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Coal Bed Methane (CBM) Extraction
Has Come to Montana

By Craig Sharpe, Executive Director
Montana Wildlife Federation
April/May 2002

Why should the extraction of our nations cleanest fossil fuel be of concern to hunters, anglers, and wildlife enthusiasts that cherish open space landscapes and the abundant fish and game of southcentral and southeastern Montana?

The short answer is that right now in Montana CBM development is one of the largest environmental issues-threats to fish and wildlife that we face. The more detailed answer is that the significant far-reaching, detrimental short-term and long-term impacts of CBM development have consequences on our natural environment that will affect our treasured sport fisheries, premier big game, upland game birds, non-game mammals and birds, agriculture, soils, vegetation, waters, and hunting and fishing recreational opportunities.

The story of CBM development goes deep and is complex. In Montana CBM development involves the Bureau of Land Management (BLM); Montana Department of Environmental Quality; Montana Fish, Wildlife and Parks and other state agencies; the Montana legislature; local governments; eastern Montana private landowners; Native American lands; water quality and quantity; and the future of fish and game in as many as 16 counties identified as the "CBM emphasis area."

What is CBM?

CBM extraction technology dates to the late 1980s when the first wells were drilled in Alabama and southern Colorado. Methane currently supplies about 5% of the nation's natural gas and is found in conjunction with coal deposits.

Coal beds naturally retain ground water, which in turn traps methane gas within the coal bed. Extraction techniques involve drilling of wells, reducing water pressure from the aquifer in the coal seams, allowing the methane gas to be released and/or trapped at a well head, and then transferring it through a pipeline system to central collection sites. While there are a multitude of issues like air quality, instream flows and others, some of the largest issues for wildlife proponents are: 1) water quality, 2) dewatering of local and regional aquifers, 3) mineral rights, 4) surface disturbance and habitat fragmentation, 5) noise, 6) local social and economic issues, and 7) impacts on fish and wildlife and related public recreation.

Water

Water is the major by-product of the CBM extraction process. A single well may discharge from 12 to 20 gallons of water every minute (gpm) or approximately 17,000 to 28,000 gallons every day. When first drilled, up to 70 gpm may be withdrawn. Most distressing is that this water is pumped from subsurface groundwaters within the primary aquifers 24 hours a day, 365 days a year. Using conservative estimates of the number of potential wells in Montana, this could result in the withdrawal of at least 480 billion gallons of water.

Water is a requirement for all living things and in southeastern Montana, which receives less than 10 inches of moisture a year, it is a valuable and precious resource. The coal seams are the primary aquifers that hold the difference between life and death. Aquifers in this arid region, according to some reports, will take between 100-200 hundred years to recharge or refill if the water is withdrawn at predicted rates based on known coal volumes. For the agricultural community, the withdrawal could mean the loss of crop irrigation, springs and artesian wells, and domestic and stock watering wells. Many of these ranches have been reliant on the subsurface waters for 100 years and now they may lose it all. The natural carrying capacity of the land for plant communities, native flora, fauna, and subirrigated crops could also diminish. For local communities, the affects could be staggering.

CBM industry proponents claim that water discharged by the wells can be used for beneficial uses, but those uses are marginal at best. While marginally potable for humans and cattle, this water is unsuitable for crop irrigation, sustainable healthy fisheries, and even lawn watering. A major problem lies in elevated salinity or dissolved salts. Each CBM well produces about 20 tons of salt in a year. The polluted discharge water, or "product water," is deadly to many Montana native plants. Any use of the CBM wastewater on our landscapes will affect soil fertility. On some lands where CBM development has taken place, polluted waters are openly discharged on the surface on non-porous or clay soils, killing nearly every plant. Additionally, CBM discharged waters can contain high levels of arsenic, ammonia, boron, iron, manganese, radium, and fluoride. Discharged water high in sodium bicarbonates and other minerals is also incompatible with healthy fish populations.

The discharge of these waters into streams, rivers, coulees, irrigation ditches, and reservoirs, and onto surface soils, as is done at most operations, will adversely effect their ability to support a diversity of plant and aquatic life.

Requiring the discharged water to be held in holding facilities or containment ponds is one effort at mitigating environmental effects. However, most CBM development companies sight the increased cost of "lined" ponds as unreasonable. A danger with "unlined" ponds is that they can seep millions of gallons of high sodium water into nearby streams and rivers. Additionally, the question must be asked, "Who will clean up the pond after the site is no longer productive or are we creating another superfund site 10-20 years down the road?"

Mineral Rights

There are two significant issues for private landowners related to the extraction of CBM and mineral rights.

  1. Landowners that own the surface property but do not own the mineral rights.
  2. Landowners that own the surface property but have leased out the mineral rights.

