. In conjunction with surface 
runoff or drainage control measures, use erosion control devices and measures 
such as temporary barriers, ditch blocks, erosion stops, mattes, mulches, and 
vegetative covers. Implement a revegetation program as soon as possible to re- 
establish the soil protection afforded by a vegetal cover. 

• Upon completion of construction activities, restore topography to near pre- 
existing contours at the well sites, along access roads and pipelines, and other 
facilities sites. Replace topsoil or suitable plant growth material over all disturbed 
surfaces, and apply fertilizer as needed, and seed. 

• When feasible, limit construction of drainage crossings to no-flow periods or low- 
flow periods. 

• Minimize the area of disturbance within ephemeral and intermittent drainage 
channel environments. 

• Avoid construction of well sites, access roads, and pipelines within 500 feet of 
surface water and/or riparian areas. Exceptions to this would be granted by the 
BLM based on an environmental analysis and site-specific mitigation plans. 


Page C-4 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX C. OPERATOR-COMMITTED PRACTICES 


• Design channel crossings to minimize changes in channel geometry and 
subsequent changes in flow hydraulics. 

• Construct channel crossings for buried pipelines such that the pipe is buried a 
minimum of four feet below the channel bottom. 

• Regrade disturbed channel beds to the original geometric configuration with the 
same or very similar bed material. 

• Case wells during drilling, and case and cement all wells in accordance with 
State, and/or Federal regulations to protect accessible high quality aquifers. 
High quality aquifers are aquifers with known water quality of 10,000 ppm TDS or 
less. Include well casing and welding of sufficient integrity to contain all fluids 
under high pressure during drilling and well completion. Further, wells would 
adhere to the appropriate BLM or WOGCC cementing policy. 

• Reserve pits would be constructed so that a minimum of one-half of the total 
depth is below the original ground surface on the lowest point within the pit. To 
prevent seepage of fluids, drilling mud gel or poly liners would be used as 
needed to line reserve pits in areas where subsurface material would not contain 
fluids. Liners would be of sufficient strength and thickness to withstand normal 
installation and use. The liner would be impermeable (i.e., having a permeability 
of less than 10' 7 cm/sec) and chemically compatible with all substances which 
may be put in the pit. 

• Maintain 2 feet of freeboard on all reserve pits to ensure the reserve pits are not 
in danger of overflowing. Shut down drilling operations until the problem is 
corrected if leakage is found outside the pit. 

• Extract hydrostatic test water used in conjunction with pipeline testing and all 
water used during construction activities from sources with sufficient quantities 
and through appropriation permits approved by the State of Wyoming. 

• Discharge hydrostatic test water in a controlled manner onto an energy 
dissipator. The water is to be discharged onto undisturbed land that has 
vegetative cover, if possible, or into an established drainage channel. Prior to 
discharge, treat or filter the water to reduce pollutant levels or to settle out 
suspended particles if necessary. If discharged into an established drainage 
channel, the rate of discharge would not exceed the capacity of the channel to 
safely convey the increased flow. Coordinate all discharge to test water with the 
SEO and the BLM. 

• Develop and implement a Storm Water Pollution Prevention Plan (SWPPP) for 
storm water runoff at drill sites as required per WDEQ storm water NPDES 
permit requirements. 

• The Operators must coordinate with the Corps of Engineers (COE) to determine 
the specific Clean Water Act (CWA) Section 404 Permit requirements and 
conditions (including the potential requirement of compensatory mitigation) for 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page C-5 


APPENDIX C. OPERATOR-COMMITTED PRACTICES 


each facility that occurs in Waters of the U.S. to prevent the occurrence of 
significant impact to such waters. 

• Exercise precautions against pipeline breaks and other potential accidental 
discharges of toxic chemicals into adjacent streams. If liquid petroleum products 
storage capacity exceeds criteria contained in 40 CFR Part 112, a Spill 
Prevention Control and Countermeasures (SPCC) plan would be developed in 
accordance with 40 CFR Part 112. 

• The project must comply with all applicable requirements of the CWA, including 
the requirement to obtain an WYPDES permit. 

VEGETATION and WETLANDS 

• Seed and stabilize disturbed areas with mixtures and treatment guidelines 
prescribed in the approved APD, ROW, or surface landowner requirements. 

• Evaluate all project facility sites for occurrence and distribution of waters of the 
U.S., special aquatic sites, and jurisdictional wetlands. All project facilities would 
be located out of these sensitive areas. If complete avoidance is not possible, 
minimize impacts through modification and minor relocations. Coordinate 
activities that involve dredge or fill into wetlands with the COE. 

• Conduct site-specific surveys for federally listed threatened and endangered 
(T&E) and candidate plant species prior to any surface disturbance in 
accordance with the Endangered Species Act. 

RANGE RESOURCES AND OTHER LAND USES 

• The Operators would coordinate with the affected livestock operators to ensure 
that livestock control structures remain functional during drilling and production 
operations. 

WILDLIFE 

• During reclamation, establish a variety of forage species that are useful to 
resident herbivores by specifying the seed mixes in the approved APD, ROW or 
surface landowner requirements. 

• Discourage unnecessary off-site activities of operational personnel in the vicinity 
of the drill sites. 

VISUAL RESOURCES 

• Paint all structures with non-reflective colors that blend with the adjacent 
landscape, except for structures that require safety coloration in accordance with 
Occupational Safety and Health Administration (OSHA) requirements. 


Page C-6 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX C. OPERATOR-COMMITTED PRACTICES 


CULTURAL RESOURCES 

• If a site is considered eligible for, or is already on the National Register of Historic 
Places (NRHP), avoidance is the preferred method for mitigating adverse effects 
to that property. 

