For Immediate Release: June 9, 2004 
Contact: Walt Brown  (970) 385-1304
Ann Bond  (970) 385-1219
Vaughn Whatley  (303)-239-3766
 

QUESTIONS & ANSWERS Northern San Juan Basin EIS

What is the Northern San Juan Basin (NSJB) Coalbed Methane EIS?

In 2001, the U.S. Forest Service (USFS) and Bureau of Land Management (BLM) received a proposal from several energy companies, including BP America, Pure Resources, XTO Energy, Elmridge Resources, Petrox Reources and Exok, to develop about 300 new coalbed methane (CBM) wells on leases already held by the companies on federal lands in La Plata and Archuleta counties. When land management agencies are approached by the private sector with a proposal that will result in such activities, the agencies study the proposal through a process outlined by the National Environment Policy Act (NEPA). The Northern San Juan Basin Environmental Impact Statement (EIS) represents both a programmatic and site-specific NEPA document. This means it studies the overall development scenario in the project area, as well including site-specific NEPA studies on proposals for individual well pads.

How can I comment on the Draft EIS?

There will be several opportunities for public input during the NEPA process. Written public comments will be accepted for 90 days, beginning June 10, 2004. Local open houses and public hearings will be held where citizens may also submit oral comments.  In addition, a subcommittee of the Bureau of Land Management Southwest Colorado Resource Advisory Council will sponsor a series of public meetings in local communities to offer additional public involvement opportunities.  Written public comments must be postmarked no later than September 8, 2004, and mailed to Northern San Juan Basin CBM EIS, USDA FS Content Analysis Team, PO Box 221150, Salt Lake City, UT 84122. Comments may also be emailed to:  nbasin-cbm-eis@fs.fed.us

What is the analysis area?

The analysis area encompasses 125,000 acres of public and private lands north of the Southern Ute Indian Reservation in the counties of La Plata and Archuleta. There are 300 existing CBM wells in the analysis area. Although the EIS considers cumulative effects from the proposed additional development on private lands, it makes no decisions involving private property, because the EIS has jurisdiction only on federal lands and minerals. The analysis area is part of the San Juan Basin, which covers 100 square miles in northwestern New Mexico and southwestern Colorado. One-third of the basin is in Colorado and includes the Southern Ute Indian Reservation and NSJB EIS Analysis Area.

What is coal bed methane (CBM)?

CBM is a natural gas produced by the decomposition of carbon-rich organic matter during coal formation. It is composed of 80-99% methane, along with ethane, propane, nitrogen, and carbon dioxide. Methane is the main component of natural gas used in homes.  The Fruitland coal seams of the Northern San Juan Basin are different than conventional gas formations.  The methane is chemically adhered, or adsorbed, to the surface of the coal.  Natural gas found in other formations is found as a free gas in pores and fractures of rock. The Fruitland coal beds, which contain CBM gas, lie at a depth of about 3,500 in the interior of the basin, but the coal seams tilt upwards and are exposed at the surface at the outcrop rim. They retain a greater amount of gas at shallow depths in comparison to conventional reservoirs at comparable depths and pressures. The Fruitland Outcrop, which forms the northern boundary of the analysis area, extends for about 90 miles across southwestern Colorado.

How much CBM is estimated to be in the analysis area?

The estimated total CBM reserve, including production to date, in the Colorado portion of the San Juan Basin (including the Southern Ute Indian Reservation) is estimated to produce about 12 trillion cubic feet of gas per year, which could result in $36 billion in gross revenues. The total CBM reserve, including production to date, in the Northern San Juan Basin analysis area only is estimated at about 2.5 trillion cubic feet, which could result in about $7.5 billion in gross revenues. The U.S. Forest Service and BLM are committed to the timely development of energy resources in an environmentally sound manner as part of the President’s National Energy Policy. 

The 300 CBM wells proposed for the Northern San Juan Basin could accommodate the residential needs of hundreds of thousands of households per year based on average residential use rates. The life expectancy of the wells is estimated at about 25 years. Residential gas use has increased 13 percent in the last decade, and some two-thirds of new homes include natural gas heating. In 2000, the consumption of natural gas production was:

• 24% Residential,
• 16% Commercial,
• 39% Industrial, and
• 21% Electricity Generation.   

What is the history of CBM development in the analysis area?

