Oil and Gas Management Decisions for the White River National Forest
The past few years have seen great strides in the development of new and innovative methods for oil and gas extraction. With these advances in technology comes the need update our policies regarding oil and extraction. Recently the Forest Service (FS) and the Bureau of Land Management (BLM) released proposals that address this very issue, specifically with regards to oil and gas policy in the White River National Forest (WRNF).
The FS recently released their Oil and Gas Leasing Draft Environmental Impact Statement (DEIS), which proposes land availability and lease stipulations for the entire 2.3 million acres of the WRNF. This DEIS was prepared to document and disclose the estimated environmental impacts analysis of an implementation of the decision to make available and apply lease stipulations to National Forest System lands within the WRNF.
The BLM recently released a draft White River Resource Management Plan (RMP) Oil and Gas Amendment, which analyzes four alternatives on potential oil and gas development and proposes appropriate mitigation measures on the 1.7 million acres of federal leasable minerals administered by the BLM’s White River Field Office (WRFO).
Both of these plans will have an impact on the WRNF, and have the potential to drastically change the future of oil and gas development in the area. And while these plans are specific to the WRNF, the plans chosen will show a trend of where Colorado as a state stands in terms of oil and gas policy, as well as the U.S. as a whole.
The FS rule:
The FS released their proposal in order to update the WRNF 1993 Oil and Gas Leasing EIS and Record of Decision. Since the 1993 EIS a lot has changed. Technological advances in oil and gas exploration and development, such as the development of the fracking technique, have expanded the potential to develop resources that were previously economically unfeasible. The Oil and Gas DEIS proposal by the FS lists four alternatives for how to address land availability and lease alternatives for the entire WRNF.
The first alternative is a “no action” alternative, and would continue current management practices. The second alternative is a “no new leasing” alternative, and wouldn’t allow any leasing other than what is already leased, and those leases would terminate once production stops. The third alternative is the “proposed action” alternative, which makes some land available for lease, closes off other areas, and increases the stipulations for the land that is available for lease. Finally, the final alternative is the “mixed roadless stipulation” alternative, which is similar to the proposed action, except that it adds in more roadless stipulations.
Deciding which option is best depends on where your priorities lie in terms of oil and gas production. If you are against oil and gas production completely, then the second alternative is your best bet. Of the alternatives, the second alternative would close off the most land to leasing.
On the other hand, if you think that we should utilize the land as much as possible for oil and gas production, then the first alternative would be best. Of the alternatives, the first alternative would leave the most land open to leasing.
However, if you believe as I do that we should utilize domestic oil and gas production as long as it is done responsibly, the proposed action seems to provide a good balance. Currently 417,000 acres are open to leasing. The proposed option would drop this down to 260,000 acres. Furthermore, it would add protective stipulations to almost 300,000 acres. The mixed roadless alternative takes this one step further, and adds roadless stipulations to some of the protective stipulations.
Both the proposed action and the mixed roadless rule could result in significantly reduced drilling activity in the WRNF. The proposal indicates that the number of wells that would be drilled could drop about 66 percent if the proposed action is adopted, compared with what's possible under current conditions.
However, some are skeptical that it will actually result in less drilling. They argue that tougher regulations could prompt gas companies to work harder to develop leases they hold under the old rules, and this could result in more drilling than the Forest Service anticipates.
Furthermore, while the acres available for leasing may be reduced, it may not take any valuable land away from the oil and gas industry. Many of the acres proposed to be made unavailable don't hold promising reserves of oil or gas.
The BLM Rule:
The Bureau of Land Management (BLM) White River Field Office (WRFO) prepared a Draft Resource Management Plan Amendment and Environmental Impact Statement (RMPA/EIS) for Oil and Gas Development to evaluate and amend, if necessary, the current management decisions for oil and gas resources within the WRFO Planning Area. Again technology has changed since the last RMPA and EIS were implemented, and the BLM is looking at four alternatives to address these changes.
Alternative A is a “no action” alternative, which would continue current management practices, with a few updates. While it retains current management practices, the action would allow the lowest amount of well and well pad production. If you believe that the least amount of land should be impacted, then this is the best alternative.
Alternative B offers greater well and well pad production than Alternative A, but offers incentives for concentrated development, which will mitigate environmental impact. This alternative would have the largest amount of NSO lease stipulations, and require less truck use during extraction. Wildlife impacts would be managed using timing limitation stipulations and voluntary acute and collective development thresholds on big game seasonal range. The thresholds would promote clustered development, which could increase impacts related to surface disturbance in development zones, but in the short term would also keep more surface areas free of disturbance. Furthermore compliance with the threshold concept would also promote timely, successful reclamation, allowing surface areas to more rapidly recover their pre-disturbance condition.
Alternative C offers even greater well and well production than the first two alternatives. Alternative C would have management actions and lease stipulations that reduce impacts similar in scope to Alternative B, but less restrictive. Impacts from road wear and tear would also be higher than Alternatives A and B because more truck trips would be required. Wildlife impacts would be managed using timing limitation stipulations and voluntary acute and collective development thresholds on big game seasonal range. The thresholds would be higher than Alternative B, and thus would do less to maintain existing conditions.
Alternative D focuses on oil and gas development, and allows the greatest well and well production, and would have the greatest overall environmental impact because it does not apply management actions to provide environmental protection for other resources other than what is consistent with applicable laws and policy. If you think that oil and gas production should be as uninhibited as possible, then this last alternative is ideal.
Our country is dealing with many issues today. Our economy is down, and jobs are harder to come by. And as gas prices rise and the future of the Middle East seems more and more uncertain, there is also a strong push for producing domestic energy in order to cut back our dependency on foreign oil. However, trying to improve our unemployment rate and curb our dependency on foreign oil, while simultaneously trying to protect our environment, is not an easy thing to do. The key is balance.
For the FS proposal, I believe that the proposed alternative is optimal. Technology has increased our ability to develop more from less land. Therefore I do believe it is necessary to cut back on the amount of land that was previously made available under the previous rules. However, given the needs of our nation, responsible oil and gas production is also necessary. The proposed alternative seems to strike a balance between these needs. While both decreasing the amount of land available, as well as implementing more prophylactic stipulations, we can provide the guidelines for responsible oil and gas production.
For the BLM proposal, I believe that the Alternative A is optimal. All of the alternatives of the plan allow for oil and gas development. Alternative A, however, allows for significantly less land to be impacted than all of the others. And while Alternatives B and C do provide some mitigating techniques, I believe the overall resource impact will still be much higher under those plans simply due to the larger scale of development.