PNG Leasing Analysis Questions and Answers

PNG Leasing Analysis Questions and Answers

Q: What is an oil and gas leasing analysis?
A: An analysis by the Forest Service to identify areas available for future leasing subject to the terms and conditions of the standard oil and gas lease form, or subject to constraints that would require the use of additional lease stipulations such as those prohibiting surface occupancy.

This analysis was an Environmental Impact Statement (EIS) and included resource specialist reports analyzing potential impacts to the various resources on the Pawnee National Grassland. The analysis considered the surface impacts. Documents, including the Final Record of Decision, regarding the project can be found online.

Q: What is the decision being made in the U.S. Forest Service Record of Decision?
A: The environmental impacts of this project are disclosed per the National Environmental Policy Act (NEPA) in an Environmental Impact Statement (EIS) with a decision being documented in the Record of Decision. Based on the analysis and information contained in the EIS, the Forest Supervisor determined which lands are available for lease, which lands will be administratively unavailable for lease, and what additional management direction will be incorporated in the Forest Plan. The Final Record of Decision is for the No Surface Occupancy Alternative.

Q: Does the BLM have to make any decisions?
A: The BLM must also comply with NEPA in deciding whether to include NFS lands in a competitive oil and gas lease sale and will adopt this NEPA document. The BLM authorizes all underground activities and effects.

Q: Will additional environmental analysis have to be completed for oil and gas projects?
A: The selected alternative is for no surface occupancy. Additional analyses are required for site specific proposals if there is disturbance (such as pipelines or access roads). This could be done through a Categorical Exclusion (CE), Environmental Assessment (EA), or EIS depending on the proposal, unless adequate detailed information is included in this programmatic analysis to account for the newly proposed activity.

Q: Why did you do this analysis?
A: The 1997 Forest Plan analyzed oil and gas development on the Pawnee National Grassland. Since the plan was signed, conditions, including technology and development interest, have changed. The current level of oil and gas development on the Pawnee was considered acceptable and consistent with the 1997 Plan; however, the expected increase in development presents the need to ensure continued consistency with the 1997 Plan.

More broadly, the Federal Onshore Oil and Gas Leasing Reform Act of 1987 requires the Forest Service to evaluate National Forest System lands for potential oil and gas leasing and establishes Forest Service consent authority for leasing prior to the Bureau of Land Management offering National Forest System lands for lease.

Q: Doesn’t the BLM have responsibility for Oil and Gas Leasing? If so, why is the Forest Service developing an Oil and Gas Leasing EIS?
A: The Forest Service and BLM are jointly responsible for oil and gas leasing on the Pawnee National Grassland. The BLM manages the Federal mineral estate. The Forest Service’s role in the Federal oil and gas program is to identify lands available for oil and gas leasing and also identify stipulations to be attached to future leases for minimizing impacts to surface resources. The BLM’s role is to serve as an independent authority in deciding whether to make leases available as part of a competitive oil and gas lease sale on lands the Forest Service has identified as available.

Q: How can the public be involved?
A: There were several opportunities for the public to provide input into this project. During the public scoping of the project proposal, which was incorporated into the Final EIS, the public was asked to provide input on the proposed action. Nearly 3,000 comments were received during the comment period. Forest Service employees reviewed these comments and addressed them in the Final EIS. 

Q: Who did the analysis?
A: The U.S. Forest Service had a team of resource specialists conduct this analysis. Along with Forest Service employees, there were cooperating agencies identified, who participate and provide information to the team.

Q: What types of items were considered in the analysis?
A: The potential effects of oil and gas related facilities, such as well pads, tank batteries, heater treaters, compressor stations, roads, pipelines, and powerlines, were included in the analysis.

Q: Did this analysis include fracking (hydraulic fracturing)?
A: The USFS does not regulate this activity and therefore it was not analyzed. There are state and other Federal agencies that regulate this activity and the expectation is that those regulations will be adhered to when/if specific project implementation occurs. The USFS role is to analyze and disclose effects of activities with respect to surface resources. Fracking will only be considered in relationship to those surface resources.

