Encampment Area Watershed Study

ENCAMPMENT AREA WATERSHED STUDY
A REVIEW OF THE RAWLINS BLM RMP AND FEIS
Prepared for
Saratoga-Encampment-Rawlins Conservation District
December 10, 2008
Ecosystem Research Group 121 Hickory Street Missoula, MT 59801 (406) 721-9420 www.ecosystemrg.com
SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study
TABLE OF CONTENTS EXECUTIVE SUMMARY .......................................................................................................................... 1 1. INTRODUCTION .................................................................................................................................... 7 1.1 1.2 1.3 Purpose of this Study.................................................................................................................7 Study Background .....................................................................................................................8 Local Government and Public Concerns...................................................................................9
2. REGULATORY SETTING.................................................................................................................... 11 3. ENERGY DEVELOPMENT SETTING ................................................................................................ 13 3.1 3.2 Rawlins Reasonably Foreseeable Development (RFD) scenario ............................................13 A Revised Reasonably Foreseeable Development Scenario (RFD2)......................................15
4. REVIEW OF RMP/FEIS BY RESOURCE............................................................................................ 23 4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 Air Resources ..........................................................................................................................23 Livestock Grazing ...................................................................................................................31 Off Highway Vehicles (OHV).................................................................................................41 Recreation and Visitor Services ..............................................................................................44 Socioeconomics.......................................................................................................................46 Vegetation ...............................................................................................................................75 Visual Resources .....................................................................................................................81 Water Quality ..........................................................................................................................84 Wildlife....................................................................................................................................96 Climate Change .....................................................................................................................115
5. ACRONYMS AND ABREVIATIONS................................................................................................ 117 6. REFERENCES ..................................................................................................................................... 119 7. LIST OF PREPARERS......................................................................................................................... 124
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ECOSYSTEM RESEARCH GROUP
APPENDICES APPENDIX A REGULATORY SETTING FOR THE RAWLINS RMP/FEIS APPENDIX B WATERSHED STUDY SURVEY RESULT REPORT APPENDIX C IMPLAN MODEL OUTPUT FOR CARBON COUNTY
TABLE OF TABLES Table 4.1-1 Recommended Additional Mitigations for Air Resources ...................................................... 30 Table 4.2-1 Recommended Additional Mitigation for Livestock Grazing ................................................. 37 Table 4.4-1 Recommended Additional Mitigations for Recreation and Visitor Services Resources ......... 46 Table 4.5-1 Carbon County Employment - Full and Part-Time Employment by Industry......................... 49 Table 4.5-2 Top Ten Major Employers in Carbon County......................................................................... 49 Table 4.5-3 Annual Unemployment Rate ................................................................................................... 50 Table 4.5-4 Carbon County Regional Economic Profile ............................................................................ 50 Table 4.5-5 Carbon County Average Annual Wages.................................................................................. 51 Table 4.5-6 Carbon County Total Labor and Non-labor Income................................................................ 51 Table 4.5-7 Federal Mineral Royalty (FMR) Distributions 2000-2007..................................................... 53 Table 4.5-8 Assessed Valuation for Carbon County Mineral Production................................................... 53 Table 4.5-9 Severance Tax Revenue 20002007........................................................................................ 54 Table 4.5-10 Payment In Lieu of Taxes (PILT) Revenue for Carbon County, 19982007........................ 54 Table 4.5-11 Carbon County Taxes Assessed on Mineral Production 20002008 .................................... 55 Table 4.5-12 Comparison of Annual Population Change vs. Rental Vacancy vs. Total Housing Units .... 55 Table 4.5-13 Comparison of Annual Average Sales Prices for Carbon County, Wyoming, and the U.S. 56 Table 4.5-14 Average Rental Rates for Carbon County and Wyoming, 20012007.................................. 56 Table 4.5-15 Carbon County Schools Student/Teacher Ratios.................................................................. 58 Table 4.5-16 Carbon County Schools Expenditures/Pupil 20002007 ...................................................... 59 Table 4.5-17 Carbon County Violent and Property Crime Statistics 19802005....................................... 60 Table 4.5-18 Carbon County Drug and Alcohol Crime Statistics 20002007............................................ 60 Table 4.5-19 Carbon County Total Vehicle Miles 20002007................................................................... 61 Table 4.5-20 Truck Miles ........................................................................................................................... 61 Table 4.5-21 Potential Study Area Drilling Schedules (wells drilled per year).......................................... 63 Table 4.5-22 Potential Study Area Employment Projections ..................................................................... 63 Table 4.5-23 Recommended Additional Mitigations for Housing.............................................................. 66 Table 4.5-24 Recommended Additional Mitigations for Schools .............................................................. 67 Table 4.5-25 Recommended Additional Mitigations for Roads/Transportation......................................... 68 Table 4.5-26 Recommended Additional Mitigations for Police/Crime/Fire/EMS ..................................... 68 Table 4.5-27 Recommended Additional Mitigations for Medical Services and Facilities ......................... 69 Table 4.5-28 Recommended Additional Mitigations for Water, Sanitary Waste, Solid Waste Services and Facilities ............................................................................................................................................... 69 Table 4.5-29 Recommended Additional Mitigations for all Socioeconomic Departments ........................ 70 Table 4.5-30 Reproduced from the Pinedale Monitoring Plan ................................................................... 72 Table 4.6-1 Land Cover by Ownership....................................................................................................... 76
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Table 4.6-2 Percent Shrub Cover for Rangeland Habitats in the Project Area ........................................... 77 Table 4.6-3 Fire Regime Condition Class (FRCC) by Fire Regime Group................................................ 78 Table 4.8-1 Ground Water Monitoring ....................................................................................................... 89 Table 4.8-2 Recommended Additional Mitigations for Water Resources .................................................. 96 Table 4.9-1 Amount of Pronghorn Antelope and Mule Deer Crucial Winter/Year-Long Range and Winter/Year-Long Ranges.................................................................................................................... 99 Table 4.9-2 Fire Regime Condition Class (FRCC) by Cover Type.......................................................... 100 Table 4.9-3 Recommended Additional Mitigations for Wildlife.............................................................. 114
TABLE OF FIGURES Figure 1.3-1 Comparison of survey results from local government and general public ............................. 10 Figure 4.2-1 Saratoga annual precipitation 19492007 ............................................................................. 34 Figure 4.2-2 Saratoga average monthly summer (JulySeptember) temperatures (19492007)................ 35 Figure 4.5-1 Carbon County population 1960-2017 ................................................................................... 48 Figure 4.5-2 Carbon County Demographic Distribution 2000 and 2007.................................................... 48 Figure 4.5-3 Carbon County labor vs. non-labor income ........................................................................... 52 Figure 4.5-4 Carbon County annual building permits ................................................................................ 57 Figure 4.5-5 Carbon County school district enrollment 19912007.......................................................... 58
TABLE OF MAPS Map 1.1-1 Map of SERCD study area .......................................................................................................... 7 Map 3.1-1 Distribution of mineral rights, oil and gas potential, and leases within study area ................... 14 Map 3.2-1 Reproduction of Map 4-7 from Rawlins RMP/FEIS................................................................. 16 Map 3.2-2 RFD2 minimal development scenario ....................................................................................... 20 Map 3.2-3 RFD2 moderate development scenario ..................................................................................... 21 Map 3.2-4 RFD2 intensive development scenario...................................................................................... 22 Map 4.8-1 Areas of ground water development in the Encampment area watersheds ............................... 87 Map 4.9-1Greater sage-grouse impact analysis ........................................................................................ 105 Map 4.9-2 Wintering mule deer impact analysis ..................................................................................... 107 Map 4.9-3 Statewide energy development and sage-grouse core areas.................................................... 110
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EXECUTIVE SUMMARY The Saratoga-Encampment-Rawlins Conservation District (SERCD) has been actively involved in the public land planning process undertaken by the Bureau of Land Management (BLM), Rawlins Field Office, during completion of the Rawlins Resource Management Plan and Final Environmental Impact Statement (RMP/FEIS). During the planning process, SERCD has provided both verbal and written comments. However, SERCD is concerned that the final RMP/FEIS does not reflect its comprehensive concerns, particularly those regarding the need to protect social and natural resources from potential impacts from future oil and gas development within Encampment-area watersheds. This study seeks to provide a summary of SERCDs concerns with the express intent of ensuring that the BLM incorporates the interests of Encampment-area residents and officials into any revisions of the RMP/FEIS, the Record of Decision (ROD), and any other future planning efforts. The spectacular mountains and valleys in Encampment and the surrounding area host unrivaled natural resources and provide the backdrop for an outstanding quality of life for residents. Because BLM lands and private lands are mixed in the area, BLM planning and management actions could significantly affect these resources. Given the amount of private land with federally held mineral estate, this is particularly true for impacts associated with future energy development. On May 28 and 29, 2008, SERCD held public input workshops to discuss energy development and associated impacts. Participating residents and local officials clearly expressed their acceptance and even desire for a moderate level of energy development in their region. However, participants also expressed their concern regarding potential impacts to area watersheds, social and economic resources, working landscapes, wildlife habitat, and other natural resources (see Section 1.3). Given these concerns and the disproportionate effects that BLM actions may have on Encampment-area resources, it is imperative that potential impacts are fully understood so that energy development may move forward while adverse effects are limited or avoided. This requires that BLM decisions be founded on thorough analyses using the best available science and data. The current RMP/FEIS, however, is inadequate to ensure appropriate, defensible, and optimal management decisions (see Section 4). Per the Council on Environmental Quality (CEQ) guidelines, the BLM must take a hard look at impacts, providing enough detail to support reasoned comparison of impacts between alternatives (40 Code of Federal Regulations [CFR], 1502.1). Further, per the BLM National Environmental Policy Act (NEPA) Handbook (H-17970-1), the BLM is required to use the best available science to support NEPA analyses, and give greater consideration to peer-reviewed science and methodology over that which is not peer-reviewed. However, in many instances, the RMP/FEIS relied on data that were out of date and failed to incorporate current scientific standards. Additionally, there are multiple instances where, even
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when sufficient data were available, the BLM failed to conduct the necessary analyses to provide a framework from which alternative management decisions could be compared. The requirement to take a hard, quantitative look extends to the consideration of cumulative impacts as well. CEQ defines cumulative impacts as the impact on the environment, which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions. CEQ requires that cumulative impacts include all actions that are reasonably foreseeable. Given the current volatility of energy prices and the potential for expanded energy exploration and development, the limited consideration given to oil and energy impacts, both generally and cumulatively, is insufficient. Other areas of Wyoming have seen a significant energy boom accompanied by negative impacts to their natural resources and socioeconomic quality of life. Further, thirteen leases were proposed for oil and gas leasing within the Encampment area. Although these leases have been temporarily withdrawn pending further study, their offering and other trends in Wyoming suggest an energy development future exceeding the parameters studied within the RMP/FEIS and certainly suggests greater cumulative impacts should have been considered as highly probable, based on known opportunities or trends (CEQ 1981). However, the RMP/FEIS assumes almost no surface disturbance in the Encampment area. Under cumulative impacts (RMP/FEIS Section 4.20), the BLM states that the RMP/FEIS is at the broadest level of decision making and that site-specific actions are seldom addressed in the RMP. Consequently, the cumulative impact analysis is also broad and general in nature. It will present ranges and qualitative conclusions as opposed to bounded quantified details. SERCD agrees that the RMP/FEIS should be conducted at a broad level, but the BLMs intention to only consider these cumulative impacts in subsequent NEPA documents that analyze specific projects or programs is not sufficient under CEQ guidance. As a counterpoint to this inadequacy, this study includes models of a broader range of possible future energy development scenarios (see Section 3). These scenarios provide an improved baseline against which to assess the BLM environmental impact analyses. Whatever the future level of energy and gas development, protecting Encampment-area resources will require robust oil and gas leasing stipulations and associated mitigations to reduce or remove any potential impacts from drilling. The CEQ repeatedly states that the BLM must consider all relevant, reasonable mitigation measures for the entire range of impacts in the proposed management actions. Further, mitigation measures must be considered even for impacts that by themselves would not be considered "significant. Once the entire proposal as a whole is considered to have significant effects, then all of its specific effects on the environment (whether or not "significant") must be considered and mitigation measures must be developed where it is feasible to do so (40 CFR 1502.14, 1502.16, 1505.2, 1508.14). Yet, there are numerous examples of inadequate mitigation measures. One concern is the BLM reliance on Best Management Practices (BMPs) instead of mitigation measures. BMPs are discretionary and unenforceable; these are not sufficient for meeting CEQ requirements or for ensuring the protection of Encampment-area resources.
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To provide sideboards for the following study, Section 2 outlines the regulatory requirements for BLM planning efforts, and Section 4 provides a range of possible oil and gas development scenarios. Using the regulatory and energy setting as a baseline, the study then assesses the adequacy of the Rawlins RMP/FEIS for each resource area of interest. Each resource section also includes suggested mitigations that the BLM should include in either the ROD or in future site-specific planning decisions and associated NEPA analyses within the Encampment area. These mitigations should apply to both BLM managed lands as well as public lands where federal jurisdictions are applicable (e.g., oil and gas stipulations on split estate private lands, wetlands, and issues pertaining to the Endangered Species Act or air quality). If the BLM does not consider all necessary mitigations to ensure protection of Encampment-area watersheds and resources, the RMP/FEIS will not be in line with CEQ regulations or BLM guidelines. SERCD looks forward to a continued collaboration and to pursuing a Memorandum of Understanding with the BLM to ensure that SERCD is recognized as a cooperating agency on all future planning efforts in the Encampment area. This will ensure that SERCDs expertise in local social and natural resources are incorporated in future planning efforts. KEY FINDINGS Energy Development
The assumptions about energy development, upon which the RMP/FEIS analyses are based, no longer may provide an accurate scenario of future energy exploration in the study area given rising energy demands and the BLMs proposed leasing of lands within the Encampment area.
Resources 1.

Air Resources
Ambient air-quality data are either very old or not close geographically to the RMP planning area (RMPPA). While incremental amounts of individual pollutants are given for each of the alternatives, no discussion of the impacts to overall air quality or the significance of those impacts is presented. Cumulative impacts are not quantified: The RMP/FEIS stated that because the ambient air concentrations are low, cumulative increases in emissions are not expected to exceed air-quality standards. Assuming cumulative increases would not cause excesses of state or federal air standards without a study of those impacts is contrary to CEQ guidelines. Mitigations are not detailed or stated using enforceable language; two additional mitigations concerning improved monitoring are recommended.
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2.

Livestock Grazing
Acreage available for grazing is not provided in the affected environment section and baseline data are missing. Criteria for determining a significant impact are not sufficient to ensure adequate grazing forage, and the impact assessment relies on unrealistic assumptions of temporally static climate conditions. The RMP/FEIS assumes no significant cumulative impacts based on mitigations, but numerous additional mitigations would be necessary to ensure resource protection and reduce potential for significant cumulative impacts.
3.

Off Highway Vehicles

The RMP/FEIS adequately designates Off Highway Vehicle (OHV) use areas. The RMP/FEIS adequately analyzes and discloses the direct, indirect, and cumulative effects of the proposed action. No additional mitigations are recommended.
4.
Recreation and Visitor Services

The RMP/FEIS inadequately defines or describes the Recreation Opportunity Spectrum (ROS), an important planning tool used by the BLM to classify existing and desired recreation opportunities, settings, and experiences. The RMP/FEIS identifies Special Recreation Management Areas (SRMAs) per direction in the BLM Land Use Planning Handbook (H-1601-1). The RMP/FEIS adequately analyzes and discloses the direct, indirect, and cumulative effects of the proposed action. The RMP/FEIS fails to provide any mitigations; one mitigation for noise control is recommended.
5.
Socioeconomics
The RMP/FEIS adequately describes the existing socioeconomic environment per Appendix D of the BLM Land Use Planning Handbook, but presents out of date information in many areas. In particular, the two significance criteria presented for socioeconomic evaluation over the next twenty years rely on data and thresholds that cannot realistically be applied to current trends. The RMP/FEIS incompletely analyzes the direct, indirect, and cumulative socioeconomic effects of the proposed actions. The document presents projected direct employment, income, and revenue information but contains no indirect effects. There is only general discussion of potential effects on housing and infrastructure, which does not help local governments or communities assess specific potential impacts to their areas. Cumulative impacts are discussed too generally to be adequate.
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6.

Vegetation
No baseline data are provided for adequate quantification of impacts to vegetation dependent resources, such as wildlife and grazing. There is no quantifiable support for the assertion of no significant cumulative impacts.
7.

Visual Resources
The RMP/FEIS clearly defines and establishes Visual Resource Management (VRM) classes across the RMPPA according to BLM policy. The RMP/FEIS adequately analyzes and discloses the direct, indirect, and cumulative effects of the proposed action. Inconsistencies exist in the mitigations regarding Class II VRM, and it is unclear whether surface disturbance from energy development will be limited in these areas or whether only discretionary BMPs apply. If made mandatory, however, the BMPs would sufficiently protect visual resources.
8.
Water Quality
The Affected Environment section of the RMP/FEIS fails to adequately describe baseline conditions for water resources, especially in regard to ground water resources. The RMP/FEIS provides no basic hydrogeologic information on the major aquifers, no summary of existing water quality by aquifer, no basic hydrologic data for important aquifers, and no discussion of areas of ground water development. The RMP/FEIS fails to provide quantitative analysis of potential impacts to water resources for direct, indirect, and cumulative impacts. Only discretionary BMPs are listed in the RMP/FEIS; several additional mitigations are recommended to ensure protection of water resources.
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9.

Wildlife
Competition-related impacts on wildlife from livestock grazing are not supported by empirical or quantitative data and appear inconsistent with conclusions in the grazing chapter. The discussion on wildlife habitat ignores the contribution of private working ranches, the risks facing working ranches, and the impacts expected if/when working ranches continue to decline. The discussion of research describing the impacts of energy development on greater sage-grouse is incomplete. The description of alternatives and the level of activity anticipated from oil and gas leasing are not disclosed in sufficient detail or in a manner that would facilitate a reasonable effects analysis. There is no quantification of effects in the environmental consequences section, even though recent, locally conducted research specifically identifies the means to quantify those effects. An example approach to such an analysis is provided. The cumulative effects analysis is inadequate. It does not evaluate or consider similar trends at regional, state, or range-wide levels for species at risk such as greater sage-grouse. Critical protections are listed as discretionary BMPs; several additional mitigations are recommended to ensure protection of sage-grouse leks and wildlife habitat on private ranchlands.
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1. INTRODUCTION 1.1 PURPOSE OF THIS STUDY
The purpose of this study is to assess the adequacy of the Bureau of Land Management (BLM) Rawlins Field Office Proposed Resource Management Plan (RMP) and corresponding Final Environmental Impact Statement (FEIS) in protecting the social, economic, ecological, and physical resources in and around the Encampment area from potential impacts, particularly associated with prospective energy development. This study primarily assesses the following:
The adequacy of the RMP/FEIS in light of regulatory requirements and surrounding land use planning efforts (see Section 2); The adequacy of the RMP/FEIS in light of potential future oil and gas development (see Section 3); The adequacy of the environmental assessment in the RMP/FEIS for air quality, livestock grazing and vegetation, off highway vehicles, recreation and visitor services, socioeconomics, visual resources, water quality, and wildlife (see Section 4); and The adequacy of mitigations and stipulations provided in the RMP/FEIS to protect resources (see Section 4).
The study area for this report, as identified by Saratoga-Encampment-Rawlins Conservation District (SERCD), consists of approximately 615,000 acres running from Saratoga in the north to south of Encampment, Wyoming (Map 1.1-1).
Map 1.1-1 Map of SERCD study area

1.2
STUDY BACKGROUND
The BLM released the Proposed RMP and FEIS for the Rawlins Field Office in January 2008. The Rawlins RMP is intended to replace the Great Divide RMP issued in 1990. The Rawlins RMP covers approximately 11.2 million acres of BLM-administered lands (Rawlins Field Office) throughout most of Albany, Carbon, Laramie, and Sweetwater counties. The RMP serves as guidance for land use planning decisions over approximately the next 20 years. The RMP is required by Sections 201 and 202 of the Federal Land Policy and Management Act of 1976 (FLPMA) and regulations listed in 43 Code of Federal Regulations (CFR) 1600. These laws and policies require that public lands be managed for multiple use and sustained yield and to protect the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archaeological values in the region. As required by National Environmental Policy Act (NEPA) and Council on Environmental Quality (CEQ) regulations (40CFR 1500-1508), the RMP requires an associated Environmental Impact Statement (EIS). These laws and regulations require that the BLM analyze the potential significant impacts to social, natural, and physical resources that may result from policies and decisions set forth in the RMP. Under NEPA, an EIS must consider reasonable alternative actions, including a no-action alternative (no change from the current BLM land use planning efforts). The Rawlins RMP/FEIS considered three alternatives in addition to the no-action alternative. The BLM has indicated that its preferred plan would be Alternative 4. As part of the EIS and in conformance with the 1987 Federal Onshore Oil and Gas Leasing Reform Act, the BLM is required to analyze the environmental effects of activities that may result from implementation of a proposed oil and gas leasing program (36 CFR 228). To provide the basis for such effects analysis, the BLM develops a scenario that predicts future mineral development as a consequence of leasing and specified leasing conditions within the RMPPA. This is referred to as the Reasonable Foreseeable Development (RFD) scenario. Although the RFD for the Rawlins Field Office suggested no or very low potential for oil and gas development in the SERCD study area, on October 18, 2007, the BLM announced its intent to offer 13 leases across both public and private (split mineral estate) lands in the SERCD study area. Several organizations filed protests against leasing these 13 parcels. The BLM Wyoming State Director determined that all 13 parcels should be removed from a December 2007 competitive sale while the merits of the protests were considered.
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1.3
LOCAL GOVERNMENT AND PUBLIC CONCERNS
Although the 13 proposed leases in the SERCD study area have been temporarily withdrawn from sale, SERCD remains concerned about the potential impact of future oil and gas leasing in the study area. These concerns are shared by many other residents and public officials. SERCD held two public meetings on May 28 (Saratoga) and May 29 (Encampment), 2008 to garner public comments and concerns regarding potential impacts of oil and gas development. At each meeting, Ecosystem Research Group (ERG) staff presented information about the forthcoming SERCD Watershed Study and potential issues associated with energy resource development in similar communities. At the end of each meeting, a survey was distributed to attendees to gain input from both the public and local government officials. A total of 72 participants provided comments at the meetings; 54 respondents were members of the public, and 18 were local government officials. The survey was a census of local governments, including members of the Saratoga, Encampment, and Riverside Town Councils; the Carbon County commissioners; and SERCD members. ERG also coordinated distribution of the survey as an insert in local newspapers. A version of the survey was available online. The public was encouraged to either return the survey to ERG via mail or submit the online version. Survey respondents were asked to select their ten most important issues from a list of 31 and then rank their choices. ERG compiled and summed these rankings to identify those issues most important to participants. The entire survey report is in Appendix B. Survey respondents indicated an overwhelming acceptance of moderate-intensity energy development within the region. However, respondents also indicated concern about the protection of important social and natural resources within the study area. Below, Figure 1.3-1 provides a summary of responses from the general public and each of the participating governmental agencies. For summary purposes, scores across several topics from the survey are combined within an index for comparison among participants (see Appendix B for ungrouped results). Results indicated that water quality, socioeconomic impacts, working landscape preservation (grazing), and wildlife habitat were among the topics of primary concern. Note the near consensus on water quality and quantity and socioeconomics being the issues of greatest importance.
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0.40 0.35 0.30 0.25 0.20 0.15 0.10 0.05 0.00

Water Quality Social and Economic Issues Grazing and Land Use Wildlife, T&E Recreation, Working Planning and Species, Tourism, and Landscapes Open Space Fisheries, Visual and Habitat Resources Restoration Riparian Areas Vegetation, Weeds, and Timber Management Roads Air Quality Public Process Wilderness
General Public Riverside Town Council
SERCD Members Encampment Town Council
Carbon County Commissioners Saratoga Town Council
Figure 1.3-1 Comparison of survey results from local government and general public 10
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2. REGULATORY SETTING The regulatory setting under which the RMP/FEIS was conducted provides a background against which the RMP/FEIS should be assessed. The regulatory setting includes both the policy setting and planning setting. Both are provided in Appendix A. The policy setting section of this report (Appendix A, Section A.1) outlines key codes and regulations with which the BLM is required to conform when conducting resource management planning and associated environmental impact analyses. The list of policies and laws is not comprehensive but identifies those most pertinent to this study. They include NEPA and CEQ regulations and associated BLM policies listed in the BLM NEPA Handbook (H-17970-1), FLPMA and associated BLM policies listed in the BLM Land Use Planning Handbook (H-1601-1), the Energy Policy Act of 2005 (EPA) and the Energy Policy and Conservation Act of 2000 (EPCA), and relevant executive orders.
One area of particular interest is in CEQ guidelines for cumulative impacts analysis. Smith
(2005), in his paper Recent Trends in Cumulative Impact Case Law, notes that the high failure rate of NEPA documents in the U.S. Court of Appeals, Ninth Circuit, was due to insufficient cumulative effects analysis.
The most common challenge to the cumulative impacts analyses of agency NEPA documents was that the document contained an inadequate analysis of other past, present, and reasonably foreseeable future actions within the analysis area. This issue appeared in 15 of the 25 cases (60%). If agencies lost a court case, this was the most common reason for the Court to rule the cumulative impacts analysis inadequate, which they did in 13 of the 15 analyses (87%) they ruled as inadequate. Agencies won only two cases out of 15 (13%) involving this challenge. The next most common challenge was that the cumulative impacts analysis lacked data and/or a convincing rationale for selection of data and a conclusion that cumulative impacts were insignificant. This challenge appeared in 11 of the 25 cases (44%). Agencies lost seven cases concerning this challenge, making it the second most common reason for losing a case (a factor in 47 percent of the losses). However, agencies won four cases involving this challenge, making it the most common issue in cases won by federal agencies (four of ten cases40%).
In a recent court decision arising from an NEPA challenge, The Great Basin Mine Watch v. Hankins 456 F. 3d 955 (9th Cir., Aug. 1, 2006), the Court agreed with plaintiffs that cumulative impacts were inadequately considered because the cumulative impact analysis consisted of only vague and conclusory statements with no supporting data. Plaintiffs argued that the EISs merely listed other mines in the area without discussing the impacts from each one and failed altogether to address specific impacts related to nearby mines. This example is particularly pertinent to the issue of oil and gas development in the Encampment area and illustrates the critical need to better consider the future potential for oil and gas development and provide adequate analysis about the potential related impacts.
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The Planning Setting section (Appendix A, Section A.2) summarizes pertinent policies from other governmental organizations relevant in the SERCD study area. As per FLPMA and CEQ guidelines, the BLM is required to coordinate planning, to the extent possible, with other governmental programs and policies, and EIS must list possible conflicts between the proposed action and the objectives of other governmental land use plans and policies. Planning documents summarized include the U.S. Forest Service (USFS) Medicine Bow National Forest Revised Land and Resource Management Plan (MBLRMP; 2003), Wyoming State Wildlife Action Plan (SWAP; 2005) and related wildlife efforts, Carbon County Land Use Plan (CCLUP; 1998), and the SERCD Long Range and Natural Resource Management Plan (2007).
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3. ENERGY DEVELOPMENT SETTING 3.1 RAWLINS REASONABLY FORESEEABLE DEVELOPMENT (RFD) SCENARIO
The BLM is required to analyze the environmental effects of activities that may result from implementation of a proposed oil and gas leasing program (36 CFR 228). To provide the basis for such effects analysis, the BLM formulates a scenario that predicts future mineral development as a consequence of leasing and specified leasing conditions within the RMPPA. This report is referred to as the RFD scenario. The RFD report is intended to present a reasonable projection of the type and amount of oil and gas exploration and development that might occur in the RMPPA through the year 2020. The Rawlins BLM released the report titled Reasonably Foreseeable Development Scenario for Oil and Gas, Rawlins Field Office, Wyoming in January 2004. The Rawlins RFD is purportedly founded on the report Scientific Inventory of Onshore Federal Lands Oil and Gas Resources and Reserves and the Extent and Nature of Restrictions or Impediments to their Development (referred to as EPCA Phase II Inventory, November 2006; a subsequent EPCA III was published in May 2008). These inventories were completed jointly by the departments of Interior, Agriculture, and Energy in compliance with EPCA 2000. However, since the Rawlins RFD report is dated prior to the EPCA Phase II Inventory report, it is unclear how the EPCA data were incorporated into the RFD. The BLM also contacted geologists and engineers in the oil and gas industry to garner insight as to what may occur in the future in the Rawlins Field Office area. Per the RFD, the BLM incorporated information from eight of those companies contacted. For a baseline, unconstrained RFD scenario, the BLM estimated that between years 2001 and 2020 as many as 9,310 well locations may be drilled in the RMPPA. Approximately 50% of these wells are expected to be conventional wells and 50% coalbed natural gas (CBNG) wells. The BLM applied this level of development to all leasable lands whether the lands were already leased or had yet to be leased. The BLM assumed an average drilling density greater than 100 wells per township (36 square miles) for areas identified as having high development potential, 20 to 100 wells for areas with moderate potential, fewer than 20 wells for areas with low potential, and fewer than two wells for areas with very low development potential. In areas estimated to have no development potential, no wells were assumed. Figures 23 and 24 in the RFD show the non-coalbed (oil and natural gas) and CBNG potentials, respectively, in the Rawlins RMPPA. No CBNG potential was anticipated in the SERCD study area, and only a small, very low oil and gas potential area was identified in the northernmost portion of the SERCD study area (Map 3.1-1).
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Saratoga-Encampment-Rawlins Study Area

Legend Watershed Study Project Area Townships Land and Mineral Ownership Bureau of Land Management (BLM) Private Lands with Federal Minerals Private State Lands National Forests
Saratoga
North Platte River- Saratoga Lake Lower Jack Creek
T17R85 T17R84
Roads Rivers www.ecosystemrg.com 6th Level Hydologic Units Energy Development Potential Low Potential Non-CBNG Development (per BLM RFD) Public Land Leases Private Land Leases
NAD 83 UTM Zone 13N 6th Principal Meridian Scale 1:250,000 0 1.25 2.5 5 Miles
130
T17R83
T17R82
Medicine Bow National Forest

T17R81 T17R80
North Draw
North Brush Creek Lower Spring Creek
North Platte River-Elk Hollow Creek

T16R85 T16R84 T16R83
130
T16R82 T16R81
South Brush Creek

T16R80
Brush Creek
South Spring Creek
T15R85
T15R84
T15R83
T15R82
North Platte River-North Cottonwood Creek

T15R81
French Creek-North Platte River

T15R80
Calf Creek
Encampment River-West Cottonwood Creek
Encampment
South Mullen Creek
T14R85
70
T14R84
T14R83
T14R82
T14R81
T14R80
North Platte River-Cottonwood Creek North Fork Encampment River Beaver Creek-North Platte River Big Creek-North Platte River
230
Miner Creek
Encampment River- Billie Creek

T13R85 T13R84 T13R83
Bear Creek-Big Creek

T13R82 T13R81 T13R80

Spring Creek-Big Creek Hog Park Creek
T12R85
North Fork Big Creek

T12R84
East Fork Encampment River

T12R83
T12R82
T12R81
T12R80
WYOMING COLORADO Map 3.1-1 Distribution of Mineral Rights, Oil and Gas Potential, and Leases within Study Area
125
Within the RFD report, the BLM then applied reductions to the assumed well densities based on BLM management restrictions. These restrictions were described as those that can affect oil and gas development activities by not allowing leasing, not allowing surface occupancy, controlling surface use, or placing restrictive stipulations on conditions of approval of federal applications to drill. For RFD scenario analysis purposes, the restrictions were separated into four classifications as per the BLM Land Use Planning Handbook (see Map 2-38 in the RMP/FEIS for areas in each category under Alternative 4):
Category A relatively minor restrictions such as standard leasing stipulations Category B moderate restrictions such as multiple, consecutive restrictions for protection of resources, including avoidance of areas near wetlands, raptor nests, or sage-grouse leks Category C moderate to severe restrictions such as no surface occupancy of areas 40 acres or fewer and protection of view sheds Category D severe restrictions such as no surface occupancy areas larger than 40 acres to protected resources.
The numbers of reductions for each alternative and restriction category are outlined in Table 10 of the Rawlins RFD. The total number of well locations for Alternative 4 (preferred alternative) with restrictions applied is 8,821. This total includes CBNG gas and non-coalbed gas wells. Table 17 in the RFD shows the drilling-related land disturbances associated with those 8,821 well locations (57,819 total acres). The RMP/FEIS assumes that almost none of this disturbance would occur within the SERCD study area because it overlies geological formations found to have no or very low oil and gas potential, a finding consistent with geologic work conducted by the USGS for the EPCA II and EPCA III inventories. Map 4-7 from the Rawlins RMP/FEIS, reproduced below as Map 3.2-1 in this study, shows areas with energy development potential within the Rawlins RMPPA. The map shows a few wells in the SERCD study area, but well data indicate they all are plugged and abandoned, suggesting they failed to produce oil or gas. 3.2 A REVISED REASONABLY FORESEEABLE DEVELOPMENT SCENARIO (RFD2)
An RFD is not intended to set a maximum number of wells allowed or exactly predict the amount of future development. It is designed to serve as a reasonable analytical baseline for identifying and quantifying impacts that then provide guidance in formulating alternatives and strategies to mitigate any identified adverse impacts. The Rawlins RFD, however, may no longer provide a sufficiently accurate scenario of future energy exploration in the SERCD study area given rising energy demands and the BLM proposed leasing of study area lands.
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Map 3.2-1 Reproduction of Map 4-7 from Rawlins RMP/FEIS

