BLM Environmental Assessment

U.S.
Department of the Interior

Bureau of Land Management
August 2019
December 2019 Competitive Oil and Gas Lease Sale

DOI-BLM-UT-0000-2019-0005-OTHER NEPA -EA
Utah State Office

440 W 200 S
Suite 500
SLC, UT 84101
DOI-BLM-UT-0000-2019-0005_Other NEPA -EA
August 2019
Table of Contents
Chapter 1 Purpose & Need .................................................................................................................... 1
1.1 Project Location and Legal Description........................................................................................ 1
1.2 Introduction ................................................................................................................................... 1
1.3 Background ................................................................................................................................... 2
1.4 Purpose and Need ......................................................................................................................... 4
1.5 Decision to be Made ..................................................................................................................... 4
1.6 Plan Conformance Review............................................................................................................ 4
1.7 Relationship to Statutes, Regulations, Policies or Other Plans ..................................................... 9
1.8 Issues Identified .......................................................................................................................... 10
1.9 Issue Statement Rationale for Not Further Discussing in Detail in the EA ................................ 11
1.10 Public Comment Period .............................................................................................................. 20
Chapter 2 Description of Alternatives ................................................................................................. 21
2.1 Introduction ................................................................................................................................. 21
2.2 Analysis Assumptions ................................................................................................................. 21
2.2.1 Reasonably Foreseeable Development Scenario ................................................................ 21
2.3 Alternative A – Proposed Action ................................................................................................ 23
2.4 Alternative B – No Action .......................................................................................................... 24
2.5 Other Alternatives Considered but Not Analyzed in Detail........................................................ 24
2.5.1 No Leasing Alternative (Designating the Parcels as Closed to Leasing) ............................ 24
2.5.2 Deferring Specific Parcels from the Sale ............................................................................ 24
2.5.3 Adding Stipulations Beyond those Required by the Management Plan ............................. 25
2.5.4 No Contribution to the Uinta Basin’s Air Quality .............................................................. 25
Chapter 3 Affected Environment ......................................................................................................... 26
3.1 Introduction ................................................................................................................................. 26
3.2 General Setting............................................................................................................................ 26
3.3 Resources/Issues Brought Forward for Analysis ........................................................................ 32
3.3.1 Issue 1: What are the Potential Impacts to Air Quality? ..................................................... 32
3.3.1.1 Affected Environment ................................................................................................. 32
3.3.1.2 Environmental Consequences ..................................................................................... 34
3.3.1.3 Required Design Features ........................................................................................... 37
3.3.1.4 Cumulative Impacts .................................................................................................... 37
3.3.2 Issue 2: What are the Potential Impacts of Oil and Gas Leasing to Climate
Change/Greenhouse Gases? ............................................................................................................... 41
i
August 2019
3.3.2.3 Mitigation of Impacts from GHG Emissions and Climate Change............................. 46
3.3.3 Issue 3: What are the potential impacts to the newly designated wilderness and the San
Rafael Recreation areas in Emery County? ........................................................................................ 54
3.3.3.3 Required Design Features ........................................................................................... 55
Chapter 4 Consultation and Coordination ........................................................................................... 56
4.1 Introduction ................................................................................................................................. 56
4.2 Persons, Groups, and Agencies Contacted/Consulted ................................................................ 56
4.2.1 Endangered Species Act of 1973 ........................................................................................ 56
4.2.2 National Historic Preservation Act (NHPA) of 1966.......................................................... 56
4.3 Public Participation ..................................................................................................................... 60
4.3.1 Modifications Based on Public Comment and Internal Review [Reserved] ....................... 60
4.4 Preparers ..................................................................................................................................... 60
Chapter 5 References ........................................................................................................................... 62
Chapter 6 Appendices .......................................................................................................................... 69
Appendix A – Parcel List with Stipulations and Notices ................................................................... 70
Appendix B – Stipulations and Notices ............................................................................................. 88
Stipulation Summary Table ........................................................................................................... 88
Notice Summary Table ................................................................................................................ 114
Threatened and Endangered Species Notices .............................................................................. 128
Appendix C – Figures/Maps ............................................................................................................ 163
Appendix D – Interdisciplinary Parcel Review Team Checklist...................................................... 176
Canyon Country District .............................................................................................................. 176
Color Country District ................................................................................................................. 212
Green River District ..................................................................................................................... 231
Appendix E – Air Quality and Green House Gas Information and Calculations ............................. 271
Appendix F – Acronyms/Abbreviations........................................................................................... 284
Appendix G – Reasonable Foreseeable Development of Leases Scenario ...................................... 285
Well Drilling and Completion Operations ................................................................................... 285
Production Operations ................................................................................................................. 287
Produced Water Handling ............................................................................................................ 287
ii
August 2019
Maintenance Operations .............................................................................................................. 288
Plugging and Abandonment ......................................................................................................... 288
Appendix H – Comments and Responses [Reserved] ...................................................................... 289
List of Tables
Table 1 Project Location by Field Office...................................................................................................... 1
Table 2. Issues Identified for Detailed Analysis ......................................................................................... 11
Table 3. Issues not included in Further Detail in the Environmental Assessment ...................................... 12
Table 4 Reasonably Foreseeable Development of Leases Scenario for the Nominated Parcels ................ 22
Table 5. Leasing Category Acreages for Moab Field Office. ..................................................................... 27
Table 6. Leasing Category Acreages for Monticello Field Office. ............................................................. 28
Table 7. Leasing Category Acreages for Richfield Field Office................................................................. 29
Table 8. Leasing Category Acreages for Price Field Office ....................................................................... 30
Table 9. Leasing Category Acreages for Vernal Field Office..................................................................... 31
Table 10. AQI Index Summary Statistics by County.................................................................................. 33
Table 11. 2015-2017 Criteria Pollutant Design Values .............................................................................. 33
Table 12. Annual Emissions Estimate for as Single Well (metric tons/year) ............................................. 35
Table 13 Visibility Impact Assessment for Development of Parcels near Capitol Reef National Park ..... 36
Table 14. Climate Trends ............................................................................................................................ 42
Table 15. Global Atmospheric Concentration and Rate of Change of Greenhouse Gases ......................... 42
Table 16. State, National, and Global GHG Emissions (CO2e) in Million Metric Tons per Year ............. 43
Table 17. Estimated Emissions from Construction and Operating Potential Future Wells ........................ 43
Table 18. Annual Estimated Emissions from Combustion of Produced Oil and Gas from the Proposed
Action.......................................................................................................................................................... 45
Table 19. Estimated Annual GHG Emissions (MT CO2e/yr.) from Existing and Reasonably Foreseeable
Oil and Gas Wells. ...................................................................................................................................... 47
Table 20. Comparison of Estimated Total Annual GHG Emissions with Annual State and National
Emissions .................................................................................................................................................... 47
Table 21 Annual Emissions Estimate from a Year of BLM Leasing (MT CO2e/yr). ................................. 48
Table 22. Expected wells from Each Field Office RMP, and Corresponding GHG Emissions ................. 48
Table 23. List of Contacts and Findings. .................................................................................................... 59
Table 24. Preparers of This EA. .................................................................................................................. 61
Table 25. 2014 Criteria Air Pollutant Emissions (tpy) in Utah by Source................................................ 272
Table 26. Triennial Inventory of HAPs (2014). ........................................................................................ 273
Table 27 Air Quality Impacts from Drilling a Single Well ...................................................................... 274
Table 28. Recent Trends in U.S. Greenhouse Gas Emissions (MMT CO2e) ............................................ 275
Table 29. Recent Trends in U.S. Energy Sector Greenhouse Gas Emissions (MMT CO2e) .................... 276
Table 30. Methane Emissions from U.S. Natural Gas Systems (MMT CO2e) ......................................... 277
Table 31. Single Well GHG Emissions Based on the Monument Butte FEIS Alternative B Inventory .. 278
Table 32. Single Well GHG Emissions Based on the Moab MLP FEIS Inventory .................................. 278
Table 33 Single Well GHG Emissions Based on the GSENM Kanab DEIS Inventory ........................... 279
Table 34. Production of Oil and Gas for a Single Well and Associated GHG Combustion Emissions ... 279
iii
August 2019
Table 35. Estimated Annual Operating Emissions from Existing Federal and Non-Federal Oil and Gas
Wells ......................................................................................................................................................... 281
Table 36. Annual GHG Emissions from Combustion of Produced Oil and Gas (2018) .......................... 281
Table 37. Estimated Annual Direct GHG Emissions from Development of APDs .................................. 282
Table 38. Gross Fossil Fuel Emissions from Federal Lands (MMT CO2e) .............................................. 282
Table 39. Net (Gross Emissions - Carbon Storage) Fossil Fuel Emissions from Federal Lands (MMT
CO2e)......................................................................................................................................................... 283
List of Figures
Figure 1. ARMS predicted ozone design values with on the books controls for oil and gas emissions in the
year 2021..................................................................................................................................................... 39
Figure 2. ARMS predicted PM2.5 design values with on the books controls for oil and gas emissions in
the year 2021. .............................................................................................................................................. 39
Figure 3. Potential for climate change impacts for the Colorado Plateau. .................................................. 50
Figure 4. Composite 2060 forecast for temperature departure from the baseline. ...................................... 51
Figure 5. Seasonal average time series of maximum 2-m air temperature for historical (black), RCP4.5
(blue), and RCP8.5 (red). Solid lines are the average and shaded areas represent the standard deviation. 52
Figure 6. Seasonal average time series of minimum 2-m air temperature for historical (black), RCP4.5
(blue), and RCP8.5 (red). Solid lines are the average and shaded areas represent the standard deviation. 52
Figure 7. Monthly averages of precipitation for four time periods for the RCP4.5 (left) and RCP8.5 (right)
simulations. The average of 30 CMIP5 models is indicated by the solid lines and their standard deviations
are indicated by the respective shaded envelopes. Triangle, diamond and square symbols indicate the
percent of models that simulate future minus present changes that are of the same sign and statistically
significant. A two-sided Students t-test is used to establish statistical significance (ρ ≤ 0.05). ................. 53
Figure 8. Parcel 024 and Parcel 025 Overview, Canyon Country District, Moab Field Office. ............... 164
Figure 9. Parcel 035 Overview, Canyon Country District, Monticello Field Office. ............................... 165
Figure 10 Parcel 031, Parcel 032, Parcel 033 and Parcel 034 Overview, Canyon Country District,
Monticello Field Office............................................................................................................................. 166
Figure 11 Parcel 027 Overview, Canyon Country District, Monticello Field Office. .............................. 167
Figure 12 Parcel 028, Parcel 029 and Parcel 030 Overview, Canyon Country District, Monticello Field
Office. ....................................................................................................................................................... 168
Figure 13 Parcel 006 Overview, Color Country District, Richfield Field Office. .................................... 169
Figure 14 Parcel 007 and Parcel 008 Overview, Color Country District, Richfield Field Office. ........... 170
Figure 17 Parcel 022 Overview, Green River District, Price Field Office. .............................................. 173
Figure 18 Parcel 014 and Parcel 017 Overview, Green River District, Price Field Office....................... 174
Figure 19 Parcel 026 Overview, Green River District, Vernal Field Office............................................. 175
Figure 20 Annual GHG emissions from major industrial sources in Utah in MMT CO2e ....................... 275
Figure 21 Total global GHG emissions in gigatons CO2e/yr. ................................................................... 276
Figure 22. Utah Federal fossil fuel GHG emissions (MMT CO2e) and trend for the period of 2005-2014.
.................................................................................................................................................................. 283
iv
August 2019
Environmental Assessment
DOI-BLM-UT-0000-2019-0005-OTHER_NEPA-EA
Chapter 1 Purpose & Need
1.1 Project Location and Legal Description

The preliminary parcel list contained 24 parcels covering 13,422.20 acres for the December 2019
Competitive Oil and Gas Lease Sale (lease sale) and are located on public lands administered by the
Bureau of Land Management’s (BLM) Monticello Field Office (MtFO), Richfield Field Office (RFO),
Price Field Office (PFO), Moab Field Office (MbFO), and Vernal Field Office (VFO) as described in
Table 1. The legal descriptions of the nominated parcels are in Appendix A – Parcel List with Stipulations
and Notices.
Table 1 Project Location by Field Office
Parcel Field Office County Parcel Field Office County
002 RFO Sevier 024 MbFO Grand
003 RFO Sevier 025 MbFO Grand
004 RFO Sanpete 026 VFO Uintah
005 RFO Sanpete 027 MtFO San Juan
009 PFO Emery 031 MtFO San Juan
010 PFO Emery 032 MtFO San Juan
014 PFO Carbon 033 MtFO San Juan
1.2 Introduction
The Utah State Office (UTSO) has prepared this environmental assessment (EA) to disclose and analyze
the environmental consequences for the selling of parcels and subsequent lease issuance to successful
bidders from the lease sale. This EA is an issue-base, site specific analysis of potential impacts that could
result from the implementation of a proposed action or alternative to the proposed action. The EA assists
the BLM in project planning and ensures compliance with the National Environmental Policy Act
(NEPA), and in making a determination as to whether any significant impacts could result from the
1
August 2019
analyzed actions. 1 This EA provides evidence for determining whether to prepare an Environmental
Impact Statement (EIS) or a statement of Finding of No Significant Impact (FONSI). If the decision
maker determines this project has significant impacts following the analysis in the EA, than an EIS would
be prepared. If not, a Decision Record (DR) may be signed for the EA approving the selected alternative,
either the proposed action or another alternative. A DR, including a FONSI statement, for this EA would
document the reasons why implementation of the selected alternative would not result in significant
environmental impacts (effects) beyond those already addressed in the governing land use plan (LUP) as
amended (Section 1.6).
1.3 Background
This EA analyzes 24 public-nominated parcels comprising of 13,422.20 acres for the lease sale that are
under the administration of the BLM. The 24 parcels were determined to be open to leasing for oil and
gas development under the applicable plans. The mineral rights for these parcels are owned by the federal
government and administered by the BLM. The legal descriptions of the nominated parcels are in
Appendix A – Parcel List with Stipulations and Notices.
During the land use planning process the BLM decides which public lands and minerals are open for
leasing and under what terms and conditions. In accord with Resource Management Plans (RMPs), lands
can be deemed open to leasing under standard terms and conditions, closed to leasing, or open under
special operating constraints identified as lease stipulations at the lease stage. Lease stipulations are used
to mitigate potential impacts to resources. Any surface management of non- BLM administered land
overlaying federal minerals is determined by the BLM in consultation with the appropriate surface
management agency or the private surface owner.
The Mineral Leasing Act of 1920 (MLA), as amended [30 U.S.C. 181 et seq.], and the Federal Onshore
Oil and Gas Leasing Reform Act of 1987 (FOOGLRA), require the BLM UTSO to conduct quarterly,
competitive lease sales to offer available oil and gas lease parcels in Utah. Expressions of Interest (EOI)
to nominate parcels for leasing by the BLM are submitted by the public. From these EOIs, the BLM
prepares the parcels and determines whether or not the existing analyses in the LUPs, as amended,
provide basis for leasing oil and gas resources within these parcels or if additional NEPA analysis is
needed before making a leasing decision.
In the process of preparing a lease sale, the UTSO compiles a list of lands nominated by the public,
legally available for leasing, and sends a preliminary parcel list to the appropriate District Office where
the parcels are located. Field Office staff reviews the legal descriptions of the parcels to determine if they
are in areas open to leasing under the relevant RMP, ensures appropriate stipulations have been applied
and identify any special resource conditions of which potential bidders should be made aware. Standard
lease terms also provide for reasonable measures to minimize adverse impacts to specific resource values,
land uses, or users (Standard Lease Terms are contained in Form 3100-11, Offer to Lease and Lease for
Oil and Gas, U.S. Department of the Interior, BLM, October 2008 or later edition). Compliance with
valid, nondiscretionary statutes (laws) is included in the standard lease terms.
Once the Field Offices completed the interdisciplinary parcel review (IDPR), the BLM determined that
preparation of an EA was necessary for considering the public nominated parcels for the lease sale. This
EA and an unsigned FONSI are made available to the public, along with the list of available parcels and
stipulations and notices, for a 30-day public comment period on the BLM’s NEPA Register 2 (also known
as ePlanning). The UTSO Oil and Gas Leasing webpage 3 is also updated and maintained for the lease
1 Significance is defined by NEPA, and is found in 40 Code of Federal Regulations (CFR) 1508.27
2
The NEPA Register is a BLM environmental information internet site and can be accessed online at: https://bit.ly/2Z5PlYd
3 UTSO Oil and Gas Leasing program webpage can be accessed at: http://go.usa.gov/xXk8c
2
August 2019
sale. Additional information regarding the BLM’s leasing process is also made available for public review
and reference. At the end of the public comment period, the BLM analyzes and incorporates the
comments, where appropriate, into the EA and/or parcel list. The final parcel list with stipulations and
notices is made available to the public through a Notice of Competitive Lease Sale (NCLS), which starts a
30-day protest period, and includes the revised EA and unsigned FONSI. If any changes to the parcels or
stipulations/notices result from the protests, an erratum to the NCLS would be posted to the BLM website
and on NEPA Register to notify the public of the change, prior to the lease sale. The parcels would be
available for sale at an online auction held by the BLM, tentatively scheduled for December 10, 2019.
If the parcel is not purchased at the lease sale by through the competitive bidding process, it may still be
leased non-competitively within two years after the initial offering at the minimum bid cost. Parcels
obtained non-competitively may be re-parceled by combining or deleting other previously offered lands.
Mineral estate that is not leased within a two-year period after an initial offering will no longer be
available and must go through another separate competitive lease sale process prior to being leased.
An issued lease may be held for ten years, after which the lease expires unless oil or gas is produced in
paying quantities (43 CFR 3107.2). A producing lease can be held indefinitely by economic production.
The act of leasing does not authorize any development or use of the surface of lease lands without further
application by the operator and approval by the BLM. In the future, operators must submit an Application
for Permit to Drill (APD) (Form 3160-3) to the BLM for approval and must possess an approved APD
prior to any surface disturbance in preparation for drilling. 4 An APD may only be approved when an
operator complies with any stipulations and/or notices attached to the standard lease form. If an APD is
received, the BLM would conduct additional site-specific NEPA analysis before deciding whether to
approve the APD, and what conditions of approval (COA) should apply.
Following BLM’s approval of an APD, a lessee may produce oil and gas from the well in a manner
approved by the BLM in the APD or in subsequent sundry notices. The operator must notify the
appropriate BLM authorized officer 48 hours before starting any surface disturbing activity approved in
the APD.
Standard lease terms provide for reasonable measures to minimize adverse impacts to specific resource
values, land uses, or users. Compliance with valid, nondiscretionary statutes (laws) is included in the
standard lease terms. Nondiscretionary actions include the BLM’s requirements under federal
environmental protection laws, such as Clean Water Act, Clean Air Act, Endangered Species Act,
National Historic Preservation Act, and Federal Land Policy and Management Act, which are applicable
to all actions on federal lands, including split estate. Also included in all leases are two mandatory
stipulations for the statutory protection of cultural resources and threatened or endangered species
(Handbook H-3120-1).
Once the lease has been issued, the lessee has the right to use as much of the leased land as necessary to
explore for, drill for, extract, remove, and dispose of oil and gas deposits located under the leased lands,
subject to the standard lease terms and additional restrictions attached to the lease in the form of lease
stipulations (S) (43 CFR 3101.1-2) and lease notices (LN) (43 CFR 3101.1-3). Even if no restrictions are
attached to the lease, the operations must be conducted in a manner that avoids unnecessary or undue
degradation of the environment and minimizes adverse impacts to the land, air, water, cultural, biological,
and visual elements of the environment, as well as other land uses or users.
4
Additional Information regarding the BLM’s oil and gas management program can be accessed online at:
https://www.blm.gov/programs/energy-and-minerals/oil-and-gas/
3
August 2019
1.4 Purpose and Need
The purpose of this action is for the UTSO to respond to the public nominations or expressions of interest
for oil and gas leasing on specific federal mineral estate through a competitive leasing process and either
lease or defer from leasing, pending additional information. The need for the Proposed Action is
established by the BLM’s responsibility under the MLA of 1920, as amended, the Mining and Minerals
Policy Act of 1970 as amended, the Federal Onshore Oil and Gas Leasing Reform Act of 1987 (Reform
Act) as amended, and Federal Land Policy and Management Act of 1976 as amended, and to promote the
development of oil and gas on the public domain. Parcels may be nominated by the public, the BLM or
other agencies. For the December 2019 Lease Sale, all parcels were nominated by the public. The MLA
establishes that deposits of oil and gas owned by the United States are subject to disposition in the form
and manner provided by the MLA under the rules and regulations prescribed by the Secretary of the
Interior, where consistent with FLPMA and other applicable laws, regulations, and policies.
1.5 Decision to be Made
Following the completion of the NEPA process the BLM would determine whether or not to lease the
nominated parcels and, if so, under what lease terms and conditions (stipulations and/or notices). In order
to make an informed decision, the BLM is using this EA to identify the environmental impacts of the
Proposed Action and its alternatives. This EA analyzes two alternatives. The first alternative analyzed is
the Proposed Action, the second is Alternative B, the No Action Alternative.
1.6 Plan Conformance Review

The statutes, regulations, policies, and plans utilized in preparing this EA include, but are not limited to
the following:
Statutes (As Amended)
• Federal Land Policy and Management Act of 1976 (FLMPA)
• Mineral Leasing Act of 1920 (MSA)
• Mining and Minerals Policy Act of 1970 (MMPA)
• Federal Onshore Oil and Gas Leasing Reform Act of 1987 (FOOGLRA)
• National Historic Preservation Act of 1966 (NHPA)
• Bald and Golden Eagle Protection Act of 1962 (BGEPA)
• Endangered Species Act of 1973 (ESA)
• Migratory Bird Treaty Act of 1918 (MBTA)
• Clean Water Act of 1972 (CWA)
Regulations
• 40 CFR Part 93 Subpart E
• 43 CFR 1600
• 43 CFR 3100
• 40 CFR 1500 – 1508
• 40 CFR 104
• 36 CFR 800
• 36CFR 60.4
4
August 2019
Manuals 5
• BLM Manual 6840 – Special Status Species
• BLM Manual 3120 – Competitive Leasing
• BLM Manual 6310 - Conducting Wilderness Characteristics Inventory of BLM Lands
• BLM Manual 6320 - Considering Lands with Wilderness Characteristics in the BLM Land Use
Planning Process
Handbooks 6
• Competitive Leasing Handbook (H-3120-1)
Policies/Instruction Memoranda (IM) 7

• Updating Oil and Gas Leasing Reform – Land Use Planning and Lease Parcel Reviews (WO IM
2018-034)
• Directional Drilling into Federal Mineral Estate from Well Pads on Non-Federal Locations (WO
IM 2018-014)
• Oil and Gas Leasing Program NEPA Procedures Pursuant to Leasing Reform (UT IM 2014-006)
• Utah Riparian Management Policy (2006)
• Utah’s Standards for Rangeland Health (1997)
• Utah BLM Drinking Water Source Protection Zone (2010)
• Secretarial Order 3355 Streamlining NEPA (2017)
• Secretarial Memorandum August 6, 2018, Streamlining Environmental Assessments
• Protection of Ground Water Associated with Oil and Gas Leasing, Exploration and Development
(BLM UT IM 2010–055)
• BLM Utah Guidance for Lands with Wilderness Characteristics Resource (UT IM 2016-027)
• Updated BLM Sensitive Species Lists for Utah (UT IM 2019-005)
• June 2019 Memorandum from Utah Deputy State Director, Lands and Minerals regarding
Preliminary List of Lands for Consideration in the December 2019 Competitive Oil and Gas
Lease Sale
• Guidance for Utah BLM to Meet Responsibilities under the Migratory Bird Treaty Act and
Executive Order 13186 (UT IM 2017–007)
Agreements
• MOU Among the United States Department of Agriculture, the United States Department of
Interior and the United States Environmental Protection Agency Regarding Air Quality Analysis
and Mitigation for Federal Oil and Gas Decisions through the NEPA Process (2011)
• State Protocol Agreement Between the Utah State Director of the Bureau of Land Management
and the Utah State Historic Preservation Officer Regarding the Manner in which the BLM Will
Meet its Responsibilities Under the National Historic Preservation Act and the National
5
BLM manuals can be accessed online at: https://www.blm.gov/media/blm-policy/manuals.
6
BLM handbooks can be accessed online at: https://www.blm.gov/media/blm-policy/handbooks.
7
BLM instruction memoranda and information bulletins can be accessed online at:
https://www.blm.gov/media/blm-policy/instruction-memorandum and https://www.blm.gov/media/blm-
policy/information-bulletin.
5
August 2019
Programmatic Agreement Among the BLM, the Advisory Council on Historic Preservation and
the National Conference of State Historic Preservation Officers (2001)
• MOU between the USDI BLM and USFWS to Promote the Conservation and Management of
Migratory Birds (April 2010)
State of Utah Plans/Rules

• Utah Wildlife Action Plan (2015)
• The Utah Oil and Gas Conservation Act (1955)
• The Utah Oil and Gas Conservation General Rules
• The State of Utah Resource Management Plan (State of Utah 2018)
BLM Activity Plans/Strategies/Practices

• T&E Habitat Management Plan (BLM 1990)
• Utah Air Resource Management Strategy (BLM 2018)
• Air Resource Management Program Strategy 2015-2020 (BLM 2015)
• Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development, The
Gold Book (USDI and USDA 2007)
• Executive Order 13186: Responsibilities of Federal Agencies to Protect Migratory Birds
• Utah Partners in Flight Avian Conservation Strategy Version 2.0 (Parrish et al., 2002)
• Birds of Conservation Concern 2002 (USFWS 2008)
• Moab Field Office Programmatic Invasive Species Management Plan, August, 2016
BLM Land Use Plans

• Moab Field Office RMP, October 2008 (Moab RMP) as amended Moab (BLM 2008)
• Record of Decision and Final Resource Management Plan. Moab Field Office. Moab, Utah.
(BLM 2008)
• Reasonably Foreseeable Development Scenario for Oil and Gas. Moab Field Office. Moab, Utah.
(BLM 2005)
• Moab Field Office Master Leasing Plan, July 2016, (Moab MLP) as maintained, Moab. (BLM
2016)
• Record of Decision and Moab MLP Approved RMP Amendments for Moab and Monticello Field
Offices. (BLM 2016)
• Reasonable Foreseeable Development Scenario for Oil and Gas in the Moab MLP Area, Canyon
Country District. (BLM 2012)
• Monticello Field Office RMP, August 2008, (MtFO RMP) as Maintained, Monticello (BLM
2008)
• Monticello Record of Decision and Approved RMP (BLM 2008)
• Monticello Reasonable Foreseeable Development Scenario for Oil and Gas (BLM 2005)
• Price Field Office Record of Decision and Approved RMP as amended, October 2008 (Price
RMP), Price (BLM 2008)
• Price Field Office Proposed Resource Management Plan/FEIS, Price (BLM 2008)
• Richfield Field Office RMP, October 2008 (Richfield RMP) as amended. Richfield, Utah (BLM
2008)
6
August 2019
• Record of Decision and Final Resource Management Plan. Richfield Field Office. Richfield, Utah
(BLM 2008).
• Reasonably Foreseeable Development Scenario for Oil and Gas. Richfield Field Office.
Richfield, Utah. (BLM 2005)
• Vernal Field Office Record of Decision and Approved RMP as amended, October 2008 (Vernal
RMP), Vernal (BLM 2008)
• Vernal Field Office FEIS, August 2008, Vernal (BLM 2008)
• 2015 Utah Greater Sage Grouse Approved Resource Management Plan/FEIS (BLM, Forest
Service 2015)
• 2015 Record of Decision and Approved RMP Amendments for the Great Basin Region, Including
the Greater Sage-Grouse Sub-Regions of Idaho, Southwestern Montana, Nevada, Northeaster
California, Oregon and Utah. (BLM 2015)
• 2015 Oil and Gas Reasonably Foreseeable Development Scenario for Greater Sage Grouse
Occupied Habitat in Utah Sub-region (BLM 2015)
• 2018 Utah Greater Sage-Grouse RMP Amendments/FEIS (BLM 2018)
• 2019 Record of Decision and Approved Utah Greater Sage-Grouse RMP Amendment (BLM
2019)
The alternatives described below are in conformance with the governing LUPs (as amended). Pursuant to
40 CFR 1508.28 and 1502.21, this EA is tiered to and incorporates by reference the information and
analysis contained in the current RMPs and RMP Amendments and their EIS. Specifically, proposed
actions align with the following BLM Land Use Plans within the designated Field Office boundaries (43
CFR 1610.5, BLM 1617.3).
Canyon Country District
Moab Field Office RMP, October 2008, as amended
The RMP designated approximately 1.45 million acres of federal mineral estate open for continued oil
and gas development and leasing (see RMP decisions Min-8, Min-11 to Min-16, and Min-19 on pages 74
through 76). Approximately 427,273 acres are open to oil and gas leasing, subject to standard terms,
806,994 acres will be subject to CSU/TL, 217,480 acres are subject to NSO, approximately 370,250 acres
are closed to oil and gas leasing. The RMP (with associated amendments) also describes specific
stipulations that would be attached to new leases offered in certain areas. Under the Proposed Action,
parcels to be offered would be leased subject to stipulations prescribed by the RMP (see RMP Appendix
A). Therefore, the Proposed Action conforms to the fluid mineral leasing decisions in the RMP and
subsequent amendments, and are consistent with the RMP’s goals and objectives for natural and cultural
resources. It is also consistent with RMP decisions and their corresponding goals and objectives related to
the management of (including but not limited to) air quality, cultural resources, recreation, riparian, soils,
water, vegetation, fish & wildlife and Areas of Critical Environmental Concern (ACEC).
Monticello RMP, October 2008, as amended

Record of Decision (ROD) The RMP designated approximately 1,290,919.00 acres of federal mineral
estate open for continued oil and gas development and leasing (see RMP/FEIS Table 4.121 on page 4-431
and RMP page 16). The RMP (with associated amendments and plan maintenance) also describes specific
parcels to be offered would be leased subject to stipulations prescribed by the RMP (see RMP MIN-6
through MIN-27 on page 80-81). Therefore, the Proposed Action conforms to the fluid mineral leasing
decisions in the RMP and subsequent amendments, and are consistent with the RMP’s goals and
objectives for natural and cultural resources. It is also consistent with RMP decisions and their
7
August 2019
corresponding goals and objectives related to the management of (including but not limited to) air quality,
cultural resources, recreation, riparian, soils, water, vegetation, fish & wildlife and Areas of Critical
Environmental Concern (ACEC).
Moab Master Leasing Plan and RMP, December 2016, as maintained

The RMP does not revise all management decisions in the Moab RMP, but it does amend certain
decisions pertaining to oil/gas and potash leasing. The Moab MLP updates leasing decisions in portions
of the existing RMPs for the Moab and Monticello Field Offices (see RMP decisions MIN-OG-1, MIN-
OG-2, MIN-OG-4 to 8 on page 17 through 19). Approximately 230, 765 acres are open to oil and gas
leasing, subject to CSU/TL stipulations, 305,899 acres are subject to NSO stipulation, 145, 284 acres are
closed to leasing (See RMP Appendix A, and Appendix B). Approximately 103, 619 acres within the
Potash Leasing Areas are open to oil and gas leasing subject to CSU/TL or NSO stipulations. The
Proposed Action conforms to the fluid mineral leasing decisions in the RMP and subsequent amendments,
and are consistent with the RMP’s goals and objectives for natural and cultural resources. It is also
consistent with RMP decisions and their corresponding goals and objectives related to the management of
(including but not limited to) air quality, cultural resources, recreation, riparian, soils, water, vegetation,
fish & wildlife and Areas of Critical Environmental Concern (ACEC).
Color Country District

Richfield Field Office RMP, October 2008, as amended
The RMP designated approximately 1.7 million acres of federal mineral estate open for continued oil and
gas development and leasing (see RMP decisions Min 1 to Min 11 on pages 135 through 136).
Approximately 608,700 acres are open to oil and gas leasing, subject to standard terms, 715,800 acres will
be subject to CSU/TL, 551,620 acres are subject to NSO, approximately 447,300 acres are closed to oil
and gas leasing (RMP page 17). The RMP (with associated amendments) also describes specific
parcels to be offered would be leased subject to stipulations prescribed by the RMP (see RMP Appendix
11, 12, 14, and 15). Therefore, the Proposed Action conforms to the fluid mineral leasing decisions in the
RMP and subsequent amendments, and are consistent with the RMP’s goals and objectives for natural
and cultural resources. It is also consistent with RMP decisions and their corresponding goals and
objectives related to the management of (including but not limited to) air quality, cultural resources,
recreation, riparian, soils, water, vegetation, fish & wildlife, and Areas of Critical Environmental Concern
(ACEC).
Green River District

Price Field Office RMP, October 2008, as amended
The RMP designated approximately 1,910,000 acres of federal mineral estate open for continued oil and
gas development and leasing. The RMP (with associated amendments) also describes specific stipulations
that would be attached to new leases offered in certain areas. Under the Proposed Action, parcels to be
offered would be leased subject to stipulations prescribed by the RMP. Therefore, the Proposed Action
conforms to the fluid mineral leasing decisions in the RMP and subsequent amendments, and are
consistent with the RMP’s goals and objectives for natural and cultural resources.
8
August 2019
Vernal Field Office RMP, October 2008, as amended
The RMP designated approximately 1,727,200 acres of federal mineral estate open for continued oil and
gas development and leasing (see RMP decisions Min 6 to Min 14 on pages 98 through 99). The RMP
(with associated amendments) also describes specific stipulations that would be attached to new leases
offered in certain areas. Under the Proposed Action, parcels to be offered would be leased subject to
stipulations prescribed by the RMP (see RMP Appendices K. L, and R). Therefore, the Proposed Action
conforms to the fluid mineral leasing decisions in the RMP and subsequent amendments, and are
consistent with the RMP’s goals and objectives for natural and cultural resources. It is also consistent
with RMP decisions and their corresponding goals and objectives related to the management of (including
but not limited to) air quality, cultural resources, recreation, riparian, soils, water, vegetation, fish &
wildlife, and Areas of Critical Environmental Concern (ACEC).
Utah Greater Sage Grouse

Utah Greater Sage Grouse Approved Resource Management Plan Amendment (ARMPA),
Approved March 2015 and Jan 2019
The ROD prepared for the 2015 ARMPA (DOI-BLM-UT-9100-2013-EIS) and the 2019 ARMPA
implemented greater sage-grouse management goals and objectives, including amending leasing
categories for managing the mineral estate. The Proposed Action is in conformance with the minerals
decisions of the Utah Greater Sage Grouse (ROD/RMP) (BLM 2015), except those decisions that were
amended by the 2019 plan. Leasing actions are specifically provided for in those planning decisions
(Management Actions for Minerals Resources)-. Under the Proposed Action, parcels to be offered would
be leased subject to stipulations prescribed by the RMP (2015 RMP Appendix G). Specific management
actions for Utah’s BLMs programs in the 2015 ARMPA are contained in the ROD Attachment 4 and in
the ROD for the 2019 ARMPA.
1.7 Relationship to Statutes, Regulations, Policies or Other Plans

