drilling in the rocky mountains:

SSCCIIEENNCCEE FFRROOMM

THE WILDERNESS SOCIETY

AnalysisEc

onom

ic

Drilling in the RockyMountains:How Much andat What Cost?

Our MissionSince 1935, The Wilderness Society has worked to preserveAmerica’s unparalleled wildland heritage and the vast storehouse ofresources these lands provide. From the threatened tupelo and cypressforests of the Southeast to critical grizzly bear and wolf habitat in theYellowstone-to-Yukon corridor to the incomparable, biologically richArctic, The Wilderness Society has forged powerful partnerships withmembers and friends across the country to conserve interconnectedlandscapes for our nation. We want to leave a legacy rich in thebiological diversity and natural systems that nurture both wildlife andhumans alike.

Headquartered in Washington, D.C., the Society also maintains nineregional offices where our staff address on-the-ground conservationissues linked to local communities. Since spearheading passage of theseminal Wilderness Act in 1964, we have been a leading advocate forevery major piece of Wilderness legislation enacted by Congress, workthat is supported by an active membership of more than 200,000committed conservationists. Our effectiveness stems from a teamapproach to conservation, which links our scientists, policy experts,and media specialists to thousands of grassroots activists — creating apotent force to promote change.

Building the case for land preservation with tactical research andsound science is the key to successful environmental advocacy andpolicy work. Nearly a quarter century ago, The Wilderness Societyhelped pioneer strategies that incorporated expert economic andecological analysis into conservation work. Today, through focusedstudies, state-of-the-art landscape analysis — and diligent legwork byour many partners who provide us with on-site data — our Ecologyand Economics Research Department is able to serve the needs of the larger conservation community.

Legislators, on-the-ground resource managers, news reporters, ourconservation partners, and — most importantly — the American people must have the facts if they are going to make informeddecisions about the future of this nation’s vanishing wildlands. Theanswers to the pressing legal, economic, social, and ecologicalquestions now at issue are the stepping stones to that understandingand, ultimately, to achieving lasting protection for the irreplaceablelands and waters that sustain our lives and spirits.

Drilling in the Rocky Mountains:How Much and at What Cost?

ByPete Morton, Ph.D.

Chris WellerJanice Thomson, Ph.D.Michelle Haefele, Ph.D.

andNada Culver


DRILLING IN THE ROCKY MOUNTAINS

Acknowledgments We express our deepest thanks to The Aspenwood Foundation for its generous

financial support of our conservation science program in the Northern Rockies, aswell as to The William and Flora Hewlett Foundation for its support of our BLM Program. We also thank the Environmental Systems Research Institute (ESRI) for itsongoing donation of state-of-the-art GIS software to The Wilderness Society.

We would like to thank Jim Mosher and the Wildlife Management Institute forinviting us to present our research at the 69th North American Wildlife and NaturalResources Conference, and Jennifer Rahm for reviewing and editing an earlier versionof this paper. We also thank Deanne Kloepfer for her editing magic on past reportswhich form the basis for this paper, and Mitchelle Stephenson for her skillful designand formatting of this report. And finally, we would like to thank all thephotographers who graciously allowed us to reprint their photos.

Citation

Morton, P., Weller, C., Thomson, J., Haefele, M., & Culver, N., 2004. Drilling in theRocky Mountains: How Much and At What Cost. The Wilderness Society,Washington, DC, 33 pages.

This paper was presented atthe 69th North American

Wildlife and NaturalResources Conference,

Spokane, WA, March 2004.The transactions from

the conference are availablefrom the Wildlife

Management Institute.

Design/format: Mitchelle Stephenson

Printed in the United States of America by The Printing Network

on recycled paper.

1615 M Street, NWWashington, DC 20036

Tel: 202-833-2300Fax: 202-454-4337

Web site: www.wilderness.org

This science report is one of a series that stems fromconservation research studies conducted by The Wilderness Society’s Ecology andEconomics Research Department. Other reports in theseries that focus on issues relevant to this report include:- FFrraaggmmeennttiinngg OOuurr LLaannddss:: The Ecological Footprint fromOil and Gas Development (A Spatial Analysis of aWyoming Gas Field)- EEnneerrggyy && WWeesstteerrnn WWiillddllaannddss:: A GIS Analysis of Eco-nomically Recoverable Oil and Gas - WWiillddlliiffee aatt aa CCrroossssrrooaaddss:: Energy Development inWestern Wyoming

These reports and related Science & Policy Briefs areavailable on The Wilderness Society’s web site<www.wilderness.org> and from The Wilderness Society,Communications Department, 1615 M Street, NW, Washing-ton, DC 20036 (202-833-2300 or 1-800-THE-WILD).

PPAAGGEE ii

Preface Part of the Bush Administration’s National Energy Plan was Executive Order

13212, which required federal land management agencies to expedite their review ofoil and gas drilling permits, open up millions more acres of public land to explorationand drilling, and remove “constraints” on drilling such as lease stipulations designedto protect fish and wildlife. The explicit and implicit assumptions driving this newenergy policy were seldom questioned.

To date the distinction between technically recoverable gas—just being able to getthe resource out of the ground—and economically recoverable gas, a profitable ven-ture, has been largely ignored by the Bureau of Land Management (BLM). Conse-quently, government estimates of the energy potential from public wildlands are gross-ly exaggerated. Also missing from the cost/benefit equation is a full accounting of thenon-market costs of extraction, including soil erosion, loss of wildlife and fish habitat,the decline in recreational experiences, a proliferation of noxious weeds, andincreased air and water pollution.

In The Wilderness Society’s report, Drilling in the Rocky Mountains: How Muchand at What Cost?, economist Pete Morton, Ph.D., along with a team of legal, eco-nomic and GIS mapping experts examine the real price this country is paying forunfettered energy development. First presented at the 2004 North American Wildlifeand Natural Resources Conference held in Spokane, Washington, the paper focuseson national forest roadless areas and national monuments administered by the BLMand estimates the actual amount of gas and oil available from these sites. Its findingsalso include spatial metrics that analyze the road density within Wyoming’s oil andgas fields, demonstrating the high ecological costs of drilling, which fragments wildlifehabitat, displaces species, and interrupts breeding and migratory patterns.

Our research explores the wide range of hidden economic costs resulting fromaccelerated, large-scale energy production. Far too often federal agencies fail toenforce lease stipulations, waiving rules meant to safeguard birds and wildlife by stat-ing where, how, and when drilling may occur. The enormous amounts of saline-sodicwater pumped from aquifers for coal bed methane gas operations is wreaking havoc onwater quality and aquatic species throughout the region. And rural communities mayfeel the economic pinch when hunters, anglers and tourists stop spending moneybecause wildlife have been pushed out by sprawling networks of pipelines and wells.

As the scale and speed of drilling increase, so do the risks to the West’s greatestasset: its natural environment. In the absence of sufficient data, adequate budgets tomonitor what is happening on the ground, and sound analyses of the cumulativeimpact of such activities, this risk will surely grow. A recent report by the Govern-ment Accountability Office (GAO) bolstered our arguments by concluding that theBLM is spending too much time issuing drilling permits to the detriment of protectingthe environment, as required by law.

Our nation should heed these warning signs and implement public land policiesthat are balanced and grounded in sound science. Only then will we be able to sus-tain our wildest landscapes into the future.

William H. Meadows G. Thomas Bancroft, Ph.D.President Vice President

The Wilderness Society Ecology and EconomicsResearch Department

PPAAGGEE iiii

IntroductionPPAAGGEE 33

TerminologyPPAAGGEE 44

Estimating theOpportunity Costs of Protecting Wildlife Habitat

PPAAGGEE 55

Drilling the Rocky Mountains:How Much Gas?

PPAAGGEE 66

Drilling the Rocky Mountains: At What Cost?

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RecommendationsPPAAGGEE 1188

Conclusions

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ReferencesPPAAGGEE 2277

CCoonntteennttss

DRILLING IN THE ROCKY MOUNTAINSPPAAGGEE iiiiii

PPAAGGEE 33

IntroductionThe Wilderness Society is a 200,000-

member national conservation groupthat focuses on public land managementissues. Wilderness Society scientists con-duct energy research and regularly pre-sent the results at congressional hearingsand other forums. Our research is guidedby the need to examine the explicit andimplicit assumptions that underlie theNational Energy Plan unveiled by theBush administration in May 2001.Among other things, the plan called forthe opening of additional public land inwestern states to gas and oil drilling andrequired a review of lease stipulationsthat protect fish and wildlife. ExecutiveOrder 13212 required federal land man-agement agencies to expedite theirreview of gas and oil drilling permits, anda new White House task force was estab-lished to oversee agency efforts to speedup the permitting process.