• In 1980, Congress passed the Crude Oil Windfall Profits Tax Act with tax incentives for unconventional fuel resources;
• In the early 1980s, management plans for the San Juan National Forest and BLM San Juan and San Miguel Resource Areas identified all federal lands in the project area as suitable for oil and gas leasing;
• In the 1980s and ‘90s, approximately 250 CBM wells were constructed in the project area under these plans; 
• In 2000, industry proponents submitted a plan for 170 new CBM wells on existing leases in La Plata County (the majority infill).  A NOI was filed by BLM in the Federal Register to prepare the NSJB EIS.  Public meetings were held in Durango and Bayfield;
• In 2001, industry submitted a revised plan for approximately 300 new CBM wells on existing leases (160 wells proposed in La Plata County; 140 in Archuleta County);
• In 2002, public meetings were again held in Durango and Bayfield to take comments on the revised proposal.

What is the purpose and need of the EIS?

To allow the companies (proponents) to develop their leases and help meet the public’s need for natural gas; and to approve a gas field development plan.

What does the NSJB EIS cover?

• It does evaluate different development scenarios on USFS and BLM lands in the analysis area;
• It does address impacts and mitigation, and evaluate environmental protection measures; 
• It does study, in detail, a myriad of issues, including social and biological impacts from development of leases;
• It does evaluate impacts specific to the HD Mountains Roadless Area; 
• It does include seven alternatives that study different development scenarios and measures proposed to mitigate, or lessen, possible impacts from development.
• It does present a project-level gas field development plan, which means the Record of Decision will approve individual Applications for Permit to Drill (APDs). 

What is not included in the NSJB EIS?

• It does not make well-density spacing decisions on public lands.
• It does not make leasing decisions on public or private land.
• It does not make development decisions on private lands or private mineral estate.
• It does not make land-use planning decisions for federal lands or minerals. 

What are the land jurisdictions in the analysis area?

The analysis area for the NSJB EIS encompasses 125,000 acres of public and private lands north of the Southern Ute Indian Reservation in La Plata and Archuleta counties in southwestern Colorado. Although the NSJB EIS evaluates cumulative effects across public and private jurisdictions, it has no jurisdiction over development decisions on private lands or private mineral estate.

Land Jurisdiction	% of Analysis Area
Private	45%
USFS	37%
Private surface/Federal mineral	7%
BLM	5%
State	4%
Federal surface/Private mineral	2%

 

What are the major issues studied in the NSJB EIS?