SOCIOECONOMICS 

• Coordinate project activities with ranching operations to minimize conflicts 
involving livestock movement or other ranch operations. This would include 
scheduling of project activities to minimize potential disturbance of large-scale 
livestock movements. Establish effective and frequent communication with 
affected ranchers to monitor and correct problems and coordinate scheduling. 

HEALTH AND SAFETY/HAZARDOUS MATERIALS 

The operators will establish and maintain an appropriate safety program for the intended 
work which will comply with all applicable Federal, State and local regulations, including 
but not limited to, RCRA, SPCC, SARA, Hazardous Substance Management. 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page C-7 































































Appendix D 


Formal and Informal Consultation for the 
Atlantic Rim Natural Gas Field Development Project 






In Reply Refer To: 


United States Department of the Interior / 

FISH AND WILDLIFE SERVICE 




>4 


ot 




Ecological Services 
5353 Yellowstone Road, Suite 308A 
Cheyenne, Wyoming 82009 


i 



AUG 0 9 



ES-6 1 4 1 1/W.02AVY06F0204 



— SD s 
' p &Ec 
■ '-SC 




Memorandum 


To: Mark Storzer, Field Manager, Bureau of Land Management, Rawlins Field 

Office, Rawlins, Wyoming 


From: 


Subject: 


Brian T. Kelly, Field Supervisor, U.S. Fish and Wildlife Seryjce^Wyoming 
Field Office, Cheyenne, Wyoming AjCv '*’* — •/" 


Formal and Informal Consultation for the Atlantic Rim Natural Gas Field 
Development Project 


Thank you for your letter of July 24, 2006, received in our office on July 25, with the biological 
assessment (BA) for the Final Environmental Impact Statement for the Atlantic Rim Natural Gas 
Field Development Project located in T13-20N, R89-92W, in Carbon County, Wyoming 
(Atlantic Rim FEIS). You requested consultation with the U.S. Fish and Wildlife Service 
(Service) pursuant to section 7(a)(2) of the Endangered Species Act of 1973, as amended (Act) 
(16 U.S.C. 1531 et seq .) for your determinations of effects to listed species in the BA. 


The letter and BA state that the preferred alternative for the Atlantic Rim FEIS consists of 
Anadarko Petroleum Corporation (APC) and other operators drilling 1800 coal bed natural gas 
(CBNG) wells and 200 deep conventional gas wells on approximately 270,000 acres of 
combined federal, state and private lands. The wells are proposed at eight wells per section (80- 
acre spacing) and will be developed over a 20-year period beginning in 2007 with an estimated 
life of project of 30 to 50 years. Well spacing may be reduced, where appropriate. Various 
drilling and production related facilities (i.e., roads, pipelines, water wells, disposal wells, 
compressor stations, and gas processing facilities) will also be constructed throughout the project 
area. 


In the BA, the Bureau of Land Management (Bureau) determined that project-related water 
depletions to the Colorado River system are “likely to adversely affect” Colorado River fish 
species. The Bureau also issued “not likely to adversely affect” determinations for the project’s 
potential effects to the bald eagle (Haliaeetus leucocephalus ), black-footed ferret ( Mustela 
nigripes), blowout penstemon ( Penstemon haydenii), and Ute-ladies’ tresses ( Spiranthes 
diluvialis). 


The Service concurs with the Bureau’s effects determination for the bald eagle because adverse 
effects are extremely unlikely to occur based on the Bureau’s commitment to implement the 
conservation measures and the limited use of the area by bald eagles. Conservation measures 
include (1) not installing overhead electric power lines, (2) training drivers how to minimize 
vehicle collisions with raptors, and (3) removing vehicle-killed carcasses from road areas to limit 
attraction of raptors. 

The Service concurs with the Bureau’s effects determination for the black-footed ferret because 
white-tailed prairie dog colonies that are not included in the block clearance will be surveyed for 
black-footed ferrets adhering to the Black-Footed Ferret Survey Guidelines (USFWS 1989). If 
the species is found, the Service will be notified within 24 hours and no project-related 
disturbance will occur within the prairie dog complex. Based on implementation of these 
commitments, adverse effects to the black-footed ferret are expected to be discountable. 

The Service concurs with the Bureau’s effects determinations for the blowout penstemon and 
Ute-ladies’ tresses because (1) both species have low probabilities of being present in the action 
area and (2) surveys and avoidance measures will be implemented to protect the species. Frank 
Blomquist, Bureau biologist, clarified, on August 9, 2006, that very little of the Sand Hills 
habitat for blowout penstemon is included within the proposed project area, and any area with 
potential habitat will be sur/eyed prior to development. He also clarified that the probability of 
Ute-ladies’ tresses being present in the project area is extremely low based on clayey soils and 
elevation (Pers. Comm. 2006). Based on these considerations, effects of the proposed action on 
these two species are discountable. 

To clarify water use for this project, the Service contacted Bob Lange and Frank Blomquist, of 
your office, on August 8, 2006. They stated that the Bureau determined that the produced water 
within the action area is not connected to the Colorado River system so that specific action would 
have no effect to Colorado River fish species. Service concurrence for no effect determinations 
is not required under the Act. They also clarified that the proposed action will cause an average 
annual depletion of 10.3 acre- feet from the Colorado River system due to surface water use for 
dust abatement and road/pad construction (Pers. Comm. 2006). A Recovery Implementation 
Program for Endangered Fish Species in the Upper Colorado River Basin (Recovery Program) 
was initiated on January 22, 1988. The Recovery program was intended to be the reasonable and 
prudent alternative to avoid jeopardy to the endangered fish by depletions from the Upper 
Colorado River. 