In this paper, we first define terms toestablish economically recoverable ener-gy resources as the policy-relevant mea-sure in evaluating the energy potential ofpublic lands. Next, we provide estimatesof the amount of gas and oil in westernwildlands, focusing on roadless areas in

national forests andin national monu-ments administeredby the Bureau ofLand Management(BLM). We thenexplore: 1) the coststo wildlife from ener-gy development,specifically, habitatfragmentation; 2) thefailure to enforcelease stipulations; 3)the damage to waterquality and aquaticspecies associatedwith development ofcoal bed methanegas; 4) the hiddencosts to the regionaleconomy; and 5) thehigh risks of acceler-ated large-scale ener-gy development in the absence of suffi-cient data and cumulative impact analy-ses. We conclude with recommendationsfor federal agencies to heed the risks towildlife, regional economies, and thepublic that are posed by the administra-tion’s plans for large-scale drilling of pub-lic land in the Rockies.

In this report, we explore:1. the amount of gas and oil in national

forest roadless areas and nationalmonuments administred by the Bureau ofLand Management (BLM);

2. the costs to wildlife from energydevelopment, specifically, habitatfragmentation;

3. the failure to enforce lease stipulations;

4. the damage to water quality and aquaticspecies associated with development ofcoal bed methane gas;

5. the hidden costs to the regional economy;and

6. the high risks of accelerated large-scaleenergy development in the absence ofsufficient data and cumulative impactanalyses.

PPAAGGEE 44

TerminologyThe debate over energy development

on western public lands centers ondrilling for methane (natural) gas, alsothe primary focus of this paper. Scientistsat the U.S.Geological Survey (USGS)classify natural gas as conventional orunconventional, partially based on thetechnology used during extraction.Unconventional gas typically has higherproduction costs because it requires a sig-nificant degree of stimulation - hydraulicfracturing, for example - to attain suffi-cient levels for economically profitableproduction (EIA 2001a).

The two main unconventional gasesare coal bed methane and continuous-type gas, commonly called tight sandsgas. Coal bed methane is a form of natur-al gas trapped within coal formations,while tight sands gas is trapped in lowpermeability sandstone. In the Rockies,92 percent of the undiscovered techni-cally recoverable gas on federal land isunconventional gas, primarily tight sandsgas (USDOI and USDOE 2003). There

is a clear distinction between discoveredgas reserves - known to be both techni-cally and economically recoverable - andundiscovered gas resources that are notyet proven to be either technically oreconomically recoverable. This distinc-tion is important, given the current pres-sure to develop the higher risk, undiscov-ered resources on public wildlands.

To estimate quantities of undiscoveredresources, USGS makes a distinctionbetween gas in place, technically recov-erable gas, and economically recoverablegas (Figure 1). Gas in place that is esti-mated to exist in sufficient quantities forrecovery with current technology, butwithout regard to profit or extractioncosts, is called technically recoverablegas. Technically recoverable gas that isestimated to be profitable to extract iscalled economically recoverable gas. Thecosts that USGS uses to assess economi-cally recoverable gas and oil include thedirect costs of exploration, development,and production at the wellhead, plus aprofit margin (Root et al. 1997, Attanasi1998). To account for the uncertaintyinherent in price forecasts, USGS uses arange of prices, rather than a single-pointestimate. USGS estimates do not includeinfrastructure costs, the costs of trans-porting the gas to market, non-marketcosts such as loss of local economic ben-efits from lower quality hunting, fishing,and camping experiences, or off-site mit-igation costs like increased water treat-ment costs. If USGS included these hid-den costs, the estimated amount of eco-nomically recoverable gas in the Rockieswould be lower.


tIn the Rockies, 92percent of theundiscoveredtechnicallyrecoverable gas onfederal land isunconventional gas,primarily tight sandsgas.s

FIGURE 1. Gas Volumes and Probabilities for Estimating Undiscovered Quantities

There is a 95 percent chance of at least V1 of economically recoverable gas, anda 5 percent chance of at least V3 of economically recoverable gas. Adapted from the U.S. Geological Survey 2001.

V2 V3V1

Prob

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Volume of gas increasing fi

PPAAGGEE 55

Estimating the Opportunity Costs of Protecting WildlifeHabitat

The opportunity cost of a policy oraction that protects wildlife habitatequals the net benefits that are foregoneas a consequence of that policy or action.With respect to energy policy, the oppor-tunity cost to protect critical wildlifehabitat or native fisheries is the amountof economically recoverable gas that isforegone as a result of such actions - notthe amount of gas that is technicallyrecoverable. As recommended by theCongressional Research Service (Corn etal. 2001), economically recoverableresources should be the basis of policyanalysis. If economic constraints on gasproduction are ignored, resource assess-ments will overestimate the quantity ofgas that is potentially off limits becauseof its location in a migratory corridor orroadless area.

USGS estimates that less than 20 per-cent of technically recoverable gas in theRockies is economically recoverable

when prices (adjusted to2001 dollars) are between$2.30 and $3.90 per thou-sand cubic feet (mcf)(Table 1). Before recentprice spikes, $2.00 permcf was viewed as thelong-term price for natur-al gas (EIA 2001b). Cur-rent projections suggestthat natural gas wellheadprices will decline fromthe high levels of 2003(around $5 per mcf) to$3.40 per mcf (2002 dol-lars) in 2010, then rise to$4.40 per mcf in 2025(EIA 2004). The priceprojected in 2010 is slightly lower, whilethe price projected in 2025 is slightlyhigher, than the USGS high price sce-nario. As with any long-term price fore-cast, uncertainty is large. If actual pricesare higher (lower) than the USGS highprice scenario, the amount of gas eco-nomically recoverable is likely toincrease (decrease) from our estimatescited here.

TABLE 1. Economic recovery rates for Technically Recoverable Gas in the United States*

Region USGS Economic Recovery Ratesa

United States 38 - 46%Rockies and Northern Plains 13 - 18%Southwestern Wyoming 1 - 5%aPercent of technically recoverable gas in reservesand gas left undiscovered that is profitable to extract(before accounting for environmental-related costs).Excludes recovery rates for offshore gas. Sources: Root et al. 1997, Attanasi 1998, andLaTourrette et al. 2002.

*based on prices of $2.30 and $3.90 (2001$) perthousand cubic feet (mcf).

The Book Cliffs along the Colorado-Utah border capture the floristic splendor of montane forests andthe stark subtleties of the high deserts of the Colorado Plateau.

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PPAAGGEE 66DRILLING IN THE ROCKY MOUNTAINS

Drilling the Rocky Mountains: How Much Gas?

In January 2001, The Wilderness Soci-ety assessed the energy potential on

western federal lands (Morton 2002a).We used government data (USGS1996a, Attanasi et al. 1998) to completea geographic information system (GIS)analysis of the overlap between the

boundaries of 200 gas and oil playsand the boundaries of westernwildlands (Figure 2). We focusedour analysis on national forestroadless areas in six Rocky Moun-tain states (Montana, North Dako-ta, Wyoming, Utah, Colorado, andNew Mexico) and in 15 nationalmonuments managed by the BLMin Oregon, California, Idaho,Utah, Montana, Colorado, NewMexico, and Arizona. We usedUSGS (1996a) mean estimates oftechnically recoverable gas and oilbecause we believe that USGSestimates represent the best, unbi-ased estimate available. We devel-oped economic recovery ratesbased on cost functions for gas-oilprovinces (Root et al. 1997,Attanasi 1998) and reported ourresults using both a high and lowprice scenario. For details, seeMorton et al. (2002a).

Using the USGS low-end andhigh-end prices, we found thatnational forest roadless areas in theRockies contain approximately 3.9trillion cubic feet to 4.9 trillioncubic feet of economically recover-able gas (Table 2), or 48 percent to59 percent of the technicallyrecoverable gas in the roadlessareas.

The roadless areas containapproximately 410 million to 478million barrels of economicallyrecoverable oil, or 69 percent to 81percent of the technically recover-able oil. National forest roadlessareas in Wyoming and Coloradocontain the majority of economi-cally recoverable gas and oil, muchof which is located in Bridger-Teton National Forest south of

FIGURE 2.

National Forest Roadless Areas and Lands with Oil and Gas Potential in Six Rocky Mountain States

Lands with oil and gas potential

Inventoried roadless areas

North DakotaMontana

Wyoming

Utah

Colorado

New Mexico

0 100 200 milesPotential gas and oil resources and roadless areas in six Rocky Mountain states. National forest roadless areas account for less than 4 percent of the land that has gas and oil potential.

Data obtained from the U.S. Forest Service and the U.S. Geological Survey.