Q: Do you consider cumulative effects?
A: The EIS disclosed cumulative effects and analyzed those effects along with direct and indirect effects for the reasonable foreseeable development activities on surface resources.

Q: How many alternatives are included in the EIS?
A: The Final EIS analyzed three alternatives in detail, including No Action Alternative (continuing to utilize direction from the 1997 Forest Plan), No Lease Alternative, and No Surface Occupancy Alternative (the Forest Service and environmentally preferred alternative that was selected).

Other alternatives were considered within the EIS but not analyzed in detail.

Q: Why was the No Surface Occupancy Alternative the Forest Service and environmentally preferred alternative and therefore selected?
A: The Forest Service preferred this alternative because it allows for extraction of all the oil and gas resources while providing the most protection of surface resources and opportunities for other multiple uses.

This alternative also results in no surface disturbance of the unleased portion of the PNG and the fewest projected wells and well pads.  While the No Leasing Alternative prohibits the sale of federal leases (and occupancy of the PNG), this alternative results in 10 to 60 percent more surface disturbance, wells, and well pads on adjacent private lands. In addition, it does not provide any oil and gas resources on the unleased portion of the PNG.

Q: Following the DEIS, what is next in the process?
A: The Final EIS was released in December 2014 and the Final Record of Decision was signed on Feb. 9, 2015.

Q: How did you determine what the reasonably foreseeable development is?
A: The Forest Service used internal information, as well as information from the BLM and industry to estimate what future development could look like.

Q: How much of the Pawnee National Grassland could be available for oil and gas development?
A: Approximately 179,650 acres of the PNG (93%) could be developed for oil and gas production, storage, transportation, etc. This leasing analysis helped define what this means for the PNG with no surface occupancy.

Q: What has been leased since this decision was signed?
A: The BLM conducted a lease auction in May 2015, where 44 lease rights were sold with the No Surface Occupancy lease stipulation. This was 25,215 acres of National Forest System lands. There was a second auction with 102 lease parcels sold with the No Surface Occupancy lease stipulation. This included 79,483 acres of National Forest System lands.

Q: What are the roles for this analysis of the various agencies involved with oil and gas development in Colorado?
A: The BLM is considered a “cooperating agencies.” Other agencies involved included:

  • National Park Service
  • State: Colorado Division of Parks and Wildlife/Colorado Department of Public Health and Environment
  • U.S. Fish and Wildlife Service
  • Weld County (Commissioners)
  • Environmental Protection Agency

Q: Did you consider development on private land?
A: The analysis disclosed cumulative and connected effects as they affect surface resources managed by the U.S. Forest Service; however, there are not stipulations put on any development of private lands by the U.S. Forest Service.

Q: What about other uses on the Pawnee National Grassland?
A: The analysis considered the multiple uses on the PNG and the impacts future leasing could have on these activities.

Q: How deep are surface resources?
A: The Forest Service analyzes impacts to surface resources. Although paleontological and archeological resources are sometimes located under the surface, they are deemed resources that need to be analyzed and, in some cases, protected from activities. All other sub-surface activity, such as well drilling, casing, and other oil/gas related activities will be analyzed by the BLM.

Q: If this analysis doesn’t address wells, then what does?
A: This analysis addresses availability of lands to be leased. There will be another opportunity to do resource analysis if/when an Application to Drill is submitted.

Q: You mention technology has changed, what does that mean?
A: When the 1997 Forest Plan was developed, most drilling taking place was vertical. Now, horizontal drilling has become more common than in 1997. It is feasible, if enough subsurface resources exist, to drill multiple wells from one pad and drain a field or reservoir more efficiently than before. If a larger well pad can contain multiple wells, the result is fewer roads, pipelines, powerlines, traffic, and ancillary facilities. Technology to determine locations (3-D seismic testing) to drill has also changed over the past 15 years.

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Additional questions and answers regarding general oil and gas activities on the Pawnee National Grassland are also available.

Page last updated on May 19, 2016.