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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.
- Landowners that own the surface property but do
not own the mineral rights.
- 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! |
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