The Rawlins RFD reports that oil and gas prices are the single most important factor controlling the amount of future oil and gas drilling and production activity, and recently, oil and gas prices have been volatile. On October 18, 2007, the Wyoming BLM State Office announced its intent to offer lands for competitive sale for oil and gas leasing1 on December 4, 2007. This notice of competitive sale stated that 13 leases were to be offered within the SERCD study area, despite the RFD identifying no or very low development potential (Map 3.1-1). While determining lands to be offered for lease is an ongoing process, it often begins with informal expressions of interest from the public, usually oil and gas companies. The BLM states that this was the case for the 13 lease parcels in the SERCD study area, which were included in the lease sale at the request of an energy company (Ahlbrandt pers. comm.). Several conservation and local groups protested these leases, arguing that potential impacts from oil and gas development were never considered and that no protective measures were applied in the 1990 Great Divide RMP. The leases were temporarily deferred from sale. On August 27, 2008, the BLM extended the temporary deferral of these leases pending further wildlife studies. Why energy companies are interested in areas identified as having almost no oil and gas potential is unclear; only 17% of the proposed leases in the SERCD study area overlie a geological formation identified in the RFD as having very low potential, and the rest overlie geology with no potential. Since energy company information is proprietary, forecasting where they may look to obtain leases in the future will be difficult. However, interest from energy companies suggests that the Rawlins RFD scenario is no longer sufficient for use as a baseline for impacts analysis. Further, Yates Petroleum Corporation provided comments on the BLM RFD. In their February 3, 2008 letter to the BLM, they stated their concern that the numbers presented in the RFD were too low for the known exploration interest in the RMPPA. Yates letter was followed by February 5 and April 24, 2008 letters from Senator Michael B. Enzi requesting BLM response. The BLM responded (undated letter to Senator Enzi) by reiterating that the RFD was merely a planning tool used to distinguish alternatives rather than a limitation imposed on future development in the planning area. This again suggests that the RFD, while meeting regulatory requirements, does not accurately reflect future oil and gas development potential. To account for the possibility that the Rawlins RFD does not reflect actual oil and gas development potential, for this study, we have developed a set of three new RFD scenarios, which are jointly referred to as RFD2. In developing RFD2, we assumed that if leases were available under the current U.S.
1 The Mineral Leasing Act of 1920 provides that all public lands are open to oil and gas leasing unless a specific order has been issued to close an area. Based on the Federal Onshore Oil and Gas Leasing Reform Act of 1987, all leases must be exposed to competitive lease sales. Competitive sales will be held at least quarterly, if land is available, and by oral auction. If land does not receive bids at competitive auction, prospective lessees can obtain a lease by submitting a bid to the proper BLM office. Competitive and non-competitive bids are issued for a primary term of 10 years. December 2008 17 ECOSYSTEM RESEARCH GROUP
energy environment (high and volatile prices and limited supply), energy companies would continue to look for new opportunities. Further, the incoming federal administration has identified energy security as its highest priority item, and this will likely result in expanded exploration. The RFD2 scenarios are used to assess potential resource impacts associated with potential future minimal, moderate, and intensive oil and gas development. RFD2 includes three scenarios based on varying development intensity:
1. 2. 3. Minimal 320-acre well spacing (roughly equivalent to 72 wells/township; Map 3.2-2) Moderate 160-acre well spacing (~ 144 wells/ township; Map 3.2-3) Intensive 80-acre well spacing (~ 72 wells/ township; Map 3.2-4).
A 160-acre well spacing is very common in developed oil and gas fields across Wyoming, and very productive fields (e.g., Jonah) can be developed at as close as 5-acre well spacing. Thus, these development scenarios were chosen to reflect a reasonable range of development intensity should energy development occur in the SERCD study area. These scenarios are not presented as a certainty, but they are useful as a planning tool given the expressed interest from energy development companies. Because the BLM analyses assumed almost no oil and gas development in the SERCD study area, these updated scenarios are used to (1) assess the adequacy of BLM analyses founded on an assumption of no or very low energy development in the study area in light of their offering these lands for lease; (2) provide sideboards for updated impact analyses should oil and gas development occur; and (3) suggest additional mitigations required to protect key social and natural resources from possible energy development activities. The RFD2 scenarios were created using GIS (Hawths Tools, Beyer 2004, in ArcGIS 9.3) to uniformly place well pads in the SERCD study area based on the three intensity levels. Well distribution depended on whether the underlying area was identified as having no or very low oil and gas potential. To obtain the map of oil and gas development potential, we used GIS to georeference and digitize Map 23 from the Rawlins RFD. Wells were placed on the following lands:
For no oil and gas potential area: 13 proposed leases State lands adjacent to the 13 leases For very low oil and gas potential area: All BLM lands All State lands All private lands with split mineral estate
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Wells were then reduced or moved as necessary to account for all mitigations provided by the BLM. These included No Surface Occupancy:
Within a quarter mile of an occupied lek Within Class I VRM areas On slopes greater than 25% Within 500 feet of surface water and/or riparian areas Within either a quarter mile or the visual horizon (whichever is closer) of historic trails.
Wells were placed in Class II VRM areas because the RMP allows leasing in these areas with mitigation, and 54% of the potential leases were in Class II VRMs. However, under all development intensity scenarios, wells were not spaced closer than 160 acres in Class II VRMs. We compared maps of potential RFD2 wells to the map for restrictions by category under Alternative 4 (Map 2-38 in the RMP/FEIS) to ensure that no conflicts existed. No changes were necessary. In order to quantify potential construction-related soil/vegetation surface disturbance, we assigned an amount of short-term and long-term disturbance by well. Short-term disturbance includes everything that could be revegetated (e.g., well pads, pipeline right-of-ways, road shoulders, etc.), while long-term disturbance includes everything related to production (e.g., roads, the graveled turnaround on each pad, compressor stations, etc.). In order to calculate these acres of disturbance by well pad, we assumed 3.53 acres of disturbance per well (28% long term and 78% short term); this is the average surface disturbance associated with the Atlantic Rim, Pinedale, and Jonah natural gas developments in Wyoming.
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Potential Natural Gas Development Scenarios

Legend Social and Natural Resources Watershed Study Project Area Historic Cherokee Trail Occupied Sage Grouse Lek Townships www.ecosystemrg.com with 1/4 mile buffer Roads BLM Class I VRM Rivers BLM Class II VRM Land and Mineral Ownership Energy Development Potential Bureau of Land Management (BLM) Low Potential Non-Coalbed Methane Development (per BLM RFD) Private Lands with Federal Minerals Public Land Leases Private Private Land Leases State Lands Potential Wells from Scenarios National Forests
Saratoga
T17R85
T17R84
130
T17R83
T17R82

T17R81 T17R80
T16R85
T16R84
T16R83
130
T16R82 T16R81 T16R80
T15R85
T15R84
T15R83
T15R82
T15R81
T15R80
Encampment
T14R85
70
T14R84
T14R83
T14R82
T14R81
T14R80
230
T13R85
Minimal Development Scenario T13R84 320 Acre Well Spacing
T13R83
T13R82
T13R81
T13R80
With Without Visual Mgmt. Visual Mgmt. Restrictions Restrictions # of Wells at 320 Acre Spacing Potential Short Term Disturbance
T12R85
287 wells 790 acres
232 wells 639 acres 180 acres 819 acres

T12R83 T12R82 T12R81 T12R80
Potential Long Term Disturbance T12R84 acres 223 Potential Total Surface Disturbance 1,013 acres
Map 3.2-2 RFD2 Minimal Development Scenario
WYOMING COLORADO
125

Saratoga
T17R85
T17R84
130
T17R83

T17R82 T17R81 T17R80
T16R85
T16R84
T16R83
130
T16R82 T16R81 T16R80
T15R85
T15R84
T15R83
T15R82
T15R81
T15R80
Encampment
T14R85
70
T14R84
T14R83
T14R82
T14R81
T14R80
230
T13R85
Moderate Development Scenario T13R84 160 Acre Well Spacing
T13R83
T13R82
T13R81
T13R80
With Without Visual Mgmt. Visual Mgmt. Restrictions Restrictions # of Wells at 160 Acre Spacing Potential Short Term Disturbance
T12R85
562 wells 1,547 acres
460 wells 1,267 acres 357 acres

T12R83 T12R82 T12R81 T12R80
Potential Long Term Disturbance T12R84 acres 436 Potential Total Surface Disturbance 1,984 acres
1,624 acres
WYOMING COLORADO
125
Map 3.2-3 RFD2 Moderate Development Scenario

Saratoga
T17R85
T17R84
130
T17R83

T17R82 T17R81 T17R80
T16R85
T16R84
T16R83
130
T16R82 T16R81 T16R80
T15R85
T15R84
T15R83
T15R82
T15R81
T15R80
Encampment
T14R85
70
T14R84
T14R83
T14R82
T14R81
T14R80
230
T13R85
Intensive Development Scenario T13R84 80 Acre Well Spacing

(160 acre spacing within Class II VMRs)
T13R83
T13R82
T13R81
T13R80
With Without Visual Mgmt. Visual Mgmt. Restrictions Restrictions # of Wells at 80 Acre Spacing Potential Short Term Disturbance T12R85 Potential Long Term Disturbance 1,010 wells
T12R84
908 wells 2,500 acres

T12R83 T12R82 T12R81
2,781 acres 784 acres
705 acres 3,205 acres
T12R80
Potential Total Surface Disturbance 3,565 acres
WYOMING COLORADO
125
Map 3.2-4 RFD2 Intensive Development Scenario
4. REVIEW OF RMP/FEIS BY RESOURCE This section provides a review of the adequacy of the RMP/FEIS discussion and analyses in relation to land use planning and environmental analysis requirements, other land use plans in the study area, and particularly in light of the potential for future energy (oil and gas) development activities as per RFD2 scenarios. For each resource, suggested additional mitigation measures to ensure resource protection are provided where necessary. Generally, resource topics follow those in the Rawlins RMP/FEIS, but several have been combined to better reflect SERCDs primary concerns. For instance, transportation is discussed under socioeconomic resources. 4.1 AIR RESOURCES
Air quality is of concern to all residents of Wyoming. On February 21, 2008, the eight-hour average for ozone near Boulder, Wyoming reached 122 parts per billion (ppb; Potts pers. comm.), and in August, 2008, the eight-hour average for ozone reached 85 ppb near the Atlantic Rim in Carbon County, Wyoming.2 Both of these ozone events exceeded the EPAs standard of 75 ppb. Ozone is known to cause adverse health effects, including decreased lung functions and increasing respiratory symptoms to serious indications of respiratory morbidity (EPA, 50 CFR, 58 CFR) National Ambient Air Standards for Ozone, Final Rule March 2008). Ozone is often associated with oil and gas development, and SERCD is concerned about the potential for degraded air quality in the region. 4.1.1 Affected Environment
The RMP/FEIS states,

Data provided by the WDEQ-AQD [Wyoming Department of Environmental Quality Air Quality Division] are used to establish background air quality levels. Information collected from the nearest applicable monitoring stations indicate current concentrations comply with applicable standards. However, current and complete data on the concentration of criteria air pollutants for the RMPPA are not available.
If current and complete data on the concentration of criteria pollutants are not available in the area of concern, then a monitoring network that addresses these issues must be developed for use in the RMP/FEIS analysis. FLPMA requires that The secretary shall prepare and maintain an inventory of all public lands and their resources, giving priority to areas of critical environmental concern. This inventory shall remain current so as to reflect changes in conditions. To fulfill this requirement, the BLM must
We contacted the WDEQ-ADQ, but was unable to obtain a copy of the Ozone Event Analysis for this event prior to completion of this watershed study.
inventory the air quality in project areas prior to project planning and continue monitoring during the life of the project. Table 3-1 in the RMP/FEIS summarizes data sources and measured background concentrations for the criteria air pollutants in the RMPPA. Carbon monoxide data were collected from 1978 to 1979 at Ryckman Creek. Nitrogen dioxide data were obtained from the Green River Basin Visibility Study site in 2001. Ozone data were collected from 1998 to 2001, also from the Green River Basin site. The particulate matter data were collected by the WDEQ in 2002 in Cheyenne, Wyoming, and the sulfur dioxide data were collected at the Northwest Pipeline Study Area in 1982 and 1983. These ambient concentrations were measured against state and federal standards, and percentages of the standards were calculated for each pollutant. The RMP/FEIS states, Specific air quality monitoring is not conducted throughout much of the project area, but air quality conditions are likely to be good, as characterized by limited air pollution emission sources. It also states, Air quality monitoring provided by the State of Wyoming shows that air quality in the Rawlins area is considered to be in compliance with state and federal air quality standards. If the data are not available, it can not be accurately stated that the air quality is considered to be in compliance. Kelly Bott of the WDEQ-AQD (pers. comm.) stated that the air in the SERCD project area has good dispersion, but she would not say that the air quality is good. She said that no air quality violations occurred in the project area; however, she is concerned with the recent BLM RMP air quality analyses and the lack of mitigations included in the RMPs. As per Section 1502.16 of the CEQ guidelines, the EIS must succinctly describe the environment of the area(s) to be affected or created by the alternatives under consideration. The use of measured background concentrations that either are not close geographically to the RMPPA or very old fails to meet this standard. These data points likely do not accurately represent the affected environment. The Wamsutter air quality monitoring station is located approximately two miles west of Wamsutter and 40 miles southwest of Rawlins. The station began operation in March 2006. Monitoring equipment includes an ozone analyzer, an oxides of nitrogen analyzer, a sulfur dioxide analyzer, a PM103 monitor, and meteorology sensors. Although a year of monitoring is necessary before data are reliable (Botts pers. comm.), data from this station have been available since 2006. It is unclear why the air quality information from the Wamsutter monitoring station was not used to update the ambient conditions in the RMP/FEIS. In addition, the monitored total nitrogen deposition reported for the Bridger Wilderness exceeds the USFS proposed level of concern (LOC; MBLRMP), and therefore should be discussed further in the RMP/FEIS.
PM10 are particulate matter with a diameter of 10 micrometers or smaller.

24 ECOSYSTEM RESEARCH GROUP
December 2008
4.1.2
Environmental Consequences
The Air Quality portion of the Environmental Consequences section of this document lacks a complete discussion of reasonably foreseeable effects associated with the proposed action, as described in the BLM NEPA Handbook. According to CEQ guidelines, the discussion must cover the environmental impacts of the alternatives, including the proposed action and any adverse environmental effects that cannot be avoided should the proposal be implemented. A limited exploration of the environmental impacts of the alternatives is provided in Appendix 4 of the RMP/FEIS, but no discussion of the significance of those impacts is made in the Environmental Consequences section. While incremental amounts for individual pollutants are given for each of the alternatives, no discussion of the impacts to overall air quality or the significance of those impacts is provided. The Emission Assumptions section of Appendix 4 states that a qualitative emission comparison approach was selected for the RMPPA air quality analysis. This approach was used because (1) lack of specific project information on location, types, and magnitude of potential projects; and (2) time constraints in completing the analysis. This explanation for the adoption of a qualitative approach does not justify curtailing the study of impacts associated with ozone and other environmental issues raised by this RMP/FEIS. This approach is inconsistent with CEQ guidance. A conclusion in Appendix 4 of the RMP/FEIS states the following:
Because a quantitative relationship between the expected air emissions calculated above and the subsequent potential impacts on ambient criteria pollutant concentrations, visibility, atmospheric deposition, or ozone are not known, it is not possible to draw any conclusions as to potential expected impacts on these air quality values from any alternative. BLM intends to make quantitative estimates of these impacts for project-specific EISs and in the statewide air quality analysis.
Referring to documents that will be released at some unknown time in the future is not an adequate discussion of all possible effects and conflicts associated with the project description. Reasonably foreseeable effects associated with the proposed action must be evaluated. The reasonably foreseeable effect related to the increase in ozone levels associated with the release of nitrogen oxides (NOx) and volatile organic compounds (VOCs) from increased oil and gas development is not adequately discussed. Recently, ozone levels have risen above both the National Ambient Air Quality Standards (NAAQS) and the Wyoming Ambient Air Quality Standards (WAAQS) for the region around Pinedale. While this area is outside the RMPPA, ozone levels are a concern in the state and could have serious consequences if not given due consideration.
Even if only limited information exists, the Environmental Consequences section must estimate the effects. Because air quality has great potential to affect not only developed areas but also recreational areas, air quality must be analyzed and discussed as both a quality of life issue and a human health issue. Wyoming Governor Dave Freudenthal agrees, and in his comments to the BLM (Bennett 2008), he states the following:
When describing air quality in a qualitative manner, it is critical that the emissions scenarios be presented in an objective and scientifically defensible way. It is not only confusing, but misleading to present emissions by summing all the various pollutants as in Figure 4-25. Air pollutants are emitted from a variety of sources through a variety of mechanisms, and the effects of various pollutants impact human health at vastly different magnitudes. Therefore, presenting a summary of emissions as depicted in Figure 4-25 is inappropriate for presentation to the public.
The air emissions analysis for the RMPPA was reportedly conducted using 9,615 non-coalbed and CBNG wells operating in 2023 (RMP/FEIS p. A4-16). A letter from Yates Petroleum Corporation (2008) to the BLM stated concerns that the
agencys Preferred Alternative projects a total number of 8,822 wells. The Continental Divide Creston Natural Gas project alone projects a total number of 8,950 wells 128 more than the total number projected for the entire planning area.
If the emissions analysis was conducted for only 9,615 wells, the air emissions and thus the environmental consequences are likely grossly underestimated for the RMPPA. Each additional well above the RMP/FEIS planning levels would further affect air quality and thus must be studied to determine site-specific impacts. If wells are drilled at the levels described in the RFD2 scenarios, air quality issues such as the recent ozone excesses in the Pinedale area likely would occur in the SERCD study area. 4.1.3 Cumulative Effects
Cumulative impacts due to criteria air pollutants have not been quantified in the RMP/FEIS. This omission contradicts CEQ guidance (40 CFR 1508.7). The RMP/FEIS states,
BLM has chosen to describe potential air quality impacts in the Rawlins Resource Management Plan qualitatively. In the near future (2007), BLM plans to analyze RMP cumulative far-field air quality impacts quantitatively with screening dispersion modeling. This would be part of a statewide analysis BLM refers to as the State of the Atmosphere study.
If these data were available in 2007, they should have been included in the 2008 RMP/FEIS analysis. In Appendix A of the RMP/FEIS, the following statement is made:
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Given the low ambient concentrations that exist in the Rawlins RMPPA for criteria pollutants except ozone, it is expected that the cumulative increase in emissions for all of sources in the region of influence (ROI) of carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), PM10, and PM2.5 would not cause any exceedance of state or federal ambient air quality standards.
Assuming any cumulative increases would not cause any state or federal air standards to be exceeded without a study of those impacts is contrary to CEQ guidelines. Appendix A continues,
Because a quantitative relationship between the expected air emissions calculated above and the subsequent potential cumulative impacts on the air quality values of visibility, atmospheric deposition, or ozone are not known, it is not possible to quantify potential impacts on these air quality values from the sources in the ROI. However, because air quality analyses from recent energy development projects, such as the Desolation Flats project (USDI, BLM 2003), estimate potential impacts on visibility, the possibility that the emissions described in Section 4.2 may contribute to significant impacts on visibility must be considered.
Chapter 4 of the RMP/FEIS reports, Results of quantitative analyses using modeling performed for these projects (Desolation Flats or Atlantic Rim) suggest that RMPPA activities could contribute to significant impacts to visibility in Bridger, Fitzpatrick, Mount Zirkel, and Rawah Wilderness areas. If the air emissions may or could have impacts on air quality, even if the consequences are not known, a discussion of the effects must be conducted. In addition, the impacts associated with ozone are not adequately explored or discussed in the RMP/FEIS. The ozone precursors, NOx and VOCs, were reported in the RMP/FEIS to increase by 201% and 48%, respectively, by the year 2023 (RMP/FEIS p. A4-25). Therefore, it is reasonable to predict that increased ozone may be an environmental consequence of the planned activity. The RMP/FEIS states,
In addition to these findings, monitoring of total nitrogen deposition in the Snowy Range shows deposition above the USFS LOC. Accordingly, emissions described in Section 4.2 may contribute to significant impacts on total nitrogen deposition. BLM intends to make quantitative estimates of these impacts in project-specific EISs and in the statewide air quality analysis.
Referencing future documents or analysis is not an acceptable means of addressing impacts or the significance of impacts associated with project activities. This approach also does not address the cumulative effects associated with multiple projects. If the nitrogen deposition already is above the USFS LOC, one can reasonably assume that any project development in the project area would cause the levels of nitrogen deposition to increase more. Chapter 4 of the RMP/FEIS reports,
Recent regulatory monitoring of ozone concentrations near natural gas development in the Upper Green River Basin recorded elevated ozone levels during the winter months. It should be noted that, to date, there is no finding of an ozone air quality standard violation at the monitoring sites in the Upper Green River Basin.
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Again, elevated ozone concentrations are a concern to all residents of Wyoming, and to state only that no violations have been recorded to date, without including an analysis of the impacts, is contrary to CEQ guidance. Each additional well above the RMPPA planning levels would add to the cumulative effects on air quality and thus must be studied to determine site specific impacts. It is probable that if wells are drilled at the levels described in the RFD2 scenarios, air quality values such as visibility would deteriorate in the SERCD study area. Ambient criteria pollutant concentrations will increase and the increased emissions will likely have significant impacts on total nitrogen deposition in adjacent areas. 4.1.4 Mitigations
4.1.4.1 Mitigations Identified by the BLM No discussion of the mitigations associated with the proposed action is made in the main document of the RMP/FEIS. A brief discussion of mitigations is included in Appendix 4, Tables A4-13 to A4-15 (see below); however, the language suggests that these should be considered and the information in the tables does not detail the mitigations, only the potential costs and benefits of the vague mitigations. Several BMPs are listed in Appendix 13 (see below). Note that the language of BMPs relies on discretionary language instead of the enforceable language generally required in a mitigation. Placement of the proposed mitigations only in an appendix is contrary to CEQ guidelines (CEQ 1502.16(h)). The mitigations for the proposed action should address all reasonably foreseeable effects associated with the stated environmental consequences. The proposed mitigations stated in these appendices do not address all of the environmental consequences or cumulative impacts associated with proposed activities. Furthermore, the RMP/FEIS states in Appendix 4 that,
Table A4-15 shows additional mitigation measures to be considered in the Rawlins impact assessment. BLM has no authority to require any application of these measures, although industry is encouraged to implement these measures on its own before they are required by WDEQ. Advances in technology are likely to offer new mitigation options during the time covered by the RMPPA. Under NEPA, the planners of individual projects in the planning area must recommend mitigations measures that are appropriate for the projects. The WDEQ, as the permitting authority, will review permit applications and require specific emission control devices and measures.
The BLM has the authority to add stipulations to lease agreements and mitigations could be included as stipulations as defined by 43 CFR 3101.1-2. Mitigations and BMPs relating to air quality in the RMP/FEIS are listed below.
Air Quality Impact Technical Support Document (Appendix 4)

Mitigation measures, such as those discussed in this AQTSD4 (see p. 28), should be considered. Some of these measures include dust suppression and control during construction, electric power generation for natural gas compressor engines, flareless completion, and natural gas compressor engine nitrogen oxide controls.
Reducing Nonpoint Source Pollution with Best Management Practices (Appendix 13) The following BMPs are suggested to limit the emission of fugitive dust:
The use of water for dust abatement on roads may be considered on a case-by-case basis. The water should meet state standards for this use and be permitted by the Wyoming State Engineers Office. There should be no traces of oil or solvents in water used for dust abatement. Only the water needed for abating dust should be applied; this method should not be used as a water disposal option under any circumstances. All-weather surfacing of roads using gravel or asphalt paving and the application of water or suitable chemicals to keep dust in place on roads or materials stockpiles Appropriate road design, including shape, drainage, and surface material, to protect the roadbed from being eroded Reduction of fugitive dust emissions by improving county roads, wetting of construction roads during construction period, and speed reductions from a 40 mph base speed Reduction of nitrogen oxide emissions (NOx) using Best Available Control Technology (BACT) field and sales compressors (selective catalytic reduction), temporary diesel generators, and voluntary use of electric engines at all locations where combustion engines, generators and compressors are used Reduction of natural gas flaring using Green Completions at new well completions Volatile organic compound (VOC) reductions at all locations where glycol dehydrators and condensate storage tanks are used Lower compressor emissions at all sales pipeline locations The use of microhole drilling will reduce fugitive dust emissions with lighter equipment on roads, use smaller site disturbances, and will decrease NOx emissions with the use of smaller drill engines. Reduce VOCs from storage vessels and fugitive dust emissions from truck travel by using condensate pipelines. Also use Stage I vapor controls for condensate transfer if only using truck transfer of condensates. Reduce peak emissions and impacts at all drilling sites by using phased oil and gas development to reduce peak emissions.
4.1.4.2 Recommended Additional Mitigations In addition to the mitigations discussed in the RMP/FEIS, these additional mitigations should be explored and incorporated in future project planning. Table 4.1-1 describes these additional mitigations for air quality.
Air Quality Impact Technical Support Document; see Appendix 4 of RMP/FEIS.

December 2008
Table 4.1-1 Recommended Additional Mitigations for Air Resources Install ambient air quality monitoring stations in project area to accurately assess MITIGATION MEASURE air quality prior to project planning. These stations could be portable to allow for increased areal monitoring. Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing All sites where energy development has a potential to occur NA An assessment of ambient air quality can be used to make project decisions WDEQ-AQD/BLM Prior to project development Use facility inspections to evaluate the integrity of air emission control systems. All locations where emissions control systems may be compromised, such as combustors (pollutant incinerators on condensate storage tanks and dehydration unit process vents). NA Regular inspections to evaluate emission control systems eliminate releases of VOCs and Hazardous Air Pollutants WDEQ-AQD/BLM Implement during production period
Although timing the drilling and production rates of new wells to average the air emissions over a longer time period was listed as a mitigation in an appendix, it was not adequately discussed in the RMP/FEIS. There may be significant impacts related to constructing oil and gas production infrastructure due to the "boom and bust" nature of that development. Therefore any project alternatives that are developed should include a phased development alternative. Just as determining where oil and gas development is appropriate, determining when development is appropriate should also be a consideration of the RMP/FEIS. An alternative that incorporates a phased development could help reduce the significance of air quality impacts by spreading them out over a period of time. Preparing infrastructure for peak production during a boom results in environmental impacts that could have been minimized through a planned or phased approach to development.
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4.2
LIVESTOCK GRAZING
Grazing opportunities on public land are of crucial importance to the economic diversity of Carbon County and the study area, and are key to maintaining existing ranches. Keeping ranches as working landscapes leverages and amplifies other resource values including biodiversity, aesthetics, water quality, open space, and wildlife habitat to name a few. Maestas et al. (2002) showed that private ranch lands offered improved biodiversity over nature reserves and ranchettes. Working landscapes are tremendously important in promoting and safeguarding ecosystem services (Brunson and Huntsinger 2008). Livestock grazing and ranching in general must be better understood and documented in relation to potential energy development so that economic and quality of the life impacts to Carbon County and Encampment area ranchers can be anticipated and mitigated. Many successful ranches have federal grazing land leases. One study found that one-third to one-half of ranchers would have to sell their ranches if they lost their public land allotments (Sulak and Huntsinger 2007). Maintaining ranching with its associated public land grazing as a viable economic sector is critically important. SERCD study area residents enjoy the cultural values associated with large wildlife populations in the county. In addition to being intrinsically attractive, wildlife provides economic benefits. Ranchers in the West occasionally offer outfitted hunting opportunities or charge hunter access fees to augment their ranching income (Brunson and Huntsinger 2008). Additionally, ranchers may have the option of exploring ecotourism opportunities where wildlife is one of the key attractions. Many ranches successfully host ecological-based tourism. 4.2.1 Affected Environment
The information contained in the Affected Environment section is inadequate. Carrying capacity for domestic livestock is based on ecological sites and similarity indices, or range sites and condition classes. In the discussion of allotments, there is no information on the quantity and quality of herbage yield. Much of the information contained in the RMP/FEIS relative to livestock grazing is interesting but superfluous to the Rawlins RMPPA. For example, the discussion of large increases in elk populations across Wyoming and neighboring states is not supported by literature citations, and other states and regions elk populations are irrelevant to grazing in this area. If local elk populations have impacted forage utilization, this should be documented. The statement that elk populations have increased several-fold across Wyoming and interstate herds move between this state and Colorado, Idaho, Montana, and Utah should be cited and the relevance should be explained. Elk populations are monitored by the Wyoming Game and Fish Department (WGFD) and, if relevant, those data should be used to support whatever point was intended. The current use figures (RMP/FEIS Table 3-5) provide the number of actual animal unit month (AUM) use. While these numbers are helpful, including the permitted use figures would allow for better
understanding of the kind of buffer there might be between actual and permitted numbers. This would identify whether areas are underutilized, and therefore, oil and gas disturbances are less likely to impact current grazing numbers. There is no documentation of utilization figures, and the intensity of grazing in the area is unclear. Lacking potential use numbers, the Affected Environment section provides no information regarding the acreage available for grazing. Further, Table 3-5 only shows actual AUMs through the year 2000. This table is eight years out of date and should have been updated. Given that disturbance figures are based on acreage, it would be helpful to have an understanding of the amount of land historically and currently grazed and area permitted to be grazed by domestic livestock. This would allow the effects of existing energy development on livestock grazing operations. Section 3.7.2 of the RMP/FEIS states,
There is [sic] a total of 582 grazing allotments within the Rawlins RMPPA (Table A29-1 in Appendix 29 and Map 3-3). These are spread across 3,492,744 acres of public land (52.9%), other federal land (0.8%), state land (5.3%), and private land (40.9%). Allotments range in size from 20 acres to 291,954 acres of public land. There are 222 allotments that contain 640 acres (one section) or less of public land, 160 allotments that contain between 640 and about 2,500 acres of public land, 115 allotments that contain between 2,500 and 10,000 acres, and 80 allotments that each contain more than 10,000 acres of public land. These 80 allotments make up 76% of the public land in the Rawlins RMPPA. The public and other federal lands that BLM administers grazing upon provide 469,575 AUMs for grazing use. The number of AUMs continues to fluctuate for various reasons. Reductions occur as a result of such actions as sheep-to-cattle conversions or following changes in season or duration of use.
The Affected Environment section also identifies an expansion of invasive poisonous plants due to surface distribution related to oil and gas development though no such information is contained in the Vegetation section. The allotment management descriptions present examples of successful BMPs used on individual allotments to improve grazing and ecological stability (selected by range staff who work on the allotments) and describe the management change and results in these allotments. The presentation of arbitrarily successful examples may work well when there are no disagreements, but this selective presentation of narrative descriptions does not appear to satisfy the BLM NEPA Handbook which states, "We recommend that the descriptions of the specific elements be quantitative wherever possible, and of sufficient detail to serve as a baseline against which to measure the potential effects of implementing an action." The BLM Planning Handbook under the Livestock Grazing Section (Appendix C) suggests the BLM
Identify lands available or not available for livestock grazing (see 43 CFR 4130.2(a)), considering the following factors: 1. Other uses for the land 2. Terrain characteristics
3. 4. 5.
Soil, vegetation, and watershed characteristics The presence of undesirable vegetation, including significant invasive weed infestations The presence of other resources that may require special management or protection, such as special status species, special recreation management areas (SRMAs), or Areas of Critical Environmental Concern (ACECs).
Of the five factors described above, none of them have been effectively analyzed in the RMP/FEIS. Given the potential use of land for energy development, it is not clearly stated what this development will do to land availability. Terrain and vegetation characteristics are not quantified. The fifth criterion is especially pertinent in considering how special status species protections will require special management. 4.2.2 Environmental Consequences
Two significance criteria are listed for grazing in the RMP/FEIS:

Resource management actions cause a reduction in forage that results in a greater than 10-percent permanent reduction in animal unit months (AUM) available for livestock grazing with the RMPPA or a given allotment. Resource management actions reduce or eliminate the opportunity to run the livestock of choice.
The first criterion is inadequate to ensure adequate forage. Short term impacts to permittees that may not reduce forage but that reduce stocking rates can dramatically harm ranching operations. Short term unavailability of permitted pasture can necessitate replacement pastures, which can be difficult to identify and expensive to use. Death losses from vehicle collision, poisoning, or drowning are significant. The recent experience of energy development impacts to grazing on the Jonah Field within the Pinedale Field Office shows dramatic impacts to ranchers. Perhaps more important than forage reduction is the increase in management required under the more intensive development scenarios. Pipelines, roads, and traffic all contribute to added difficulties in managing livestock. These issues should all be considered in determining significance. The RMP/FEIS projects that 107 allotments with about 220,000 AUMs (80% of total) would be impacted by minerals management. This figure represents those areas with high or moderate oil and gas potential. The list of impacts described in this chapter (e.g., loss of palatable forage, open gates, tooth wear, mortality) can be significant and mitigation measures should be developed. The RMP/FEIS acknowledges loss of AUMs from roads and increased weed encroachment. It also suggest that the increased road network would be beneficial as it would allow improved access, but other areas in Wyoming have generally found any benefits offset by increased road and vehicle use making it difficult to move cattle and road disturbances encouraging weed encroachment.
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The RMP/FEIS suggests that increased water availability to livestock as a result of wells being drilled would be beneficial, but past experiences have shown this to be a temporary and not dependable water source. In both the Jonah and Pinedale Anticline project areas, well maintenance by energy operators has been poor, and wells have gone unused (Sommers pers. comm.). The impact assessment in the RMP/FEIS assumes a similar level of grazing based on the 10-year average from 1991 to 2000. This assumption does not take into consideration drought cycles or the changes in precipitation and temperature that are anticipated under a changing climate. Figure 4.2-1 and Figure 4.2-2 show that despite the recent drought, temperatures and precipitation around Saratoga are both on the rise. This suggests that assumptions based on temporally static climate variables are unrealistic. Given that vegetation changes are strongly tied to temperature and precipitation trends, the RMP/FEIS should not assume a stable grazing base when considering potential impacts from management activities, particularly oil and gas development (see also Section 4.10).
18 16 14
Precipitation (inches) _
12 10 8 6 4 2 0
1950 1960 1970 1980 Years 1990 2000
Figure 4.2-1 Saratoga annual precipitation 19492007
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65 64 63 Degrees Fahrenheit 62 61 60 59 58 57 1950 1960 1970 1980 Years 1990 2000
Figure 4.2-2 Saratoga average monthly summer (JulySeptember) temperatures (19492007)
The impacts to herbivory from weed infestations should be documented. If increases in weed infestations are anticipated to occur as a result of the preferred alternative, mitigations to protect livestock grazing should be developed. 4.2.3 Cumulative Effects
The cumulative effects section of the RMP/FEIS provides a qualitative review of potential impacts to grazing resources that could result from oil and gas development, primarily due to forage removal and weed proliferation. The RMP/FEIS states that the
implementation of BLMs Mitigation Guidelines, restrictions on surface use, continued implementation of Standards for Healthy Rangelands (USDI, BLM 1997), vegetation treatments, and monitoring efforts would provide protection to forage resources on federal lands and lands with federal subsurface minerals, which would help reduce overall effects to livestock grazing operations.
It is unclear how these guidelines will ensure that grazing is not significantly impacted given that the Mitigation Guidelines (Appendix 1) make no mention of vegetation (beyond threatened species) or grazing and there are no restrictions on surface use related to grazing. Further, the vegetation treatment
guidelines are discretionary and only indirectly discuss revegetation of well pads, and monitoring efforts are not detailed. The RMP/FEIS acknowledges that areas with concentrated mineral development would result in substantial rangeland degradation and thereby jeopardize maintaining or fulfilling the Standards for Healthy Rangelands on some allotments. Additional mitigations should have been included to ensure protection of grazing resources given these acknowledged significant cumulative impacts. 4.2.4 Mitigations
4.2.4.1 Mitigations Identified by BLM BLM outlines a series of BMPs to avoid or minimize the impact of energy development on grazing. While these BMPs should be implemented, they should be made into mandatory standards, not discretionary suggestions.
Vegetation Treatments, Forest Practices, and Range Improvements (Appendix 19)

Under Grazing Management Prescriptions, several BMPs are suggested: Consider season of use, soil type, precipitation, rangeland condition, stocking rates, type of livestock, plant growth rates, and range site potential. Manage livestock use of plant communities so that plant cover and desired community composition are maintained and erosion and sedimentation are not accelerated above acceptable levels. Maintain or increase plant cover, including residue, which should in turn slow down or reduce runoff and increase water infiltration. Adjust livestock stocking rates, distribution, timing and duration, and kind and class to improve vegetation health and soil cover. Develop additional water sources to improve distribution of livestock and control water source availability to move use in or out of specific areas. Locate salt/mineral and supplemental feeding facilities in areas to increase use from livestock. Hoof action increases vegetation disturbance and accelerates the mineral cycle, thereby improving longterm vegetation health.
Under Design of Range Improvements, one BMP is provided: All range improvements will be designed and constructed in a manner to minimize environmental impacts while maximizing function and cost-effectiveness. Prior to the installation of any range improvements, an environmental analysis will be prepared. Whenever possible, water will be provided to benefit the seasonal needs for wildlife.
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1.1.4.2 Recommended Additional Mitigation Again, the RMP/FEIS relies on discretionary BMPs rather than the enforceable language generally required in a mitigation. BMPs should be reissued as mitigations in the ROD or future site specific NEPA analyses. We also recommend the addition of the following mitigations for livestock grazing to ensure protection of these resources.
Table 4.2-1 Recommended Additional Mitigation for Livestock Grazing Holders of energy leases will meet no less than quarterly with BLM grazing Mitigation Measure permittees where grazing/energy leases overlap. Energy leasees will purchase equivalent off-site foraging areas and/or hay when foraging areas are excluded due to drilling/development and make that forage/hay available to the grazing permittees during the equivalent grazing season and within a location that is economically viable to the permittees. Location Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Monitoring /Reporting Action Establish a mandatory coordination protocol so that forage lost due to areas excluded by fencing around wellheads and access roads, is compensated for by direct purchase by the energy leasee of off-site grazing areas or hay. Effectiveness Criteria Monitoring data Responsible Agency BLM and Energy Leasees Timing Quarterly when exploration is foreseeable and fencing needs have been identified When industrial use dominates an allotment to the point of making it unsuitable Mitigation Measure for livestock grazing, BLM would consider granting special non-use so that livestock could be removed without penalty for a specified amount of time. Location Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Monitoring /Reporting Action Annual BLM evaluation report to SERCD Effectiveness Criteria Responsible Agency Timing Mitigation Measure Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified Develop a program for local landowners to participate in conservation efforts including a local initiative to develop and implement Contracts for Environmental Services as a means to preserve Carbon Countys working landscapes, working ranches, and open space values. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified
Location Effectiveness Criteria Responsible Agency Timing
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Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure
Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing
Well pads, pits, and other facilities that could be hazardous to livestock would be fenced to keep livestock out, and the fences maintained in functioning condition. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Supplement to application for permit to drill Monitoring data BLM and Energy Leasees Quarterly when exploration is foreseeable and fencing needs have been identified Livestock grazing management would be conducted to meet the Standards for Healthy Rangelands. Improvements for livestock grazing management would be constructed and managed to meet the Standards for Healthy Rangelands. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) BLM monitoring and annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified Springs and seeps used for livestock water sources would be fenced to protect these water sources and to maintain unrestricted flow rates. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) BLM and SERCD; BLM annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified Livestock grazing Best Management Practices (BMP) would be implemented to maintain or restore habitat conditions for various fish and wildlife species. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) BLM annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified Rangeland and vegetation monitoring would be conducted to detect changes in grazing use, trend, and range conditions. These data would be used to support and direct grazing management decisions consistent with national policy. These efforts would help ensure that livestock grazing meets objectives for rangeland health and resolves conflicts with wildlife habitats or may provide a benefit to wildlife habitats. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) NRCS/ BLM transect data; annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified
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Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure
Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure
Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing

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Existing fences would be reconstructed or modified to meet BLM wildlife friendly standards to reduce or offset impacts to wildlife where determined necessary. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM and Energy Leasees Quarterly when exploration is foreseeable and fencing needs have been identified Surface disturbing activities will be coordinated with livestock grazing permittees to minimize the effects of the surface disturbance on other approved operations. To the maximum extent practicable, this effort would include consulting on scheduling of operations to mutually minimize effects. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM and Energy Leasees Quarterly when exploration is foreseeable and fencing needs have been identified Any damage to the function of range improvements from BLM approved operations (e.g., fence damage, cattle guard cleaning, livestock loss) would be repaired immediately or remedied by the operator causing the damage. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM or Energy Leasees Quarterly when exploration is foreseeable and fencing needs have been identified All range improvements (e.g., stock water tanks, pipelines, corrals) would be avoided by 500 feet unless no other alternative is available and impacts can be mitigated as per the BLM Assistance Officer. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified Compensation would be provided by operators for cattle lost to oil and gas activities (includes deaths from pits and animals struck on roads). This would be addressed in the same manner as a road maintenance agreement, with operators making payment based on their level of activity, not on the proximity to the dead animal. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM, SERCD, and Energy Leasees Quarterly when exploration is foreseeable and fencing needs have been identified
Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing
Oil and gas or other operations would be conducted so as to retain access to cattle movement corridors (trails) so that livestock can be managed. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified Pipeline projects would be conducted to allow natural movement of livestock through the field. Gaps would be provided in the trenching process to allow cows to move or get pipeline projects completed while cattle are not on the allotment. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified Grazing management decisions would be based on monitoring data, both shortterm and long-term, which would be jointly developed by grazing permittees and the appropriate federal land management agency. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified Protocols for monitoring would be consistent with the Memorandum of Understanding in place between the National Public Lands Council and the BLM. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified A menu of incentive based mitigation and conservation measures would be developed that will encourage local, private land owners to participate. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) SERCD reporting Monitoring data BLM and SERCD Quarterly when exploration is foreseeable and fencing needs have been identified
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Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing Mitigation Measure Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing
Acceptable levels of grazing would be maintained to benefit both sage-grouse and agricultural operations. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified BLM would meet with permittees, at minimum, twice annually before turnout to schedule maintenance activities and after the grazing season to discuss monitoring. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified A mitigation plan would be developed with state and local representatives to maintain existing ranch lands. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) SERCD, county, and permittees reporting Monitoring data SERCD Quarterly when exploration is foreseeable and fencing needs have been identified A fund would be established to develop range improvement projects away from individual oil and gas developments. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Annual reporting Monitoring data BLM and Energy Leasees Quarterly when exploration is foreseeable and fencing needs have been identified
4.3
OFF HIGHWAY VEHICLES (OHV)
OHV use is an accepted and a popular recreation activity within the RMPPA. OHVs provide access to the many recreational opportunities offered within the area, and OHV riding is a popular recreation activity in and of itself. OHVs also provide authorized users and their employees, such as government agencies, ranches, oil and gas companies, and various utility providers, motorized access to administer, manage, and/or maintain authorized developments and activities that are integral to the continued operation of their business or facilities.
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4.3.1
Affected Environment
Per 43 CFR 8342.1, the RMP/FEIS adequately designates OHV use areas, which are classified as open, limited, or closed to motorized travel (RMP/FEIS Appendix 21). The OHV management goal emphasizes the continued availability of OHV opportunities. OHV use is closely related to several environmental resource issues addressed in other sections of Chapter 3 of the RMP/FEIS. Aspects of OHV use that are specifically addressed in other sections of the RMP/FEIS include Recreation (RMP/FEIS Section 3.1) and Transportation and Access (RMP/FEIS Section 3.14). 4.3.2 Environmental Consequences
The BLM analysis of potential OHV impacts identified mineral development, including oil and gas development, as having already had a significant impact on OHV use because of a substantial reduction in the quality of OHV experiences available in the RMPPA. Further oil and gas development will continue to reduce the quality of OHV experiences and displace users, although increased development may mean more roads, thus more access to some areas previously not accessible by motorized vehicle. For all RFD2 scenarios, the quantity of accessible areas will be inversely related to the quality of the experience. However, given the RFD used in the RMP/FEIS, the potential impacts of continued mineral development, including oil and gas development, on OHV use are explored and fully disclosed. We do not identify any conflicts with the RMP/FEIS and other local land use plans regarding OHV. Wildlife or other resource management actions could limit or preclude OHV use in some areas in order to protect or preserve other important resource values. 4.3.3 Cumulative Effects
The BLM adequately identified the cumulative impacts to OHV use arising from the significant issues they identified. However, under the moderate or intensive RFD2 scenarios, cumulative impacts could be more substantial than listed in the RMP/FEIS given the addition of new roads. 4.3.3.1 Mitigations Identified by BLM For the OHV resource, the RMP/FEIS identifies the following mitigations: Clarification of OHV Designations and Travel Management in the BLM Land Use Planning Process (Appendix 21, FEIS) Under the section Road and Vehicle Route Designation Process for Limited to Designated OHV Areas, the following mitigations are listed:
During the travel management planning period, the following will occur: Interim management guidelines for identification of the road and vehicle route network, including signing and maintenance, will be defined. Additional data needs and collection strategy will be outlined. A clear planning sequence, including public collaboration, criteria, and constraints for subsequent road and vehicle route selection and identification, will be established with a schedule not to exceed 5 years. Collaboration on designation of roads and vehicle routes will occur, consistent with the goals, objectives, and other considerations described in the Resource Management Plan (RMP), according to the above planning sequence. A travel management implementation plan will be written. Installation of signs and barriers where needed, and reclamation according to the plan will occur. Desirable roads may be reopened after repairs, recovery, or adequate mitigation has occurred.
Until the designation process is completed, travel limited to designated areas (LDA) will remain limited to existing roads and vehicle routes. Some portions of LDAs may receive other designations during the planning process outlined above. Travel on parcels of public land not having legal public access will remain limited to existing roads and vehicle routes. The LDAs [travel limited to designated areas] will be divided into geographic sub-areas in which specific roads and vehicle routes will be designated open to OHV travel. Geographic sub-areas and their order of consideration will be determined based on criteria such as current OHV use, areas with sensitive resources, and areas with special designations (i.e., areas of critical environmental concern [ACEC], wildlife habitat management areas, and special recreation management areas [SRMA]). Roads and vehicle routes that are designated open may have further restrictions placed on their use.
Additional BLM mitigations that may beneficially or negatively affect the OHV resource are included in the FEIS and referenced below.
Road Design and Maintenance BMPs (Appendix 13) Designing Roads BMPs (Appendix 13) Undeveloped Vehicle Routes BMPs (Appendix 13) Road and/or Road Closure and Reclamation BMPs (Appendix 13) Watershed Protection BMPs (Appendix 13) Soil BMPs (Appendix 13) Wildlife Mitigations (Appendix 1) Reducing Impacts to Big Game Crucial Winter Range BMPs (Appendix 15) Reducing Impacts to Sage-Grouse Habitat BMPs (Appendix 15) Reducing Impacts to Wildlife BMPs (Appendix 15) Mountain Plover Management Guidelines: Occupied Habitat Protection Measures (Appendix 16)
4.3.3.2 Recommended Additional Mitigations These mitigations are adequate. No additional mitigations are recommended.
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4.4
RECREATION AND VISITOR SERVICES
Recreation is one of the most important and popular resource uses within the RMPPA. Outdoor recreation opportunities, activities, and uses in the study area contribute to the quality of life, health, and welfare of the state and the nation, in addition to benefiting the local, regional, and national economies. The RMP/FEIS recognizes that oil and gas development that results in long-term elimination of a recreational use would constitute a significant issue. Several other resources located within the RMPPA contribute to existing recreation opportunities. These other resources may include, but are not limited to wildlife; fisheries; water resources such as reservoirs, rivers, and streams; transportation facilities such as roads and trails; historic and cultural resources; and wilderness resources. 4.4.1 Affected Environment
The RMP/FEIS adequately addresses and describes the recreation resources, Special Recreation Management Areas (SRMAs), levels of recreation use, and recreation trends within the RMPPA. The BLM refers to the Recreation Opportunity Spectrum (ROS) classification system (p. 3-51) but is remiss in not defining or describing the ROS as a planning tool the BLM uses to classify recreation environments (existing and desired) along a continuum ranging from primitive, low use, inconspicuous administration to urban, high-use, highly visible administration as defined in the BLM Land Use Planning Handbook (p. Glossary-6). The ROS needs to be explained in more detail in the RMP/FEIS and referenced as an appendix item much like other BLM RMP/NEPA documents and the MBLRMP have done. Mapping the existing and desired ROS classes across the RMPPA would be very helpful and would be more consistent with what is normally done as part of any recreation planning effort using the ROS classification system. The BLMs response to public comments #3791 and #3793 was, See ROS Map XXX in RMP FEIS. No such ROS map exists in the RMP/FEIS. Maps 2-58 and 2-59 of the Adobe Town Dispersed Use Area ROS and Desired Future Condition ROS are found in the RMP/FEIS, but these maps have no legend. The BLM refers to two managed ROS classes as Middle and Front Country in the RMP/FEIS (p. 3-51). These classes are not part of the standard six ROS classes along the spectrum. The BLM should use standard accepted terminology or explain any deviations or changes from the standard terminology.
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4.4.2
The BLM has adequately analyzed the potential impacts of other resource activities on the recreation and visitor services resource, including impacts to SRMAs. Most other resource programs would have a positive impact on recreational settings and experiences in the RMPPA. Stipulations applied to mineral activities by other resource programs would result in reduced surface disturbing activities, which would further protect visual resources, wildlife, historic and cultural resources, SRMAs, soil and water resources, and other resources or areas that have important recreation values from mineral impacts. Oil and gas development would result in long-term significant impacts to and reduction in recreation use in areas of high or even moderate oil and gas potential. The significance of these negative impacts would be increased and expanded under the three presented RFD2 scenarios. These would result in long-term elimination of recreation opportunities and use over a large area. With greater energy development, the RMP/FEIS may not provide sufficient mitigations to be in accordance with the MBLRMP stating that noise associated with oil and gas development will not exceed 70 decibels near recreation and residential interface areas. 4.4.3 Cumulative Effects
The BLM adequately disclosed the cumulative impacts to recreation and visitor services arising from the significant issues they identified. Pending oil and gas projects, in addition to current development, would significantly reduce recreational opportunities in the RMPPA, especially in the western portion. Further displacement of recreation users would occur as would displacement of big-game wildlife species, which would also reduce big-game hunting opportunities and displace hunters. 4.4.4 Mitigations
4.4.4.1 Mitigations Identified by BLM Although the BLM is required to provide mitigations for any potentially significant issue, the RMP/FEIS does not present any mitigations for the recreation and visitor services. 1.1.4.2 Recommended Additional Mitigation The following mitigation is recommended to reduce noise pollution in the vicinity of highly developed recreation sites and/or high use areas.
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Table 4.4-1 Recommended Additional Mitigations for Recreation and Visitor Services Resources Develop and implement noise reduction techniques and designs to minimize MITIGATION MEASURE impacts of noise pollution on recreation settings and experiences. (The Medicine Bow NF LRMP establishes a 70 decibel threshold for oil and gas production facilities at the edge of identified residential and recreation interface areas) Location Monitoring / Reporting Action From to mile from developed and heavily used dispersed recreation sites, WSA boundaries, SRMAs, CDNST, Historic Trails, and other areas of heavy, concentrated recreation use Establish acceptable and safe noise levels for the above mentioned locations. Monitor noise levels during development in the above mentioned locations and implement techniques to reduce unacceptable levels detected during monitoring. Continue monitoring to assure compliance with designed mitigation. Monitoring data and recreation user feedback BLM During high use seasons or periods (e.g., summer, hunting season)
Effectiveness Criteria Responsible Agency Timing
4.5
SOCIOECONOMICS
The issue of social impacts is a top priority for residents and governmental officials within the SERCD study area (Figure 1.3-1). These concerns arise from regional experiences; neighboring Sublette County has experienced a wide range of social and economic impacts resulting from the presence of the energy industry, including a lack of available housing for county residents as well as energy workers; inflated housing prices for existing residences; increased wear and tear on roads from heavy truck traffic; substandard levels of air quality; higher demand for water and subsequent impacts to groundwater supplies; increased strain on sewer and septic systems; and a rising number of emergency medical calls necessitating the purchase of additional ambulances and construction of a new emergency medical services barn. The price of addressing these impacts can be very high. For example, it is estimated that replacing the sewer/water system for the town of Pinedale would cost $80 million. It is critical for communities to carefully identify likely impacts from the energy industry and anticipate cost of mitigation. If revenues from increased taxes are not enough to offset the cost of mitigation, local government must work with industry and state officials to determine how to bridge the gap between projected revenue and expenses. 4.5.1 Affected Environment
The socioeconomic description of the existing environment in the Rawlins RMP/FEIS includes the required elements for NEPA analysis as described in Appendix D of the BLM Land Use Planning Handbook. Detailed information is presented on population, demographics, employment, income, and revenues. However, the information presented is out of date in many instances. Revenue figures were
presented for fiscal year 2001 when more current information, such as fiscal years 2006 or 2007, could have been applied. Labor information from the U.S. Bureau of Economic Analysis (USBEA) covered the years 1990-2000 when data from 2005 were available. Below, more current socioeconomic information is presented, with summaries targeted specifically to Carbon County to provide a more accurate baseline for effects analysis within the SERCD study area. Appendix C provides model results from running the IMPLAN (IMpact analysis for PLANning) model for the year 2007 for the Carbon County Area. IMPLAN is the model used by the BLM to assess potential impacts from management and planning decisions. We ran IMPLAN using updated 2007 data not to assess impacts, but to provide additional detail to the improved affected environment data below. 4.5.1.1 Population and Demographics Carbon Countys total area is 7,984 square miles, and the U.S. Census Bureau (USCB) estimated the 2007 population of Carbon County at 15,486 with a population density of two people per square mile. The 2006 population was estimated to be 95.8% white. Carbon County has experienced fluctuations in population over the past 25 years, as depicted in Figure 4.5-1. From the 1970s and through the early 1980s, population grew as coal mining boomed in the town of Hanna, Wyoming, located approximately 40 miles northeast of Saratoga. Between 1970 and 1980, the number of Carbon County residents increased 63%, from approximately 13,000 to almost 22,000 people (USCB 2008). Employment in Carbon Countys mining sector increased from 852 jobs in 1971 to 1,037 jobs in 1972, an increase of 20%. Mining peaked in 1980 at 3,563 jobs, and then declined to pre-boom levels by 1986 at 768 jobs (USBEA 2008). The mining boom contributed to a population increase in many nearby towns as workers chose to commute rather than live in Hanna. From the 1980s to 2000, Carbon Countys population continued to decline, reaching a low of 15,195 residents in 2001. Recent years have seen a reverse of this trend with annual growth in the 12% range. Carbon Countys population has gained slightly since 2000, and the Wyoming Economic Analysis Division projects that it will steadily increase by less than 1% annually through the year 2017. Two sawmill factories recently left the area contributing to another economic change. The Louisiana Pacific mill in Saratoga and a private mill operating in Encampment left the area over five years ago (Runner pers. comm.). The demographics of Carbon County are shifting, with fewer young people and more older residents. Figure 4.5-2 shows that in 2000 the majority of the population was between the ages of 45 and 50, moving to the 50 to 55 year range by 2007. In contrast, the number of 15 to 20 year olds peaked in 2000 but was substantially lower in 2007.
Carbon County Population 1960-2017

25000 Population 20000 15000 10000 5000 0 1960 1970 1980 1990 Year
Figure 4.5-1 Carbon County population 1960-2017 Dashed line delineates actual and projected values (WDAI 2008).
Carbon County Encampment Rawlins Saratoga
2000
2010
2020
Carbon County Demographic Distribution

1,500 Number of People 1,000 500 20 40 Age
Figure 4.5-2 Carbon County Demographic Distribution 2000 and 2007 (WDAI 2008)
2000 2007
60
80
100
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4.5.1.2 Employment Carbon Countys top five employment sectors are construction, retail trade, transportation and warehousing, accommodation and food services, and government and government enterprises (USBEA 2008). Table 4.5-1 displays the employment trends in these sectors between 2001 and 2006. The construction and transportation/warehousing sectors have grown recently, with the number of construction workers increasing over 55% between 2005 and 2006. As discussed in Section 4.5.1.5, the housing market emulates this trend, with the number of building permits increasing by 20% during the same time period.
Table 4.5-1 Carbon County Employment - Full and Part-Time Employment by Industry Industry Government Construction Accommodation Retail Transportation and Warehousing Mining Total Employment (USBEA 2008) Table 4.5-2 Top Ten Major Employers in Carbon County Major Employers Wyoming State Penitentiary Carbon County School District 1 Sinclair Oil Corporation Memorial Hospital of Carbon County Union Pacific Railroad Hyland Enterprises Carbon County Rip Griffin Travel Center Bureau of Land Management City of Rawlins (Wyoming Business Council 2008) Employees 385 308 295 220 155 150 134 130 115 100 Education Refinery Health Care Railroad Trucking and Oil Field Service County Government Truck Stop Federal Government City Government Product/ Service State Government 2001 2,239 696 974 1,039 487 245 9,601 2002 2,248 618 986 1,110 468 224 9,638 2003 2,228 644 971 1,127 498 180 9,454 2004 2,120 N/A 1,012 1,100 502 245 9,578 2005 2,073 786 1,066 1,041 552 N/A 9,869 2006 2,062 1,224 1,118 1,070 630 294 10,633
Carbon Countys unemployment rate has been relatively steady during this decade, hovering between the 34% range, with a peak in 2003 at 5.6%. This trend is consistent with the rest of the state and nation, whose unemployment rates also peaked in 2003. Since 2003 unemployment has decreased to 3.1% in
2007, only slightly higher than Wyomings unemployment rate of 3% and lower than the national rate of 4.6%.
Table 4.5-3 Annual Unemployment Rate Location Carbon County Wyoming U.S. (USDL 2008) 2000 4.2 3.8 4.0 2001 4.4 3.9 4.7 2002 4.6 4.2 5.8 2003 5.6 4.5 6.0 2004 4.5 3.9 5.5 2005 4.0 3.7 5.1 2006 3.4 3.3 4.6 2007 3.1 3.0 4.6
4.5.1.3 Income Income data is divided into two categories: labor, which is generally job-related, and non-labor, which is further divided into transfer payments (such as Medicare and welfare checks) and dividends, interest, rent, and retirement pay. As seen in Table 4.5-4, Carbon Countys per capita income for all categories in 2006 was $34,857, a 37% increase from 2001s $25,373. Annually, per capita income has steadily increased this decade from 1.69% in 2002 to 11.55% in 2006.
Table 4.5-4 Carbon County Regional Economic Profile 2001 2002 Total Personal Income $385,550 $393,330 Population 15,195 15,244 Per Capita Personal Income $25,373 $25,802 Annual Per Capita Income Growth N/A 1.69% (USBEA 2008)
2003 $412,288 15,207 $27,112 5.08%
2004 $440,762 15,215 $28,969 6.85%
2005 $470,332 15,051 $31,249 7.87%
2006 $528,599 15,165 $34,857 11.55%
Average annual wages in Carbon County have also risen substantially since 2001, at times increasing at a faster rate than either the state of Wyoming or the nation. Table 4.5-5 illustrates these changes with comparisons for Wyoming and the nation.
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Table 4.5-5 Carbon County Average Annual Wages Carbon Annual Year Wyoming County Change 2007 2006 2005 2004 2003 2002 2001 (USDL 2008) $37,654 $33,109 $28,903 $27,106 $25,948 $25,283 $24,823 13.73% 14.55% 6.63% 4.46% 2.63% 1.85% N/A $39,245 $36,662 $33,251 $31,210 $29,924 $28,975 $28,043
Annual Change 7.05% 10.26% 6.54% 4.30% 3.28% 3.32% N/A
Nation $44,450 $42,535 $40,677 $39,354 $37,765 $36,764 $36,219
Annual Change 4.50% 4.57% 3.36% 4.21% 2.72% 1.50% N/A
Population demographics can be determined by comparing non-labor and labor income, as non-labor income includes retirement and welfare payments. Table 4.5-6 shows 20012006 total personal income split between labor and non-labor income. Both categories have increased since 2001 with labor income growing 41% and non-labor income rising 31%. While current income data show steady increases for overall income, historical data demonstrate a different trend. Figure 4.5-3 shows that between 1980 and 1985 labor income decreased sharply and then slowly increased until 2000. In comparison, non-labor income grew at a fairly steady rate during the same time period, becoming a substantial component of overall personal income in recent years. Carbon County appears to have a consistently growing population of retired persons since 1980 and a varying population of laborers.
Table 4.5-6 Carbon County Total Labor and Non-labor Income 2001 2002 2003 $226,256 $224,828 $229,432 Total Labor Income Total Non-labor Income $217,961 $231,223 $250,294 (USBEA 2008)
2004 $252,968 $256,944
2005 $276,199 $266,310
2006 $318,995 $286,744
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Carbon County Labor vs. Non-labor Income

$350,000 $300,000 $250,000 Annual Income $200,000 $150,000 $100,000 $50,000 $0 1975
Total Labor Income Total Non-labor Income
1980
1985
1990
1995
2000
2005
2010
Year
Figure 4.5-3 Carbon County labor vs. non-labor income (WDAI 2008)
4.5.1.4 Revenues Energy-related income to Fremont County and its municipalities is received through four revenue streams. Federal Mineral Royalties (FMR) are paid by the operators to the federal government for minerals, oil, and/or gas extracted from federal land. Fifty percent of these funds are returned to the state of origin. In Wyoming, a portion of the returned royalties are distributed to cities and towns, based on population. These royalties are not distributed directly to counties. Table 4.5-7 shows FMR received by Carbon County municipalities and the state of Wyoming between 1998 and 2007.
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Table 4.5-7 Federal Mineral Royalty (FMR) Distributions 2000-2007 Total FMR Year FMR - Encampment FMR-Saratoga Distributed 2007 2006 2005 2004 2003 2002 2001 2000 $927,155,177 $1,067,957,946 $845,774,343 $554,366,613 $476,269,633 $348,649,073 $448,120,028 $309,092,856 $31,013 $31,153 $31,530 $31,829 $31,952 $35,233 $34,064 $35,180 $77,389 $42,004 $79,404 $80,570 $81,047 $93,830 $90,966 $96,089
FMR-Rawlins $340,535 $343,380 $351,049 $357,132 $359,621 $413,683 $380,621 $401,294
(Wyoming State Treasurers Office 2008)
Severance taxes are collected by the state of Wyoming on all minerals, oil, and/or gas produced in the state. An assessed value is determined at the point of production for each mineral extracted, which is then multiplied by the severance tax rate. Rates vary based on the particular mineral extracted. Natural gas is usually calculated at 6%, oil at 12%. A portion of severance taxes are returned to counties, cities, and towns, based on population and other factors. Table 4.5-8 shows the assessed valuations for minerals produced in Carbon County between 2000-2007. The major mineral extracted in the county is natural gas, followed by crude oil, surface coal, stripper oil, then sand and gravel. Table 4.5-9 displays revenues received in Carbon County from severance taxes between 20002007.
Table 4.5-8 Assessed Valuation for Carbon County Mineral Production Year 2008 2007 2006 2005 2004 2003 2002 2001 Crude Oil $83,000,000 $81,000,000 $65,000,000 $56,000,000 $32,000,000 $27,000,000 $23,000,000 $27,000,000 Stripper Oil $7,000,000 $7,000,000 $7,000,000 $5,000,000 $4,000,000 $3,000,000 $3,000,000 $4,000,000 Natural Gas $530,000,000 $586,000,000 $658,000,000 $447,000,000 $366,000,000 $199,000,000 $338,000,000 $363,000,000 Surface Coal $4,000,000 $0 $0 $3,000,000 $7,000,000 $9,000,000 $10,000,000 $9,000,000 Sand & Gravel $1,589,000 $1,270,000 $819,000 $483,000 $308,000 $213,000 $505,000 $281,000 $367,000 Total Assessment $625,000,000 $676,000,000 $730,000,000 $512,000,000 $409,000,000 $239,000,000 $376,000,000 $426,000,000 $217,000,000
2000 $15,000,000 $2,000,000 $159,000,000 $12,000,000 Rounded to the nearest million or thousand (Wyoming State Treasurers Office 2008)
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Table 4.5-9 Severance Tax Revenue 20002007 Year Carbon County Encampment 2007 2006 2005 2004 2003 2002 2001 2000 $195,929 $193,584 $188,710 $143,021 $228,887 $257,711 $484,427 $209,662 $21,164 $20,673 $19,791 $19,313 $19,953 $23,660 $51,688 $27,156
Rawlins $430,264 $420,269 $402,332 $329,663 $405,646 $465,952 $991,321 $519,842
Saratoga $82,460 $20,953 $77,107 $75,248 $77,742 $92,182 $205,960 $109,122
Payments in Lieu of Taxes (PILT) are paid by the federal government to counties as compensation for loss of tax revenue on federal lands. Payment amounts are based on three factors: eligible federal acres in the county, prior year federal revenue-sharing received by the county, and county population. As mentioned previously, 54% of the acreage in Carbon County, 2,728,408 acres, is federal land. Table 4.5-10 shows PILT distributions for 20002007.
Table 4.5-10 Payment In Lieu of Taxes (PILT) Revenue for Carbon County, 19982007 Year Amount Received 2007 2006 2005 2004 2003 2002 2001 2000 (Foulke et al. 2008) $684,030 $684,186 $668,767 $654,838 $634,389 $682,128 $628,695 $330,724
The final energy-related revenue stream is county-assessed tax. By taking the state-assessed valuation on mineral production (final column from Table 4.5-11, showing amount of assessed taxes levied by county on mineral production), mill levies are applied to calculate the county taxes owed. As the data show, mineral production in Carbon County this decade has provided between 63% and 81% of county-assessed taxes.
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Table 4.5-11 Carbon County Taxes Assessed on Mineral Production 20002008 Year 2008 2007 2006 2005 2004 2003 2002 2001 2000 Mineral Assessment $625,000,000 $676,000,000 $730,000,000 $512,000,000 $409,000,000 $239,000,000 $376,000,000 $426,000,000 $217,000,000 Total Assessment $896,215,989 $891,998,340 $898,683,428 $667,954,557 $559,882,048 $382,269,728 $515,258,813 $554,063,441 $336,773,742 Mills Levied 65.19 62.25 63.23 62.68 63.49 64.34 62.91 63.04 70.38 Amount Levied $58,419,690 $55,528,148 $56,822,170 $41,865,221 $35,548,661 $24,595,682 $32,412,418 $34,927,573 $21,329,756 Mineral Percentage of Total Taxes 70% 76% 81% 77% 73% 63% 73% 77% 64%
4.5.1.5 Housing Over the past several years, the housing market in Carbon County exhibits contradictory trends. As seen in Table 4.5-12, both the population and the total number of housing units increased slightly between 2001 and 2007. However, the overall rental vacancy rate in the county decreased from double digit rates to just over 1% during the same time period.
Table 4.5-12 Comparison of Annual Population Change vs. Rental Vacancy vs. Total Housing Units Rental % Change Total Housing % Change Year Population Vacancy Rate 2001-2007 Units 2001-2007 2007 2006 2005 2004 2003 2002 2001 1.37 1.67 5.62 11.42 11.46 12.27 10.90 15,486 15,165 15,051 15,215 15,207 15,244 15,195 1.92% -0.20% -0.95% 0.13% 0.08% 0.32% N/A 8,545 8,501 8,454 8,416 8,400 8,365 8,353 2.30% 1.77% 1.21% 0.75% 0.56% 0.14% N/A
(WCDA 2008 and USCB 2008)
There are several possibilities that account for these divergent trends. Data on the vacancy rate of homes is not readily available, but that value could have increased over the time period. It is also possible that older rental structures no longer exist and have been replaced by homes rather than multi-family rental units or that rental units have been converted to homes and have decreased the number of facilities available. Indeed, during the 20012007 timeframe, approximately 389 single family building permits
were issued in Carbon County, contrasted with a total of four duplex permits and four multi-family permits (WCDA 2008). Table 4.5-13 describes the change in the average sales price of homes in Carbon County, Wyoming, and the United States. While Carbon County lags behind Wyoming in terms of price increases between 2001 and 2007, the county outpaced the nation in the past few years with an overall increase of 74%.
Table 4.5-13 Comparison of Annual Average Sales Prices for Carbon County, Wyoming, and the U.S. Year 2007 2006 2005 2004 2003 2002 2001 (WCDA 2008) Carbon County $148,813 $118,335 $96,200 $94,377 $88,123 $78,436 $85,176 % Change 20012007 74.71% 38.93% 12.94% 10.80% 3.46% -7.91% Wyoming $265,044 $187,869 $159,776 $142,501 $132,708 $121,140 $116,469 % Change 20012007 127.57% 61.30% 37.18% 22.35% 13.94% 4.01% U.S. $284,400 $301,900 $290,200 $284,300 $253,900 $237,800 $228,700 % Change 20012007 24.36% 32.01% 26.89% 24.31% 11.02% 3.98%
Evidence of a tight rental market in traditional units (apartments and mobile homes) is indicated in Table 4.5-14. The average monthly rental for apartments, mobile home lots, and mobile homes plus lots is higher than the statewide average. It should be noted that overall in Wyoming, the average rental vacancy rate is 2.89%, or nearly double that of Carbon County.
Table 4.5-14 Average Rental Rates for Carbon County and Wyoming, 20012007 Year Homes County 2001 2002 2003 2004 2005 2006 2007 (WCDA 2008) 443 472 487 522 561 695 869 State 599 618 661 681 711 782 878 Apartments County 383 359 394 439 452 690 660 State 430 443 466 497 523 567 599 Lots Only County 118 110 118 130 128 288 289 State 178 183 195 188 200 225 232 Lot plus mobile home County 304 331 364 365 398 613 609 State 436 449 460 481 505 561 569
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As discussed in the Employment section, the number of workers in the construction trade has increased in recent years. This is reflected in the number of building permits issued (Figure 4.5-4), which shows increases of approximately 20% for 20052006 and 20062007.
Carbon County Annual Building Permits Number of Permits Issued 150 100 50 0 1990
1995
2000 Year
2005
2010
Figure 4.5-4 Carbon County annual building permits (WCDA 2008)
4.5.1.6 Medical Medical care is readily available within the watershed area. Memorial Hospital of Carbon County, the only hospital within the county, is a 45 bed facility located in Rawlins. The Wyoming State Board of Medicine lists 11 physicians licensed with a Rawlins mailing address and three physicians licensed with a Saratoga mailing address. Four dentists currently practice in Rawlins and one is located in Saratoga. Emergency medical services and ambulance transportation are provided by Carbon County Fire Department. Approximately 30 firefighters are associated with the department, which averaged just over 200 emergency runs in 2006 and 2007 (Carbon County Fire Department 2008).
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4.5.1.7 Schools Carbon County is home to two public school districts, Carbon #1, which serves Rawlins and Baggs, and Carbon #2, which serves Saratoga, Encampment, and Hanna. Of the two districts Carbon #2 is smaller, serving a student population just under 700 in 2007. Carbon #1 is almost twice as large, with a 2007 student count of approximately 1800. As seen in Figure 4.5-5, student numbers have steadily declined since 1991 and are at approximately 60% of their 1991 value. Taken in context with the overall population trends in the county, it would appear that demographics are shifting away from the 18 and under group.
Carbon County School District Enrollment