• Economic impact of development:
  • 50% of La Plata County’s property tax base comes from oil and gas development. In 2003, federal mineral revenues generated $5.7 million in royalties and revenues with $2.8 million dispersed to the State of Colorado
  • In Archuleta County, federal mineral revenues generated $211,112 in 2003 with $105,556 dispersed to the State of Colorado
  • Impacts of development on private property values
• Social impacts and quality of life:
  • Noise from construction and well pad equipment afterwards 
  • Impacts of development on aesthetics and scenic values of the area
  • Dust from new traffic on roads developed for well pads
  • Other residential and agricultural issues
• Water depletions/effects on water rights:
  • Combination of existing and proposed development may intersect up to 200 acre-feet per year of surface recharge of four river basins.  (Almost all of this interception is a result of existing CBM development.  Although not a substantial amount, all rivers but the Animas River are already over-appropriated.)
• Possibility of gas seepage into domestic water wells:
  • BLM believes this problem has been solved through Bradenhead testing of existing wells, resealing of older offending wells, and enforcement of new methods of well bore sealing.
• Soils and slope stability:
  • Surface disturbance could exacerbate existing landslides and cause new landslide hazards. Based on preliminary location of proposed access roads, 15 miles of new roads would cross high landslide-hazard areas. Additionally, 17 proposed well pads would require cut and fill construction in areas of high landslide hazard. Landslides could be activated during facility construction. Facility design, construction practices, and mitigation measures would be put in place to help minimize the risk of landslides.
• Fruitland Outcrop issues:
  • The Fruitland Outcrop, where the Fruitland coal seam crops out at the surface of the Northern San Juan Basin rim, extends for about 90 miles across southwestern Colorado. 
  • Dying vegetation, methane seepage, and coal fires have occurred along the Outcrop creating public health and safety issues.
• Wildlife and Fisheries habitat:
  • Increased wildlife harassment, road kill, hunting  pressure, and displacement.
  • Impacts of development on important game species
  • Suitability of wildlife habitat, loss of critical big-game winter ranges, habitat fragmentation , and disruption of migration routes.
  • Long-term viability of wildlife populations
  • Impacts on downstream fisheries from effects of dewatering of coal seams on groundwater and surface water quality and quantity
  • Impacts to federal and state listed threatened, endangered, proposed, candidate and sensitive species, and their habitats.
• Vegetation:
  • Vegetation would be removed where well pads, compressor stations, pipelines, and roads are constructed. Ponderosa pine, pinyon-juniper, and Gambel oak would be most affected. Facilities would be partially re-vegetated following construction. Full reclamation would occur after the production phase.
  • Loss of wetlands and riparian areas may occur, despite efforts to avoid them. Well pads and compressor stations would be located in upland sites where they would not impact wetlands and riparian areas. Roads and pipelines would not be constructed across perennial streams and rivers. However, roads and pipelines would be constructed across some 128 intermittent streams, where some wetlands and riparian vegetation may exist. Best management practices would be utilized to reduce sedimentation to wetlands and riparian areas.
  • Weed seeds may be introduced accidentally as a result of project activity. Mitigation measures designed to prevent the introduction and spread of noxious weeds would be implemented. However, complete prevention and control of weeds is unlikely.
  • Portions of old-growth ponderosa pine stands may be removed by construction. Without avoidance mitigation, the Preferred Alternative would impact 36 acres of old growth pine, approximately 4% of the old-growth present on National Forest lands in analysis area. To the extent practical, old growth stands would be avoided during road and well pad staking. However, until firm locations are proposed during APD submittal, the effective ability to move facilities to avoid old-growth impact is unknown.
  • During the development phase of the project, cut trees and limbs would be present along roads and at well pads and may increase infestations of the Ips beetle. By attracting more beetles, the surrounding trees that are not directly affected by construction would be at greater risk of insect attack. Mitigation measures would require timely removal of wood from construction areas.
  • One federally listed plant species, four USFS sensitive plant species, and two BLM sensitive plant species may occur in the analysis area and may be affected by the proposed project. Pre-construction surveys for these species would be conducted in all suitable habitat, and impacts minimized by avoidance mitigation.
• Cultural resources:
  • Hopi Tribe has expressed concerns over site-specific vs. block surveys in the Project Area.
  • Visual landscape issues with Chimney Rock Archaeological Area
• Recreation and Travel Management:
  • CBM development would entail construction of new roads into areas not previously accessible by road. Increased road access would result in impacts on wildlife and natural resources.
  • Off-road, cross-country travel by motorized vehicles is currently allowed on federal lands in the analysis area. Motorized travel on BLM lands is currently unrestricted. National Forest lands are closed year-round to all but off-road vehicles, which can travel unrestricted from June - Nov.
  • No change in travel management is proposed for BLM land, but for National Forest land, some alternatives propose that motorized use be limited seasonally to designated roads and trails. Access roads to well pads would be gated and closed year-round, except those designated as travel routes. Operators could use the roads to maintain facilities, in compliance with seasonal restrictions and mitigation measures.
• Air quality:
  • Sources of contaminants:
    • Farmington EIS – 20,000 existing wells, 10,000 proposed
    • Colorado O&G – 2,500 existing wells, 1,000 proposed
    • New Mexico power plants
    • Urban and residential growth
  • BLM/USFS are considering the creation of a formal Interagency Task Force of state and federal officials, local and tribal officials, industry, and environmental representatives. This group would discuss issues, such as emission source growth beyond oil and gas development, potential ozone impacts, increment issues, and expanded coal-fired power plant development, to identify mitigation measures. Study area would be expanded beyond the current analysis area. Enforcement would rest with air-quality regulatory agencies.
  • Although the emission rate would not be determined until a Record of Decision is issued, a mandatory emission limit of 2.0 gm/hp-hr is under consideration for all new and replacement small well-head engines. Such a limit would remain in effect until Task Force determines mitigation measures. If it is unable to develop specific measures, interim requirements would remain in place.
• Air quality impacts on Class 1 Areas (Weminuche Wilderness, Mesa Verde NP):
  • Cumulative impacts from NM and CO sources in the San Juan Basin are predicted to exceed visibility thresholds (19-38 days annually);
  • Cumulative visibility impacts could be reduced to 3-17 days annually if state-of-the-art emission sources are required on new O&G-related emission sources of nitrogen oxides;
  • BLM Farmington FEIS/ROD deferred a regional cumulative far-field air analysis and additional mitigation measures to the NSJB EIS. 
  • USFS and BLM have discussed with state and federal air-quality management agencies several possible visibility mitigation measures to limit the predicted significant adverse impacts. A specific mitigation strategy will not be selected until the NEPA analysis and disclosure process is completed, and a formal Record of Decision is issued.
• HD Mountains Roadless Area:
  • In the late 1970s, the Roadless Area Review and Evaluation (RARE) process identified all roadless and undeveloped lands on the National Forests. About 20,000 acres in the HDs were classified as roadless as part of this national inventory. However, the HDs were not included in the Colorado Wilderness Act of 1980, and the area was released for multiple-use management. Large portions of the HDs were leased for oil and gas development after the USGS identified the area as having high potential for development of oil and gas resources.
  • Although the Clinton Administration issued the Roadless Area Conservation Rule in 2001, strengthening protections for areas included in the RARE inventories, such as the HDs, the rule protected the right to develop existing leases for oil and gas resources.

