CBM is a form of natural gas extraction, although as the name implies, the methane (gas) is derived from an unconventional source - underground coal seams that also serve as aquifers. Liberating the methane from the coal seams, and thereby allowing it to be captured at the ground surface, is what leads to the key environmental problems. The extraction method, described by the Bureau of Land Management as "radically different" than that for deep, conventional natural gas, involves massive dewatering of the coal seam. The "dewatering" process is necessary to liberate the gas from the coal particulates; otherwise, the hydrostatic pressure keeps the methane underground. What to do with this byproduct water, that is typically high in total dissolved solids and sodium, as well as having a high sodium adsorption ratio (SAR), is at the heart of the environmental hazards.

The first issue is water quantity - CBM wells average about 15,000 gallons of produced water per day, per well - which is either dumped onto the ground, or in the latest trend in Wyoming, stored in massive, unlined "infiltration" reservoirs, that are tearing up the landscape by the thousands in order to allow this water to slowly bleed into the water table, streams and rivers. The byproduct water depletes important underground aquifers, while at the same time, creating unprecedented soil erosion impacts on the surface, in addition to altering hydrographs of entire river drainages.

The second issue is the quality of this water, which threatens vegetation, encourages weed infestation by salt-tolerant exotics, and has untold - because of the lack of scientific study - impacts to wildlife and fisheries. Because the Clean Water Act has clear standards for and limits on the discharge of pollution into streams, and much of the CBM waste water qualifies as a pollutant, the Clean Water Act has important relevance to handling of CBM water quality issues. However, CBM is a relatively new form of production, regulations specific to CBM, and thus more narrowly tailored and enforceable, have yet to be promulgated.

Also unique to CBM extraction are noise and air quality issues associated with the need for huge amounts of energy needed to power submersible pumps needed to drain the coal seams. In Wyoming, many operators find the cheapest method of supplying this power to be hundreds, if not thousands, of polluting diesel generators.

Other unique impacts to CBM include methane migration (whereby the methane can escape and migrate into homes, water wells and soils), possible subsidence of the ground surface due to the dewatering, and the potential for underground coal fires once the water is removed.

Unfortunately, the problem is not limited to the Powder River Basin in Wyoming. The Wyoming portion of the Powder River Basin has 39 trillion cubic feet (TCF) of CBM, of which, 25 TCF (a little over one year's supply for U.S. consumption) are deemed recoverable. That area, and the Montana portion of the Basin, are currently thought of as the "hottest" natural gas play in the country. BLM is now predicting as many as 138,000 CBM wells during the life of the play in the Wyoming Powder River Basin alone. The Greater Green River Basin, existing mostly in southwest Wyoming, has 314 TCF in CBM reserves, which if recoverable in any decent percentage, could make this play do the seemingly impossible: dwarf the CBM frenzy in the Powder River Basin. That poses enormous threats to the wild lands at play here, including Wyoming's Red Desert, that serve as crucial habitat and winter range for elk, pronghorn antelope and mule deer. Initial projects - one near the Bridger Teton National Forest and another near the Medicine Bow National Forest – have indicated that the CBM in this reserve is economically recoverable. More recent proposed projects, including the 3,800 well Atlantic Rim CBM project and 1,240 well Seminoe Road project in southwestern Wyoming and the 210 well South Piney Gas/CBM project adjacent to the Wyoming Range in the Upper Green River Valley, are proposing over 5,000 CBM wells in this region….and more proposals consistently appear.

For private and state CBM wells, Wyoming has three separate agencies that permit all natural gas wells. The Wyoming State Engineer (WSE) approves permits for the water removed from the ground; the Wyoming Oil and Gas Conservation Commission (WOGCC) permits wells for spacing, density, well construction and safety; the Wyoming Department of Environmental Quality (WDEQ) administers section 402 of the Clean Water Act and permits each well as the discharge water is considered a pollutant. A fourth permit is needed for all federal wells - CBM producers on federal mineral estates have to submit an Application for Permit to Drill (APD) and have that approved by BLM prior to drilling. If the water containment proposal involves reservoirs or other activities that add dredge or fill material into a wetland or ephemeral drainage, a fifth permit is needed (from the Army Corps of Engineers) to comply with section 404 of the Clean Water Act.

In our efforts to assure that impacts of CBM development are properly understood and analyzed prior to development so effective mitigation can occur and development does not occur where it will be too damaging, we have succeeded in numerous instances in establishing that the agencies have failed to meet the requirements of the National Environmental Policy Act (NEPA) in their frenzy to expedite development. NEPA requires that federal agencies take a hard look at significant actions that will affect the human environment, and in many cases the BLM in particular have simply relied on existing oil and gas analysis, rather than ones evaluating the unique additional impacts of CBM, to approve CBM development. The Interior Board of Land Appeals has repeatedly held that CBM is unique and therefore particularized studies for CBM impacts must occur. See IBLA opinion 10.15.2002 (1.6MB pdf).

BLM and the Forest Service are catching up, however, and land use plans are being updated throughout Wyoming to study, in most cases for the first time, these impacts. In addition, site-specific CBM NEPA studies are ongoing throughout Wyoming by Buffalo BLM (Sheridan, Johnson and Campbell counties); Rawlins BLM (Carbon County) and Pinedale BLM (Sublette County).

Learn How You Can Help prevent CBM damage.