N

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Jackson Hole, Wyoming, and San JuanNational Forest near Durango, Colorado.Based on total demand for gas and oil inthe United States and on current energyconsumption rates, economically recov-erable gas in the roadless areas wouldmeet total U.S. gas consumption for 2-2.5 months. Economically recoverable oilin the roadless areas would meet totalU.S. oil consumption for 21-24 days.Obviously, the gas would be producedover a much longer period of time, butthese estimates provide an indication ofthe relatively small amount of economi-cally recoverable gas and oil in nationalforest roadless areas.

The 15 national monuments containless than 15 days of oil and 6 days of gas.Even this small amount is overestimated,however, because spatial inaccuracies inthe GIS layer make it impossible to sepa-rate energy resources under ocean watersadjacent to the California CoastalNational Monument. If a more accurateboundary were used, the amount of gasand oil in the California Coastal Nation-al Monument as well as the total for allmonuments would drop dramatically.

Additional analysis of government dataindicate that across the country, develop-ment of undiscovered gas and oilresources on federal lands - nationalparks, national forests, lands managed byBLM, and national wildlife refuges(including the Arctic National WildlifeRefuge) - would satisfy U.S. demand forgas and oil for less than 2 years (Attanasi

1998, Minerals Management Service2001, Morton et al. 2002a). In contrast,the gas and oil supply already discoveredin proven reserves, along with theexpected growth of those reserves, is pro-jected to meet U.S. demand for oil for 15years and gas demand for 21 years(Attanasi 1998, MMS 2000). If we makestrategic investments in energy conserva-tion, energy efficiency, and alternativeenergy sources, the gas and oil in ourproven reserves will last even longer.

TABLE 2. Estimates of Gas and Oil in National Forest Roadless Areas in Six Rocky Mountain Statesa

Resource Economically recoverable Economically recoverable as Economically recoverable inQuantity % of technically recoverable relation to total U.S. consumption

Conventional gas 3,223 - 3,665 billion cubic feet 74% - 84% 52 - 59 daysTight sands gas 199 - 285 billion cubic feet 8% - 11% 3 - 5 daysCoal bed methane gas 500 - 943 billion cubic feet 41% - 77% 8 - 15 daysTotal Gas 3,922 - 4,893 billion cubic feet 48% - 59% 63 - 79 daysOil and natural gas liquids 410 - 478 million barrels 69% - 81% 21 - 24 daysaMontana, North Dakota, Wyoming, Utah, Colorado, and New Mexico

Pump jack in the midst of scenicredrock canyons at the rim of

Bull Canyon, in Moab, Utah. Thearea is administered by the BLM

and is just outside the Goldbarproposed wilderness area.

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Drilling the Rocky Mountains: At What Cost?

An economic analysis of recoverablegas must include a full accounting of thenon-market costs in addition to thosemore readily observed and measured inmarket prices (Loomis 1993). Non-mar-ket costs include erosion, loss of wildlifeand fish habitat, decline in quality ofrecreational experiences, proliferation ofnoxious weeds, and increased air andwater pollution. While difficult to valuein traditional monetary terms throughstandard cost-benefit analyses, thesecosts are nonetheless very real. Here we

will focus on the costs associated withthe loss and fragmentation of habitatassociated with energy development.

Habitat Fragmentation fromDrilling: The View from Above

Amos (2003) used historical Landsatsatellite imagery to show the temporaldevelopment of the ecological footprintfrom gas drilling in the Jonah Field inWyoming. Figure 3 shows undisturbedsagebrush and grassland habitat prior todrilling in 1986. In 1998, the BLMapproved full field development of 497wells to be drilled over 10 to 15 years,with a maximum drilling density of onewell per 80 acres (8 pads per squaremile). Figure 4 shows the same area in1999 with 100 gas wells drilled andembedded in a web of access roads, wastepits, and pipelines that were clearly visi-ble from space. In 2000, two years afterthe management plan was completed,BLM approved spacing of one well per40 acres (16 pads per square mile). By2002, nearly 400 wells had been drilled(Figure 5), approaching the maximumnumber projected in the 1998 manage-ment plan. By 2003 more than 500 wellshad been drilled, and industry requesteda plan revision allowing 1,250 additionalwells from 850 new well pads, with wellspacing of just 16 acres and a drillingdensity of 40 wells pads per square mile(Amos 2003).

Habitat Fragmentation fromDrilling: Quantifying theLandscape Impacts

The satellite images illustrate the lossand fragmentation of habitat associatedwith drilling. Fragmentation of habitat iswidely acknowledged as detrimental tomany plant and wildlife species, includ-ing birds, but there are few studies thatexamine the exact size and extent of theecological footprint of energy develop-ment. Spatial analysis can help fill thisinformation gap.

In 2002, scientists at The WildernessSociety completed a habitat fragmenta-tion analysis of the Big Piney-LaBarge oil


Ariel view of the fragmentationof wildlife habitat caused bydrilling in the Upper GreenRiver Valley of Wyoming.

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and gas field in the Upper Green RiverValley of Wyoming (Weller et al. 2002).The valley is home to at least 25 specieslisted as threatened or endangered,including the Bald Eagle (Haliaeetus leu-cocephalus), Mountain Plover(Charadrius montanus), NorthernGoshawk (Accipiter gentilis) and Pere-grine Falcon (Falco peregrinus), and it iswintering ground for elk (Cervus ela-phus), pronghorn antelope (Antilocapraamericano), and mule deer (Odocoileushemionus) (BLM 2001).

As of 1990, the Big Piney-LaBarge gasfield had a total of 1,864 drilled wells, ofwhich 1,080 were still active (BLM1990). The field has produced oil and gasin the past, but current production is pri-marily tight sands gas. To complete ourstudy, we generated infrastructure datathrough on-screen digitizing of 12 digitalorthophoto quads, then quantified thedegree of habitat fragmentation usingthree landscape metrics: linear featuredensity (primarily roads and pipelines),habitat in the infrastructure effect zone,and the amount of habitat in core areas(interior habitat that is remote frominfrastructure). (See Weller et al. 2002for more detail.)

Linear feature densityLinear feature density was calculated

both as an average for the entire studyarea and as a series of one- mile2 andfour- mile2 sampling windows across thelandscape. Measuring density in samplingwindows of different sizes provides anunderstanding of the variability of densi-ty across scales, which is important togauge the effects on different species(Urban et al. 1987, Wiens and Milne1989, Turner et al. 1994). For example,differences in dispersal distances amongspecies cause them to respond to habitatfeatures at different scales.

The overall area of oil and gas infra-structure (roads, pipelines, pads, wastepits, etc.) at Big Piney-LaBarge covers 7

FIGURE 3.

1986 — Prior to DrillingThe area of the Jonah GasField in Wyoming, showing theundisturbed sagebrush andgrassland habitat prior todrilling in 1986

Source: Amos 2003.

FIGURE 4.

1999 — After One Yearof DrillingThe Jonah Gas Field in 1999after one year of full-fielddevelopment at 80-acre spac-ing (8 well pads per squaremile) using state-of-the-artdrilling technology. The web ofwells pads, access roads, com-pressor stations and waste pitsis clearly visible.

Source: Amos 2003.

FIGURE 5.

2002 — Nearing theMaximum under the1998 Management PlanThe Jonah Gas Field in 2002,after nearly 400 wells havebeen drilled at 40-acre spacing(16 well pads per square mile),approaching the maximumnumber allowed by the 1998management plan. Industry isnow asking for 1,250 addition-al wells from 850 new wellpads, resulting in 16-acre wellspacing (40 well pads persquare mile).

Source: Amos 2003.

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miles2 of habitat, or 4 percent of thestudy area (Figure 6). Our results indi-cate a direct physical footprint of 1,400miles of linear features and 3.8 square

miles of polygon features, resulting in anoverall density of 8.43 miles of roads andpipelines per mile2. This density is atleast three times greater than road densi-ties on national forests in Wyoming,South Dakota, and Colorado and is“extremely high” based on ratings in theInterior Columbia Basin Ecosystem Man-agement Plan (Forest Service 1996).

Linear feature density estimates arescale dependent and vary across thestudy area, ranging from 17.1 miles permile2 to 0.9 miles per mile2 (Figure 7).At all scales analyzed, most grid cellshave a density between 3 and 6 miles permile2. Twenty-nine percent of the land-scape in the one- mile2 scenario, and 24percent of the landscape in the four-mile2 scenario, have linear densities ofmore than 6 miles per mile2.

Infrastructure effect zoneThe ecological effects of infrastructure

features extend across the landscapebeyond physical structures of the oil orgas field. Forman (1999) calls the influ-ence on edge environments parallel toroads the “road effect zone.” We extend-ed this zone of influence to all forms ofinfrastructure and completed the effectzone analyses using widths of one mile,one-half mile, one-quarter mile, 500 feet,250 feet, and 100 feet. Results of theinfrastructure effect zone analyses showthat the entire 166-mile2 study area iswithin one-half mile of a road, wellhead, pipeline, compressor station, wastepit, or other component of the infra-structure involved in oil and gas drilling.One hundred and sixty miles2 - 97 per-cent of the landscape - fall within one-quarter mile of the infrastructure.