The alternatives described below are also consistent with the LUPs decisions related to the management
of the following resources/uses, including but not limited to: fire/fuels, geology/mineral resources,
invasive species/noxious weeds, lands, livestock grazing, recreation, socio economics,
travel/transportation, soil/vegetation, visual resources, and forestry. Other NEPA documents and relevant
studies that are applicable to this analysis include:
• Inventory of Onshore Federal Oil and Natural Gas Resources and Restrictions to Their
Development 2008 Phase III inventory-Onshore United States
• 2007 Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17
Western States Programmatic Environmental Impact Statement and Record of Decision (BLM
2007)
• 2008 Monticello Field Office ROD (BLM 2008) and RMP/FEIS (BLM 2008) as amended
• 2008 Biological Opinion for the Monticello Field Office RMP 8 (BLM 2008)
• Moab Field Office Proposed RMP and Final Environmental Impact Statement (PRMP) (BLM
2016)and Record of Decision (BLM 2008)
• Biological Opinion for the Moab RMP (BLM 2008)
8
MtFO ROD, RMP/FEIS is located on ePlanning at https://eplanning.blm.gov/epl-front-
office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentPageId=98873
9
August 2019
• Moab Master Leasing Plan and Proposed Resource Management Plan Amendments/Final
Environmental Impact Statement (MLP/FEIS) (BLM 2016)and Record of Decision (BLM 2016)
• 2009 Canyons of the Ancients National Monument Proposed Resource Management Plan and
Final Environmental Impact Statement. (BLM 2009)
• 2016 Biological Opinion for the Moab Master Leasing Plan (BLM 2016)
• 2008 Price Field Office FEIS and approved RMP as amended (BLM 2008)
• 2008 Price Field Office ROD and approved RMP (BLM 2008)
• Biological Opinion for the Price Field Office RMP (USFWS 2008)
• 2008 Richfield Field Office ROD and approved RMP as amended (BLM 2008)
• 2008 Richfield Field Office FEIS and approved RMP as amended (BLM 2008)
• Biological Opinion for the Richfield RMP (BLM 2008)
• 2008 Vernal Field Office ROD and approved RMP as amended (BLM 2008)
• 2008 Vernal Field Office FEIS (BLM 2008)
• Biological Opinion for the Vernal RMP (USFWS 2008)
• 2015 Utah Greater Sage Grouse ROD and ARMPA (BLM 2015)
• 2019 Utah Greater Sage Grouse ROD and ARMPA (BLM 2019)
• 2017 Vernal Field Office Invasive Plant Management Plan (BLM-UT-G010-2016-011-EA)
(BLM 2017)
• December 2019 Lease Sale Cultural Resources Report (Utah SHPO Case No.
U19BL0485)[ongoing] (BLM 2019)
In order to reduce redundant paperwork and analysis in the NEPA process (See 40 CFR 1502.20 and
1502.21) the previous documents and their associated information or analysis are hereby incorporated by
reference. The attached IDPR Checklist, Appendix D – Interdisciplinary Parcel Review Team Checklist
was also developed after consideration of these documents and their contents.
1.8 Issues Identified
Identification of issues, concerns, and potential impacts that require detailed analysis was accomplished
through internal review/discussion. The UTSO sent letters/ memorandum to the following stakeholders:
the National Park Service (NPS), the United States Fish and Wildlife Service (USFWS), the United States
Forest Service (USFS), the State of Utah’s Public Lands Policy Coordination Office (PLPCO), Division
of Wildlife Resources (UDWR), and the School Institutional Trust Lands Administration (SITLA) to
notify them of the pending lease sale, and solicit comments and concerns on the preliminary parcel list.
The BLM also provided GIS shapefiles depicting the proposed sale parcels to contacts within the NPS
and UDWR. Consultation and coordination efforts are summarized in Chapter 4, Table 23.
The UTSO received the December 2019 lease sale parcel nomination list on June 25, 2019.
Internal scoping was initiated on July 24, 2019 when the nominated lease parcels for the December 2019
competitive oil and gas lease sale were presented to the Interdisciplinary (ID) Team. Resource specialists
on the ID teams helped identify the following issues through coordination, and meetings.
The key issues identified through the scoping process were developed using the guidelines set forth in
section 8.3.3 of the BLM NEPA Handbook and EA are summarized in Table 2 and Table 3, below.
10
August 2019
Table 2. Issues Identified for Detailed Analysis
Issue Issue Statement Impact Indicator
Air Quality What quantity of air pollutants would be Tons per year of PM-10,
produced based on the reasonably PM-2.5, NO X, SO2, CO,
foreseeable development (RFD) scenario? VOCs, HAPs.
How would air pollutant emissions from
subsequent development of leased parcels
affect air quality?
Greenhouse What quantity of greenhouse gas emissions Metric tons (MT) or million
Gas/Climate (GHG) would be generated from subsequent metric tons (MMT) per year of
Change oil and gas development of leased parcels carbon dioxide equivalents
based upon the RFD scenario? How do (CO2eq)
these amounts compare to other sources of
GHGs?
Wilderness Areas What would be the impacts to wilderness Length of time and intensity
characteristics from development outside the of that auditory impacts
Wilderness boundary? would affect solitude.
1.9 Issue Statement Rationale for Not Further Discussing in Detail in the EA9
Where resources are present but not determined to be impacted or resources are determined not to be
present, a rationale for not considering them further is provided in the Interdisciplinary Parcel Review
Team (IDPRT) checklist (Appendix D – Interdisciplinary Parcel Review Team Checklist), and in the
external coordination as described in Table 23. Table 3 highlights key issues evaluated and not discussed
in further detail in this EA for the resources the BLM commonly receives public comments and/or
interests. These resources are described below in Table 3.
9
Refer to the IDPRT checklist (Appendix D – Interdisciplinary Parcel Review Team Checklist) for the complete
rational for resources identified for analysis and resources not considered for further detailed analyses.
11
August 2019
Table 3. Issues not included in Further Detail in the Environmental Assessment
Issue Issue Statement Rationale for Not Further Discussing in Detail in the EA
T&E Species What are the potential The parcels involved in the December 2019 lease sale were analyzed individually within each field office
impacts to federally-listed for occurrence of federally-listed species, in coordination with the USFWS. The Threatened and
threatened and Endangered Species Act Stipulation is applied across all lease parcels, and states that if any parcel is
endangered species or found to contain plants, animals or their habitats determined to be threatened, endangered or special
habitats in areas related to status species, the BLM may recommend modifications to exploration and development proposals to
oil and gas development? further its conservation and management objective. Under this stipulation, the BLM may also require
modifications to or disapprove proposed activity that is likely to result in jeopardy to the continued
existence of a proposed or listed threatened or endangered species, or result in destruction or adverse
modification of a designated or proposed critical habitat.
As appropriate, BLM attaches stipulations or notices to the lease which give notice to the lessor/operator
of potential for occurrence of federally-listed species, and measures that may be required to mitigate
impacts.
The BLM will not approve any ground-disturbing activity that may affect any such species or critical
habitat until it completes its obligations under applicable requirements of the Endangered Species Act as
amended, 16 U.S.C. § 1531 et seq., including completion of any required procedure for conference or
consultation.
BLM Sensitive What are the potential The Federal Land Policy and Management Act of 1976, Section 102.8, requires environmental resources
Species impacts to BLM sensitive to be managed to provide food and habitat for fish and wildlife. The Sikes Act instructs agencies to
(Wildlife and species (wildlife and develop, maintain, and coordinate programs for the conservation and rehabilitation of wildlife, fish and
Plants) plants) or their habitats game (16 U.S.C. 670g et seq., section 670h). The DOI Manual 632 and BLM Manual 6840 requires
from oil and gas conservation of special status species and the ecosystems upon which they depend on BLM-administered
development? lands. BLM special status species are those listed or proposed for listing under the ESA, and species
requiring special management consideration to promote their conservation and reduce the likelihood and
need for future listing under the ESA. Instructional Memorandum No. UT IM-2019-005 provides the
plant and wildlife Species lists for BLM-administered public lands in Utah and these species have been
evaluated for potential impacts from the proposed lease sale, as documented by the checklist found in
Appendix D of this EA.
The Utah BLM has several lease notices that protect sensitive species statewide (see UT-LN-49 Utah
Sensitive Species in Appendix A of this document) or on a species specific basis (for example, see UT-
LN-107: Bald Eagle). For the December 2019 lease sale, the BLM analysis of potential for impacts to
12
August 2019
sensitive wildlife and plants or their habitat, and determined that application of the UT-LN-49: Utah
Sensitive Species to all parcels in the sale will notify the lessee/operator that no surface use or otherwise
disruptive activity would be allowed that would result in direct disturbance to populations or individual
special status plant and animal species, and that modifications to the Surface Use Plan of Operations may
be required to protect these resources from surface disturbing activities.
Specific parcels have been identified as having occurrence, or potential occurrence of several species of
plants or animals that may require modification of surface use plans to avoid disruptive or harmful
activities. In addition, multiple parcels contained sensitive habitat for game species such as elk, mule
deer or pronghorn antelope. Lease notices specified by parcel in Appendices A and D of this EA identify
those species to make the operator aware of possible additional action. Justification for stipulations and
lease notices applied by parcel is discussed in detail in Appendix D of this EA.
Leasing of the proposed leases would not, by itself, authorize any ground disturbance; however, the
proposed lease sale has the potential to impact habitat through future oil and gas development. Although
site-specific effects cannot be analyzed until an exploration or development application is received,
attachments of stipulations and notices to leases will assure the opportunity to make adjustments, such as
design modifications, at the site specific level when an Application for Permit to Drill is received, to
address specific wildlife and plant resources.
Migratory Birds What are the potential The Migratory Bird Treaty Act (MBTA) protects migratory birds; Instructional Memorandum No. 2008-
impacts to migratory 050 requires the BLM to Address the potential effects of the project son migratory bird populations and
birds from oil and gas their habitat, and implement best management practices to avoid or minimize the possibility of impacts,
development? through such measures as timing limitations during nesting seasons, surveys for bird nests, and
monitoring (https://www.blm.gov/policy/im-2008-050).
The Utah BLM has several lease notices that implement this policy during lease sales, ranging from those
applied statewide (UT-LN-45: Migratory Birds, found in Appendix B of this document) to species
specific (see UT-LN-107L Bald Eagle and UT-LN-44 Raptors). In addition, several migratory birds have
been designated as BLM Sensitive Species, and these may have additional protections through notices to
potential buyers of potential for occurrence on a given parcel (see UT-LN-49).
For the December 2019 lease sale, the BLM analysis of potential for occurrence indicated that application
of the following lease notices was appropriate for every parcel in the sale, UT-LN-43 Raptors, and UT-
LN-45: Migratory Birds.
13
August 2019
UT-LN-43 provides that raptor habitat exists in a given parcel, and that surveys will be required to
identify any nesting birds. UT-LN-45 gives prospective buyers notice that surveys for nesting migratory
birds may be required during migratory bird breeding season whenever surface disturbances and/or
occupancy is proposed in association with fluid mineral exploration and development within priority
habitats. Based on these surveys, buffers and timing limitations may be applied. In combination these
lease notices provide mitigation measures which will mitigate impacts to migratory birds, by allowing the
opportunity to make adjustments, such as design modifications, at the site specific level when an
Application for Permit to Drill is received.
Greater Sage What are the potential Resource Management plans for each office affected by the December 2019 lease sale analyzed the
Grouse impacts to Greater Sage effects of leasing and developing oil and gas resources on sage-grouse and other sensitive wildlife
Grouse from oil and gas species. On March 14, 2019, the BLM approved the Utah Greater Sage-Grouse Resource Management
development? Plan Amendment (ARMPA), which guides management actions for greater sage-grouse (GRSG) habitat
management areas (BLM 2019). The ARMPA identifies priority habitat management areas (PHMA) for
BLM-administered sage-grouse habitat across Utah, and provides measures to minimize impacts to
PHMA where they cannot be avoided.
Greater sage grouse inhabit sagebrush plains, foothills, and mountain valleys. Greater sage grouse are a
sagebrush obligate species, therefore require quality sagebrush habitat, especially for brood rearing and
wintering habitat. No PHMA has been identified within the nominated parcels, and no known leks have
been identified within 4 miles of the parcels. Only two lease parcels contained in the December 2019
lease sale, parcels 007 and 014, overlap summer and winter seasonal habitat located outside PHMA.
Implementation of UT-LN-49 on lease parcels 007 and 014 will allow the BLM to require modifications
to the Surface Use Plan of Operations may be required to minimize impact to GRSG seasonal summer
habitat and individuals of the species that may occur in these parcels. Collectively the stipulation and
notice will minimize impacts to the species to the degree that no additional detailed analysis in this EA is
necessary.
Paleontology What are the potential Fossils uncovered during ground disturbing activities would be protected owing to the standard discovery
impacts on the integrity requirements. Additionally, should a parcel be located in an area that has high potential for
of paleontological paleontological resources, COAs would be applied at the APD stage. The proponent may be required to
resources associated with do pre-constructional surveys and/or have a paleontologist onsite for any surface disturbing activities.
oil and gas disturbance? The proponent is required to notify the BLM of any discoveries they come across during construction
following the APD stage.
14
August 2019
According to the 2008 MtFO RMP FEIS: “Based on the percentage of non-WSA lands with wilderness
Lands With What are the potential
characteristics and the existing and pending leases within those areas, the highest potential for leasing and
Wilderness impacts to Lands With
development would be in Comb Ridge, Cross Canyon, and Squaw and Papoose Canyon. Given that the
Characteristics Wilderness
projection for drilling for oil and gas is three wells per year for all of the public lands within the Blanding
Characteristics?
Subbasin area, and that just over 9% of the development area includes non-WSA lands with wilderness
characteristics open to leasing under standard stipulations, CSU, or TL stipulations, it is still anticipated
that up to one well per year would be drilled in the non-WSA lands with wilderness characteristics
because the Blanding Sub-basin area contains oil and gas fields and the majority of existing wells within
the Monticello PA. This would disturb up to 9.6 acres per year, or approximately 144 acres over the next
15 years…Leasing and development within these non-WSA lands with wilderness characteristics would
cause the affected portion to lose its natural characteristics. Loss of opportunities for solitude and
primitive recreation due to exploration for and development of oil and gas resources would be broader
than just for the 144 acres of direct surface-disturbing activities, and could impact these values for up to
one-half mile from the ongoing activity. However, it is not anticipated that any of the areas would lose
their wilderness characteristics in totality because of the small amount of acreage projected to be
disturbed and the few projected wells in this development area over the next 15 years.”On October 21,
2014, the Southern Utah Wilderness Alliance (SUWA) submitted information suggesting the presence of
wilderness characteristics in the Tin Cup Mesa Central and Monument Canyon units. BLM conducted an
analysis and lands within these units were found to possess wilderness character (WC) as determined by
the Documentation of BLM Wilderness Characteristics Inventory Findings: The Tin Cup Mesa Unit was
found to have 9,743 acres of Wilderness Characteristics, and the Monument Canyon Unit was found to
have 17,200 acres, adding a total of 26,953 acres of identified acres of WC within the Blanding Subbasin
area. At the time the RMP FEIS was prepared, there were 38,540 acres of identified acres of wilderness
characteristics, however since that time the Fish and Owl Creeks, Lime Creek, Road Canyon, San Juan
River and Comb Ridge, Unit, consisting of 33,260 acres, have been incorporated into the Bears Ears
National Monument and is no longer available for lease, leaving 32,233 acres of wilderness
characteristics available for lease, or a 20% decrease in lands with wilderness characteristics within the
Blanding Subbasin available for lease. Thus, the RMP FEIS projection of a total loss of 144 acres of
wilderness characteristics with no totality of loss in any one unit is still valid.
Since the Monument Canyon Unit was found to possess wilderness characteristics subsequent to the
RMP, it was not considered to be subject to RMP decision WC-1 to “Protect, maintain and preserve
wilderness characteristics…” However the March 2018 Oil and Gas Lease EA disclosed the possible
impairment of the Unit, and the decision was made to lease several parcels within the units. This lease
15
August 2019
sale will increase the acreage leased in the unit, to a total of about 80% leased. This number cannot be
extended out to the projected acres of wilderness characteristics that may be impacted beyond saying
that the Units may experience a decrease of no, some or all of its wilderness characteristics.
National What are the potential On July 3, 2019, Shape files and other information were sent to the National Park Units within Utah to
Historic impacts to Capital Reef scope for possible impacts to Park lands from leasing. On July 31, 2019, Joe Neubauer of the Park
Trails/Units of National Park? Service called to ask for more information about the parcels, 009 and 010 near Capital Reef National
the National Park. (CRNP)
Park Service
Parcels 009 and 010 are in the vicinity of a small gas strike that was made in the 1950s. There is little
potential for oil production in the area. Oil production tends to be more obtrusive due to the need for
pumpjacks and multiple tanks to be staged on the drill pad for the life of the well, and because of the need
for large trucks to regularly visit the site to transport the oil. Gas wells typically have only a wellhead and
a tank for condensate. Gas well sites are typically much quieter than oil due to there being no need for
engines and motors to run the pumpjacks.
Development of the parcels would require a gas pipeline from the area to connect into existing pipeline
infrastructure. The lack of existing infrastructure within 30 miles would constrain development of the
parcels. However, should exploration and development occur, the time period that there would be
obtrusive impacts would be limited to the drilling, completion and workover stages.
An operator/lessee must state the routes it intends to use to access a drill site when submitting an APD. It
is possible the potential lessee would propose to access the parcels via the Hartnet-Cathedral Road Class
B road in Wayne County, a road claimed by Wayne County as an RS 2477 Right-of-Way. The road
crosses into the northeast corner of the CNP. The County’s claim has not been adjudicated and the NPS
would likely object to commercial use of it through CRNP. However, the logistics of accessing the
parcels from this route rather than the Class B Last Chance Loop Route through Emery County makes it
unlikely the operator would propose the Hartnet Cathedral Road. A Lease Notice is attached to the
parcels stating that the BLM does not guarantee access to the parcels from the south across Park Service
lands.
Mitigating measures to prevent impacts to night skies can be addressed at the APD stage when COAs can
be attached to the permit to minimize light sources.
Cultural What are the potential The BLM has conducted a literature search using survey and site information from the CURES
Resources impacts from ground geodatabase, Preservation Pro, DAM, GLO maps, and Field Office records to identify currently known
disturbing oil and gas sites within the lease parcels, and to determine whether these sites could be avoided or mitigated
16
August 2019
activities on cultural through standard archaeological practices at the APD stage.
resources?
The Cultural Resources and Tribal Consultation Stipulation (H 3120-1) is applied across all lease parcels.
This stipulation states that the lease area may be found to contain historic properties and/or resources
protected under the National Historic Preservation Act (NHPA), American Indian Religious Freedom
Act, Native American Graves Protection and Repatriation Act, Executive Order 13007, or other statutes
and executive orders. The BLM will not approve any ground-disturbing activities that may affect any
such properties or resources until it completes its obligations (e.g., State Historic Preservation Officer
(SHPO) and tribal consultation) under applicable requirements of the NHPA and other authorities.
The BLM may require modification to exploration or development proposals to protect such properties,
or disapprove any activity that is likely to result in adverse effects that cannot be successfully avoided,
minimized, or mitigated. Moreover, prior to granting APDs on Federal surface or split-estate lands,
cultural resource inventories are required.
Riparian/ What are the potential Resource Management plans for each office affected by the December 2019 lease sale analyzed the
Wetlands/ impacts from oil and gas effects of leasing and developing oil and gas resources on water resources and associated features.
Floodplains exploration and Leasing of parcels would not directly affect these resources. Current regulations such as Onshore Order
development ground #1, Onshore Order #2, Onshore Order #7, 43 CFR 3162.3-3, section 404 of the 1972 Clean Water Act as
disturbing activities on amended, and 1974 Safe Drinking Water Act as amended, 1968 Floodplain Regulation Act as amended
riparian, wetlands, and provide additional protection to water resources. BMPs, SOPs, and site specific mitigation may be
floodplains? applied at the APD stage as COAs. Applying the following stipulations to parcels as needed will
minimize potential impacts to wetland and riparian resources.
UT-LN-53— Riparian Areas states no surface use or otherwise disruptive activity allowed within 100
meters of riparian areas.
UT-S-386—NSO: Water Resources mandates no surface occupancy within 100-year floodplains, and
within 500 feet of intermittent and perennial streams, rivers, riparian area, wetlands, water wells, and
springs.
UT-S-387—NSO: Ephemeral Streams and states no surface occupancy allowed within 100 feet of
ephemeral streams.
UT-LN-128— Floodplains Management mandates avoiding adverse impacts to floodplains.
17
August 2019
With these stipulations and other site specific mitigation practices, no additional analysis is required in
this EA.
Potential site-specific impacts relating to future authorizations will be analyzed when an APD is received.
Hydrology/ What are the potential
Prior to approving an APD, Hydrologic and Engineering reviews would be conducted on all proposed
impacts from oil and gas
Surface and down-hole activities, including hydraulic fracturing (if proposed). All appropriate regulatory and
exploration and
Groundwater mitigation measures would be included in the approved APDs and all potential impacts would be
development ground
Resources identified and addressed during the site-specific NEPA process.
disturbing activities on
hydrology and
Groundwater:
hydrogeology?
Groundwater quality protection for oil and gas leasing, exploration and development is outlined in
Instruction Memorandum (IM) No. UT 2010-055: Protection of Ground Water Associated with Oil and
Gas Leasing, Exploration and Development- Utah BLM. The purpose of this IM is to clarify the process
for the protection of usable ground water zones (< 10,000 mg/L as defined in Onshore Oil and Gas Order
No. 2) associated with oil and gas exploration and development activities. All potential usable water
aquifers would be cased and cemented. Well casings would be pressure tested to ensure integrity.
The lease parcels are not within nor do they contain any Sole Source Aquifers or Public Drinking Water
Source Protection Zones.
The requirements for oil and gas drilling operations are described in Onshore Oil and Gas Order (OO)
No. 2 and the requirements for disposal of produced water from oil and gas activities are contained in OO
No. 7. Adherence to these regulatory requirements will adequately mitigate impacts from the Proposed
Action to groundwater resources. Specific to groundwater protection, OO #2 requires that the proposed
casing, cementing and abandonment programs shall be conducted as approved to protect and/or isolate all
usable water zones and requires pressure testing the casing string. Known water bearing zones would be
protected by drilling requirements and, with proper practices, contamination of ground water resources is
highly unlikely. As a result, groundwater resources would not be impacted to the degree that would
require detailed analysis in the EA.
Surface water:
The lessee/operator would submit an APD when oil and gas exploration and development activities are
proposed. The APD would be subject to site specific NEPA analysis. An approved APD is subject to
standard operation procedures (SOP) required by regulation, stipulations attached to the lease, best
management practices (BMP) included in the APD submission, and conditions of approval (COA)
18
August 2019
developed during the NEPA analysis and documentation process. These SOPS, BMPs and COAs
mitigate impacts to water resources from oil and gas exploration and development activities. Standard
operating procedures including interim and final reclamation are required and site specific APD
approvals would provide mitigation for potential direct and indirect impacts to surface water quality.
To protect water resources BLM proposes to apply the following stipulations and lease notices as needed:
Stipulation UT-S-128, UT-S-386, UT-S-387, UT-LN-128 and UT-LN-53.
The SOPs, BMPs, COAs and stipulations will adequately mitigate impacts from the Proposed Action to
surface water resources. Surface water resources will not be impacted to the degree that will require
detailed analysis in the EA.
19
August 2019
1.10 Public Comment Period

The preliminary EA and the unsigned FONSI is subject to a public comment period, which will be held
from August 29, 2019 through September 30, 2019. (Appendix H – Comments and Responses [reserved])
20
August 2019
Chapter 2 Description of Alternatives
2.1 Introduction
This EA addresses two alternatives (Alternative A – Proposed Action and Alternative B – No Action, No
Leasing).
Other alternatives were not considered in detail because the issues identified during scoping or the
alternatives identified during the comment period did not indicate a need for additional alternatives or
protective measures beyond those contained in the Proposed Action. The No Action alternative is
considered and analyzed to provide a baseline for comparison of the impacts of the Proposed Action.
Leasing is an administrative action that does not directly cause environmental consequences. However,
leasing is considered to be an irretrievable commitment of resources because the BLM generally cannot
deny all surface use of a lease unless the lease is issued with a no surface occupancy (NSO) stipulation.
Potential oil and gas exploration and production activities, committed to in a lease sale, could impact
other resources and uses in the planning area. Direct, indirect, or cumulative effects to resources and uses
could result from future levels of lease exploration or development, however these future levels are
uncertain and undetermined.
2.2 Analysis Assumptions
2.2.1 Reasonably Foreseeable Development Scenario
The Reasonably Foreseeable Development Scenario (RFDS) is a planning tool to provide a reasonable
estimate of what oil and gas exploration and development activities might be proposed, should a decision
be made to lease the area. The RFDS is a 20-year forward-looking estimation of oil and gas exploration
and development that is exclusive of other concerns that might compete for use of land in a multiple-use
scenario.
Although at this time the BLM does not know when, where, or if future well sites or roads might be
proposed on any leased parcel. Should a lease be issued, site specific analysis of individual wells or roads
would occur when a lease holder submits an APD.
When and if an APD is submitted for any of the leases, BLM would adhere to numerous IMs (as revised
through the life of an active lease) including specific instructions for directional drilling, split estate,
bonding, and other laws (such as NHPA, ESA). Some of these IMs include:
• Approval of Notice of Intent to Conduct Geophysical Exploration to Federal Oil and Gas Lessee
on Split Estate (WO IM 2009-121)
• Cultural Resources Requirements for Split Estate Oil & Gas Development (WO IM-2009-027)
• Split Estate Report to Congress--Implementation of Fluid Mineral Leasing and Land Use
Planning Recommendations (WO IM 2007-165)
• Permitting Oil & Gas on Split Estate Lands (WO IM 2003-131)
• Legal Responsibilities on Split Estate Lands (WO IM 1989-201)
• Directional Drilling into Federal Mineral Estate from Well Pads on Non‑Federal Locations (WO
IM 2018-014).
Management provisions would adhere to the Gold Book best management practices (United States
Department of the Interior and United States Department of Agriculture 2007). In general, activities are
anticipated to take place as described in Appendix G – Reasonable Foreseeable Development of Leases
Scenario. This appendix provide a general discussion of possible post-leasing RFDS activities. All of
these activities would require additional NEPA review when a lease holder submits an APD.
The United States Government Accountability Office (GAO) completed a detailed data review of
approximately 47,925 federal onshore oil and gas leases issued from 1987 through 1996 (GAO 2008).
21
August 2019
The GAO found that only 6 percent (2,904 leases) of the leases issued were drilled during the 10-year
lease term, and about 5 percent (2,386 leases) of the leases produced oil and gas by 2007.
BLM Utah issued 10.7 percent (5,127) of the total federal onshore oil and gas leases (47,925) analyzed in
the GAO report. Of those leases in Utah, 6.17 percent (1,556) were drilled and 3.76 percent produced
[refer to Table 4 in (GAO 2008)]. Over a five year period between 2014 and 2018, on average only 58%
of approved APDs (federal and non-federal) across Utah were developed (UDOGM 2018).
RFDS Assumption for Analysis in this EA
For the analysis of the 24 nominated parcels by the public, encompassing 13,422.20 acres, it was
estimated a maximum of 22 wells 10 would be drilled (BLM 2005, BLM 2005, BLM 2015, BLM 2005,
BLM 2008, BLM 2008, BLM 2012), and the maximum new disturbance will be 22 wells totaling 96.0
acres (Table 4 Reasonably Foreseeable Development of Leases Scenario for the Nominated Parcels). This
scenario would occur rarely, if at all (Appendix G). Statistically, only the parcels located in Vernal, Price,
and Richfield have a higher probability those may be acquired, capable of production, and subsequently
may receive an APD during the 10-year lease term.
Table 4 Reasonably Foreseeable Development of Leases Scenario for the Nominated Parcels
Field Office Nominated Nominated Total RFDs Total RFDs
Parcels (well) (acreage)
Acres
Moab 2 393.39 1 well 10 acres
Monticello 9 5,536.26 1 well 10 acres
Richfield 7 3,914.82 14 wells 30 acres
Price 5 3,267.11 5 wells 41 acres
Vernal 1 310.62 1 well 5 acres
Total 24 13,422.20 22 wells 96.0 acres

Moab Field Office
The Moab Field Office Reasonably Foreseeable Development Scenario for Oil and Gas in the Moab
Master Leasing Plan Area (BLM 2012), Canyon Country District contains a summary of the RFD. The
proposed action parcels are located within the Salt Wash-Big Flat planning area. The 2005 RFD (BLM
2005) to the MFO RMP predicted that on 325,147 acres of BLM lands within the Salt Wash-Big Flat
planning area, 60 wells would be drilled over the entire RFD 15 year period, or an average of four wells
per year. The proposed action to offer for lease 393.39 acres would compose 0.12 percent of the total
BLM acreage and wells, rounded to one percent. One percent of 60 wells is less than one well for the 15
year RFD. For the purpose of this analysis it is assumed the two nominated parcels encompassing 393.39
acres will result in one well and 10 acres of surface disturbance.
10
Additional information is located in Appendix G.
22
August 2019
Monticello Field Office
The Monticello Field Office RMP-FEIS contains a summary of the RFD (RMP-FEIS pg. 4-112). The
proposed action parcels are located within the Blanding Sub-basin. The 2005 RFD (BLM 2005) to the
MtFO RMP predicted that on 405,664 acres of BLM lands within the Blanding Sub-basin, 42 wells would
be drilled over the RFD 15 year period, or an average of three wells per year. It is estimated that 59
percent of the wells drilled in MtFO will be capable of production and 41 percent is estimated to be a dry
hole. The proposed action to offer for lease 5,536.26 acres would compose 1.36 percent of the total BLM
acreage and wells. One percent of 42 wells is less than one well for the 15 year RFD. For the purpose of
this analysis it is assumed the 9 nominated parcels encompassing 5,536.26 acres will result in one well
and 10 acres of surface disturbance.

Richfield Field Office
The RFO RMP (BLM 2005), predicted a high development potential. These seven nominated parcels are
located in the Sevier Frontal Zone Play. For the analysis of the 7 nominated parcels encompassing
3,914.82 acres, it is estimated a maximum of 14 wells would be drilled on 5 well pads. The maximum
new disturbance will be 14 wells totaling 30 acres (one well pad and access road disturbance at 6 acres).