In order to further define and clarify the process in the Recovery Program, a section 7 agreement 
was implemented on October 15, 1993, by the Recovery Program participants. Incorporated into 
this agreement is a Recovery Implementation Program Recovery Action Plan (Plan) which 
identifies actions currently believed to be required to recover the endangered fish in the most 
expeditious manner in the Upper Colorado River Basin. 

A part of the Recovery Program was the requirement that if a project was going to result in a 
depletion, a depletion fee would be paid to help support the Recovery Program. On July 5, 1994, 
the Service issued a biological opinion determining that the fee for depletions of 100 acre-feet or 
less would no longer be required. This was based on the premise that the Recovery Program has 
made sufficient progress to be considered the reasonable and prudent alternative avoiding the 
likelihood of jeopardy to the endangered fishes and avoiding destruction or adverse modification 


2 


of their critical habitat by depletions of 100 acre-feet or less. Therefore, the depletion fee for 
this project is waived. 

Permits or other documents authorizing specific projects, which result in depletions, should state 
that the Bureau retains discretionary authority over each project for the purpose of endangered 
species consultation. If the Recovery Program is unable to implement the Plan in a timely 
manner, reinitiation of section 7 consultation may be required so that a new reasonable and 
prudent alternative can be developed by the Service. 

This concludes consultation pursuant to the regulations implementing the Act, 50 C.F.R. § 

402.14 and § 402.13. This project should be re-analyzed if new information reveals effects of the 
action that may affect listed species or designated or proposed critical habitat (1) in a manner or 
to an extent not considered in this letter, (2) if the action is subsequently modified in a manner 
that causes an effect to a listed species or designated or proposed critical habitat that was not 
considered in this consultation, and (3) if a new species is listed or critical habitat is designated 
that may be affected by this project. 

The Bureau made “no effect” determinations for the Canada lynx {Lynx candensis ), Preble’s 
meadow jumping mouse ( Zapua hudsonius preblei), Wyoming toad {Bufo baxteri), Colorado 
butterfly plant ( Gaura neomexicans spp. color adensis), and Platte P.iver species. Service 
concurrence for no effect determinations is not required under the Act; however, we do 
appreciate receiving information as to the status of these species in the project area. 

If you have further questions regarding your responsibilities under the Act, please contact Dan 
Blake of my staff at 1300 N. Third St., Rawlins, WY 82301 or phone (307) 328-4333. 


cc: FWS, Fish and Wildlife Biologist, Rawlins Field Office, Rawlins, WY (D. Blake) 

WGFD, Statewide Habitat Protection Coordinator, Cheyenne, WY (V. Stelter) 
WGFD, Non-Game Coordinator, Lander, WY (B. Oakleaf) 


References 

Pers. Comm. 2006. Phone calls between Blomquist, F. and B. Lange, Bureau of Land 

Management, Rawlins Field Office and K. Erwin and D. Blake, U.S. Fish and Wildlife 
Service, Ecological Services, Wyoming. 

U.S. Fish and Wildlife Service. 1989. Black-footed ferret survey guidelines for compliance with 
the Endangered Species Act, April 1989. U. S. Fish and Wildlife Service, Denver, 
Colorado and Albuquerque, New Mexico. 15pp. 


3 




Appendix E 


Summary of Public Comments on the 
Atlantic Rim Natural Gas Project 
Final Environmental Impact Statement 




APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


The Final Environmental Impact Statement (FEIS) for the Atlantic Rim Natural Gas Project 
(ARNG) was released for public review on December 1, 2006. The comment period closed on 
January 4, 2007. Organization and individuals who submitted comments on the ARNG FEIS 
during this time are identified in table E-1. 

Issue Summary 

Comments on the Atlantic Rim Project Area (ARPA) FEIS raised a variety of issues including 
use of mitigation measures, avoidance of cultural sites, the groundwater and wildlife impact 
analysis, wildlife, habitat and reclamation monitoring, rationale for selection of the preferred 
alternative, future public input, surface disturbance reclamation, air quality analysis and 
palentological condition and classification. A summary of significant comments and Bureau of 
Land Management (BLM) responses categorized by issue are summarized below. 

Mitigation Measures - Best Management Practices and Protective 
Measures 

Comment Summary: Several comments suggested the need for additional, modified or fewer 
Best Management Practices (BMPs) and protective measures to mitigate resource impacts and 
to help direct development practices. Comments also suggested involvement of state and 
federal wildlife agencies in the project planning process. 

Response: Drilling, development, and reclamation activities in the ARPA will be 

managed through a performance-based, adaptive management process as described in 
appendix B (Performance-Based Monitoring and Best Management Practices). The 
process includes a requirement for Operators to submit an annual operating plan to the 
BLM RFO AO. The overall purpose of this process is to meet resource management 
objectives and ensure that the Performance Goals are achieved to the greatest extent 
possible. A mitigation and monitoring process will be required, and its development will 
begin within 30 days of the effective date of the Record of Decision (ROD). This process 
will be developed by the Review Team (BLM, cooperating and interested agencies and 
Operators) and will provide quantifiable criteria to identify trends associated with the 
Performance Goals. The process will include the types of mitigation responses that will 
be considered in the event that monitoring data indicates a downward trend relative to 
the Performance Goals. Throughout the life of the project, monitoring data will be 
reviewed to determine if mitigation is effective and leading to the achievement of 
reclamation and Performance Goals. The monitoring data will be evaluated on a regular 
basis (at least annually) and BMPs, conditions of approval (COAs), protective measures, 
reclamation criteria, and mitigation measures may be modified, as appropriate, based on 
the monitoring results. 

While described as an “annual” planning process, this concept is adaptive and open for 
modification and improvement, including more frequent planning meetings if necessary. 

