U.S. DEPARTMENT OF THE INTERIOR  BUREAU OF LAND MANAGEMENT  
ePlanning DOI-BLM-CO-N040-2017-0050-EA (North Fork Mancos Master Development Plan (NFMMDP))  
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Last Updated:
08/20/2019 13:12:41 MDT
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Synopsis of Project  NEW!
The Project as Described in the Preliminary EA
            Gunnison Energy LLC (GELLC) proposed to drill, complete, and operate up to 35 horizontal wells from one existing well pad, one expanded well pad, and three new well pads and to construct access roads and gathering pipelines in Gunnison and Delta counties, Colorado.  The project, referred to as the North Fork Mancos Master Development Plan (NFMMDP), would occur within an area encompassing 34,906 acres of public and private lands.  This includes 25,790 acres administered by the U.S. Forest Service, Grand Mesa-Uncompahgre-Gunnison National Forests, Paonia Ranger District; 468 acres administered by the Bureau of Land Management (BLM), Uncompahgre Field Office; and 8,648 acres of private lands.  Federal fluid mineral estate in the project area totals 30,972 acres, including all of the Federal lands and 4,714 acres beneath some of the private lands. General access to the project area would be via State Highway 133 to County Road 265.  GELLC plans to begin project activities in summer 2020.  Project workforce would be approximately 122 workers during the 4-year development phase, including construction, drilling, and completion activities, depending on one versus two drilling rigs. Long-term operational life of the project is estimated at 30 years, during which time up to 700 billion cubic feet of natural gas is expected to be produced. 
            The proposal includes use of up to 26 miles of existing roads and up to 4.2 miles of upgraded or new administrative access roads.  The lack of certainty regarding road lengths reflects that the EA analyzes two road options for accessing one of the Federal well pads, depending on GELLC’s ability to obtain access across private land instead of constructing a new road segment across National Forest System lands.  Total initial surface disturbance associated with the project would be approximately 35.9 acres on Federal (mostly National Forest System) lands and 10.2 acres on private lands.  Of these totals, 14.5 acres on Federal lands and 2.9 acres on private lands would remain disturbed over the long-term, until final reclamation of the pads.

Modifications to the Project that Led to Preparation of the Revised Preliminary EA
            Since publication for public review of a Preliminary EA in May 2018, GELLC has modified its proposal to use the most common and reliable method of hydraulic fracturing, called the slickwater method, instead of the originally proposed nitrogen foam (or gel) method analyzed in an earlier Preliminary EA published in May 2018.  GELLC now considers the nitrogen foam method unfeasible based on the geology of the targeted Manos Shale in combination with the anticipated depth and length of the horizontal well bores.  In addition, the nitrogen used in the nitrogen foam method must be transported and handled onsite at high pressures.  The modification in completions method would result in increased water requirements from the initially estimated 30,000 barrels (3.9 acre-feet) per well to the currently estimated 500,000 barrels (64.4 acre-feet) per well for completions.  For all uses, including drilling, completions, and ongoing dust abatement, the increased per-well water consumption is estimated to increase from 44,535 barrels (5.8 acre-feet) to 522,520 barrels (67.3 acre-feet) per well.  Annual consumption is estimated at 336.7 acre-feet during the first year, when five wells are planned, and 404.1 acre-feet during the second year, when six wells are planned.
            Existing water sources—primarily the Hotchkiss Water Treatment facility within the project area, GELLC’s water right facility for the Elk Creek Mine (Oxbow Mining), and produced water from GELLC’s coalbed methane wells—would be sufficient to meet 90% of the proposed water requirements.  To make up the difference during the first 2 years, GELLC proposes to truck 34 acre-feet of water acquired from the City of Delta via State Highways 92 and 133 to a turnoff into the project area on a private road north of Paonia Reservoir.  Once inside the project area, the water would be transferred into GELLC's existing pipeline system.  GELLC is actively pursuing additional water sources and storage facilities to eliminate the need for truck haulage in the third and fourth years.  The Revised Proposed Action also includes use of a temporary surface pipeline to deliver water from the Elk Creek Mine water right facility to an existing pad near the southern end of the project area, where it would be transferred into GELLC’s existing pipeline system.  
            The currently proposed method of completions would also require the delivery of sand, used as a “proppant” to help keep the fractures open and facilitate release of natural gas into the well bore.  Delivery of sand would utilize haul trucks traveling on SH 133 from a railroad loadout at the Elk Creek Mine to the intersection with CR 265, and from there to pads being completed.  Both the water and sand haulage would occur on 50 to 60 days distributed through late summer and fall. 