Price Field Office
Appendix M in the Price RMP (BLM 2008), predicted a high potential for oil and gas. Oil and gas drilling
has declined and is unlikely to return to the activity levels of 1999-2001 due to field maturity.
Development of the oil and gas fields has matured to the point where lower drilling rates will likely
continue in the future. For the analysis of the 5 nominated parcels encompassing 3,267.11 acres, the PFO
estimated a maximum of 5 wells would be drilled, and the maximum new disturbance will be 5 wells
totaling 41 acres (one well pad and access road disturbance at 8.2 acres).
Vernal Field Office
The VFO analyzed production of nearby wells. The parcel is located in a well explored natural gas field,
with very little oil production. Moderate amounts of Gas have been produced. The RFDs are based on one
mile buffer of each parcel, and if there were no production within the one mile, one test well was
recommended. If there was production within the 1 mile buffer, the total number of potential wells was
calculated by the downhole spacing order (Appendix G – Reasonable Foreseeable Development of Leases
Scenario The maximum new disturbance will be 1 well totaling 5 acres (one well pad and access road
disturbance).
2.3 Alternative A – Proposed Action

Alternative A would offer for lease the 24 nominated parcels (covering 13,422.20 acres) which have been
proposed for inclusion in this lease sale. The leases would include the standard lease terms and conditions
for development of the surface of oil and gas leases provided in 43 CFR 3100 (BLM Form 3100-11)
along with all stipulations mandated by policy (such as the Competitive Leasing Handbook, H-3120-1)
and by the governing Land Use Plans (LUP). Legal land descriptions along with corresponding
stipulations as well as notices added to address resource issues found through review and analysis that
would be attached to each parcel are located within Appendix A – Parcel List with Stipulations and
Notices. All stipulations from the governing LUP(s) and necessary notices being applied to the parcels are
23
August 2019
detailed in Appendix B – Stipulations and Notices Areas offered for oil and gas leasing would be subject
to measures necessary to mitigate adverse impacts, according to the categories, terms, conditions, and
stipulations identified in the land use plans, as amended.
BLM regulations at 43 CFR 3101.1-2 allow for the relocation of proposed oil and gas leasing operations
up to 200 meters and/or timing limitations up to 60 days to provide additional protection to ensure that
proposed operations minimize adverse impacts to resources, uses, and users.
Additional measures would be applied to some leases to further protect specific resources (Appendices A
and Appendix B – Stipulations and Notices). In addition to the stipulations provided for by the governing
LUPs (as amended) and BLM policies, Lease Notices have been developed for conservation measures
and would be applied on specific parcels as warranted by subsequent IDPRT review. The addition of
prescribed notices would be applied to all leasing categories detailed in Appendix B – Stipulations and
Notices.
At the leasing stage it is uncertain whether development on all leased parcels will move forward;
however, for the purposes of this analysis, and in order to assess potential impacts, Reasonably
Foreseeable Development (RFD) is assumed wherein all 24 nominated parcels will be developed. The
Reasonably Foreseeable Development used for analysis assumptions under this alternative is described in
Section 2.2.1.
2.4 Alternative B – No Action
The No Action Alternative would not offer any of the nominated parcels in the lease sale. The parcels
could be considered for inclusion in future lease sales. Surface management would remain the same and
ongoing oil and gas development would continue on surrounding private, state, and existing federal
leases.
2.5 Other Alternatives Considered but Not Analyzed in Detail
Other alternatives to the Proposed Action were not identified that would meet the purpose and need of
agency action.
The Interior Board of Land Appeals has held that subsumed in a no action alternative is consideration of
not leasing any or all parcels (Biodiversity Conservation Alliance et al., 183 IBLA 97, 124 (2013)). The
No Action alternative allows the authorized officer to resolve resource conflicts by deferring or removing
parcels from the lease sale, before offering those parcels for sale. The alternatives carried forward
represent those necessary for a reasoned choice (40 CFR 1502.14) and are based on the issues that were
identified by the IDPRT.
2.5.1 No Leasing Alternative (Designating the Parcels as Closed to Leasing)
A no leasing alternative was considered but eliminated because it is inconsistent with the management
plans for the area, and therefore is outside the purpose and need of this EA. This alternative would require
a RMP Plan Amendment because the areas in question were found suitable for leasing by the governing
RMPs and preceding management plans. The RMPs as amended also identified the lands as available for
leasing subject to a range of constraints, and reject a no leasing alternative. This alternative was dismissed
from detailed consideration.
2.5.2 Deferring Specific Parcels from the Sale
Since each parcel is an independent, though similar, action the BLM at the end of the EA process could
choose to either lease or defer any parcel in the EA’s decision record. Therefore this alternative to defer
for specific resource concerns was not considered in detail because it is substantially a combination of the
proposed action and no action and does not improve the range of alternatives. Offering or deferring any
particular parcel in this EA is within the range of alternatives already considered in detail in this EA, and
24
August 2019
can be implemented at the discretion of the Authorized Officer, as the need is identified in the NEPA
analysis.
2.5.3 Adding Stipulations Beyond those Required by the Management Plan
This alternative to add additional stipulations beyond those identified by the applicable Management Plan
to the nominated parcels was not considered in detail because it would require a plan amendment, which
is outside the scope of this EA. A plan maintenance was done to the Monticello RMP (BLM 2017)
Maintenance Change 102 to adopt the Moab MLP notices. Therefore, those notices in the MLP can be
applied to the parcels in Appendix A – Parcel List with Stipulations and Notices. However, deferral of
any particular parcel due to unresolved resource conflicts is within the range of alternatives considered in
detail in this EA, and can be implemented at the discretion of the Authorized Officer, or as the need is
identified in the NEPA analysis.
2.5.4 No Contribution to the Uinta Basin’s Air Quality
An alternative was suggested that prohibit contribution to or exacerbation of the air quality in the Uinta
Basin. This alternative was not considered in detail because: 1) the act of leasing does not result in
emissions and 2) no Federal or State laws prohibit contribution of emissions to a non-attainment airshed.
Oil and gas exploration or development (which would result in emissions) is not being proposed in or
authorized through the proposed action, and is outside the scope of this EA. If the leases are issued, and if
development is proposed, additional analysis of the impacts to air quality would be conducted before an
authorization may be granted.
25
August 2019
Chapter 3 Affected Environment
3.1 Introduction
This chapter presents the potentially affected existing environment (i.e., the physical, biological, social,
and economic values and resources) of the impact area as identified in the IDPRT Checklist as found in
Appendix D – Interdisciplinary Parcel Review Team Checklist and introduced in Chapter 1 of this EA.
Only those aspects of the affected environment that are potentially impacted are described in detail. Only
those aspects of the affected environment related to the issues presented in Table 2 and discloses any
potential direct, indirect and cumulative impacts on the resources identified as issues. Once issues are
identified, impact indicators are selected to assess the impacts of alternatives and are used as a basis for
future monitoring (Table 2. Issues Identified for Detailed Analysis).
The CEQ Regulations state that NEPA documents “must concentrate on the issues that are truly
significant to the action in question, rather than amassing needless detail” (40 CFR 1500.1(b)). While
many issues may arise during scoping, not all of the issues raised warrant analysis in an EA. Issues will
be analyzed if: 1) an analysis of the issue is necessary to make a reasoned choice between alternatives; or
2) if the issue is associated with a significant direct, indirect, or cumulative impact, or where analysis is
necessary to determine the significance of the impacts. To see which resources were determined to not be
present or not expected to be impacted by the Proposed Action please refer to Appendix D –
Interdisciplinary Parcel Review Team Checklist.
Assumptions for analysis
The act of leasing 24 nominated parcels covering 13,422.20 acres in and of itself would have no
immediate impacts on resources in the Monticello Field Office (MtFO), Richfield Field Office (RFO),
Price Field Office (PFO), Moab Field Office (MbFO), and Vernal Field Office (VFO). However, for the
purposes of this analysis, a framework of RFD is assumed wherein all parcels under each alternative are
leased and developed.
While an appropriate level of NEPA for wells or roads would occur when a leaseholder submits an APD,
reasonable development assumptions for lease development will be used in the analysis of impacts in this
EA to inform the decision since leasing results in a commitment resources unless the lease is allowed to
expire without development.
Cumulative impacts include the combined effect of past projects, ongoing projects, and other reasonably
foreseeable future actions.
3.2 General Setting

The proposed action would result in additional leasing of acres in Canyon Country District (5 percent),
Color Country District (1 percent), and Green River District (2 percent). Utah’s State and Institutional
Trust Lands Administration (SITLA) offered quarterly competitive lease sales in January, April, and July
2019, and will hold one in October 2019 11. The STILA parcels may be interspersed or located in the
general vicinity of the nominated lease parcels analyzed in this EA
Moab Field Office
To date the MbFO has 530,580 authorized leased acres (Table 5). The Moab Field Office RMP, as
amended by the GRSG ARMPA (BLM 2015 and 2019) designates 234,814 acres in the planning area as
11
Additional information regarding the SITLA can be accessed online at:
http://sitla.maps.arcgis.com/apps/MapSeries/index.html?appid=4744407de569440b875849fa34672865.
26
August 2019
open to leasing with standard stipulations where approximately 40% (93,381 acres) have been leased. An
additional 750,729 acres are open to leasing with moderate stipulations (CSU and TL) where
approximately 44% (328,466 acres) have been leased. Major stipulations, such as No Surface Occupancy
(NSO), has been designated across 326,268 acres and approximately 25% (81,960 acres) of these acres
have been leased. The December 2019 lease sale would offer no acres with standard stipulations, <1%
(2,079 acres) of acres with moderate stipulations, and 3% (9,238 acres) acres with major stipulations
available for leasing. Currently there are 530,580 leased acres within the MbFO boundary and the lease
sale would make an additional 395 acres available for lease. To date, the nominated parcels for March,
June, and September Lease Sales have not been issued. If the March, June, and September leases are
issued before the December lease sale, then the total authorized leased acres for the MbFO would be
554,095 or 31% leased. If all parcels offered at the December lease sale are sold and leases issued, then
total authorized leased acres for the MbFO would cumulatively increase to 554,490 acres or 31% leased.
This would be a cumulative increase of less than 1% compared to the current authorized leased acres and
offered acres (March, June, and September lease sales) combined (Table 5).
Table 5. Leasing Category Acreages for Moab Field Office.

Acres % Dec
Authorize Dec 2019 2019
Designated % Leased Offered-
Leasing Category d Lease Proposed Proposed
Acres Acres Leases Not
Acres1 Acres Acres
Issued5
234,814 93,381 40% 4,368 0 0%

Standard Stipulations (Open)
Moderate Stipulations (CSU and 750,729 328,466 44% 18,214 177 <1%
TL)
326,268 81,960 25% 854 218 3%
Major Stipulations (NSO)
NA 13,437 NA 79 0 NA
No Leasing Decision Category
464,701 13,336 3% 0 0 0
Closed2
1,776,5123 530,580 30% 23,515 395 <1%

TOTAL
1
Leased acres are calculated as of March 1, 2019 and include the previous NCLS lease sales. Acres calculated using
GIS data and are therefore a close approximation of actual leased acres. All calculations were rounded to the nearest
whole number.
2
Authorized leases, held by production
3
Designated acres total only includes the leasable designated acres and excludes the 464,701 closed acres.
5
Acres offered at the March 25 – 26, June 11, and September 9 – 11, 2019 lease sales are show here. These acres
were offered for sale, but a decision to issue leases has not been signed and therefore no leases have been
authorized.
27
August 2019
Currently the MtFO has 243,736 authorized leased acres 12 (Table 6). The Monticello Field Office RMP,
as amended by the GRSG ARMPA (BLM 2015 and 2019) designates 432,296 acres in the planning area
as open to leasing with standard stipulations where approximately 23% (99,051 acres) have been leased.
An additional 586,736 acres are open to leasing with moderate stipulations (CSU/TL) where
have been leased. The December 2019 lease sale would make approximately an additional 1% (4,779
acres) acres with standard stipulations, 5% (33,578 acres) acres with moderate stipulations, and no acres
with major stipulations available for leasing. Currently there are 243,736 leased acres within the MtFO
boundary and the lease sale would make an additional 38,905 acres available for lease. To date, the
nominated parcels for March, June, and September Lease Sales have not been issued. If the March, June,
and September leases are issued before the December lease sale, then the total authorized leased acres for
the MtFO would be 273,636 or 25% leased. If all parcels offered at the December lease sale are sold and
leases issued, then total authorized leased acres for the MtFO would cumulatively increase to 312,541
acres or 28% leased. This would be a cumulative increase of approximately 4% compared to the current
authorized leased acres and offered acres (March, June, and September lease sales) combined (Table 6).
Table 6. Leasing Category Acreages for Monticello Field Office.

Acres % Dec
Authorize Dec 2019 2019
Leasing Category d Lease Proposed Proposed
Acres1 Acres Acres
Issued5
432,296 99,051 23% 27,896 4,779 1%

Moderate Stipulations (CSU and 586,736 92,143 16% 2,004 33,578 5%

TL)
82,216 14,553 18% 0 0 0%
NA 37,754 NA 0 5484 NA
682,286 235 NA 0 0 0%
Closed2
1,101,2483 243,736 22% 29,900 38,905 4%

TOTAL
1
whole number.
2
Authorized leases, held by production.
3
4
Surface is private ownership or doesn’t have a leasing category decision from the RMP.
12
ArcGIS data displaying land status by surface management agency and existing oil and gas leases on federal lands
can be found at: https://bit.ly/2Uy8TpF.
28
August 2019
5
Acres offered at the March 25 – 26, June 11, and September 9 – 11, 2019 lease sales are show here.
These acres were offered for sale, but a decision to issue leases has not been signed and therefore no
leases have been authorized.
Currently there are 186,003 authorized leased13 acres (Table 7) in the RFO. To date, the Richfield Field
Office RMP, as amended by the GRSG ARMPA (BLM 2015 and 2019) designates 608,741 acres in the
planning area as open to leasing with standard stipulations where approximately 9% (56,213 acres) have
been leased. An additional 715,798 acres are open to leasing with moderate stipulations (CSU and TL)
where approximately 5% (38,112 acres) have been leased. Major stipulations, such as No Surface
Occupancy (NSO), has been designated across 551,620 acres and approximately 3% (18,898 acres) of
these acres have been leased. The December 2019 lease sale would make approximately less than 1% (29
acres) acres with standard stipulations, less than 1% (2,577 acres) acres with moderate stipulations, less
than 1% (6 acres) acres with major stipulations, and less than 1% (1,288 acres) acres with no leasing
decision available for leasing. Currently there are 186,003 leased acres within the RFO boundary and the
December lease sale would make an additional 3,900 acres available for lease. To date, the nominated
parcels for March, June, and September Lease Sales have not been issued. If the March, June, and
September leases are issued before the December lease sale, then the total authorized leased acres for the
RFO would be 242,455 or 13% leased. If all parcels offered at the December lease sale are sold and leases
issued, then total authorized leased acres for the RFO would cumulatively increase to 246,355 acres or
13% leased. This would be a cumulative increase of less than 1% compared to the current authorized
leased acres and offered acres (March, June, and September lease sales) combined (Table 7).
Table 7. Leasing Category Acreages for Richfield Field Office.

Acres % Dec
Authorized Dec 2019 2019
Leasing Category Lease Proposed Proposed
Acres1 Acres Acres
Issued5
608,741 56,213 9% 9,483 29 <1%

Moderate Stipulations (CSU and 715,798 38,112 5% 34,282 2,577 <1%

TL)
551,620 18,898 3% 13 6 <1%
NA 41,727 NA 12,674 1,288 NA

447,304 31,053 NA 0 0 0
Closed2
1,876,1593 186,003 10% 56,452 3,900 <1%

TOTAL
1
whole number.
13
can be found at: https://bit.ly/2Uy8TpF.
29
August 2019
2
3
5
authorized.

Price Field Office
The PFO has 2,086,369 authorized leased acres (Table 8). To date, the Price Field Office RMP, as
amended by the GRSG ARMPA (BLM 2015 and 2019) designates 1,146,076 acres in the planning area
as open to leasing with standard stipulations where approximately 25% (290,447 acres) have been leased.
An additional 480,170 acres are open to leasing with moderate stipulations (CSU and TL) where
have been leased. The December 2019 lease sale would make less than 1% additional acres (268 acres)
with moderate stipulations and with major stipulations (35 acres) available for leasing. Currently there are
491,905 leased acres within the PFO boundary and the December lease sale would make an additional
3,259 acres available for lease. To date, the nominated parcels for March, June, and September Lease
Sales have not been issued. If the March, June, and September leases are issued before the December
lease sale, then the total authorized leased acres for the PFO would be 517,247 or 25% leased. If all
parcels offered at the December lease sale are sold and leases issued, then total authorized leased acres for
the PFO would cumulatively increase to 520,506 acres or 25% leased. This would be a cumulative
increase of less than 1% compared to the current authorized leased acres and offered acres (March, June,
and September lease sales) combined (Table 8).
Table 8. Leasing Category Acreages for Price Field Office
Acres % Dec
Authorize % Leased Dec 2019
Designated Offered- 2019
Leasing Category d Lease Acres Proposed
Acres Leases Not Proposed
Acres1 Acres
Issued5 Acres
Standard Stipulations (Open) 1,146,083 290,447 25% 0 2,956 <1%
Moderate Stipulations (CSU and

480,170 101,745 21% 4,350 268 <1%
TL)
Major Stipulations (NSO) 460,116 34,442 8% 35 <1%

18,431
No Leasing Decision Category NA 58,844 NA 2,561 0 0
Closed2 577,216 6,426 NA 0 0 0
TOTAL 2,086,3693 491,905 24% 25,342 3,259 <1%

1
whole number.
30
August 2019
2
3
5
authorized.
Vernal Field Office
Currently there are 1,168,221 authorized leased 14 acres in the VFO (Table 9). To date, the Vernal Field
Office RMP, as amended by the GRSG ARMPA (BLM 2015 and 2019) designates 700,626 acres in the
planning area as open to leasing with standard stipulations where approximately 78% (549,295 acres)
have been leased. An additional 709,276 acres are open to leasing with moderate stipulations (CSU and
TL) where approximately 59% (415,814 acres) have been leased. Major stipulations, such as No Surface
Occupancy (NSO), has been designated across 468,392 acres and approximately 20% (92,219 acres) of
these acres have been leased. The December 2019 lease sale would make approximately less than 1%
(129 acres) acres with standard stipulations, less than 1% (158 acres) acres with moderate stipulations,
and less than 1% (15 acres) acres with major stipulations available for leasing. Currently there are
1,168,221 leased acres within the VFO boundary and the lease sale would make an additional 302 acres
available for lease. To date, the nominated parcels for March, June, and September Lease Sales have not
been issued. If the March, June, and September leases are issued before the December lease sale, then the
total authorized leased acres for the VFO would be 1,315,040 or 70% leased. If all parcels offered at the
December lease sale are sold and leases issued, then total authorized leased acres for the VFO would
cumulatively increase to 1,315,342 acres or 70% leased. This would be a cumulative increase of less than
1% compared to the current authorized leased acres and offered acres (March, June, and September lease
sales) combined (Table 9).
Table 9. Leasing Category Acreages for Vernal Field Office
Acres % Dec
Authorized % Dec 2019
Designated Offered- 2019
Leasing Category Lease Leased Proposed
Acres Leases Not Proposed
Acres1 Acres Acres
Issued5 Acres
Standard Stipulations 45,133
700,626 549,295 78% 129 <1%
(Open)
Moderate Stipulations 86,222
709,276 415,814 59% 158 <1%
(CSU and TL)
Major Stipulations (NSO) 468,392 92,219 20% 7,053 15 <1%
No Leasing Decision 8,411

NA 78,666 NA 0 NA
Category
Closed2 194,566 32,227 NA 0 0 0%
TOTAL 1,878,2943 1,168,221 62% 146,819 302 <1%

1
whole number.
2
14
can be found at: https://bit.ly/2Uy8TpF
31
August 2019
3
5
authorized.
3.3 Resources/Issues Brought Forward for Analysis

The affected environment of the proposed action and no action alternatives, and their potential
environmental effects were considered and analyzed by the IDPRT as documented in the IDPRT
Checklist, Appendix D – Interdisciplinary Parcel Review Team Checklist The checklist indicates which
resources of concern are either not present in the project area or would not be impacted to a degree that
requires detailed analysis. Resources which could be impacted to a level requiring further analysis are
described in this chapter and impacts to these resources are analyzed below.
3.3.1 Issue 1: What are the Potential Impacts to Air Quality?
3.3.1.1 Affected Environment
Information on air quality in the leasing area is contained in the 2018 BLM Utah Air Monitoring Report
(AMR) (BLM 2019) and in each field office RMP (see Section 1.7) to which this analysis tiers and
incorporates by reference. This EA summarizes technical information related to air resources affected
environment.
Air Quality
The Environmental Protection Agency (EPA) has the primary responsibility for regulating air quality,
including six nationally regulated ambient air pollutants including carbon monoxide (CO), nitrogen
dioxide (NO2), ozone (O3), particulate matter (PM10 & PM2.5), sulfur dioxide (SO2) and lead (Pb). EPA
has established National Ambient Air Quality Standards (NAAQS) for criteria pollutants (Section 2.2.1,
AMR). The NAAQS are protective of human health and the environment. Compliance with the NAAQS
is typically demonstrated by monitoring for ground-level atmospheric air pollutant concentrations. Areas
where pollutant concentrations are below the NAAQS are designated as attainment or unclassifiable, and
air quality is generally considered to be good. Locations where monitored pollutant concentrations are
higher than the NAAQS are designated nonattainment, and air quality is considered unhealthy.
Nonattainment areas in Utah have been designated in portions of the Salt Lake Field Office (primarily
along the Wasatch Front) and in the Vernal Field Office (portions of Duchesne and Uintah Counties
below 6,250 ft elevation) (BLM 2019). Parcel 026 (Table 1), in the Vernal Field Office, is located in a
nonattainment area for ozone, while all other parcels are in areas designated as attainment or
unclassifiable.
Air quality in a given region can be measured by its Air Quality Index value (AQI). The AQI is reported
according to a 500-point scale for each of the major criteria air pollutants, with the worst denominator
determining the ranking. For example, if an area has a CO value of 132 on a given day and all other
pollutants are below 50, the AQI for that day would be 132. The AQI scale breaks down into six
categories: good (AQI<50), moderate (50-100), unhealthy for sensitive groups (100-150), unhealthy
(>150), very unhealthy and hazardous. The AQI is a national index, therefore the air quality rating and the
associated level of health concern is the same throughout the country. The AQI is an important indicator
for populations sensitive to air quality changes (USEPA, 2018c).
When the AQI value is in the good range, pollutant concentrations are well below the NAAQS and air
pollution poses little or no risk. Moderate AQI values occur when pollution is below but near the NAAQS
and voluntary emission reduction measures are encouraged. The AQI is considered unhealthy when the
NAAQS is exceeded and major pollution sources are often required to implement mandatory emission
reduction measures. Counties without AQI data have fewer air pollutant sources and are assumed to have
32
August 2019
good air quality for this analysis.
AQI data that is available for counties in which lease parcels are located is presented in Table 10. During
the 2015-2017 timeframe most counties have good or moderate air quality (i.e., pollution concentrations
below the NAAQS) more than 99% of the time. The data for Uintah County shows days with unhealthy
air quality occur approximately 2% of the time. In this EA, additional air pollutant concentration
information is provided for counties that have more than 1% of days rated as unhealthy. AQI and
pollution concentration information, for the rest of the state, is available in the AMR (BLM 2019).
Table 10. AQI Index Summary Statistics by County
# of Days When AQI was… % of Days Rated …

# Days
County with AQI Good Moderate Unhealthy Good Moderate Unhealthy
Carbon County, UT 969 692 275 2 71% 28% 0%
San Juan County, UT 1058 852 205 1 81% 19% 0%
Uintah County, UT 1096 731 341 24 67% 31% 2%
In areas identified with more than 1% of days having unhealthy air quality, Ozone and PM2.5 are
identified in the AQI data as the primary pollutants determining air quality for the area. Air pollutant
concentrations are reported using design values. A design value is a statistic that describes the air quality
status of a given location relative to the level of the NAAQS. Design values are typically used to
designate and classify nonattainment areas, as well as to assess progress towards meeting the NAAQS.
Design values are provided in Table 11. No design value for PM2.5 is reported for Uintah County, so
values from the nearest representative county (Duchesne County, UT) is presented. Reported PM2.5
concentrations are below the NAAQS, and ozone values above the standard.
Table 11. 2015-2017 Criteria Pollutant Design Values
Pollutant Location Averaging Time Concentration NAAQS
O3 Uintah Basin 8-hour 0.088 ppm 0.070 ppm
PM2.5 Duchesne County Annual 6.1 µg/m3 12.0 µg/m3
PM2.5 Duchesne County 24-hour 24 µg/m3 35 µg/m3
The Utah Division of Air Quality (DAQ) compiles statewide emission inventories to assess the level of
pollutants released into the air from various sources. The latest inventory is summarized in the AMR
(BLM 2019), and provided in Appendix E – Air Quality and Green House Gas Information and
Calculations. Emissions for each individual county where parcels are located can be found in the AMR
(BLM 2019) and in the UDAQ emission inventory report (UDAQ 2018). The largest human sources of
criteria air pollutants in Utah are on-road mobile sources for CO, point sources for NOx and SOx, area
sources for PM10 and PM2.5, and oil and gas sources for VOCs.
Hazardous air pollutants (HAPs) are known or suspected to cause cancer or other serious health effects, or
adverse environmental effects, so they are also regulated by the EPA. Examples of listed HAPs emitted
by the oil and gas industry include benzene, toluene, ethyl benzene, mixed xylenes, formaldehyde,
normal-hexane, acetaldehyde, and methanol. A list of HAP point source emissions by County is published
by the Utah Division of Air Quality (UDAQ 2018), and is incorporated by reference. More information
on HAPS can be found in Appendix E – Air Quality and Green House Gas Information and Calculations.
The parcels in this lease sale occur within Prevention of Significant Deterioration (PSD) Class II areas
and do not occur adjacent to Class I National Parks in Utah. The CAA PSD requirements give more
33
August 2019
stringent air quality and visibility protection to national parks and national wilderness that are designated
as Class I areas, but PSD does not prevent emission increases. Federal Land Managers are responsible for
defining specific Air Quality Related Values (AQRVs), including visual air quality (haze), and acid
(nitrogen and sulfur) deposition, for an area and for establishing the criteria to determine and adverse
impact on the AQRVs. AQRVs do not have threshold standards, but Federal land managers have
identified levels of concern. Current visibility and deposition information for nearby Class I areas is
summarized in the AMR (BLM 2019). Each Class I area in shows an improving visibility trend, with
Canyonlands showing a statistically significant improvement in the clearest and haziest days. Both
nitrogen and sulfur deposition show improving trends from 2000 to 2016.
Consultation with air technical advisory group (including the National Park Service, U.S. Forest Service,
U.S. Fish and Wildlife Service, and the Environmental Protection Agency) identified parcels (009 and
010, Table 1) as needing additional visibility analysis due to their proximity to Capitol Reef National
Park. Parcel 026 was identified as needing a general conformity applicability analysis since it is located in
the Uinta Basin ozone nonattainment area. No other parcels were identified as needing additional analysis
since there is no development plan for any parcels and existing modeling studies adequately inform the
decision maker and public about potential impacts.
3.3.1.2 Environmental Consequences
Impacts of the Proposed Action
Leasing the subject tracts would have no direct impacts to air quality. Any potential effects to air quality
from the sale of lease parcels would occur at such time that any issued leases are developed. Please note,
this proposed action does not authorize or guarantee specific development scenarios. If leased, drilling of
wells on a lease would not be permitted until the BLM approves an Application for Permit to Drill (APD).
Any APDs received would be subject to additional site specific NEPA review. However development
assumptions have been made in this EA to inform the decision since an issued lease must be developed to
keep it from expiring. This discussion remains qualitative as variations in emission control technologies
as well as construction, drilling, and production technologies used by various operators make it difficult
to accurately estimate specific air quality impacts at this time. Well development on parcels outside the
Vernal Field Office would likely be exploratory and impacts from construction and drilling would be
temporary or short-term and would cease after the associated activities.
During well development, there could be emissions from earth-moving equipment, vehicle traffic,
drilling, and completion activities. NO2, SO2, and CO would be emitted from vehicle tailpipes. Fugitive
dust concentrations would increase with additional vehicle traffic on unpaved roads and from wind
erosion in areas of soil disturbance. Drill rig and fracturing engine operations would result mainly in NO2
and CO emissions, with lesser amounts of SO2. These temporary emissions would be short-term during
the drilling and completion times.
During well production there could be continuous emissions from separators, condensate storage tanks,
and daily tailpipe and fugitive dust emissions from operations traffic. During the operational phase of the
Proposed Action, NO2, CO, VOC, and HAP emissions would result from the long-term operation of
condensate storage tank vents, and well pad separators. Additionally, road dust (PM10 and PM2.5) would
be produced by vehicles servicing the wells.
Annual estimated criteria pollutant emissions from potential future development of a single well was
estimated from the Grand Staircase Escalante National Monument and Kanab RMP FEIS (BLM 2019)
emissions inventory, and is summarized in Table 12. Methods and assumptions for developing the
emission inventory are incorporated by reference from the RMP FEIS. Emission amounts smaller than
one thousandth were determined to be negligible. Development of individual lease parcels may result in
higher or lower emissions for various reasons, including differences with geologic formations, proximity
to existing support infrastructure, different development methods and technology, and other reasons. For
total foreseeable emissions, multiply the amounts in the table by the total number of foreseeable wells
34
August 2019
(24). However, it is not reasonable to assume that all wells will be drilled in a single year because the
lessee has 10 years to establish production on a lease, and historically most leases never have production
attempted or established 15. If production is not attempted within the 10 year timeframe, the lease will be
terminated with no development or production emissions occurring.
Table 12. Annual Emissions Estimate for as Single Well (metric tons/year)
NOx CO VOC SO2 PM10 PM2.5 HAPs
Constructio 0.069 0.160 0.011 0.000 0.040 0.002 0.002