Core area analysisAnother commonly used measure for

landscape fragmentation is core area,sometimes referred to as interior habitat.Core areas exist in natural landscapes ascontiguous blocks of uniform habitat


FIGURE 6.

The “Physical Footprint” of Oil and Gas Development in the Big Piney-LeBarge Field

The digitized physical footprint from oil and gas development in the Big Piney-LaBarge field, Wyoming. The footprint includes both linear infrastructure featuressuch as roads and pipelines, and polygonal features such as well pads, pumpingstations and waste pits.

Polygonal infrastructureLinear infrastructure

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types away from natural breaksor habitat edges. For our analy-sis, we examined habitat patcheson the landscape outside of theinfrastructure effect zones. Ourresults show that for the entirestudy area, no core areas existfarther than one mile from theinfrastructure. Only 27 percentof the study area is more than500 feet from infrastructure, andonly 3 percent is more than one-quarter mile away (Figure 8).

Habitat Fragmentationfrom Drilling: The HiddenCosts to Wildlife

Without access to populationor habitat data, we examined thehabitat costs to wildlife from oiland gas development by con-necting the results of our spatialanalysis to spatial metrics foundin the scientific literature.Numerous studies document thatelk avoid roads. Lyon (1983)found that when road densitiesare two miles per mile2, elk canbe displaced from up to 50 per-cent of their habitat. When road densi-ties exceed five to six miles per mile2, elkcan be displaced from 75 percent of thehabitat. Roughly a quarter of our studyarea falls within the latter category.

Road avoidance by wildlife is evidentin open landscapes with little surround-ing vegetation (Perry and Overly 1976,Morgantini and Hudson 1979, Rost andBailey 1979). In areas with little cover,habitat is compromised at a road densityof only 0.8 miles of road per mile2 (Lyon1979). A study on elk habitat effective-ness in north central Wyoming foundthat fewer elk used areas with road densi-ties higher than 0.5 miles per mile2

(Sawyer et al. 1997). Our results indicatethat most of our study area has linearfeature densities much higher than 0.5 or0.8 miles per mile2. Another study in

western Wyoming indicates that elkavoid a relatively high-density oil andgas field in open habitat (Bock andLindzey 1999). The lack of physical bar-riers to screen drilling activities has dis-placed elk up to three miles.

Wyoming has the greatest concentra-tion of pronghorn antelope in any stateor provincial authority in North Ameri-ca, and the Green River Valley holds thehighest concentration of this animal inWyoming (BLM 2000). With respect topotential impacts, antelope in the nearbyWhitney Canyon-Carter Lease fields feltthe impacts of oil and gas projects with“nearly one mile of road per every squaremile of occupied habitat” (BLM 1999).Our study area has average linear featuredensities more than eight times greaterthan one mile per square mile.

FIGURE 7.

Density of Linear Features Associated with Oil and Gas Development

Density of linear features, Big Piney-LaBarge oil-gas field, Wyoming. The density of linear infra-structure features was calculated using both a 1-square mile grid and a 4-square mile grid. Lin-ear feature density ranges from 17.1 – 0.9 miles per square mile. The darker the shading, thehigher the linear feature density.

Based on a one-square-mile grid

Density (miles-square miles)0-33-66-9>9

Based on a four-square-mile grid

The bulk of the study area is designat-ed as winter habitat for mule deer (BLM1990), an animal that also avoids oil andgas development in their habitat. Astudy conducted in North Dakota foundthat mule deer avoided areas within 300feet of well sites for feeding and bedding,resulting in a 28 percent reduction insecure bedding areas, and that thisbehavior continued for more than 7years (Jensen 1991).

Wildlife species other than big gameanimals also face the impacts of infra-structure. Wyoming is home to thelargest and most robust North Americanpopulation of the Greater Sage-grouse(Centrocercus urophasianus), a bird thatis facing severe declines in populationsbecause of habitat loss (Christiansen2000). Approximately two-thirds of the

150 leks (breeding grounds)for this species in Wyomingare located in Upper GreenRiver Valley (BLM 1999). Astudy in Wyoming found thatthe negative effects of oil andgas development on nest-initi-ation rates of Greater Sage-grouse can extend for 2 milesbeyond the infrastructure(Lyon 2000). Given ourresults, there is no place in theBig Piney-LaBarge gas fieldwhere the Greater Sage-grousewould not be affected by nat-ural gas development.

Lease Stipulations HelpProtect Wildlife: ButOnly if they are Enforced

As part of the oil and gasleasing process, BLM or ForestService officials may subjectthe leases to environmentalstipulations that are meant toprotect birds and wildlife bystating where, how, and whendrilling activities may occur.Lease stipulations, designed byagency professionals, may

include seasonal closures of critical habi-tat to benefit wildlife such as elk, ante-lope, and sage grouse; no surface occu-pancy provisions to protect sensitivehabitats, campgrounds and recreationareas; and controlled use provisions toprotect endangered species, archaeologi-cal and other important cultural sites.Lease stipulations may offset the habitatfragmentation impacts from drilling, butonly if the stipulations are enforced.

A review of BLM stipulation exceptiondata for the agency’s Pinedale District inWyoming indicates that seasonal wildlifestipulations are waived quite frequently.Between 2001 and 2004, 86 percent ofthe raptor stipulations, 90 percent of thesage grouse stipulations, and 88 percentof the wildlife stipulations protectingwinter range were waived (BLM 2004a).


FIGURE 8.

Core Areas Beyond Infrastructure Effect Zone

Core areas beyond infrastructure effect zone, Big Piney-LaBarge oil-gas field, Wyoming. Twoexamples of core area maps based on 250-foot and one-quarter mile infrastructure effect zones.Only 3 percent of the study area is more than one-quarter mile away from gas-oil infrastructure.Shading represents the areas beyond relatively narrow and wide infrastructure effect zones.

Core areas beyond 250-foot effect zone Core areas beyond one-quarter-mile effect zone

An analysis in southwestern Wyomingindicates that the gas industry’s requeststo waive wildlife and fish stipulationswere granted 97 percent of the time(Trout Unlimited 2003). Many waiverswere issued during crucial winter monthswith no understanding or assessment ofthe impacts, owing to inadequate dataand monitoring by the BLM.

Of equal concern are lease stipulationsthat only apply during the drilling phase,not during the production phase, provid-ing at most a short-term positive effect.According to Noon (2002a):

...the nature of the proposed mitiga-tion efforts have only short-term posi-tive effects because they represent “tim-ing limitations” only... For example, elkcalving areas potentially disturbed byCBM projects have a seasonal closurefrom 5/1 - 6/30 in a given year. Afterthat time period, development activi-ties at a site near calving habitat maybe re-initiated. The end result is thatnext year there is a high likelihood thissite will no longer be suitable. This isnot meaningful mitigation. This policysimply delays an inevitable loss of habi-tat.... In my opinion, it is misleadingto refer to these policies as mitigationactions (emphasis added).

In addition, a recent BLM policy(Instruction Memorandum #2003-233,July 28, 2003) discourages the use of stip-ulations at all to protect wildliferesources and will likely mean that evenfewer leases will contain special stipula-tions to protect wildlife and wildlifehabitats.

Drilling for Coal Bed Methane:The Hidden Costs to Fish

While we focus here on wildlifeimpacts the potential negative impactsto water quality and aquatic species fromdrilling for coal bed methane may be sig-nificant. The Powder River Basin in thesemi-arid Great Plains region ofWyoming and Montana is a case inpoint. The river itself, without a majordam, is in relatively healthy shape. With

its four tributaries, it supports a rareinvertebrate fauna and 25 native fishspecies that are much less common nowthan in years past (Allan 2002). Accord-ing to Hubert (1993), “The fish commu-nity of the Powder River is unique...and... probably represents the kind ofcommunity that was found in free-flow-ing Great Plains rivers.” Since similarrivers in the region have been altered,there is a special responsibility to ensurethat drilling for coal bed methane(CBM) does not eliminate a critical rem-nant on a once vast and unspoiledecosystem (Allan 2002).

The Powder River Basin is currentlybeing targeted for tens of thousands ofcoal bed methane wells connected by anetwork of roads. Roads are the majorsource of sediment into streams.

Clements (2002) has the following con-cerns about the scale of CBM develop-ment proposed in the Draft Environmen-tal Impact Statement (DEIS) for thePowder River Basin in Wyoming:

[T]he DEIS has not given sufficientattention to the impacts of increasedsedimentation on aquatic ecosystems in

PPAAGGEE 1133

tBetween 2001 and

2004, 86 percent of the raptor

stipulations and 88 percent of the

wildlife stipulationsprotecting winter

range were waived.s

Sludge pit immediately adjacentto the Goldbar proposed

wilderness area. Moab, Utah.

