The Tale of "Two" Basins

by Tom Darin

The Bureau of Land Management (BLM) has released for public comment two separate draft environmental impact statements (DEISs) for the largest natural gas project ever studied by the agency.

Although the environmental impacts of the massive Powder River Basin coalbed methane (CBM) project should have been assessed in one document, BLM offices in Montana and Wyoming split the project at the state line and each prepared its own draft study.

Of course, there is only one basin, and key differences within each DEIS underscore WOC's position that the BLM should have looked at the basin as a single geographic and ecological unit.

Montana's study of a projected 26,000 CBM wells over the next 20 years is replete with deficiencies. Perhaps the most glaring error is that while the Montana portion of the Powder River will be enormously affected by water discharges from 51,000 or more CBM wells in Wyoming during the same time period, the state based its cumulative-impacts analysis on only 6,000 Wyoming wells, a number cited in the now-outdated EIS for the Wyodak Project in the basin.

The most striking differences between the two DEISs for the same basin appear in their overall approach. For example, the heart of an EIS is the formulation, discussion and analysis of a full range of reasonable alternatives.

The Wyoming BLM interpreted that to mean analyzing: (1) dumping 90% or more of the produced wastewater on the ground, untreated (the agency's and industry's preferred alternative); or (2) dumping most of the water untreated on the ground or into wastewater pits designed to bleed into the water table.

In stark contrast, the Montana BLM study analyzed the following alternatives:

• emphasizing protection of soils, water, air, vegetation, wildlife and cultural resources;
  
  
• focusing on maintaining existing land uses;
  
  
• development while minimizing impacts to environmental resources; and
  
  
• development with minimal environmental protections.

There are other key differences. Montana would require directional drilling in certain circumstances; require drilling plans that include consultation with landowners prior to surface disturbance; evaluate different well-spacing options; consider mandatory injection of all produced water; and, unlike Wyoming, minimize impacts to landowners in cases where federal minerals underlie private surface lands.

As a result, water, air and wildlife resources in the same area may receive significantly different treatment merely because each state's BLM has different attitudes and objectives.

The need for a coordinated, basin-wide approach to CBM development is obvious when you look at each state's wildly inconsistent assumptions. Montana's study of a projected 26,000 CBM wells over the next 20 years is replete with deficiencies. If Montana's interpretation is correct, Wyoming's is way off-base, and the environmental impacts of CBM development in the Wyoming portion of the basin will be far greater than the BLM predicts.

Major inconsistencies between the two draft studies include:

• 20 vs. 7 years. While Montana says that CBM wells have production life cycles of 20 years, Wyoming claims that wells produce for only seven years. If Montana is right, then Wyoming's analysis of impacts through 2017 is off by 13 years: CBM wells will be productive through 2030.
  
  
• 300 vs. 400 million cubic feet of gas. Montana says that each CBM well will extract 300 million cubic feet (mmcf) of gas, while Wyoming says that number is 400 mmcf for each well's life cycle - a 25% difference. If Montana is right, Wyoming's estimate of how many wells are needed to extract recoverable CBM - and thus their environmental impacts - is low by 13,000 wells.
  
  
• .25 acres vs. .3 to .7 acres disturbed. Montana says that .25 acres will be disturbed by each well pad. Wyoming says that figure is .3 to .7. Why does the average acreage disturbance magically change when crossing the state line?

WOC's comments to the Wyoming and Montana BLM will point out these important discrepancies in studies for the "two" basins in the hope that each state will learn from the shortcomings of the other. We will press the agency to choose the least environmentally destructive alternative in its final environmental impact statements.

The final EIS for Wyoming is due in late summer. Please watch for our continuing coverage of this important issue and action alerts on how you can voice your concerns.