n
Drilling 4.669 2.892 0.280 0.011 0.264 0.013 0.013
Completion 0.830 0.843 0.995 0.002 0.176 0.031 0.031
Production 1.180 3.469 4.072 0.004 0.254 0.074 0.084
Totals 6.748 7.363 5.359 0.017 2.404 0.554 0.130
Project emissions of ozone precursors, whether generated by construction and drilling operations, or by
production operations, would be dispersed and/or diluted to the extent where any local ozone impacts
from the Proposed Action would be indistinguishable from background or cumulative conditions. The
primary sources of HAPs would be from oil storage tanks and smaller amounts from other production
equipment. Small amounts of HAPs would be emitted by construction equipment. However, these
emissions are estimated to be less than 1 ton per year. Based on the negligible amount of project-specific
emissions, the Proposed Action is not likely to violate, or otherwise contribute to any violation of any
applicable air quality standard, and may only contribute a small amount to any projected future potential
exceedance of any applicable air quality standards.
Air quality and AQRV impacts from the development of exploratory wells and production wells were
modeled in the Fishlake National Forest Oil and Gas Leasing Analysis FEIS (USDAFS 2013), and are
incorporated by reference. The analysis evaluated maximum modeled air pollutant concentrations at
various distances and elevations (above and below) from a well site, and compared them to Class I and
Class II increments. Generally, results predicted that air quality standards would continue to be met if the
model receptor was in a Class I airshed and was at an elevation above or below the well site and at a
distance of 55 kilometers (34 miles) or greater away from a production well or 5 kilometers (3 miles) or
greater away from an exploratory well. Further modeling and analysis is recommended if the source is
less than 55 or 5 kilometers respectively. Results predicted no potential compliance problems if the
receptor was in a Class II airshed. Similar results and recommendations are made about visibility
standards. Oil and gas development may also release criteria pollutants that can contribute to acid rain and
its impacts on lakes and vegetation. Fishlake National Forest FEIS modeling results are provided in
Appendix E – Air Quality and Green House Gas Information and Calculations.
A Visual Impact Screening Model (VISCREEN) analysis was prepared to identify potential visibility
impacts to Capitol Reef National Park, if parcels 009 and 010 are developed. The VISCREEN model is
used to assess the change in color difference index (ΔE) and plume contrast (C) against the background
sky and terrain. Two scenarios were analyzed with Tier 2 and Tier 4 engine emission rates. The first
scenario is the drilling of an exploratory well, and the second scenario is for completion of a well if
profitable amounts of oil and gas are found. Due to the proximity of the parcel to Capitol Reef National
15
See GAO’s October 2008 finding that for leases issued from 1987 through 1996, development occurred on 6% of
onshore leases and production was achieved on 5%. https://www.gao.gov/new.items/d0974.pdf
35
August 2019
Park a Level-2 screening was performed. Results from the VISCREEN analysis are presented in Table 13.
The first scenario passed all screening criteria, and no visibility impacts are anticipated for drilling an
exploratory well. The second scenario failed to pass the screening criteria, although impacts are reduced
with the use of lower emitting engines. Additional analysis or mitigation may be needed based on future
development of these parcels.
Table 13 Visibility Impact Assessment for Development of Parcels near Capitol Reef National Park
ΔE Contrast (Pasq, Pass
Emissions Source Assessment Result Criterion Result Criterion wspd) (Y/N)
Sky 1 1.58 2.00 -0.15 0.05 Y
Sky 2 1.44 2.00 -0.02 0.05 Y
Drilling (Tier 2) D,1
Terrain 1 1.52 2.00 0.01 0.05 Y
Terrain 2 1.12 2.00 0.01 0.05 Y
Sky 1 0.15 2.00 0.00 0.05 Y
Sky 2 0.15 2.00 0.00 0.05 Y
Drilling (Tier 4) D,1
Terrain 1 0.16 2.00 0.00 0.05 Y
Terrain 2 0.11 2.00 0.00 0.05 Y
Sky 1 5.13 2.00 -0.05 0.05 N
Completion (Tier Sky 2 4.71 2.00 -0.07 0.05 N
D,1
2) Terrain 1 4.83 2.00 0.04 0.05 N
Terrain 2 3.60 2.00 0.03 0.05 N
Sky 1 2.85 2.00 -0.02 0.05 N
Completion (Tier Sky 2 2.37 2.00 -0.02 0.05 N
D,1
4) Terrain 1 2.24 2.00 0.01 0.05 N
Terrain 2 1.82 2.00 0.01 0.05 Y
If exploration occurs, short-term impacts would be stabilized or managed rapidly (within two to five
years) and long-term impacts are those that would substantially remain for more than five years.
A general conformity applicability analysis shows that a general conformity determination is not possible
at the leasing stage for parcel 026, but would be required before approval of an APD, see Appendix E –
Air Quality and Green House Gas Information and Calculations for details. Substantial air resource
impacts are not anticipated from the development of the remaining parcels based on the emissions
estimates contained in Table 12, the parcels being in areas compliant with all NAAQS, and considering
the location of parcels relative to population centers and Class I areas. No further analysis or modeling is
warranted for the leasing decision. Emissions resulting from the development of the remaining parcels
are not likely to result in major impacts to air quality nor are they likely to cause a violation of the
NAAQS. As identified in notice UT-LN-102 additional analysis or mitigation may be required when
parcels are developed.
Impacts of the No Alternative Action
Under the No Action Alternative, BLM would continue to manage these lands based on the objectives
outlined in their class categories. No new attendant infrastructure associated with oil and gas development
would be built under the No Action Alternative. No new emissions of pollutants would occur.
36
August 2019
3.3.1.3 Required Design Features
Application of stipulations and notices listed in Appendix B – Stipulations and Notices would be
adequate for the leasing stage to disclose potential future restrictions and to facilitate the reduction of
potential impacts.
The BLM does look to mitigate pollutants via lease stipulations and notices and further NEPA actions
throughout the lease process. Stipulations and notices would be applied to leases when issued to notify the
operator of what would be required (stipulation) and what could potentially be required (notice) at the
APD stage. This allows the potential lessee, at the time of bidding on the parcel, to be informed of the
range of requirements that could be expect when lease rights are exercised. Additional air quality control
measures may be warranted and imposed at the APD stage (such as mitigation measures, best
management practices, and an air emissions inventory). The BLM would do this in coordination with the
EPA, UDAQ and other agencies that have jurisdiction on air quality. By applying stipulations and
notices, leasing would have little impact on air quality. At the APD stage, further conditions of approval
(COAs) could be applied based on the environmental analysis for the APD. These control measures are
dependent on future regional modeling studies or other analysis or changes in regulatory standards.
Application of these notices would be sufficient to notify the lease holder of additional air quality control
measures that are necessary to ensure protection and maintenance of the NAAQS.
The BLM requires industry to incorporate and implement BMPs, which are designed to reduce impacts to
air quality by reducing emissions, surface disturbances, and dust from field production and operations.
Typical measures include: adherence to BLM’s waste prevention regulations, flare hydrocarbon gases at
high temperatures to reduce emissions of incomplete combustion; water dirt roads during periods of high
use to reduce fugitive dust emissions; collocate wells and production facilities to reduce new surface
disturbance; implementation of directional drilling and horizontal completion technologies whereby one
well provides access to petroleum resources that would normally require the drilling of several vertical
wellbores; suggest that vapor recovery systems be maintained and functional in areas where petroleum
liquids are stored; and perform interim reclamation to revegetate areas of the pad not required for
production facilities and to reduce the amount of dust from the pads.
In addition, the BLM encourages industry to participate in the Gas STAR program that is administered by
EPA. The Natural Gas STAR program is a flexible, voluntary partnership that encourages oil and natural
gas companies to adopt proven, cost-effective technologies and practices that improve operational
efficiency and reduce natural gas emissions. The EPA has promulgated air quality regulations for
completion of hydraulically fractured gas wells. These rules require air pollution mitigation measures that
reduce the emissions of volatile organic compounds during gas well completions.
Southeastern Utah has been identified as an area susceptible to wind erosion (Duniway et. al 2019). BMPs
to reduce fugitive dust include use of speed mitigation techniques, use of over-sized or low pressure tires,
directional drilling to reduce the number of well pads, and application of soil stabilization techniques
(Duniway et. al 2019).
3.3.1.4 Cumulative Impacts
The cumulative impact analysis area (CIAA) for air quality is the counties and field offices where lease
parcels are located. The CIAA also includes regional Class I areas and other environmentally sensitive
areas (e.g., national parks and monuments, wilderness areas, etc.) nearest to the parcels. No recent
cumulative modeling analysis has been performed for the entire CIAA area. However, modeling domains
from the Moab MLP (BLM 2016) and BLM’s Air Resource Management Strategy (ARMS) Modeling
Project (BLM 2014) cover portions of the CIAA. These modeling analysis provide a reference for
potential cumulative impacts due to regional oil and gas development. It is important to note that the
ARMS model performance evaluation of ozone indicated a negative model bias (under predicts) during
the winter and a positive model bias (over predict) during the summer in the 4 km domain. The model
37
August 2019
performance evaluation for PM2.5, indicated a negative model bias (under predict) throughout the year in
the 4 km domain (BLM 2014).
Emissions
Past and present actions that have affected and would likely continue to affect air quality in the CIAA
include surface disturbance resulting from oil and gas development and associated infrastructure,
geophysical exploration, ranching and livestock grazing, range improvements, recreation (including OHV
use), authorization of ROWs for utilities and other uses, and road development. Past and present actions
in CIAA that have affected and would likely continue to affect air quality are too numerous to list here
but would include the development of power plants; the development of energy sources such as oil, gas,
and coal; the development of highways and roads; and the development of various industries that emit
pollutants. These types of actions and activities can reduce air quality through emissions of criteria
pollutants (including fugitive dust), VOCs, and HAPs, as well as contribute to deposition impacts and to a
reduction in visibility.
Past, present, and reasonably foreseeable oil and gas development is listed in the Utah Division of Oil Gas
and Mining’s Well Counts statistical report (UDOGM 2018). At the end of 2018 there were 14,028 active
wells in Utah. In 2008 the active number of wells was 10,308, showing an increase in near 4,000 active
wells over a ten year period. At the end of 2014 National Emission Inventory year there were 13,961
active wells. Emissions from the wells estimated for this lease sale would add to the emissions from the
existing active wells. Total oil and gas emissions are anticipated to have a small increase to the values
listed in Table 25.
Modeled Impacts
The Moab MLP analysis included far-field modeling to evaluate impacts on NAAQS and AQRVs from
multiple sources over the entire MLP area (portions of Moab and Monticello Field Offices. Technical
details for this modeling are incorporated from Appendix F of the MLP FEIS. The modeling analysis
evaluated three scenarios based on the range of alternatives in the MLP FEIS. Modeling results show no
exceedances of the NAAQS for any pollutant for any of the modeled scenarios (BLM 2016). Emissions
from this lease sale would slightly increase modeled concentrations, but pollutant concentrations are
likely to remain below the NAAQS due to the low amount of anticipated development.
The ARMS model determined that in the 2021 future year, all assessment areas are within the applicable
PSD increments for annual NO2, 3-hour SO2, annual SO2, and annual PM10, while most assessment areas
exceed the 24-hour PM2.5 and PM10 PSD increment (BLM 2014). Figure 1 shows that the ARMS
predicted ozone design values for the CIAA exceed the NAAQS, in the Uinta Basin and along the
Wasatch Front metropolitan area. Other areas of the state have concentrations below the NAAQS,
generally between 0.055 to 0.065 ppm. However, a few hot spots approach the NAAQS, with
concentration between 0.065 and 0.070 ppm. In Class I and Class II areas outside the Uinta Basin ARMS
study area, O3 concentrations are highest during the summer period (BLM 2014). For areas outside the
Uinta basin, the modeling results are likely conservative due to the over prediction of summertime O3 in
the ARMS model. If background O3 levels rise additional analysis may be needed when plans of
development are submitted for the lease parcels. Predicted PM2.5 design values are shown in Figure 2,
with annual concentrations in the CIAA generally in the 4-8 µg/m3 range. Exceedances are predicted near
the Wasatch front and St George urban areas, and in the Uinta Basin. Although it is important to note that
no monitored exceedances have been reported in the Uinta Basin and the reported PM2.5 design values,
Table 11, are well below the NAAQS.
38
August 2019
Figure 1. ARMS predicted ozone design values with on the books controls for oil and gas emissions
in the year 2021.
Figure 2. ARMS predicted PM2.5 design values with on the books controls for oil and gas emissions
in the year 2021.
39
August 2019
Based on the relatively minor levels of emissions associated with this proposed development, and the
application of BMPs, it is unlikely emissions from any subsequent development of the proposed leases
would contribute to regional ozone formation in the project area, nor is it likely to contribute or cause
exceedances of any NAAQS. Other emission contributors would continue at present rates such as
construction, urban development, and personal vehicle use.
Air Quality Related Values
The MLP analyzed changes to visibility conditions by modeling the number of days there was a change in
deciviews, which is a unit of measurement to quantify human perception of visibility. It is derived from
the natural logarithm of atmospheric light extinction coefficient. One (1) deciview is roughly the smallest
change in visibility (haze) that is barely perceptible. Modeled visibility impacts ranged from greater than
0.5 dv impacts on almost half the year (159 days) at Canyonlands National Park during the 2008
meteorological year for the high emissions scenario, to no visibility impacts greater than 1.0 dv at any
park for any meteorological year under the low emissions scenario. Coarse particulate (PM10), primarily
road dust from truck traffic on unpaved roads, was the dominate pollutant of concern under both high and
medium emissions scenarios. Under the low emissions scenarios nitrogen oxides play a greater role in
visibility impacts. The specific meteorological year used in the analysis also had a significant influence on
modeled impacts. Meteorology in 2008 had substantially greater levels of impacts across the board
compared to the previous two years of meteorological data. This indicates sensitivity to meteorological
variability, and given the large role particulates play, adverse visibility impacts can most likely be tied to
drier, hotter, and/or windier conditions (BLM 2016). Additionally the AMR (BLM 2019) shows that
visibility has been improving at the Class I areas in Utah. Development of lease sale parcels would
slightly increase the impacts to visibility, but are not likely to be perceptible or substantially change the
improving visibility trend. AQRVs were also analyzed in the ARMS modeling study. Visibility
conditions in Class I areas generally show improvement in the 2021 future year scenarios relative to the
2010 Base Year and 2010 Typical Year.
All MLP modeled values of sulfur and nitrogen deposition were near or below the Deposition Analysis
Thresholds of 0.005 kg/ha/yr for total nitrogen and total sulfur for all the modeled alternatives, with the
exception of the high and medium emissions scenarios for nitrogen deposition in Arches and
Canyonlands National Park for the 2008 meteorological year (BLM 2016). Development of lease parcels
has the potential to slightly add to the deposition rate.
ARMS model results generally show a decrease in deposition values for the 2021 future year scenarios
relative to the 2010 Typical Year. However, the differences in estimated deposition values between all
four future year scenarios are generally very small. Acid neutralizing capacity change at all seven
sensitive lakes exceeds the 10 percent limit of acceptable change for all model scenarios.
The proposed action, in concert with other past, present, and reasonably foreseeable actions may
contribute to an increase of emissions through direct and indirect impacts, but it would not be expected to
increase cumulative effects to levels that would compromise the viability of air quality within or near the
CIAA. Visibility and deposition conditions in Class I and Class II areas would likely follow current
improving trends as described in the AMR (BLM 2019).
Hazardous Air Pollutants
The Past and present projects which contribute HAPs to the CIAA are detailed in the Utah Division of Air
Quality’s 2014 Point Source Emissions Inventory (UDAQ 2018). The 2014 Triennial Inventory of HAPs
(cumulative inventory of point source HAPs) for the project area is summarized in Table 26. The EPA has
determined that for all of Utah the total cancer risk is 11 to 41 in 1 million (EPA 2019). This cancer risk is
within the acceptable range of risk published by the EPA of 1 to 100 in a million as discussed in the
National Contingency Plan, 40 CFR 300.430. The highest cancer risks in Utah are found in counties along
40
August 2019
the Wasatch Front and Washington County. The total cancer risk in counties where parcels are located is
15 to 20 in 1 million.
The proposed action of leasing would not directly contribute to cumulative HAPs emissions or cancer
risk. Future potential development of the leases would contribute to HAPs emissions and cancer risk.
However, the HAPs emission contribution is not meaningful in the context of point source emissions
ongoing in the CIAA.
The No Action alternative would not contribute to criteria pollutant emissions, HAP emissions, or AQRV
impacts because the leases would not be issued and no development could occur.
3.3.2 Issue 2: What are the Potential Impacts of Oil and Gas Leasing to Climate
Change/Greenhouse Gases?
Climate is the composite of generally prevailing weather conditions of a particular region throughout the
year, averaged over a series of years such as temperature and precipitation. Climate change is the long-
term (several decades or longer) alteration of atmospheric weather patterns (temperature, precipitation,
winds, etc), but changes could also occur in other parts of the climate system such as the hydrosphere
(water), cryosphere (ice), biosphere (living organisms, ecosystems), or lithosphere. The 2018 BLM Utah
Air Monitoring Report (BLM 2019) discusses the current climate conditions in Utah, and is incorporated
by reference. The report presents the three-decade average and trends of temperature and precipitation for
each of the seven climate divisions in Utah.
Utah’s climate has average annual temperatures ranging between 45-52 ºF and average precipitation of
10-13 inches (BLM 2019). Mountainous areas have annual average temperatures near 40 ºF with average
precipitation of 23 inches. Southern Utah low elevation areas in the St George Field Office have average
temperatures of about 59 ºF. Trends over the most recent climate normal period (1981-2010) show
average temperatures increase 0.5 ºF while precipitation decrease between 0.3 and 1.5 inches. However, it
is noted that decreases in precipitation are heavily influenced by the historic rain and snowfall in the early
1980’s and recent precipitation is near the 1895-2017 average.
Average annual temperature and precipitation information for each Utah climate division is presented in
Table 14, along with trends from the most recent climate normal period (1981-2010). The lease parcels
are located in all of the climate divisions except for the Western and Dixie divisions. Average annual
temperatures range from 40-52℉, with the Northern Mountains division being the coolest and the
Southeast division the warmest. The 30 year climate trends of annual averages show increasing
temperatures and decreasing precipitation. However, the decreasing precipitation trend is heavily
influenced by the record amounts of precipitation that occurred in the early 1980’s. Additional details on
climate in these areas and the rest of Utah are provided in the 2018 BLM Utah Air Monitoring Report
(BLM 2019).
41
August 2019
Table 14. Climate Trends
1895-2017 Mean 1981-2010 Trend
Climate Division Temp (ºF) Precip (in.) Temp (ºF) Precip (in.)
1, Western 49.6 9.81 + 0.5 -0.76
2, Dixie 58.5 12.94 + 0.6 -0.60
3, North Central 47.9 16.7 + 0.6 -1.49
4, South Central 46 15.71 + 0.5 -0.78
5, Northern Mountains 40.1 23.46 + 0.5 -1.32
6, Uinta Basin 45.1 10.72 + 0.5 -0.65
7, Southeast 51.5 9.8 + 0.5 -0.51
In November 2018 the Fourth National Climate Assessment (NCA4) Volume II was published.
Compared to previous reports, NCA4 provides greater detail on regional scales as impacts and adaptation
tend to be realized at a more local level. The Southwest region (Arizona, California, Colorado, New
Mexico, Nevada, and Utah) encompasses diverse ecosystems, cultures, and economies, reflecting a broad
range of climate conditions, including the hottest and driest climate in the United States. The average
annual temperature of the Southwest increased 1.6°F (0.9ºC) between 1901 and 2016. Moreover, the
region recorded more warm nights and fewer cold nights between 1990 and 2016, including an increase
of 4.1°F (2.3°C) for the coldest day of the year. Each NCA has consistently identified drought, water
shortages, and loss of ecosystem integrity as major challenges that the Southwest confronts under climate
change. Since the last assessment, published field research has provided even stronger detection of
hydrological drought, tree death, wildfire increases, sea level rise and warming, oxygen loss, and
acidification of the ocean that have been statistically different from natural variation, with much of the
attribution pointing to human-caused climate change (USGCRP 2018).
Climate change includes both historic and predicted climate shifts that are beyond normal weather
variations. Climate change may be due to natural internal processes or external forces. Earth’s atmosphere
has a natural greenhouse effect wherein naturally occurring gases such as water vapor, carbon dioxide
(CO2), methane (CH4), nitrous oxide (N2O) and fluorinated gases absorb and retain heat (EPA 2018). A
number of activities contribute to the phenomenon of climate change, including emissions of GHGs
(especially CO2 and methane) from fossil fuel development, large wildfires, activities using combustion
engines, changes to the natural carbon cycle, and changes to radiative forces and reflectivity (albedo). In
order to assess the potential for climate change, and the resultant effects of climate change, the standard
approach is to measure and predict emissions of GHGs. Since the pre-industrial era (approximately 1750)
to 2017, concentrations of GHG’s have increased 45% for CO2, 164% for CH4, and 22% for N2O, Table
15. In 2017, the atmospheric concentration of CO2 was 407 ppm and is increasing at a rate of 2.2 ppm/yr.
Table 15. Global Atmospheric Concentration and Rate of Change of Greenhouse Gases
CO2 CH4 N2O
Pre-Industrial Concentration 280 ppm 0.700 ppm 0.270 ppm
2017 Atmospheric Concentration 407 ppm 1.850 ppm 0.330 ppm
2007-2017 Rate of Change 2.2 ppm/yr 0.007 ppm/yr 0.008 ppm/yr
Source: EPA Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2017 (EPA 2019)
Each GHG has a global warming potential (GWP) that accounts for the intensity of each GHG’s heat
trapping effect and its longevity in the atmosphere. GWP values allow for a comparison of the impacts of
emissions and reductions of different gases. Specifically, it is a measure of how much energy the
42
August 2019
emissions of 1 ton of a gas will absorb over a given period of time, relative to the emissions of 1 ton of
CO2. The GHGs are presented using the unit of Metric Tons of CO2 equivalent (MT CO2e), a metric to
express the impact of each different GHG in terms of the amount of CO2 making it possible to express
GHGs as a single number. According to the IPCC, GWPs typically have an uncertainty of ±35 percent.
GWPs have been developed for several GHGs over different time horizons including 20 year, 100 year,
and 500 year. The choice of emission metric and time horizon depends on type of application and policy
context; hence, no single metric is optimal for all policy goals. The 100-year GWP (GWP100) was
adopted by the United Nations Framework Convention on Climate Change (UNFCCC) and its Kyoto
Protocol and is now used widely as the default metric. In addition, the EPA uses the 100 year time
horizon in its Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2017 (EPA 2019) and GHG
Reporting Rule requirements under 40 CFR Part 98 Subpart A, and uses the GWPs and time horizon
consistent with the Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment Report, Climate
Change Synthesis Report (2014) in its science communications. BLM Utah uses GWPs that reflect the
current state of science and the 100 year time horizon to allow for direct comparison to state and national
emissions.
State, national, and global GHG emissions are reported in Table 16. Additional details about state,
national, and global GHG emissions are discussed in Appendix E – . Since 2013, emissions from major
sources in Utah has decreased from 44.5 million metric tons (MMT) CO2e to 35 MMT CO2e. Nationally,
emission have decreased by 253.5 MMT CO2e from 2013 to 2017.
Table 16. State, National, and Global GHG Emissions (CO2e) in Million Metric Tons per Year
Utah US Energy United Global

Sector States
35.0 5,424.8 6,456.7 46,423.3
Source: EPA Inventory of US Greenhouse Gases Emission and Sinks 1990-2017 (EPA 2019)
EPA GHG Reporting Program FLIGHT tool (EPA 2018)
Fossil CO2 & GHG Emissions of all World Countries, recent year 2012 (Janssens-Maenhout, et al. 2017)
While the leasing action itself would not generate any GHG emissions, the BLM recognizes that the
reasonably foreseeable consequence of leasing may lead to oil and gas development, and that such
development could result in an increase in GHG emissions due to well development and operations, and
from downstream uses of the petroleum products produced from these parcels.
Emissions from Lease Parcel Development
At the leasing stage, BLM cannot develop a precise emissions inventory, as many factors, including the
duration of possible development, and the types of related equipment (rig engine tier, horse power, etc.)
that may be utilized by a lessee in the future, are unknown. Emissions inventories developed for recent
projects in each BLM Utah district are used as estimates for this EA. Methods and assumptions used for
estimating GHG emissions from the development of lease parcels are described in Appendix E – .
Emissions of GHGs can occur during both the construction and operation phase of a well. Construction
emissions occur from heavy equipment and vehicle exhaust, drill rigs, completion equipment including
fracturing engines, and venting. Operation emissions occur from storage tank breathing and flashing,
truck loading, pump engines, heaters and dehydrators, pneumatics, flaring, fugitives, and vehicle exhaust.
Estimates of single well GHG emissions based on BLM Utah’s district emissions inventories are listed in
Table 17.
Table 17. Estimated Emissions from Construction and Operating Potential Future Wells
43
August 2019
Single Well Emissions Total Emissions

(MT CO2e) (MT CO2e)
RFD
Field Office Construction Operation/yr Construction Operation/yr
(wells)
Moab 2 2,733 1,788 28,287 60,738
Monticello 9 2,733 1,788 24,597 16,096
Price 5 678 428 3,392 2,139
Richfield 7 943 2,025 6,600 14,172
Vernal 1 678 428 678 428
State Total 24 - - 40,734 36,411
Total estimated GHG emissions from operating the projected number of wells from this lease sale is
36,411 MT CO2e/yr. Using the 20 year GWP time horizon, operation emissions are 71,614 MT CO2e/yr.
Construction emissions are estimated at 40,734 MT CO2e/yr, or 47,357 MT CO2e/yr with the 20 year
GWP.
Emissions from Combustion of Produced Oil or Gas
If lease parcels are developed and if the resulting well produces oil or gas, GHG emissions are expected
to result from the downstream end-use of the fossil fuel. To calculate estimates of these downstream
emissions for this EA, BLM assumed that all produced oil or gas will be combusted (such as for domestic
heating or energy production). However, the BLM has no authority to direct or regulate the end-use of the
produced products and an actual end-use may differ from the assumption used for calculating downstream
GHG emissions.
Estimates of GHG emissions from combustion can be made by multiplying the produced number of
barrels (bbl) of oil and thousand cubic feet (mcf) of gas with GHG emission factors from the EPA
Greenhouse Gases Equivalencies Calculator – Calculations and References website (EPA, 2019). These
emission factors provide an estimate of the equivalent amount of CO2 produced from a bbl of oil or mcf
of gas. The emission factors follow IPCC guidance by accounting for 100% oxidation of carbon in the
fossil fuel to CO2, regardless if the carbon atom is part of a CO2, CH4, or other hydrocarbon molecule.
As BLM does not know how much oil or gas will be produced from the parcels that would be affected by
the proposed action, BLM has assumed that future wells will produce oil and gas in similar amounts as
existing nearby wells. Annual production data for oil and gas is obtained from the Utah Division of Oil,
Gas and Mining (UDOGM, 2018). BLM used annual data from 2008 to 2018 to calculate the average
production per well in a field office. However, some wells may produce more or less than the average.
Low and high production estimates are also used to calculate a range of combustion emissions, in order to
better inform decision makers and the public of potential emissions. Details on estimating production and
combustion emissions are presented in Appendix E –
Table 18 lists the estimated range of annual GHG emissions from combustion of oil and gas produced by
a single well and the total estimated combustion emissions for all parcels considered in the original EAs.
While a range of combustion emissions is presented, for simplicity, the average is used when discussing
total emissions for the proposed action.
44
August 2019
Table 18. Annual Estimated Emissions from Combustion of Produced Oil and Gas from the
Proposed Action
Single Well Combustion
Emissions Range Total Emissions Range
(MT CO2e/yr) (MT CO2e/yr)
RFD
Field Office
(wells) Low Average High Low Average High
Moab 2 298 904 1,786 596 1,807 3,573
Monticello 9 2,609 3,140 3,670 23,484 28,258 33,032
Price 5 1,581 3,445 5,308 7,907 17,223 26,538
Richfield 7 12,352 32,713 53,928 86,457 228,992 377,495
Vernal 1 1,133 2,577 4,020 1,133 2,577 4,020
State Total 24 - - - 119,587 278,856 444,658
Projected average annual combustion GHG emissions from all of the parcels considered in the original
EAs is 278,856 MT CO2e/yr. GHG emissions may range from 119,587 MT CO2e/yr, to 444,658 MT
CO2e/yr, depending on realized production rates, control technology, and physical characteristics of any
oil produced.
The estimated production-based combustion emissions for the Richfield Field Office shown in Table
18are skewed high due to the low number of producing wells in that field office, and the inclusion of the
highest producing well in the state, 16 which elevates total and average production. 17 To provide context
for the high emissions estimates for the Richfield Field Office, the average single well emissions in the
field office (32,713 MT CO2e/yr) is an order of magnitude higher than the state average emissions
estimate (2,715 MT CO2e/yr). Although production and emissions estimates are likely high for Richfield,
the UDOGM data is the best available information for estimating combustion emissions from production.
As climate change is a response to global emissions of GHGs, it is difficult to assign a “significance”
value or impact based on a single action. Emissions estimates themselves are presented for disclosure
purposes and as a proxy for impacts from the proposed action. Emissions can be compared to annual state
and national emissions listed in Table 16 to provide a measure of the relative impact. The total estimated
GHG emissions from construction (40,734 MT CO2e), operations (36,411 MT CO2e/yr), and combustion
(278,856 MT CO2e /yr) from development on the parcels considered is 356,001 MT CO2e/yr, which is
1.02% of Utah major industrial sources. To express GHG emissions on a scale relatable to everyday life
the EPA GHG equivalency calculator can be used (https://www.epa.gov/energy/greenhouse-gas-
equivalencies-calculator). The projected total emissions (75,584 MT CO2e/yr) are equivalent to 75,584
passenger vehicles driven for one year, or energy use for 42,630 homes for one year. Climate change
impacts are further discussed in the cumulative impacts section of this document.
Lifetime GHG emissions from the parcels considered can be estimated by multiplying well production
life with the operation and combustion emissions and adding the one-time construction emissions.
Assuming an average well life of 30 years, the total gross emissions from the parcels analyzed would be
9.5 MMT CO2e. However, assuming the production life of a well is somewhat speculative at the leasing
stage. Individual wells could be dry or have shorter or longer production lifespans, resulting in lower or
higher lifetime emissions.
While the BLM provides an estimate of direct and indirect GHG emissions from the potential
development of lease parcels, there is significant uncertainty due to unknown factors including actual
16 To date, total oil production of Wolverine Federal 17-12 is 3,581,110 bbls of oil. Production started in 2008.
https://oilgas.ogm.utah.gov/oilgasweb/live-data-search/lds-prod/prod-lu.xhtml
17 The Covenant Field in Sevier County has a total of 32 wells. In 2018, the field produced 1,345,937 bbls of oil.
https://oilgas.ogm.utah.gov/oilgasweb/statistics/oil-prod-by-opr.xhtml?selectedYear=2018
45
August 2019
production, life expectancy of a well, how produced minerals are used, the form of regulation of GHG
parameters by delegated agencies, and whether any Best Available Control Technologies are utilized at
the upstream or downstream emission location(s). Statewide, the range of combustion emissions alone has
an uncertainty of nearly 340% based on if a well is low or high producing. This uncertainty is
compounded when accounting for other factors listed above. Other factors that account for uncertainty in
emissions calculations is provided in Appendix E – Air Quality and Green House Gas Information and
Calculations.
Impacts of the No Alternative Action
Under the No Action Alternative, the parcels would not be leased so no future development could occur.
As a result, no GHG emissions from the development of these lease parcels would occur and there would
be no addition to the existing national and global emissions that influence climate change.
3.3.2.3 Mitigation of Impacts from GHG Emissions and Climate Change
The BLM regulates portions of natural gas and petroleum systems identified in the EPA Inventory of U.S.
Greenhouse Gas Emissions and Sinks report (EPA, Inventory of U.S. Greenhouse Gas Emissions and
Sinks 1990-2017 2019). In carrying out its responsibilities, BLM has developed a list of best management
practices (BMPs) designed to reduce emissions from field production and operations. Analysis and
approval of future development on the lease parcels may include application of BMPs within BLM’s
authority, as Conditions of Approval, to reduce or mitigate GHG emissions. Additional measures
developed at the project development stage also may be incorporated as applicant-committed measures by
the project proponent, or added to necessary air quality permits.
BMPs to reduce the impacts of climate change and GHG emissions may include, but are not limited to:
• Flare hydrocarbon and gases at high temperatures in order to reduce emissions of incomplete
combustion through the use of multi-chamber combustors;
• Require that vapor recovery systems be maintained and functional in areas where petroleum liquids
are stored;
• Installation of liquids gathering facilities or central production facilities to reduce the total number
of sources and minimize truck traffic;
• Use of natural gas fired or electric drill rig engines;
• The use of selective catalytic reducers and low-sulfur fuel for diesel-fired drill rig engines; and,
• Implementation of directional and horizontal drilling technologies whereby one well provides
access to petroleum resources that would normally require the drilling of several vertical wellbores;
Additionally, the BLM encourages natural gas companies to adopt proven cost-effective technologies and
practices that improve operation efficiency and reduce natural gas emissions, to reduce the ultimate
impact from the emissions.
In October 2012, the EPA promulgated air quality regulations for completion of hydraulically fractured
gas wells. These rules require air pollution mitigation measures that reduce the emissions of VOCs during
gas well completions. Mitigation includes a process known as “green completion” in which the recovered
products are sent through a series of aboveground, closed, separators which negates the need for flowing
back into surface pits as the product is immediately sent to gas lines and the fluids are transferred to
onsite tanks.
Even though leasing by itself does not contribute to cumulative (total) effects on air resources, future
foreseeable development on leased parcels, and related combustion, could contribute to total GHG
46
August 2019
emissions and therefore climate change. Total GHG emissions from existing and foreseeable oil and gas
wells are calculated and presented in detail in section 2.2.1 and Appendix E –
Estimated annual GHG emissions from existing and foreseeable oil and gas sources are presented in
Table 19. Existing oil and gas sources include active producing wells, and shut-in wells that are capable
of producing, as reported by UDOGM at the end of 2018. Foreseeable oil and gas sources include the
development of approved APDs that have not been drilled to completion. Emissions for existing wells
include the operation and combustion emissions, while estimates of foreseeable wells include
construction, operation, and combustion emissions. Federal and non-federal wells are included in both the
existing and foreseeable estimates. Total annual oil and gas related emissions in the State of Utah is
41,977,559 MT CO2e/yr.
Table 19. Estimated Annual GHG Emissions (MT CO2e/yr.) from Existing and Reasonably
Foreseeable Oil and Gas Wells.
Existing Well Foreseeable Well Total Annual

Field Office
Emissions Emissions O&G Emissions
Moab 1,130,785 55,636 1,186,420
Monticello 3,495,152 99,595 3,594,747
Price 3,314,642 13,652 3,328,294
Richfield 680,534 216,646 897,181
Vernal 30,773,120 1,789,810 32,562,930
Statewide Total 39,783,694 2,193,865 41,977,559
For context, in Table 20, these estimated total annual emissions from Table 19 are compared to annual
state and U.S. emissions from 2017. Statewide, oil and gas related emissions are 54.48% of major
industrial sources (35 MMT CO2e) plus oil and gas source (42 MMT CO2e). However, state total GHG
emissions do not include emissions from the agriculture, transportation, and waste management sectors,
which are substantial sources of GHG emissions. Current emissions information for these sectors is not
available. The Utah Greenhouse Gas Inventory and Reference Case Projections (Strategies 2007) report
projected that in 2020 agriculture, transportation, and waste management emissions in Utah would be 5.8
MMT CO2e, 22.4 MMT CO2e, and 4.7 MMT CO2e respectively. Adding the projections for these sectors
with the reported major source and oil and gas estimated emissions results in approximately 110 MMT
CO2e total GHG emissions estimate for the State of Utah.
Table 20. Comparison of Estimated Total Annual GHG Emissions with Annual State and National
Emissions
Total Annual O&G Percent of Utah