Modifications to the Project Action Incorporated into the Final EA
            The Final EA published on August 16, 2019, differs from the previous version in two primary ways (also see the Preface in the Final EA document).  First, GELLC has commited to use of one drilling rig and one completions rig throughout the development, instead of doubling the drilling rate by use two rigs after the first 2 years.  This necessarily resulted in extending the development period from 4 years to 6 years to drill and complete all 35 wells.  The resulting lower intensity but longer duration results in varying changes in impacts to different resources and uses, as was disclosed and analyzed in the Revised Preliminary EA as a possibility.  Among the differences associated with the change to a longer development period using only one drilling rig and completions rig would be lower peak levels of emissions to the atmosphere, lower peak levels of consumptive water use on a per-year basis than previously proposed, and lower peak levels of truck traffic associated with delivery of sand and water.  The size of the labor force during development has been increased to 135 workers for 6 years instead of 122 workers for 4 years as in earlier versions of the EA.           

Public Involvement
            The first opportunity for public comment was the scoping period from February 17, 2017, to April 17, 2017.  A total of 1,349 scoping comments on the Proposed Action were submitted by individual citizens, elected officials, governmental entities, and non-governmental organizations.  A 30-day public comment period on the Preliminary EA began on May 10, 2018.  During this public comment period, 102 unique comment letters and emails were received, along with 117 form letters from individual members of environmental groups.  A 30-day public comment period on the Revised Preliminary EA  began on February 28, 2019.  During this public comment period, 113 unique comment letters and emails were received, along with 100 form letters from individual members of environmental groups.   Included on this project webpage is Appendix K to the Final EA. 

            Appendix K presents synopses of the publc comments received during review periods for the Preliminary and Revised Preliminary EA documents and BLM/Forest Service responses to those comments.

         
Provided separately from the Final EA documents is the 2017 Programmatic Biological Opinion (PBO) prepared by the U.S. Fish and Wildlife Service (USFWS) for effects on four endangered species of Colorado River fishes resulting from BLM-authorized oil and gas projects in the  Colorado River Basin (including the Green, mainstem Colorado, Gunnison, and Dolores Subbasins) of northwestern Colorado.  The 2017 PBO addresses depletions in streamflows related to consumptive water uses, including drilling, completions, hydrostatic testing of pipelines, and dust abatement, and identifies mandatory conservation (mitigation) measures.  The Final EA for the NFMMDP incoporates these conservation measures and references the PBO in the analysis of potential impacts to Federally listed or proposed threatened or endangered species.

Decision Process
            Although the BLM and Forest Service have prepared a joint Environmental Assessment for the North Fork Mancos Master Development Plan, the two agencies have separate decision processes.  Documents provided on this website include the body of the Final EA; the associated appendices, consisting of Appendices A through D, Appendices E through J, and Appendix K; the joint Finding of No Significant Impact (FONSI), and the BLM's Decision Record (DR).
            1.  The BLM DR issued with the EA approves  portions of the NFMMDP not involving National Forest System Lands and deferring a decision on portions that would occur on National Forest System lands.  This decision does not approve any Application for Permit to Drill (APD) or Right-of-Way (ROW) Grant or ROW Amendment associated with the proposed development on private lands.  Approval or denial of those components of development would not occur until completion of BLM's regulation-based APD and ROW processes.  
             2.  A Draft Decision by the Forest Service on its portion of the NFMMDP is provided on this website as well as the Forest Service website at https://www.fs.usda.gov/project/?project=50966.  Under that agency's process, legal notice of the Draft Decision initiates an objection period.  At the end of the objection period, the Forest Service will issue a Final Decision. 
             3.  The BLM will then issue a second DR, consistent with the Forest Service's Final Decision, for portions of the NFMMDP that involve the use of National Forest System lands.  This is explained in detail in the BLM DR provided on this website.