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the project area. Increased sedimenta-tion resulting from erosion of streambanks, overland flow, and road con-struction will likely impact aquaticorganisms. ...Input of sediments toaquatic ecosystems is widely regardedas a major source of stream degradationin North America (Waters 1995). Inparticular, fine sediments fill interstitialspaces and reduce available habitat forfish and macroinvertebrates.

Water is the central issue surroundingdevelopment of coal bed methane. To“release” methane gas from coal beds,enormous amounts of saline-sodic waterfrom shallow and deep aquifers must bepumped to the surface. While waterquality and quantity vary by region,CBM wells in Wyoming have dischargedbetween 20,000 to 40,000 gallons perday per well. The dewatering phase typi-cally lasts 2-5 years. Schlesinger (2002)after reviewing the Montana StatewideDEIS concludes that “Clearly water fromCBM wells is likely to reach majorregional rivers” - raising concerns aboutpumping too much produced water into

streams. The altered water flows from thesurface release of the produced water willnegatively impact thermal and flowregimes, and likely contribute to bankerosion and changes in riparian vegeta-tion (Allan 2002). Gore (2002) warnedthat the loss of habitat caused byincreased water flows from dischargedwater at coal bed methane projects couldeliminate up to 30 aquatic species within20 years.

The water discharged by CBM produc-tion in the Powder River Basin is charac-terized with very high levels of salinityand total dissolved solids (TDS). Manyof the constituents that comprise totaldissolved solids are toxic to aquaticorganisms and have the potential to neg-atively impact aquatic resources. In par-ticular, discharge of high salinity andTDS effluents into receiving systems mayresult in physiologically stressful condi-tions for some species due to alterationsin osmotic conditions (Clements, 2002).It is well established that elevated con-centrations of major ions can reducewater quality and significantly impactfish and wildlife populations (Goetschand Palmer 1997, Dickerson and Vinyard1999, Pillard et al. 1999, Chapman et al.2000). Unfortunately, the Draft Environ-mental Impact Statement made noattempt to evaluate potential toxicologi-cal impacts of coal bed methane-pro-duced effluents on fish and macroinver-tebrates (Clements 2002). Dr. Clementsconcludes his critique with the followingopinion:

In summary, the Montana DEIS doesnot provide sufficient information toevaluate the potential risk... Based onmy analysis of information presented inthe DEIS and my best professionaljudgement, I expect that CBM pro-duced effluents and associated sedi-ments released into watersheds in theproject area will have deleteriousimpacts on benthic macroinvertebratesand fish.

DRILLING IN THE ROCKY MOUNTAINSPPAAGGEE 1144

In the Powder River Basin ofWyoming and Montana,proposals to drill tens of thousandsof coal bed methane wellsthreaten the river’s environmentaland economic viability.

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Drilling the Rocky Mountains:The Hidden Costs to the Regional Economy

The results of our fragmentation analy-sis, when combined with scientific con-cerns over water quantity and quality,indicate that large-scale drilling as cur-rently proposed on public lands will gen-erate substantial costs to fish and wildlife.This will, in turn, result in lost economicbenefits for Americans who enjoy view-ing wildlife, hunting, and fishing in apristine environment. Nationally, morethan 82 million Americans participate insome form of wildlife-related recreation(Fish and Wildlife Service (FWS) 2003).In the Rocky Mountain states of Col-orado, Wyoming, Montana, Utah, andNew Mexico alone, an estimated that 3.5million residents, or 49 percent of theregion’s entire population, hunt, fish, orwatch wildlife (FWS 2003). Thus, lossand fragmentation of wildlife habitatresulting from proposed, large-scaledrilling could negatively effect nearly halfof the region’s residents.

Development of oil and gas resourcescan also have negative impacts on com-munities where revenues from hunters,anglers, and wildlife watchers are a sig-nificant part of the economy. In theRockies during 2001, participants inwildlife-viewing activities spent nearly$2.3 billion for license fees, equipment,and other related purchases, whilehunters and anglers spent $3.6 billion(FWS 2002). If fragmentation of habitatfrom proposed oil and gas projects resultsin, say, declining elk populations and thedeclining elk populations result in alower-quality hunting experience, fewerhunters, and a drop in related spending,the overall negative economic effect forrural businesses and communities couldbe substantial.

The hidden costs associated with devel-opment of oil and gas resources can nega-tively impact other sectors of the econo-my. Air pollution arising from gas com-

pressors contributes to regional ozoneproblems and, when combined with dustfrom roads, creates regional haze and acorresponding decline in visibility(Yuhnke 2002). Loss of, or decline in, thequality of scenic landscapes and view-sheds could hurt the region’s billion dol-lar tourism industry as well as potentialeconomic growth stemming from engi-neering firms, business consultants, andretirees if they chose to locate somewhereelse where the air is cleaner. A growingbody of literature suggests that futurediversification of rural western economiesdepends to a large extent on “amenityservices” such as watershed protection,wildlife habitat, and scenic vistas thatpublic lands provide (Rasker 1995, Power1996, Haynes and Horne 1997, Morton1999). Public lands improve the qualityof life for retirees and a trained and edu-cated workforce capable of attracting newbusinesses and capital to communities.Expediting large-scale oil and gas drillingon public land threatens the comparativeeconomic advantage that amenities onpublic lands provide for nearby communi-ties (Morton et al. 2002b).

Drilling the Rocky Mountains: The Environmental Risks are High

In order to protect the West’s greatestasset - our environment, we mustimprove the science behind adaptivelymanaging our public lands, especially ouroil and gas resources. Improving the sci-ence is vital as expert assessments (Allan2002, Braun 2002, Clements 2002, Gore2002, Noon 2002a, Noon 2002b,Schlesinger 2002, Western EcoSystemsTechnology 2002) reveal that theimpacts from proposed oil and gasdrilling in the Rockies will be widespreadand negative, posing high risks for theenvironment, wildlife, local economies,and our quality of life. We expect therisks to be large due to the speed and thelarge scale of the proposed drilling, the

tAir pollution

arising from gascompressors

contributes toregional ozone

problems and, whencombined with dustfrom roads, creates

regional haze and acorresponding

decline in visibility.s


poor state of scientific knowledge aboutthe environmental impacts from drilling,and the fact that the BLM has inadequatestaffing levels, poor baseline data, andinsufficient budgets to inventory, analyzeand monitor resource conditions.

The Environmental Risks Increase with Scale

As the scale and speed of drillingincrease, so does the environmental risk,particularly when baseline data are limit-ed or non-existent. The administration iscurrently expediting drilling plans fortens of millions of acres in the West,despite the fact that drilling for oil andespecially natural gas is already at a prettylarge scale. In the Rockies, public landmanaged by the BLM has more than53,000 producing oil and gas wells (BLM2003a). Nationally the BLM has about33 million acres of federal minerals (pub-lic and split estate) under lease to indus-try (BLM 2002). The BLM oversees54,000 oil and gas leases, with only 40%of the leases currently producing gas oroil (BLM 2002, BLM 2004b). InWyoming there are over 21,000 federaloil and gas leases, covering approximately15 million acres of federal land (Bennett

2003). In 2002,only 3.6 millionacres of federalland in Wyomingwere in produc-tion (BLM 2003)- illustrating thelarge scaledrilling potential(i.e. drillingopportunities)currently avail-able to industry.If leaseholdersplace the current

inventory of non-producing leases into oilor gas production, the scale of drilling onpublic lands will increase dramatically -even without any additional leasing.Between 2000 and 2003, more than

46,000 drilling permits were issued forpublic and private lands in the five RockyMountain States (Rig Data 2004). It isdifficult to understand why, with the largescale drilling currently occurring, there isa need to speed up the process of approv-ing drilling permits at the expense of acareful examination of the impacts onwildlife and local economies. Note, too,that it appears likely that a substantialbacklog exists of surplus permits thathave already been approved but whereindustry has chosen not to begin drilling.

Environmental Risks Increasewhen Data are Limited

The National Environmental PolicyAct requires federal agencies to disclosein their Environmental Impact State-ments the risks of proposed action and torespond to the adverse opinions held byrespected scientists. (See, e.g., SeattleAudubon Society v. Moseley, 798 F.Supp.1473, 1482 (W.D.Wash. 1992).) TheData Quality Act of 2000 (Pub. L. No.106-554) requires agencies to incorporatehigh quality, usable, verifiable, and objec-tive information. Fulfilling these obliga-tions is especially critical to reduce therisks from large-scale, accelerated drillingplans.