Percent of U.S. Percent of
Field Office Emissions (MT (Major + O&G)
Energy U.S. Total
CO2e/yr) Emissions
Moab 1,186,420 1.54% 0.02% 0.02%
Monticello 3,594,747 4.67% 0.07% 0.06%
Price 3,328,294 4.32% 0.06% 0.05%
Richfield 897,181 1.16% 0.02% 0.01%
Vernal 32,562,930 42.26% 0.60% 0.50%
Statewide 41,977,559 54.48% 0.77% 0.65%
Table 21, shows the annual GHG emissions estimate, from well operation and product combustion, for a
years’ worth of BLM Utah lease sales (March, 2019, June 2019, September 2019, and December 2019).
Emissions after the full development of the RFD from the four lease sales is 2,623,981 MT CO2e/yr,
47
August 2019
which is about 6.3% of total annual oil and gas emissions (41,977,559 MT CO2e/yr.). An additional
407,483 MT CO2e would occur from constructing the wells, but these emissions would be spread out over
a 10 year period.
Table 21 Annual Emissions Estimate from a Year of BLM Leasing (MT CO2e/yr).
Comparison to
Total
Total Lease Operation Combustion Total Annual
Field Office Leasing
RFD Emissions Emissions O&G
Emissions
Emissions
Cedar City 2 4,049 5,430 9,480 100.0%
Fillmore 0 0 0 0 0.0%
Kanab 0 0 0 0 0.0%
Moab 7 12,519 6,325 18,844 1.6%
Monticello 13 23,249 40,817 64,066 1.8%
Price 21 8,982 72,335 81,317 2.4%
Richfield 31 62,763 1,014,107 1,076,870 120.0%
Salt Lake 3 6,074 18,412 24,486 8.1%
St George 0 0 0 0 0%
Vernal 449 192,042 1,156,876 1,348,918 4.1%
State Total 526 309,678 2,314,302 2,623,981 6.3%
The Resource Management Plan (RMP) for each field office planning area includes an RFD scenario
describing the number of expected wells over the life of the plan. These expected wells can be used to
estimate the potential total GHG emissions for all of the lands open to leasing in each planning area.
Planning-area-wide emissions are estimated by multiplying the expected number of wells by the single
well construction, operation, and combustion emissions, assuming all lands would be leased, and fully
developed concurrently (Table 22). Total annual oil and gas emissions from the RMP expected number of
wells is 43,855,596 MT CO2e/yr, with additional one-time emissions of 6,636,988 MT CO2e from well
construction.
Table 22. Expected wells from Each Field Office RMP, and Corresponding GHG Emissions
Construction Average
RMP Expected Operation (MT
Field Office Combustion (MT
wells (MT CO2e) CO2e/yr)
CO2e/yr)
Moab 390 921,308 600,016 352,409
Moab MLP 128 302,378 196,928 115,663
Monticello 195 460,654 300,008 612,253
Price 1,900 1,289,084 812,649 6,544,567
Richfield 454 366,191 919,176 14,851,756
Vernal 6,530 3,224,780 1,260,667 16,824,944
BLM Utah 9,687 6,636,988 4,271,660 39,583,936
48
August 2019
The U.S. Geological Survey (USGS) has produced estimates of the GHG resulting from the extraction
and end-use combustion of fossil fuels produced on Federal lands in the United States, as well as
estimates of ecosystem carbon emissions and sequestration on those lands (USGS 2018). The study
reports GHG emissions from extraction, transport, fugitives, and combustion of fuel over a ten year
period (2005-2014). In 2014, nationwide gross GHG emissions from fossil fuels extracted from Federal
lands was 1,332.1 MMT CO2e. Emissions from fossil fuels produced on Federal lands represent, on
average, 23.7 percent of national emissions for CO2, 7.3 percent for CH4, and 1.5 percent for N2O over
the 10 years included in this estimate (USGS, Federal lands greenhouse emissions and sequestration in
the United States—Estimates for 2005–14: Merrill, M.D., Sleeter, B.M., Freeman, P.A., Liu, J., Warwick,
P.D., and Reed, B.C. 2018). Uncertainty associated with emissions estimates is 2-5% for combustion, 25-
42% for fugitives, and 12-15% for degassed CH4 emissions from coal mines. Trends and relative
magnitude of emissions are roughly parallel to production volumes.
Utah Federal fossil-fuel-related gross emissions in 2014 were 46.75 MMT CO2e, approximately 3.5% of
the estimate of national emissions from Federal fossil fuels (USGS, Federal lands greenhouse emissions
and sequestration in the United States—Estimates for 2005–14: Merrill, M.D., Sleeter, B.M., Freeman,
P.A., Liu, J., Warwick, P.D., and Reed, B.C. 2018). Emissions from the adjacent fossil fuel producing
states of Colorado, New Mexico, and Wyoming were 55.78, 91.63, and 744.2 MMT CO2e, respectively,
in 2014. USGS annual emissions data for each state is shown in Appendix E – Air Quality and Green
House Gas Information and Calculations. The linear trend of the USGS data shows a decrease of 0.4
MMT CO2e/yr in Utah. Assuming this trend continues, projected Utah Federal fossil fuel emissions in
2019 would be 43.1 MMT CO2e. Estimated lease sale emissions would add to the USGS calculated
emissions by 1,054,420 MT CO2e.
Federal lands also uptake carbon in vegetation, soils, and water. In 2014, carbon storage on Federal lands
was 83,600 MMT CO2e nationally and 3,611 MMT CO2e in Utah. Soils stored 63% of carbon with
vegetation and dead organic matter storing 26% and 11% respectively. The national rate of net carbon
uptake (sequestration) varies from 475 MMT CO2e/yr. to a source (emissions) of 51 MMT CO2e due to
changes in climate/weather, land use, land cover change, wild fire frequency, and other factors. From
2005 to 2014, terrestrial ecosystems on Federal lands sequestered an average of 195 MMT CO2e/yr,
offsetting about 15% of emissions resulting from Federal fossil fuel extraction and combustion nationally.
In Utah, the annual average ecosystem carbon storage is 3,581 MMT CO2e, with soils accounting for
about 70%. In Utah, the annual average sequestration over the ten years was 8.6 MMT CO2e/yr, offsetting
about 18% of extraction and combustion emissions from fossil fuels produced on Federal lands in Utah.
Carbon emissions from Utah ecosystems due to land-use and land-cover change, including surface
disturbing activities such as well pad construction, averaged 1.3 MMT CO2e/yr from 2005 to 2014
(USGS 2018). While surface disturbance from well pad construction contributes to ecosystem carbon
emissions and a reduction in the lands ability to store carbon, these impacts are anticipated to be
temporary during the life of a well, as reclamation requirements should return the land to a condition
approximately equal to that which existed prior to the disturbance (BLM 2007).
Climate Change
As climate impacts and trends tend to be realized at local levels (USGCRP 2018) climate change is
discussed on a regional scale, as opposed to a national or global scale. BLM prepared several Rapid
Ecoregional Assessments (REA) to predict future conditions, including climate change, in various
regions. Utah lies within two ecoregions, the Colorado Plateau and the Central Basin and Range. The
Colorado Plateau REA (Bryce 2012) covers areas east of the Wasatch Mountains and south of the Uinta
Mountains, include the Kanab, Moab, Monticello, Price, Richfield, and Vernal field offices. The Central
Basin and Range REA (Comer 2013) covers most of the Great Basin and western parts of Utah including
the Cedar City, Fillmore, St George, and Salt Lake BLM field offices.
49
August 2019
The Colorado Plateau REA analysis covered the years 1968 to 2060. Past, present, and reasonably
foreseeable activities in the analysis include energy development, agricultural development, urban and
road development, and recreation development. The assumption details and modeling methodology are
incorporated by reference. The Colorado Plateau REA depicts the data sources for potential oil and gas
leasing, development and production, and oil shale and tar sand extraction. Modeled average annual
future temperatures in the Colorado Plateau REA are generally predicted to increase. Average annual
precipitation predicted by the model in general are predicted to decrease (drier) through 2030 and increase
(wetter) through 2060. Figure 3 shows the potential for climate related change and is a composite of
predicted changes to temperature, precipitation, runoff, and vegetation. Potential for climate related
change in the Colorado Plateau area is generally predicted to be mostly moderate or lower (about 70%),
with areas with high or very high (approximately 30%) potential for change generally seen in higher
elevations. Due to uncertainties described in the Colorado Plateau REA, caution should be used for
interpreting climate change potential at site-specific scales (Bryce 2012).
Figure 3. Potential for climate change impacts for the Colorado Plateau.
The Central Basin and Range REA used an ensemble mean from 6 global climate models to determine
future climate change projections in the Great Basin and western portions of Utah. Details and
assumptions about climate change projects are discussed in the report and included by reference. Results
for precipitation suggest there is no strong trend toward either wetter or drier conditions in any month for
the Central Basin. With the exception of a slight increase in summer “monsoon” rains toward the south
and east, there are no significant forecasted trends in precipitation for any other months in either the near
term (2020s) or midcentury (2050s). The Central Basin and Range REA projected changes to temperature
by 2060 by showing areas where the one or more of the 24 monthly maximum and minimum
temperatures deviate by two standard deviations or more from the baseline 20th century mean
temperature, as shown in Figure 4. This analysis identifies areas where concentrated climate change or
lack of climate change is projected to occur. Areas with a larger number of monthly deviations are more
likely to experience temperature related climate change. In general, temperatures are projected to
increase, with mountainous areas expected to see the most change. Potential impacts to individual
50
August 2019
resources from projected climate change are further described in the Central Basin and Range REA
(Comer 2013).
Figure 4. Composite 2060 forecast for temperature departure from the baseline.
The U.S. Geological Survey National Climate Change Viewer (USGS 2019) can be used to evaluate
potential climate change at the state and county level. Data presented in the climate viewer is intended to
assist the scientific community in conducting studies on climate changes and to enhance public
understanding of possible future climate impacts to their local communities. The viewer provides
historical (1950-2005) and future (2006-2099) climate projects under a moderate (RCP4.5) and
aggressive (RCP8.5) emissions scenario. Theses emission scenarios correspond to atmospheric
concentrations of CO2 by 2100 of 650 ppm for RCP4.5, and 1370 ppm for RCP8.5. Observed
concentration in 2017 were 407 ppm, see Table 15. The climate viewer compiles projections from 30
different global climate models. Projected changes to maximum and minimum temperature and
precipitation for Utah are presented in this EA as the climate change anticipated from the different
greenhouse gas emission scenarios.
Projected changed to seasonal maximum 2-m air temperature is presented in Figure 5 with seasonal
changes to minimum 2-m air temperature is presented in Figure 6. For both GHG emissions scenarios
temperatures increase above historical levels by mid-century and 2100. Projections for RCP8.5 begin to
deviate from the RCP4.5 projections after mid-century, and depending on the season are approximately
5ºF or more warmer by 2100. For the RCP4.5 scenario, both maximum and minimum temperatures level
51
August 2019
off approximately 5ºF warmer than historical temperatures, while the RCP8.5 scenario shows a continued
increasing trend at year 2100.
Figure 5. Seasonal average time series of maximum 2-m air temperature for historical (black),
RCP4.5 (blue), and RCP8.5 (red). Solid lines are the average and shaded areas represent the
standard deviation.
Figure 6. Seasonal average time series of minimum 2-m air temperature for historical (black),
RCP4.5 (blue), and RCP8.5 (red). Solid lines are the average and shaded areas represent the
standard deviation.
Projected changes to monthly precipitation for four time periods (1961-2010 historical, 2025-2049, 2050-
2074, and 2075-2099) is presented in Figure 7. Estimated changes for all time periods and both emission
scenarios is minimal (not statistically significant) with respect to historic precipitation, but with a slight
increase in precipitation for RCP8.5 during the winter. The historical precipitation falls within the upper
and lower ranges for all estimates of precipitation change. However, both the RCP8.5 and RCP4.5
projections show statistically significant lower amounts of snow water equivalent and runoff for all future
52
August 2019
time periods. In other words, less snow pack in the winter, more runoff during the winter, and less during
the spring and summer.
Figure 7. Monthly averages of precipitation for four time periods for the RCP4.5 (left) and RCP8.5
(right) simulations. The average of 30 CMIP5 models is indicated by the solid lines and their
standard deviations are indicated by the respective shaded envelopes. Triangle, diamond and
square symbols indicate the percent of models that simulate future minus present changes that are
of the same sign and statistically significant. A two-sided Students t-test is used to establish
statistical significance (ρ ≤ 0.05).
“Social cost of carbon” estimates are one approach that an agency can take to examine climate
consequences from greenhouse gas emissions resulting from a proposed action. However, this EA
provides no quantitative monetary estimates of any benefits or costs. NEPA does not require an economic
cost-benefit analysis (40 C.F.R. § 1502.23), although NEPA does require consideration of “effects” that
include “economic” and “social” effects (40 C.F.R. 1508.8(b)). Quantifying only the costs of oil and gas
development, by using the social cost of carbon metrics, but not the benefits (as measured by the
economic value of the proposed oil and gas development and production generally equaling the price of
oil and gas minus the cost of producing, processing, and transporting the minerals), would yield
information that is inaccurate and not useful for the decision-maker, especially given that there are no
current criteria or thresholds that determine a level of significance for social cost of carbon monetary
values.
Instead of relying on such metric, BLM’s approach to estimating GHG emissions and potential effects on
climate change in this EA is to include calculations to show estimated construction, operation,
combustion, and cumulative GHG emissions from potential future development. BLM’s approach
recognizes that there are adverse environmental impacts related to climate change associated with the
development and use of fossil fuels, provides potential GHG emissions estimates, and discusses potential
climate change impacts qualitatively. This effectively informs the decision-maker and the public of the
potential for GHG emissions and the potential implications of climate change. This approach presents the
data and information in a manner that follows many of the guidelines for effective climate change
communication developed by the National Academy of Sciences (Council 2010) by making the
information more readily understood and relatable to the decision-maker and the general public.
The proposed action may result in GHG emissions that contribute to statewide, regional, and national
GHG emissions totals in the estimated percentages described in the foregoing sections. There are
53
August 2019
currently no established significance thresholds for GHG emissions that BLM can reference in NEPA
analyses, but all GHGs contribute incrementally to the climate change phenomenon. When determining
NEPA significance for an action, BLM is constrained to the extent that cumulative effects (such as
climate change) are only considered in the determination of significance when such effects can be
prevented or modified by decision-making (refer to BLM NEPA Handbook, pg.72). While GHG
emissions resulting from individual decisions can certainly be modified or potentially prevented by
analyzing and selecting reasonable alternatives that appropriately respond to the action’s purpose and
need, BLM has limited decision authority too meaningfully or measurably prevent the cumulative climate
change impacts that would result from global emissions.
The No Action alternative would not contribute to the cumulative emissions or climate change because
the subject leases would not continue, and no development of those leases would occur.
3.3.3 Issue 3: What are the potential impacts to the newly designated wilderness and the
San Rafael Recreation areas in Emery County?
The 2019 “John D. Dingell, Jr. Conservation, Management, and Recreation Act” designated the Lower
Last Chance Wilderness Area (LLCWA) the Muddy Creek Wilderness Area (MCWA) and the San Rafael
Recreation Area in the southwestern section of Emery County in the Price Field Office. Management of
the LLCWA and MCWA is now prescribed by BLM Manual 6340 Management of BLM Wilderness. The
Manual states:
“NEPA analysis for a lease of public lands outside the boundary of a wilderness should address
impacts to adjacent wilderness values; mitigation measures should be considered to the extent
reasonable and feasible (see also 1.6.D.2.a in this manual)…In general, the BLM does not
prohibit uses outside a wilderness on public lands solely to protect the wilderness character of the
designated lands. When activities on adjacent public lands are proposed, the potential impacts, if
any, of those activities upon the wilderness resource and upon public use of the adjacent
wilderness area must be analyzed in the applicable NEPA document.”

Parcels 009 and 010 are just outside the LLCWA, and activities on the parcels could seen or heard from
inside the LLCWA, and to a lesser extent the MCWA and the San Rafael Recreation Area. These impacts
could potentially affect most of the area of the LLCWA.
Parcels 009 and 010 are in the vicinity of a small gas strike that was made in the 1950s for natural gas.
There is little potential for oil production in the area; however, there is low potential for natural gas. Oil
production tends to be more obtrusive due to the need for pumpjacks and multiple tanks to be staged on
the drill pad for the life of the well, and because of the need for large trucks to regularly visit the site to
transport the oil. Gas wells typically have only a wellhead and a tank for condensate. Gas well sites are
typically much quieter than oil due to there being no need for engines and motors to run the pumpjacks.
Development of the parcels would require a gas pipeline from the area to connect into existing pipeline
infrastructure. The lack of existing infrastructure within 30 miles would constrain development of the
parcels. However, should exploration and development occur, the time period that there would be
obtrusive impacts would be limited to the drilling, completion and workover stages. During these times,
solitude in the WAs would be negatively impacted.
54
August 2019
Impacts of the No Action Alternative
No impacts noise or viewshed on the parcels would occur from the decision not to lease them.
3.3.3.3 Required Design Features
As stated in the Interdisciplinary Checklist (Appendix D – Interdisciplinary Parcel Review Team
Checklist), Congress specifically legislated that activities that can be seen or heard from outside the
wilderness boundary were not to be precluded from approval for that reason alone. However, BLM
Manual 6340 states:
“In authorizing new uses, as long as the purpose and need can be met, a reasonable effort must be
made to protect the character and values of the nearby wilderness.
“If allowed by law and regulation, the BLM may require actions to mitigate potential impacts on
public lands (such as minor changes to location, limited timing restrictions, using certain paint
schemes on equipment, or requiring shades on lights) as identified through the NEPA process if
they would not impose additional undue financial burden on the operator.”
Lease Notice, UT-LN-125, developed from the Moab Master Leasing Plan, will be applied to the parcels
to inform the lessee/operator that COAs may be applied to exploration/development permits to reduce the
impacts to the wilderness areas, and in doing so will also reduce impacts to other nearby sensitive
resources.
The cumulative impact analysis area (CIAA) is the entire LLWCA and the portion of the MCWA within
six miles of Parcel 10. Other actions that could affect the CIAA is development of Lease UTU-84526 and
SITLA Lease ML52614, and the plugging and reclamation of five orphaned wells within or just outside
the LLWCA. However most impacts would be short-term and would not be expected to impair the WAs.
55
August 2019
Chapter 4 Consultation and Coordination
4.1 Introduction
The issues included in Section 1.8 identifies those that are analyzed in detail in Chapter 3. The IDPRT
Checklist (Appendix D) provides the rationale for issues that were considered but not analyzed further.
The issues were identified through the public and agency involvement process described in Sections 4.3
below.
4.2 Persons, Groups, and Agencies Contacted/Consulted
Persons, agencies, and organizations that were contacted or consulted during the preparation this EA are
identified in Table 23.
4.2.1 Endangered Species Act of 1973
The effects of Oil and Gas leasing development on T&E species were analyzed through Section 7
consultation on existing Utah BLM resource Management Plans, as follows:
• Moab RMP: 2008 (Cons. # 6-UT-08-F-0022), and 2016 (Cons. # 6-UT-16-F-0223)
• Moab MLP 2016
• Monticello RMP: 2008 (Cons. # 6-UT-08-F-0024)
• Price RMP: 2008 (Cons. # 6-UT-08-F-0026)
• Richfield RMP: 2008 (Cons. # 6-UT-08-F-023)
• Vernal RMP: 2008 (Cons. # 6-UT-08-F-0025)
The December 2019 lease action is in compliance with T&E species management outlined in accordance
with the requirements under the FLMPA and the NEPA.
While Federal regulations and policies require the BLM to make its public land and resources available
on the basis of the principle of multiple-use, it is BLM policy to conserve special status species and their
habitats, and to ensure that actions authorized by the BLM do not contribute to the need for the species to
become listed as T&E by the USFWS.
For lease sales conducted on listed species covered by these consultation actions, the BLM regularly
coordinates with the USFWS to assure agreement that the Proposed Action (leasing): 1) does not exceed
the impacts analyzed in the PRMP and BA/BO; and 2) would not exceed the effects contained in the
associated USFWS biological opinion(s) concurring with BLM’s Not Likely to Adversely Affect
(NLAA) determinations.
• December 2019
o Lease notice provided to USFWS: June 2, 2019
o Email with preliminary shapefiles: June 24, 2019
o Additional information supporting determination: July 23, 2019
o NLAA Agreement: August 28, 2019
The BLM is working with USFWS to confirm their agreement with BLM determinations. The BLM will
complete coordination on the December 2019 lease sale with the USFWS prior to issuance of the leases
for all parcels contained in the December 2019 lease sale, if offered. When or if disturbance is proposed
for parcels (APD stage) that contain or affect ESA species, further evaluation and Section 7 consultation
of these ESA species with the USFWS will occur as necessary. The USFWS agreed with the NLAA
determination on August 28, 2019.
4.2.2 National Historic Preservation Act (NHPA) of 1966
The BLM prepared a cultural resources report to document its reasonable and good faith effort to identify
effects this undertaking may have on historic properties, as required by Section 106 of the National
56
August 2019
Historic Preservation Act of 1966 (54 U.S.C 306108).
The Advisory Council for Historic Preservation’s (ACHP) document titled Meeting the “Reasonable and
Good Faith” Identification Standards in Section 106 Review, from
https://www.achp.gov/sites/default/files/guidance/2018-05/reasonable_good_faith_identification.pdf
outlines the steps to determine when a reasonable and good faith identification effort has been met. The
ACHP states:
• Prior to beginning the identification stage in the Section 106 process, the regulations (at 36 CFR §
800.4) require the federal agency to do the following:
• Determine and document the APE [Area of Potential Effect] in order to define where the agency
will look for historic properties that may be directly or indirectly affected by the undertaking;
• Review existing information on known and potential historic properties within the APE, so the
agency will have current data on what can be expected, or may be encountered, within the APE;
• Seek information from others who may have knowledge of historic properties in the area. This
includes the State Historic Preservation Officer (SHPO)/Tribal Historic Preservation Officer
(THPO) and, as appropriate, Indian tribes or Native Hawaiian organizations who may have
concerns about historic properties of religious and cultural significance to them within the APE.
Following these initial steps, the regulations (36 CFR § 800.4(b) (1)) set out several factors the agency
must consider in determining what is a “reasonable and good faith effort” to identify historic properties:
Take into account past planning, research and studies; the magnitude and nature of the
undertaking and the degree of federal involvement; the nature and extent of potential effects on
historic properties; and the likely nature and location of historic properties within the APE. The
Secretary of the Interior’s standards and guidelines for identification provide guidance on this
subject. The agency official should also consider other applicable professional, state, tribal, and
local laws, standards, and guidelines. The regulations note that a reasonable and good faith effort
may consist of or include ‘background research, consultation, oral history interviews, sample
field investigation, and field survey.’
For lease sales, BLM’s identification efforts include: (1) completing a comprehensive "records review,"
which is an intensive review and analysis of available pertinent cultural resource records and information
for each parcel and the surrounding areas that are included in the undertaking APE; and (2) proactively
seeking information from others who may have knowledge of historic properties in the area. The BLM's
identification efforts that are described in this report for the March 2019 lease sale undertaking are
consistent with the direction provided in multiple Interior Board of Land Appeals (IBLA)
decisions/orders, including Mandan, Hidatsa, and Arikara Nation, 164 IBLA 343 (2005), Southern Utah
Wilderness Alliance, IBLA 2008-264 (2009), and Southern Utah Wilderness Alliance, IBLA 2002-334.
On June 25, 2019 the BLM sent invitations to participate in government to government consultations to:
All Pueblo Council of Governors , Cedar Band of Paiutes, Colorado River Indian Tribes, Confederated
Tribes of the Goshute, Eastern Shoshone Tribe, Indian Peaks Band of Paiutes, Jicarilla Apache Nation,
Kaibab Band of Paiute Indians, Kanosh Band of Paiutes, Moapa Band of Paiute Indians, Navajo Nation,
Navajo Nation, Aneth Chapter, Navajo Nation, Dennehotso Chapter, Navajo Nation, Kayenta Chapter,
Navajo Nation, Mexican Water Chapter, Navajo Nation, Navajo Mountain Chapter, Navajo Nation,
Oljato Chapter, Navajo Nation, Red Mesa Chapter, Navajo Nation, Shonto Community Governance,
Navajo Nation, Teec Nos Pos Chapter, Navajo Utah Commission, Northwest Band of Shoshone Nation,
Ohkay Owingeh, Paiute Indian Tribe of Utah , Pueblo of Acoma, Pueblo of Cochiti, Pueblo of Isleta,
Pueblo of Jemez, Pueblo of Kewa (Santo Domingo), Pueblo of Laguna, Pueblo of Nambe, Pueblo of
Ohkay Owingeh, Pueblo of Picuris, Pueblo of Pojoaque, Pueblo of San Felipe, Pueblo of San Ildefonso,
Pueblo of Sandia, Pueblo of Santa Ana, Pueblo of Santa Clara, Pueblo of Taos, Pueblo of Tesuque,
Pueblo of Ysleta del Sur, Pueblo of Zia, Pueblo of Zuni, San Juan Southern Paiute Tribe, Shivwits Band
of Paiutes, Shoshone-Bannock, Skull Valley Band of Goshute Indians, Southern Ute Indian Tribe, The
57
August 2019
Hopi Tribe, Uintah and Ouray Ute Tribe, Ute Indian Tribe, Ute Mountain Ute Tribe, White Mesa Ute
On June 20, 2019 UTSO BLM posted data and instructions on ePlanning for consulting parties to request
consulting party status on the December 2019 Lease Sale Cultural Resource Report. At this time,
consultation with consulting parties is ongoing..
58
August 2019
Table 23. List of Contacts and Findings.
Name Purpose & Authorities Findings & Conclusions
for Consultation or
Coordination
National Park Service Coordinated with as a A memorandum transmitting the preliminary list of parcels was sent on July 2,
potential Stakeholder in 2019, followed up the next day with an email including GIS shapefiles. On
the affected lands. August 16, 2019, NPS sent coordinates of high visitation panoramic sites.
Coordination is ongoing.
United States Fish and Wildlife Service Coordinated/consulted A memorandum transmitting the preliminary list of parcels was sent on July 2,
with for compliance 2019. Emails were sent on transmitting the corresponding shapefiles on June
with the Endangered 24, 2018, with additional information provided July 23, 2019. The USFWS
Species Act. agreed with the NLAA determination on August 28, 2019. See Section 4.2.1.
United States Forest Service Coordinated with as a A letter transmitting the preliminary list of parcels was sent on July 2, 2019.
potential Stakeholder in Comments or concerns were not expressed. Coordination is ongoing.
the affected lands.
Public Lands Policy Coordination Office/ Coordinated with as Letters transmitting the preliminary list of parcels were sent on July 2, 2019.
Utah Division of Wildlife Resources leasing program partner. An e-mail with GIS shape-files was sent to UDWR on June 24, 2019, with
additional information provided July 23, 2019 to satisfy the requirements of
IM-2012-43.
State Institutional Trust Lands Coordinated with as a A letter transmitting the preliminary list of parcels was sent on July 2, 2019.
Administration potential Stakeholder in Comments or concerns were not expressed.
the affected lands.
State Historic Preservation Office and Consultation as required On [ongoing], a [ongoing] determination was mailed to the SHPO. On
Consulting Parties by NHPA (16 USC 470) [ongoing] SHPO concurrence was received. Coordination is ongoing.
Various Tribal Governments (see section Consultation as required On July 25, 2019, UTSO sent an invitation to consult letter to each tribe. No
4.2.2) by the American Indian tribes have responded to the invitation to consult. Coordination and
Religious Freedom Act consultation will continue up until the lease auction, at the request of any tribe.
of 1978 (42 USC 1996)
and NHPA (16 USC
470)
59
August 2019
4.3 Public Participation

Scoping Period
The UTSO sent letters/memorandum to the following stakeholders: the National Park Service (NPS), the
United States Fish and Wildlife Service (USFWS), the United States Forest Service (USFS) and the State
of Utah’s Public Lands Policy Coordination Office (PLPCO), Division of Wildlife Resources (UDWR)
and the School Institutional Trust Lands Administration (SITLA) to notify them of the pending lease sale,
solicit comments and concerns on the preliminary parcel list. The BLM also provided GIS shapefiles
depicting the proposed sale parcels to contact points within the NPS and UDWR. Consultation and
coordination efforts are summarized in Table 23.
Comment Period
As introduced in Section 1.2, the preliminary EA and the unsigned Finding of No Significant Impact
(FONSI) were posted and made available for a 30-day public review and comment period on May 30,
2019. This announced the 30-day comment period (08/29/2019-09/30/2019) for this lease sale. The
documents were made available online at the Utah State Office’s Oil and Gas Leasing Webpage and the
BLM’s NEPA Register.
Section 4.3.1 will identify changes to this EA that were made as a result of public comments and internal
review. Comments and BLM’s responses to each of the comment letters will be shown in Appendix H
[Reserved].
NHPA Coordination
The BLM utilized and coordinated the NEPA public participation requirements to assist the agency in
satisfying the public involvement requirements under Section 106 of the National Historic Preservation
Act (NHPA) [16 U.S.C. 470(f) pursuant to 36 CFR 800.2(d)(3)]. The information about historic and
cultural resources within the area potentially affected by the proposed project/action/approval will assist
the BLM in identifying and evaluating impacts to such resources in the context of both NEPA and Section
106 of the NHPA. The BLM will consult with Indian tribes on a government-to-government basis in
accordance with Executive Order 13175 and other policies, if requested by any Tribe. If Tribal concerns
are identified, including impacts on Indian trust assets and potential impacts to cultural resources, they
will be given due consideration.
BLM will also provide a copy of the draft cultural report [ongoing] to individuals and/or organizations
who participated as a Consulting Party.
4.3.1 Modifications Based on Public Comment and Internal Review [Reserved]
The public comment period and corresponding internal review identified necessary corrections or
clarifications to this EA [Reserved].
4.4 Preparers
An IDPRT prepared the document and analyzed the impact of the proposed action upon the various
resources (Table 24). They considered the affected environment and documented their determination in
the IDPRT Checklist (Appendix D – Interdisciplinary Parcel Review Team Checklist). Only those
resources that would likely be impacted were carried forward into the body of the EA for further analysis.
60
August 2019
Table 24. Preparers of This EA.
Name Title Responsible for the Following Section(s) of this
Document
Leah Waldner Natural Resource Project Lead, Oil and Gas Leasing Program Coordinator
Specialist
Glenn Stelter Archaeologist Oil and Gas Leasing Program, NHPA Compliance
Karen Cathey Natural Resource Oil and Gas Leasing Program, USFWS Consultation
Specialist
Angela Wadman Natural Resource Oil and Gas Leasing Program, NEPA Compliance
Specialist
Sheri Wysong Natural Resource Oil and Gas Leasing Program, NLCS and Recreation
Specialist
Ann Marie Aubry Hydrologist Oil and Gas Leasing Program
Aaron Roe Botanist Oil and Gas Leasing Program, USFWS Consultation
Erik Vernon Air Quality Specialist Oil and Gas Leasing Program, Air Quality; Greenhouse
Gases.
Robin Naeve Fluid Minerals Branch Oil and Gas Leasing Program Review and Oversight
Chief
All specialists that reviewed the parcels are identified in Appendix D – Interdisciplinary Parcel Review
Team Checklist.
61
August 2019
Chapter 5 References
APCD. 2017. "Colorado Air Pollution Control Division, Department of Public Health and
Environment. PS Memo 05-01." State of Colorado.
https://www.colorado.gov/pacific/sites/default/files/AP_Memo-05-01-Oil-and-Gas-
Condensate-Tank-Batteries-Guidance.pdf.
BLM. 2019. "2018 BLM Utah Air Monitoring Report." https://go.usa.gov/xmDkx.
—. 2015. "Air Resource Management Program Strategy 2015-2020 ." Bureau of Land
Management. February. Accessed August 17, 2018.
https://www.blm.gov/sites/blm.gov/files/AirResourceProgramStrategy.pdf.
BLM. 2008. "Biological Opinion for BLM Monticello Field Office RMP." West Valley City,
UT. https://eplanning.blm.gov/epl-front-
office/projects/lup/68097/85495/102695/Monticello_Biological_Opinion.pdf.
—. 2008. Biological Opinion for BLM RMP, Moab Field Office. Moab: USFWS.
https://eplanning.blm.gov/epl-front-
office/projects/lup/66098/80423/93492/Moab_Biological_Opinion.pdf.
—. 2008. Biological Opinion for the Richfield BLM RMP. Richfield, Utah.
office/projects/lup/68293/86879/104136/Richfield_Biological_Opinion.pdf.
—. 2008. BLM Monticello Field Office Record of Decision and Approved RMP (UT-090-2007-
40). Monticello, Utah. https://eplanning.blm.gov/epl-front-
office/projects/lup/68097/85493/102694/Monticello_Final_Plan.pdf.
BLM. 2009. "Canyons of the Ancients National Monument Proposed Resource Management
Plan and Final Environmental Impact Statement."
BLM. 2019. December 2019 Lease Sale Cultural Resources Report (DRAFT). Cultural report,
Salt Lake City: Utah State Office.
BLM. 2019. "December 2019 Lease Sale Cultural Resources Report (Utah SHPO Case No.
U19BL0485)." Salt Lake City, Utah.
BLM. 2007. Final Vegetation Treatments Using Herbicides Programmatic Environmental
Impact Statement and Record of Decision. Washingtion, D.C., September.
office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentP
ageId=103592.
—. 2018. "Grand Staircase Escalante National Monument and Kanab Field Office Resource
Management Plan Draft Environmental Impact Statement." August.
office/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite&
projectId=94706&dctmId=0b0003e881033dcd.
—. 2019. "Grand Staircase Escalanten National Monument and Kanab Field Office Resource
Management Plan Final Environemental Impact Statment." August.
62
August 2019
projectId=94706&dctmId=0b0003e881033dcd.
BLM. 2016. "MLP Biological Opinion: Conclusion of Formal Consultation for the Proposed
Moab MLP Plan." West Valley. https://eplanning.blm.gov/epl-front-
office/projects/lup/68430/144188/177752/MLP_Biological_Opinion.pdf.
—. 2008. Moab Field Office Record of Decision and Approved RMP. Moab.
office/projects/lup/66098/80422/93491/Moab_Final_Plan.pdf.
—. 2008. Moab Field Office RMP and Final EIS. Moab: Moab Field Office.
ageId=94940.
—. 2016. "Moab Master Leasing Plan and Proposed Resource Management Plan
Amendments/Final Environmental Impact Statement." July.
projectId=68430&dctmId=0b0003e880d9ffc7.
—. 2016. Moab Master Leasing Plan and Proposed RMP Amendments/FEIS for Moab and
Monticello Field Offices (DOI-BLM-UT-Y010-2012-0107-EIS). Moab, Utah.
ageId=99718.
—. 2005. Moab RMP Reasonably Foreseeable Development Scenario for Oil and Gas. Moab,
Utah. https://eplanning.blm.gov/epl-front-
office/projects/lup/66098/80928/94437/MoabFinalRFDwithMaps.pdf.
—. 2008. Monticello Field Office Proposed RMP and FEIS. Monticello: Monticello Field Office.
https://eplanning.blm.gov/epl-front-office/projects/lup/68097/85623/102818/RMP.pdf.
—. 2005. Monticello Reasonable Foreseeable Development Scenario (RFD) For Oil and Gas.
Monticello, Utah. https://eplanning.blm.gov/epl-front-
office/projects/lup/68097/85828/103015/RFD.pdf.
BLM. 2017. Monticello RMP Land Use Amendment/Maintence Change No. 102. Monticello,
July 24. https://eplanning.blm.gov/epl-front-
office/projects/lup/68097/144192/177756/Monticello_RMP_Maintenance_102.pdf.
—. 2016. "Monument Butte Oil and Gas Development Project Final Enivronmental Impact
Statement." 06. https://eplanning.blm.gov/epl-front-
projectId=62904&dctmId=0b0003e880ba28f6.
—. 2015. Oil and Gas Reasonably Foreseeable Development Scenario For Greater Sage-Grouse
Occupied Habitat in Utah Sub-Region (Appendix R). Salt Lake City, Utah: Bureau of
Land Management. Accessed 2019. https://eplanning.blm.gov/epl-front-
office/projects/lup/68351/93525/112633/Vol4FluidRFD.pdf.
63
August 2019
BLM. 2008. Price Field Office Proposed Resource Management Plan and Final Environmental
Statement. Price Field Office. https://eplanning.blm.gov/epl-front-
ageId=96976.
BLM. 2008. Price Field Office Record of Decision and Approved Resource Management Plan.
October: Price Field Office. https://eplanning.blm.gov/epl-front-
office/projects/lup/67041/83197/99802/Price_Final_Plan.pdf.
BLM. 2008. Proposed Resource Managment Plan and Final Environmental Impact Statement
for the Price Field Office. Bureau of Land Management.
—. 2012. Reasonably Foreseeable Development Scenario for Oil and Gas in the Moab MLP
Area, Canyon Country District. Moab, Utah: Bureau of Land Management.
office/projects/lup/68430/88315/105655/MLP_OG_RFD_final_091012_508_web.pdf.
—. 2015. Record of Decision and Approved Resource Management Plan Amendments for the
Great Basin Region, Including the Greater Sage-Grouse Sub-Regions of Idaho and
Southwestern Montana Nevada and Northeastern California Oregon Utah. Washington,
DC. https://eplanning.blm.gov/epl-front-
ageId=99422.
Southwestern Montana, Nevada and Northeastern California, Oregon, and Utah. Bureau
of Land Management, Washington, DC. https://eplanning.blm.gov/epl-front-
office/projects/lup/68351/87599/104855/GB_ROD_9.21.15_508_lowres.pdf.
Southwestern Montana, Nevada and Northeastern California, Oregon, and Utah. Plans
for Casper, Kemmere, Newcastle, Pinedale, Rawlins, and Rock Springs Field Offices:
Bureau of Land Management, Wyoming State Office.
—. 2008. Record of Decision and Approved RMP for Richfield RMP (UT-050-2007-090-EIS).
Richfield: Richfield Field Office. https://eplanning.blm.gov/epl-front-
office/projects/lup/68293/86880/104137/Richfield_Final_Plan.pdf.
—. 2016. Record of Decision and Moab MLP Approved RMP Amendments for Moab and
Monticello Field Offices (DOI-BLM-UT-y010-2012-0107-EIS). Moab, Utah: Bureau of
Land Management. https://eplanning.blm.gov/epl-front-
ageId=99718.
—. 2019. Record of Decision for Utah Greater Sage-Grouse RMP/FEIS.
office/projects/lup/103346/168792/205436/2019_ROD_and_Utah_Approved_GRSG_R
MPA_FINAL_03-14-2019.pdf.
64
August 2019
—. 2008. Richfield RMP/FEIS (BLM-UT-050-2007-090-EIS). Richfield, Utah.
ageId=99311.
—. 2005. Richfield Field Office Reasonable Foreseeable Development Scenario For Oil and
Gas. Richfield, Utah: Bureau of Land Management. Accessed May 2019.
office/projects/lup/68293/87520/104777/RFOOilGasRFD.pdf.
BLM. 2019. "Specialist Report on GHG Analysis for BLM Utah Oil and Gas Leasing."
—. 2007. "Surface Operating Standards and Guideline for Oil and Gas Exploration and
Development. The Gold Book, Fourth Edition." Denver, Colorado: BLM/WO/ST-
06/021+3071/REV 07. Bureau of Land Management. 84pp.
https://www.blm.gov/sites/blm.gov/files/uploads/The%20Gold%20Book%20-
%204th%20Ed%20-%20Revised%202007.pdf.
—. 2018. "Telephone Call Record. Hydraulic Fracking and Seismic Activity in Utah." March.
—. 2018. "Utah Air Resource Management Strategy (ARMS)." Bureau of Land Management.
Accessed April 23, 2019. https://go.usa.gov/xmDkx.
BLM. 2014. Utah Air Resource Management Strategy Modeling Project Impact Assessment
Report. Modeling Project, Fort Collins: AECOM. Accessed August 2018.
https://www.blm.gov/sites/blm.gov/files/program_natural%20resources_soil%20air%20
water_airut_quick%20links_ImpactsRpt.pdf.
—. 2018. "Utah Greater Sage-Grouse Draft Land Use Plan Amendment and FInal EIS." Bureau
of Land Management. December. Accessed March 17, 2018.
ageId=99422.
BLM. 2008. Vernal Field Office Record of Decision and Approved Resource Management Plan.
Vernal, Utah: Bureau of Land Management. https://eplanning.blm.gov/epl-front-
office/projects/lup/68145/86218/103392/VernalFinalPlan.pdf.
BLM. 2008. Vernal Field Office Resource Management Plan and Final Impact Statement.
Vernal: Vernal Field Office. https://eplanning.blm.gov/epl-front-
ageId=98982.
BLM. 2017. Vernal Planning Area Invasive Weed Management Plan (DOI-BLM-UT-G010-
2016-0011-EA). Vernal, May. https://eplanning.blm.gov/epl-front-
ageId=71127.
BLM, Forest Service. 2015. Utah Greater Sage-Grouse Proposed Land Use Plan Amendment
and Final EIS. USDI Bureau of Land Management and USDA Forest Service.
ageId=99423.
65
August 2019
Bryce, S.A., J.R. Strittholt, B.C. Ward, and D.M. Bachelet. 2012. "Colorado Plateau Rapid
Ecoregional Assessment Report. Prepared for the U.S. DOI."
https://landscape.blm.gov/REA_General_Docs/COP_Final_Report_Body.pdf.
Comer, P., P. Crist, M. Reid, J. Hak, H. Hamilton, D. Braun, G. Kittel, I. Varley,. 2013. "Central
Basin and Range Rapid Ecoregional Assessment Report."
https://landscape.blm.gov/REA_General_Docs/CBR_1_ReportBody.pdf.
Council, National Research. 2010. "Informing an Effective Response to Climate Change."
http://nap.edu/12784.
Duniway et. al. 2019. "Wind Errosion and dust from US drylands: a review of causes,
consequences, and solutions in a changing world." Ecosphere 28.
EPA. 2019. 2014 National Air Toxics Assessment. Accessed 5 23, 2019.
https://gispub.epa.gov/NATA/.
—. 1995. "AP-42: Compilation of Air Emissions Factors." United States Environmental
Protection Agency. https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-
compilation-air-emissions-factors#5thed.
—. 2018. Facility Level Information on GreenHouse Gases Tool (FLIGHT).
https://ghgdata.epa.gov/ghgp/main.do.
—. 2019. Greenhouse Gases Equivalencies Calculator - Calculations and References.
https://www.epa.gov/energy/greenhouse-gases-equivalencies-calculator-calculations-and-
references.
—. 2019. "Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2017." 5 6.
https://www.epa.gov/sites/production/files/2019-04/documents/us-ghg-inventory-2019-
main-text.pdf.
—. 2018. Overview of Greenhouse Gases. Accessed August 16, 2018.
https://www.epa.gov/ghgemissions/overview-greenhouse-gases.
—. 2017. "Ozone Designations - 2015 Standards - Utah State Recommendations and EPA
Response." United States Environmental Protection Agency. December 20.
https://www.epa.gov/sites/production/files/2017-12/documents/ut-epa-resp-ozone.pdf.
GAO. 2008. "Oil and Gas Leasing: Interior Could Do More to Encourage Diligent
Development." https://www.gao.gov/new.items/d0974.pdf.
Golder. 2010. Cane Creek Air Quality Impact Assessment (letter submitted to the BLM and
NPS). Fort Collins, CO: Golder Associates Inc.
Janssens-Maenhout, G., M. Crippa, D. Guizzardi, M. Muntean, E. Schaaf, J.G.J Olivier, J.A.H.W
Peters, and K.M. Schure. 2017. Fossil CO2 and GHG Emissions of All World Countries.
Luxembourg: Publications Office of the European Union. doi:10.2760/709792.
Jepsen, S., D.F. Schweitzer, B. Young, N. Sears, M. Ormes and S.H. Black. 2015. "Conservation
Status and Ecology of Monarchs in the United States." (NatureServe) 36 pp.
Natureserve. 2019. NatureServe Explorer. An online encyclopedia of life [web application].
Version 7.0. Arlington, VA: NatureServe. http://explorer.natureserve.org.
66
August 2019
Rubinstein, Justin and Alireaza Babaie Mahani. 2015. Myths and Facts on Waste Water
Injection, Hydraulic Fracturing, Enhanced Oil Recovery, and Induced Seismicity. Vols.
Volume 86, Number 4. Sesimological Research Letters, July/August.
https://scits.stanford.edu/sites/default/files/isfc_2_rubenstein_pap_srl-2015067.pdf.
State of Utah. 2018. State of Utah Resource Managment Plan. Salt Lake City, Utah: State of
Utah. Accessed August 2018. http://publiclands.utah.gov/current-projects/rmp/.
Strategies, Center for Climate. 2007. "Utah Greenhouse Gas Inventory and Reference Case
Projections, 1990-220." http://www.climatestrategies.us/policy_tracker/policy/index/45.
UDAQ. 2018. "2014 Statewide Emissions Inventories."
https://deq.utah.gov/legacy/programs/air-quality/emissions-inventories/inventories/2014-
state-list.htm.
UDOGM. 2018. Utah Oil and Gas Monthly Production Reports by County.
https://oilgas.ogm.utah.gov/oilgasweb/publications/monthly-rpts-by-
cnty.xhtml?rptType=CNTY.
UDWR. 2005. Biotics Database. Utah Division of Wildlife Resources, NatureServe, and the
network of Natural Heritage Programs and Conservation Data Centers. Accessed July 17,
2019.
United States Congress. 2019. "Excerpt from the John D. Dingell, Jr. Conservation,
Management, and Recreation Act." 03 12.
United States Department of the Interior and United States Department of Agriculture. 2007.
Surface Operating Standards and Guidelines for Oil and Gas Exploration and
Development. BLM/WO/ST-06/021+307/REV 07. . Denver, Colorado: Bureau of Land
Management.
UNPS. 2015. "Navajo Sedge." Accessed July 17, 2019. https://www.nps.gov/articles/navajo-
sedge.htm.
USDAFS. 2013. "Record of Decision and Final Environemental Impact Statement, Fishlake
National Forest Oil and Gas Leasing Analysis."
USDI and USDA. 2007. "The Gold Book." Vers. Fourth Edition - Revised 2007. Bureau of Land
Management. Accessed August 29, 2018. https://www.blm.gov/programs/energy-and-
minerals/oil-and-gas/operations-and-production/the-gold-book.
USFWS. 2008. Biological Opinion for BLM Resource Management Plan, Price Field Office.
West Valley City: USFWS. https://eplanning.blm.gov/epl-front-
office/projects/lup/67041/83196/99801/Price_Biological_Opinion.pdf.
USFWS. 2008. Biological Opinion For BLM Resource Management Plan, Vernal Field Office.
West Valley City: USFWS. https://eplanning.blm.gov/epl-front-
office/projects/lup/68145/86216/103391/VernalBiologicalOpinion.pdf.
USGCRP. 2018. "Impacts, Risks, and Adaptation in the United States: Fourth National Climate
[Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K."
Washington, DS, USA: U.S. Global Change Research Program.
67
August 2019
USGS. 2018. "Federal lands greenhouse emissions and sequestration in the United States—
Estimates for 2005–14: Merrill, M.D., Sleeter, B.M., Freeman, P.A., Liu, J., Warwick,
P.D., and Reed, B.C."
—. 2019. National Climate Change Viewer . Accessed 05 22, 2019.
https://www2.usgs.gov/landresources/lcs/nccv/viewer.asp.
WRAP. 2013. "West-wide Jumpstart Air Quality Modeling Studay, Final Project Report and
Modeling Results." Accessed 05 24, 2019.
https://www.wrapair2.org/pdf/WestJumpAQMS_Model_Results_UT_April16_2014.pdf.
68
August 2019
Chapter 6 Appendices
A. Parcel List with Stipulations and Notices

