Amy Hadden Marsh: Could you talk about what is the pipeline that the public is commenting on? (Public comments on the pipeline’s federal environmental analysis were due Feb.3.)
Peter Hart: It's actually four pipelines. The proponent is Terra Energy Partners. They're requesting rights of way from the Bureau of Land Management and special and temporary use permits from the Forest Service to install and operate two water pipelines.
Those are produced water pipelines that will transport water produced during drilling and used for fracking operations. In addition to that, there are two natural gas pipelines that will be operated by Grand River Gathering, which is a subsidiary of Summit Midstream. Those pipelines are intended to take the gas that's produced from wells up in the West Mamm Creek area to market. What the agencies need to consider in their environmental analysis is if these oil and gas companies are producing natural gas to be burned. Then when they're producing that, they need to think about that end use and the impacts of that end use on climate, right? You have to examine and analyze the impacts of end use, basically from drilling the well to burning the gas.
AHM: Well, that's what brought the Uinta Basin Railway to the Supreme Court.
PH: Case law, I think, has over the years been sort of expanding the scope of analysis to the point where, you know, generally, the rule is that if you produce it, you need to actually consider the impacts of burning it. I think it's fair to say that you're well aware that the Supreme Court is doing what they can to constrain the scope of the required analysis.
AHM: Why did Wilderness Workshop decide to get involved at least with comments?
PH: Well, this is what we do, right? We monitor proposed development on public lands with an eye toward protecting the environment and the environmental values that we think make Colorado such a unique space and our public lands one of our greatest assets here. Our comments are asking the agencies to take a hard look at the potential impacts of the proposal, which, you know, frankly, we don't think that they've really done.
The E. A. [environmental analysis] says that these pipelines will facilitate up to 47 new wells in the West Mamm watershed, but we've seen maps showing plans to build more than 60 wells up there, and we've talked to local landowners who have heard from the company that they actually intend to drill maybe 70 wells up there, So, you know, I mean, there's, like, a moving target here. And so, you know, if the BLM and the U. S. Forest Service are going to approve these pipelines and if Terra Energy Partners isn't really being clear or consistent disclosing how many wells the pipelines may service, then, you know, we think that there's more analysis that needs to be done.
What the agency should do is they should look at the size of the pipelines. They should figure out how much gas it's going to take to fill that pipeline, to keep it full and operational, and then work backwards, based on average well production and decline, and figure out, okay, well, how many wells are we going to see? What would build out look like? How many wells would it take up in that Mamm Creek watershed to fill up this pipeline?
I mean, obviously when Terra Energy Partners designs a pipeline, they're basing the size of that pipeline on how much gas they think they might need to produce or want to produce from the area, right? So, you know, rather than having the agency take at face value the number of wells Terra Energy Partners says they might drill up there - which, like I said, does not seem to be consistent - it seems like they should look a little bit harder.
And the reason we think that's important is because Mamm Creek is a pretty special spot. I mean, it still retains a lot of that sort of rural character, which, you know, frankly has disappeared from a lot of the surrounding areas due to the amount of gas development that's occurred - sort of the industrialization that's happened. What the Forest Service and the BLM are going to do by approving these pipelines is ultimately industrialize West Mamm Creek. Then that is what the analysis should say.
Pipelines facilitate and induce additional development and that additional development results in fragmentation of wildlife habitat. It results in more drilling, which means more air emissions, more water use, more potential for water spills, more climate emissions.
All of those things are significant and they need to be looked at and disclosed, I think, to the public so that we know what we're getting into.
AHM: Can you talk briefly about the wildlife impacts?
PH: That's all important winter range for deer and elk. And so our concern is that if we're going to see 70 new wells up there, and who knows how many well pads, you know, that's a lot of fragmentation to some really important habitat.
AHM: Everything now is in significant winter range for deer and elk. I mean, the housing developments that we're dealing with in the Roaring Fork and Colorado River Valleys, it's like, as you know, the developments that have occurred over the decades in this area have been on winter range. And now we're looking at, I think, the last of the significant pieces of winter range.
PH: It's a huge part of our comments. Western Watersheds Project did a GIS analysis on the habitat values that would be affected. In the broader context, it highlights the fact that this West Mam Creek area really is sort of a unique pocket in a sea of industrial development, and makes the point that we have lost so much. And, we need to think really hard before we lose this too.