The intent of the process is to have future, site-specific development plans for Atlantic 
Rim be submitted to the BLM for review in a manner that will allow the BLM to capture 
economies of scale in planning, processing, approving, and involving other cooperating 
agencies. The BLM (including interdisciplinary team members), cooperating and 
interested agencies, and the Operators will make up a Review Team to evaluate annual 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page E-1 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


and site-specific development proposals and monitoring reports. By receiving 
development proposals in groups, the Review Team will be able to develop a more 
holistic view of future development and reclamation progress and success, and more 
effectively apply mitigations and BMPs to reduce development effects. Proposals should 
span several years or stages of development and must include the entire proposal 
including well sites, compressor stations, utility and pipeline corridors, roads, status and 
success of reclamation efforts for a specific area, and any other disturbances planned 
and their timing. The review and approval process will include a site specific visit by the 
Review Team, NEPA or Categorical Exclusion (pursuant to section 390 of the Energy 
Policy Act of 2005) evaluation, as appropriate, and establishing required BMPs, COAs or 
other protective measures to mitigate environmental impacts. (See ARNG ROD: Plan, 
Review and Approval Process ; and Mitigation Measures) 

Cultural 

Comment Summary: Some comments suggested that BLM should consider avoidance of 
cultural areas as a first course of action prior to use of a mitigation plan. 

Response: The FEIS states in appendix I, Cultural Resource Management, “Avoidance, 
through modification of the proposed undertaking, is the primary and preferred measure 
used to protect cultural resources. This can be accomplished at the project planning 
stage.” Surface-disturbance impacts on cultural resource are mitigated through 
avoidance. Where avoidance is not possible, recovery of the cultural resource prior to 
allowing disturbance activities to occur will be considered on a site-specific basis. 

Impact Analysis 

Groundwater Impacts 

Comment Summary: Several comments questioned the efficacy of produced water reinjection, 
especially given reports of mud pots and geysers associated with current operations. 

Response: BLM is looking into reports of mud pots and geysers and how they may be 
related to current operations. Given that produced water is injected into geologic 
formations below the coal seams being dewatered, BLM currently speculates that the 
mud pots and geysers are not likely related to injection of produced water. 

Wildlife Impacts 

Comment Summary: Several comments asked that BLM include current data from other 

studies (specifically, the Baggs Mule Deer Study) into the ROD. One comment suggested 
referencing the WGFD recommendations for oil and gas development as potential mitigation 
measures to be used in the ARPA. 

Response: Data collected from wildlife studies in areas near the ARPA may prove 
useful in determining mitigation needs for the ARPA. This information will be evaluated 
and incorporated, as appropriate, into the wildlife monitoring and mitigation process 
described in appendix E of the FEIS. 

The WGFD recommendations for oil and gas development will be considered for 
potential mitigation in the ARPA within the process of wildlife monitoring and mitigation 


Page E-2 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


described in appendix E of the FEIS, where such measures are not in conflict with this 
ROD. 

Monitoring 

Roles and Responsibilities. Annual Planning and Review Team 

Comment Summary: Many comments indicated the importance of identifying who has 

responsibility for reclamation, wildlife, and habitat monitoring and inspection, and that state 
agencies need to be part of a Review Team to evaluate monitoring results and development 
plans. Some comments stated that the Rawlins Field Office (RFO) needs to take an active role 
in monitoring, inspection and compliance. 

Response: As stated above, the BLM, cooperating and interested agencies and the 
Operators will make up a Review Team to evaluate annual and site specific 
development proposals and monitoring reports. Review Team members will be invited 
to participate in the annual planning process and site-specific review process based on 
their interest, time, and availability. Review Team member participation would be in 
addition to their separate and independent permitting and approval responsibilities under 
any other authorities. The BLM is the final decision authority and will set the schedule 
for meetings, site visits, review periods, etc. When appropriate, Memoranda of 
Understanding (MOUs) or other applicable inter-agency agreements may be prepared 
and utilized between the parties to document the extent of participation in the annual 
planning and site-specific review processes. 

The initial monitoring plan will be based on the Wildlife Monitoring and Protection Plan 
(FEIS appendix E) but may be modified annually, as necessary, based monitoring 
results. A mitigation plan will be developed with the state cooperators (e.g., the Review 
Team) with the intent of monitoring the Performance Goals. This information should be 
reviewed at least annually with development plans modified based on trends. The 
purpose of monitoring is to assess the status of the Performance Goals, measure and 
detect trends, or detect any other undesired effects. Monitoring will also be used to 
assess the effectiveness of reclamation efforts and any approved mitigation measures. 

Funding for wildlife and habitat monitoring may be obtained from BLM appropriations, in 
collaboration with cooperating or interested agencies, from the voluntary participation of 
the Operators, or from outside sources that may have an interest or desire to participate 
or contribute, or from a combination of these sources. Operators are responsible for 
demonstrating successful achievement of Performance Goals. Early efforts are to be 
made to collect or consolidate resource data to form a baseline against which future 
monitoring efforts and data would be compared to indicate trends. In the absence of 
sufficient data illustrating Operator achievement of Performance Goals, the BLM will use 
a conservative approach when considering additional approvals. The Review Team, or 
the BLM, or both, will identify the level of effort required for Performance-Based 
Monitoring and develop associated monitoring plans. 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page E-3 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


Preferred Alternative 

Rationale 

Comment Summary: Some comments questioned BLM’s selection of the Preferred Alternative 
(Alternative D) over Alternative C and the Proposed Action. 