BLM has adopted an adaptive manage-ment approach to assess the impacts fromoil and gas drilling. A major implicationof adaptive management is that acquisi-tion of useful data becomes one of theprimary goals of management (West2002). Acquiring data is sorely needed asvery little wildlife or fish data were usedto support the preferred alternatives andconclusions of the fast tracked energyplans. As noted by Dr Schlesinger(2002) when reviewing the MontanaStatewide DEIS:

In general, I am struck by the lack ofdata obtained from the existing coal bedmethane (CBM) gas wells in Wyomingand Montana. These existing wells,with their associated reservoirs and out-flows, represent a large, replicated

tAs the scale andspeed of drillingincrease, so doesthe environmentalrisk, particularlywhen baseline data are limited or non-existent.s

The 1.2 million-acre GreaterOtero Mesa area contains thelargest Chihuahuan Desertgrassland in North America and ishome to New Mexico’s healthiestpopulation of pronghorn antelope.

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PPAAGGEE 1177

experiment that should have providedample opportunity to answer some ofthe questions that I will pose below.

Schlesinger (2002) concludes: “Myexpert opinion is that the water qualitydata presented are completely inadequateto assess the impact of waters from addi-tional coal bed methane wells on theregional environment.” Allan (2002)with respect to the Powder River echoesthese concerns:

The DEIS lacks critical informationabout the basic ecology of the PowderRiver Ecosystem, and it lacks criticalinformation about the amount andquality of water that will be dischargedonto the land and into surfacedrainages. Without this information it isan inadequate document on which toassess impacts on aquatic ecosystems.

And by Noon (2002a) with respect tothe Powder River Basin, Wyoming DEIS:

In the DEIS there is a pattern of firstasserting a lack of data as a rationale forno quantitative analysis and then con-cluding no adverse effects. Within thelast 10 years a large number of publica-tions have documented adverse effectsto wildlife and their habitats as a conse-quence of habitat fragmentation,human disturbance, roads, and changesin land cover. In the absence of dataand high uncertainty, logic would sug-gest a slow and incremental approach toCBM development coupled with closemonitoring to detect possible adverseimpacts. The public expects responsibleresource managers to implement moni-toring and adaptive management in anincremental fashion when irrevocableor irreversible outcomes are possible.

And by Braun (2002) with respect tosage-grouse:

A major deficit is the lack of knowl-edge about sage-grouse in the areas tobe impacted. This includes adequatebaseline data on current population lev-els and trends as well as amount andquality of present habitat... The presentbaseline data are totally inadequate toallow an adequate evaluation of the

potential impacts on sage-grouse in thearea.

And by Noon (2002b) with respect towildlife data in the Farmington DEIS:

To infer an effect, or lack of an effect,resulting from oil and gas developmentrequires pre-project baseline informa-tion. I could find no evidence in theDEIS that baseline data exist for indi-vidual species populations or their habi-tats. In fact, the DEIS openly admitsthe lack of data. For example, here aresome statements from the DEIS: “Therehave been few surveys for non-gamespecies in the planning area” (P. 3-40);“Few non-game mammal studies havebeen conducted” (p. 3-41); [there is]“...incomplete data on mule deer andelk populations in the planning area”(p. 4-30), and [there is] “...lack of site-specific data on the effects of roads onmule deer and elk” (p. 4-30)....In theabsence of baseline information, theenvironmentally responsible course ofaction would be to collect such infor-mation prior to development.

The problem of poor data is not new(Loomis 1993). In 1986, a former BLMplanning official stated one of the key ail-ments in BLM planning: “Lack of solideconomic, analytical procedures and harddata continually handicaps planning byfailing to portray objectively trade-off val-ues to be gained or lost through manager-ial decisions” (Crawford 1986). Nearly 20years later the problems, questions andchallenges are much more complex, butthe data are arguably in worse shape. Wecan and must do better. A recent surveyof BLM staff (BLM 2003c) affirms ourconcerns over a “data crisis”. The issue ofinadequate data for fish, wildlife, botanyand special status species is particularlycritical for the fast tracked energy plans.The authors conclude: “The acceleratedtime frame for completing time sensitiveplans may not provide sufficient time toaddress FWBSS species conservationissues” (BLM 2003c).

t“My expert opinion

is that the waterquality data

presented arecompletely

inadequate to assessthe impact of watersfrom additional coal

bed methane wellson the regionalenvironment.”

— DR. WILLIAM SCHLESINGER,DEAN OF THE NICHOLAS

SCHOOL OF THE ENVIRONMENT

AND EARTH SCIENCES

AT DUKE UNIVERSITY

s


RecommendationsThe Economic Analysis Must be Improved

As this paper shows, public wildlandsin the Rocky Mountains contain undis-covered gas and oil resources, the majori-ty of which are not economical to recov-er. Where economically recoverable gasand oil does exist on those lands, theamount produced would supply U.S.demand at current rates for only a veryshort time. Unconventional gasresources, like tight sands gas and coalbed methane in the Rockies, are subjectto higher production costs and substan-tial uncertainty (LaTourrette et al.2002). Tight sands gas, for example, areexpensive to develop because the gas isoften deeply buried, wells have low flowrates, reservoir pathways may beobstructed, concentrations often aremore diffuse, and costly recovery tech-niques such as fracturing are needed(Cleveland 2003). Failure to recognizethese essential elements of low-perme-ability sandstone reservoirs has led to amisunderstanding of the risks associatedwith basin-centered gas plays and a sig-nificant over-estimation of availableresource levels (Shanley et al. 2003).Sixty percent of exploratory wells drilledin the U.S. are either dry or have too lit-tle gas to make development economical(Morton 2003), underscoring the highrisk and poor economics associated withdrilling for undiscovered resources.USGS (Attanasi 1998) estimates thatonly about 18 percent of the technicallyrecoverable tight sands gas is economicto recover.

Focus on EconomicallyRecoverable Gas

Instruction Memorandum #2003-233of July 28, 2003, requires BLM plannersto use estimates of technically recover-able gas in management plans, thusensuring that the plans will exaggerate

the energy potential, jobs, and revenuesfrom proposed drilling projects, as well asthe opportunity costs of protectingwildlife habitat or enforcing wildlife stip-ulations in leases. For reasons document-ed in this paper, planning documentsshould not rely on estimates of techni-cally recoverable resources or other mea-sures that ignore economics.

USGS is currently updating its esti-mates of economically recoverable gas inthe Rockies using a range of prices thataddresses concerns over price uncertaintyand the accuracy of economic forecast-ing. Until the updates are ready, we rec-ommend that BLM rescind InstructionMemorandum #2003-233 and that theagency and Forest Service use the USGShigh and low price mean estimates ofeconomically viable gas (Attanasi 1998)as a starting point to evaluate variousland management alternatives in upcom-ing plan revisions.

Include a Full Accounting ofEnvironmental Costs

In addition to market costs, economicanalyses of recoverable gas must includea full accounting of non-market costs.Because they exclude non-market costs,USGS estimates are just the startingpoint to determine whether undiscov-ered gas is economically viable toextract. After 35 years of research byacademic and federal agency economists(Krutilla 1967, Krutilla and Fisher 1985,Peterson and Sorg 1987, Loomis andRichardson 2001), it is now possible toquantify non-market environmentalcosts that arise from development of nat-ural resources (see Table 3). The BLMand the Forest Service should include afull accounting of non-market costs inthe effects analysis required by theNational Environmental Policy Act(NEPA) for leasing and drilling deci-sions.

t“The West’s naturalenvironment is,arguably, itsgreatest, long-runeconomic strength.”— LETTER FROM

100 ECONOMISTS TO

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PPAAGGEE 1199

Account for the negative impactson local economies

The BLM and the Forest Serviceshould assess the potential impacts onthe regional economy that may flowfrom environmental degradation broughtabout by proposed large-scale oil and gasdrilling in the Rockies. Considerationsshould include the negative impacts onhunting, fishing, ranching, recreationand service jobs, plus the negativeimpacts on our retirement and invest-ment income, and our overall quality-of-life-based economy. This recommenda-tion is consistent with that of more than100 economists, who, in a 2003 letter toPresident Bush, stated, “The West’s nat-ural environment is, arguably, its great-est, long-run economic strength”(Whitelaw et al. 2003). The economistsagreed that protecting the West’s naturalenvironment would strengthen the abili-ty of western communities to generatemore jobs and more income.

Invest in Baseline DataCollection, Spatial Analysis andBLM Field StaffImprove baseline data collection.