B. Stipulations and Notices
C. Figures (Maps)
D. Interdisciplinary Parcel Review Team Checklist
E. Air Quality and Green House Gas Information and Calculations
F. Acronyms/Abbreviations
G. Reasonable Foreseeable Development Scenario
H. Comments and Responses
69
August 2019
Appendix A – Parcel List with Stipulations and Notices

In addition to the parcel specific Stipulations and Notices listed below, the stipulations and notices
presented in this table would be applied to ALL parcels:
Stipulations Notices
Cultural Resources Protection (Handbook H- Notice to Lessee (MLA)
3120-1)
Threatened & Endangered Species Act
(Handbook H-3120-1)
UT1219 – 002
T. 21 S., R 1 E., Salt Lake Meridian
Sec. 19: Lots 5-7, 9;
Sec. 20: NWNW.
203.57 Acres
Sevier County, Utah
STIPULATIONS
UT-S-102: CSU- Fragile Soils/Slopes 30 Percent or Greater
UT-S-221: CSU/TL - Utah Prairie Dog
UT-S-233: TL - Crucial Mule Deer and Elk Winter Habitat
UT-S-276: CSU/TL Bald Eagles
UT-S-293: CSU/TL - California Condor
NOTICES
T&E-09: Utah Prairie Dog
T&E-11: California Condor
T&E-19: Jones Cycladenia (Cycladenia hymilis var jonsii)
UT-LN-11: Crucial Elk Calving and Deer Fawning Habitat
UT-LN-44: Raptors
UT-LN-45: Migratory Bird
UT-LN-49: Utah Sensitive Species
UT-LN-52: Noxious Weed
UT-LN-96: Air Quality Mitigation Measures
UT-LN-99: Regional Ozone Formation Controls
UT-LN-101: Air Quality
UT-LN-102: Air Quality Analysis
UT-LN-107: Bald Eagle
UT-LN-128: Floodplain Management
UT-LN-156: Pollinators and Pollinator Habitat
UT1219 – 003
Sec. 20: Lots 1-12;
Sec. 21: All;
Sec. 22: NE, W2;
70
August 2019
Sec. 28: NE, W2;

Sec. 29: Lots 1 and 2, NE, E2NW.
2443.10 Acres
Sevier County, Utah
STIPULATIONS
UT-S-293: CSU/TL - California Condor
NOTICES
T&E 11: California Condor
T&E-19: Jones Cycladenia (Cycladenia hymilis var jonsii)
UT-LN-44: Raptors
UT1219 – 004
Sec. 14: SWNW, N2SW, SWSW;
Sec. 15: SENE, NESE;
Sec. 23: NWNW.
280.00 Acres
Sanpete County, Utah
STIPULATIONS
NOTICES
UT-LN-44: Raptors
71
August 2019

UT1219 – 005
Sec. 34: E2NE, E2SE;
Sec. 35: W2NW, W2SW.
320.00 Acres
STIPULATIONS
NOTICES
UT-LN-44: Raptors
UT1219 – 006
Sec. 7: Lots 3 and 4, E2SW.
188.15 Acres
STIPULATIONS
72
August 2019
NOTICES
UT-LN-44: Raptors
UT1219 – 007
Sec. 15: W2SW.
80.00 Acres
STIPULATIONS
NOTICES
UT-LN-44: Raptors
UT1219 – 008
Sec. 35: W2NW, S2.
400.00 Acres
73
August 2019
STIPULATIONS
NOTICES
UT-LN-44: Raptors
UT1219 – 009
Sec. 6: All;
Sec. 7: All.
1268.00 Acres
Emery County, Utah
Price Field Office
STIPULATIONS
UT-S-127: NSO – Intermittent and Perennial Streams
UT-S-260: TL – Raptor Habitat
UT-S-285: TL-Migratory Bird Nesting
UT-S-293: CSU/TL – California Condor
UT-S-305: CSU – Noxious Weed
NOTICES
T&E-05: Listed Plant Species
T&E-13: Barneby Reed Mustard (Schoenocrambe Barnebyi)
T&E-14: Last Chance Townsendia (Townsendia aprica)
T&E-15: Wright Fishhook Cactus (Sclerocactus Wrightii)
T&E-16: Winkler Pincushion Cactus (Pediocactus winkleri)
T&E-17: San Rafael Cactus (Pediocactus Despainii)
T&E-19: Jones Cycladenia (Cycladenia Hymilis Var Jonesii)
UT-LN-44: Raptors
74
August 2019

UT-LN-51: Special Status Plants: Not Federally Listed
UT-LN-79: NPS Roads
UT1219 – 010
Sec. 4: All;
Sec. 5: All;
Sec. 8: N2;
Sec. 9: NWNW.
1686.00 Acres
Emery County, Utah
Price Field Office
STIPULATIONS
UT-S-285: TL-Migratory Bird Nesting
NOTICES
T&E-13: Barneby Reed Mustard (Schoenocrambe Barnebyi)
T&E-14: Last Chance Townsendia (Townsendia aprica)
T&E-15: Wright Fishhook Cactus (Sclerocactus Wrightii)
T&E-16: Winkler Pincushion Cactus (Pediocactus winkleri)
T&E-19: Jones Cycladenia (Cycladenia Hymilis Var Jonesii)
UT-LN-44: Raptors
UT-LN-79: NPS Roads
UT-LN-83: Site ROW
75
August 2019

UT-LN-157: San Rafael Swell SRMA
UT1219 – 014
Sec. 27: N2NE, N2NW, SENW, excepting ROW UTU79642.
193.11 Acres
Carbon County, Utah
Price Field Office
STIPULATIONS
UT-S-176: CSU– Fossil Resources (Preconstruction Surveys)
UT-S-177: CSU– Fossil Resources
UT-S-232: TL – Mule Deer and Elk Crucial Winter Range
UT-S-257: TL- Moose Winter Range
UT-S-285: TL - Migratory Bird Nesting
NOTICES
T&E-06: Mexican Spotted Owl
T&E-23: Colorado River Endangered Fish
UT-LN-44: Raptors
UT-LN-72: High Potential Paleontological Resources
UT-LN-83: Site ROW
UT1219 – 017
Sec. 34: S2SE.
80.00 Acres
Carbon County, Utah
Price Field Office
STIPULATIONS
UT-S-176: CSU– Fossil Resources (Preconstruction Surveys)
UT-S-177: CSU– Fossil Resources
76
August 2019
UT-S-232: TL – Mule Deer and Elk Crucial Winter Range

UT-S-257: TL- Moose Winter Range
UT-S-285: TL – Migratory Bird Nesting
NOTICES
UT-LN-44: Raptors
UT1219 – 022
Sec. 25: NWNE.
40.00 Acres
Carbon County, Utah
Price Field Office
STIPULATIONS
UT-S-285: TL – Migratory Bird Nesting
NOTICES
UT-LN-25: White-Tailed and Gunnison prairie Dog
UT-LN-44: Raptors
UT-LN-104: Burrowing Owl Habitat
77
August 2019
UT1219 – 024
Sec. 7: Lots 3 and 4.
73.39 Acres
Grand County, Utah
Moab Field Office
STIPULATIONS
UT-S-358: Air Quality and Greenhouse Gases
UT-S-359: Air Quality I
UT-S-360: Air Quality II
UT-S-364: CSU – Filming Locations
UT-S-370: CSU – Paleontology
UT-S-376: CSU-Canyon Rims, Labyrinth Rims/Gemini Bridges and South Moab
UT-S-384: CSU - Steep Slopes
UT-S-386: NSO – Water Resources
UT-S-387: NSO – Ephemeral Streams
UT-S-407: NSO – Visual Resources-Rimlands of the Green and Colorado Rivers
NOTICES
T&E-28: California Condor – Potential Habitat
T&E-29: Jones Cycladenia – Potential, Suitable, and Occupied Habitat
UT-LN-52: Noxious Weeds
UT-LN-70: High Potential for Cultural Resource Occurrence
UT-LN-125 – Light and Sound – Sensitive Resources
UT-LN-137: Cultural Resources I
UT-LN-138: Cultural Resources II
UT-LN-139: Cultural Resources – High Potential for Cultural Sites
UT-LN-143: Raptors
UT-LN-144: Migratory Birds
UT-LN-147: Kit Fox Habitat
78
August 2019
UT1219 – 025
Sec. 21: W2.
320.00 Acres
Grand County, Utah
Moab Field Office
STIPULATIONS
UT-S-54: NSO – Developed Recreation Sites
UT-S-358: Air Quality and Greenhouse Gases
UT-S-359: Air Quality I
UT-S-360: Air Quality II
UT-S-364: CSU – Filming Locations
UT-S-371: NSO – Developed Recreation Sites
UT-S-376: CSU-Canyon Rims, Labyrinth Rims/Gemini Bridges and South Moab
UT-S-384: CSU - Steep Slopes
UT-S-386: NSO – Water Resources
UT-S-387: NSO – Ephemeral Streams
NOTICES
T&E-28: California Condor – Potential Habitat
T&E-29: Jones Cycladenia – Potential, Suitable, and Occupied Habitat
UT-LN-53: Riparian Areas
UT-LN-83: Site ROW
UT-LN -125: Light and Sound – Sensitive Resources
UT-LN-137: Cultural Resources I
UT-LN-138: Cultural Resources II
UT-LN-139: Cultural Resources – High Potential for Cultural Sites
UT-LN-143: Raptors
UT-LN-144: Migratory Birds
UT-LN-147: Kit Fox Habitat
UT1219 – 026
Sec. 6: Lots 3-7, SENW, E2SW.
310.62 Acres
Uintah County, Utah
79
August 2019
Vernal Field Office
STIPULATIONS
UT-S-96: NSO – Fragile Soils/Slopes Greater Than 40%
UT-S-99: CSU – Fragile Soils/Slopes
UT-S-100: CSU – Fragile Soils/Slopes (21%-40%)
UT-S-157: NSO/CSU/TL – Visual Resources
UT-S-159: CSU – Visual Resources – VRM II
UT-S-231: CSU – Crucial Deer Winter Range
UT-S-247: TL – Crucial Elk Calving and Deer Fawning Habitat
UT-S-261: TL – Raptor Buffers
UT-S-278: CSU – Bald Eagle Winter Roost
NOTICES
T&E-03: Endangered Fish of the Upper Colorado River Drainage Basin
T&E-12: Pariette Cactus [Sclerocactus brevispinus] and Uinta Basin hookless cactus [Sclerocactus
glaucus (brevispinus and wetlandicus)]
T&E-20: Clay Reed - Mustard (Schoencrambe Argillacea)
T&E-31: Western Yellow-billed Cuckoo
UT-LN-13: Pronghorn Winter Habitat
UT-LN-14: Pronghorn Fawning Habitat
UT-LN-20: Rocky Mountain/Desert Bighorn Sheep Crucial Lambing and Rutting Habitat
UT-LN-44: Raptors
UT-LN-83: Site ROW
UT-LN-90: Graham’s Beardtongue (Penstemon grahamii)
UT-LN-134: Graham’s Beardtongue (Penstemon grahamii) and White River Beardtongue (P. scariosus
var. albifluvis) Conservation Area
UT1219 – 027
Sec. 18: All.
623.52 Acres
San Juan County, Utah
STIPULATIONS
UT-S-01: Air Quality
UT-S-98: NSO – Fragile Soils/Slopes Greater than 40 Percent
80
August 2019
UT-S-106: CSU – Fragile Soils/Slopes 21-40 Percent

UT-S-128: NSO – Floodplains, Riparian Areas, Springs, and Public Water Reserves
UT-S-170: CSU – Cultural
UT-S-182: NSO – Critical Habitat of the Endangered Colorado River Fishes
UT-S-234: TL – Crucial Deer Winter Range
UT-S-288: CSU/TL – Mexican Spotted Owl
UT-S-290: CSU/TL – Southwestern Willow Flycatcher
UT-S-297: CSU/TL – Yellow-billed Cuckoo
NOTICES
T&E-07: Southwestern Willow Flycatcher
UT-LN-25: White-Tailed and Gunnison Prairie Dog
UT-LN-44: Raptors
UT-LN-113: Western Yellow-Billed Cuckoo
UT-LN-125: Light and Sound – Sensitive Resources
UT1219 – 028
Sec. 31: All.
619.68 Acres
STIPULATIONS
NOTICES
81
August 2019
UT-LN-44: Raptors
UT1219 – 029
Sec. 33: W2NE, SENE, W2, SE.
600.00 Acres
STIPULATIONS
UT-S-275: CSU/TL – Bald Eagles
NOTICES
UT-LN-44: Raptors
82
August 2019
UT1219 – 030
Sec. 7: All;
Sec. 8: All;
Sec. 9: NW, S2;
Sec. 18: Lots 1 and 2, NE, E2NW.
2053.06 Acres
STIPULATIONS
UT-S-290: CSU/TL – Southwestern Willow Flycatcher
UT-S-297: CSU/TL – Yellow-billed Cuckoo
NOTICES
T&E-07: Southwestern Willow Flycatcher
UT-LN-44: Raptors
UT-LN-113: Western Yellow-Billed Cuckoo
UT1219 – 031
Sec. 15: E2.
320.00 Acres
83
August 2019
STIPULATIONS
UT-S-98: NSO – Fragile Soils/Slopes Greater than 40 Percent
NOTICES
UT-LN-44: Raptors
UT1219 – 032
Sec. 17: E2.
320.00 Acres
STIPULATIONS
84
August 2019
NOTICES
UT-LN-44: Raptors
UT1219 – 033
Sec. 30: SENE.
40.00 Acres
STIPULATIONS
NOTICES
T&E-06 Mexican Spotted Owl
UT-LN-44: Raptors
85
August 2019
UT1219 – 034
Sec. 26: W2.
320.00 Acres
STIPULATIONS
NOTICES
UT-LN-44: Raptors
UT1219 – 035
Sec. 15: All.
640.00 Acres
STIPULATIONS
86
August 2019

NOTICES
UT-LN-44: Raptors
87
August 2019
Appendix B – Stipulations and Notices

Stipulation Summary Table
NUMBER UTAH STIPULATIONS
AIR QUALITY
All new and replacement internal combustion gas field engines of less than or equal to 300 design-rated horsepower shall not
emit more than 2 grams of NOx per horsepower-hour.
Exception: This requirement does not apply to gas field engines of less than or equal to 40 design-rated horsepower.
UT-S-01 Modification: None
2008 RMPs Only Waiver: None
(Outside of AND
Moab MLP) All new and replacement internal combustion gas field engines of greater than 300 design rated horsepower must not emit
more than 1.0 gram of NOx per horsepower-hour.
Exception: None
Modification: None
Waiver: None
NO SURFACE OCCUPANCY – DEVELOPED RECREATION SITES
No surface-disturbing activities are allowed within 0.5 miles of developed recreation sites (current and planned as Potential
UT-S-54 Future Facilities).
Exception: An exception could be granted if a viewshed analysis indicates no impairment of the visual resources from the
Moab
recreation site. Also, an exception could be authorized if the use is consistent and compatible with protection or enhancement
(Outside the of the resource values or the use would provide suitable opportunities for public enjoyment of the applicable resources. No
MLP) exception for oil and gas leasing.
Modification: None
Waiver: None
NO SURFACE OCCUPANCY – FRAGILE SOILS/SLOPES GREATER THAN 40%
UT-S-96 No surface occupancy for slopes greater than 40 percent.
Exception: If after an environment analysis the authorized officer determines that it would cause undue or unnecessary
Vernal degradation to pursue other placement alternatives; surface occupancy in the NSO area may be authorized. Additionally a
plan shall be submitted by the operator and approved by BLM prior to construction and maintenance and include:
88
August 2019

• An erosion control strategy;
• GIS modeling;
• Proper survey and design by a certified engineer.
Modification: Modifications also may be granted if a more detailed analysis, i.e. Order I, soil survey conducted by a
qualified soil scientist finds that surface disturbance activities could occur on slopes greater than 40% while adequately
protecting the area from accelerated erosion.
Waiver: None
NO SURFACE OCCUPANCY – FRAGILE SOILS/SLOPES GREATER THAN 40 PERCENT
No new surface-disturbing activities allowed on slopes greater than 40% to protect soils, avoid erosion, and maintain public
UT-S-98 health and safety in sloped embankments.
Monticello Exception: If after an analysis the authorized officer determines that it would cause undue or unnecessary degradation to
(Outside of pursue other placement alternatives; surface occupancy in the NSO may be authorized. Additionally, a plan would be
MLP) submitted by the operator and approved by BLM prior to construction and maintenance.
Modification: None
Waiver: None
CONTROLLED SURFACE USE – FRAGILE SOILS/SLOPES
The surface operating standards for oil and gas exploration and development (Gold Book) shall be used as a guide for
UT-S-99 surface-disturbing proposals on steep slopes/hillsides.
Vernal Exception: None
Modification: None
Waiver: None
CONTROLLED SURFACE USE – FRAGILE SOILS/SLOPES (21%-40%)
If surface-disturbing activities cannot be avoided on slopes from 21-40% a plan will be required. The plan will approved by
BLM prior to construction and maintenance and include:
UT-S-100 • An erosion control strategy;
Vernal • GIS modeling;
• Proper survey and design by a certified engineer.
Exception: None
Modification: None
89
August 2019

Waiver: None
CONTROLLED SURFACE USE – FRAGILE SOILS/SLOPES 30 PERCENT OR GREATER
No surface disturbing proposed projects involving construction on slopes greater than 30. If the action cannot be avoided,
rerouted, or relocated than a proposed project will include an erosion control strategy, reclamation and a site plan with a
UT-S-102 detailed survey and design completed by a certified engineer. This proposed project must be approved by the BLM prior to
Richfield construction and maintenance.
Exception: None
Modification: None
Waiver: None
CONTROLLED SURFACE USE – FRAGILE SOILS/SLOPES 21-40 PERCENT
No new surface disturbance/construction on slopes between 21-40% without a BLM approved site plan that is prepared for
UT-S-106
any surface disturbing or construction activity. This plan would include an erosion control strategy, survey and design, and
Monticello reclamation plan.
(Outside of Exception: None
MLP) Modification: None
Waiver: None
NO SURFACE OCCUPANCY – INTERMITTENT AND PERENNIAL STREAMS
No new surface disturbance (excluding fence lines) will be allowed in areas within the 100-year floodplain or 100 meters
(330 feet) on either side from the centerline, whichever is greater, along all perennial and intermittent streams, streams with
perennial reaches, and riparian areas.
UT-S-127 Exception: The authorized officer could authorize an exception if it could be shown that the project as mitigated eliminated
Price the need for the restriction.
An exception could be authorized if (a) there are no practical alternatives, (b) impacts could be fully mitigated, or (c) the
action is designed to enhance the riparian resources.
Modification: None
Waiver: None
NO SURFACE OCCUPANCY – FLOODPLAINS, RIPARIAN AREAS, SPRINGS, AND PUBLIC WATER
RESERVES
UT-S-128
No surface-disturbing activities are allowed in active floodplains, public water reserves or within 100 meters of riparian areas
along perennial streams and springs.
90
August 2019

Monticello Exception: An exception could be authorized if: (a) there are no practical alternatives, (b) impacts could be fully mitigated,
(Outside of or (c) the action is designed to enhance the riparian resource values.
MLP) Modification: None
Waiver: None
NO SURFACE OCCUPANCY/CONTROLLED SURFACE USE/TIMING LIMITATION – VISUAL RESOURCES
Visual resource management activities will comply with BLM Handbook 8410-1.
Within VRM Class I areas, very limited management activity will be allowed, with the objective of preserving the existing
character of the landscape, allowing for natural ecological changes. The level of change to the landscape should be very low
and shall not attract attention.
Within VRM Class II areas, surface-disturbing activities will retain the existing character of the landscape. The level of
change to the landscape should be low. Management activities may be seen, but should not attract the attention of the casual
observer. Any change to the landscape shall repeat the basic elements of form, line, color and texture found in the
predominant natural features of the characteristic landscape.
UT-S-157
Within VRM Class III areas, surface disturbing activities will partially retain the existing character of the landscape. The
Vernal allowable level of change will be moderate, may attract attention, but should not dominate the view of the casual observer.
Landscape changes should repeat the basic elements of form, line, color and texture found in the predominant natural features
of the characteristic landscape.
Within VRM Class IV areas, surface disturbing activities are allowed to dominate the view and the major focus of viewer
attention. Major modifications to the existing character of the landscape are allowed. But every attempt should be made to
minimize and mitigate the impacts.
Exception: Exempted are recognized utility corridors.
Modification: None
Waiver: None
CONTROLLED SURFACE USE – VISUAL RESOURCES - VRM II
Within VRM II areas, surface-disturbing activities will retain the existing character of the landscape. The level of change to
the landscape should be low. Management activities may be seen, but should not attract attention of the casual observer. Any
UT-S-159 change to the landscape must repeat the basic elements of form, line, color, and texture found in the predominant natural
Vernal features of the characteristic landscape.
Exception: Exempted are recognized utility corridors.
Modification: None
Waiver: None
91
August 2019
CONTROLLED SURFACE USE – CULTURAL

Cultural properties eligible for or listed on the National Register of Historic Places shall be surrounded by an avoidance area
sufficient to avoid impacts. (Although oil and gas activity must also meet this standard, a CSU lease stipulation is not
UT-S-170 necessary since this can be accomplished under the terms of the standard lease form.)
Exceptions: An exception could be granted if the BLM authorized officer determines that avoidance of direct and indirect
Monticello impacts to historic properties is not feasible (e.g. avoidance may cause unacceptable damage to other public land resources or
affect valid existing rights).
Modification: None
Waiver: None
CONTROLLED SURFACE USE – FOSSIL RESOURCES (PRECONSTRUCTION SURVEYS)
Preconstruction paleo surveys will be required prior to any surface disturbing activity in the Morrison, Cedar Mountain,
Blackhawk, North Horn, or Chinle Formations.
UT-S-176
Exception: The authorized officer may grant an exception if the area has previously been inventoried within the last three (3)
Price years.
Modification: None
Waiver: None
CONTROLLED SURFACE USE – FOSSIL RESOURCES
A BLM permitted paleontologist will be required to be onsite during surface disturbance in any Potential Fossil Yield
UT-S-177 Classification (PFYC) 4 or 5 areas.
Price Exceptions: None
Modification: None
Waiver: None
NO SURFACE OCCUPANCY – CRITICAL HABITAT OF THE ENDANGERED COLORADO RIVER FISHES
Surface-disturbing activities will not be allowed within the 100-year floodplain of the Colorado River and San Juan River or
UT-S-182 lands within this watershed that contains tributaries with designated critical habitat for the Colorado River fish (bonytail,
Monticello humpback chub, Colorado pike minnow, and razorback sucker) listed as endangered under the Endangered Species Act.
(Outside of Critical habitat was designated for the four endangered Colorado River fishes on March 21, 1994 (59 FR 13374-13400).
MLP) Designated critical habitat for all the endangered fishes includes those portions of the 100-year floodplain that contain
primary constituent elements necessary for survival of the species. Avoidance or use restrictions may be placed on portions
of the lease. The following avoidance and minimization measures have been designed to ensure activities carried out on the
lease are in compliance with the Endangered Species Act. Integration of, and adherence to these measures will facilitate
92
August 2019

review and analysis of any submitted permits under the authority of this lease. Following these measures could reduce the
scope of Endangered Species Act, Section 7 consultation at the permit stage.
Current avoidance and minimization measures include the following:
1. Surveys will be required prior to operations unless species occupancy and distribution information is complete and
available. All surveys must be conducted by qualified individual(s).
2. Lease activities will require monitoring throughout the duration of the project. To ensure desired results are being
achieved, minimization measures will be evaluated and, if necessary, Section 7 consultation reinitiated.
3. Water production will be managed to ensure maintenance or enhancement of riparian habitat.
4. Avoid loss or disturbance of riparian habitats.
5. Where technically and economically feasible, use directional drilling or multiple wells from the same pad to reduce
surface disturbance and eliminate drilling in suitable riparian habitat. Ensure that such directional drilling does not
intercept or degrade alluvial aquifers.
6. Conduct watershed analysis for leases in designated critical habitat and overlapping major tributaries in order to
determine toxicity risk from permanent facilities.
7. Implement the Utah Oil and Gas Pipeline Crossing Guidance (from BLM National Science and Technology Center).
8. Drilling will not occur within 100-year floodplains of rivers or tributaries to rivers that contain listed fish species or
critical habitat.
9. In areas adjacent to 100-year floodplains, particularly in systems prone to flash floods, analyze the risk for flash floods
to impact facilities, and use closed loop drilling, and pipeline burial or suspension according to the Utah Oil and Gas
Pipeline Crossing Guidance, to minimize the potential for equipment damage and resulting leaks or spills.
Water depletions from any portion of the Upper Colorado River drainage basin above Lake Powell are considered to
adversely affect or adversely modify the critical habitat of the four resident endangered fish species, and must be evaluated
with regard to the criteria described in the Upper Colorado River Endangered Fish Recovery Program. Formal consultation
with USFWS is required for all depletions. All depletion amounts must be reported to BLM.
Additional measures to avoid or minimize effects to the species may be developed and implemented in consultation with the
USFWS between the lease sale stage and lease development stage to ensure continued compliance with the ESA.
Exception: An exception may be granted by the authorized officer if: 1) There is no practical alternative, and 2) The
development would enhance riparian/aquatic values. This exception would require consultation with the USFWS. The
authorized officer may also grant an exception if an environmental analysis indicates that the nature or the conduct of the
actions, as proposed or conditioned, would not impair the primary constituent element determined necessary for the survival
and recovery of the Endangered Colorado River Fishes.
93
August 2019

Modification: The authorized officer may modify the boundaries of the stipulation area if an environmental analysis
indicates, and USFWS (through applicable provisions of the ESA) determines a portion of the area is not being used as
Critical Habitat.
Waiver: A waiver may be granted if the Endangered Colorado River Fishes are de-listed and the Critical Habitat is
determined by USFWS as not necessary for the survival and recovery of the Endangered Colorado River Fishes.
CONTROLLED SURFACE USE/TIMING LIMITATIONS – UTAH PRAIRIE DOG
The Lessee/Operator is given notice that lands in this lease may contain historic and/or occupied Utah prairie dog habitat, a
threatened species under the Endangered Species Act (ESA). Avoidance or use restrictions may be placed on portions of the
lease. Application of appropriate measures will depend on whether the action is temporary or permanent, and whether it
occurs when prairie dogs are active or hibernating. A temporary action is completed prior to the following active season
leaving no permanent structures and resulting in no permanent habitat loss. A permanent action continues for more than one
activity/hibernation season and/or causes a loss of Utah prairie dog habitat or displaces prairie dogs through disturbances
(e.g., creation of a permanent structure). The following avoidance and minimization measures have been designed to ensure
activities carried out on the lease are in compliance with the ESA. Integration of, and adherence to, these measures will
facilitate review and analysis of any submitted permits under the authority of this lease. Following these measures could
reduce the scope of ESA Section 7 consultation at the permit stage.
UT-S-221 1. Surveys will be required prior to operations unless species occupancy and distribution information is complete and
available. All surveys must be conducted by qualified individual(s).
Richfield
2. Lease activities will required monitoring throughout the duration of the project. To ensure desired results are being
surface disturbance and eliminate drilling in prairie dog habitat.
4. Surface occupancy or other surface disturbing activity will be avoided within 0.5 mile of active prairie dog colonies.
5. Permanent surface disturbance or facilities will be avoided within 0.5 mile of potentially suitable, unoccupied prairie
dog habitat, identified and mapped by Utah Division of Wildlife Resources since 1976.
6. The lessee/operator should consider if fencing infrastructure on well pad, e.g., drill pads, tank batteries, and
compressors, would be needed to protect equipment from burrowing activities. In addition, the operator should consider
if future surface disturbing activities would be required at the site.
7. Within occupied habitat, set a 25 mph speed limit on operator-created and maintained roads.
8. Limit disturbances to and within suitable habitat by staying on designated routes.
9. Limit new access routes created by the project.
94
August 2019

Additional measures to avoid or minimize effects to the species may be developed and implemented in consultation with
Exception: None
Modification: None
Waiver: None
CONTROLLED SURFACE USE – CRUCIAL DEER WINTER RANGE

Within crucial deer winter range, no more than 10% of such habitat will be subject to surface disturbance and remain un-
reclaimed at any given time.
UT-S-231
Exception: This stipulation may be excepted if either the resource values change or the lessee/operator demonstrates to
Vernal BLMs satisfaction that impacts can be mitigated.
Modification: None
Waiver: None
TIMING LIMITATION – MULE DEER AND ELK CRUCIAL WINTER RANGE