Response: Alternative D was developed in response to comments received on the Draft 
EIS (DEIS). The BLM recognized that resource impacts can be reduced by limiting the 
amount of initial disturbance (goal of 6.5 acres/well site) combined with timely 
reclamation. The BLM’s evaluation of exploratory activities that have occurred over the 
past five years determined that average initial and long-term disturbance could be 
reduced by approximately 18 percent from the Proposed Action (e.g., 60-ft. wide roads 
vs. 80-ft. width) if Alternative D were implemented. While a conservative analysis of 
Alternative D and the Proposed Action indicates similar levels of impacts, the reduced 
initial surface disturbance, reduced disturbance at any time, and lower long-term 
disturbance outlined in Alternative D provides the most practical alternative for mitigating 
environmental impacts while maximizing natural gas recovery (Purpose and Need for the 
Project). 

Alternative C was prepared to evaluate natural gas resource development while 
aggressively mitigating impacts to sensitive resource values using additional 
development protection measures. Public comments received on the DEIS, results of 
interim exploration, and technical evaluations by the BLM Reservoir Management 
Group, all indicated drilling on 160-acre spacing would not achieve maximum recovery of 
natural gas resources, was likely not economically feasible, and was likely an inefficient 
recovery of the natural gas resource in the ARPA. Additionally, displacement of 
disturbance from federal lands to state and fee lands due to these aggressive protective 
measures may result in higher initial disturbance, disturbance at any time, and long-term 
disturbance compared to Alternative D, with uneconomical and inefficient natural gas 
recovery. Protective measures used in Alternative C (FEIS, appendix L) will be 
considered based on site-specific conditions, where such measures are not otherwise in 
conflict with the ROD. 

Public Input 

Comment Summary: Several comments noted that the process for review and approval of 
annual development plans defers important decisions on field development to a process that 
does not provide for meaningful public input. The use of APDs or Categorical Exclusions for 
approval of specific development activities does not provide for a sufficient level of site-specific 
NEPA analysis. Others questioned BLM’s authority under the annual planning process to 
actually reduce surface disturbance in the ARPA. 

Response: As noted in the ROD, the annual review and planning process will include 
cooperating agencies as well as the BLM (See Review Team discussion under 
Mitigation Measures, above). Public input will be provided through the NEPA evaluation 
process for site specific proposals, unless Categorical Exclusions (pursuant to 
Section 390 of the Energy Policy Act of 2005) are used, if appropriate, for the approval 
of site-specific development activities. APDs will be posted in the RFO and available for 
public review. This ROD gives BLM the authority to make decisions that limit surface 
disturbance in the ARPA. 


Page E-4 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


Reclamation 

Bank Process 

Comment Summary: Several comments requested a description of the disturbance cap 

“banking process”, including how disturbance will be allocated among Operators and how 
reclaimed acreage will return to the bank, and flexibility in the disturbance cap due to 
unforeseen circumstances. Some comments questioned BLM’s authority to impose the 
disturbance cap on state and fee lands. Another comment suggested an alternative standard 
for linear disturbance features, such as pipelines, to facilitate reclamation success. Comments 
included an inquiry about the use, and process, of waivers and exceptions. 

Response: This decision includes an unreclaimed disturbance cap of 7,600 acres at any 
time. Disturbance acreage will be monitored using geospatial tracking methods. 
Operators are required to provide the BLM a map of existing disturbance associated with 
activities authorized during the period of time when the interim drilling policy was in 
effect. The 7,600-acre disturbance cap will be allocated to Operators on a prorated, 
mineral leasehold basis. Existing surface disturbance from activities approved under the 
Interim Drilling Policy (IDP) will count against each Operators disturbance cap allocation. 
Past oil and gas development will not count against the disturbance cap, and those 
lease holdings are not eligible for disturbance cap allocation. In addition, “as built” 
disturbance will be measured and reported and subsequent reclamation efforts will be 
monitored, documented, and provided annually to the BLM RFO AO. Adaptive 
management techniques will be used to correct any deficiencies and modify reclamation 
criteria as is necessary (Reclamation Plan, appendix A). 

The 7,600-acre disturbance cap will be allocated to Operators on a prorated, mineral 
leasehold basis. Only successfully-reclaimed acreage (See ROD appendix A, Criteria 
for Reclamation Success) that was disturbed during the implementation of activities 
associated with this decision or the IDP will be allocated back to the Operator based on 
their prorated disturbance cap. Regardless of the number of Operators within the ARPA, 
the total of all prorated disturbance cap allocations may not exceed 7,600 acres. 

When a site attains the interim reclamation vegetation cover and soil stability standards 
detailed in “Criteria for Reclamation Success” in the Reclamation Plan (appendix A), the 
reclaimed acreage will be deducted from an Operators disturbance cap allocation and 
additional disturbance on federal lands leased for oil and gas development in the ARPA 
will be permitted by BLM. In the event an Operator reaches their disturbance cap 
allocation, further disturbance on federal minerals will not be permitted. When 
successful interim reclamation by an Operator reduces disturbance on their leases to 
below their disturbance cap allocation across the ARPA, additional activities on federal 
lands may be approved. 

The environmental analysis of Alternative D presented in the FEIS and the decisions 
made in this ROD are based on these disturbance limits applied across the ARPA. The 
BLM has approval authority over actions on federal minerals and lands. When 
evaluating development applications for affected federal minerals and lands, the BLM 
will consider impacts and surface disturbance that occur on private or state lands, 
relative to an Operator’s disturbance cap allocation. 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page E-5 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


Appropriate seed mixtures should be selected based on site-specific needs (soil type, 
linear disturbance, etc.). Operators should propose in their reclamation plan for a 
site/area the most appropriate seed mixture and include their rationale for selecting that 
mix. 

Exceptions, waivers or modifications of requirements must be based upon environmental 
analysis of proposals (e.g., activity plans, plan of development, plans of operations, 
applications for permit to drill, etc.) and, if necessary, must allow for other mitigation to 
be applied on a site-specific basis. 