Many landowners in coal seam regions are caught in the crossfire as high oil costs spur aggressive energy-hungry development companies to search out cheaper fuels so they can reap huge profits. Owning the surface land and not the mineral rights, "split estate" rights, a landowner is at risk that a company may develop a well site without permission. In most cases during the western land boom over a 100 years ago, when land was purchased from the government, the mineral rights did not go along with the land. Government land managers can lease these rights and, therefore, a landowner may not be able to stop the development of minerals below the surface. This was just the case when between 1996-2001 the BLM issued 500 CBM leases on more than 500,000 acres of private lands and some public lands. Fighting a developer requires costly litigation by a landowner with no guarantees. Landowners without mineral rights or a surface use agreement with the development company have little control over access, surface damage, water loss, and water quality degradation. Likewise, someone that owns the surface property but leases out their mineral rights may have limited control.

Surface Damage and Habitat Fragmentation

The development of a well site carries a litany of problems for wildlife. Wells require a complex network of access roads, pipelines, power lines, drill pads, and compressor stations. Each site may disturb a minimum of three acres, but as high as six acres of surface land. These lands may be agricultural, riparian areas, nesting and feeding areas for waterfowl, critical big game winter range, or land vital to the survival of upland game birds, non-game birds, and a myriad of other living creatures. The projected number of wells in Montana could mean the construction of 9,000 to 27,000 new roads spider-webbing across once secure habitat that supports deer, elk, antelope, sage grouse, sharptailed grouse, bears, big horn sheep, wild turkey, and other wildlife. Utility corridors and pipelines will further destroy and fragment habitat with between 27,000 and 83,000 miles of constructed routes. The impacts from loss of habitat and wildlife dispersal due to traffic and human disturbances could diminish populations if not seriously compromising sensitive species like sage grouse. The loud droning of compressor stations is recognized by many as a threat to birds such as sage grouse that depend on vocalizations during mating recruitment.

A study recently sighted in the Billings Gazette written about the impacts to Wyoming wildlife, "The Effects of Natural Gas Development on Sagebrush Steppe Passerines in Sublette County, Wyoming," documented a 50% reduction in songbirds that require sagebrush for their habitat within 100 meters of gas development roads.

This evil web of roads, pipelines, and stations can be compared to 40-acre mini-subdivisions crisscrossing a swath of once prime wildlife habitat and agricultural lands.

Wyoming

To grasp the significance to Montana, our wildlife, and to hunting and fishing, we only have to look south to our neighbor Wyoming. It has only been in the past three years that skyrocketing demands for cheap power sources and the gigantic coal reserves of Wyoming have triggered a CBM "rush." A landscape where deer and antelope once played is now broken-up by over 10,000 coal bed methane wells with a projection of 50,000 to 80,000 by 2010.

A recently released Wyoming Draft Environmental Impact Statement (DEIS) for 51,444 CBM wells sights the need for nearly 17,000 miles of new roads (over 64,000 acres), 20,000 miles of new pipelines, 5,300 miles of above-ground power lines, up to 1,200 surface water discharge facilities, and the discharge of 1.4 trillion gallons of water, or enough water for all the residents of Wyoming for 30 years. Over 400 miles of power lines were constructed in the past year alone. Half of the entire project area, over 4 million acres, is described by BLM as private surface lands ("split estate") over federal minerals. The DEIS describes the disturbances to wildlife from 51,444 wells as widespread and significant, yet, they are moving forward.

According to the Powder River Basin Resource Council, the Wyoming Game and Fish has stated that CBM development on this scale could have an unprecedented impact on sagebrush communities and the wildlife species they support, including mule deer, elk, antelope, waterfowl, sage and sharp-tailed grouse, and many non-game species. Right now, domestic and stock water wells are drying up or becoming contaminated with gas or other constituents as some water tables drop as much as 200 feet. Some stockgrowers are talking about reducing cattle production due to the loss of pastures. Based on BLM estimates, the entire Powder River Basin within Wyoming and Montana could see as many as 175,000 wells in the next ten years withdrawing up to eight trillion gallons of "product water."

Discussions and objections over the last year by conservationists and the State of Montana with Wyoming DEQ officials have led to one good thing: an agreement for a temporary halt to direct CBM "product water" discharge into the Tongue River in Wyoming. The Tongue flows from Wyoming into Montana and is the lifeblood for many ranchers, and for fish and wildlife in southeastern Montana.

One element of the water quality monitoring of the Tongue River in Montana implemented by the Colstrip High School Biology Program (led by Bernie and Dorothy Smith), is an ocular inventory of acro-invertebrates. The presence and diversity of macro-invertebrates is a useful indicator of riverine ecosystem health and, of course, a very significant forage component for fish. Macro-invertebrates species include mayflies, caddis flies, stoneflies, the larvae from these insects, and many more aquatic invertebrates. Data collected suggests the frequency and diversity of macro-invertebrates observed in the Tongue in Montana has declined significantly from pre-discharge data. This data is an example of one affect of significant impact downstream from Wyoming CBM sites. Discharges into the Powder River from newly proposed CBM sites are also on hold, temporarily. However, many other drainages continue to receive "product water" compromising water quality for many downstream users.