Data collection and monitoring areprerequisites to cost-effective, science-based adaptive management of publicland, but data collection and monitoringgenerally take a back seat in BLM andForest Service budgets and planningprocesses. A quick review of the ForestService proposed budget for Fiscal Year2005 shows that Inventory and Monitor-ing, much of which is devoted to themonitoring of visitor use and notresource conditions, represents just 3.7percent of the total agency budget (For-est Service 2004). The BLM’s Fiscal Year2005 budget request is more difficult todecipher, but it appears that funding formonitoring accounts for just 1.6 percentof the total request (BLM 2004c). In arecent review of the BLM budget, theOffice of Management and Budget iden-

tified several weaknesses, including gapsin monitoring resource conditions tosupport management decisions andinsufficient data. This is consistent withopinions of the scientists cited in thispaper; the lack of credible data is a fatalflaw with recent BLM decision docu-ments examining the environmentalimpacts from drilling in the Rockies.

The BLM (2003c) acknowledges thepressing need for data collection andmonitoring:

The lack of a coordinated, nationalprogram for inventory of (wildlife andfish) resources on BLM-managed landis problematic, because it is difficult tomanage resources without full knowl-edge of their status on public land.When inventory is performed, coverageof resources may be inconsistent, andin some instances, current office staffmay be unaware of inventory efforts byprevious employees.

While the agency is starting to recog-nize the data crisis, we believe recentlydeveloped energy plans fail to complywith the Data Quality Act of 2000, whichrequires the agency to use data of suffi-cient quality to make a reasoned analysis.In order to decrease environmental costsand risks, the BLM (and the Forest Ser-vice) should accelerate efforts to collect

Elk that winter in Wyoming’sUpper Green River Valley face

reduced habitat effectivenessfrom the growing network of

roads, drill pads and waste pits.

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examining theenvironmental

impacts from drillingin the Rockies.

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PPAAGGEE 2200

baseline data, analyze the data, and moni-tor resource conditions. This informationis required to adaptively manage ecosys-tems and is vital if the public is to fullyunderstand the potentially irreversible,cumulative environmental impacts fromlarge-scale energy development in the

Rocky Mountains. To their credit, boththe Forest Service and the BLM haveincreased the budgets for monitoring inthe FY 2005 budget. This is a step in theright direction, but a much greater long-term budget commitment to data collec-tion, analysis and monitoring is required


TABLE 3. The Hidden Economic Costs of Gas and Oil Extraction

Cost category Description of potential cost Methods for estimating costs

Direct use Decline in quality of recreation, including hunting, fishing, Travel cost and contingent valuation surveys.hiking, biking, horseback riding. Loss of productive landfor grazing and farming.

Community Air, water, and noise pollution negatively impacts quality Surveys of residents and businesses. Averting of life for area residents with potential decline in the expenditure methods for estimating costs of number of retirees and households with non-labor income, mitigating health and noise impacts. Changes loss of educated workforce, and negative impacts on in recreation visitation, expenditures and business non-recreation businesses. Decline in recreation visits and income. Documented migration patterns. return visits negatively impact recreation businesses. Socio-economic costs of boom-bust cycles.

Science Oil and gas extraction in roadless areas reduces value of Change in management costs, loss of information area for study of natural ecosystems and as an experimental from natural studies foregone.control for adaptive ecosystem management.

Off site Air, water, and noise pollution decrease quality of life for Contingent valuation surveys, hedonic pricing local residents and decrease quality of recreation experiences analysis of property values, preventive expenditures, for downstream and downwind visitors. Haze and drilling well replacement costs, restoration and rigs in viewsheds reduce quality of scenic landscapes, environmental mitigation costs, direct impact driving for pleasure, and other recreation activities and analysis of the change in crop yields and revenues.negatively impact adjacent property values. Groundwater discharge can negatively impact adjacent habitat, property, and crop yields, while depleting aquifers and wells.

Biodiversity Air, water, and noise pollution can negatively impact fish Replacement costs, restoration and environmental and wildlife species. Groundwater discharge changes mitigation costs. hydrological regimes with negative impacts on riparian areas and species. Road and drill site construction displaces and fragments wildlife habitat.

Ecosystem services Discharging ground water negatively impacts aquifer Change in productivity, replacement costs, increased recharge and wetland water filtration services. Road water treatment costs, preventive expenditures.and drill site construction increases erosion, causing a decline in watershed protection services.

Passive use Roads, drilling rigs, and pipelines in roadless areas result Contingent valuation surveys, opportunity costs of in fewer passive use benefits for natural environments. not utilizing future information about the health,

safety, and environmental impacts of oil and gas drilling.

PPAAGGEE 2211

to bring the agencies in compliance withthe Data Quality Act of 2000. Scientistsat Western EcoSystems Technology(2002) summarize the risks, uncertainties,and data challenges faced by BLM:

...there is a paucity of well designedstudies that assess the impacts of oil andgas activity on ungulate populations.The Upper Green River Basin containsa variety of ungulate habitats and con-tains winter ranges for some of thelongest migrating ungulate herds in thewest. Thus the most effective means forassessing impacts from oil and gas pro-jects on ungulate populations withinthe area is the implementation of welldesigned studies of the effects of oil andgas development on ungulate ecologyand habitat. Long term monitoringshould also be used to verify the effica-cy of approved mitigation measureswithin important big game habitats.The revision of the Pinedale RMPshould include requirements for moni-toring of ungulate use and movementsthrough radio telemetry to verify theaccuracy of existing range designations.Ideally, these studies should be of suffi-cient duration (e.g., 5-10 years) in orderto capture a fairly wide range of winterseverity. The studies should be conduct-ed so that inferences can be made to allherd segments within the PinedaleResource Area potentially impacted byresource development. Additionally,habitat mapping is needed to help iden-tify key areas for ungulates.

Incorporate Spatial Analysis intoEvaluation of Proposed Drillingand Monitoring of Actual Drilling

Despite the documented impacts thathabitat fragmentation has on wildlife pro-posed oil and gas projects are moving for-ward without adequate evaluation of theimpacts that they have on wildlife, espe-cially their role in habitat fragmentation.The DEIS for the coal bed methane pro-jects in the Powder River Basin led to thefollowing comments on the document’sshortcomings by Noon (2002a):

The relevance of the fragmentationprocess affecting wildlife populationsrests on the understanding that infor-mation on habitat amount alone maybe insufficient to predict the status of aspecies. When habitat is potentiallylimiting, then information on the spa-tial pattern of the habitat may beequally or more relevant than informa-tion on habitat amount. The impor-tance of incorporating spatial data intoeffects analysis cannot be overemphasized(emphasis added). Knowledge of whereon the landscape habitat loss will occurand in what spatial pattern is essentialbefore one can conclude no significantadverse effects.

The BLM is currently developing bestmanagement practices (BMPs) for reduc-ing fragmentation of wildlife habitat.While certainly a step in the right direc-tion, developing BMPs is a necessary butnot sufficient condition for addressinghabitat fragmentation. In addition todeveloping and enforcing BMPs forexisting energy development, spatialanalysis should be incorporated into theevaluation of the ecological impacts ofproposed oil and gas projects — in addi-tion to monitoring existing energy pro-jects. The significant increase in avail-ability of GIS data and software technol-

Backpackers crossing a stream inthe Badger Two-Medicine roadless

area located along Montana’sRocky Mountain Front — an area

where drilling has been proposed.

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ogy in recent years makes this possible.Prior to exploration and development ofnew oil and gas fields and before newdrilling in existing fields, BLM and theForest Service should, at a minimum,complete the same kind of spatial analy-sis that we used in our study. In addition,information on habitat quantity andquality, species populations and birthrates, and the frequency of vehicle use ofroads should be considered in the analy-sis. See Weller et al. (2002) and Hartleyet al. (2003) for more recommendations.

Invest in additional BLM andForest Service Field Staff

In order to collect and analyze base-line data, complete spatial analysis, andmonitor cumulative impacts from theproposed drilling, Congress must allo-cate funds to add field staff to the BLMand Forest Service ranks. Over the past10 years the number of BLM wildlifebiologists decreased nearly 20 percent,while fishery biologists and botany posi-tions increased slightly. Based on ananalysis of BLM data (BLM 2003a,2003c) the agency has only 12 ecolo-gists, 6 botanists, 9 fishery biologists and91 wildlife biologist to oversee steward-ship of 7 million acres of public land inthe Rockies. While the current BLMstaff is inadequate to provide oversightof wildlife, fish and plant resources inthe Rockies, New Mexico provides astriking case. In 2002, the BLM appar-ently did not have a single ecologist,botanist or fisheries biologist on fieldstaff in New Mexico (BLM 2003c).Additional staff is especially needed toaddress the added workload placed onForest Service and BLM employees fromthe executive order requiring fasttracked energy plans. As noted from asurvey of BLM employees in Utah (BLM2003c):

In areas with high demand for energydevelopment there is insufficient timefor existing staff to keep up with theworkload it creates. In all cases,

staffing and funding are insufficient toestablish and implement a proactiveFWBSS program.... The increasedworkload generated by energy develop-ment, land and realty actions, mineralsdevelopment and grazing are creating aworkforce that is stressed, over-worked,and facing potential burnout.