3000 2500 2000 1500 1000 500 0 Student Enrollment
District #1 District #2
19 90
19 92
19 94
19 96
19 98
20 00
20 02
20 04
20 06
2002 10.6 6.81
Year
Figure 4.5-5 Carbon County school district enrollment 19912007 (Wyoming Department of Education 2008)
As student population decreases in both school districts, the student-to-teacher ratio also declines. Table 4.5-15 shows the trend in student-to-teacher ratios between 1995 and 2007. While a decline in student numbers generally results in a negative financial impact for a school district, one upside to this situation is the opportunity for more individualized instruction as there are fewer students per teacher.
Table 4.5-15 Carbon County Schools Student/Teacher Ratios Year 1995 1996 1997 1998 1999 2000 2001 District 12.2 11.9 11.1 11 10.8 10.6 10.4 #1 District 8.11 7.92 8.18 7.61 7.58 6.93 6.86 #2 (Wyoming Department of Education 2008)
20 08
2003 9.55 6.55 2004 9.24 6.63
2005 9.09 6.15
2006 9.26 6.42
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Overall district spending has followed an increasing trend since 2000, rising 40% in District #1 and 50% in District #2 from 2000 to 2007. Per-pupil spending follows this trend, increasing 51% and 76% respectively during the same time period. This information is summarized in Table 4.5-16.
Table 4.5-16 Carbon County Schools Expenditures/Pupil 20002007 Annual Budget Annual Expenditure/Pupil District # 1 2007 2006 2005 2004 2003 2002 2001 $25,592,449 $21,417,700 $19,530,422 $17,224,677 $16,310,559 $18,497,550 $18,931,962 $14,101 $12,218 $11,309 $10,351 $9,439 $10,404 $9,845 50.78% 30.64% 20.93% 10.69% 0.93% 11.25% 5.27% N/A $15,083,784 $14,102,028 $12,836,011 $12,292,774 $11,748,155 $11,972,973 $10,719,914 $10,085,752 % Increase from 2000 Annual Budget Annual Expenditure/Pupil District # 2 $22,547 $21,302 $19,390 $17,561 $16,807 $16,114 $14,807 $12,751 76.83% 67.07% 52.07% 37.73% 31.81% 26.38% 16.12% N/A % Increase from 2000
Year
2000 $18,198,803 $9,352 (Wyoming Department of Education 2008)
Teacher pay in Carbon County is lower than most school districts in Wyoming. For the 20082009 school year, District #1 ranks 43rd of 48 districts with a base salary of $37,650, while District #2 is ranked 48th with a base salary of $35,500 (Wyoming School Boards Association 2008). 4.5.1.8 Crime In addition to the Carbon County Sheriffs Department, the watershed study area is served by police departments in the towns of Rawlins, Encampment, and Saratoga. A total of 45 officers were employed throughout Carbon County in 2007, with the majority in Rawlins and the County Sheriffs Department. Each organization provides information on crime statistics through the Uniform Crime Reporting program. Table 4.5-17 provides historical information on violent and property crimes handled by these law enforcement agencies.
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Table 4.5-17 Carbon County Violent and Property Crime Statistics 19802005 Carbon Saratoga Rawlins Encampment Saratoga Rawlins Encampment County Year PD PD PD PD PD PD SD Total Violent Crime Total Property Crime 2005 2000 1995 1990 1985 1980 13 33 4 1 5 2 34 19 27 18 11 88 0 0 0 2 4 0 3 7 3 7 6 14 59 57 67 46 74 69 422 299 285 450 459 796 0 0 4 10 16 0
Carbon County SD 83 59 92 77 77 137
(Wyoming State Office of the Attorney General 2008)
Overall, the data shows the trend over the past 25 years of lower crime rates, especially during the period from 1980 to 2000. (As previously noted, the early 1980s were a boom time for the mining industry in the area.) The town of Saratoga is the notable exception to this trend, with a peak in violent crime in 2000. County-wide statistics on drug and alcohol violations in Table 4.5-18 indicate that arrests for drug sales and liquor violations have remained steady this decade, while drug possession and DUI incidents have increased by 72% and 53% respectively since 2000.
Table 4.5-18 Carbon County Drug and Alcohol Crime Statistics 20002007 Year 2007 2006 2005 2004 2003 2002 2001 2000 Drug Sale 15 24 22 24 32 28 15 26 Drug Possession 122 116 126 125 73 80 95 71 DUI 284 221 172 135 152 172 182 186 Liquor Law Violation 154 150 104 96 127 188 155 154
(Wyoming State Office of the Attorney General 2008)
4.5.1.9 Transportation The Wyoming Department of Transportation annually tracks the number of miles covered by vehicles and light trucks. Data from 2000 to 2007 show that total vehicle miles have increased at both the state and county levels, as shown in Table 4.5-19. The annual increase in vehicle miles varies from 0% to 5% for both the state and county with the exception of 2003, when Carbon Countys count of vehicle miles decreased by 2.63%. This indicates a steady increase in people for Carbon County and Wyoming, which
roughly correlates with the observed population increase. Other reasons for increased traffic could be commuting workers, rise in tourism, or a variety of other factors.
Table 4.5-19 Carbon County Total Vehicle Miles 20002007 Year Carbon Annual Change 2007 449,350 2.64% 2006 437,810 0.19% 2005 436,960 2.22% 2004 427,480 3.54% 2003 412,870 -2.63% 2002 424,030 1.75% 2001 416,740 4.44% 2000 399,040 N/A (Wyoming Department of Transportation 2008)
Wyoming 8,463,105 8,340,364 8,098,504 8,071,406 7,854,871 7,785,830 7,602,485 7,242,485
Annual Change 1.47% 2.99% 0.34% 2.76% 0.89% 2.41% 4.97% N/A
The Wyoming Department of Transportation also collects data on annual miles of truck traffic throughout the area. Any vehicle larger than a pickup is classified as a truck (Wiseman pers. comm.). As described in Table 4.5-20, annual truck miles have increased across both the state and Carbon County since 2000. Truck traffic is significant because trucks contribute to road degradation and increase the need for road maintenance.
Table 4.5-20 Truck Miles Year Carbon 2007 159,275 2006 153,245 2005 154,585 2004 148,405 2003 143,095 2002 144,935 2001 143,500 2000 143,520
Annual Change 3.93% -0.87% 4.16% 3.71% -1.27% 1.00% -0.01% N/A
Wyoming 1,322,703 1,284,771 1,247,450 1,202,630 1,182,325 1,205,705 1,181,735 1,219,010
Annual Change 2.95% 2.99% 3.73% 1.72% -1.94% 2.03% -3.06% N/A
(Wyoming Department of Transportation 2008)
4.5.2
For identifying significant issues in the RMP/FEIS, the BLM analysis established two significance criteria:
Changes in total employment in any of the four counties exceeding an increase or decrease of 1% of the trend measured for the period 19902000. The trend of population change was 16%, thus a change greater than 1,100 jobs (positive or negative) across the entire RMPPA would be considered significant.
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Changes in mineral ad valorem tax revenues exceeding an increase or decrease of 15% of the trend, which measured approximately $2.6 million for the period 19852002. Thus, a change greater than $4 million (positive or negative) across the entire RMPPA would be considered significant.
In general, while these criteria are quantifiable, the use of a RMPPA-wide trend based on a set time period fails to account for spatial and temporal socioeconomic differences. For example, while employment within the four county area increased 16% between 1990 and 2000. Carbon County did not show this trend and in fact showed a decrease of 2.2% in total employment during this time period. Thus, it would be difficult for even relatively significant changes in Carbon County population to meet the threshold for significance. Moreover, the data used to establish the criteria baseline are dated and do not reflect current trends in employment or tax revenues. Incorporating current data into Carbon County calculations shows a 10% increase in employment between 2000 and 2007, and an overall increase of 7.6% between the years 1990 and 2007. Mineral tax revenue trends in Carbon County between 1990 and 2007 show an increase of 425%, with 2001 marking the start of a period of large increases in mineral tax revenue. Adjusted for inflation, mineral tax revenues grew by 222% during this period. As with the employment criteria, the 15% threshold may not be applicable to Carbon County, and a different threshold should be established to measure tax revenue significance. Further, the BLMs reliance solely on employment numbers accounts for changes in the labor force in an area but not for changes in the total population. Yet, many social programs and services are staffed and sized on a per-capita basis, or serve a non-labor segment of the population. For example, nursing homes service older, non-working citizens. Schools serve children through age 18. Infrastructure components such as water, sewer, solid waste, and fire and ambulance services are usually based on a per-capita basis as well. We suggest that significance criteria include trends in overall population, including age group demographics. Another potential indicator of impact is the housing market. The number of housing units in Carbon County has generally increased along with the population. However, a large influx of workers and families would stress the already-tight rental market. Even if housing starts were to increase as soon as possible, there is generally a lag time of twelve to eighteen months between the beginning of a residential development and completion. We suggest that housing be monitored, including both rental and purchased dwellings. This information would help the affected areas plan for necessary increases in services and facilities. Regardless of the criterion for determining significance, many socioeconomic impacts derive from increases in area population due to increased employment from oil and gas activity. Improvements in service and expansion of infrastructure to mitigate potential negative effects can be expensive undertakings. New buildings, increased sewer capacity, expansion of the public water supply, and accelerated road maintenance schedules are only a few of the issues communities face when energy companies come into an area on a large scale. Energy development also provides positive benefits like increasing revenues, but often it is unlikely that increased revenues completely offset the cost of
necessary improvements. To this end, a detailed cost/benefit analysis should be conducted for future proposed energy development projects. Currently, the RMP/FEIS presents projected direct employment, income and revenue information but contains no indirect effects. There is only general discussion of potential effects on housing and infrastructure, which do not help local governments or communities assess specific potential impacts to their areas. Below, we provide a brief assessment of potential socioeconomic impacts to Carbon County and the SERCD study area based on the three RFD2 scenarios. Because the RMP/FEIS does not contain specific information related to drilling projects or schedules, general assumptions based on the proposed alternative were made in reviewing the potential impacts as shown below:
Development and completion personnel needs will average 8.1 workers/well/year. Drilling activity would take place within a 10 to 20 year timeframe.
Table 4.5-21 depicts potential annual drilling activity for each alternative under RFD2, calculated using a 10 year and 20 year drilling plan.
Table 4.5-21 Potential Study Area Drilling Schedules (wells drilled per year) 10 year plan Minimal Development Moderate Development Intensive Development 23 46 91 20 year plan 13 23 46
4.5.2.1 Population and Demographics and Employment The RMP/FEIS anticipates a slight decrease in regional employment within the RMPPA under Alternative 4 due to restrictions on energy development. The BLM assumes that this will have no significant impact on population trends. Under RFD2 in the study area, we anticipate an increase in employment. The preferred alternative suggests that 8.1 workers are needed per well per year for development and completion tasks. Using this figure, drilling schedules would equate to the following employment numbers for the two drilling timetables, as shown in Table 4.5-22.
Table 4.5-22 Potential Study Area Employment Projections 10 year plan Minimal Development Moderate Development Intensive Development 20 year plan
186 373 737
105 186 373
From the above data, even the most aggressive development scenario would increase population by less than 750 workers in the county. Given Carbon Countys 2008 population of 15,750, this equates to an
increase to 16,487 residents. While this represents a 4.6% increase in population for the county, the overall total is well below the 1980 threshold of 22,000 workers. Thus, even intensive energy development within the study area would not unduly affect employment. In recent years the unemployment rate in Carbon County has followed the national and state trends very closely, albeit at a slightly lower rate. Assuming that local residents would be employed in any capacity under RFD2, the unemployment rate in the area would be expected to decrease. 4.5.2.2 Income As noted in Section 4.5.1.2, mining jobs in Carbon County are not a major employment sector, totaling approximately 3% of the county workforce in 2006. However, 2006 mining wages were much higher than any other sector, averaging over $67,000 annually (USDL 2008). This is almost 50% higher than the $44,000 annual income of construction workers in 2006, which was the next-highest-paying sector in the county. Under RFD2, wages and household income within the project area would be positively affected regardless of the level of development activity. In contrast, the RMP/FEIS expects a slight decline in employment across the entire RMPPA. Our anticipated increase in employment assumes that local residents would be employed by operators for any work and would receive wages comparable to that of the mining sector. Due to the specialized skills needed for drilling and completion tasks, the number of local workers with appropriate skills may be low. It is common for workers from out of the area, often termed transient workers, to be employed for many of the development positions. If this is the case, the indirect jobs would be the most likely sector for local residents to gain employment. Wages and household income may be affected to a smaller degree if indirect jobs are the primary source of employment. 4.5.2.3 Revenues The RMP/FEIS anticipates a slight decline in mineral revenues across the RMPPA. The data do not exist to make accurate predictions for revenues from FMR, severance taxes, PILT, or county-assessed taxes in the study area. However, it can be assumed that any future energy development in the study area will contribute positively to county revenues. 4.5.2.4 Housing and Community Services The RMP/FEIS anticipates no notable changes in demands for housing or community services. However, under RFD2, housing availability could be problematic given the tight rental market in Carbon County at present. A sudden influx of 100 to 500 new residents would likely strain the housing market. The RMP suggests that Rawlins could accommodate additional residents. This should be verified prior to the start of any activities so that alternate accommodations can be located if necessary.
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Medical, crime, fire, and other municipal service agencies could also be strained by a large influx of transient workers. Due to the nature of drilling and completion activities, emergency medical response units could see a sharp rise in the number of ambulance runs under the proposed alternative. Fire responders and law enforcement personnel could also see an increase in activity. The RMP/FEIS states that larger communities such as Rock Springs and Rawlins have excess capacity in infrastructure and can absorb a large population increase. If this statement is based on 2000 or 2001 data, it should be reexamined under current conditions. Further, it is unclear whether this is realistic given the distance from these communities to the study area. School capacity should not be an issue regardless of any RFD2 activity. Demographic information shows that the 18-and-under cohort has declined in recent years and that schools throughout the county are at approximately 60% of their enrollment peak seen in the early 1990s. Moreover, development or transient workers tend to travel without families, which would lessen the influx of school-aged children to the county from energy-related activities. 4.5.2.5 Transportation Our RFD2 and the RMP/FEIS cannot provide detail on the location of potential wells, plans for new roads, or renovations to existing roadways with available information. They also cannot contain estimates for truck traffic during development operations. Therefore, impacts to traffic and roadways cannot be quantified. However, it can be assumed that any energy development in the study area will, at a minimum, increase traffic, with the potential for construction of new roadways and possible accelerated degradation of existing surfaces. 4.5.3 Cumulative Effects
The RMP/FEIS identified the cumulative impacts to social and economic arenas, but did so very broadly:
Since the price and demand for oil and gas are the driving force in the pace of exploration and development, it is difficult to predict when and to what degree impacts may be felt.
The RMP/FIES document states,

Increased oil and gas development throughout the region will increase the mineral tax revenue and royalty payments that can be used by local and state government to help mitigate the anticipated impacts. For some counties, the increases are expected to be significant and will remain a major source of revenue for many years to come for various jurisdictions.
and,
it is likely that communities within the study area will be affected by the boom and bust cycle and the intensity of this cycle will be a function of pace. Moreover, it is anticipated that this phenomenon will likely cause hardships for areas that must improve or expand infrastructure and
services to accommodate the large, temporary increases in population. However, to some extent, these hardships will be offset by the tax revenues generated by the oil and gas activity.
These generalizations are not sufficient to adequately describe the economic affects of the oil and gas industry within the confines of the project area. Indeed, Appendix D of BLM Land Use Planning Handbook clearly states that land use planning must analyze the social and economic affects of the alternatives 4.5.4 Mitigations
4.5.4.1 Mitigations Identified by BLM The only socioeconomic mitigation discussed by the BLM is increased revenues to offset impacts to the community. As discussed previously, this alone is inadequate as detailed cost/benefit analyses will be required at the project level to determine whether revenues will sufficiently mitigate negative impacts. 4.5.4.2 Recommended Additional Mitigations We recommend the following socioeconomic mitigations be adopted:
Table 4.5-23 Recommended Additional Mitigations for Housing Establish non-residential housing needs MITIGATION MEASURE Location Carbon County Monitoring / Reporting Action Establish acceptable vacancy rates, monitor housing availability Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing Assure that vacancy rates indicate available housing BLM During high-use seasons or periods (e.g., summer) Establish non-residential housing Establish sufficient temporary housing in the form of man camps and RV/motor home/trailer parks Carbon County Establish acceptable vacancy rates, monitor housing availability BLM Assure that vacancy rates indicate available housing Establish long-term, non-residential housing Explore longer-term facilities in the form of dormitory-style, apartment, and duplex/multiplex housing Carbon County Establish acceptable vacancy rates, monitor housing availability BLM Assure that vacancy rates indicate available housing
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MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing
Plan for future housing surplus Explore options for alternative uses of housing structures when demand has lessened Carbon County Establish plan for population decline BLM Assure that plan includes clear implementation guidelines
Table 4.5-24 Recommended Additional Mitigations for Schools Estimate student population MITIGATION MEASURE Location Estimate short- and long-term student population Monitoring / Reporting Action Carbon County Effectiveness Criteria Collect data on student-age population changes Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing BLM Monitor actual student population change and compare to estimates Estimate short- and long-term staffing needs Carbon County Collect data on student-age population changes and relation to teacher needs Monitor actual teacher population change and compare to estimates BLM Annually Estimate educational facility needs Carbon County Collect data on student-age population changes and relation to facility needs Monitor facility BLM Annually Propose educational facility expansion plan Carbon County Follow increasing student-age population and relation to facility needs Monitor facility BLM Annually Allocate space for educational facility Carbon County Follow increasing student-age population and relation to facility needs Monitor facility BLM Annually
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Table 4.5-25 Recommended Additional Mitigations for Roads/Transportation Determine current and projected infrastructure needs for roads/transportation MITIGATION MEASURE (road and bridge construction, paving, gravel) Location Carbon County Monitoring / Reporting Action Monitor traffic increase and compare to estimates Effectiveness Criteria Assure roads and infrastructure accommodate traffic volume Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing BLM Ongoing Determine projected equipment and personnel needs, including departmental storage and office space for roads/transportation Carbon County Follow up with new equipment usage and personnel duties Assure equipment and personnel cover needs BLM Ongoing Determine cost of infrastructure, necessary equipment, and personnel for roads/transportation Carbon County Annual budget analysis Assure costs allow for road/transportation needs BLM Annually
Table 4.5-26 Recommended Additional Mitigations for Police/Crime/Fire/EMS Determine projected levels of crime and fire-related activities, determine MITIGATION MEASURE personnel, equipment, and office space needs to sufficiently handle anticipated activity Location Carbon County Monitoring / Reporting Action Monitor increased crime and fire-related activities, compare to estimates Effectiveness Criteria Assure projections align with actual change Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing BLM Ongoing Compare current detention facility capacity to projected needs, develop options to handle increased population along with associated costs for infrastructure and personnel Carbon County Monitor actual increased needs, compare with projected Assure projections align with actual change BLM Ongoing
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Determine cost of infrastructure, necessary equipment, and personnel for Police/Crime/Fire/EMS Carbon County Follow actual cost and compare with estimates Assure costs cover needs BLM Ongoing
Table 4.5-27 Recommended Additional Mitigations for Medical Services and Facilities Determine projected levels of medical service needs (routine and acute care, MITIGATION MEASURE mental health, substance abuse, and counseling services) Location Carbon County Monitoring / Reporting Action Monitor increased medical needs, compare to estimates Effectiveness Criteria Assure projections align with actual change Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing BLM Ongoing Compare current facility capacity to projected needs, develop options to increase facilities as needed for medical services and facilities Carbon County Monitor actual increased needs, compare with projected Assure projections align with, and plans allow for, actual change BLM Ongoing Determine cost of infrastructure, necessary equipment, and personnel for medical services and facilities Carbon County Follow actual cost and compare with estimates Assure costs cover needs BLM Ongoing
Table 4.5-28 Recommended Additional Mitigations for Water, Sanitary Waste, Solid Waste Services and Facilities Determine projected levels of household and commercial water and sanitary MITIGATION MEASURE waste consumption/creation Location Carbon County Monitoring / Reporting Action Monitor increased water and sanitary needs, compare to estimates Effectiveness Criteria Assure projections align with actual change Responsible Agency Timing BLM Ongoing
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MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing
Determine projected rate of solid waste generation Carbon County Monitor increased rate, compare to estimates Assure projections align with actual change BLM Ongoing Compare current facility capacity to projected needs, develop options to increase facilities or reduce needs for water, sanitary waste, solid waste services and facilities Carbon County Monitor actual increased needs, compare with projected Assure projections align with, and plans allow for, actual change BLM Ongoing Explore alternatives to solid waste disposal (e.g., recycling, use of consumables in construction projects) Carbon County Consider viability of alternatives Assure analysis of alternatives is considered BLM Ongoing Determine cost of infrastructure, necessary equipment, and personnel for water, sanitary waste, solid waste services and facilities Carbon County Follow actual cost and compare with estimates Assure costs cover needs BLM Ongoing
Table 4.5-29 Recommended Additional Mitigations for all Socioeconomic Departments Allocate sufficient housing to accommodate projected employee increases MITIGATION MEASURE Location Carbon County Monitoring / Reporting Action Follow actual employee increases along with estimates Effectiveness Criteria Ensure occupancy rates are below 100% Responsible Agency Timing MITIGATION MEASURE Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing BLM Ongoing Develop projected short- and long-term projected budgets, work with local government to determine revenues/funding sources for projects, identify areas of shortfall Carbon County Follow actual expenditures and compare with budget projections Assure needs are met and covered by budget BLM Ongoing
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Establish a monitoring plan to track effectiveness of mitigation measures Carbon County Follow up with mitigation measures Assure that mitigations have been implemented BLM Ongoing
4.5.5
Example Monitoring Plan
As an example monitoring plan, Sublette County has adopted the following socioeconomic monitoring plan and is in the process of implementation. This plan, entitled Pinedale Field Office Oil and Gas Development Social and Economic Monitoring Plan (Draft 6/24/08)5, was developed by Rob Winthrop, economist for the BLM. Excerpts from this plan follow.
Western Wyoming is currently experiencing rapid economic growth, strongly associated with the development of oil and gas resources. This document proposes a set of indicators through which to track social and economic change generated by oil and gas development in the Pinedale Field Office of the Bureau of Land Management (BLM), particularly in the Pinedale Anticline and the Jonah Field. The plan is intended to provide an annual update to inform county and municipal planning and budgeting, community participation, and federal agency resource management. This draft has been prepared to facilitate discussion by citizens, local and state government officials, operators, BLM managers and staff, and other interested parties. It does not represent BLM policy, nor does it imply a commitment by the BLM to provide funds or staffing to a monitoring effort. Oil and gas activities in the Pinedale planning area form part of a larger region of energy development that also includes Sweetwater and Lincoln Counties. In addition, while BLMs Pinedale planning area falls largely within Sublette County, oil and gas activities in that field office generate social and economic impacts in communities outside the county, for example in Rock Springs (Sweetwater County). For these reasons, the monitoring program outlined below is proposed for use across Sublette, Sweetwater, and Lincoln Counties. The indicators are prioritized in three tiers. Priority 1 provides the most limited monitoring program, Priority 3 the most extensive and most costly. Priorities 2 and 3 include indicators listed under Priority 1 and Priorities 1 and 2, respectively. The indicators were selected using several criteria. Balanced. The indicators should reflect both the benefits and the challenges of oil and gas development, as well as other drivers of economic change. Consistent. The indicators selected should be broadly consistent with the monitoring objectives proposed by the Pinedale Anticline Working Group (PAWG), though not necessarily with the data sets used by the PAWG. Comparable. At least some of the indicators should be applicable to any area of the country, to facilitate the implementation of a consistent social and economic monitoring strategy across the
5
Document history: Draft 1 prepared by Rob Winthrop, Senior Social Scientist, BLM Washington Office, Division of Decision Support, Planning, and NEPA (WO-210); 202-557-3587. Draft 1a reflects comments from Roy Allen, Regional Economist, BLM Wyoming State Office, and Jeffrey Jacquet, Sublette County Socioeconomic Analyst. 71 ECOSYSTEM RESEARCH GROUP
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lands administered by the Bureau of Land Management. Economic and demographic indicators should use readily available federal or state data, to the extent feasible. Federal data sources provided through the BLMs Economic Profile System are particularly useful.6 Issues needing further consideration. (1) Cumulative effects. How should the monitoring effort consider (a) oil and gas development on non-BLM lands and (b) other industrial activities within the monitoring area, such as a proposed carbon sequestration project near Big Piney? (2) Sources of data. If timeliness of data is important, federal data may need to be supplemented with other sources which may be more recent. 7 (3) Use of projections. Most of the indicators listed below are retrospective: they estimate what has happened. To the extent that future oil and gas activity can be estimated, such data could be used to project many of these indicators forward, which would make the monitoring effort much more valuable as a basis for local planning for facilities and services.8 (4) Staffing and coordination. Given the commitment already made by Sublette County to track social and economic conditions and trends, it may be appropriate to request that the countys Socioeconomic Analyst assume certain responsibilities for conducting monitoring activities under this plan. Depending on the specifics of the final monitoring plan, available skills, and level of funding for the position, this role could involve providing data, analyzing data, coordinating monitoring activities, or preparing the monitoring report. Benchmarking. Categories marked by () could also be compared with data for a benchmark county selected for minimal oil and gas activity. (Teton County?) Table 4.5-30 Reproduced from the Pinedale Monitoring Plan
Priority Oil and Gas Activity 1 oil and natural gas prices oil: Wyoming Sweet; gas: prices at Opal Hub. Operators Price trends may provide an early indicator of shifts in exploration activity. Use a 3-year moving average? Indicator Source Notes
rig months, oil and gas wells (1) in operation and (2) 10-year projected
The Economic Profile System application and database as well as county-level reports can be downloaded free of charge at www.headwaterseconomics.org/eps.
Jeffrey Jacquet suggests that because most federal data will be two to three years old, the monitoring program may need to rely more on state data.. The Wyoming Department of Administration and Information -- Economic Analysis Division and the Wyoming Department of Employment -- Research and Planning offer similar statistics that are typically only 6 months to 1 year old.
Jeffrey Jacquet: The BLM is supposed to be providing yearly 10-year development projections for both the Anticline and the Jonah field. Could the monitoring program take into account these development scenarios and then project the impacts to the selected indicators? As well as track the changes in field development and the changes in the development projections such as when "the bust" is scheduled to hit, etc 72 ECOSYSTEM RESEARCH GROUP
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Priority
Indicator drilling activity
Source
Notes
10-year projected oil and gas production
Operators
R. Allen. This would provide the basis for estimating county mineral revenues.9 To protect proprietary data, submissions could be aggregated by a third party.
Demographics 1 2 Population: county trend compared with benchmark county and state Oil and gas workers and dependents, by county BEA REIS, Table CA30? Operators J. Jacquet: Have to estimate these numbers, using workforce requirements on a per-well or per-rig basis. Need to collaborate on a methodology to do so. 10
Economic Activity (by county, unless otherwise noted) 1 estimated oil and gas industry employment, including subcontractors employment by sector personal income by sector; nonlabor income income distribution unemployment rate compared with benchmark county, state, and nation employment diversity/specialization Bureau of Labor Statistics Are annual data available for this analysis? See index used in EPS.12 Operators? [sic] BLS: NAICS sectors 211, 212, 213? [sic] BEA, REIS, Table CA25N - NAICS BEA, REIS, Table CA05N - NAICS Are annual data available for this analysis? Can we use the Kuznets ratio or Gini coefficient?11 See note 5. Will Bureau of Labor Statistics capture out-ofstate subcontractors employees?
1 1 2 1
Roy Allen: By including [production projections] in the monitoring plan, the impacted counties and communities would be able to project earnings, employment and population by 10 year increments that would then be updated on an annual basis based on industry submissions. They would also be able to estimate taxes and royalties on the same 10 year basis as a function of industry provided production estimates and these projections would also be kept current by sending out an annual request to industry for this information.
10
99
Comment by Jeffrey Jacquet re estimating number of oil and gas workers and dependents, by county: The operators do not have this information. The gas field organization and employment residency is too complex and decentralized for the operators to provide this information. The only so-far proven way of obtaining these numbers is to estimate them, using workforce requirements on a per-well or per-rig basis, et cetera. The operators do not have qualified staff to provide these numbers. The monitoring program will have to work with the operators and various subcontractors to put together a methodology to estimate the workers and dependents accurately.
Debraj Ray, Development Economics, Oxford UP, 1998, pp. 187-190.
11
12
n
The specialization index used in the Economic Profile System is calculated as:
SPECIALit = ((EMPijt/EMPit)-(EMPusjt/EMPust)) 2
j=1
Where, SPECIALit = specialization of economy in county i in year t EMPijt = employment in industry j in county i in year t EMPit = total employment in county i in year t EMPusjt = employment in industry j in US in year t
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Priority 2
Indicator recreation use: recreation days by category, Pinedale Field Office tourism: visitor origin, recreational use, and spending
Source BLM Recreation Management Information System intercept survey
Notes
3 Revenues 1 1 1
Wyoming share of federal mineral revenues Wyoming severance tax county property tax revenues, by source, including ad valorem oil and gas production tax
Minerals Management Service Wyoming Dept. of Revenue county assessor
can this be tracked by project (Pinedale Anticline, etc.)?
Demand on Public Services 1 value of proposed and current growth-related capital improvements, by jurisdiction (e.g., sewer, water, roads, public facilities) traffic accidents by county provided by counties and municipalities suggested by Pinedale council member
Wyoming Dept. of Transportation
Housing (by county, unless otherwise noted) 1 Housing availability: rental occupancy rates by category of housing Housing availability: existing stock and new construction of housing units by category Housing affordability Temporary (operator provided) housing: worker-months occupied operators county assessor
1 2
What sources can provide annual data?
Social Impacts (by county, unless otherwise noted) 1 2 Crimes charged, adult and juvenile Circuit Court cases U.S. Dept. of Justice, Uniform Crime Report Highlight categories of particular interest: drug offenses, domestic violence, etc. Could provide more detail than Uniform Crime Report. A quality of life survey would be most useful if administered on a regular basis, annually or semi-annually, based on a random sample of residents. The questions should be closedended and limited in number. The attitudinal questions should be scaled (typically on a 5-point scale, strongly agree to strongly disagree.). An example: Overall, energy development has benefited county residents. These should be accompanied by demographic questions, including income,
Quality of life survey
EMPust = total employment in US in year t n = number of industries
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Priority
Indicator
Source
Notes education, sector of employment, and years of county residence.
Focus groups to address particular issues related to energy development
A focus group is valuable for interpreting existing information (e.g., explaining changes in patterns of tourism and recreation) or eliciting suggestions for solving problems (e.g., how to accommodate growing housing demand by oil and gas workers). For issues related to energy development, focus groups should include both long-term residents and shorterterm oil and gas workers.
4.6
VEGETATION
Vegetation resources in the Encampment area are critical to the natural and economic well-being of the community. Vegetation composition is important to the ecological function of the watersheds within the area and provides the foundation for economic drivers in the region, such as livestock grazing and wildlife-associated recreation. 4.6.1 Affected Environment
The vegetation information contained in the Affected Environment section of the RMP/FEIS is insufficient. The broad scale ecoregional and general vegetation zone descriptions are not adequate for planning as they are insufficiently detailed to be used as a baseline. Specific vegetation data and quantifiable mapping units should be used. As vegetation is the foundation for herbivory potential for both wildlife and grazing, there can be no accurate quantification of carrying capacity or grazing capability using the general vegetation descriptions found in the RMP/FEIS. In Instruction Memorandum (IM) No. 2007-202, the BLM notes that "the BLM utilizes ecological sites as the method to divide rangeland into basic units for study, evaluation, and management." Ecological sites best describe plant communities and are used to understand Historic Climax Plant Communities and other vegetation states. The RMP/FEIS does not appear to utilize ecological site descriptions, and there is no mention of these descriptions under affected environment. We recognize there may be limitations to soil surveys that form the basis for ecological sites but believes that the inventory requirements in 43 CFR 1610.4-3 (Inventory Data and Information Collection) clearly provide for and support the collection of data necessary to ensure consistency with the IM noted above. Based on the following direction from the BLM NEPA Handbook, the RMP/FEIS is not consistent with national direction:
The District or Area Manager shall arrange for resource, environmental, social, economic and institutional data and information to be collected, or assembled if already available. New information and inventory data collection will emphasize significant issues and decisions with the greatest potential impact. Inventory data and information shall be collected in a manner that aids application in the planning process, including subsequent monitoring requirements.
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In addition, the BLM NEPA Handbook notes that the affected environment section should be of sufficient detail to serve as a baseline against which to measure the potential effects of implementing an action. Further, it states,
The CEQ regulations discuss human environment at 40 CFR 1508.14; the term broadly relates to biological, physical, social, and economic elements of the environment. We recommend that the descriptions of the specific elements be quantitative wherever possible, and of sufficient detail to serve as a baseline against which to measure the potential effects of implementing an action.
However, vegetation data for the RMPPA were summarized from the landcover layer obtained from the Wyoming Gap Analysis Project (WY-GAP 1996). Per the RMP/FEIS
The general vegetation zones illustrated in Map 3-10 represent combinations of plant community classes taken directly from the Geographical Analysis Program [sic; Gap Analysis project] (GAP) satellite imagery analysis. The classes combined for each zone, the zones total area, the dominant vegetation, and a description of the area where the vegetation occurs are also provided. Note that the percentages indicated represent total area within the RMPPA, some of which is owned by private, state, or other federal entities.
Based on the BLM NEPA Handbook, the vegetation descriptions do not meet requirements, as the broad variability of GAP data is well known. Further, the GAP data only provide percent of broad land cover types. They do not provide detailed information on percent cover or density of various rangeland, forested, or other habitats and thereby fail to summarize rangeland condition. Table 4.6-1 below provides an example of the GAP data for the SERCD study area. The SERCD study area is dominated by rangeland cover types (46%), followed by forested areas (37%), agriculture (15%), and riparian and water (2%) cover types. The GAP data only provide percent canopy cover and rangeland.
Table 4.6-1 Land Cover by Ownership Land Cover Federal Groupings Forests 33.5% Rangeland 24.7% Agriculture 0.4% Human settlements 0.0% Riparian and Water 0.2% Total 58.8% (WGA 1996)
Private 2.3% 18.8% 14.3% 0.3% 1.5% 37.1%
State 1.0% 2.6% 0.4% 0.0% 0.1% 4.1%
Total 36.7% 46.1% 15.1% 0.3% 1.7% 100%
More recent and detailed data on the condition of the rangeland habitats in the RMPPA exist. The United States Department of Agriculture (USDA) and United States Department of the Interiors (USDI) Landscape Fire and Resource Management Planning Tools Project (LANDFIRE 2006) data products include layers of vegetation composition and structure, surface and canopy fuel characteristics, and historical fire regimes. When comparing the GAP cover types to those provided by LANDFIREs Existing Vegetation Type Layer, the two datasets yield similar results with respect to land cover
groupings (GAP had rangelands at 46% of the project area, while LANDFIRE calculated rangelands as 44% of the project area). Yet, LANDFIREs existing vegetation dataset provided more detailed information on the characteristics of rangeland habitats, and these improved data should have been used. Table 4.6-2 below presents the canopy cover groups for the rangeland habitats within the project area.
Table 4.6-2 Percent Shrub Cover for Rangeland Habitats in the Project Area Percent% Shrub Cover Acres 10-20 90,115 20-30 76,345 30-40 53,191 40-50 35,390 50-60 14,498 60-70 841 70-80 66 80-90 15 Total 270,463 (LANDFIRE 2006)
% of Rangeland Habitats 33.32% 28.23% 19.67% 13.08% 5.36% 0.31% 0.02% 0.01% 43.96%
Ecological condition data provide further information on the quality of the rangeland vegetation. LANDFIRE provides data on the fire regime condition class (FRCC) of the vegetation in the RMPPA. FRCC is a discrete metric that quantifies the amount the current vegetation has departed from the simulated historical vegetation reference conditions (Hann and Bunnell 2001; Hardy et al. 2001; Hann et al. 2004; Holsinger et al. 2006). The three FRCC condition classes describe low departure (FRCC 1), moderate departure (FRCC 2), and high departure (FRCC 3). This departure is calculated based on changes to species composition, structural stage, and canopy closure (LANDFIRE 2006). The LANDFIRE Fire Regime Groups layer represents an integration of the spatial fire regime characteristics of frequency and severity simulated using the vegetation and disturbance dynamics model LANDSUM (Keane et al. 2002). Table 4.6-3 presents the condition class data combined with the fire regime groups. Lands listed as FRCC 2 or 3 suggest that the ecological condition of rangelands is reduced as a result of altered disturbance cycles. This type of analysis in the Affected Environment section would provide more sufficient background for assessing potential impacts to grazing, wildlife, and other vegetation dependent resources.
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Table 4.6-3 Fire Regime Condition Class (FRCC) by Fire Regime Group Fire Regime Groups Fire Regime Group I 35 Year Fire Return Interval, Low and Mixed Severity FRCC 1 2 3 Water Urban Agriculture 1 2 3 Barren Agriculture 1 2 3 Water Urban Barren Agriculture 1 2 3 Water Urban Barren Agriculture 1 2 3 Water Urban Barren Agriculture Acres 1,004.4 421.91 598.75 0.03 0.37 2.37 2,027.83 1,071.5 426.25 70.59 0.05 1.82 1,570.21 103,641.2 58,835.23 16,819.04 60.93 817.32 11.46 26,015.5 206,200.68 158,789.55 168,504.47 1,603.44 20.4 3,012.64 18.3 3,8516.74 370,465.54 13,941.23 13,197.52 1,111.13 62.03 344.44 7.83 2,330.57 30,994.75 % 49.5% 20.8% 29.5% 0.0% 0.0% 0.1% 100.0% 68.2% 27.1% 4.5% 0.0% 0.1% 100.0% 50.3% 28.5% 8.2% 0.0% 0.4% 0.0% 12.6% 100.0% 42.9% 45.5% 0.4% 0.0% 0.8% 0.0% 10.4% 100.0% 45.0% 42.6% 3.6% 0.2% 1.1% 0.0% 7.5% 100.0%
Fire Regime Group I Total Fire Regime Group II 35 Year Fire Return Interval, Replacement Severity
Fire Regime Group II Total Fire Regime Group III 35200 Year Fire Return Interval, Low and Mixed Severity
Fire Regime Group III Total Fire Regime Group IV 35200 Year Fire Return Interval, Replacement Severity
Fire Regime Group IV Total Fire Regime Group V > 200 Year Fire Return Interval, Any Severity
Fire Regime Group V Total (LANDFIRE 2006)
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BLM IM 2007-202 discusses the planning advantages of using ecological site descriptions for planning purposes. The bio-region discussion, while enlightening for a regional perspective, does not provide the detailed planning information required. We recommend that the BLM utilize ecological site descriptions as noted in IM 2007-202. Ecological site descriptions can then be used to describe the ecological condition of the area, as well as provide for a more precise initial stocking rate. We recommend that the State-and-Transition models, contained within the ecological site descriptions, be used in order to fully investigate the affected environment. The Affected Environment section also does not quantify noxious weeds or invasive plants. This section estimates 20,000 acres of noxious weed infestations, but no basis is given for this estimate. Lack of methodological rigor and explanation makes the information useless as a baseline for comparing future changes to plant communities caused by continued weed expansion or management efforts to reduce weed infestations. Further, there is no discussion of the threats to wildlife and grazing potential from existing weed infestations beyond a single sentence mentioning the threat. Detailed baseline data on the intersection of weed infestations and herbivory potential should have been included and analyzed in the vegetation, wildlife, and livestock grazing sections. 4.6.2 Environmental Consequences
The RMP/FEIS provided the following significance criteria for vegetation:

Any action or event that would remove a communitys unique attributes or ability to support other resource values within the planning period, or if corrective actions were beyond the scope of this document. The viability of protected plant species is jeopardized, with little likelihood of reestablishment after disturbance, or actions result in the need to list a species under ESA. Actions that have the potential to remove sensitive plant species or substantially alter the habitats ability to support the species. Reclaimed areas do not attain adequate vegetation groundcover and species composition to stabilize the site within 5 years from disturbance, or there is invasion and establishment of noxious or invasive weeds that contribute to unsuccessful revegetation. Introduction of noxious and invasive weeds into areas considered weed-free, or an increase in weeds where they already exist.
These significance criteria are generally adequate. However, the baseline data for vegetation resources do not follow the policy and guidelines from the BLM as discussed previously. Without these baseline data, changes to the vegetative resource cannot be quantified, and in the case of weeds, neither new infestations nor increases to existing populations can be measured. Thus, based on the baseline work conducted by the Rawlins BLM, the RMP/FEIS is unable to adequately assess whether significance criteria for vegetation have been met. Further, because there is no quantitative baseline data, there is no quantification of potential impacts to vegetation resources associated with the alternatives considered. The RMP/FEIS
provides total number of acres disturbed under the preferred alternative, but there is no attempt to stratify these numbers by vegetation type or by impact (e.g., grazing lands, wildlife habitat). We recognize the broad-scale focus of the RMP/FEIS, yet some quantification of effects is necessary to provide adequate detail for comparison of alternatives. Merely stating the total acreage to be disturbed is not sufficient. Total numbers of disturbance do not sufficiently inform the reader as to the impacts to vegetation resources and the potential impact to resources that rely on vegetation resources. Additionally, we believe that five years is not enough time to adequately revegetate a drill pad (fourth significance criterion, above). Reclamation data from other Wyoming gas fields should be provided to show what range of success rates are expected in five years. We think that 2040 years is likely a more realistic timeline, particularly for sagebrush cover. The RMP/FEIS also claims that enhanced forage availability and production would be realized over the long-term with increased production and availability of herbaceous vegetation as dense and/or old shrub stands are treated. The RMP/FEIS does not define vegetation treatments, but the thinning of shrubs is highly unlikely given that state and federal agencies have identified increasing big sage brush cover as a priority to maximize greater sage-grouse habitat. We recognize the need for oil and gas development, but it is important to maintain the agricultural productivity within the RMPPA to ensure a sustainable foundation of economic diversity that stakeholders want to keep once the energy development has run its course. 4.6.3 Cumulative Effects
One criterion for significant impact would be any action that would remove a communitys ability to support other resource values per the RMP/FEIS. The Cumulative Impact section states that there would be no significant cumulative impacts; however, there is no quantification to support this assertion. There is no consideration of the cumulative impacts from weeds, energy development, and other actions and how they might cumulatively reduce vegetation, impact wildlife, or impair the resilience of working ranches. The consideration of energy development beyond the BLMs RFD scenario, such as those described in RFD2, would exacerbate the potential for significant cumulative impacts. 4.6.4 Mitigations
4.6.4.1 Mitigations Identified by BLM BLM outlines a series of BMPs and mitigations related to vegetative resources. The BMPs should be made into mandatory standards, not discretionary suggestions. Further, we do not find any mitigations related to protection of vegetation resources from oil and gas development beyond a general no surface occupancy mitigation for any threatened or endangered plant species habitat (Appendix 1). Vegetation Treatments, Forest Practices, and Range Improvements (Appendix 19) BMPs cover the following:
Vegetation treatment guidelines for proscribed fire; chemical and biological treatment; mechanical treatments; grazing management prescriptions; plantings of vegetation; seedings of vegetation; design of range improvements; springs and seeps; troughs; wells; water pipelines; reservoirs; fences; cattleguards; instream structures Forest management Silvicultural practices Management direction for forests and woodlands.
For details, see RMP/FEIS Appendix 19. Mitigation Guidelines for Special Status Plants (Appendix 24) The following three mitigations are provided:
A field visit would be conducted to identify if habitat and/or plants are in the project area. The project is moved or modified to avoid the habitat or the plants; however, if avoidance is not possible, the project is designed to minimize disturbance to the identified habitat or plants. In the rare instance that a project would not be able to be modified to the extent needed to protect the plants, the project would not be authorized. Once a sensitive species population is identified, the objective of vegetation management for the area is to protect and maintain that plant population by designing treatments to maintain or enhance the habitat to meet the needs of the plant (desired plant community [DPC]). Inventory for plants and habitat would be a priority to develop management objectives that are designed to maintain or enhance habitat for the plant. As unique plant communities, such as the sand hills bitterbrush/silver sagebrush, cushion plant, and chain lakes alkaline wetland communities, are identified, protection measures are developed.
1.1.4.2 Recommended Additional Mitigation Because the primary concern with vegetation resources are related to livestock grazing and wildlife resources, recommended additional mitigations relating to vegetation are listed under those resource topics. 4.7 VISUAL RESOURCES
Visual Resources are an important resource because of their close relationship to recreation resources; many recreational activities depend on the natural landscape, settings, and scenic vistas that visual resource management (VRM) is intended to protect. Visual sensitivity is a key attribute for many residents, tourists, and visitors. 4.7.1 Affected Environment
The RMP/FEIS clearly defines and establishes VRM classes across the RMPPA in accordance with BLM policy found in the BLM Land Use Planning Handbook, Appendix C. The VRM process is discussed in the RMP/FEIS (pp. 3-120 and 3-121), and the VRM process is defined in Appendix C of the BLM Land
Use Planning Handbook. The established VRM classes in the RMPPA are depicted for Alternatives 1-4 on Maps 2-49, 2-50, 2-51, and 2-52. Maps 2-49 and Maps 2-51 lack legends. 4.7.2 Environmental Consequences
The RMP/FEIS identifies two criteria for significant impacts to visual resources:
An activity or development in an area is incompatible with the designated VRM class objective and becomes an unacceptable feature of the landscape or visual horizon. Surface disturbance, development, or other visual intrusions are so dominant on the landscape that they overwhelm the casual observer, regardless of the VRM Class, to the point that he would not want to return to the area.
The analysis presented within the RMP/FEIS is based on the assumption that a management action for a program or resource will have an effect on visual resources if that action does not conform to the designated VRM class. Further, the RFD/FEIS states that,
Oil and gas development and production facilities would be compatible with VRM Class IV objectives Developments in Class II areas would be mitigated so as to retain the scenic quality and not attract the attention of the casual observer VRM management actions would mitigate visual intrusions applied in the form of BMPs and condition of approvals which would decrease the visual impacts [these mitigations] would prevent significant impacts, except where facilities are densely located to prevent them from dominating the landscape, which would create visual distractions.
Thus, the BLM finds that energy development in the RMPPA has already created direct, negative impacts and that under Alternative 4, future development will continue to do so, particularly in Class II VRM areas. Class II VRM areas underlie the majority of the lands proposed for leasing in the study area. Leasing in this area at very low densities could be mitigated as necessary. More intensive energy development, similar to the RFD2 scenarios, however, would likely be incompatible with Class II VRM objectives and BLM policy that directs mangers to
Manage resource uses and management activities consistent with VRM objectives Design all BLM resource uses, management activities, and other implementation decision to meet VRM objectives established in the land use plans. (BLM Land Use Planning Handbook, Appendix C)
Further, the RMP/FEIS continues,

However, development activities would potentially exceed these prescribed [VRM] levels in order to better effectively extract resources, which would constitute a significant impact to visual resources.
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This is clearly inconsistent with BLM Land Use Planning Handbook guidance. Designating Class II VRM areas and then offering them for lease requires analyses of the impacts acknowledged by the BLM. However, the level of detail regarding potential drilling numbers and locations in the RMP/FEIS does not allow for a sufficient analysis of impacts to visual resources. 4.7.3 Cumulative Effects
The BLM adequately disclosed the cumulative impacts to visual resources arising from the significant issues they identified. 4.7.3.1 Mitigations Identified by BLM In Appendix 1 of the RMP/FEIS, the BLM lists the following two mitigations related to energy development and visual resources:
Surface disturbance will be prohibited in any of the following areas or conditions unless excepted, waived, or modified by the Authorized Officer: Within important scenic areas (Class I and II Visual Resource Management Areas) Within either one-quarter mile or the visual horizon (whichever is close) of historic trails
The historic trail mitigations should be sufficient to protect visual resources near the Cherokee Trail in the study area. However, we assume that limitations for Class II VRMs have been waived in the study area given the proposed offering of leases on these lands and no other mention of this restriction on Class II lands throughout the RMP/FEIS. BLM also provided the BMPs listed below to avoid or minimize the impact of energy development on VRM Class II and III lands. Given that the entire mitigation strategy relies on these BMPs to be consistent with NEPA, the BMPs must be restated as mandatory mitigations as opposed to discretionary suggestions. Best Management Practices for Reducing Surface Disturbance and Disruptive Activities (Appendix 15) The following BMPs would be considered to reduce impacts to visual resource management Class II and III areas:
Burying of distribution power lines and flow lines in or adjacent to access roads Repeating elements of form, line, color, and texture to blend facilities and access roads with the surrounding landscape Painting all above-ground structures, production equipment, tanks, transformers, and insulators not subject to safety requirements to blend with the natural color of the landscape, using paint that is a non-reflective standard environmental color approved by the BLM visual resource management (VRM) specialist
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Performing final reclamation re-contouring of all disturbed areas, including access roads, to the original contour or a contour that blends with the surrounding topography Avoiding facility placement on steep slopes, ridge tops, and hilltops Screening facilities from view Following contours of the land to reduce unnecessary disturbance Re-contouring and revegetating disturbed areas to blend with the surrounding landscape Reclaiming unnecessary access roads as soon as possible to the original contour Using gravel of a similar color to adjacent dominant soil and vegetation colors for road surfacing Avoiding locating pads in areas visible from primary roads Using subsurface or low-profile facilities to prevent protrusion above horizon line when viewed from any primary road Avoiding the routing of well access roads directly from state, county, or BLM roads Co-locating wells when possible Locating facilities far enough from the cut and fill slopes to facilitate re-contouring for interim reclamation Locating wells away from prominent features, such as rock outcrops Completing an annual transportation plan for entire area before beginning construction, and making a layout that will minimize disturbance and visual impact Designing and constructing all new roads to a safe and appropriate standard no higher than necessary to accommodate their intended use Locating roads far enough off the back of ridgelines so they arent visible from state, county, or BLM roads Using remote monitoring to reduce traffic and road requirements Removing unused equipment, trash, and junk immediately.
4.7.3.2 Additional Mitigations No additional mitigations are recommended. 4.8 WATER QUALITY
Protection of water resources (water quality, yield, and supply) was identified as the most important issue in the Encampment Areas Watersheds Study survey (Figure 1.3-1). The BLM also identified water quality and potential impacts from land management decisions as a key issue for in-depth analysis in the RMP/FEIS. The importance of water resources in this area cannot be understated. The Encampment-area watersheds form the headwaters for the North Platte and Encampment Rivers, which provide critical surface water resources for local and downstream municipal, agriculture, and industrial purposes. The uplifted Sierra Madre and Medicine Bow Mountains surrounding the North Platte Valley are important
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recharge areas for the ground water aquifers, which provide domestic and stock water to most rural areas in Wyoming. 4.8.1 Affected Environment
4.8.1.1 Surface Water The Affected Environment section adequately describes existing conditions for surface water resources, including information on the stresses affecting surface waters and includes some baseline water quality data collected by the USGS. However, the RMP/FEIS only generally discusses water uses and fails to mention that there are several community water systems that rely on surface water, including those for the communities of Encampment and Saratoga (although Saratoga is in the process of developing ground water for their municipal supplies [BLM 2008]). The RMP/FEIS provides information on stream flow but does not discuss the effects of recent drought conditions. According to the Wyoming State Engineers Office (WSEO), flows on the North Fork Platte River have reached average in only one (water year 2008) of the last nine years (Hoobler pers. comm.). Turbidity is considered the key surface water concern in the North Platte River basin. Stream bank degradation and soil erosion due to inadequate vegetative cover are considered the primary sources for excess sediment. The water quality data summarized in the RMP/FEIS from USGS surface water quality monitoring sites at the North Fork Platte River above Seminoe Reservoir station (USGS Site Number 6630000) and the Encampment River at Mouth station (USGS Site Number 6625000) provide baseline data relevant to the study area watersheds. These data (RMP/FIES Table 3-9) indicate that turbidity, along with most other water quality parameters, increases as water moves downstream. However, the water quality data from the Encampment River site were for the period from 19651989 and, therefore, may not represent current baseline conditions. The Wyoming Department of Environmental Quality (WDEQ) and SERCD both have more recent water quality data for the Encampment and North Fork Platte River (Hargett 2000, 2007) that should also have been included in describing baseline conditions. 4.8.1.2 Ground Water The Affected Environment section does not adequately describe existing conditions for ground water resources. With the potential for an estimated 9,000 new oil and gas well locations in the RMPPA, along with likely increased demand for ground water resources for other uses, the RMP/FEIS fails to provide a substantive discussion of the basic characteristics and properties of the ground water aquifers needed to fully understand and assess the potential impacts due to energy development. Petroleum hydrocarbons from oil and gas development have already adversely impacted ground water in the Jonah and Pinedale Anticline gas fields (BLM 2007a), and because ground water is the source for most residential and stock water uses in the region (Bartos et al. 2006), the lack of attention to ground water issues in the RMP/FEIS is a serious failure of the NEPA process.
To begin, in the RMP/FEIS, the entire discussion of ground water is included in the introductory paragraphs to the Water Management and Monitoring section (RMP/FEIS p. 3-132). This completely minimizes the importance of this resource, despite most people living in the area depending on ground water for domestic, stock, and other uses. Management and monitoring apply to both ground water and surface water resources, and the RMP/FEIS confuses that discussion by including within it the description of the ground water affected environment. Ground water is a critical resource and its characteristics, quality, and occurrences need to be described in stand-alone sections, as was done for surface water. The description of the affected environment for ground water acknowledges the numerous studies conducted on ground water resources within the RMP/FEIS (p. 3-132). However, the RMP/FEIS then fails to clearly incorporate or describe any of the relevant content from these reports. What little information is provided on ground-water occurrence emphasizes only the Quaternary and Tertiary aquifers. There are no maps or other graphics provided to help understand the geologic context, distribution, or hydrogeologic properties of all the regional aquifers. There is no discussion of where ground water development is concentrated, and there is no quantitative information provided to establish baseline water quality. The ground water information in the RMP/FEIS is so generic it could apply to almost any area in Wyoming. Without a thorough description of the ground water affected environment, it is impossible to fully assess how activities proposed in the RMP/FEIS could impact this resource as required by NEPA. The RMP/FEIS fails to adequately describe surface water-ground water relations. This is a critically important issue, especially in terms of water depletions and meeting the requirements of the recovery programs and interagency agreements related to water depletions in the Colorado and Platte River systems (Hoobler pers. comm.). The RMP/FEIS states (p. 3-132) that site-specific ground water data is limited. While this may be true, there are a wealth of readily-available regional data, more appropriate to this planning effort, that should be evaluated and discussed in the RMP/FEIS. For starters, the RMP/FEIS should include an analysis of which areas have developed ground water resources. A cursory review of the Wyoming State Engineers Office on-line ground water database for the Encampment watersheds indicates there are around 420 domestic wells, 169 domestic/stock wells, 134 stock/irrigation wells, and six municipal wells in good standing (WSEO 2008a). The general distribution of these wells is shown in Map 4.8-1 along with existing oil and gas exploration wells (all abandoned), areas of oil and gas development potential, and the potential lease areas outside the area of likely gas development potential. This simple type of analysis clearly illustrates that ground water is a well developed resource in the Encampment watersheds. It shows where development is concentrated, and is the type of analysis that should have been conducted for the RMP/FEIS.
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Legend Watershed Study Project Area Townships Water Wells Per Section
Roads Rivers
www.ecosystemrg.com
1-5 6 - 10 11 - 20 > 20
Saratoga
Energy Development Potential Low Potential Non-Coalbed Methane Development (per BLM RFD) Public Land Leases Private Land Leases
T17R85
T17R84
130
T17R83
T17R82

T17R81 T17R80
T16R85
T16R84
T16R83
130
T16R82 T16R81 T16R80
T15R85
T15R84
T15R83
T15R82
T15R81
T15R80
Encampment
T14R85
70
T14R84
T14R83
T14R82
T14R81
T14R80
230
T13R85
T13R84
T13R83
T13R82
T13R81
T13R80
T12R85
T12R84
T12R83
T12R82
T12R81
T12R80
WYOMING COLORADO Map 4.8-1 Areas of ground water development in the Encampment area watersheds
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The RMP/FEIS completely fails to provide a serious analysis or adequate description of existing ground water quality. Despite acknowledging the fact that the hydrogeologic environment is complex, the description of water quality is confined to one short paragraph containing only vague generalizations and incomplete data. Water quality is described as highly variable, yet no actual data is included to quantitatively evaluate what highly variable means. The BLM discusses the substantial data on existing ground water quality collected by the mining industry but failed to include the data. What little water quality data is provided appears to be completely random. The RMP/FEIS mentions the high concentrations of sulfate, fluoride, boron, iron, and manganese as reported by the U.S. Geological Survey (USGS) for Sweetwater County (Mason and Miller 2004). The exact same findings by the USGS for Carbon County (Bartos et. al. 2006) are not reported. There is reference to high radionuclide concentrations in the Battle Springs aquifer in the Great Divide Basin but not to similar results for other aquifers, also reported by Bartos et al. (2006). Regional quantitative water quality data are readily available (e.g., Mason and Miller 2004, Bartos et al. 2006) and should have been summarized in the RMP/FEIS, as was done for surface water (RMP/FEIS Table 3-39) and in accordance with BLM planning guidance for establishing baselines (BLM NEPA Handbook, p.53). The lack of consistency and seemingly random reporting of water quality data indicates the water quality analysis was not seriously addressed and does not meet the requirements of NEPA. Finally, to emphasize the importance of ground water as a key resource, it should be noted that the community of Saratoga is in the process of developing ground water for their municipal supply to replace the current system that uses surface water from the North Platte River. Further, the community of Riverside obtains water from the Tertiary North Park aquifer at the base of the Parker Hills (Sierra Madre), not the Medicine Bow Mountain Range as incorrectly stated in the RMP/FEIS. 4.8.1.3 Water Management The RMP/FEIS adequately describes the various agencies involved in water resource management in the RMPPA. The Platte River Recovery Implementation Program (USDI 2006) and associated Wyoming Depletions plan will provide guidance for addressing potential water depletions in relation to all proposed management actions, including energy development. 4.8.1.4 Water Monitoring A summary of the ground water monitoring program from Appendix 17 in the RMP/FEIS is summarized below (Table 4.8-1).
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Table 4.8-1 Ground Water Monitoring Indicator Method or Location Technique Groundwater Groundwater Where quality sampling groundwater resources are used (stock watering or water supplies for campgrounds) Groundwater Well monitoring, Area-wide resources sampling, and potentially modeling impacted by resource development
Unit of Measures Representative sample of water quality in standard units depending on parameter Depth to groundwater, water quality parameters
Frequency and Duration Varies by project when they are established and campgrounds monthly Monitoring wells may collect continuously, frequency and duration driven by project specifics
Action Trigger When water quality does not meet needs for uses
A significant environmental impact not considered or disclosed in the NEPA process
For the indicator Ground water resources potentially impacted by resource development, the trigger needs to be explained. It reads like the trigger only applies to significant environmental impacts not disclosed in the NEPA process. Does that mean an aquifer could be contaminated by petroleum hydrocarbons but monitoring would not trigger anything because the impact was disclosed in the RMP/FEIS? And what specific actions occur if an action trigger is met? The RMP/FEIS goal of protecting water resources is generally consistent with water resource goals stated in the 1998 Carbon County Land Use Plan (CCLUP) and the 2008 SERCD Long Range Plan, although the RMP/FEIS fails to acknowledge (as required by CEQ 1502.16(c)) that the CCLUP excludes most of the area encompassed by the Encampment area watershed from oil and gas exploration, production, processing, and transportation. BLM clearly intends to allow leasing in this area and therefore must discuss this conflict with the local plan. Recent drought, water quantity, and potential ground water and/or surface water depletions associated with oil and gas development are a concern of the WSEO for the North Platte River basin (Hoobler pers. comm.). New depletions are permitted by the WSEO and reviewed in terms of the Platte River Recovery Implementation Program (USDI 2006) and associated Wyoming Depletions plan. The RMP/FEIS identifies the Platte River Recovery Program as a key water management document. The Wyoming Governors Office is opposed to oil and gas leasing in the Saratoga Valley until a thorough analysis of water resources is conducted (Stevenson pers. comm.). In the RFD2 scenarios, oil and gas development would most likely occur west of the North Platte River and in the Encampment River area. These rivers and their tributary streams have their headwaters in the Sierra Madre Range. Areas not considered in the RMP/FEIS but where leases were requested include
Calf Creek and Encampment River-West Cottonwood Creek, and the Beaver Creek-North Platte River watersheds in the North Platte watershed. Surface water quality data has been collected from the Encampment and North Platte Rivers as discussed in the RMP/FEIS (p. 3-131, Table 3-39). The WDEQ has not assessed water quality in the smaller, tributary watersheds where oil and gas development could occur. The Encampment River is classified as 2AB and is fully supportive of drinking water, wildlife, industrial, aesthetic value, agricultural, cold-water fisheries, non-game fisheries, aquatic life other than fish, and fish consumption uses (Hargett 2000). The river provides municipal water for the community of Encampment. Effluent from the Riverside and Encampment wastewater treatment facilities discharges to the Encampment River and is a WDEQ permitted point source discharge facility. Pollutants of concern include biochemical oxygen demand (BOD), fecal coliform, total suspended solids (TSS), and total residual chlorine. The North Fork Platte River in the Encampment watershed area is Class 1 water. Based on data collected in the 1990s, it is considered fully supportive of fisheries and other aquatic life uses although the effect of the recent drought is unknown (Hargett 2007). Other designated uses protected for Class 1 waters (drinking water supplies, primary contact recreation, wildlife, industry, agriculture, and scenic value) were indeterminate as far as use support, but most are likely met if fish and aquatic life uses are met. Ground water is an important developed resource in the RFD2 scenario areas (Map 3.2-2, Map 3.2-3, and Map 3.2-4). Oil and gas development would be concentrated in the Saratoga Valley, which is underlain by the Tertiary North Park Formation (also referred to as the Browns Park Formation in Bartos et al. 2006). Ground water flow in the North Park Formation is from recharge areas in the Sierra Madre and Medicine Bow Mountains and foothills toward the North Fork Platte River (Bartos et. al. 2006). The primary developed aquifers are in the North Park Formation and the Quaternary alluvial deposits found along the major streams. Most reported well depths are less than 300 feet (WSEO 2008a) and provide water for municipal, residential, stock, and irrigation uses. The surficial aquifers are considered moderate to highly sensitive to contamination (WWRC 1997). Ground water in the majority of the RFD2 area is considered to be hydrologically connected to the North Fork Platte River (WSEO 2008b). 4.8.2 Environmental Consequences
The specific critical issues related to water quality identified in the RMP/FEIS were increased interest in natural gas production, legal changes to the status of depletions in the Colorado and Platte River drainages, and rule changes for salt loading in the Colorado River Basin. Impacts from energy development as addressed in the RMP/FEIS are discussed below.
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The RMP/FEIS describes the methods used to conduct the impact analysis, including criteria to determine the significance of impacts and assumptions used for the analysis (p. 4-4084-410). While the RMP/FEIS identifies most of the expected impacts related to energy development, it fails to provide any actual analysis of the impacts. Furthermore, the organization is so poor that it is difficult to understand what the specific impacts to surface water, ground water, or soils would be. For example, salt loading is a potential impact to surface water associated with ground disturbance and runoff. This impact is not mentioned under impacts from energy development but is included under impacts from transportation and livestock grazing. The RMP/FEIS should present a more coherent discussion so decision makers and the public can easily find pertinent information. The analysis of environmental consequences is intended to form the scientific and analytic basis for comparing alternatives (40 CFR 1502.16). The RMP/FEIS fails to meet this requirement. For example, in the energy development section of Impacts Common to all Alternatives, the RMP/FEIS (p. 4-412) states,
Oil and gas development would result in increased soil erosion, sediment loading, and potential groundwater contamination from drilling operations. Increased erosion and surface runoff would occur from soil compaction and the channelization of surface runoff in culverts and road ditches. Intercepting runoff above roads concentrates flows and increases erosion. As this runoff is not respread below roads, these areas become drier, which reduces plant productivity, alters species composition, and increases soil surface exposed to wind and water erosion. Drainages which receive this concentrated, increased flow often erode downward, further increasing erosion and sediment loading downstream. Proper construction of well pads and roads, disposal practices, proper casing and cementing, and reclamation of drilling reserve pits in accordance with BLM guidelines would reduce these impacts (Appendixes 1, 11, 13, and 27); however, soil erosion would still be significant in developed areas.
This discussion does not constitute impact analysis; it merely describes in qualitative terms potential impacts and concludes that soil erosion, even with mitigations, would still be significant in developed areas. Are soil conditions, geology, road density, or other factors affecting erosion the same in all developed areas? What specific data were used to determine that erosion would still be significant? If ground water can potentially be contaminated, would it also be significant? The same types of generalized discussions are repeated for each alternative, and in no case does the RMP/FEIS provide the detail needed to support a reasoned comparison of the impacts between alternatives as required by NEPA (40 CFR 1502.1). The only quantified data provided is acres of disturbance and miles of potential new roads. Differences in impact intensity are described in vague terms such as similar to, slightly larger, or slightly lower with no explanation of the criteria used to compare the relative intensity from the various activities under the identified alternatives. Rarely are impacts discussed in term of direct, indirect, short- or long-term effects.
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The RMP/FEIS adequately describes likely impacts to ground water, but aquifer drawdown should be included as a potential impact, especially since interrupted or reduced natural flow to springs and artesian wells or to ground water level in wells is one of the threshold criteria for determining significance (p. 4408). The RMP/FEIS fails to provide any real analysis of how impacts would differ between the specific alternatives. The lack of serious analysis of ground water impacts is typified in the RMP/FEIS by the meaningless conclusion that,
Localized contamination of groundwater would occur because groundwater quality and contaminate sources are likely to be impacted in some locations.
Even a simple analysis showing existing ground water development in relation to areas open to energy development under each alternative would have been helpful as a start. One of the key concerns associated with oil and gas development is water production and disposal, especially for CBNG development and potential impacts on surface water. The RMP/FEIS provides an incomplete analysis of the impacts associated with CBNG development. This is especially problematic in light of the rapid development of CBNG resources elsewhere in Wyoming and pending projects such as Seminoe Road Gas Development Project where 1,240 CBNG wells are proposed (BLM 2007b). The most substantive discussion of impacts from CBNG in the RMP/FEIS (p. 4-423 for Alternative 1) is as follows:
CBNG development would occur in the North Platte, Great Divide, and Colorado River Basins. Typical CBNG development requires the production of relatively high quantities of water (as compared to conventional gas or oil production). Anticipated volumes from potential CBNG projects are difficult to anticipate because most of the projects are at the pilot or exploratory stage and differences in regional and geographic targets exist. Water disposal needs and options for disposal are evaluated in the water quality, watershed, and soils section, including a discussion of impacts from water disposal options by alternative.
Although water production is one of the most contentious issues associated with CBNG, an analysis of production apparently was not done because anticipated volumes from potential CBNG projects are difficult to anticipate. NEPA regulations do not allow difficult to analyze issues to be ignored. Data for estimating volumes are available, including some in the RMP/FEIS (Appendix 20), and should have been used in the analysis. Appendix 20 of the RMP/FEIS (p. A20-16) provides rough estimates of water production for the Atlantic Rim CBNG project (250,000 to 450,000 barrels of water per day over a period of six to eight years) and for the Seminoe Road Gas Development project (180 barrels of water per day at peak production). The Seminoe Road Draft EIS (BLM 2007b) includes an estimated production from 1,240 potential wells of 101,000 acre-feet (approximately 783,590,000 barrels of water per day) over the 30 year life of the project. By using some of these estimates, along with the estimated number of CBNG wells to be drilled (4,411 based on the BLM RFD scenario for Alternative 4), a reasonable estimate of produced water
volume could be calculated. This information could then be used to assess how augmented flows and higher salt loads could impact disposal areas and options. The RMP/FEIS does an adequate job of describing the impact associated with disposal of CBNG water, although it is done in the Water Quality, Watershed, and Soils section (p. 4-426 and 4-427) while the other impacts are described in the Minerals Management section (p. 4-423). The RMP/FEIS fails to adequately discuss all the impacts from CBNG development including drawdown of ground water aquifers, potential contamination of shallow aquifers from produced water disposal, and contributions to greenhouse gases (methane). The RMP/FEIS also states that,
Water management plans for surface discharges would address reclamation strategies and would likely require monitoring to assess impacts.
Given the potential for significant adverse impacts even when mitigations are applied, why wouldnt a monitoring plan always be a requirement? At the Seminoe Road Coalbed Methane Pilot project (BLM 2007b) it was found that continuous discharge of water into ephemeral channels resulted in channel incision and lateral adjustment producing channel erosion substantially above undisturbed conditions. Monitoring should absolutely be required to detect adverse impacts in a timely manner, to track trends, and to fully understand the effects. Most of the area in the RFD2 was outside the area where oil and gas development was expected to occur so would not have been considered in the impacts analysis. Adverse impacts from increased soil erosion, sediment loading, surface spills of hazardous material, disposal of produced water, and impacts to ground water quality and quantity from drilling operations would be greater than disclosed in the RMP/FEIS. Surface water in the Encampment watersheds is classified as Class 1 or Class 2ab water where designated uses are protected for drinking water supplies, non-game fisheries, cold-water fisheries, fish consumption, aquatic life other than fish, primary contact recreation, wildlife, industry, agriculture, and scenic value (RMP/FEIS Appendix 11). The RFD2 did not consider CBNG development since it is very unlikely to occur in the study area. 4.8.3 Cumulative Effects
BLM identifies oil and gas development as having the highest likelihood for significant impacts in the RMPPA (p. 4-487). Other activities such as urbanization, recreation, and livestock grazing on federal, state and private lands would also contribute to impacts. The cumulative effects analysis suffers from the same lack of analysis discussed above for Environmental Consequences section. There is no clear discussion of past oil and gas development projects or the levels of disturbance that have occurred. The RMP/FEIS provides information on the number of wells drilled for past and pending projects (Table 4-6, p. 4-488) but carries the analysis no further. What are the
effects of the past projects, where did they occur, and what is the connection between past, present, and future oil and gas development projects? The RMP/FEIS states that the cumulative effects of past and present actions and activities on resources are manifested in the current condition of the resource. However, since baseline for water resources is not adequately defined, how was it even possible to evaluate cumulative impacts? In the event of energy development similar to any of the RFD2 scenarios, each additional well above the RMPPA planning levels would add to the cumulative effects on water quality and would require study to determine site specific impacts. 4.8.4 Mitigations
4.8.4.1 Mitigations Identified by BLM BLM outlines three mitigations and a series of BMPs to avoid or minimize the impact of energy development on water resources. We agree that these BMPs should be implemented, but as mandatory standards, not as discretionary suggestions. The BMPs identified in the RMP/FEIS are summarized below. Wyoming Bureau of Land Management Mitigation Guidelines for Surface Disturbing and Disruptive Activities (Appendix 1) Surface disturbance would be prohibited (except when waiver or modification approved in writing) under the following areas or conditions:
Slopes in excess of 25 percent Within 500 feet of surface water and/or riparian areas Construction with frozen material or during periods when the soil material is saturated or when watershed damage is likely to occur
Reducing Nonpoint Source Pollution with Best Management Practices (Appendix 13) BMPs for watershed protection:
Construction of ephemeral, intermittent, and perennial stream crossings associated with road and utility line construction generally would be restricted until after spring runoff and until normal flows are established. Adequate drainage control devices and measures would 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. The aim is to avoid concentrated flows. Erosion control devices would also be used with the surface runoff and drainage control devices, such as temporary barriers, ditch blocks, erosion stops, mattes, mulches, and vegetative covers. A revegetation program would be implemented as soon as possible to reestablish the soil protection afforded by a vegetal cover.
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Vegetative buffer strips should be maintained between developed recreational facilities and live water. Installation of instream structures for fishery, watershed, or irrigation enhancement should be engineered if the high flow for the stream exceeds 10 cubic ft/sec. 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 through surface stability, techniques to reduce wind erosion should be considered. These methods could include snow fences, soil tackifiers, and erosion control matting. When an old project such as an impoundment, reservoir, dam, spreader dyke system, headcut remediation structure, well, wetland, or range improvement project on public lands needs maintenance to restore its former function, the utility of its original function based on current management goals will be considered. Alternative methods to meet the function of the project, such as providing a well or guzzler as a water source would be considered before investment of public funds and if the project is still needed to meet management goals. Restoration cost and plans will also be evaluated during the decision process, as well as impacts to the human environment.
BMPs for floodplain protection:

For the most part, standard practices to protect water quality and floodplains are to avoid surface disturbing activity in identified 100-year floodplains, within 500 feet of perennial waters and wetland/riparian areas and 100 feet from the inner gorge of ephemeral channels. These 100- and 500-foot buffers often contain the 100-year floodplains. They provide an opportunity for concentrated flows to be dispersed before they reach other water. They often preclude construction in riparian zones, except for linear features. Surface disturbing activities and permanent facilities placement avoid these buffers unless it is determined through site-specific analysis that there is no practical alternative. If such a circumstance exists, then all practical measures to mitigate possible harm to the above areas are employed. These mitigating measures would be determined case by case. They may include, but are not limited to, armoring, diking, lining, screening, mulching, terracing, and diversions.
BMPs for soil resource protection: According to the RMP/FEIS, management of the soil resource would continue to be based on the following factors: (1) interpretation of soils in relation to project design and development; (2) identification and inventory of soils for baseline data (soil surveys); and (3) identification and implementation accelerated erosion of top soil. These factors are discussed below. Some examples of BMPs applied throughout the RMPPA based on soil management criteria are as follows:
Individual road closures due to saturated soil conditions when soil resource damage would occur due to wheel rutting or compaction of wet soils Salvage and subsequent replacement of topsoil whenever possible on surface disturbing activities Avoidance of disturbance on unstable slopes or slopes with angles greater than 25% Identification of critical erosion condition areas during site-specific project analysis, and activity plan development for the purpose of avoidance and special management
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Temporary disturbances that 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.
4.8.4.2 Recommended Additional Mitigations The following additional mitigations are recommended to protect water resources.
Table 4.8-2 Recommended Additional Mitigations for Water Resources Evaluate existing water quality data and collect additional samples as necessary MITIGATION MEASURE to establish baseline water quality conditions for surface and ground water resources Location Area wide Monitoring /Reporting Action Establish minimum baseline water quality data requirements needed to sufficiently characterize water quality conditions prior to energy development. Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring /Reporting Action Meets water sampling protocols established by Wyoming Department of Environmental Quality (WDEQ), results submitted to BLM and WDEQ BLM/Operator Prior to energy development Establish a ground water and surface water monitoring network around energy development areas Area wide Establish monitoring protocols that will allow understanding of basic hydraulic properties of water resources and that is sufficient for detecting potential adverse impacts or adverse trends to baseline water quality and quantity. Monitoring data BLM/WDEQ Duration of development and reclamation Oil and gas operators should remedy any damage to water sources caused by their operations Area wide Establish a protocol for replacing or remediating damage to surface or ground water sources when that resource no longer meets existing beneficial uses Damage rectified BLM/WDEQ/Operator As soon as practical but within six months of identifying damage to water sources
Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE Location Monitoring /Reporting Action Effectiveness Criteria Responsible Agency Timing
4.9
WILDLIFE
The lands covered in the RMP/FEIS have world class wildlife resources. Included are large populations of many different hunted and viewed species, rare, local endemic species, and excellent public access for hunting or wildlife viewing to both public and private lands (a commodity that is becoming increasingly
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rare across the West). These wildlife populations occur within an extraordinarily dramatic visual and cultural setting. 4.9.1 Affected Environment
While the unique value of the wildlife resource is characterized as amazing in the discussion of recreation values (RMP/FEIS p.3-55), nowhere are wildlife and its contribution to the local communities or national interests given sufficient attention. This lack of emphasis substantially compromises the wildlife resource in terms of ensuring adequate protection and mitigation. Five of the seven identified planning issues (issues of concern or unresolved conflicts) in the RMP/FEIS (p.1-8 to 1-11), are especially pertinent to wildlife resources:
Issue #1, Development of Energy Resources, adequately recognizes the impacts that energy development can have to wintering mule deer, wintering pronghorn, nesting greater sage-grouse, and other wildlife. Issue #2, Special Management Designations, adequately recognizes the potential for spatially allocating lands for individual species (including 109,650 acres for white-tailed prairie dogs) but fails to demonstrate in Chapter 3 why such protection is necessary. Issue #4, Wildland Urban Interface, adequately recognizes the ongoing loss of working ranches, associated losses in wildlife habitat, losses of public hunting access, and wildlife habitat fragmentation. Unfortunately, as the following discussion will demonstrate, there is no attempt in chapters 3 and 4 to acknowledge or resolve the issue, or disclose any effects from other RMP/FEIS actions on the viability of working ranches. Issue #5, Management of Special Status Species, adequately recognizes the risks facing local endemic species like Wyoming toads and Prebles jumping mice, and other more widespread species at risk like mountain plovers. Issue #7, Vegetation Management, covers an enormous range of individual issues including the impacts of fire suppression on crucial winter ranges, impacts of grazing on wildlife, and impacts of re-introducing prescribed burning on wildlife and wildlife habitats.
The wildlife issues could have been more clearly characterized to support more detailed analysis. Recommendations include:
Issue 2, Special Management Designations, assigns 109,650 acres for emphasizing white-tailed prairie dogs. While the discussion describes the role of prairie dogs as a keystone species important to other potentially at-risk species such as burrowing owls, the RMP/FEIS provides no information on the degree of risk facing the species, population levels at local, state-wide, or range-wide scales, or the degree of relative habitat connectivity or isolation with the species range. Without this information, there is no way of determining whether or not the allocation of 109,650 acres would contribute to the species viability, avoid potential federal listing under the ESA, or be worth the tradeoffs to other resources. Issue 4, Wildland Urban Interface, adequately sets the stage to address the impacts of losses in working ranches on wildlife. As worded, we find the issue sufficient. Oddly, the wildlife discussion in Chapter 3 fails to recognize the value of working ranches to wildlife, ignores the risks facing working ranches, and
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basically ignores the entire issue. We find this disconnect concerning, especially since it has been identified as a major risk facing wildlife by WGFD (2005, Schultz pers. comm.) and Carbon County (Pederson Planning Consultants 1998). We suggest that the wildlife analysis in Chapters 3 and 4 be reevaluated to address these extremely important relationships. Issue #7, Vegetation Management, is very complex and does not adequately address in sufficient detail all the elements of vegetation management affecting wildlife. We suggest that the wildlife analysis in Chapters 3 and 4 be reorganized to address (1) natural disturbances affecting wildlife habitats such as wildfires; (2) disturbances from keystone species such as bison or prairie dogs; (3) interruptions in those disturbances such as fire suppression or bison extirpation; (4) changes in wildlife habitats and/or loss of niches as a result of the loss of those natural disturbances; and (5) opportunities to mimic those disturbances to restore critical habitats and niches.
The description of affected environment also fails to succinctly yet adequately describe existing conditions. Primary insufficiencies include the descriptions related to wildlife/grazing/private land interactions, the potential ESA listing of the greater sage-grouse, vegetation coverage for winter range, energy development impacts to greater sage-grouse, and issues related to other species of concern. These are described in detail below. In regard to the impacts on wildlife from domestic livestock grazing, first, the impacts from grazing are explained in Chapter 4 (p.4-454) as a simple (presumably negative) competition issue (the more cows, the fewer wild ungulates). This conclusion grossly oversimplifies the issue for several reasons. The most serious omission in the discussion of grazing impacts is that the RMP/FEIS never discusses the role that private ranches play in providing habitat for wildlife. For instance, by overlaying BLM data for ownership and wildlife seasonal ranges, we conclude that in almost all instances a majority of crucial winter range occurs on private working ranches. As an example, Table 4.9-1 illustrates the percentages of mule deer and pronghorn winter range occurring on private ranches. The wildlife assessment in the RMP/FEIS not only ignores this contribution from private lands, but also ignores the need of private landowners to maintain an economically viable operation including the need to graze on both private and public lands. This relationship between public and private lands should be an integral part of the wildlife analysis. Furthermore, the wildlife/grazing issue ignores current rangeland condition, trend, and utilization levels. While these are discussed in a non-quantified manner in the Range section (RMP/FEIS p. 3-30 to 3-33), there is no cross-reference between the Wildlife and Range sections and no data to justify that competition is a significant issue.
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Table 4.9-1 Amount of Pronghorn Antelope and Mule Deer Crucial Winter/Year-Long Range and Winter/Year-Long Ranges Mule Deer Range Type Ownership Total Acres % of Total Crucial Winter/Year-Long BLM 29,978 27% USFS 670 1% Private 72,386 66% State 6,250 6% Crucial Winter/Year-Long Total 109,285 100% Winter/Year-Long BLM 91,843 30% USFS 53,053 17% Private 147,392 48% State 14,266 5% Winter/Year-Long Total 306,553 100% Antelope Range Type Ownership Total Acres % of Total Crucial Winter/Year-Long L BLM 3,297 32% Private 6,087 58% State 1,076 10% Crucial Winter/Year-Long Total 10,460 100% Winter/Year-Long BLM 64,057 39% Private 94,227 57% State 7,969 5% Winter/Year-Long Total 166,253 100%
The wildlife discussion ignores the risks facing local ranches in terms of long-term sustainability. Subdivision of ranches into small residential lots and the sale of ranches to outside corporations for leased hunting is dramatically impacting the ability of those former working ranches to support wildlife and/or provide recreational hunting opportunities for local individuals (Schultz pers. comm.). While this problem is discussed in the Socioeconomics chapter, this issue is largely ignored in the wildlife Affected Environment section. Lastly, concerning wildlife and grazing, the wildlife discussion ignored the fact that wild ungulates, greater sage-grouse, and native shrubs and grasses co-evolved with large numbers of bison, a species that is now missing from the area. Native ungulates and greater sage-grouse are well-adapted to large grazing animals. While cattle and sheep do not necessarily mimic bison in terms of grazing intensity and seasonal timing, grazing systems can be designed to create some of the same habitats and niches created by bison. This relationship needs to be identified along with the body of research that has been done on this topic. The wildlife affected environment discussion recognizes the socioeconomic importance of greater sagegrouse. The RMP/FEIS also recognizes and discloses the impacts of energy development on greater sageDecember 2008 99 ECOSYSTEM RESEARCH GROUP
grouse based on some, but not all, of the latest research. What is lacking in this discussion is an acknowledgment of the potential for sage-grouse to be listed under the Endangered Species Act and the socioeconomic impacts this listing would have on local communities, especially working ranches. The discussion also fails to address the degree to which this project is cumulatively affected by other energy developments across the state and across the West. The discussion needs to reflect these complex elements. The RMP/FEIS suggests there is a need to reduce juniper coverage to enhance winter range habitat for deer and pronghorn. The document also suggests that the percent cover of sagebrush may be excessive for greater sage-grouse. While these conclusions may be true, there is no attempt to identify the cause of these problems, i.e., an interruption in natural disturbance regimes. Assuming that fire suppression is the cause of excessive juniper or sagebrush coverage, then the issue needs to be rewritten to state that interruption of the natural disturbance regime is the problem, to what magnitude it is a problem based on vegetative data, and why that equates to a problem for wintering ungulates or nesting greater sage-grouse. The discussion should have been cross-referenced to the findings in the Fire discussion (p. 3-18 to 3-20). As an example of what could have been done in the RMP/FEIS to determine whether juniper or sagebrush encroachment was a significant problem, we overlaid cover type and FRCC (LANDFIRE 2006). FRCC is a discrete metric that quantifies the amount the current vegetation has departed from the simulated historical vegetation reference conditions (Hann and Bunnell 2001; Hardy et al. 2001; Hann et al. 2004; Holsinger et al. 2006). The three condition classes describe low departure (FRCC 1), moderate departure (FRCC 2), and high departure (FRCC 3). This departure is calculated based on changes to species composition, structural stage, and canopy closure. Forty-eight per cent of the sagebrush cover types and 77% of the juniper types have conditions of moderate and high departure (FRCC 2 and 3) from reference condition vegetation, fuels, and disturbance regimes (Hann et al. 2004). Table 4.9-2 shows areas within the RMPPA where elevated FRCC classes suggest greater coverage of juniper or sagebrush than historic levels.
Table 4.9-2 Fire Regime Condition Class (FRCC) by Cover Type Cover Type FRCC Acres 1 Sagebrush 2 3 Sagebrush Total 1 Juniper Woodland 2 3 Juniper Woodland Total
% 83,435 67,652 8,844 159,931 1,749 5,546 146 7,441 52.2% 42.3% 5.5% 100.0% 23.5% 74.5% 2.0% 100.0%
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Problems facing mountain plovers are discussed in detail. Unfortunately, the discussion does not explain the relationship between bison, prairie dogs, and mountain plovers, and how the loss of bison and the reduction in prairie dog densities has affected mountain plover habitat.. The impacts of energy development on wildlife are given a reasonable discussion. The discussion on recent, locally-conducted research on mule deer (Sawyer et al. 2005) and greater sage-grouse (Holloran 2005, Naugle et al. 2006) is well done. While the RMP/FEIS discussion on greater sage-grouse research findings is generally sufficient, it ignores the latest findings from WGFD (2008a) showing a loss of greater sage-grouse population persistence within 4.0 miles of active drilling (Figure 4.9-1). The RMP/FEIS assumes no loss in persistence beyond 2.0 miles. We understand that greater sage-grouse impacts from drilling depend on several factors, and that the science, like most wildlife research, is not completely understood. Nonetheless, the RMP/FEIS cannot ignore science-based, locally-collected research. The BLM NEPA Handbook requires the BLM [to] Use the best available science to support NEPA analyses, and give greater consideration to peer-reviewed science and methodology over that which is not peerreviewed (from 40 CFR 1502.1 definition of hard look). Therefore, the RMP/FEIS needs to disclose greater sage-grouse effects based on the 4.0 mile persistence curve and utilize this relationship in the quantitative calculation and disclosure of effects. Much of the research cited in the RMP/FEIS provides excellent opportunities to quantitatively model the impacts of energy development on wintering mule deer, pronghorn, and greater sage-grouse under the different alternatives. Unfortunately, as discussed under environmental consequences, the RMP/FEIS provides no quantifiable effects and relies instead on a barely qualified approach that concludes this alternative is better than that with no attempt to identify how much better, while ignoring all the detailed research disclosed in the Affected Environment section of the RMP/FEIS.
Figure 4.9-1 Estimated probability of lek persistence in fully developed coal-bed natural gas fields, assuming that only development within 4.0 miles of lek affects persistence (NSO = no surface occupancy, dashed lines represent 95% confidence intervals; WGFD 2008a)
The RMP/FEIS identifies the economic and social importance of bighorn sheep. Since there is no discussion of domestic sheep disease-prevalence in local or larger-scale bighorn sheep populations, it is assumed that disease or conflict with domestic sheep
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grazing is not an issue within the RMPPA. Some words to this effect would have been useful. Lastly, the RMP/FEIS includes a thorough discussion of rare, local endemic species such as the Wyoming toad and Prebles jumping mouse including life histories, why they are at risk, and measures needed for their recovery. 4.9.2 Environmental Consequences
The BLM analysis of environmental consequences for identified significant issues is inadequate for the following issues:
Issue #1, Development of Energy Resources: fails to quantifiably model impacts of energy development on wildlife resources Issue #2, Special Management Designations: fails to demonstrate why protection of lands for species-atrisk is necessary Issue #4, Wildland Urban Interface: fails to provide analysis on how the loss of working ranches would impact wildlife, how those losses might be exacerbated by energy development, and what mitigation measures might reduce those impacts.
Below, we provide an example of quantifiable, replicatable modeling of energy development impacts on wildlife resources as a recommended approach to addressing the inadequacies listed above.
BLM direction is clear regarding the need for science-based, quantitative analyses using replicateable, analytical methods. Both CEQ and the BLM NEPA Handbook require that the effects analysis must rely on a reasoned analysis containing quantitative or detailed qualitative information sufficient to support comparison between alternatives. The BLM NEPA Handbook further requires the use [of] the best available science to support NEPA analyses, and give greater consideration to peerreviewed science and methodology over that which is not peer-reviewed. Describe the methodology and analytical assumptions for the effects analysis. The definition of methodology is explained in the BLM NEPA Handbook as Your NEPA document must describe the analytical methodology sufficiently so that the reader can understand how the analysis was conducted and why the particular methodology was used (40 CFR 1502.24).
In general, there was no attempt in Chapter 4 of the RMP/FEIS to quantitatively identify the impacts on wintering mule deer, wintering pronghorn, or nesting greater sage-grouse. As a result, the RMP/FEIS does not meet NEPA disclosure requirements for effects analysis. In addition to failure to identify quantifiable effects, there is a failure to identify or develop any methodologies that would identify quantified effects upon wildlife based upon recent, locally-conducted, well-quantified research results. The sections below demonstrate a relatively simple, quantifiable, methodological approach by conducting
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an effects analysis of RFD2 scenario impacts on sage-grouse leks and wintering mule deer within the SERCD study area. The BLM preferred alternative (Alternative 4) for the Rawlins RMP includes seasonal stipulations that avoid disturbance-related impacts from energy development to protect both greater sage-grouse leks and mule deer winter range. This is an efficient means to avoid impacts. However, the preference for Alternative 4 does not release the BLM from its obligation to provide quantitative modeling for potential impacts to allow comparison between alternatives. With no stated estimate of how severe the direct or indirect impacts of drilling might be, the public has no basis for making an informed response to the RMP/FEIS or the selection of a preferred alternative. Without an estimate of effects, there is no way to determine how much (if any) off-site mitigation or additional compensation might be needed and where that off-site mitigation/compensation should occur. Here, we provide an example of the type of modeling that should have been conducted for alternatives that did not include seasonal restrictions on drilling activity, such as Alternative 2 in the RMP/FEIS. Such an analysis provides a baseline from which to assess and compare alternatives. 4.9.2.1 An example model of effects from energy development on greater sage-grouse Holloran (2005), Naugle et al. (2006), and Walker et al. (2007) investigated how sage-grouse respond to gas field and coal bed methane development. These three papers dealt with a set of complex, multiple variables, including male lek attendance, nesting success, female survival, chick recruitment, and overall population vigor. Given that segregating multiple variables in any research effort is difficult, Hollorans, Naugles, and Walkers findings are more susceptible to criticism. However, both Holloran and Naugle demonstrated fairly conclusively that sage-grouse populations are highly likely to decline from extensive energy field development where widespread surface occupancy exists. Furthermore, the adverse impacts extend far beyond the 0.25 miles from leks zone that are identified as No Surface Occupancy zones in the RMP/FEIS Chapter 2 (p. 2-110 to 2-111). A recent compendium of sage-grouse findings (WGFD 2008a) plots sage-grouse lek persistence as a logistic curve depending on the distance from the drilling area. A worst-case scenario (i.e., impacts on sage-grouse lek persistence extend for four miles from active drilling; Figure 4.9-1) and best-case scenario (i.e., impacts on sage-grouse lek persistence extend for only two mile; Figure 4.9-2) were presented in the paper. By comparing both response curves with probable drilling locations, a range of outcomes for sage-grouse lek persistence can be estimated. By overlaying maps of probable drilling patterns with sage-grouse leks, the WGFD (2008a) research-derived coefficients can be used to mathematically calculate indirect effects scenarios via a GIS application. Overlaying the greater sage-grouse lek locations on potential drilling activity allows one to visualize the impact on sage-grouse lek persistence as illustrated in the following figures. This GIS model was applied to Alternative 2 (energy emphasis, no seasonal constraints to protect nesting sage-grouse). The lek
locations were overlaid on the moderate intensity drilling scenario from RFD2. Modeling assumptions included (1) within any given 12 month period, five drilling rigs would be available for exploration/development; and (2) the rigs would be concentrated within a given area to minimize movein/move-out costs. The five concentrated rig locations were arbitrarily located within one of the lease proposal areas that contained both ungulate winter range and sage-grouse leks. We found that, based on the moderate RFD2 scenario and under Alternative 2 stipulations, lek persistence would be reduced by 6065% (Map 4.9-1).
Figure 4.9-2 Estimated probability of lek persistence in fully developed coal-bed natural gas fields, assuming that only development within 2.0 miles of lek affects persistence (NSO = no surface occupancy; dashed lines represent 95% confidence intervals; WGFD 2008a)
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Natural Gas Development Impacts to Sage Grouse

Legend Occupied Sage Grouse Lek Watershed Study Project Area with 1/4 mile buffer Townships Potential Wells from Scenarios Roads Potential Wells in Development Rivers Land and Mineral Ownership Bureau of Land Management (BLM) Private Lands with Federal Minerals Private State Lands National Forests
Saratoga
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T17R85
T17R84
130
T17R83
T17R82
T17R81
T17R80

T16R85 T16R84 T16R83
130
T16R82 T16R81 T16R80
T15R85
T15R84
T15R83
T15R82
T15R81
T15R80
Encampment
T14R85
70
T14R84
T14R83
T14R82
T14R81
T14R80
230
T13R85
T13R84
T13R83
T13R82
T13R81
T13R80
Sage Grouse Impact Analysis

Distance From Well Pad Zone A 2 Zone B 3 Zone C T12R85 D4 Zone 5 Area of No Impact
1
Number of Leks in Zone 4 1 1 0 13
Probability of Persistence 6 0% - 10% 10% - 28% 28% - 62% 62% - 85% 85%
Number of Leks Persisting 0 - 0.40 0.10 - 0.28 0.28 - 0.62 0-0 5.95T12R83
Overall Persistence NA NA NA NA NA
23 of 30
T12R84
Well Pad
T12R82
T12R81
Total 19 NA 10.73 - 15.47 60% - 65% 1 2 3 4 5 6 0 - 1.0 Mile 1.0 - 2.0 Mile 2.0 - 3.0 Mile 3.0 - 4.0 Mile >4.0 Mile From Wyoming Game and Fish Department 2008 *Data from Wyoming GIS Center (WyGISC), Wyoming Oil and Gas Conservation Commission, BLM, and ESRI. Map last updated October 23, 2008.
T12R80
125
Map 4.9-1 Greater Sage-Grouse Impact Analysis
4.9.2.2 An example model of effects from energy development on wintering mule deer The BLM should have developed a model for mule deer winter range based on the research discussed in the RMP/FEIS of Sawyer et al. (2005). This study was specifically designed to identify impacts from gas field development in the Sublette deer herd and included control (pre-disturbance) data on deer distribution across a crucial winter range. In general, Sawyer et al. concluded that after three years of field exploration (drilling), deer were substantially displaced from preferred wintering habitat. The deer population on the mesa declined from more than 5,000 animals in 2002 to fewer than 3,000 animals in 2004 and 2005. By the third year of development, only 37% of initial mule deer high use areas were classified as high use (Sawyer et al. 2005). For three straight years, there was a positive linear relationship between the distance from a disturbance and deer number ( i.e., the nearer the disturbance, the fewer deer that used the area). The distances from which the deer were displaced were substantial. Averaging the data for three years suggests that (1) deer use was only 0 to 25% of pre-disturbance levels within 0.37 miles of drilling activity; (2) deer use was only 26 to 50% of pre-disturbance levels within 1.04 miles of drilling activity; (3) deer use was only 51 to 75% of pre-disturbance levels within 1.56 miles of drilling activity; and (4) deer use was 76 to 100% of pre-disturbance levels within 1.88 miles of drilling activity. No displacement was noted beyond 2.30 miles of disturbance. Sawyers radioed mule deer constituted a relatively large sample size (Sawyer pers. comm.); radioed animals were distributed widely across the winter range and imbedded within the overall wintering population (Sawyer pers. comm.), further suggesting the sample size was adequate. The results in year four of Sawyers research were very different. Wintering conditions during year four were quite severe, causing deer to use areas closer to disturbance than expected based on previous years. Year four data were ignored in the above calculations on the assumption that extremes (i.e., severe wintering conditions) should be regarded with caution. The most likely explanation for this behavior was that deer were more desperate to find food and would rather avoid starvation than avoid human disturbance (Sawyer pers. comm.). This should not be interpreted that deer neither exhibited habituation to drilling disturbance nor failed to suffer some level of stress from adjacent drilling activity (Sawyer pers. comm.). By overlying GIS layers of probable drilling patterns with mule deer winter range, Sawyers researchderived coefficients can be used to calculate indirect effects scenarios via a GIS application. This model was applied to Alternative 2 (energy emphasis, no seasonal constraints to protect wintering ungulates) and the moderate intensity RFD2 drilling scenario. Modeling assumptions included (1) within any given year five drilling rigs would be available for exploration/development; and (2) the rigs would be concentrated within a given area to minimize move-in/move-out costs. We found that at the study area scale, under Alternative 2 and moderate drilling intensity, mule deer winter range would be reduced by approximately 3% (Map 4.9-2).
Natural Gas Development Impacts to Mule Deer

Legend Mule Deer Winter Range Watershed Study Project Area Potential Wells from Scenarios Townships Potential Wells in Development Roads Rivers Land and Mineral Ownership Bureau of Land Management (BLM) Private Lands with Federal Minerals Private State Lands National Forests
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T17R85
T17R84
130
T17R83
T17R82
T17R81
T17R80

T16R85 T16R84 T16R83
130
T16R82 T16R81 T16R80
T15R85
T15R84
T15R83
T15R82
T15R81
T15R80
Encampment
T14R85
70
T14R84
T14R83
T14R82
T14R81
T14R80
230
T13R85
T13R84
T13R83
T13R82
T13R81
T13R80
Wintering Mule Deer Analysis

Distance From Well Pad Zone A 2 Zone B 3 Zone C 4 Zone D 5 Area T12R85 of No Impact Total
1 2 3 1
Acres in Big Game Crucial Winter Range 1,373 7,587 6,348 4,258 397,293 416,859
4
Deer Use as Percent of Predisturbance Levels6 0% - 25% 26% - 50% 51% - 75% 76% - 100% 100% NA
5 6
Acres of Functioning Percent Functioning Mule Deer Winter Range Mule Deer Winter Range 0 - 343 1,973 - 3,794 3,237 - 4,761 3,236 - 4,258 397,293 405,739 - 410,449 0% - 0.1% 0.5% - 0.9% 0.8% - 1.1% 0.8% - 1.0% 95.3%
Well Pad
T12R84
T12R83
97.3% - 98.5%
T12R82
T12R81
T12R80
0 - 0.37 Mile 0.38 - 1.04 Mile 1.05 - 1.56 Mile 1.57 - 1.88 Mile >1.88 Mile From Sawyer et al. 2005 *Data from Wyoming GIS Center (WyGISC), Wyoming Oil and Gas Conservation Commission, BLM, and ESRI. Map last updated October 23, 2008.
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Map 4.9-2 Wintering Mule Deer Impact Analysis
This modeled potential loss in access to winter range is presumably insignificant to wintering mule deer populations considering other factors such as winter severity or forage productivity. While these effects are insignificant, the EIS should have still quantitatively modeled and disclosed comparable effects as stated in the BLM NEPA Handbook: the effects analysis must rely on a reasoned analysis containing quantitative or detailed qualitative information sufficient to support comparison between alternatives. 4.9.3 Cumulative Effects
Four of the seven identified issues in the RMP/FEIS have significant cumulative effects when evaluated at coarser scales:
Issue #1, Development of Energy Resources: fails to provide broad-extent analysis to determine the extent to which the states wildlife resources are adversely impacted by energy development Issue #2, Special Management Designations: fails to demonstrate why habitat protection for white tailed prairie dogs is necessary primarily because other cumulative impacts across their range, including population densities, levels of disease (plague), degree of genetic isolation, trends, and levels of pesticide and other control actions, are ignored Issue #4, Wildland Urban Interface: no cumulative evaluation of loss of working ranches, associated losses in wildlife habitat, losses of public hunting access, and wildlife habitat fragmentation Issue #7, Vegetation management: No cumulative effects analysis was done to address vegetative trends at larger scales or equate those trends into risks for given species.
The RMP/FEIS does an adequate job of describing cumulative activities on multiple ownerships (RMP/FEIS Appendix 33, pp. A33-1 to A33-16). Unfortunately, the cumulative impacts on wildlife are disclosed in a purely qualitative manner with no attempt to quantify impacts from disturbances at coarser scales. For instance, the RMP/FEIS concludes
The majority of cumulative impacts on wildlife habitat within all the CIAAs [cumulative impact analysis area] would result from surface disturbing and disruptive activities, such as mineral development and associated wells, roads, pipelines, and facilities, livestock grazing, range improvements, and others (e.g., geophysical exploration) on private, state, and other federal lands within the RMPPA. Effects would result in habitat fragmentation and animal displacement (shortterm or long-term), depending on the amount, location, and timing of activities. All effects would depend on the amount and timing of activities and whether the amount of activity within each CIAA outpaces the success of reclamation and revegetation efforts in disturbed areas.
The previous disclosure is inadequate. It suggests that the BLM has no control over the timing of activities and whether (or not) the amount of activity outpaces the success of reclamation and therefore is unable to identify cumulative effects of its activities on wildlife. In fact, the purpose of the RMP/FEIS is to identify exactly what measures are needed to meet planning objectives. For instance, if sustaining viable populations of sage-grouse to avoid federal listing is a valid planning objective, then the
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mitigation measures need to be designed to precisely identify what timing restrictions are needed, and assure that the pace of development is subservient to the pace of successful reclamation and revegetation. Additionally, the cumulative effects disclosure quoted previously is inadequate in that it does not address impacts at larger scales or at the appropriate geographic scope. For instance, under Geographic Scope, the BLM NEPA Handbook, 6.8.3.2 states,
We recommend that you establish and describe the geographic scope for each cumulative effects issue, which will help bound the description of the affected environment (see section 6.7.1, Affected Environment). Describe in your EA or EIS the rationale for the geographic scope established. The geographic scope is generally based on the natural boundaries of the resource affected, rather than jurisdictional boundaries. The geographic scope will often be different for each cumulative effects issue. The geographic scope of cumulative effects will often extend beyond the scope of the direct effects.
The BLM NEPA Handbook further states,

Non-federal actions which potentially have a cumulatively significant impact together with the proposed action must be considered in the same NEPA document (40 CFR 1508.25). Identifying an action as a cumulative non-federal action is a component of your cumulative effects analysis of the proposed action (see section 6.8.3, Cumulative Effects).
If just greater sage-grouse are considered, ongoing research (Holloran 2005; Naugle et al. 2006) has shown that greater sage-grouse populations have consistently declined in areas with extensive energy development. Therefore, two questions that should have been addressed include (1) how much of the state is impacted by major energy development?; and (2) to what degree do sage-grouse core populations overlap with energy development? Without addressing these two questions, it is not possible to conclude that limiting the geographic scope to the RMP/FEIS project area adequately addressed cumulative effects on sage-grouse. Energy development in the RMP/FEIS project area will likely be cumulatively significant at larger (core population area or statewide) scales in terms of sage-grouse viability. As a means of addressing this cumulative impact at an appropriate geographic scope, We overlaid existing oil/gas wells with greater sage-grouse core populations (WGFD 2008b) at two scales: (1) South Central Sage-grouse Working Group scale (SCSGWG 2007); and (2) statewide (Map 4.9-3).
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Wyoming Energy Development Sage Grouse Core Areas

Legend Watershed Study Project Area Counties Roads Sage Grouse Core Areas Sage Grouse Working Groups Oil and Gas Percent of South Percent of Sage Wells per Section Grouse Core Areas Central Sage Grouse www.ecosystemrg.com (640 acres) Working Group Statewide None 94.6% 86.0% Low (1-3) 4.0% 9.3% Moderate (4-16) 1.2% 4.6% High (> 16) 0.2% 0.1%
NAD 83 UTM Zone 13N Scale 1:1,500,000 0 4.5 9 18 Miles
Bighorn Basin
Casper
Jackson Hole
Northeast
Northeast
N ii o b r a r a N obrara
Wind River/Sweetwater River Basin
F r e m o n tt Fremon
Wind River/Sweetwater River Basin
N a tt r o n a Na rona
C o n v e rGreen River Basin C o n Upper r s e ve se
Bates Hole/Shirley Basin
Southwest
South Central South Central
Bates Hole/Shirley Basin
P ll a tt tt e P a e
Goshen Goshen
25
Rawlins
90
Wamsutter
S w e e tt w a tt e r Swee wa er
Carbon Carbon
South Central
A ll b a n y A bany
Southwest
Saratoga
Laramie Encampment
L a r a m ii e Laram e
Cheyenne
Map 4.9-3 Statewide Energy Development and Sage Grouse Core Areas
Note that at the statewide scale, 5.4% of core sage-grouse populations have a wellhead density of greater than one wellhead/section. Note too, that at the South Central Sage-Grouse Working Group (SCSGWG 2007) scale, 14% of the working group area has a wellhead density of greater than one wellhead/section. This provides a basis for addressing other cumulative effects questions. For instance, is energy development at the statewide level likely to significantly impact sage-grouse recovery? Or, are the mitigation measures in the alternatives consistent with recovery? While our analysis is meant to provide only an example of the kind of quantification that should have been done in the RMP/FEIS, it does suggest that energy development is likely to have cumulative impacts of greater significance than what the RMP/FEIS suggests. Furthermore, it suggests that since energy development is proposed within a sage-grouse population core area (where the objective is to sustain high densities of sage-grouse), the mitigation proposed in Alternative 4 may be insufficient. This type of analysis could also have been applied to the degree of overlap between energy development and ungulate crucial winter ranges. Again, no such analysis was done. 4.9.4 Mitigations
4.9.4.1 Mitigations Identified by BLM Several mitigations and discretionary BMPs and management guidelines are provided in the RMP/FEIS as follows. Wyoming Bureau of Land Management Mitigation Guidelines for Surface Disturbing and Disruptive Activities (Appendix 1)
To protect important big game winter habitat, activities or surface use will not be allowed from November 15 to April 30 within certain areas encompassed by the authorization. The same criteria apply to defined big game birthing areas from May 1 to June 30. To protect important raptor and/or sage and sharp-tailed grouse nesting habitat, activities or surface use will not be allowed from February 1 to July 31 within certain areas encompassed by the authorization. The same criteria apply to defined raptor and game bird winter concentration areas from November 15 to April 30.
Best Management Practices for Reducing Surface Disturbance and Disruptive Activities (Appendix 15)
The following BMPs would be considered to reduce impacts to big game crucial winter range:
Directional drilling Drilling of multiple wells from a single pad Remote well monitoring Piping of produced liquids to centralized tank batteries offsite to reduce traffic to individual wells Transportation planning (to reduce road density and traffic volumes) Cluster development
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Compensation mitigation Seasonal restriction of public vehicular access Monitoring of wildlife populations during drilling operations and design and employment of additional best management practices whenever monitoring identifies undesirable impacts.
The following BMPs would be considered to reduce impacts to sage-grouse habitat:

Directional drilling Drilling of multiple wells from a single pad Seasonal restriction of public vehicular access Noise-reduction techniques and designs Using low-profile well facilities and tanks Burying of power lines to avoid use of poles and other tall structures Transportation planning to align roads out of sight and sound of leks and to schedule traffic to avoid sagegrouse activity periods Designing roads to minimum safe standard for intended use and partial reclamation of high-standard roads needed for project construction to lower standards necessary for maintenance operations Monitoring of wildlife populations during drilling operations and design, and employing additional best management practices whenever monitoring identifies undesirable impacts Prohibiting surface disturbance or occupancy within mile of the perimeter of occupied sage-grouse leks Avoidance of human activity between 6:00 p.m. and 9:00 a.m. from March 1 through May 20 within mile of the perimeter of occupied sage-grouse leks. These times and dates reflect recommendations from Wyoming Game and Fish Department (WGFD) based on site-specific data for the RMPPA Avoidance of surface disturbance or other disruptive activity from March 1 through July 15 up to two miles from an active lek in suitable greater sage-grouse nesting habitat. These dates reflect recommendations from WGFD based on site-specific data for the RMPPA.
The following BMPs would be considered to reduce impacts to wildlife habitat:

Seasonal restriction of public vehicular access Noise reduction techniques and designs Installation of raptor anti-perch devices Monitoring of wildlife populations during drilling operations and design, and employment of additional best management practices whenever monitoring identifies undesirable impacts Implementation of the Wyoming Bird Conservation Plan from Wyoming Partners In Flight.
Mountain Plover Management Guidelines: Occupied Habitat Protection Measures (Appendix 16)
The following guidelines would be considered to reduce impacts to mountain plovers:
To protect the identified mountain plover-occupied habitat, the proposed activity will not be allowed as proposed. An alternative, such as moving the facility, directional drilling, piping and storing condensate off the identified mountain plover-occupied habitat to a centralized facility, or other techniques that minimize ground disturbance and habitat degradation, will be required. To protect the identified mountain plover-occupied habitat, the proposed facility will be moved mile from the identified occupied habitat. The access road will be realigned to avoid the identified mountain plover-occupied habitat.
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Within one-half mile of the identified mountain plover-occupied habitat, speed limits will be posted at 25 miles per hour (mph) on resources roads and 35 mph on local roads during the brood-rearing period (June 1July 10). To protect the identified mountain plover-occupied habitat, power lines will be buried or poles will include a perch-inhibitor in their design. This will be required within one-half mile of the identified mountain plover-occupied habitat. To protect the identified mountain plover-occupied habitat, fences, storage tanks, and other elevated structures will be constructed as low as possible and/or will incorporate perch inhibitors into their design. Road-killed animals will be promptly removed from areas within one-half mile of the identified mountain plover-occupied habitat. To protect the identified mountain plover-occupied habitat, seed mixes and application rates for reclamation will be designed to produce stands of sparse, low-growing vegetation suitable for plover nesting. To minimize destruction of nests and disturbance to breeding mountain plovers, no reclamation activities or other ground-disturbing activities will occur from April 10July 10, unless surveys consistent with the Plover Guidelines or other methods approved by the U.S. Fish and Wildlife Service find that no plovers are nesting in the area. A plugged and abandoned well within one-half mile of the identified mountain plover-occupied habitat will have the casing cut off at the base of the cellar or three feet below the final restored ground level (whichever is deeper). The well bore shall then be covered with a metal plate at least -inch thick and welded in place. To protect the identified mountain plover-occupied habitat, and because mountain plover adults and broods may forage along roads during the night, traffic speed and traffic volume will be limited during nighttime hours from April 10July 10. To protect the identified mountain plover-occupied habitat, work schedules and shift changes will be modified from June 1July 10 to avoid the periods of activity from hour before sunrise to 10:00 a.m. and from 5:00 p.m. to one-half hour after sunset. To protect the identified mountain plover-occupied habitat, traffic will be minimized from June 1July 10 by carpooling and organizing work activities to minimize trips on roads within mile of the mountain plover-occupied habitat area.
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4.9.4.2 Recommended Additional Mitigations The following additional mitigations are recommended to protect wildlife resources.
Table 4.9-3 Recommended Additional Mitigations for Wildlife Apply seasonal operating constraints (March 1 to July 15) to all exploratory MITIGATION MEASURE drilling activity within 4.0 miles of greater sage-grouse leks. Location Monitoring / Reporting Action Within 0 to 4 miles of inventoried greater sage-grouse leks Establish no-activity zones during the greater sage-grouse breeding and nesting period within areas of concentrated nesting. Continue monitoring to assure compliance with designed mitigation. Monitoring data BLM March 1 to July 15 Holders of energy leases will meet no less than quarterly with BLM grazing permittees where grazing/energy leases overlap. Energy leasees will outline drilling/development plans. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Establish a mandatory coordination protocol so that ranchers are appraised of energy exploration activities Monitoring data BLM Quarterly when exploration is foreseeable Holders of energy leases will meet no less than quarterly with BLM grazing permittees where grazing/energy leases overlap. Energy leasees will identify fencing needed around wellhead/roads to avoid livestock mortality Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Establish a mandatory coordination protocol so that fencing needed to avoid livestock mortality around wellheads and access roads is identified Monitoring data BLM Quarterly when exploration is foreseeable
Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE
Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE
Location Monitoring / Reporting Action Effectiveness Criteria Responsible Agency Timing
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MITIGATION MEASURE
Holders of energy leases will meet no less than quarterly with BLM grazing permittees where grazing/energy leases overlap. Energy leasees will construct those fences to BLM standards prior to the grazing season. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Establish a mandatory coordination protocol so that fencing needed to avoid livestock mortality around wellheads and access roads is constructed in a timely manner to appropriate BLM standards Monitoring data BLM Quarterly when exploration is foreseeable Holders of energy leases will meet no less than quarterly with BLM grazing permittees where grazing/energy leases overlap. Energy leasees will purchase equivalent off-site foraging areas and/or hay when foraging areas are excluded due to drilling/development, and make that forage/hay available to the grazing permittees during the equivalent grazing season, and within a location that is economically viable to the permittees. Within all areas where energy exploration overlaps with domestic livestock grazing (BLM grazing leases and private, working ranches) Establish a mandatory coordination protocol so that forage lost due to areas excluded by fencing around wellheads and access roads, is compensated for by direct purchase by the energy leasee of off-site grazing areas or hay Monitoring data BLM Quarterly when exploration is foreseeable and fencing needs have been identified
Location Monitoring / Reporting Action
Effectiveness Criteria Responsible Agency Timing MITIGATION MEASURE
Location Monitoring / Reporting Action
Effectiveness Criteria Responsible Agency Timing
4.10
CLIMATE CHANGE
Climate change impacts are an emerging national issue and several recent court rulings require proper analysis within NEPA documents. The BLM has not yet provided national direction on how to incorporate climate change into NEPA documents. Regardless, agencies have lost cases for not including climate change in their NEPA documents. There is no discussion of climate change in the RMP/FEIS as it relates to the affected environment or environmental consequences. Increasingly, the dynamics between vegetation, land management, and climate change are being recognized and documented (IPCC 2007). Although uncertainty exists in quantifying the impact of greenhouse gas emissions on climate, a global warming of 1.4 to 5.8 degrees centigrade is projected by 2100 (USDA 2007). As climate change advances, there are indications that there will be increases in disturbances such as wildfires, drought, and insects, especially in the western United States (Running 2006; USDA 2007). In response to these issues
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and the growing body of scientific and legal documentation surrounding them, the Secretary of the Interior created the Interior Department Climate Change Task Force (DOI 2007). The RMP/FEIS is remiss in failing to analyze climate change in at least two regards:
1. 2. Failure to acknowledge climate change as an integral part of the affected environment Failure to consider the role of the BLM management in greenhouse gas emissions and consider the proper mitigations.
The BLM needs to include discussion of climate change on the affected environment because climate changes can affect reclamation, disaster, water resources, vegetation, and habitat management. Increasing wildfire is currently being witnessed, and there is a considerable body of evidence suggesting that this trend will continue into the foreseeable future (Running 2006; IPCC 2007; USDA 2007). A continuation of trends could have significant consequences through impacts to species compositions, wildlife distribution, and water quality (Joyce and Birdsey 2000). The RMP/FEIS must disclose greenhouse gas emissions and propose specific strategies to mitigate them. Because of the gradual nature of climate change and noted long-term trends (USDA 2007), BLM policies and plans need to adequately consider climate change in their cumulative effects analysis and long-term responses. According to a November 2007 ruling by the 9th Circuit Court, The impact of greenhouse gas emissions on climate change is precisely the kind of cumulative impacts analysis that NEPA requires (Center of Biological Diversity v. National Highway Traffic Safety Administration; emphasis ours). CEQ Guidance (1502.14 and 1502.16) requires that the BLM explore and disclose environmental consequences and discuss potential mitigations. Because ignoring greenhouse gas emissions could have cumulative effects leading to changing conditions, treatment should acknowledge climate change and the hydrological and vegetation trends associated with it. Dismissing climate change because of inadequate information is not an option since reasonably foreseeable impacts include those with significant consequences (see CEQ 1502.22).
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5. ACRONYMS AND ABREVIATIONS

AUM ACEC BACT BMPs BLM CCLUP CBNG CFR CEQ EPA EPCA EIS ERG FEIS FLPMA FMR FRCC IM IMPLAN LANDFIRE LOC MBLRMP NAAQS NEPA NOx OHV PILT ppb RFD ROD ROS RMP
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Animal Unit Month Areas of Critical Environmental Concern Best Available Control Technology Best Management Practices Bureau of Land Management Carbon County Land Use Plan Coalbed Natural Gas Code of Federal Regulations Council on Environmental Quality Energy Policy Act Energy Policy and Conservation Act Environmental Impact Statement Ecosystem Research Group Final Environmental Impact Statement Federal Land Policy and Management Act Federal Mineral Royalties Fire Regime Condition Class BLM Instruction Memorandum Impact Analysis for Planning socioeconomic model Landscape Fire and Resource Management Planning Tools Project Location Of Concern Medicine Bow National Forest Revised Land and Resource Management Plan National Ambient Air Quality Standards National Environmental Policy Act Nitrogen Oxide Off Highway Vehicle Payment in Lieu of Taxes parts per billion Reasonable Foreseeable Development Record of Decision Recreation Opportunity Spectrum Resource Management Plan
RMPPA SERCD SCSGWG SRMAs USBEA USCB USFS USDA USDI USGS VRM VOC WAAQS WDEQ WDEQ-AQD WGFD WSEO SWAP
RMP Planning Area Saratoga-Encampment-Rawlins Conservation District South Central Sage-Grouse Working Group Special Recreation Management Area U.S. Bureau of Economic Analysis U.S. Census Bureau U.S. Forest Service U.S. Department of Agriculture U.S. Department of the Interior U.S. Geological Survey Visual Resource Management Volatile Organic Compound Wyoming Ambient Air Quality Standards Wyoming Department of Environmental Quality Wyoming Department of Environmental Quality -Air Quality Division Wyoming Game and Fish Department Wyoming State Engineers Office Wyoming State Wildlife Action Plan
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6. REFERENCES
Ahlbrandt, John. 2008. [personal communication]. Natural Resource Specialist. BLM. Rawlins Field Office, Wyoming. Bartos, T.T., L.L. Halberg, J.P. Mason, J.R. Norris, and K.A. Miller. 2006. Water resource of Carbon County, Wyoming: U.S. Geological Survey Scientific Investigations Report 2006-5027. 191 pp. Bennett, Bob. 2008. Governor's Consistency Review for the Proposed Resource Management Plan and Final Environmental Impact Statement for the Rawlins Field Office. March 4, 2008. Beyer, H. L. 2004. Hawth's Analysis Tools for ArcGIS. Available at http://www.spatialecology.com/htools. BLM 2007. 2007a. News release BLM, Wyoming DEQ Require Test of Water Wells Within the Pinedale Anticline and Jonah Fields. April 27, 2007. http://www.blm.gov/wy/st/en/info/news_room/2007/04/26pfoDEQ-BLMwatertests.html (accessed on-line on October 19, 2008). BLM 2007b. Seminoe Road Gas Development Project. Draft Environmental Impact Statement. Carbon County, Wyoming. November 2005 http://www.blm.gov/pgdata/etc/medialib/blm/wy/information/NEPA/rfodocs/seminoeroad/deis.Par.3198.Fi le.dat/SeminoeDEIS.pdf (Accessed on October 19, 2008). BLM 2008. Decision Record and Finding of No Significant Impact. Saratoga well field and transmission line, EA No. 030-08-EA-100 http://www.blm.gov/pgdata/etc/medialib/blm/wy/information/NEPA/rfodocs/saratogawells.Par.66823.File. dat/dr_fonsi.pdf (Accessed on October 16, 2008). Bott, Kelly. 2008. [Personal communication]. Environmental Specialist. Wyoming Department of Environmental Quality, Air Quality Division. Cheyenne, Wyoming. Brunson, M.W. and L. Huntsinger. 2008. Ranching as a conservation strategy: can old ranchers save the new West? Rangeland Ecology & Management. 61, no. 2: 137-147 Carbon County Fire Department. 2008. http://www.carboncountyfire.com/ (accessed October 2008). Council on Environmental Quality (CEQ). 1981. NEPA Guidance; 40 Questions: Guidance issued by CEQ to address frequently asked questions (FAQs) concerning NEPA implementation. 46 Fed. Reg. 18026. Foulke, Thomas, Roger H. Taylor, and David Coupal. 2008. Payment in Lieu of Taxes in Wyoming. http://agecon.uwyo.edu/econdev/PILT1.htm. 2008. Hann, W. J. and D. L. Bunnell, 2001. Fire and land management planning and implementation across multiple scales. International Journal of Wildland Fire 10:389-403. Hann, W.; Shlisky, A.; Havlina, D.; Schon, K.; Barrett, S.; DeMeo, T.; Pohl, K.; Menakis, J.; Hamilton, D.; Jones, J.; Levesque, M.; Frame, C. 2004. Interagency Fire Regime Condition Class Guidebook. Last update October 2007: Version 1.3.
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Hardy, C. C., K. M. Schmidt, J. M. Menakis, and N. R. Sampson. 2001. Spatial data for national fire planning and fuel management. International Journal of Wildland Fire 10:353-372. Hargett, Eric 2000. Wyoming Department of Environmental Quality Monitoring and Assessment Report, Encampment River Segment 86 On-line Report. http://deq.state.wy.us/wqd/watershed/Downloads/Monitoring/MonitoringReports/North%20Platte%20Basi n%20PDFs/Encampment.pdf (accessed on October 20, 2008). Hargett, Eric 2007.Water quality conditions of the North Fork Platte River, 1996-2005. Wyoming Department of Environmental Quality Water Quality Division. On-line report. http://deq.state.wy.us/wqd/watershed/Downloads/Monitoring/MonitoringReports/North%20Platte%20Basi n%20PDFs/NorthPlatte_AssessmentReport_FINAL.pdf (accessed on October 20, 2008). Holloran, Matthew J. 2005. Greater sage-grouse (Centrocercus urophasianus) population response to natural gas field development in western Wyoming. PhD diss., Department of Zoology and Physiology, University of Wyoming, Laramie. Holsinger, L, R.E. Keane, B. Steele, M. Reeves, and S.D. Pratt. 2006a. Using historical simulations of vegetation to assess departure of current vegetation conditions across large landscapes. Pp. 315-366 in: Rollins, M.G. and C.K. Frame, tech. eds. 2006. The LANDFIRE Prototype Project: nationally consistent and locally relevant geospatial data for wildland fire management. Gen. Tech. Rep. RMRS-GTR-175.. U.S. Forest Service, Rocky Mountain Research Station, Fort Collins, Colorado. Hoobler, Mark. 2008. [Personal communication]. North Platte River Coordinator, Wyoming State Engineers Office, Cheyenne, Wyoming. October 20, 2008. Joyce, Linda A.; Birdsey, Richard, technical editors. 2000. The impact of climate change on America's forests: a technical document supporting the 2000 USDA Forest Service RPA Assessment. Gen. Tech. Rep. RMRSGTR-59. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 133 p. Keane, R. E., R. Parsons, and P. Hessburg. 2002. Estimating historical range and variation of landscape patch dynamics: limitations of the simulation approach. Ecological Modeling 151:29-49. Maestas, J.D., R.L. Knight, and W.C. Gilgert. 2003. Biodiversity across a rural land-use gradient. Conservation Biology. 17, no.5: 1425-1434. Mason, J. P. and K.A. Miller. 2004. Water Resources of Sweetwater County, Wyoming, U.S. Geological Survey Scientific Investigations Report 2004-5214. 188 pp. Minnesota IMPLAN Group. 2004. IMPLAN Professional. Stillwater, Minnesota: MIG, Inc. Minnesota IMPLAN Group. 2007. Wyoming 2007 dataset. Stillwater, Minnesota: MIG, Inc. The National Map LANDFIRE. 2006. LANDFIRE Rapid Assessment Fire Regimes layer. Version September, 2006. U.S. Department of Interior, Geological Survey. [Online]. Available: http://gisdata.usgs.net/website/landfire/
Naugle, D. E., B. L. Walker, and K. E. Doherty. 2006. Sage-grouse population response to coal-bed natural gas development in the Powder River basin: Interim progress report on region-wide lek-count analysis. College of Forestry and Conservation, University of Montana. Missoula, MT. IPCC (Intergovernmental Panel on Climate Change). 2007. Intergovernmental panel on climate change, fourth assessment report, climate change 2007: Synthesis report. http://www.ipcc.ch/ipccreports/ar4-syr.htm. Pederson Planning Consultants. 1998. Carbon County land use plan. Published by the consultant in Encampment Wyoming. Potts, Amber. 2008. [Personal communication]. Environmental Specialist. Wyoming Department of Environmental Quality, Air Quality Division. Cheyenne, Wyoming. Runner, Jean. 2008. [Personal communication]. Office Manager. Saratoga-Encampment Conservation District. Saratoga, WY. Running, S. 2006. Is Global Warming Causing More, Larger Wildfires? Published in Science Vol. 313. no. 5789, pp. 927928. Accessed online at http://www.ntsg.umt.edu/publications/pdfs/SRunningScienceAug18.pdf Sawyer, Hall, Ryan M. Nielson, Dale Strickland, and Lyman Lyman L. McDonald. 2005. Sublette mule deer study (phase II): Long-term monitoring plan to assess potential impacts of energy development on mule deer in the Pinedale anticline project area. 2005 Annual Report. Cheyenne, WY: Western EcoSystems Technology, Inc. October. Sawyer, Hall. 2006. [Personal communication]. Research Wildlife Biologist, WEST Inc., Bozeman, MT. November. Schultz, Will. 2008. Personal communication regarding imminent wildlife issues in the Saratoga Valley, adequacy of the Saratoga Encampment Rawlins RMP/EIS, and ongoing WGFD research. Will is a WGFD Wildlife Biologist stationed in Saratoga, WY. Smith, M. D. 2005. Recent trends in cumulative impact case law. Presented at the National Association of Environmental Professionals Annual Conference, Alexandria, VA, April 1619. Sommers, Albert. 2008 [Personal Communication]. Rancher, Sublette County, WY. South Central Sage-grouse Working Group (SCSGWG). 2007. South central sage-grouse conservation plan. Published as an in-house working document. Wyoming Game and Fish Department. Cheyenne, WY. 74p. Stevenson, Temple. 2008. [Personal communication]. Natural Resource Policy Analyst, Wyoming Governors Office, Cheyenne, Wyoming. October 17, 2008. Sulak, A. and L. Huntsinger. 2007. Public land grazing in California: untapped conservation potential for private lands? Rangelands 29, no. 3: 9-12. U.S. Bureau of Economic Analysis (USBEA). 2008. http://www.bea.gov/.
U.S. Census Bureau (USCB). 2008. State and county quick facts. U.S. Department of Agriculture (USDA). 2007. Interim update of the 2000 renewable resources planning act assessment. Publication #FS-874. Washington, D.C. April. http://www.fs.fed.us/research/rpa/ U.S. Department of the Interior (USDI). 2007. News release: New Climate Change Task Force at Interior Department May 31. Accessed online at http://www.doi.gov/news/07_News_Releases/070601.html U.S. Department of the Interior (USDI), Bureau of Reclamation and the U.S. Fish and Wildlife Service. 2006. Platte River recovery implementation program: Final Environmental Impact Statement, April 2006 http://www.platteriver.org/library/FEIS/Summary/summary.pdf (Accessed on October 7, 2008) U.S. Department of Labor (USDL). 2008. Bureau of Labor Statistics Data. http://www.bls.gov/data/home.htm (accessed September 2008). Walker, Brett L., David E. Naugle, and Kevin E. Doherty. 2007. Greater sage-grouse population response to energy development and habitat loss. Journal of Wildlife Management 71 (8): 264454. Wiseman, Sherman. 2008. [Personal communication]. Transportation Survey Specialist. Wyoming Department of Transportation. Cheyenne, WY. Wyoming Business Council. 2008. http://www.whywyoming.org/counties/Carbon.aspx. (accessed October 2008). Wyoming Community Development Authority (WCDA). 2008. Wyoming demographics, economics, and housing. Wyoming Housing Data Base Partnership. http://www.wyomingcda.com/Main.html (accessed October 2008). Wyoming Department of Administration and Information (WDAI), Economic Analysis Division. 2008. http://eadiv.state.wy.us/ (accessed October 2008). Wyoming Department of Education. 2008. Education Statistics. http://www.k12.wy.us/statistics/index.html (accessed September 2008). Wyoming Department of Transportation. 2008. http://dot.state.wy.us/ (accessed September 2008). Wyoming Game and Fish Department (WGFD). 2005. A comprehensive wildlife strategy for Wyoming. Available at gf.state.wy.us/wildlife/CompConvStrategy/Introduction.pdf. 562p. Wyoming Game and Fish Department (WGFD). 2008a. Letter to Wildlife director Terry Cleveland regarding the 1/29/08 results of the multi-state sage-grouse effort. Cheyenne, WY. Wyoming Game and Fish Department (WGFD). 2008b. Wyoming greater sage-grouse core areas map. FTP site: http://gf.state.wy.us/wildlife/wildlife_management/sagegrouse/index.asp. Wyoming GAP Analysis (WY-GAP), 1996, Land Cover for Wyoming: University of Wyoming, Spatial Data and Visualization Center, Laramie, Wyoming.
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Wyoming School Boards Association. 2008. 2008-2009 Teacher Salary Settlements. http://www.wsbawy.org/Salaries2008-09.htm (accessed October 2008). Wyoming State Engineers Office (WSEO). 2008a. Water Rights Database http://seo.state.wy.us/wrdb/index.aspx (accessed on February 23, 2008). Wyoming State Engineers Office (WSEO). 2008b. Water Rights Database http://seo.state.wy.us/wrdb/index.aspx (accessed on February 23, 2008). Wyoming State Office of the Attorney General. 2008. Department of Criminal Investigation. Crime in Wyoming Reports. http://attorneygeneral.state.wy.us/dci/CrimeInWyomingReports.html/ (accessed October 2008). Wyoming Water Resources Center (WWRC). 1997. Wyoming Geohydrologic Setting Sensitivity Ratings at 1:500,000-Scale: Wyoming Water Resources Center, Laramie, Wyoming. http://www.sdvc.uwyo.edu/groundwater/data21.html (accessed on October 5, 2008). Wyoming State Treasurers Office. 2008. http://treasurer.state.wy.us/ (accessed October 2008). Yates Petroleum Corporation. 2008. Comments on the Proposed Resource Management Plan and Final Environmental Impact Statement for the Rawlins Field Office. Feb. 3, 2008.
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7. LIST OF PREPARERS
Agency/Firm /Organization Years Experience 26 11 27
Name/Role Jeanie Alonzo-Adams Petroleum Engineer Travis Benton Environmental Scientist Dianne Burke Environmental Scientist Morgan Davies Wildlife Biologist Environmental Scientist Mike Hillis Wildlife Biologist Gregory Kennett, CPRM Senior Environmental Scientist President Katie McDonald Geohydrologist Environmental Scientist Rosemary Moore Socioeconomic Analyst Remy Pochelon Recreation Specialist Alisa Wade Environmental Scientist
Education
Ecosystem Research Group B.S. Petroleum Engineering Ecosystem Research Group B.S. Forestry M.S. Chemistry Ecosystem Research Group B.A. Biochemistry M.S. Ecology and Natural Resources Ecosystem Research Group B.S. Biology Ecosystem Research Group B.S. Wildlife Biology B.S. Forestry, Watershed Management Certified Professional in Range Ecosystem Research Group Management M.S. Geology Ecosystem Research Group B.S. Geology Ecosystem Research Group B.A. Economics B.S. Forest Resource Management Professional Outdoor Recreation Ecosystem Research Group Management Course M.C.P. Environmental Planning M.P.A. Environmental Policy Ecosystem Research Group ABD PhD Conservation Planning
7 39
27
18 4
32
13
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124
APPENDIX A Regulatory Setting for the Rawlins RMP/FEIS
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A-0
A.1.
POLICY SETTING
A.1.1. Citations Used in This Section

Environmental Protection 1. National Environmental Policy Act (NEPA; 42 USC 4321-4727) [NEPA Section#] 2. Protection of the Environment regulations (primarily Council on Environmental Quality (CEQ) [40 CFR #] and 40 Most Asked Questions Concerning CEQ's NEPA Regulations [CEQ 1981]) 3. BLM NEPA Handbook [BLM Handbook H-17970-1 p.#] Land Use Planning 1. Federal Land Policy and Management Act of 1976 (FLMPA; 43 USC 1701-1712) [FLPMA S#] 2. Public Lands: Interior regulations [43 CFR #] 3. BLM Land Use Planning Handbook [BLM Handbook H-1601-1 p.#] Other Code, Regulations, and Statutes 1. Other U.S. Code [# USC Section#] 2. Other U.S. Regulations [# CFR #] 3. Energy Policy Act of 2005 [EPA Section#] 4. Energy Policy and Conservation Act [EPCA Section#] 5. Executive Orders [EO #]
A.1.2. Public and Intergovernmental Involvement Policies

Make diligent efforts to include public; hold public meetings when substantial environmental controversy exists; solicit information from public; explain its procedures; maintain public involvement records; allow for public involvement at specific points in the environmental analysis (e.g., scoping) [40 CFR 1500-1508] Coordination and on-going communication between BLM managers and state, local, and Tribal governments to ensure BLM considers pertinent provisions of non-BLM plans in managing public lands and seeks to resolve inconsistencies between such plans [FLPMA S 202(c)(9)] and provides ample opportunity for government representatives to comment on RMP [43 CFR 1610.3-1]; ensure timely coordination on interagency issues [40 CFR 1501.6] 1. Community advisory boards, county commissions, planning boards, and land use boards, etc. should be actively engaged from the beginning of the planning effort [BLM Handbook H1601-1 p.6].
Cooperating agencies identified and participate in a meaningful manner [40 CFR 1501.5-6]. Cooperating agency status depends on jurisdiction by law or jurisdiction by special expertise (statutory responsibility, agency mission, or related program experience) [40 CFR 1508.15 and 1508.26].
A.1.3. Land Use Planning Policies [FLPMA 202(c)]

Must analyze issues related to potentially significant effects [40 CFR 1501.7, 1502.1, 1502.2] Observe principles of multiple use and sustained yield Use systematic interdisciplinary approach to integrate physical, biological, economic, and other sciences
A-1 ECOSYSTEM RESEARCH GROUP
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Consider present and potential uses of public lands Consider the relative scarcity of the values involved and the availability of alternative means and sites for realizing those values Weigh long-term benefits to the public against short-term benefits Provide for compliance with applicable tribal, federal, and state pollution controls laws, standards, and implementation plans To the extent consistent with FLPMA, coordinate planning with planning and management programs of other federal/state/local government programs and policies Land use plan decisions [BLM Handbook H-1601-1 p.12-14] Must identify desired outcomes expressed in terms of specific goals and objectives Goals are broad statements of desired outcomes that are usually not quantifiable Objectives identify specific desired outcomes for resources and are usually quantifiable and may have established timeframes for achievement Must identify allowable uses and management actions Allowable uses identify uses or allocations that are allowable, restructured or prohibited on public lands or mineral estate Management actions identify actions anticipated to achieve desired outcomes to maintain, restore, or improve land health.
A.1.4. Environmental Analysis Policies A.1.4.1.

Affected Environment [40 CFR 1502.15]

Shall succinctly describe environment of areas to be affected or created by alternatives under consideration [40 CFR 1502.15] Shall concentrate effort and attention on important issues; especially the presence or absence of potentially significant resources 1. 2. 3. 4. 5. 6. 7. Floodplains [EO 11988] Wetlands [EO 11990; 40 CFR 1508.27(b)(3)] Threatened, endangered, or candidate species and their critical habitat and other special status species [40 CFR 1508.27(b)(9)] Prime or unique farmland [7 USC 4201; 40 CFR 1508.27(b)(3)] Natural resources [40 CFR 1508.8] Minority and low-income populations (including description of their use and consumption of environmental resources) [EO 13186] Migratory birds [EO 13186]
The description of the affected environment should be quantitative whenever possible and should provide a baseline for affects analysis. [BLM Handbook H-17970-1 p.53].
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Identify regulatory thresholds and characterize what is known about stresses affecting the resources and biological or physical thresholds; if possible identify threshold conditions beyond which change could cause significant impacts [BLM Handbook H-17970-1 p.53] BLM should obtain information if it is relevant to reasonably foreseeable significant adverse impacts or it is essential to a reasoned choice among alternatives; make a statement if data are missing due to unavailability or excessive cost and discuss the effect the missing information may have on ability to predict impacts to a particular resource [40 CFR 1502.22].
A.1.4.2.

Environmental Consequences/Effects Analysis [40 CFR 1502.16]

Environmental impact of proposed action, particularly the presence of potentially significant resources [NEPA (102(2)(C)(i))] Unavoidable adverse effects [NEPA (102(2)(C)(ii))] Relationships between local short-term uses of resources and maintenance and enhancement of longterm productivity [NEPA (102(2)(C)(iv))]; recommended definition of duration of long- and shortterm [BLM Handbook H-17970-1 p.55] Irreversible and irretrievable commitments of resources [NEPA (102(2)(C)(v))] BLM must take a hard look at impacts; enough detail to support reasoned comparison of impacts between alternatives [40 CFR 1502.1] BLM should obtain information if it is relevant to reasonably foreseeable significant adverse impacts or it is essential to a reasoned choice among alternatives; make a statement if data are missing due to unavailability or excessive cost and discuss the effect the missing information may have on ability to predict impacts to a particular resource. [40 CFR 1502.22] Impact analysis must include direct effects [40 CFR 1502.16(a)], indirect effects [40 CFR 02.16(b)], beneficial and adverse impacts [40 CFR 1502.27(b)] Analyses must consider natural or depleteable resource requirements and conservation potential of various alternatives and mitigation measures [40 CFR 1502.16(f)]. Ensure professional and scientific integrity of the analyses; identify methodologies and make explicit reference to sources used for analyses [40 CFR 1502.24] Recommended that document states the analytical assumptions, including the geographic and temporal scope of the analysis, baseline for the analysis, and reasonably foreseeable future actions [BLM Handbook H-17970-1 p.56]
A.1.4.3.
Cumulative Impacts
Include cumulative impacts [40 CFR 1508.7] and determine which of the issues identified for analysis may involve cumulative effect with other past, present, or reasonably foreseeable future actions [BLM Handbook H-17970-1 p.57]; recommended that staff establish and describe the geographic scope and timeframe of each cumulative effects issue and the rationale for choosing the scope and timeframe [BLM Handbook H-17970-1 p. 58] You must include reasonably foreseeable future actions within the geographic scope and the timeframe of the analysis [40 CFR 1508.7]. You cannot limit reasonably foreseeable future actions to those that are approved or funded. On the other hand, you are not required to speculate about future actions.
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Reasonably foreseeable future actions are those for which there are existing decisions, funding, formal proposals, or which are highly probable, based on known opportunities or trends. Reasonably foreseeable development scenarios may be valuable sources of information to assist in the BLMs cumulative effects analysis. Analyzing future actions, such as speculative developments, is not required but may be useful in some circumstances. Including assumptions about possible future actions may increase the longevity of the document and expand the value for subsequent tiering. Principles of cumulative effects analysis per CEQ [CEQ, 40 Most Asked Questions Concerning CEQ's NEPA Regulations, 1981, updated 1987]. 1. Cumulative effects are caused by the aggregate of past, present, and reasonably foreseeable future actions. The effects of a proposed action on a given resource, ecosystem, and human community include the present and future effects added to the effects that have taken place in the past. Such cumulative effects must also be added to effects (past, present, and future) caused by all other actions that affect the same resource. Cumulative effects are the total effect, including both the direct and indirect effects, on a given resource, ecosystem, and human community of all actions taken, no matter who (federal, nonfederal, or private) has taken the actions. Individual effects from disparate activities may add up or interact to cause additional effects not apparent when looking at the individual effects one at a time. The additional effects contributed by actions unrelated to the proposed action must be included in the analysis of cumulative effects. Cumulative effects need to be analyzed in terms of the specific resource, ecosystem, and human community being affected. Environmental effects are often evaluated from the perspective of the proposed action. Analyzing cumulative effects requires focusing on the resource, ecosystem, and human community that may be affected and developing an adequate understanding of how the resources are susceptible to effects. It is not practical to analyze the cumulative effects of an action on the universe; the list of environmental effects must focus on those that are truly meaningful. For cumulative effects analysis to help the decision maker and inform interested parties, it must be limited through scoping to effects that can be evaluated meaningfully. The boundaries for evaluating cumulative effects should be expanded to the point at which the resource is no longer affected significantly or the effects are no longer of interest to affected parties. Cumulative effects on a given resource, ecosystem, and human community are rarely aligned with political or administrative boundaries. Resources typically are demarcated according to agency responsibilities, county lines, grazing allotments, or other administrative boundaries. Because natural and sociocultural resources are not usually so aligned, each political entity actually manages only a piece of the affected resource or ecosystem. Cumulative effects analysis on natural systems must use natural ecological boundaries and analysis of human communities must use actual sociocultural boundaries to ensure including all effects. Cumulative effects may result from the accumulation of similar effects or the synergistic interaction of different effects. Repeated actions may cause effects to build up through simple addition (more and more of the same type of effect), and the same or different actions may produce effects that interact to produce cumulative effects greater than the sum of the effects. Cumulative effects may last for many years beyond the life of the action that caused the effects. Some actions cause damage lasting far longer than the life of the action itself (e.g., acid mine drainage, radioactive waste contamination, species extinctions). Cumulative effects analysis needs to apply the best science and forecasting techniques to assess potential catastrophic consequences in the future.
2.
3.
4.
5.
6.
7.
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8.
Each affected resource, ecosystem, and human community must be analyzed in terms of the capacity to accommodate additional effects, based on its own time and space parameters. Analysts tend to think in terms of how the resource, ecosystem, and human community will be modified given the action's development needs. The mast effective cumulative effects analysis focuses on what is needed to ensure long term productivity or sustainability of the resource. Identify the significant cumulative effects issues associated with the proposed action and define the assessment goals. Establish the geographic scope for the analysis. Establish the time frame for the analysis. Identify other actions affecting the resources, ecosystems, and human communities of concern. Characterize the resources, ecosystems, and human communities identified in scoping in terms of their response to change and capacity to withstand stresses. Characterize the stresses affecting these resources, ecosystems, and human communities and their relation to regulatory thresholds. Define a baseline condition for the resources, ecosystems, and human communities. Identify the important cause-and-effect relationships between human activities and resources, ecosystems, and human communities. Determine the magnitude and significance of cumulative effects.
Steps in cumulative effects analysis per CEQ [40 Questions]. 1. 2. 3. 4. 5. 6. 7. 8. 9.
10. Modify or add alternatives to avoid, minimize, or mitigate significant cumulative effects. 11. Monitor the cumulative effects of the selected alternative and adapt management.
A.1.4.4.

Mitigations (in addition to references listed under Environmental Consequences, above)

Include appropriate mitigation measures not already included in proposed action or alternatives [40 CFR 1502.15], including means to mitigate adverse environmental effects [40 CFR 1502.16(h)] "Mitigation" includes [40 CFR 1508.20] 1. 2. 3. 4. 5. Avoiding the impact altogether by not taking a certain action or parts of an action. Minimizing impacts by limiting the degree or magnitude of the action and its implementation. Rectifying the impact by repairing, rehabilitating, or restoring the affected environment. Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action. Compensating for the impact by replacing or providing substitute resources or environments.
Guidance per CEQ [CEQ, 40 Most Asked Questions Concerning CEQ's NEPA Regulations, 1981, updated 1987]. 1. The mitigation measures discussed in an EIS must cover the range of impacts of the proposal. The measures must include such things as design alternatives that would decrease pollution emissions, construction impacts, esthetic intrusion, as well as relocation assistance, possible land use controls that could be enacted, and other possible efforts. Mitigation measures must
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be considered even for impacts that by themselves would not be considered significant. Once the proposal itself is considered as a whole to have significant effects, all of its specific effects on the environment (whether or not significant) must be considered, and mitigation measures must be developed where it is feasible to do so. Sections 1502.14(f), 1502.16(h), 1508.14. 2. All relevant, reasonable mitigation measures that could improve the project are to be identified, even if they are outside the jurisdiction of the lead agency or the cooperating agencies, and thus would not be committed as part of the RODs of these agencies. Sections 1502.16(h), 1505.2(c). This will serve to [46 FR 18032] alert agencies or officials who can implement these extra measures, and will encourage them to do so. Because the EIS is the most comprehensive environmental document, it is an ideal vehicle in which to lay out not only the full range of environmental impacts but also the full spectrum of appropriate mitigation. However, to ensure that environmental effects of a proposed action are fairly assessed, the probability of the mitigation measures being implemented must also be discussed. Thus the EIS and the Record of Decision should indicate the likelihood that such measures will be adopted or enforced by the responsible agencies. Sections 1502.16(h), 1505.2. If there is a history of non-enforcement or opposition to such measures, the EIS and Record of Decision should acknowledge such opposition or non-enforcement. If the necessary mitigation measures will not be ready for a long period of time, this fact, of course, should also be recognized.
If mitigation measures are incorporated into the proposed action or alternatives, they are called design features, not mitigation measures [BLM Handbook H-17970-1 p.61]
A.1.5. Resource Specific Land Use Planning and Environmental Analyses Policies A.1.5.1.