Disturbance Cap 

Comment Summary: Comments requested that BLM explain the basis for the 6.5 acre per well 
site goal, and 7,600 acre disturbance cap. Operator comments question BLM’s authority to 
impose the disturbance cap on state and fee land. One Operator noted that the air monitoring 
station required by WDEQ should not count against the disturbance cap. Another Operator 
noted that disturbance associated with existing conventional fields (e.g., Cherokee Creek in the 
Category A area) should not be included in the disturbance cap. 

Response: BLM used multiple lines of data to establish a 6.5 acre well site goal. These 
lines of data included the proponents Proposed Action (FEIS, appendix K), information 
provided by Anadarko E&P Company, LP (AEPC) during a presentation on 
May 1 1 , 2006, and field observations by BLM staff. 

The Proposed Action included an estimated average disturbance per well site of 
7.9 acres (well pad, resource roads, utilities, pipelines and ancillary facilities), composed 
of 4.8 acres per well site in short-term (reclaimable) disturbance and 3.1 acres of long- 
term disturbance. 

The May 1 1 , 2006 presentation by AEPC to BLM and cooperators of the Doty Mountain 
project was to provide “an example of how (AEPC) can address environmental issues at 
the APD level”. Total surface disturbance at Doty Mountain was estimated to be 
5.7 acres per well site, with 3.8 acres of reclaimable acreage and 1.9 acres of long-term 
disturbance. While these estimates did not include the entire infrastructure assumed in 
the Proposed Action, there is a significant reduction in disturbance from key construction 
elements such as buried utilities under roadways and 25 percent narrower roadways. 
BLM recognizes the Doty Mountain example may be an aggressive estimation to use 
across the ARPA due to conversion of two-track trails to resource roads, but it does 
indicate that it is reasonable and achievable to reduce surface disturbance below levels 
recommended in the Proposed Action. Based on field observations, Proponent input 
(Proposed Action and Doty Mountain overview) and professional judgment BLM 
established an average goal (not a cap) of 6.5 acres per well site (2.5 acres per well site 
long-term disturbance) across the ARPA. 

BLM established a surface disturbance cap for the ARPA to encourage reduced initial 
disturbance and timely reclamation, resulting in reduced environmental impacts on 
resources. The 7,600 acre disturbance cap was derived using the following 
assumptions. 


Page E-6 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


• 2.5 acres per well site long-term disturbance 

• Initiate reclamation (e.g., grading, seeding, etc.) - year 1 after disturbance 

• Reclamation success per year: 0% - 0% - 0% - 40% - 60% (five growing 
seasons after initial seeding) 

Peak disturbance at any time occurs after six years, at approximately 7,600 acres 
(includes existing estimated disturbance from the interim drilling policy), as shown in 
Alternative D - Acreage Disturbance Profile below. 

Figure 1. Atlantic Rim Gas Project Location, Carbon County, Wyoming 2006. 


Alternative D - Acreage Disturbance Profile 
Atlantic Rim 



Year 


- Unreclaimed-Reclamable — Cumulative Long Term (Ac) 

Total Disturbance (Ac) 


The environmental analysis of Alternative D presented in the FEIS and the decisions 
made in this ROD are based on these disturbance limits applied across the ARPA. The 
BLM has approval authority over actions on federal minerals and lands. When 
evaluating development applications for affected federal minerals and lands, the BLM 
will consider impacts and surface disturbance that occur on private or state lands, 
relative to an Operator’s disturbance cap allocation. 

Many of the subsequent actions in the ARPA project may be eligible for categorical 
exclusion under the Energy Policy Act of 2005. The review and approval process prior 
to allowing a federal leaseholder to extract federal minerals will be subject to further 
environmental review. In some instances, further NEPA documentation will be prepared. 
In other instances, where certain criteria are met, the action may be categorically 
excluded from the requirements of NEPA and will be approved under the provisions of 
section 390 of the Energy Policy Act of 2005. In all cases, the action will be subject to 
onsite investigation, cultural reviews, T&E consultation, and environmental reviews. In 
cases where development to access privately-owned minerals is proposed on private or 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page E-7 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


state lands, and access across public lands is requested, the BLM will conduct the 
appropriate level of NEPA analysis prior to granting a right-of-way. Environmental 
documents prepared under NEPA will consider cumulative impacts that may result from 
the private actions within the ARPA. Prior to approval of all oil-and-gas-related activities 
in the ARPA, the BLM will consider surface-disturbing activities associated with natural 
gas development that occur on private lands and include that information when 
estimating the acreage towards the 7,600 acres “cap.” 

Surface disturbance associated with the air monitoring station is anticipated to be 
minimal, and will not count against the ARPA disturbance cap. 

Future disturbance on federal minerals subsequent to the date the ARPA ROD is 
approved is subject to the disturbance cap. Operators are required to submit a summary 
of their mineral lease holdings to BLM to receive their disturbance cap allocation. Past 
oil and gas development (approval prior to the IDP) will not count against the 
disturbance cap, and those lease holdings are not eligible for disturbance cap allocation. 

Performance Standards 

Comment Summary: A number of comments observed that the ROD should include desired 
conditions, monitoring methods, potential mitigation considerations, and a clear identification of 
who is responsible for monitoring and reporting. Some reviewers commented that the 
reclamation standards should be achievable, with flexibility to adapt to unforeseen 
circumstances, while others noted that the reclamation standards were appropriate and should 
be adhered to strictly. Still others noted that the reclamation criteria were not consistent and 
requested clarification, particularly for the interim reclamation criteria which will be used to 
return disturbed land into the “disturbance bank.” Several commenter’s suggested that a 
working group be convened to deal with unforeseen reclamation issues. 