What are the Alternatives for development considered in the Draft EIS?

• Alternative 1: Companies’ Proposed Action
  • 273 well pads
  • 118 road miles
  • 1,113 impacted acres
• Alternative 1A: Reduction of Surface Impacts (Preferred Alternative)
  • 211 well pads
  • 94 road miles
  • 965 impacted acres
• Alternative 1B: Reduction of Surface Impacts
  • 158 well pads
  • 62 road miles
  • 690 impacted acres
• Alternative 2: Maximum Development
  • 499 well pads
  • 203 road miles
  • 1,843 impacted acres
• Alternative 3: No New Development in HD Mountains Roadless Area
  • 212 well pads
  • 78 road miles
  • 756 impacted acres
• Alternative 4: Proceed Under Existing Guidance (following Interim Criteria and USFS/BLM planning documents)
  • 185 well pads
  • 91 road miles
  • 766 impacted acres
• Alternative 5: No Action (no development on federal lands or of federal minerals)
  • 117 well pads
  • 39 road miles
  • 422 impacted acres

How can I find out more?

The Draft EIS covers each of these issues in great detail. CD copies of the document are available by calling or stopping by the San Juan Public Lands Center, 15 Burnett Court, Durango (970 247-4874), or the Columbine Public Lands Office, 367 Pearl Street, Bayfield (970 884-2512).  Because the EIS is very large, handing out hard copies is cost prohibitive, and limited copies will be available. The document may be viewed on the Web at www.fs.fed.us/r2/sanjuan or www.nsjb-eis.org.

How are Applications for Permit to Drill (APDs) handled in the EIS?

The NSJB EIS represents both a programmatic and site-specific NEPA document. This means it studies both the overall development scenario in the project area as well as site-specific NEPA proposals for individual well pads. The proponents have submitted 56 APDs that are studied specifically in the EIS.  Those received in the future would go through an abbreviated NEPA process tiered to the EIS. 

How does BLM lease federal lands for energy development?

Leasing of energy resources is a decision made by the Department of Interior, through BLM, which has authority to manage minerals on federal lands. In the analysis area, almost half of the subsurface mineral estate is administered by BLM through the auspices of the Mineral Leasing Act and Mineral Leasing Act for Acquired Lands, Federal Onshore Oil and Gas Leasing Reform Act, Federal Coal Leasing Amendments Act, Mining and Mineral Policy Act, National Materials and Mineral Policy, Research and Development Act, Energy Security Act.  

How is the USFS involved in energy leasing, development and production?

USFS is responsible for managing surface impacts of energy projects when they occur on National Forest lands. The decision as to what areas are available to lease is based on Forest Plans. Once an area is offered for lease, USFS provides concurrence to BLM, based on NEPA analysis. USFS also follows full NEPA disclosure and public notice and comment for later proposals for exploration, development, and production.  Agency line officers are the field-level decision makers. Laws that govern management of energy resources on National Forests include the National Environmental Protection Act, Mineral Leasing Act, National Environmental Policy Act, National Forest Management Act, Endangered Species Act, Clean Water Act, Clean Air Act.

What does the government receive in return for leasing of federal minerals?

The federal government receives a 12.5% royalty assessed on all production, bonus bids, and annual rentals. In 2000, the federal government received about $146 million from royalties on coal, hard rock, and fluid minerals leasing of NFS lands (a mineral value of about $1.35 billion). USFS does not receive any of these monies directly.

 -BLM-