Minerals (Energy Development) and Leasing

See [BLM Handbook H-1601-1, Appendix C, pp. 20-26] The BLM will approach compensatory mitigation on an as appropriate basis where it can be performed onsite and on a voluntary basis where it is performed offsite. Further, this Instruction Memoranda is not intended to establish an equivalency of mitigation policy by the BLM (i.e. acre for acre) [EPA 362/363; BLM IM 2005-069] Use of The Gold Book (Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development) Best Management Practices (BMPs) [EPA 262/263; BLM Gold Book 2005] See EPCA inventories of onshore federal lands to identify oil and gas resources http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/EPCA_III.html [EPA 364, EPCA 604] See BLM Instruction Memoranda 2004-089 for Policy for Reasonable Foreseeable Development (RFD) Scenario for Oil and Gas [BLM IM 2004-089] A lessee shall have the right to use so much of the leased lands as is necessary to explore for, drill for, mine, extract, remove and dispose of all the leased resource in a leasehold subject to: Stipulations attached to the lease; restrictions deriving from specific, nondiscretionary statutes; and such reasonable measures as may be required by the authorized officer to minimize adverse impacts to other resource values, land uses or users not addressed in the lease stipulations at the time operations are proposed. To the extent consistent with lease rights granted, such reasonable measures may include, but are not limited to, modification to siting or design of facilities, timing of operations, and specification of interim and final reclamation measures. At a minimum, measures shall be deemed consistent with
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lease rights granted provided that they do not: require relocation of proposed operations by more than 200 meters; require that operations be sited off the leasehold; or prohibit new surface disturbing operations for a period in excess of 60 days in any lease year [43 CFR 3101.1-2].
A.1.5.2.

Air Resources
See [BLM Handbook H-1601-1, Appendix C, p. 2] Must consider The Clean Air Act as amended [42 USC 7401 et seq.]
A.1.5.3.

Livestock Grazing and Vegetation

Vegetation - See [BLM Handbook H-1601-1, Appendix C, p. 3-4] Livestock Grazing - See [BLM Handbook H-1601-1, Appendix C, p. 14-15]
A.1.5.4.
Off-Highway Vehicles (OHV)

See [BLM Handbook H-1601-1, Appendix C, p. 17-18]
A.1.5.5.

See [BLM Handbook H-1601-1, Appendix C, p. 15-16]
A.1.5.6.
Socioeconomics
See [BLM Handbook H-1601-1 Appendix D]
A.1.5.7.
Transportation
See [BLM Handbook H-1601-1, Appendix C, p. 30]
A.1.5.8.
Visual Resources
See [BLM Handbook H-1601-1, Appendix C, p. 11]
A.1.5.9.

Water Quality
See [BLM Handbook H-1601-1, Appendix C, p. 2] Must consider Safe Drinking Water Act, as amended [43 USC 300f et seq.] Must consider Clean Water Act of 1977 [33 USC 1251 et seq.] Must consider Floodplain Management [EO 11988] Must consider Protection of Wetlands [EO 11990] See Effects of Coalbed Methane Production on Surface and Ground Water Resources report (National Academy of Sciences) at http://www.blm.gov/wo/st/en/prog/energy/epca_chart.html [EPA 1811]
A.1.5.10.

Wildlife and Fish

Special Status Species - See [BLM Handbook H-1601-1, Appendix C, p. 4] Fish and Wildlife - See [BLM Handbook H-1601-1, Appendix C, p. 6] Must consider the Magnuson-Stevens Act Provision: Essential Fish Habitat (EFH): Final Rule [50 CFR Part 600; 67 FR 2376, January 17, 2002] Must consider Migratory Bird Treaty Act of 1918, as amended [16 USC 703 et seq.] Must consider Responsibilities of Federal Agencies to Protect Migratory Birds [EO 131186] Must consider Endangered Species Act of 1983, as amended [16 USC 1531]
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A.1.6. Monitoring, Evaluation, and Adaptive Management Policies [43 CFR 1610.4-9], [BLM Handbook H-17970-1 Chapter 10]
Land use plans must establish intervals and standards for monitoring and evaluations of land use planning actions and decisions, based on the sensitivity of the resource decisions, to allow for adaptive management.
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A-8
A.2. FEDERAL/STATE/LOCAL GOVERNMENT PLANNING SETTING To the extent consistent with FLPMA, coordinate planning with planning and management programs of other federal/state/local government programs and policies [FLPMA 202(c)]. Environmental consequences must include possible conflicts between proposed action and objectives of federal, regional, State, and local land use plans, policies, and controls for the area concerned [40 CFR 1502.16(c)]. A.2.1. Medicine Bow National Forest Revised Land and Resource Management Plan 2003 (MBLMRP) A.2.1.1.

Minerals (Energy Development)

Surface occupancy and use is prohibited on slopes 60% or greater. Recommend against or deny consent to the Bureau of Land Management for issuance of leases, permits, or coal exploration licenses where operational damages to surface resources could not be reclaimed to acceptable conditions. Operational damages to surface resources include impacts from surface based access, product transportation, and ancillary facilities necessary to production and related operations [R2 Desk Guide].
A.2.1.2.


Cooperate with other government agencies to provide mitigation measures to protect National Forest resources from animal damage control activities conducted by other governmental entities. Mitigation measures emphasize protection of public safety; threatened, endangered, or sensitive species; water quality; and other resource values [R2 Desk Guide].
A.2.1.3.

Noise from oil and gas production facilities will not exceed 70 decibels (as measured by the Aweighted sound level [dBA] system of measurement) at the edge of identified residential and developed recreation interface areas.
A.2.1.4.
Water Quality
Try to locate activities and facilities away from the waters edge and outside the riparian areas, woody draws, wetlands, and floodplains.
A.2.1.5.
Wildlife
Prohibit new disturbances such as construction, drilling, new recreation facilities, logging, or other concentrated intense activities according to the following table. Short-term projects designed to improve habitat such as prescribed burning are permitted. See Table 1-14 from MBLMRP, below.
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Table 1-14 Timing Restrictions on Disturbances Near Concentrated Breeding Sites. Distances Species Effective Dates (miles) Bighorn sheep lambing areas April 1 through June 30 1.0 Sharp tail grouse breeding complexes March 1 through June 30 1.0 Sage-grouse breeding complexes March 1 through June 30 2.0 Greater sandhill crane breeding March 1 through June 30 0.5 complexes During project design, maintain or increase security areas composed of blocks of hiding cover >250 acres over one-half mile from any roads or motorized trails that are open to motorized use. Apply seasonal restrictions as needed on motorized use of travelways to reduce disturbance in sensitive big game areas, such as birthing areas and winter range [R2 Desk Guide]. See Table 1-15 from MBLMRP, below, for raptor standards and guidelines.
Table 1-15 Summary table of restrictions on surface occupancy and disturbance around raptor nests. Seasonal Buffer for Buffer for surface Human Dates for Seasonal Species Number of years occupancy the site is protected Disturbance Disturbance after last occupancy (miles) (miles) Restriction Bald eagle 5 0.50 1.00 February 1 to August 15 Golden eagle 7 0.25 0.50 February 1 to July 31 Ferruginous hawk 7 0.25 0.50 March 1 to July 31 Peregrine falcon 7 0.25 0.50 March 1 to August 15 Osprey 7 0.25 0.50 April 1 to August 15 Swainson's hawk 7 0.25 0.50 April 1 to August 15 Northern harrier* 0** No buffer 0.50 April 1 to August 15 Short-eared owl* 0** No buffer 0.25 March 1 to August 1 * Protect nests from disturbance only in year the nest is active. ** No occupancy buffer because these ground nesting species have more nest site options and move around from year to year. In suitable habitat within the range of the Preble's meadow jumping mouse, avoid placing new recreation sites, trails or roads within the riparian zone. Existing roads in designated critical habitat will be reviewed for possible closure or relocation [Medicine Bow NF]. Allow no loss or degradation of known or historic habitat for the boreal toad, wood frog, or northern leopard frog [Medicine Bow NF].
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Activities will be managed to avoid disturbance to sensitive species and species of local concern, which would result in a trend toward federal listing or loss of population viability. The protection will vary depending on the species, potential for disturbance, topography, location of important habitat components and other pertinent factors. Special attention will be given during breeding, young rearing, and other times which are critical to survival of both flora and fauna [R2 Desk Guide]. New or expanded permanent developments and vegetation management activities and practices must maintain habitat connectivity (for lynx).
A.2.2. Wyoming State Game and Fish Department (WGFD) related plans
The Wyoming State Wildlife Action Plan (WGFD 2005) was drafted in 2005 with the intent of being a dynamic document that would be updated as new data is collected. The Plan includes an inventory of vertebrate and invertebrate species. Lack of sufficient data is identified as one of the biggest problems with the Plan, and illustrates the need to collect additional information in the years ahead. For instance, of 279 vertebrate species identified State-wide, 235 were identified as having insufficient information to determine current status, or take steps to assure the species long-term viability. Of the total 279 species, 100 were identified as occurring within habitats that have been degraded to some extent. The major risks identified facing wildlife within the State include resource extraction, rural residential development, and impacts to riparian and aquatic habitats. As part of WGFDs efforts to address current issues such as energy development, and validate research findings from other portions of the State, WGFD has two ongoing studies in the RMP/FEIS project area. The Platte Valley Mule Deer Habitat Assessment will evaluate a number of variables to address recent fluctuations in mule deer populations. The principle investigator will be the Teton Science School. Field work will be ongoing through 2009, with the results published sometime after that date. The Mule Deer Idaho Sightability Index Study will establish a total mule deer population index. In the past, mule deer populations were expressed as a trend (upward, stable, or downward), and not as a total population, although WGFDs POP2 model more recently has provided a means of estimating total populations based on multiple variables. The sightability index will provide another, potentially more accurate means of estimating total populations, assuming the studys results have acceptable confidence limits. The South Central Sage-grouse Conservation Plan (SCSGWG 2007) is one of eight Plans covering sage-grouse habitat across Wyoming. All eight plans were developed by local working groups comprised of members representing agriculture, energy, local government, Wyoming Game and Fish Department, conservation groups, and other interests. This effort was initiated by Governor Fruedenthal in 2004, and funded by State legislative action in 2005. The South Central Sage-grouse Conservation Plan identifies potential impacts on sage-grouse from grazing, energy development, predation from increased densities of indigenous predators (ravens, magpies), predation from introduced, exotic predators (red foxes, raccoons), sagebrush conversion, and irrigated agriculture. Climate change was not addressed in detail, but was suggested as another variable likely affecting sage-grouse.
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A.2.3. Carbon County Land Use Plan 1998 A.2.3.1.
Minerals (Energy Development)

Carbon County recommends that, at least, the following areas could be used to accommodate potential industrial mining activity to the year 2015: (none in SERCD project area) and other known coal deposit areas. County Planning Commission recommends that the following areas could be used for future industrial mining: (none in SERCD project area) Carbon County recommends that these areas should be used for potential coal mining activity: (none in SERCD project area) Carbon County recommends that the following areas should be used for potential oil and gas exploration and production, as well as related oil and gas processing facilities: see map 7-1 from the Carbon County Land Use Plan, below.
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A.2.3.2.
Air Resources
Carbon County recommends that the Towns of Encampment and Saratoga should continue to consider air quality and vehicular traffic considerations for adjoining lands that may eventually be proposed for other land uses (e.g., retail commercial and residential land uses). Otherwise, existing mill operations may unnecessarily be subjected to increased mill operation costs.
A.2.3.3.

Carbon County recommends that all lands that have suitability for agriculture be used for future agricultural use unless existing land uses now preclude agricultural activities. This recommendation refers to both private and public lands in the County. Some of the lands that are suitable for commercial agricultural in Carbon County also contain valuable minerals in the subsurface estate. Gravel, coal, as well as oil and gas resources can often be feasibly mined and used for commercial production. Such activities can usually share land and water resources without causing any significant impact to agriculture. Carbon County recommends and encourages the continued mining of these resources on agricultural lands. Mineral development enables some ranchers in the County to supplement the income that is derived from agricultural activities. To facilitate greater cooperation, Carbon County recommends that the U.S. Bureau of Land Management also hold informal workshops with the grazing permittees in Carbon County. Such workshops should, at least, include the presentation and discussion of economical livestock techniques, range improvements, monitoring techniques that will help promote the maintenance of healthy rangelands in the County.
A.2.3.4.


Carbon County recommends that the visitor industry of Carbon County continue to be encouraged. Carbon County recommends that lands near Green Mountain be used for the potential development of a private downhill ski area.
A.2.3.5.
Socioeconomics
Urban residential expansion will take place within the corporate boundaries of the ten existing municipalities in Carbon County, as well as within a one-mile radius of these communities.
A.2.3.6.
Water Quality
A reasonable setback will be established for all structural development that occurs adjacent to surface water bodies such as creeks, streams, ponds and lakes, and natural impoundments. This consideration, which will be applicable to all residential, commercial, and industrial land uses, will consider flood protection, water quality, public recreation, and aquatic habitat. Carbon County will also evaluate future options for the long-term conservation of irrigated lands in the Little Snake River and Upper North Platte River basins.
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A.2.3.7.
Wildlife
County believes that the physical and biological resources of the regional environment should be used and conserved wisely. At the same time, the conservation of these resources should be balanced with social and economic needs of Carbon County residents who serve as both stewards and users of the land and natural resources.
A.2.4. SERCD Long Range and Natural Resource Management Plan 2007 A.2.4.1.

GOAL Provide expertise and guidance to promote healthy rangelands 1. Monitor present sites, install new transects, analyze data and develop trends 2. Enhance working relationships with local, state and federal agencies 3. Provide assistance to landowners/cooperators to implement BMPs on grazing land GOAL Promote the wise use of our tree resources 1. Investigate economic development of forest resources
A.2.4.2.
Water Quality
GOAL Promote the conservation and availability of water for all beneficial uses 1. Protect all water rights 2. Promote the wise use of water to ensure future water supplies 3. Participate in watershed studies and plans GOAL Provide leadership to maintain or improve the quality of water within all watersheds in the SERCD 1. Provide assistance on local water quality issues 2. Continue efforts to remove all DEQ listed waters 3. Implement water quality monitoring on a request basis
A.2.4.3.
Wildlife
GOAL Promote the sustainability of healthy populations and their contributions to the economic stability of the District 1. Participate in the Sage-grouse Working Group 2. Cooperate with other agencies in their wildlife programs/efforts
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APPENDIX B Watershed Study Survey Results Report
SEPTEMBER, 2008
B-0
SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT WATERSHED STUDY SURVEY RESULTS
Prepared for
September 2008
Ecosystem Research Group 121 Hickory Street Missoula, MT 59801 (406) 721-9420 www.ecosystemrg.com
SEPTEMBER, 2008
B-1
SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study Survey Results
1. METHODOLOGY
The Saratoga-Encampment-Rawlins Conservation District (SERCD) and Ecosystem Research Group (ERG) held two public meetings to discuss the forthcoming SERCD sponsored Watersheds Study and to garner public comments on the proposed energy activities allowed in the recent (2008) Bureau of Land Management (BLM) Resource Management Plan (RMP) and Final Environmental Impact Statement (FEIS) for the Rawlins Field Office. The Saratoga public meeting was held on May 28, 2008 at the Platte Valley Community Center, 122 W. Elm Ave., Saratoga, from 6:30 to 8:30 p.m.. The Encampment public meeting was held on May 29, 2008 at the Encampment Town Hall, 622 Rankin Ave., Encampment, from 6:30 to 8:30 p.m. At each meeting, ERG staff presented information about the forthcoming SERCD Watershed Study and socioeconomic issues associated with energy resource development in similar communities. At the end of each meeting, a survey was distributed to all attendees to garner input from both the public and local government officials. The local government officials who participated included members of the Saratoga, Encampment, and Riverside Town Councils; the Carbon County Commissioners; and SERCD Members. ERG also coordinated distribution of the survey as an insert in the local newspaper, The Saratoga Sun, and a version of the survey was posted on the World Wide Web. The public were encouraged to either return the survey to ERG via mail or submit the online version. Survey respondents were asked to pick ten issues from the 31 issues listed below (Table 1) that they felt were the most important. The participants were then asked to rank their ten chosen issues (1 being the most important and 10 being the least important) and to describe problems and solutions associated with each of the ten chosen issues. Participants were encouraged to give their name, email address, and physical address to ensure that each person only submitted one survey.
Table 1 Survey Issues Survey Issues Cultural Air quality Social impacts (sense of community lifestyle changes, Working landscapes (farm and ranch) preservation way of life) Restoration (how aggressively should BLM restore Wildlife habitat habitat) Economics Riparian areas Municipal services (physical infrastructure, water, Roads (too many, too few, quality) sewer, etc.) Tourism Threatened and Endangered Species Fire (risk, management, hazard, etc.) Vegetation management (timber harvest etc.) Fisheries Water quality and yield Grazing (public land) Wilderness Mining Public process Full oil and gas leasing Social services (health care, schools, government
SEPTEMBER, 2008 B-2 ECOSYSTEM RESEARCH GROUP
Survey Issues assistance, law enforcement, etc.) Some moderate level of energy development Weeds No energy development Land use planning Open space preservation Aesthetics (visual quality of local landscapes) Recreation (motorized, snowmobiling, OHV, etc.) Other (please specify) Recreation (non motorized, fishing, backpacking, etc.)
ERG created a database to store contact information and score the responses. Comments from the online survey were also stored in the database as text files. Surveys that were mailed in were scanned to Adobe Portable Document Format (.pdf) and included in the database. 1.1 SCORING OF THE RATED ISSUES
Once the completed surveys were compiled into the database, ERG scored the ranked issues to identify those that were most importance to participants. If an issue received a rank of 1, it was given a score of 10; if the rank was 2 the score was 9; a rank of 3 was scored as 8, etc. We then summed these scores for each issue. The issues with the highest summed scores were considered to be of greatest importance to participants. To compare scores between different local governments or between government and the public, we normalized the scores by taking the total score of each individual issue as a percent of the total score for all issues. A common error when filling out the surveys was to select the ten issues as asked, but then to rank each individual issue from 1 to 10. To include issues ranked in this manner but to avoid bias from this error, ERG assigned a rank of 5.5 (the mean value between 10 and 1).
SEPTEMBER, 2008
B-3
2. RESULTS
A Total of 72 individuals participated in the survey. A breakdown of the number of participants by affiliation is shown in Table 2. The Carbon County Treasurer was included in the number of participants associated with the Carbon County Commissioners.
Table 2 Number of Participants by Affiliation Affiliation General Public Saratoga Town Council Encampment Town Council Riverside Town Council Carbon County Commissioners SERCD Total
Number of Participants 54 4 5 1 4 4 72
2.1
GENERAL PUBLIC
Figure 1 shows the total scores gathered from members of the general public. The top scored issues generated by the public were (1) Water quality and water yield; (2) Wildlife habitat; (3) Social impacts (sense of community lifestyle changes, way of life); and (4) Working landscape preservation. The three issues of least importance according to the survey results were Weeds, Mining, and Aesthetics. 2.2 COMBINED LOCAL GOVERNMENT
The scores of all the local governments that participated in the survey were combined to form Figure 2. The top four issues of concern to all local government officials according to the survey were (1) Social impacts (sense of community lifestyle changes, way of life); (2) Water quality and water yield; (3) Municipal services; and (4) Working landscape preservation. The three least important issues were Weeds, No energy development, and Mining. 2.3 COMPARISON OF THE VARIOUS LOCAL GOVERNMENTS
A comparison of the normalized scores from the various local governments can be found in Figure 3. The normalized scores generated by each of the local governments varied widely on many of the issues. For example Working landscapes preservation was very important to the SERCD members and the Riverside Town Council but not as important to the other local governments. Water quality and yield was an issue that was considered relatively important by all government officials. The non-normalized scores from each of the individual local governments can be found in Figures 59.
SEPTEMBER, 2008 B-4 ECOSYSTEM RESEARCH GROUP
2.4
COMPARISON OF THE COMBINED LOCAL GOVERNMENTS AND THE GENERAL PUBLIC
A comparison of the normalized scores between the combined local governments and the general public can be found in Figure 4. Generally, there was agreement on critical issues between the two groups. Social impacts, Water quality and yield, Working landscape preservation, and Wildlife habitat, for example, were important to all groups. Government officials particularly scored Municipal services and Social impacts more highly than the public, while the public scored Wildlife habitat higher than government officials.
SEPTEMBER, 2008
B-5
3. CONCLUSIONS
Top issues differed slightly between the public and local government, but the following issues were ranked the highest by most of the groups surveyed, listed in order of total score across all respondents:
Water quality and yield Social impacts (sense of community lifestyle changes, way of life) Working landscapes (farm and ranch) preservation Municipal services (physical infrastructure, water, sewer, etc.) Wildlife habitat
SEPTEMBER, 2008
B-6
Score 100 150 200 250 300 350 50 0

Cultural Social impacts Wildlife habitat Economics Municipal services Tourism Fire Fisheries Grazing Mining Full oil and gas leasing Moderate energy development No energy developments Open space preservation Recreation (motorized)
SEPTEMBER, 2008
Issue
Recreation (non motorized) Air quality Working landscapes preservation Restoration Riparian areas Roads Threatened and Endangered Species Vegetation management Water quality and yield Wilderness Public process Social services Weeds Land use planning Aesthetics Other
Figure 1 General public survey results
Survey Results for the General Public
B-7 ECOSYSTEM RESEARCH GROUP
Score 100 120 20 40 60 80 0 Cultural Social impacts Wildlife habitat Economics Municipal services Tourism Fire Fisheries Grazing Mining Full oil and gas leasing Moderate energy development No energy developments Open space preservation Recreation (motorized) Recreation (non motorized) Air quality Working landscapes preservation Restoration Riparian areas Roads Threatened and Endangered Species Vegetation management Water quality and yield Wilderness Public process Social services Weeds Land use planning Aesthetics Other
Figure 2 All local government survey results combined
SEPTEMBER, 2008
Score from the Combined Local Governments
Percentage of Total Score Across All Categories 10 12 14 16 18 20 0 Cultural Social impacts Wildlife habitat Economics Municipal services Tourism Fire Fisheries Grazing Mining Full oil and gas leasing Moderate energy development No energy developments Open space preservation Recreation (motorized) Recreation (non motorized) Air quality Working landscapes preservation Restoration Riparian areas Roads Threatened and Endangered Species Vegetation management Water quality and yield Wilderness Public process Social services Weeds Land use planning Aesthetics Other Conservation District Members Encampment Town Council 2 4 6 8 Saratoga Town Council
SEPTEMBER, 2008
Riverside Town Council
Figure 3 Normalized comparison of survey results for the five local governments
Comparison of the Local Governments
B-9
Carbon County Commissioners
Percentage of Total Score Across All Catagories 10 12 0 Cultural Social impacts Wildlife habitat Economics Municipal services Tourism Fire Fisheries Grazing Mining Full oil and gas leasing Moderate energy development No energy developments Open space preservation Recreation (motorized) Recreation (non motorized) Air quality Working landscapes preservation Restoration Riparian areas Roads Threatened and Endangered Species Vegetation management Water quality and yield Wilderness Public process Social services Weeds Land use planning Aesthetics Other 2 4 6 8
Figure 4 Normalized comparison of survey results for local government and the general public
SEPTEMBER, 2008
Local Government
Comparison of Local Government and General Public
B-10
General Public
Score 10 15 20 25 30 0 Cultural Social impacts Wildlife habitat Economics Municipal services Tourism Fire Fisheries Grazing Mining Full oil and gas leasing Moderate energy development No energy developments Open space preservation Recreation (motorized) Recreation (non motorized) Air quality Working landscapes preservation Restoration Riparian areas Roads Threatened and Endangered Species Vegetation management Water quality and yield Wilderness Public process Social services Weeds Land use planning Aesthetics Other 5
SEPTEMBER, 2008
Figure 5 Saratoga Town Council survey results
Survey Results from the Saratoga Town Council
Score 10 15 20 25 30 35 40 0 Cultural Social impacts Wildlife habitat Economics Municipal services Tourism Fire Fisheries Grazing Mining Full oil and gas leasing Moderate energy development No energy developments Open space preservation Recreation (motorized) 5
Figure 6 Encampment Town Council survey results

SEPTEMBER, 2008
Survey Results from the Encampment Town Council
Score 10 12 0 Cultural Social impacts Wildlife habitat Economics Municipal services Tourism Fire Fisheries Grazing Mining Full oil and gas leasing Moderate energy development No energy developments Open space preservation Recreation (motorized) 2 4 6 8
Figure 7 Riverside Town Council survey results

SEPTEMBER, 2008
Survey Results from the Riverside Town Council
Score 10 15 20 25 30 35 40 0 Cultural Social impacts Wildlife habitat Economics Municipal services Tourism Fire Fisheries Grazing Mining Full oil and gas leasing Moderate energy development No energy developments Open space preservation Recreation (motorized) Recreation (non motorized) Air quality Working landscapes preservation Restoration Riparian areas Roads Threatened and Endangered Species Vegetation management Water quality and yield Wilderness Public process Social services Weeds Land use planning Aesthetics Other 5
Figure 8 Carbon County Commissioner survey results
SEPTEMBER, 2008
Survey Results from the Carbon County Commissioners
Score 10 15 20 25 30 35 40 0 Cultural Social impacts Wildlife habitat Economics Municipal services Tourism Fire Fisheries Grazing Mining Full oil and gas leasing Moderate energy development No energy developments Open space preservation Recreation (motorized) Recreation (non motorized) Air quality Working landscapes preservation Restoration Riparian areas Roads Threatened and Endangered Species Vegetation management Water quality and yield Wilderness Public process Social services Weeds Land use planning Aesthetics Other 5
Figure 9 SERCD Member survey results
SEPTEMBER, 2008
Survey Results from the SERCD Members
APPENDIX C IMPLAN Model Output for Carbon County
DECEMBER, 2008
C-0
1. IMPLAN MODEL RESULTS

IMPLANs 2007 report of Carbon County, Wyoming by industry provides an overview of the socioeconomic setting within Carbon County. We ran the IMPLAN model using 2007 data to provide additional detail on industrial output and employment by sector for Carbon County. This information is provided to SERCD as additional background. Cattle ranching and farming, oil and natural gas extraction, construction, petroleum refineries, and retail are strong employment sectors in Carbon County. Cattle ranching and farming employed 346 people in 2007. Mining and oil and natural gas extraction provided 306 jobs, mostly in support activities for oil and gas operations. Construction of both residential and non-residential structures contributed 1,484 jobs. Petroleum refineries supplied 209 employees with jobs. Retail employed 984 total people. Like most counties, Carbon County also has a large portion of their workforce in healthcare, social services, and state, local, and federal government. All output data are provided in Table 1-1. The table is divided into industry output, number of employees, employee compensation, proprietary income, property income, and indirect business tax by sector. Employee compensation is wage/salary payments plus benefits to employees. Proprietary income consists of payments received by self-employed individuals as income. Other property type income consists of payments from interest, rents, royalties, dividends, and profits. This also includes corporate profits earned by corporations. Indirect business taxes consist of excise and sales taxes paid by individuals to businesses. These do not include taxes on profit or income (Minnesota IMPLAN group 2004). Output, employee compensation, proprietary income, other property income, indirect business tax, and total value added are shown in millions of dollars.
Table 1-1 Carbon Countys Industrial Output and Employment by Sector Employee PropSecComprietor tor # Industry Output* Employee ensation* Income* 2 Grain farming 0.028 1 0.001 0 All other crop 10 farming 11.124 52 1.717 -0.548 Cattle ranching 11 and farming 46.524 346 5.845 -2.681 Forestry-forest products- and timber tract 0 0 0 0 15 production 16 Commercial logging 5.618 51 0.24 0.367
DECEMBER, 2008 C-1
Other Property Income* 0.007 1.705 4.71
Indirect Business Tax* 0.001 0.573 1.229
Total Value Added* 0.009 3.447 9.104
0 1.325
0 0.051
0 1.983
Sector #
18
19 20 21 22
23
24 25
26
27 28
29
30
Industry Commercial hunting and trapping Support activities for agriculture and forestry Extraction of oil and natural gas Mining coal Mining iron ore Mining coppernickel-lead-and zinc Mining goldsilver- and other metal ore Mining and quarrying stone Mining and quarrying sandgravel-clay-and ceramics Mining and quarrying other nonmetallic minerals Drilling oil and gas wells Support activities for oil and gas operations Support activities for other mining
Output*
Employee
Employee Compensation*
Proprietor Income*
Other Property Income*
Indirect Business Tax*
Total Value Added*
1.095
0.176
0.52
0.075
0.771
1.109 23.995 23.556 0
60 40 41 0
0.407 2.063 3.095 0
0.651 4.033 4.961 0
-0.162 6.938 3.685 0
0.015 1.415 2.441 0
0.911 14.45 14.181 0
0 0.096
0 1
0 0.029
0 0.001
0 0.03
0 0.002
0 0.061
0.074
0.022
0.002
0.009
0.001
0.034
0 0
0 0
0 0
0 0
0 0
0 0
0 0
43.919
208
10.715
0.473
3.168
0.44
14.797
5.501
15
0.745
0.011
0.655
0.02
1.431
DECEMBER, 2008
C-2
Sector #
31 32
33
34
35
36
37
38
39
40
Industry Electric power generationtransmissionand distribution Natural gas distribution Water- sewage and other treatment and delivery sys Construct new nonresidential commercial and health Construct new nonresidential manufacturing structure Construct other new nonresidential structures Construct new residential permanent site single-an Construct other new residential structures Maintenance & repair construct of nonresident structures Maintenance & repair construct of residential structures
Output*
Employee
Proprietor Income*
Total Value Added*
23.903 4.653
63 6
4.162 0.178
0.684 0.014
9.491 0.192
2.879 0.067
17.216 0.451
0.033
0.013
0.001
0.008
0.001
0.024
63.979
466
26.506
2.036
2.438
0.445
31.426
8.384
60
3.398
0.261
1.107
0.027
4.793
38.293
290
16.553
1.263
1.157
0.237
19.21
68.304
326
18.584
1.428
7.201
0.533
27.747
21.707
101
5.731
0.44
2.948
0.067
9.187
26.574
230
13.718
0.659
0.364
0.185
14.926
5.657
11
0.606
0.338
1.505
0.299
2.749
DECEMBER, 2008
C-3
Sector #
59
95
96
97
98
99
100
101
102
103 104 105 106
Industry Animal (except poultry) slaughteringrenderingSawmills and wood preservation Veneer and plywood manufacturing Engineered wood member and truss manufacturing Reconstituted wood product manufacturing Wood windows and doors and millwork manufacturing Wood container and pallet manufacturing Manufactured home (mobile home) manufacturing Prefabricated wood building manufacturing All other miscellaneous wood product manufacturing Pulp mills Paper mills Paperboard Mills
Output*
Employee
Proprietor Income*
Total Value Added*
3.333
0.072
0.011
0.004
0.001
0.088
11.091
43
1.091
0.445
0.694
0.032
2.263
0 0 0 0
0 0 0 0
C-4
0 0 0 0
0 0 0 0
0 0 0 0
0 0 0 0
0 0 0 0
DECEMBER, 2008
Sector #
107
108 115
203
206 319
324 326
328 333 335 337
338
Industry Paperboard container manufacturing Coated and laminated paperpackaging paper and pl Petroleum refineries Farm machinery and equipment manufacturing Mining and oil and gas field machinery manufacturing Wholesale trade businesses Retail Stores Food and beverage Retail Stores Gasoline stations Retail Stores Sporting goodshobby- book and music Transport by rail Transport by truck Transport by pipeline Scenic and sightseeing transportation and support
Output*
Employee
Proprietor Income*
Total Value Added*
0 1,461.73
0 209
0 27.836
0 1.812
0 53.376
0 2.631
0 85.654
0 44.127
0 263
0 16.481
0 0.311
0 5.44
0 6.293
0 28.525
9.579 20.498
151 302
4.303 7.088
0.217 0.827
0.58 4.079
1.48 3.194
6.579 15.187
0.713 66.519 32.874 50.635
30 161 247 63
0.225 16.48 8.661 5.575
0.097 0 2.972 0
0.067 14.298 3.647 -0.21
0.11 0.864 0.336 1.684
0.499 31.642 15.616 7.05
2.672
33
1.366
0.134
0.154
0.208
1.862
DECEMBER, 2008
C-5
Sector #
354 360
361
374
375 379
394
398 399 400
401
Industry Monetary authorities and depository credit intermediaries Real estate establishments Imputed rental activity for owner-occupied dwellings Managementscientific- and technical consulting Environmental and other technical consulting services Veterinary services Offices of physiciansdentists-and other health Nursing and residential care facilities Child day care services Individual and family services Community food- housingand other relief services
Output*
Employee
Proprietor Income*
Total Value Added*
10.4 27.376
106 193
4.199 1.154
0.08 3.137
0 14.808
0 3.367
4.278 22.465
55.714
30.268
6.112
36.38
4.214
35
1.45
0.73
0.141
0.022
2.343
0.862 1.333
6 24
0.25 0.258
0.162 0.137
0.091 0.022
0.004 0.016
0.505 0.434
17.075
181
8.466
1.477
1.106
0.114
11.163
10.294 8.666 6.677
203 341 326
5.364 2.304 0.842
0 0.858 0.376
1.579 1.253 0.075
0.281 0.057 0.008
7.225 4.471 1.301
4.452
139
1.049
0.599
0.07
0.015
1.732
DECEMBER, 2008
C-6
Sector #
405
411
413
414
425 426
437
438
439
440
Industry Independent artists- writersand performers Hotels and motelsincluding casino hotels Food services and drinking places Automotive repair and maintenanceexcept car wash Civic-socialprofessionaland similar organizations Private household ops * Special (S&LG Non-Ed Employment) * Special (S&LG Ed Employment) * Special (Federal NonMilitary Employment) * Special (Federal Military Employment)
Output*
Employee
Proprietor Income*
Total Value Added*
1.059
21
0.24
0.406
0.157
0.005
0.808
16.276
267
4.737
0.407
2.574
1.33
9.048
27.894
591
8.36
0.258
2.101
1.243
11.963
8.395
102
2.64
0.423
0.562
0.651
4.276
4.279 1.476
124 267
1.078 1.476
0.017 0
-0.131 0
0.059 0
1.022 1.476
37.085
691
33.104
3.98
37.085
54.002
1,077
48.206
5.796
54.002
21.441
278
19.698
1.743
21.441
6.154
105
3.85
2.305
6.154
*Millions of dollars (Minnesota IMPLAN Group 2007)
DECEMBER, 2008
C-7

Encampment Area Watershed Study

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Encampment Area Watershed Study

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ENCAMPMENT AREA WATERSHED STUDY

A REVIEW OF THE RAWLINS BLM RMP AND FEIS

Saratoga-Encampment-Rawlins Conservation District

December 10, 2008

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

Off Highway Vehicles

Recreation and Visitor Services

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

1. INTRODUCTION 1.1 PURPOSE OF THIS STUDY

Map 1.1-1 Map of SERCD study area

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

LOCAL GOVERNMENT AND PUBLIC CONCERNS

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

0.40 0.35 0.30 0.25 0.20 0.15 0.10 0.05 0.00

General Public Riverside Town Council

SERCD Members Encampment Town Council

Carbon County Commissioners Saratoga Town Council

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

Saratoga-Encampment-Rawlins Study Area

Medicine Bow National Forest

North Brush Creek Lower Spring Creek

North Platte River-Elk Hollow Creek

South Brush Creek

South Spring Creek

North Platte River-North Cottonwood Creek

French Creek-North Platte River

Encampment River-West Cottonwood Creek

Encampment River- Billie Creek

Bear Creek-Big Creek

Medicine Bow National Forest

North Fork Big Creek

East Fork Encampment River

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

Map 3.2-1 Reproduction of Map 4-7 from Rawlins RMP/FEIS

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

SARATOGA-ENCAMPMENT-RAWLINS CONSERVATION DISTRICT Watershed Study

ECOSYSTEM RESEARCH GROUP