Response: As noted in the ROD, drilling, development, and reclamation activities in the 
ARPA will be managed through a performance-based, adaptive management process as 
described in appendix B (Performance-Based Monitoring and Best Management 
Practices). A mitigation and monitoring process will be developed by the Review Team 
(BLM, cooperating and interested agencies, and Operators) and will provide quantifiable 
criteria to identify trends associated with the Performance Goals. The process will 
include the types of mitigation responses that will be considered in the event that 
monitoring data indicates a downward trend relative to the Performance Goals. 
Throughout the life of the project, monitoring data will be reviewed to determine if 
mitigation is effective and leading to the achievement of reclamation and Performance 
Goals. The monitoring data will be evaluated on a regular basis (at least annually) and 
BMPs, COAs, protective measures, reclamation criteria, and mitigation measures may 
be modified, as appropriate, based on the monitoring results. 

Please refer to appendix A of this ROD for a revised version of the ARPA Reclamation 
Plan. This plan has been revised to clarify the difference in reclamation success criteria 
for interim versus final reclamation. 

BLM considers the Reclamation Plan to be an “evergreen document” that will be revised 
as necessary and appropriate through an adaptive management process. For instance, 


Page E-8 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


monitoring of reclamation efforts may reveal a need to adjust reclamation criteria, 
thereby providing flexibility in the reclamation approval and disturbance banking process. 

The Review Team described in the ROD, consisting of BLM, cooperating and interested 
agencies, and the Operators is responsible for evaluating monitoring plans and reports, 
including reclamation, and can serve as a working group to manage unforeseen 
reclamation issues. 

Air Quality 

Comment Summary: One comment noted that use of the Scheffe method to predict ozone 
impacts is not scientifically valid. Another comment noted a discrepancy in background 
concentrations for ozone between the affected environment section (table 3-6) and the impact 
analysis section (table 4-2). In addition, table 4-1 has some negative numbers which are 
confusing. Still another comment noted that BLM should consider and abide by critical nitrogen 
deposition loads recently developed for Rocky Mountain National Park. And finally, one 
comment notes that BLM should recognize the recent change in the particulate standard for 
PM 2.5 from 65 ug/m3 to 35 ug/m3. 

Response: BLM recognizes that the Scheffe method for estimating ozone impacts is no 
longer used for the intended purpose, and BLM is no longer using the method for 
projects currently undergoing analysis of air impacts. However, as noted on page 4-15 
of the FEIS, the Scheffe method was considered by the inter-agency air quality team to 
be a reasonable tool for estimating ozone impacts at the time the air quality analysis was 
conducted. 

The background ozone concentrations presented in table 3-6 are maximum 8-hour 
values (specifically, the fourth highest daily 8-hour value), whereas the ozone 
concentrations presented in table 4-2 are average hourly values. Hence, the average 
numbers are lower than the maximum values. 

The values in table 4-1 represent the change in emissions over the period for which the 
regional emissions inventory was conducted (January 1, 2001 through March 31, 2004). 

The negative values represent a reduction in emissions over the inventory period. 

Nitrogen deposition impacts on PSD Class I and Sensitive PSD Class II areas, including 
Rocky Mountain National Park, were estimated for the proposed Atlantic Rim project and 
for other regional sources. The estimated nitrogen deposition impacts were below levels 
of concern established at the time the analysis was conducted. 

The BLM anticipated the change in the PM 2.5 standard by inserting text in the FEIS 
recognizing the change and how the change does not change the analysis in the 
document. Please refer to text on page 3-19 of the FEIS for a description of the change 
in the standard, and to text on page 4-12 for a statement that the predicted impact is 
below the new standard. 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page E-9 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


Paleontology 

Comment Summary: One comment noted BLM’s assertion (response to DEIS comments) that 
there are no known occurrences of localities meeting the Condition 1 determination is incorrect. 
Another noted that the FEIS does not contain definitions of "paleontological condition" or 
"probable fossil yield classification" or a reference to BLM’s original documents containing at 
least the paleontological condition definitions. Finally, the FEIS does not contain reliable 
quantitative estimates of probable fossil yield classification (PFYC). 

Response: As stated in FEIS appendix H, Best Management Practices, paleontological 
category 1 and category 2 areas will be managed in the same manner; therefore, 
identification of specific localities or quantification of PFYC is not necessary. Please 
refer to the errata section of this ROD for a correction to our response to DEIS 
comment 671-73-1. 

Definitions for "paleontological condition" and "probable fossil yield classification" may 
be found in the two following sources: 

1) BLM Handbook H-8270-1 (GENERAL PROCEDURAL GUIDANCE FOR 
PALEONTOLOGICAL RESOURCE MANAGEMENT) 

2) BLM Draft Policy for Paleontological Resource Management 


Page E-10 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


Table El. Individuals and Organizations Submitting Comments on the Atlantic Rim 
Natural Gas Development Project Final EIS 


Date 

Received 

Individual, Agency or Organization 

Hard Copy 

12/11/2006 

Andrew Blair 

12/26/2006 

John and Clara Blair 

12/26/2006 

Kathy Morarty, PhD 

12/26/2006 

Brian A. Rutledge, Audubon Wyoming 

12/27/2006 

Heath Van Eaton, Heartland BioComposites, LLC 

12/28/2006 

Larry Svoboda, USEPA, Region 8 

12/28/2006 

Shelley and John Ellis 

1/3/2007 

Mike Zancanella 

1/3/2007 

Barbara Parsons 

1/3/2007 

Tom Clayson, Anadarko E&P Company, LP 

1/3/2007 

Bruce Pendery, Wyoming Outdoor Council; 
Nada Culver, The Wildnerness Society; 

Joy Owens, Friends of the Red Desert 

1/3/2007 

Scott Hedlund, Warren E&P, Inc. 