Montana

Methane extraction in Montana began in the fall of 1999 with the issuing of the first drill permits. Today there are already 233 wells pumping 1600 gallons of water every minute or more than 2 million gallons every day from aquifers primarily near Decker, Montana. The two primary 'Resource Management Plan' (RMP) areas in Montana, as described in a recently released Draft Environmental Impact Statement, are the Billings and Powder River Basin. While the coal seams in Montana are thinner than in Wyoming, CBM development is expected to explode in this region and may spread north following seams that reach all the way from our southeastern border with Wyoming to our border with Canada. The current hot "emphasis area" includes more than 1.5 million acres of federal-public land and over 3.5 million acres of private land with "split estate" mineral rights.

The rivers of significant impact in this area are the Tongue, Powder, Little Powder, Little Bighorn, and Yellowstone River. Many other area rivers and creeks could also suffer negative impacts from CBM development: the Clark Fork of the Yellowstone, Rosebud Creek, Musselshell River, Lodge Creek, Milk River, Squirrel Creek, Peoples Creek, and even as far west as the Boulder and Gallatin rivers. These waterways support 50 species of fish and CBM-introduced hydrologic influences could have huge impacts. Additionally, these areas are host to 7 Montana big game species, 34 species of small mammals, 17 species of predators, 250 species of birds, including 32 species of waterfowl, and a host of bats, shrews, amphibians, and reptiles. One company that has expressed an interest in the Bozeman to Livingston area has already leased mineral rights on 18,000 acres around Bozeman.

Current estimates are that between 14,000 to 23,000 wells could be drilled in Montana during the next 10 years. Conservative estimates of total water withdrawal are nearly 6 billion oilfield barrels of water (42 gallons per barrel). The affects on our aquifers and our fisheries are largely unknown.

In Montana, CBM "product water" is allowed to be discharged into rivers, streams, and creeks, and down coulees and across our open spaces because it is considered a byproduct of development and legally falls under a non-beneficial use.

As a result of a lawsuit and subsequent court settlement, there is currently a moratorium on new CBM drilling until the summer of 2002.

The enthusiasm of some Montana politicians to "secure" energy revenues caused the Montana legislature in 2001 to promote legislation that authorized (HB 573) "a compelling state interest to authorize the Board of Oil and Gas Conservation to act in a timely and expeditious manner to permit offset wells", and identified "a delay in the development of certain coal bed methane wells may inadvertently result in the loss of coal bed methane resources".

A final issue concerns the recent completion of a Montana Draft Environmental Impact Statement (DEIS) for the two "CBM emphasis areas." The total surface area of the CBM "emphasis area" (all owners) exceeds 25 million acres.

The DEIS is based on 18,000 wells, but this number could go as high as 70,000 by 2020.

While MWF believes the DEIS, unfortunately, is flawed and inadequate, it does recognize that: "Virtually every wildlife species that occurs within CBM development would be impacted with sensitive species suffering the greatest impacts." The DEIS mitigation measures and actions do not, however, offer any specific measures to address these impacts. There are no provisions or mitigation measures to protect opportunities for hunting and fishing. The DEIS does recognize, "The oil and gas infrastructure and activities would reduce the number of game animals in the area or force some game animals to leave the area, which would reduce or eliminate certain hunting activities."

Alternatives and Advocates to Ensure Our Montana

CBM development in Montana is in its infancy and most of the long-term impacts have not been adequately assessed. Yes, further CBM development will occur. Yes, CBM development will provide some economic benefits to local and our state economy. But, the staggering cumulative effects have such substantial potential to impact nearly over one-quarter of our Montana landscapes, our way of life, our farm and ranch communities, our fisheries, our wildlife, our surface and subsurface waters, and our hunting and fishing heritage -- sportsmen and sportswomen can hardly afford to be silent. The time for action by wildlife, hunting, and fishing advocates is now -- before it is too late! We must stand up and make our voices heard. We must demand that CBM development companies be held to the highest standards. We must demand our state and federal agencies, and our state legislature, take a cautious approach while establishing sideboards on development that protect our fisheries, our wildlife, and the habitat upon which they depend.

While some in the ranching community view environmentally-oriented organizations with skepticism, many could find substantial benefits with new constructive partnerships within the hunting and fishing community. Certainly the habitat degradation, the damage to water quality, the loss of water quantity, the access problems, and the loss of grazing lands will cause some ranchers to think about their options. Together, hunters, anglers, and agriculture can build an allegiance that ensures the sustainability of family farms and fish and game. Together we must demand the collection of data that can be used to analyze the long-range impacts to OUR Montana. Together we must demand a halt to a haphazard approach. Together we must say that mitigation is, in some cases, not good enough. Together we must ask our political representatives to stand strong and not bend to economic incentives. We must ask for surface owner protection laws, we must demand that discharge waters be reinjected back into aquifers, we must demand discharge water treatment, we must ask for reclamation of sites and roads, and we must demand bonding to compensate for damage or ensure reclamation. In some wildlife sensitive and environmentally-sensitive areas we simply need to say, "NO!"

Our wildlife, our fisheries, our ranching communities, our Montana is at risk. Some measures can be put in place to reduce the impacts of CBM development.

The time is now. We, as sportsmen and women, must step forward to protect OUR MONTANA!