Obviously more field ecologists andbiologists are needed for stewardship tobe successful.

The BLM must complete aCumulative Impact Analysis

As part of its energy policy, the currentadministration has essentially directedagencies with jurisdiction over energydevelopment on public lands to prioritizedrilling over all other concerns, includ-ing protection of wildlife. As one exam-ple, in a recent Final EnvironmentalImpact Statement, BLM revoked signifi-cant protections for wildlife and habitatthat were included in the draft, statingthat “BLM is required to impose the leastrestrictive constraints needed to provideadequate protection while allowing fluidminerals leasing and development”(BLM2003b).

This nationally mandated approachrequires a corresponding national analy-sis of the potential cumulative impacts towildlife and other resources. As theNational Environmental Policy Actrequires, federal agencies must assess theenvironmental impact of a proposedaction, taking a “hard look” at environ-mental consequences [see 42 U.S.C. §4321 et seq.; Metcalf v. Daley, 214 F.3d1135, 1151 (9th Cir. 2000); Robertson v.Methow Valley Citizens Council, 490 U.S.332, 348 (1989)], and the scope of theanalysis “must be appropriate to theaction in question.”

In determining the appropriate scopeof environmental analysis for an action,federal agencies must consider not onlythe single proposed action, but also threetypes of related actions: 1) connectedactions, 2) cumulative actions, and 3)


t“The importance ofincorporating spatialdata into effectsanalysis cannot beoveremphasized.”— DR. BARRY NOON,PROFESSOR, DEPARTMENT OF

FISHERIES AND WILDLIFE BIOLOGY,COLORADO STATE UNIVERSITY

s

A hiker gazes down on theGreen River, from the rim ofDesolation Canyon in Utah.

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similar actions (see 40 C.F.R. § 1508.25).Under any of the three classifications,the coordinated actions that federalagencies are directed to take in compli-ance with the current energy policy, trig-ger a broad assessment of cumulativeimpacts. Since the government is man-dating a program of prioritizing oil andgas development, the resulting agencyactions are connected as “interdependentparts of a larger action,” all of which“depend on the larger action [the gov-ernment policy] for their justification.”Further, the many actions taken by dif-ferent federal agencies to acceleratedrilling will have a compounding impacton species and habitat, so adding togeth-er each of the areas of habitat lost to orfragmented by development will have a“cumulatively significant” impact onspecies. Finally, because the administra-tion’s energy policy extends to all agen-cies with responsibilities for oil and gas

development, and will be concentratedin the Rocky Mountains, the reasonablyforeseeable actions will have “commontiming and geography,” and will be simi-lar in terms of opening more areas fordevelopment and approving more devel-opment activities.

The cumulative impact analysisrequired to accurately evaluate thepotential environmental consequences ofthis policy would necessarily include theentire area that is potentially affected.We interpret this to include the 100 mil-lion acres identified in the administra-tion’s recent energy assessment (DOI andDOE 2003) as well as the areas targetedby the administration for expedited ener-gy plans including the Rocky MountainFront, the Powder River Basin, theUpper Green River Valley, the RoanPlateau, the HD Mountains, the BookCliffs, and Otero Mesa.

tAs part of its energy

policy, the currentadministration hasessentially directed

agencies withjurisdiction over

energy developmenton public lands toprioritize drilling

over all otherconcerns, including

protection of wildlife.s

Memorial Day sunset at Canyons of the Ancients National Monument in Colorado.

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ConclusionsOur fragmentation analysis showed the

significant fragmentation of wildlife habi-tat associated with large-scale energydevelopment. Based on our GIS analysisof gas and oil, it is clear that drilling pub-lic wildlands in the West will do little toaffect the nation’s energy future. There-fore, one should not assume that extract-ing energy resources is always the highestand best use of public lands. As roadlesswildlands and critical wildlife habitatbecome scarce, their economic and eco-logical values increase. As a result, themarginal benefits from wildland conser-vation are, in many cases, much greaterthan the marginal costs in the form offoregone undiscovered, economicallyrecoverable energy resources.

With this in mind, we urge BLM toreduce the environmental risks by slow-ing down and reducing the scale of pro-posed drilling while taking a more con-servative approach that is consistentwith adaptive management principles.

Stewardship of public lands requires noless.

We urge Congress and the states toreduce the environmental risks byinvesting in applied research by agencyand university scientists to improve thescience behind adaptive managementdecisions. Applied research begets stew-ardship.

We urge the agencies to address the“data crisis” by investing in spatiallyexplicit baseline data, based on ground-truthing resource conditions. Investingin accurate baseline data and scientificanalysis and monitoring of the data col-lected is a prerequisite for good steward-ship. To accomplish this, we recommendthat the agencies add staff while alsoincreasing the budgets for agency biolo-gists, botanists and ecologists in districtand regional offices.

We also urge the agencies to stop orslow the outsourcing of environmentalanalyses to private firms, especially thosewith consulting connections to the ener-gy industry. The quality of the analysis


tAs a result of Enron,we no longer allowaccounting firms tobe both accountantsand consultants tothe same clients. Weshould follow suitwith public landmanagement.s

Wild horses and badlands in Adobe Town wilderness study area, the largest potential BLMwilderness area in Wyoming.

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suffers, the costs to taxpayers are greater,and the conflict of interest is obvious.As a result of Enron, we no longer allowaccounting firms to be both accountantsand consultants to the same clients. Weshould follow suit with public land man-agement. Rather than outsourcing jobsfrom rural communities, we recommendincreasing the number of BLM fieldstaff. Investing in field staff will helppromote economic development,because in many western communities,BLM employees provide an importantsource of basic income that supportslocal jobs.

We urge the BLM and the Forest Ser-vice to consider wilderness a vital com-ponent of stewardship. Wilderness epito-mizes multiple-use public land in a purebut rugged sense. Wilderness areas pro-

tect watersheds and wildlifehabitat. Wilderness providespristine settings for high-quali-ty backcountry hunting, fish-ing, hiking, bird watching, ski-ing, horseback riding, climb-ing, and camping. Westernersand visitors alike are not inter-ested in pursuing these activi-ties near drilling rigs, noisy gascompressors, or smelly wastepits.

While demand for natural gas hasbeen flat, consumers have suffered fromtwo prices spikes. The government hasconcluded that price manipulationoccurred and the current spike in natur-al gas prices is under investigation formarket manipulation (GAO 2002,FERC 2002, Morton 2003). Ratherthan using taxpayer dollars to subsidizerisky and potentially low productivitygas wells, federal energy policy shouldstretch proven gas reserves by reducingwaste through investments in low cost,low risk, no regret solutions like energyconservation and efficiency. We canalso reduce our risks by diversifying ourenergy portfolio with renewable energysources such as solar, wind and biofuels- at the appropriate locations and scale.Conservation combined with competi-

tThe public deserves

an honest assessmentof the economics,

including negativeimpacts of reducing

environmentalprotection, on localtourism, ranching,

recreation, hunting,fishing and quality

of life.s

Pristine areas like the Bridger-Teton National Forest in Wyoming

(at right) and Thompson Creekroadless area in the White RiverNational Forest in Colorado, are

increasingly threatened by gasand oil drilling.

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tion from renewable energy will reducethe demand for natural gas and result inlower prices for consumers. Simple effi-ciency measures can permanentlyreduce utility bills, while drilling mar-ginal gas wells results in, at most, a tem-porary cost savings for consumers.

With a ten-year supply of gas inproven reserves, 53,000 producing wellson public land in the Rockies, 46,000drilling permits issued since 2000, and 32million acres of federal minerals alreadyunder lease, there is no need to expedite

drilling in pristine areas. The publicdeserves a better understanding of thecumulative environmental impacts thatthe current drilling boom has on air,water, and western landscapes. The pub-lic deserves an honest assessment of theeconomics, including the negativeimpacts of reducing environmental pro-tection, on local tourism, ranching,recreation, hunting, fishing and qualityof life. These are not unreasonablerequests or concerns.


PPAAGGEE 2277

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COVER PHOTOS: West of the Wind River Range,

40,000 pronghorn winter in the Upper Green River Valley.

Photo by Linda Baker.

Pinedale drill rig (Wyoming). Photo courtesy TWS archive.


Pete Morton, [email protected]

Michelle Haefele, [email protected]

Nada [email protected]

The Wilderness SocietyFour Corners States Office

1660 Wynkoop StreetSuite 850

Denver, CO 80202(303) 650-5818

Janice Thomson, [email protected]

The Wilderness SocietySeattle Office

720 3rd AvenueSuite 1800

Seattle, WA 98104(206) 624-6430

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