1/4/2007 

Jason Begger, Petroleum Association of Wyoming 

1/4/2007 

Tyler H. Vanderhoer, Gene R. George & Associates 

1/4/2007 

Linda Guthrie, Devon Energy Corporation 

1/4/2007 

Chuck Mollica 

1/5/2007 

Erik Molvar, Biodiversity Conservation Alliance, et al. 

1/5/2007 

Vern Stelter for John Emmerich, State of Wyoming, 
Wyoming Game and Fish Department 

1/5/2007 

John Etchepare, State of Wyoming, Department of Agriculture 

1/5/2007 

Richard L. Currit, State Historic Preservation Office, Wyoming State Parks and Cultural Resources, 

1/5/2007 

D. Steven Degenfelder, Double Eagle Petroleum and Mining Company 

1/8/2007 

Todd Parfitt, State of Wyoming, Department of Environmental Quality 

1/8/2007 

Dave Freudenthal, State of Wyoming, Office of the Governor 

1/8/2007 

Martha Christensen 

1/8/2007 

Lisa Eadens for Michael A. Saul and Mark Winland, Wyoming Wildlife Federation 

12/30/2006 

Scott Hedlund, Warren E&P, Inc. 

1/4/2007 

Eileen Caryl 

1/4/2007 

D. Steven Degenfelder, Double Eagle Petroleum and Mining Company 

1/4/2007 

Todd Parfitt, State of Wyoming, Department of Environmental Quality 

1/5/2007 

Jason A. Lillegraven 

1/5/2007 

Richard M. Garrett, Jr. 

1/5/2007 

Tom Ritter 

1/5/2007 

Teresa Davidson 

1/5/2007 

Alexis Dale 

1/5/2007 

Patrick W. Gonzales, Rawlins-Carbon County Chamber of Commerce 

1/9/2007 

Asa S. Nielson, Environmental Preservation Foundation 

1/8/2007 

Brian T. Kelly, USFWS, Wyoming Field Office 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page E-1 1 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


Table El. Individuals and Organizations Submitting Comments on the Atlantic Rim 
Natural Gas Development Project Final EIS cont. 


Date 

Received 

Individual, Agency or Organization 

Email 

12/7/2006 

Bob Layboum 

12/17/2006 

Jean Public 

12/17/2006 

Carol Rothrock 

12/18/2006 

Asa Nielson, Environmental Preservation Foundation 

12/20/2006 

Lowell Wade, Flying X Ranch 

12/20/2006 

Dinda Evans 

12/20/2006 

Dinda Evans 

12/21/2006 

Bart Geerts 

12/21/2006 

Jana Weber 

12/22/2006 

Robert Anthony 

12/23/2006 

Jane Warren 

12/23/2006 

Lydia Garvey 

12/24/2006 

Sidney Peters 

12/26/2006 

Mike Evans 

12/26/2006 

Lynne Berg 

12/28/2006 

Mark Jenkins 

12/29/2006 

Jan Leopold 

12/29/2006 

Tom Clayson, Anadarko E&P Company, LP 

12/30/2006 

Scott Hedlund, Warren E&P, Inc. 

12/31/2006 

Alyson Hagy 

1/1/2007 

Paul Moss 

1/1/2007 

Paul Taylor 

1/2/2007 

Chuck Mollica 

1/2/2007 

Jason Begger, Petroleum Association of Wyoming 

1/2/2007 

Daniel Dale 

1/2/2007 

Aaron McCallister 

1/2/2007 

Robyn Morrison 

1/2/2007 

Richard Spotts 

1/3/2007 

Christian Rudolph 

1/3/2007 

Sigrid Mayer 

1/3/2007 

Richard M. Garrett 

1/3/2007 

Hannah Griscom 

1/3/2007 

Linda Guthrie, Devon Energy Corporation 

1/3/2007 

Jerry Goodbody 

1/3/2007 

Charlie Wymer 

1/3/2007 

Debbie Ritter 

1/3/2007 

Bobby Johnson 

1/3/2007 

Dave Roberts 

1/3/2007 

Jason A. Lillegraven, 


Page E-12 


Record of Decision for the Atlantic Rim Natural Gas Project 


APPENDIX E. 

SUMMARY OF PUBLIC COMMENTS ON THE ATLANTIC RIM NATURAL GAS 
FIELD DEVELOPMENT PROJECT FINAL EIS AND BLM’S RESPONSES 


Table El. Individuals and Organizations Submitting Comments on the Atlantic Rim 
Natural Gas Development Project Final EIS cont. 


Date 

Received 

Individual, Agency or Organization 


Email cont. 

1/4/2007 

Dani Sullivan, DSULLI1@state.wy. us 

1/4/2007 

Lisa Eadens, PLIntem@nwf.org 

1/4/2007 

George R. Salisbury submitted via Sharon OToole, sharonsotoole@gmail.com 

1/4/2007 

Sharon OToole, sharonsotoole@gmail.com 

1/4/2007 

Steve Belinda, sbelinda@trcp.org 

1/4/2007 

John D. Adamson, info@geopinion.com 

1/4/2007 

Asa Nielson, acenielson@gmail.com 

1/4/2007 

Erik Molvar, erik@voiceforthewild.org 

1/5/2007 

Patrick OToole, h2otoole@hotmail.com 

12/30/2006 

Michael Ockinga, ockinga48@msn.com 

1/5/2007 

Vern Stelter, Wyoming Game & Fish Department, Vem.Stelter@wgf.state.wy.us 

1/9/2007 

Don Christianson, Department of Agriculture, DCHRIS@state.wy.us 


Record of Decision for the Atlantic Rim Natural Gas Project 


Page E-13