By Amanda Cardenas

Embarking on a tour of the Atlantic Rim region in Wyoming, one immediately feels the desolation and serenity of a landscape raised by plateaus and mesas and filled with stream-laden valleys carpeted in multiple blue-gray to blue-green species of sagebrush.  It does not take much to find yourself disoriented in this impressive landscape.  In July of 2009, National Wildlife Federation (NWF) attorneys Joe Feller and Michael Saul, NWF Public Lands Organizer Dwayne Meadows, Wyoming Wildlife Federation’s Field Director Joy Bannon, and I found ourselves traversing a landscape that unfortunately may look, sound, and feel much different several decades from now.  

The Atlantic Rim Natural Gas Field Development project was approved in May of 2007, when the Bureau of Land Management (BLM) issued a Record of Decision (ROD) on its Final Environmental Impact Statement (FEIS).  This decision opened 270,000 acres of rich wildlife habitat to intensive coalbed methane (CBM) development in addition to the more familiar traditional natural gas development. 

This project involves the drilling of 2,000 natural gas wells, not to mention the associated roads, pipelines, compressor stations, and pumped and discharged water.  Several hundred wells have already been drilled.  Bound by Rawlins to the North and Baggs to the South in Carbon County, this project area is primarily composed of BLM land but is checkered by private and state surface ownership.  Spanning a range of habitats from sagebrush to varied uplands with consistent water sources, this diverse landscape is home to some of Wyoming’s densest populations of elk, pronghorn, mule deer, and sage grouse.  This area encompasses critical migration corridors, seasonal ranges, and breeding grounds for many of these species.  The Greater Sage-Grouse is currently undergoing review for its listing under the Endangered Species Act, a determination that is expected to be reached early next year.  

In June 2007, Wyoming Wildlife Federation and NWF filed a joint administrative appeal with the Interior Board of Land Appeals (IBLA) in reaction to the BLM’s ROD.  Other environmental and wildlife organizations filed suit in the U.S. District Court for the District of Columbia.  Both actions were unsuccessful and lost to the government and energy companies (Anadarko Petroleum Corporation, Warren Resources, Inc., and Double Eagle Petroleum, Co.).  As other environmental organizations plan to appeal the district court decision, NWF remains vigilant of the promises and legally binding commitments found in the BLM’s ROD for the Atlantic Rim.

The 2007 ROD clearly binds the BLM to various commitments.  In defending its decision in front of the IBLA and the district court, the BLM even relied on these promises and commitments.  NWF intends to hold the BLM accountable for these commitments to monitor, analyze, and review as part of the adaptive management process.  The BLM stated in its ROD that it would set “quantifiable criteria to identify trends associated with the Performance Goals.”  It committed itself to efforts to collect and consolidate resource data that would “form a baseline against which future monitoring efforts and data would be compared to indicate trends.”  As part of its decision, the BLM made a commitment to make publicly available the final annual reports due each February that summarize annual wildlife inventory and monitoring results and trends, assess protection measures, specify upcoming monitoring and protection measures, and more.  In addition, annual operating plans are to be submitted to the BLM by operators, along with “as-built” disturbance reports.  NWF has yet to see these requested documents and reports.

During our recent July visit, Professor Joe Feller and I met with several BLM officials in the Rawlins Field Office, including the Rawlins Field Manager and the Atlantic Rim Project Manager.  NWF is pressing the BLM for greater clarity, transparency, public review, and public input before final decisions are reached for the Plans of Development (PODs), which authorize the drilling of specific groups of gas wells.  The Rawlins Field Office’s page devoted to the Atlantic Rim is outdated with pre-2007 Interim Drilling PODs and their associated site-specific or tiered Environmental Assessments (EAs).  The BLM recognizes the necessity of posting documents online and updating current websites.  NWF strongly encourages the BLM Rawlins Field Office to utilize this method of information dissemination to the public in order to make the process more comprehendible and transparent, as natural gas development on the Atlantic Rim will become more prevalent, at an increasing rate.  

Currently, what publicly exists are the draft EIS and final EIS documents, the ROD, pre-2007 EAs and PODs, and Applications for Permits to Drill (APDs), available at least 30 days before BLM action to approve the applications, which you can only view inside the Rawlins Field Office.  EAs and PODs have been developed and approved since 2007, and some are pending, so why has this information not been made available to the public?  

During our field tour of the Atlantic Rim, led by Meadows, we visited the Sun Dog POD, where the silence of the Atlantic Rim was disturbed by the resounding large compressor station in addition to all the ground-specific ecological, environmental, and aesthetic impacts.  Alone, a natural gas well does not seem very imposing; together, 2,000 wells (along with presently operating oil rigs) creates a whole different image.  We understand that wells will be drilled.  However, NWF intends to be a watchdog of the BLM’s compliance with the NEPA process and its numerous ROD commitments.

Other plans for development around the Atlantic Rim include a renewable resource – wind – high on the plateaus.  The Chokecherry and Sierra Madre Wind Energy Project is a proposed action that includes the construction, operation, and maintenance of approximately 1,000 turbines (and ancillary facilities) for 2,000 megawatts of wind energy.  Further information may be found on the BLM’s website:  http://www.blm.gov/wy/st/en/info/NEPA/rfodocs/Chokecherry.html.   NWF and Wyoming Wildlife Federation remain concerned about the cumulative impacts on wildlife that may result from wind development in addition to the current natural gas and oil development in the region.  

Amanda Cardenas is working as a summer legal intern for NWF in Boulder.  She holds a B.S. and M.S. in Environmental Studies and is currently a law student at the University of Washington in Seattle.  

To see more photographs from the trip described in this article, click here to see the author's Flickr account .

Additional Resources:

• Sportsmen Challenge Gas Development Decision Endangering World-Class Wildlife Resource in Atlantic Rim
• Atlantic Rim Fact Sheet 

Related Links:

• News: Fed land management plan endangers wildlife (09/19/2008)
• BLM report: Drilling would boost gas leakage (3/4/08)
• Judge Won't Halt Drilling - Dec. 4, 2007 - Casper Star Tribune
• Casper Star Tribune article on the methane seeps developing in the Atlantic Rim
• Final Environmental Impact Statement and Record of Decision on Atlantic Rim
• BLM Press Release - Dec 3, 2007 - District Court Denies Injunction on Atlantic Rim
• Scientific Studies
• Skytruth Blog
• CBM Drilling Simulation: Before-after pairs of satellite images showing the Atlantic Rim region of central Wyoming, and how it may appear after proposed drilling for coalbed methane based on the "preferred alternative" described in the Final Environmental Impact Statement issued by the Bureau of Land Management.

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