No surface disturbing or otherwise disruptive activities within mule deer and elk crucial winter range from December 1 to
April 15.
UT-S-232 Exception: Upon review and monitoring, the authorized officer may grant exceptions because of climatic and/or range
Price conditions if certain criteria are met and if activities would not cause undue stress to deer and/or elk populations or habitats.
Modification: Season may be adjusted depending on climatic and range conditions.
Waiver: A waiver may be granted if the winter range habitat is unsuitable for or unoccupied during winter months by
deer/elk and there is no reasonable likelihood of future winter range use.
TIMING LIMITATION – CRUCIAL MULE DEER AND ELK WINTER HABITAT
Restrict surface disturbing activities in crucial mule deer and elk habitats from December 15 to April 15 to protect winter
UT-S-233 habitats.
Richfield Exception: This stipulation does not apply to the maintenance and operation of existing and ongoing facilities. An exception
may be granted by the Field Manager if the operator submits a plan that demonstrates that impacts from the proposed action
can be adequately mitigated or it is determined the habitat is not being used during the winter period for any given year.
95
August 2019

Modification: The Field Manager may modify the boundaries of the stipulation area if (1) a portion of the area is not being
used as crucial winter range by deer/elk, (2) habitat outside of stipulation boundaries is being used as crucial winter range and
needs to be protected, or (3) the migration patterns have changed causing a difference in the season of use.
Waiver: A waiver may be granted if the winter range habitat is unsuitable or unoccupied during winter months by deer/elk
and there is no reasonable likelihood of future winter range use.
TIMING LIMITATION – CRUCIAL DEER WINTER RANGE
No surface-disturbing activities within crucial deer winter range from November 15 to April 15 to minimize stress and
disturbance to deer during crucial winter months.
UT-S-234 Exception: The authorized officer may grant an exception if, after an analysis, the authorized officer determines that the
Monticello animals are not present in the project area or the activity can be completed so as to not adversely affect the animals. Routine
(Outside of operation and maintenance is allowed.
MLP) Modification: The authorized officer may modify the boundaries of the stipulation area if a portion of the area is not being
used as deer winter range.
Waiver: May be granted if the deer winter range is determined to be unsuitable or unoccupied and there is no reasonable
likelihood of future use of the deer winter range.
TIMING LIMITATION – CRUCIAL ELK CALVING AND DEER FAWNING HABITAT
In order to protect crucial elk calving and deer fawning habitat exploration, drilling, and other development activity will not
be allowed from May 15 - June 30.
UT-S-247 Exception: This restriction would not apply to maintenance and operation of existing facilities. This stipulation may be
Vernal excepted if either the resource values change or the lessee/operator demonstrates to BLMs satisfaction that adverse impact
can be mitigated.
Modification: None
Waiver: None
TIMING LIMITATION – MOOSE WINTER RANGE
No surface disturbing or otherwise disruptive activities within moose winter range from December 1 to April 15.
UT-S-257 Exception: Upon review and monitoring, the authorized officer may grant exceptions because of climatic and/or range
conditions if certain criteria are met and if activities would not cause undue stress to moose populations or habitats.
Price Modification: Season may be adjusted depending on climatic and range conditions.
Waiver: A waiver may be granted if the winter range habitat is unsuitable or unoccupied during winter months by moose and
there is no reasonable likelihood of future winter range use.
96
August 2019
TIMING LIMITATION – RAPTOR HABITAT

Raptor nesting complexes and known raptor nest sites will be closed seasonally from February 1 to July 15 within ½ mile
of occupied nests.
Exception: The authorized officer may grant an exception if the raptor nest in question is deemed to be inactive by May 31
UT-S-260 and if the proposed activity would not result in a permanent structure or facility that would cause the subject nest to become
Price unsuitable for nesting in future years.
Modification: Season may be adjusted depending on climatic and range conditions. Distance may be adjusted if natural
features provide adequate visual screening.
Waiver: This stipulation may be waived if, in cooperation with the UDWR, it is determined that the site has been
permanently abandoned or unoccupied for a minimum of 3 years.
TIMING LIMITATION – RAPTOR BUFFERS
Raptor management will be guided by the use of "Best Management Practices for Raptors and Their Associated Habitats in
Utah" (Utah BLM, 2006, Appendix A), utilizing seasonal and spatial buffers, as well as mitigation, to maintain and enhance
raptor nesting and foraging habitat, while allowing other resource uses.
Exception: None
Modification: Criteria that would need to be met, prior to implementing modifications to the spatial and seasonal buffers in
the “Raptor BMPs”, would include the following:
1. Completion of a site-specific assessment by a wildlife biologist or other qualified individual. See example (Attachment
1 of the Raptor BMPs in Appendix A)
UT-S-261 2. Written documentation by the BLM Field Office Wildlife Biologist, identifying the proposed modification and
affirming that implementation of the proposed modification(s) would not affect nest success or the suitability of the site
Vernal
for future nesting. Modification of the “BMPs” would not be recommended if it is determined that adverse impacts to
nesting raptors would occur or that the suitability of the site for future nesting would be compromised.
3. Development of a monitoring and mitigation strategy by a BLM biologist, or other raptor biologist. Impacts of
authorized activities would be documented to determine if the modifications were implemented as described in the
environmental documentation or Conditions of Approval, and were adequate to protect the nest site. Should adverse
impacts be identified during monitoring of an activity, BLM would follow an appropriate course of action, which may
include cessation or modification of activities that would avoid, minimize or mitigate the impact, or, with the approval
of UDWR and the USFWS, BLM could allow the activity to continue while requiring monitoring to determine the full
impact of the activity on the affected raptor nest. A monitoring report would be completed and forwarded to UDWR for
incorporation into the Natural Heritage Program (NHP) raptor database.
97
August 2019

Waiver: None
CONTROLLED SURFACE USE/TIMING LIMITATION – BALD EAGLES
Bald eagles would be protected as outlined in the Bald Eagle Protection Act of 1940 (16 U.S.C. 668-668d, 54 Stat. 250, as
amended). Activities on BLM lands that contain nesting or winter roosting habitat for the bald eagle would be avoided or
restricted, depending on the duration and timing of the activity. Bald eagles would be managed according to the Best
Management Practices for Raptors and their Associated Habitats in Utah (BLM 2006c). These management requirements
would include restrictions and avoidance measures, including required surveys prior to activity, possible monitoring during
the activity, implementation of seasonal and spatial buffers during the breeding season (January 1 – August 31), and
avoidance of disturbance in riparian areas unless impracticable. No future ground-disturbing activities would be authorized
within a 1.0-mile radius of known bald eagle nest sites year-round. Deviations may be allowed only after appropriate levels
of consultation and coordination with the USFWS/UDWR. In addition, no permanent above-ground structures would be
allowed within a 0.50-mile radius of a winter roost site if the structure would result in the habitat becoming unsuitable for
future winter roosting by bald eagles.
UT-S-275 These requirements would help to mitigate the adverse impacts of human disturbance on bald eagles during breeding and
Moab, roosting seasons.
Monticello 1. Surveys will be required prior to operations unless species occupancy and distribution information is complete and
(Outside of available. All surveys must be conducted by qualified individual(s), and be conducted according to protocol.
MLP) 2. Lease activities will require monitoring throughout the duration of the project. To ensure desired results are being
achieved, minimization measures would be evaluated.
4. Temporary activities within 1.0 mile of nest sites will not occur during the breeding season of January 1 to August 31,
unless the area has been surveyed according to protocol and determined to be unoccupied.
5. Temporary activities within 0.5 miles of winter roost areas, e.g., cottonwood galleries, will not occur during the winter
roost season of November 1 to March 31, unless the area has been surveyed according to protocol and determined to
be unoccupied.
6. No permanent infrastructure will be placed within 1.0 mile of nest sites.
7. No permanent infrastructure will be placed within 0.5 miles of winter roost areas.
8. Remove big game carrion within 100 feet of lease roadways occurring within Bald Eagle foraging range.
9. Avoid loss or disturbance to large cottonwood gallery riparian habitats.
98
August 2019

surface disturbance and eliminate drilling in suitable habitat. Utilize direction drilling to avoid direct impacts to large
cottonwood gallery riparian habitats. Ensure that such direction drilling does not intercept or degrade alluvial aquifers.
11. All areas of surface disturbance within riparian areas and/or adjacent uplands should be re-vegetated with native
species.
Additional measures may also be employed to avoid or minimize effects to the species between the lease stage and lease
development stage. These additional measures will be developed and implemented in coordination with the USFWS/UDWR
to ensure continued compliance with the Bald Eagle Protection Act.
Exception: An exception may be granted by the authorized officer if authorization is obtained from USFWS/UDWR. The
authorized officer may also grant an exception if an analysis indicates that the nature of the conduct of the actions, as
proposed or conditioned, would not impair the habitat and physical requirements determined necessary for the survival of the
Bald Eagles.
Modification: The authorized officer may modify the boundaries of the stipulation area if an analysis indicates, and
USFWS/UDWR determines that a portion of the area is not being used as Bald Eagle nesting or roosting territories or if
additional nesting or roosting territories are identified.
Waiver: May be granted if there is no reasonable likelihood of site occupancy over a minimum 10 year period.
CONTROLLED SURFACE USE/TIMING LIMITATIONS – BALD EAGLE
The Lessee/Operator is given notice that the lands in this parcel contains nesting/winter roost habitat for the bald eagle, a
federally listed species. Avoidance or use restrictions may be placed on portions of the lease. Application of appropriate
measures will depend on whether the action is temporary or permanent, and whether it occurs within or outside the bald eagle
breeding or roosting season. A temporary action is completed prior to the following breeding or roosting season, leaving no
permanent structures and resulting in no permanent habitat loss. A permanent action continues for more than one breeding or
roosting season and/or causes a loss of eagle habitat or displaces eagles through disturbances (e.g., creation of a permanent
UT-S-276 structure). The following avoidance and minimization measures have been designed to ensure activities carried out on the
Richfield lease are in compliance with the Endangered Species Act (ESA). Integration of, and adherence to, these measures will
facilitate review and analysis of any submitted permits under the authority of this lease. Following these measures could
reduce the scope of ESA Section 7 consultation at the permit stage.
1. Surveys will be required prior to operations, unless species occupancy and distribution information is complete and
available. All surveys must be conducted by qualified individual(s), and be conducted according to protocol.
99
August 2019

4. Temporary activities within 1.0 mile of nest sites will not occur during the breeding season of January 1 to August 31,
unless the area has been surveyed according to protocol and determined to be unoccupied.
5. Temporary activities within 0.5 miles of winter roost areas, e.g., cottonwood galleries, will not occur during the winter
roost season of November 1 to March 31, unless the area has been surveyed according to protocol and determined to be
unoccupied.
8. Remove big game carrion from within 100 feet from lease roadways occurring within bald eagle foraging range.
surface disturbance and eliminate drilling in suitable habitat. Utilize directional drilling to avoid direct impacts to large
cottonwood gallery riparian habitats. Ensure that such directional drilling does not intercept or degrade alluvial aquifers.
11. All areas of surface disturbance within riparian areas and/or adjacent uplands should be re-vegetated with native
species.
Additional measures may also be employed to avoid or minimize effects to the species between the lease sale stage and lease
development stage. These additional measures will be developed and implemented in consultation with the U.S. Fish and
Wildlife Service to ensure continued compliance with the ESA.
Exception: None
Modification: None
Waiver: None
CONTROLLED SURFACE USE – BALD EAGLE WINTER ROOST
Protect and restore cottonwood bottoms for bald eagle winter habitat along the Green and White Rivers, at Pelican Lake, and
UT-S-278 at the Cliff Creek Bald Eagle roost site, as well as any new roost sites discovered in the future.
Vernal Exception: None
Modification: None
Waiver: None
UT-S-285 TIMING LIMITATION – MIGRATORY BIRD NESTING
Migratory bird nesting areas will be closed seasonally from April 15 to August 1. Areas with migratory birds designated as
Price BLM Special Status Species will have the highest priority.
100
August 2019

Exception: Upon review and monitoring, the authorized officer may grant exceptions because of climatic and/or habitat
conditions if activities would not cause undue stress to migratory bird populations.
Modification: Season may be adjusted depending on climatic and range conditions. Distance may be adjusted if natural
features provide adequate visual screening.
Waiver: None
CONTROLLED SURFACE USE/TIMING LIMITATION – MEXICAN SPOTTED OWL
In areas that contain suitable habitat for MSO or designated Critical Habitat, actions would be avoided or restricted that may
cause stress and disturbance during nesting and rearing of their young. Appropriate measures would depend on whether the
action is temporary or permanent and whether it occurs within or outside the owl nesting season. A temporary action is
completed prior to the following breeding season leaving no permanent structures and resulting in no permanent habitat loss.
A permanent action continues for more than one breeding season and/or causes a loss of owl habitat or displaces owls
through disturbances, i.e., creation of a permanent structure. The following avoidance and minimization measures have been
designed to ensure activities carried out on the lease are in compliance with the Endangered Species Act. Integration of, and
adherence to these measures, will facilitate review and analysis of any submitted permits under the authority of this lease.
Following these measures could reduce the scope of Endangered Species Act, Section 7 consultation at the permit stage.
1. Surveys will be required prior to implementation of the proposed action. All surveys must be conducted by qualified
UT-S-288
individual(s) acceptable to the BLM.
Monticello 2. Assess habitat suitability for both nesting and foraging using accepted habitat models in conjunction with field reviews.
(Outside of Apply the conservation measures below if project activities occur within 0.5 mile of suitable owl habitat. Determine
MLP) potential effects of actions to owls and their habitat.
a. Document type of activity, acreage and location of direct habitat impacts, type and extent of indirect impacts
relative to location of suitable owl habitat.
b. Document if action is temporary or permanent.
achieved, minimization measures will be evaluated, and, if necessary, Section 7 consultation reinitiated.
4. Any activity that includes water production will be managed to ensure maintenance or enhancement of riparian habitat.
surface disturbance and eliminate drilling in canyon habitat suitable for MSO nesting.
6. For all temporary actions that may impact owls or suitable habitat:
a. If the action occurs entirely outside of the owl breeding season from March 1 through August 31, and leaves no
permanent structure or permanent habitat disturbance, the action can proceed without an occupancy survey.
101
August 2019

b. If the action will occur during a breeding season, a survey for owls is required prior to commencing the activity. If
owls are found, the activity shall be delayed until outside of the breeding season.
c. Rehabilitate access routes created by the project through such means as raking out scars, re-vegetation, gating
access points, etc.
7. For all permanent actions that may impact owls or suitable habitat:
a. Survey two consecutive years for owls according to accepted protocol prior to commencing activities.
b. If owls are found, no disturbing actions will occur within 0.5 mile of an identified site. If nest site is unknown, no
activity will occur within the designated current and historic Protected Activity Center (PAC).
c. Avoid permanent structures within 0.5 mile of suitable habitat unless surveyed and not occupied.
d. Reduce noise emissions (e.g., use hospital-grade mufflers) to 45 dBA at 0.5 mile from suitable habitat, including
canyon rims. Placement of permanent noise-generating facilities should be contingent upon a noise analysis to
ensure noise does not encroach upon a 0.5 mile buffer for suitable habitat, including canyon rims.
e. Limit disturbances to and within suitable habitat by staying on designated and/or approved routes.
f. Limit new access routes created by the project.
U.S. Fish and Wildlife Service between the lease sale stage and lease development stage to ensure continued compliance with
the ESA.
Modifications to the Surface Use Plan of Operations may be required in order to protect the MSO and/or habitat in
accordance with Section 6 of the lease terms, the Endangered Species Act, and the regulations at 43 CFR 3101.1-2.
Exception: An exception may be granted by the authorized officer if authorization is obtained from USFWS (through
applicable provisions of the ESA). The authorized officer may also grant an exception if an analysis indicates that the nature
or the conduct of the actions would not impair the primary constituent element determined necessary for the survival and
recovery of the MSO and USFWS through consultation concurs with this determination.
Modification: The authorized officer may modify the boundaries of the stipulation area if an analysis indicates and USFWS
(through applicable provisions of the ESA) determines a portion of the area is not being used as Critical Habitat.
Waiver: A waiver may be granted if the MSO is de-listed and the Critical Habitat is determined by USFWS as not necessary
for the survival and recovery of the MSO.
UT-S-290 CONTROLLED SURFACE USE/TIMING LIMITATION – SOUTHWESTERN WILLOW FLYCATCHER
In areas that contain riparian habitat within the range for the Southwestern Willow Flycatcher, actions would be avoided or
Monticello restricted that may cause stress and disturbance during nesting and rearing of their young. Appropriate measures will depend
(Outside of on whether the action is temporary or permanent, and whether it occurs within or outside the nesting season. A temporary
MLP) action is completed prior to the following breeding season leaving no permanent structures and resulting in no permanent
102
August 2019

habitat loss. A permanent action continues for more than one breeding season and/or causes a loss of habitat or displaces
flycatchers through disturbances, i.e., creation of a permanent structure. The following avoidance and minimization measures
have been designed to ensure activities carried out on the lease are in compliance with the Endangered Species Act.
Integration of, and adherence to these measures, will facilitate review and analysis of any submitted permits under the
authority of this lease. Following these measures could reduce the scope of Endangered Species Act, Section 7 consultation
at the permit stage.
available. All surveys must be conducted by qualified individual(s) and be conducted according to protocol.
2. Activities will require monitoring throughout the duration of the project. To ensure desired results are being achieved,
minimization measures would be evaluated and, if necessary, Section 7 consultation reinitiated.
surface disturbance and eliminate drilling in suitable riparian habitat. Ensure that such directional drilling does not
5. Activities will maintain a 300 feet buffer from suitable riparian habitat year long.
6. Activities within 0.25 mile of occupied breeding habitat would not occur during the breeding season of May 1 to
August 15.
7. Ensure that water extraction or disposal practices do not result in change of hydrologic regime that would result in loss
or degradation of riparian habitat.
8. Re-vegetate with native species all areas of surface disturbance within riparian areas and/or adjacent land.
applicable provisions of the ESA). The authorized officer may also grant an exception if an environmental analysis indicates
that the nature of the conduct of the actions, as proposed or conditioned, would not impair the primary constituent element
determined necessary for the survival and recovery of the Southwestern Willow Flycatcher and USFWS concurs with this
determination.
indicates, and USFWS (through applicable provisions of the ESA) determines that a portion of the area is not being used as
Southwestern Willow Flycatcher habitat.
103
August 2019

Waiver: May be granted if the Southwestern Willow Flycatcher is de-listed and the Critical Habitat is determined by
USFWS as not necessary for the survival and recovery of the Southwestern Willow Flycatcher.
CONTROLLED SURFACE USE/TIMING LIMITATIONS – CALIFORNIA CONDOR
The Lessee/Operator is given notice that the lands located in this parcel contain potential habitat for the California Condor, a
federally listed species. Avoidance or use restrictions may be placed on portions of the lease if the area is known or suspected
to be used by condors. Application of appropriate measures will depend on whether the action is temporary or permanent,
and whether it occurs within or outside potential habitat. A temporary action is completed prior to the following important
season of use, leaving no permanent structures and resulting in no permanent habitat loss. This would include consideration
for habitat functionality. A permanent action continues for more than one season of habitat use, and/or causes a loss of
condor habitat function or displaces condors through continued disturbance (i.e. creation of a permanent structure requiring
repetitious maintenance, or emits disruptive levels of noise).
The following avoidance and minimization measures have been designed to ensure activities carried out on the lease are in
compliance with the Endangered Species Act (ESA). Integration of, and adherence to these measures will facilitate review
and analysis of any submitted permits under the authority of this lease. Following these measures could reduce the scope of
ESA, Section 7 consultation at the permit stage. Current avoidance and minimization measures include the following:
UT-S-293
available. All Surveys must be conducted by qualified individual(s) approved by the BLM, and must be conducted
Richfield according to approved protocol.
2. If surveys result in positive identification of condor use, all lease activities will require monitoring throughout the
duration of the project to ensure desired results of applied mitigation and protection. Minimization measures will be
evaluated during development and, if necessary, Section 7 consultation may be reinitiated.
3. Temporary activities within 1.0 mile of nest sites will not occur during the breeding season.
4. Temporary activities within 0.5 miles of established roosting sites or areas will not occur during the season of use,
August 1 to November 31, unless the area has been surveyed according to protocol and determined to be unoccupied.
6. No permanent infrastructure will be placed within 0.5 miles of established roosting sites or areas.
7. Remove big game carrion from within 100 feet from lease roadways occurring within foraging range.
surface disturbance and eliminate drilling in suitable habitat utilize directional drilling to avoid direct impacts to large
9. Re-initiation of section 7 consultation with the Service will be sought immediately if mortality or disturbance to
California condors is anticipated as a result of project activities. Additional site-specific measures may also be
104
August 2019

employed to avoid or minimize effects to the species. These additional measures will be developed and implemented in
consultation with the U.S. Fish and Wildlife Service to ensure continued compliance with the ESA.
Additional measures may also be employed to avoid or minimize effects to the species between the lease sale and lease
development stages. These additional measures will be developed and implemented in consultation with the U.S. Fish and
Wildlife Service to ensure continued compliance with the ESA.
Exception: None
Modification: None
Waiver: None
CONTROLLED SURFACE USE/TIMING LIMITATION – CALIFORNIA CONDOR
In areas that contain habitat for California Condors, actions will be avoided or restricted if the area is known or suspected to
be used by condors that may cause stress and disturbance to condors. Application of appropriate measures will depend on
whether the action is temporary or permanent, and whether it occurs within or outside potential habitat. A temporary action is
completed prior to the following important season of use, leaving no permanent structures and resulting in no permanent
habitat loss. This would include consideration for habitat functionality. A permanent action continues for more than one
season of habitat use, and/or causes a loss of condor habitat function or displaces condors through continued disturbance (i.e.
creation of a permanent structure requiring repetitious maintenance, or emits disruptive levels of noise).
The following avoidance and minimization measures have been designed to ensure activities carried out on the lease are in
compliance with the Endangered Species Act. Integration of, and adherence to these measures will facilitate review and
UT-S-294 analysis of any submitted permits under the authority of this lease. Following these measures could reduce the scope of
Endangered Species Act, Section 7 consultation at the permit stage. Current avoidance and minimization measures include
Monticello,
the following:
Moab
available. All Surveys must be conducted by qualified individual(s) approved by the BLM, and must be conducted
according to approved protocol.
2. If surveys result in positive identification of condor use, all lease activities will require monitoring throughout the
duration of the project to ensure desired results of applied mitigation and protection. Minimization measures will be
evaluated during development and, if necessary, Section 7 consultation may be reinitiated.
4. Temporary activities within 0.5 miles of established roosting sites or areas will not occur during the season of use,
August 1 to November 31, unless the area has been surveyed according to protocol and determined to be unoccupied.
105
August 2019

7. Remove big game carrion to 100 feet from on lease roadways occurring within foraging range.
surface disturbance and eliminate drilling in suitable habitat Utilize directional drilling to avoid direct impacts to large
employed to avoid or minimize effects to the species. These additional measures will be developed and implemented in
consultation with the U.S. Fish and Wildlife Service to ensure continued compliance with the ESA.
development stages. These additional measures will be developed and implemented in consultation with the U.S. Fish and
Wildlife Service to ensure continued compliance with the Endangered Species Act.
applicable provisions of the ESA). The authorized officer may also grant an exception if an analysis indicates that the nature
of the conduct of the actions, as proposed or conditioned, would not impair the primary constituent element determined
necessary for the survival and recovery of the California Condor and USFWS concurs with this determination.
Modification: The authorized officer may modify the boundaries of the stipulation area if an analysis indicates, and USFWS
(through applicable provisions of the ESA) determines that a portion of the area is not being used as California Condor
nesting or roosting territories.
Waiver: May be granted (through applicable provisions of the ESA) if there is no reasonable likelihood of site occupancy
over a minimum 10-year period.
CONTROLLED SURFACE USE/TIMING LIMITATION – YELLOW-BILLED CUCKOO
No surface-disturbing activities will be conducted within 100 meters of Yellow-billed Cuckoo habitat (riparian areas) from
May 15th through July 20th.
UT-S-297 Exception: An exception may be granted by the authorized officer if authorization is obtained from USFWS (through
Moab, applicable provisions of the ESA). The authorized officer may also grant an exception if an environmental analysis indicates
Monticello that the nature of the conduct of the actions, as proposed or conditioned, would not impair the primary constituent element
(Outside of determined necessary for the survival and recovery of the Yellow-billed Cuckoo and USFWS concurs with this
MLP) determination.
indicates, and USFWS (through applicable provisions of the ESA) determines that a portion of the area is not being used as
Yellow-billed Cuckoo habitat.
106
August 2019

Waiver: May be granted if the Yellow-billed Cuckoo is de-listed and if USFWS determines it is not necessary for the
survival and recovery of the Western Yellow-billed Cuckoo.
CONTROLLED SURFACE USE – NOXIOUS WEED
Continue implementation of noxious weed and invasive species control actions in accordance with national guidance and
local weed management plans, in cooperation with State, federal, affected counties, adjoining private land owners, and other
partners or interests directly affected. Implement Standard Operating Procedures and Mitigation Measures for herbicide use
UT-S-305
as well as prevention measures for noxious and invasive plants identified in the Record of Decision Vegetation Treatments
Price Using Herbicides on Bureau of Land Management Lands in 17 Western States PEIS and associated documents.
Exception: None
Modification: None
Waiver: None
AIR QUALITY AND GREENHOUSE GASES
All new and replacement internal combustion gas field engines of less than or equal to 300 design-rated horsepower shall not
emit more than 2 grams of NOx per horsepower-hour. This requirement does not apply to gas field engines of less than or
equal to 40 design-rated horsepower.
All new and replacement internal combustion gas field engines of greater than 300 design-rated horsepower must not emit
UT-S-358 more than 1 gram of NOx per horsepower-hour.
Moab MLP Purpose: To protect air quality and minimize greenhouse gas emissions.
Exception: None
Modification: The Authorized Officer may modify the stated requirements in accordance with updated specifications to
comply with the Clean Air Act, or as deemed necessary to ensure that the stipulation is sufficient to maintain air quality and
protect air quality related values.
Waiver: None
AIR QUALITY I
All drilling and production operations are required to adhere to the following minimum standards:
UT-S-359 1. Drill rig engines must meet Tier II or better standards, as necessary based on air quality conditions or projections, and
consistent with the most stringent Environmental Protection Agency emissions standards that are in force at the time of
Moab MLP installation or approval.
2. Stationary internal combustion engine standard of 2g NOx/bhp-hr for engines<300HP and 1g NOx/bhp-hr for engines
>300 HP.
107
August 2019

3. Low bleed or no bleed pneumatic controller.
4. Dehydrator VOC emission controls to +95 percent efficiency.
5. Tank VOC emission controls to +95 percent efficiency equivalent to NSPS subpart 0000.
Purpose: To mitigate any potential impact mineral development emissions may have on regional ozone formation.
Exception: None
Modification: The Authorized Officer may modify the stipulation as a result of new information if: 1) the protection
provided by the stipulation is no longer justified or necessary to meet resource objectives established in the Moab MLP; 2)
the protection provided by the stipulation is no longer sufficient to meet resource objectives established in the Moab MLP; or
3) proposed operations would not cause unacceptable impacts. The Authorized Officer may require additional plans of
development, surveys, mitigation proposals, or environmental analysis, and may be required to consult with other
government agencies and/or the public in order to make this determination. The modification may be subject to public review
for at least a 30-day period.
Waiver: None
AIR QUALITY II
A Fugitive Dust Control Plan is required for mineral activities that would disturb a surface area larger than 0.25 acres or that
would involve truck traffic on unpaved or untreated surfaces.
Purpose: To minimize the generation of fugitive dust.
Exception: None
UT-S-360 Modification: The Authorized Officer may modify the stipulation as a result of new information if: 1) the protection
Moab MLP
Waiver: None
CONTROLLED SURFACE USE - FILMING LOCATIONS
UT-S-364 A visual assessment is required within 1-mile of the high use filming locations listed below. This assessment must
demonstrate that the proposed mineral operations within this area would not result in long-term impairment to the scenic
Moab MLP quality from the filming locations. These filming locations include:
• Needles Overlook
108
August 2019

• Colorado River Corridor and Corona Arch
• Green River Canyon
• Kane Creek Corridor
• Looking Glass Rock
• View from Dead Horse Point
• Potash Road/Shafer Basin (including Fossil Point)
• Long Canyon
• Highway 211 (including Newspaper Rock)
• Highway 313
• Mineral Bottom Road
• Behind the Rocks Jeep Route
• Monitor and Merrimac/Determination Towers/Mill Canyon/Bartlett Wash
• Gemini Bridges/Bull Canyon
• Jewell Tibbetts Arch
• White Wash.
Purpose: To protect the immediate foreground of high use filming locations.
Exception: The Authorized Officer may grant an exception if a visual assessment demonstrates that the proposed mineral
operations would not result in long-term impairment to the scenic quality from the filming location.
Modification: The Authorized Officer may modify the stipulation if a filming location ceases to be utilized or if a new
location becomes heavily used.
Waiver: The Authorized Officer may waive the stipulation if the film industry ceases to utilize the area for filming.
CONTROLLED SURFACE USE – PALEONTOLOGY
Surveys and monitoring (where appropriate) are required for all surface-disturbing mineral activities in PFYC Class 4 and 5
areas. Where monitoring encounters vertebrate and vertebrate trace fossils during mineral operations, all operations must
cease until the BLM determines whether the site can be avoided, protected, or fully excavated.
UT-S-370 Purpose: To protect paleontological resources.
Moab MLP Exception: None
Modification: The Authorized Officer could modify the stipulation if it is determined that the project area is not located
within a PFYC Class 4 or 5 area.
Waiver: The Authorized Officer could waive the stipulation if it is determined that the entire lease area is not located within
a PFYC Class 4 or 5 area.
109
August 2019
NO SURFACE OCCUPANCY – DEVELOPED RECREATION SITES

No surface-disturbing activities are allowed within 0.5-miles of developed recreation site boundaries (current and planned,
See Appendix D of the Moab MLP ROD).
Purpose: To protect Federal investment in facilities, to provide for recreational use, and to protect the viewshed and
UT-S-371 soundscape from the facility.
Exception: The Authorized Officer may grant an exception if a viewshed analysis indicates no long-term impairment of the
Moab MLP visual resources from the recreation site and if it can be demonstrated there would be no auditory impacts to the recreation
facility.
Modification: The Authorized Officer may modify the stipulation to the boundary of the developed recreation site if the site
is expanded.
Waiver: The Authorized Officer may waive the stipulation if the developed recreation site has been decommissioned.
CONTROLLED SURFACE USE – CANYON RIMS, LABYRINTH RIMS/GEMINI BRIDGES AND SOUTH
MOAB SRMAs
Mineral operations outside the area designated as NSO are subject to the following requirements:
1. Multiple wells per pad as appropriate.
2. Well pads would be placed no closer than 2-miles apart.
3. Oil and Gas: Production facilities would be co-located and designed to minimize surface impacts. Pipelines and utilities
would be placed within or immediately adjacent to existing roads.
4. Limit unreclaimed surface disturbance to no more than 15 acres per well pad (including associated facilities, roads,
pipelines, and utilities) following interim reclamation.
UT-S-376
5. Extensive interim reclamation of roadway disturbance and reclamation of well pads to minimize long-term surface
Moab MLP disturbance.
6. Final reclamation fully restoring the original landform. Travel routes would be restored to their original character.
7. This stipulation would allow for geophysical operations.
8. Compensatory mitigation outside the area of impact could be required to minimize impacts to resources.
Purpose: To minimize the amount of surface disturbance and related impacts resulting from mineral development in areas
with sensitive resources.
Exception: Where it can be shown that the proposed operation would not cause unacceptable impacts, the Authorized
Officer may grant an exception based on any of the factors listed below:
1. If alternative placement of well pads would enable the operator to use areas that have been previously disturbed.
110
August 2019

2. If alternative placement of well pads would minimize the need for new road construction.
3. If there is a demonstrated reduction in the impacts to resources.
4. If there is a valid safety concern.
5. If the requirement of 2-mile spacing would preclude a lessee/operator from exercising their lease rights where the
spacing would locate a well pad outside of the lease.
6. An exception to the 2-mile placement could be granted if the proponent successfully demonstrates that geologic factors
preclude access to a substantial portion of the oil and gas reservoir. An exception to the 2-mile placement would still
require the maximum technologically feasible placement of oil and gas wells.
Waiver: The Authorized Officer may waive the stipulation if it is determined that the factors leading to its inclusion in the
lease no longer exist. The Authorized Officer may require additional plans of development, surveys, mitigation proposals, or
environmental analysis, and may be required to consult with other government agencies and/or the public in order to make
this determination. The waiver may be subject to public review for at least a 30-day period.
CONTROLLED SURFACE USE – STEEP SLOPES
An erosion control plan approved by the BLM is required on slopes greater than 21 percent prior to construction and
maintenance if these activities cannot be avoided. The plan would include the following: 1) an erosion control strategy; and
2) a BLM-accepted access road and well pad survey and design.
Purpose: To minimize soil erosion, sedimentation, soil compaction, runoff and associated loss of soil productivity.
UT-S-384 Exception: The Authorized Officer may grant an exception if it is determined that the factors leading to its inclusion in the
lease have changed sufficiently such that: 1) the protection provided by the stipulation is no longer justified or necessary to
Moab MLP meet resource objectives established in the Moab MLP; or 2) proposed operations would not cause unacceptable impacts.
The Authorized Officer may require additional plans of development, surveys, mitigation proposals, or environmental
analysis, and may be required to consult with other government agencies and/or the public in order to make this
determination.
Modification: The Authorized Officer may modify the stipulation if it is determined that the project area does not contain
slopes greater than 21 percent.
111
August 2019

Waiver: The Authorized Officer may waive the stipulation if it is verified that steep slopes are not present on the entire
leasehold.
NO SURFACE OCCUPANCY – WATER RESOURCES
No surface occupancy allowed within public water reserves, 100-year floodplains, and within 500 feet of intermittent and
perennial streams, rivers, riparian areas, wetlands, water wells, and springs.
Purpose: To protect public water reserves, 100-year floodplains, intermittent and perennial streams, rivers, springs,
wetlands, riparian areas, and water wells.
UT-S-386 Exception: The Authorized Officer may grant an exception only for access roads and pipelines if: a) there are no practical
Moab MLP alternatives; b) impacts could be fully mitigated; and c) proposed operations would not result in unacceptable impacts.
Modification: The Authorized Officer may modify the stipulation if it is determined that the project area no longer contains
a public water reserve, 100-year floodplains, intermittent and perennial streams, rivers, springs, wetlands, riparian areas, or
water wells.
Waiver: The Authorized Officer may waive the stipulation if public water reserves, 100-year floodplains, intermittent and
perennial streams, rivers, springs, wetlands, riparian areas, or water wells are not present on the entire leasehold.
NO SURFACE OCCUPANCY – EPHEMERAL STREAMS
No surface occupancy allowed within 100 feet of ephemeral streams.
Purpose: To protect ephemeral streams.
UT-S-387 Exception: The Authorized Officer may grant an exception if: a) there are no practical alternatives; b) impacts could be fully
mitigated; and c) proposed operations would not result in unacceptable impacts.
Moab MLP
Modification: The Authorized Officer may modify the stipulation if it is determined that the project area does not contain an
ephemeral stream.
Waiver: The Authorized Officer may waive the stipulation if ephemeral streams are verified as not present on the entire
leasehold.
NO SURFACE OCCUPANCY – VISUAL RESOURCES – RIMLANDS OF THE GREEN AND COLORADO
RIVERS
No surface occupancy allowed within a 1-mile setback from the rims of the Colorado and Green Rivers.
UT-S-407 Purpose: To protect high quality visual resources along the rims of the Green and Colorado Rivers.
Moab MLP Exception: The Authorized Officer may grant an exception if a viewshed analysis indicates no impairment of the visual
resources of the rims from either the rims or from the rivers.
112
August 2019

Waiver: The Authorized Officer may waive the stipulation if it is determined that the factors leading to its inclusion in the
lease no longer exist. The Authorized Officer may require additional plans of development, surveys, mitigation proposals, or
environmental analysis, and may be required to consult with other government agencies and/or the public in order to make
this determination. The waiver may be subject to public review for at least a 30-day period.
113
August 2019
Notice Summary Table
NUMBER UTAH LEASE NOTICES
CRUCIAL ELK CALVING AND DEER FAWNING HABITAT

UT-LN-11 The lessee/operator is given notice that lands in this lease have been identified as containing crucial elk calving or
deer fawning habitat. Exploration, drilling and other development activities may be restricted for up to 60 days.
Statewide
Modifications may be required in the Surface Use Plan of Operations including seasonal timing restrictions to
protect the species and its habitat.
PRONGHORN WINTER HABITAT
The lessee/operator is given notice that lands in this lease have been identified as containing crucial pronghorn
UT-LN-13 winter habitat. Surface use or otherwise disruptive activity may be restricted for up to 60 days during pronghorn
Statewide fawning season, as determined by BLM, including exploration, drilling and other development activities.
Modifications may be required in the Surface Use Plan of Operations including seasonal timing restrictions to
protect the species and its habitat.
PRONGHORN FAWNING HABITAT
UT-LN-14
The lessee/operator is given notice that this lease has been identified as containing crucial pronghorn fawning
Statewide (Outside of Moab
habitat. Surface use or otherwise disruptive activity may be restricted for up to 60 days during pronghorn fawning
MLP and areas defined in
season, as determined by BLM within identified crucial/important pronghorn fawning habitat from disruptive
the VFO, RFO, MbFO and
activity. Modifications to the Surface Use Plan of Operations may be required in accordance with section 6 of the
MtFO stips)
lease terms and 43CFR3101.1-2.
ROCKY MOUNTAIN/DESERT BIGHORN SHEEP CRUCIAL LAMBING AND RUTTING HABITAT
The Lessee/Operator is given notice that the lands in this parcel contains habitat for bighorn sheep. Modifications
UT-LN-20 to the surface use plan may be required in order to protect habitat from surface disturbing activities. Surface use or
otherwise disruptive activity may be restricted for up to 60 days during pronghorn fawning season, as determined
Statewide
by BLM. These modifications may include such measures as timing restrictions to avoid surface use during the
crucial lambing and rutting seasons. Measure may also include avoidance of certain areas such as water sources and
talus slopes.
114
August 2019
WHITE-TAILED AND GUNNISON PRAIRIE DOG

UT-LN-25
The lessee/operator is given notice that this lease parcel has been identified as containing white-tailed or Gunnison
Moab, Monticello, Vernal,
prairie dog habitat. Modifications to the Surface Use Plan of Operations may be required in order to protect white-
Price (Outside of Moab
tailed or Gunnison prairie dog from surface disturbing activities in accordance with the Endangered Species Act
MLP)
and 43 CFR 3101.1-2.
RAPTORS
Appropriate seasonal and spatial buffers shall be placed on all known raptor nests in accordance with Utah Field
Office Guidelines for Raptor Protection from Human and Land use Disturbances (USFWS 2002) and Best
Management Practices for Raptors and their Associated Habitats in Utah (BLM 2006). All construction related
activities will not occur within these buffers if pre-construction monitoring indicates the nests are active, unless a
site-specific evaluation for active nests is completed prior to construction and if a BLM wildlife biologist, in
UT-LN-44 consultation with USFWS and UDWR, recommends that activities may be permitted within the buffer. The BLM
Statewide will coordinate with the USFWS and UDWR and have a recommendation within 3-5 days of notification. Any
construction activities authorized within a protective (spatial and seasonal) buffer for raptors will require an on-site
monitor. Any indication that activities are adversely affecting the raptor and/or its' young the on-site monitor will
suspend activities and contact the BLM Authorized Officer immediately. Construction may occur within the buffers
of inactive nests. Construction activities may commence once monitoring of the active nest site determines that
fledglings have left the nest and are no longer dependent on the nest site. Modifications to the Surface Use Plan of
Operations may be required in accordance with section 6 of the lease terms and 43CFR3101.1-2.
MIGRATORY BIRD
The lessee/operator is given notice that surveys for nesting migratory birds may be required during migratory bird
UT-LN-45 breeding season whenever surface disturbances and/or occupancy is proposed in association with fluid mineral
exploration and development within priority habitats. Surveys should focus on identified priority bird species in
Statewide
Utah. Field surveys will be conducted as determined by the authorized officer of the Bureau of Land Management.
Based on the result of the field survey, the authorized officer will determine appropriate buffers and timing
limitations.
UTAH SENSITIVE SPECIES
The lessee/operator is given notice that no surface use or otherwise disruptive activity would be allowed that would
UT-LN-49 result in direct disturbance to populations or individual special status plant and animal species, including those
Statewide listed on the BLM sensitive species list and the Utah sensitive species list. The lessee/operator is also given notice
that lands in this parcel have been identified as containing potential habitat for species on the Utah Sensitive
Species List. Modifications to the Surface Use Plan of Operations may be required in order to protect these
115
August 2019

resources from surface disturbing activities in accordance with Section 6 of the lease terms, Endangered Species
Act, Migratory Bird Treaty Act and 43 CFR 3101.1-2.
SPECIAL STATUS PLANTS: NOT FEDERALLY LISTED
UT-LN-51 The lessee/operator is given notice that lands in this lease have been identified as containing special status plants,
not federally listed, and their habitats. Modifications to the Surface Use Plan of Operations may be required in
Statewide
order to protect the special status plants and/or habitat from surface disturbing activities in accordance with Section
6 of the lease terms, Endangered Species Act, and 43 CFR 3101.1-2.
NOXIOUS WEEDS
UT-LN-52
The lessee/operator is given notice that lands in this lease have been identified as containing or is near areas
Statewide (except PFO, use
containing noxious weeds. Best management practices to prevent or control noxious weeds may be required for
UT-S-305)
operations on the lease.
RIPARIAN AREAS
The lessee/operator is given notice that this lease has been identified as containing riparian areas. No surface use or
UT-LN-53 otherwise disruptive activity allowed within 100 meters of riparian areas unless it can be shown that (1) there is no
Statewide practicable alternative; (2) that all long-term impacts are fully mitigated; or (3) that the construction is an
enhancement to the riparian areas. Modifications to the Surface Use Plan of Operations may be required in
accordance with section 6 of the lease terms and 43CFR3101.1-2.
CULTURAL RESOURCES LOCATED SANDY OR ERODIBLE SOILS
This parcel is located in an area of high concentrations of cultural resources. Known cultural sites are fragile and
many are buried under sandy deposits which migrate due to their susceptibility to wind. These sites, or large
portions, are not visible from the surface. Therefore, the following mitigation measures may be applied to any
UT-LN-66
surface disturbance of this parcel:
Statewide
1. pre-surface disturbance cultural resource inventories;
2. pre-surface disturbance subsurface testing;
3. monitoring of ground disturbance; and
4. post-disturbance monitoring identifying resources as the soils stabilize around a project.
HIGH POTENTIAL FOR CULTURAL RESOURCE OCCURRENCE
UT-LN-70 The lessee/operator is given notice that lands in this lease contain significant Cultural Resources. Modifications to
Statewide the Surface Use Plan of Operations may be required for the protection of these resources. Class III level block
inventories may be required to determine resource location and possible impact to the resource.
116
August 2019
HIGH POTENTIAL PALEONTOLOGICAL RESOURCES

The lessee/operator is given notice that lands in this lease have been identified as having high potential for
UT-LN-72 paleontological resources. Surveys will be required and modifications to the Surface Use Plan of Operations may
Statewide be required in order to protect paleontological resources from surface disturbing activities in accordance with
Section 6 of the lease terms and 43 CFR 3101.1-2. In addition, monitoring may be required during surface
disturbing activities.
NPS ROADS
UT-LN-79
The use of National Park Service roads or lands to access the lease is not allowed in accordance with the Capital
Price
Reef National Park management plan. Modifications to the surface use plan may be required.
SITE ROW
UT-LN-83 The lessee/operator is given notice that lands in this lease have an existing site ROW present. Modifications to the
Statewide Surface Use Plan of Operations may be required or other appropriate mitigation as deemed necessary by the BLM
Authorized Officer in order to protect the valid existing rights.
GRAHAM’S BEARDTONGUE (PENSTEMON GRAHAMII)
In order to minimize effects to the federally proposed Graham’s beardtongue, the Bureau of Land Management
(BLM) in coordination with the U.S. Fish and Wildlife Service (Service) developed the following avoidance and
minimization measures. The following avoidance and minimization measures should be included in the Plan of
Development:
1. Pre-project habitat assessments will be completed across 100% of the project disturbance area within
potential habitat1 prior to any ground disturbing activities to determine if suitable Graham’s beardtongue
habitat is present.
UT-LN-90 2. Within suitable habitat3, site inventories will be conducted to determine occupancy. Inventories:
Vernal a. Must be conducted by qualified individual(s) and according to BLM and Service accepted survey
protocols,
b. Will be conducted in suitable and occupied habitat4 for all areas proposed for surface disturbance prior to
initiation of project activities and within the same growing season, at a time when the plant can be
detected (usually April 15th to May 20th in the Uintah Basin; however, surveyors should verify that the
plant is flowering by contacting a BLM or FWS botanist or demonstrating that the nearest known
population is in flower),
c. Will occur within 300’ from the centerline of the proposed right-of-way for surface pipelines or roads;
and within 300’ from the perimeter of disturbance for the proposed well pad including the well pad,
117
August 2019

d. Will include, but not be limited to, plant species lists and habitat characteristics, and
e. Will be valid until April 15th the following year.
3. Design project infrastructure to minimize impacts within suitable habitat2:
a. Reduce well pad size to the minimum needed, without compromising safety,
b. Limit new access routes created by the project,
c. Roads and utilities should share common right-of-ways where possible,
d. Reduce the width of right-of-ways and minimize the depth of excavation needed for the road bed; where
feasible, use the natural ground surface for the road within habitat,
e. Place signing to limit off-road travel in sensitive areas, and
f. Stay on designated routes and other cleared/approved areas.
4. Within occupied habitat4, project infrastructure will be designed to avoid direct disturbance and minimize
indirect impacts to populations and to individual plants:
a. Follow the above (3.) recommendations for project design within suitable habitats,
b. Construction of roads will occur such that the edge of the right of way is at least 300’ from any plant,
c. Roads will be graveled within occupied habitat; the operator is encouraged to apply water for dust
abatement to such areas from April 15th to May 20th (flowering period); dust abatement applications will
be comprised of water only,
d. The edge of the well pad should be located at least 300’ away from plants,
e. Surface pipelines will be laid such that a 300 foot buffer exists between the edge of the right of way and
the plants, use stabilizing and anchoring techniques when the pipeline crosses the habitat (exposed raw
shale knolls and slopes derived from the Parachute Creek and Evacuation Creek members of the geologic
Green River Formation) to ensure pipelines don’t move towards the population,
f. Construction activities will not occur from April 15th through May 30th within occupied habitat,
g. Before and during construction, areas for avoidance should be visually identifiable in the field, e.g.,
flagging, temporary fencing, rebar, etc.,
h. Where technically and economically feasible, use directional drilling or multiple wells from the same
pad,
i. Designs will avoid concentrating water flows or sediments into occupied habitat,
j. Place produced oil, water, or condensate tanks in centralized locations, away from occupied habitat, and
k. Minimize the disturbed area of producing well locations through interim and final reclamation. Reclaim
well pads following drilling to the smallest area possible.
5. Occupied Graham’s beardtongue habitats within 300’ of the edge of the surface pipelines’ right-of-ways,
300’ of the edge of the roads’ right-of-ways, and 300’ from the edge of well pads shall be monitored for a
118
August 2019

period of three years after ground disturbing activities. Monitoring will include annual plant surveys to
determine plant and habitat impacts relative to project facilities. Annual reports shall be provided to the BLM
and the Service. To ensure desired results are being achieved, minimization measures will be evaluated and
may be changed after a thorough review of the monitoring results and annual reports during annual meetings
between the BLM and the Service.
Additional site-specific measures may also be employed to avoid or minimize effects to the species. These
additional measures will be developed and implemented in consultation with the U.S. Fish and Wildlife Service to
ensure continued conservation of the species.
AIR QUALITY MITIGATION MEASURES
The lessee is given notice that the Bureau of Land Management (BLM) in coordination with the U.S.
Environmental Protection Agency and the Utah Department of Air Quality, among others, has developed the
following air quality mitigation measures that may be applied to any development proposed on this lease.
Integration of and adherence to these measures may help minimize adverse local or regional air quality impacts
from oil and gas development (including but not limited to construction, drilling, and production) on regional ozone
formation.
• All internal combustion equipment would be kept in good working order.
• Water or other approved dust suppressants would be used at construction sites and along roads, as determined
appropriate by the Authorized Officer.
• Open burning of garbage or refuse would not occur at well sites or other facilities.
UT-LN-96 • Drill rigs would be equipped with Tier II or better diesel engines.
Statewide • Vent emissions from stock tanks and natural gas TEG dehydrators would be controlled by routing the
emissions to a flare or similar control device which would reduce emissions by 95% or greater.
• Low bleed or no bleed pneumatics would be installed on separator dump valves and other controllers.
• During completion, flaring would be limited as much as possible. Production equipment and gathering lines
would be installed as soon as possible.
• Well site telemetry would be utilized as feasible for production operations.
• Stationary internal combustion engine would comply with the following standards: 2g NOx/bhp-hr for
engines <300HP; and 1g NOx/bhp-hr for engines >300HP.
Additional site-specific measures may also be employed to avoid or minimize effects to local or regional air
quality. These additional measures will be developed and implemented in coordination with the U.S.
Environmental Protection Agency, the Utah Department of Air Quality, and other agencies with expertise or
jurisdiction as appropriate based on the size of the project and magnitude of emissions.
119
August 2019
REGIONAL OZONE FORMATION CONTROLS

To mitigate any potential impact oil and gas development emissions may have on regional ozone formation, the
following Best Management Practices (BMPs) would be required for any development projects:
UT-LN-99 • Tier II or better drilling rig engines
• Stationary internal combustion engine standard of 2g NOx/bhp-hr for engines <300HP and 1g NOx/bhp-hr
Statewide
for engines >300HP
• Low bleed or no bleed pneumatic pump valves
• Dehydrator VOC emission controls to +95% efficiency
• Tank VOC emission controls to +95% efficiency
AIR QUALITY
All new and replacement internal combustion gas field engines of less than or equal to 300 design-rated horsepower
UT-LN-101 must not emit more than 2 grams of NOx per horsepower-hour. This requirement does not apply to gas field
West Desert DO, Color engines of less than or equal to 40 design-rated horsepower. AND All new and replacement internal combustion
Country DO gas field engines of greater than 300 design rated horsepower must not emit more than 1.0 grams of NOx per
horsepower-hour. Modifications to the Surface Use Plan of Operations may be required in accordance with section
6 of the lease terms and 43CFR3101.1-2.
AIR QUALITY ANALYSIS
The lessee/operator is given notice that prior to project-specific approval, additional air quality analyses may be
UT-LN-102 required to comply with the National Environmental Policy Act, Federal Land Policy Management Act, and/or
other applicable laws and regulations. Analyses may include dispersion modeling and/or photochemical modeling
Statewide
for deposition and visibility impacts analysis, control equipment determinations, and/or emission inventory
development. These analyses may result in the imposition of additional project-specific air quality control
measures.
BURROWING OWL HABITAT
UT-LN-104 The lessee/operator is given notice that lands in this lease have been identified as containing Burrowing Owl
Habitat. Modification to the Surface Use Plan of Operations may be required in order to protect the Burrowing Owl
Price
and/or habitat from surface disturbing activities in accordance with Section 6 of the lease terms, Endangered
Species Act, and 43 CFR 3101.1-2.
UT-LN-107 BALD EAGLE
Statewide The Lessee/Operator is given notice that the lands in this parcel contains nesting/winter roost habitat for the bald
(Formerly eagle. The bald eagle was de-listed in 2007; however, it is still afforded protection under the Bald and Golden
120
August 2019

T&E-01) (Outside of Moab Eagle Protection Act (16 U.S.C. 668-668c, 1940). Therefore, avoidance or use restrictions may be placed on
MLP) portions of the lease. Application of appropriate measures will depend on whether the action is temporary or
permanent, and whether it occurs within or outside the bald eagle breeding or roosting season. A temporary action
is completed prior to the following breeding or roosting season leaving no permanent structures and resulting in no
permanent habitat loss. A permanent action continues for more than one breeding or roosting season and/or causes
a loss of eagle habitat or displaces eagles through disturbances, i.e. creation of a permanent structure. The following
avoidance and minimization measures have been designed to ensure activities carried out on the lease will not lead
to the need to consider listing the eagle as threatened or endangered. Integration of, and adherence to the following
measures will facilitate review and analysis of any submitted permits under the authority of this lease.
1. Surveys will be required prior to operations unless species occupancy and distribution information is
complete and available. All Surveys must be conducted by qualified individual(s), and be conducted
according to protocol.
2. Lease activities will require monitoring throughout the duration of the project. To ensure desired results are
being achieved, minimization measures will be evaluated.
4. Temporary activities within 1.0 mile of nest sites will not occur during the breeding season of January 1 to
August 31, unless the area has been surveyed according to protocol and determined to be unoccupied.
5. Temporary activities within 0.5 miles of winter roost areas, e.g., cottonwood galleries, will not occur during
the winter roost season of November 1 to March 31, unless the area has been surveyed according to protocol
and determined to be unoccupied.
8. Remove big game carrion from within 100 feet of lease roadways occurring within bald eagle foraging range.
10. Where technically and economically feasible, use directional drilling or multiple wells from the same pad to
reduce surface disturbance and eliminate drilling in suitable habitat Utilize directional drilling to avoid
direct impacts to large cottonwood gallery riparian habitats. Ensure that such directional drilling does not
11. All areas of surface disturbance within riparian areas and/or adjacent uplands should be re-vegetated with
native species.
121
August 2019

Additional measures may also be employed to avoid or minimize effects to the species between the lease sale stage
and lease development stage. These additional measures will be developed and implemented in coordination with
the U.S. Fish and Wildlife Service.
WESTERN YELLOW-BILLED CUCKOO
The Lessee/Operator is given notice that the lands in or adjacent to this parcel contain potentially suitable habitat
that falls within the range for western yellow-billed cuckoo, a federally listed species. Avoidance or use restrictions
may be placed on portions of the lease. Application of appropriate measures will depend upon whether the action is
temporary or permanent, and whether it occurs within or outside the breeding and nesting season. A temporary
action is completed prior to the following breeding season leaving no permanent structures and resulting in no
permanent habitat loss. A permanent action could continue for more than one breeding season and/or cause a loss
of habitat or displace western yellow-billed cuckoos through disturbances. The following avoidance and
minimization measures have been designed to ensure activities carried out on the lease are in compliance with the
Endangered Species Act. Integration of, and adherence to, these measures will facilitate review and analysis of any
submitted permits under the authority of this lease. Following these measures could reduce the scope of
Endangered Species Act, Section 7 consultation at the permit stage. Avoidance and minimization measures include
the following:
UT-LN-113 (Outside of 1. Habitat suitability within the parcel and/or within a 0.25 mile buffer of the parcel will be identified prior to
Moab MLP and Vernal) lease development to identify potential survey needs.
2. Protocol Breeding Season Surveys will be required in suitable habitats prior to operations unless species
occupancy and distribution information is complete and available. All Surveys must be conducted by
permitted individual(s), and be conducted according to protocol.
3. For all temporary actions that may impact cuckoo or suitable habitat:
a. If action occurs entirely outside of the cuckoo breeding season (June 1 – Aug 31), and leaves no structure
or habitat disturbance, action can proceed without a presence/absence survey.
b. If action is proposed between June 1 and August 31, presence/absence surveys for cuckoo will be
conducted prior to commencing activity. If cuckoo are detected, activity should be delayed until
September 1.
c. Eliminate access routes created by the project through such means as raking out scars, revegetation,
gating access points, etc.
4. For all permanent actions that may impact cuckoo or suitable habitat:
a. Protocol level surveys by permitted individuals will be conducted prior to commencing activities.
b. If cuckoos are detected, no activity will occur within 0.25 mile of occupied habitat.
122
August 2019

c. Avoid drilling and permanent structures within 0.25 mile of suitable habitat unless absence is determined
according to protocol level surveys conducted by permitted individual(s).
d. Ensure noise levels at 0.25 mile from suitable habitat do not exceed baseline conditions. Placement of
permanent noise-generating facilities should be determined by a noise analysis to ensure noise does not
encroach upon a 0.25 mile buffer for suitable habitat.
5. Temporary or permanent actions will require monitoring throughout the duration of the project to ensure that
western yellow-billed cuckoo or its habitat is not affected in a manner or to an extent not previous
considered. Avoidance and minimization measures will be evaluated throughout the duration of the project.
6. Water produced as a by-product of drilling or pumping will be managed to ensure maintenance or
enhancement of riparian habitat.
reduce surface disturbance and eliminate drilling in suitable habitat. Ensure that such directional drilling
does not intercept or degrade alluvial aquifers.
8. Ensure that water extraction or disposal practices do not result in change of hydrologic regime that would
result in loss or degradation of riparian habitat.
9. Re-vegetate with native species all areas of surface disturbance within riparian areas and/or adjacent uplands.
Additional measures to avoid or minimize effects to the species may be developed and implemented in consultation
with the U.S. Fish and Wildlife Service between the lease sale stage and lease development stage to ensure
continued compliance with the ESA.
123
August 2019
LIGHT AND SOUND - SENSITIVE RESOURCES

The lessee/operator may be required to utilize best management practices and the best available technology in order
to minimize/mitigate noise and light pollution impacts.In accordance with section 6 of the lease terms and 43 CFR
3101.1-2, modifications to Surface Use Plan of Operations may be required to comply with the following decisions
UT-LN-125 in the Resource Management Plans, Min 6 - Monticello Field Office RMP and Min 12 - Moab Field Office RMP to
"encourage conservation of sensitive resource values" the lessee/operator may be required to take measures to
MbFO and MtFO (Outside
minimize the impacts to the values of silence and night skies to visitors of parks, monuments, river corridors and
MLP) RFO (Wayne and
other destinations where light and/or sound impacts would mar the visitor experience. For example, the
Southeast Sevier Counties)
lessee/operator may be required to install multi-cylinder pumps, hospital sound reducing mufflers, and/or place
and PFO (Southern Emery
exhaust systems in manner that directs noise away from or reduces noise at the area. Additionally, the
County)
lessee/operator may be required to utilize such methods such as limiting the height of light poles, limiting wattage
intensity, constructing light shields and/or adhering to prescribed restrictions on the timing for conducting
artificially illuminated operations in order to minimize/mitigate light pollution impacts. However, the above
described requirements will not be applicable when their implementation would adversely affect human health and
safety.
FLOODPLAIN MANAGEMENT
UT-LN-128 The lessee/operator is given notice that, in accordance with Executive Order 11988, to avoid adverse impact to
Statewide floodplains 1) facilities should be located outside the 100 year floodplain, or 2) would be minimized or mitigated
by modification of surface use plans within floodplains present within the lease.
GRAHAM’S BEARDTONGUE (PENSTEMON GRAHAMII) & WHITE RIVER BEARDTONGUE (P.
SCARIOSUS VAR. ALBIFLUVIS) CONSERVATION AREA
This lease is subject to the management requirements set forth in the Conservation Agreement for Graham’s
Beardtongue (Penstemon grahamii) and White River Beardtongue (P. scariosus var. albifluvis) (July 2014 as
UT-LN-134
amended), to the extent this Conservation Agreement is further amended and/or in effect. Additional measures to
avoid or minimize effects to the species may be developed and implemented in consultation with the U.S. Fish and
Wildlife Service between the lease sale stage and lease development stage to ensure continued conservation of the
species.
AIR QUALITY
UT-LN-136 The lessee/operator is given notice that prior to project-specific approval, additional air quality analyses may be
Moab MLP required to comply with the National Environmental Policy Act, Federal Land Policy and Management Act, and/or
other applicable laws and regulations. Analyses may include dispersion modeling for deposition and visibility
124
August 2019

impacts analysis, control equipment determinations, and/or emission inventory development. These analyses may
result in the imposition of additional project-specific air quality control measures.
CULTURAL RESOURCES I
UT-LN-137 The lessee/operator is given notice that measures to mitigate the potential impacts to TCPs or cultural plants
identified through consultation may be required. Mitigation would be developed through further consultation with
Moab MLP
affected groups, which may include measures to maintain the viewshed and intrinsic values, as well as the auditory,
visual, and aesthetic settings of the resources.
CULTURAL RESOURCES II
The lessee/operator is given notice that a viewshed assessment would be required for those cultural sites that
UT-LN-138 receive a high degree of visitor use or properties of traditional religious and cultural importance to a Native
Moab MLP American tribe. If the assessment shows that the project would have adverse effects to the historic properties, the
project may require relocation. The Historic Properties Visual Assessment for Effect Determination Worksheet
would be utilized for the viewshed assessment.
CULTURAL RESOURCES – HIGH POTENTIAL FOR CULTURAL SITES
UT-LN-139 The lessee/operator is given notice that in areas of high potential for cultural site occurrence there is a higher
likelihood of encountering cultural resource concerns (i.e., potential adverse effects) that may require
Moab MLP
archaeological monitoring, ethnographic data collection, data recovery, and mitigation of historic properties in
order to exercise lease rights.
RAPTORS
The lessee/operator is given notice that appropriate seasonal and spatial buffers shall be placed on all known raptor
nests in accordance with Utah Field Office Guidelines for Raptor Protection from Human and Land use
Disturbances (USFWS 2002) and BMPs for Raptors and their Associated Habitats in Utah (BLM 2006). All
construction-related activities will not occur within these buffers if pre-construction monitoring indicates the nests
UT-LN-143 are active, unless a site specific evaluation(survey) for active nests is completed prior to construction and if a BLM
wildlife biologist, in consultation with USFWS and UDWR, recommends that activities may be permitted within
Moab MLP
the buffer. The BLM will coordinate with the USFWS and UDWR and have a recommendation within 3 to 5 days
of notification. Any construction activities authorized within a protective (spatial and seasonal) buffer for raptors
will require an onsite monitor. Any indication that activities are adversely affecting the raptor and/or its young the
onsite monitor will suspend activities and contact the BLM Authorized Officer immediately. Construction may
occur within the buffers of inactive nests. Construction activities may commence once monitoring of the active nest
site determines that fledglings have left the nest and are no longer dependent on the nest site. Modifications to the
125
August 2019

Surface Use Plan of Operations may be required in accordance with Section 6 of the lease terms and 43CFR3101.1-
2.
MIGRATORY BIRDS
The lessee/operator is given notice that surveys for nesting migratory birds may be required during migratory bird
UT-LN-144 breeding season (April 1 to July 31) whenever surface disturbances and/or occupancy is proposed in association
Moab MLP with mineral exploration and development within priority habitats. Surveys should focus on identified priority bird
species in Utah. Field surveys will be conducted as determined by the Authorized Officer of the BLM. Based on the
result of the field survey, the Authorized Officer will determine appropriate buffers and timing limitations.
KIT FOX HABITAT
UT-LN-147
The lessee/operator is given notice that no surface disturbances would be allowed within 660 feet (200 meters) of
Moab MLP
an occupied natal kit fox den.
POLLINATORS AND POLLINATOR HABITAT
In order to protect pollinators and pollinator habitat, in accordance with BLM policy outlined in Instruction
Memorandum No. 2016-013, Managing for Pollinators on Public Lands, and Pollinator-Friendly Best Management
Practices for Federal Lands (2015), the following avoidance, minimization, and mitigation measures would apply to
this parcel:
1. Give a preference for placing well pads in previously disturbed areas, dry areas that do not support forbs, or
areas dominated by nonnative grasses.
UT-LN-156
2. Utilize existing well pads where feasible.
Statewide 3. Avoid disturbance to native milkweed patches within Monarch migration routes to protect Monarch butterfly
(Based on the September habitat.
2018 San Rafael EA 4. Avoid disturbance of riparian and meadow sites, as well as small depressed areas that may function as water
DOI-BLM-UT-0000-2018- catchments and host nectar-producing species, to protect Monarch butterfly habitat and nectaring sites.
0001-EA 5. Minimize the use of pesticides that negatively impact pollinators.
6. During revegetation treatments:
a. Use minimum till drills where feasible.
b. Include pollinator-friendly site-appropriate native plant seeds or seedlings in seed mixes.
c. Where possible, increase the cover and diversity of essential habitat components for native pollinators
by:
 Using site-appropriate milkweed seeds or seedlings within Monarch migration routes through
priority sage-grouse habitat.
126
August 2019

 Using seed mixes with annual and short-lived perennial native forbs that will bloom the first year
and provide forage for pollinators.
 Using seed mixes with a variety of native forb species to ensure different colored and shaped
flowers to provide nectar and pollen throughout the growing season for a variety of pollinators.
 Seeding forbs in separate rows from grasses to avoid competition during establishment.
 Avoiding seeding non-native forbs and grasses that establish early and out compete slower-growing
natives.
SAN RAFAEL SWELL SRMA
The lessee/operator is given notice that this lease occurs within the San Rafael Swell Special Recreation
Management Area (SRMA). The Price Field Office Resource Management Plan (RMP) requires the SRMA to be
managed to provide the following benefits, experiences, and opportunities: undeveloped recreation tourism with
UT-LN-157 portions that are destination strategy associated with OHV routes (REC-11: Within SRMAs, manage for Recreation
Price Opportunity Spectrum (ROS), as identified in the ROS inventory. Recreation facilities will be developed only in
(Based on RMP) response to resource management needs and will be appropriate to the managerial setting identified for each ROS
class). Development that interferes with the SRMAs goals and objectives should be avoided to the extent
practicable. Modifications to the Surface Use Plan of Operations may be required in order to protect remote,
expansive, intact landscapes from surface disturbing activities in accordance with section 6 of the lease terms and
43 CFR 3110.1-2.
127
August 2019
Threatened and Endangered Species Notices
NUMBER THREATENED & ENDANGERED SPECIES NOTICES
ENDANGERED FISH OF THE UPPER COLORADO RIVER DRAINAGE BASIN

The Lessee/Operator is given notice that the lands in this parcel contain Critical Habitat for the Colorado River fish
(bonytail, humpback chub, Colorado pike minnow, and razorback sucker) listed as endangered under the Endangered
Species Act, or these parcels have watersheds that are tributary to designated habitat. Critical habitat was designated
for the four endangered Colorado River fishes on March 21, 1994(59 FR 13374-13400). Designated critical habitat for
all the endangered fishes includes those portions of the 100-year floodplain that contain primary constituent elements
necessary for survival of the species. Avoidance or use restrictions may be placed on portions of the lease. The
following avoidance and minimization measures have been designed to ensure activities carried out on the lease are in
compliance with the Endangered Species Act. Integration of and adherence to these measures will facilitate review and
analysis of any submitted permits under the authority of this lease. Following these measures could reduce the scope of
Endangered Species Act, Section 7 consultation at the permit stage. Current avoidance and minimization measures
include the following:
1. Surveys will be required prior to operations unless species occupancy and distribution information is complete
T&E-03 and available. All surveys must be conducted by qualified individual(s).
Price, 2. Lease activities will require monitoring throughout the duration of the project. To ensure desired results are
Vernal being achieved, minimization measures will be evaluated and, if necessary, Section 7 consultation reinitiated.
4. Avoid loss or disturbance of riparian habitats.
reduce surface disturbance and eliminate drilling in suitable riparian habitat. Ensure that such directional drilling
6. Conduct watershed analysis for leases in designated critical habitat and overlapping major tributaries in order to
determine toxicity risk from permanent facilities.
7. Implement Appendix B (Hydrologic Considerations for Pipeline Crossing Stream Channels, Technical Note
423).
8. Drilling will not occur within 100 year floodplains of rivers or tributaries to rivers that contain listed fish species
or critical habitat.
9. In areas adjacent to 100-year flood plains, particularly in systems prone to flash floods, analyze the risk for flash
floods to impact facilities, and use closed loop drilling, and pipeline burial or suspension according to Appendix
128
August 2019

B (Hydrologic Considerations for Pipeline Crossing Stream Channels, Technical Note 423, to minimize the
potential for equipment damage and resulting leaks or spills.
Water depletions from any portion of the Upper Colorado River drainage basin above Lake Powell are considered to
adversely affect or adversely modify the critical habitat of the four resident endangered fish species, and must be
evaluated with regard to the criteria described in the Upper Colorado River Endangered Fish Recovery Program.
Formal consultation with USFWS is required for all depletions. All depletion amounts must be reported to BLM.
with the U.S. Fish and Wildlife Service between the lease sale stage and lease development stage to ensure continued
compliance with the ESA.
LISTED PLANT SPECIES
The Lessee/Operator is given notice that the lands in this parcel contain suitable habitat for federally listed plant
species under the Endangered Species Act. The following avoidance and minimization measures have been developed
to facilitate review and analysis of any submitted permits under the authority of this lease
1. Site inventories:
a. Must be conducted to determine habitat suitability,
b. Are required in known or potential habitat for all areas proposed for surface disturbance prior to initiation of
project activities, at a time when the plant can be detected, and during appropriate flowering periods,
c. Documentation should include, but not be limited to individual plant locations and suitable habitat
distributions, and
d. All surveys must be conducted by qualified individuals.
T&E-05
being achieved, minimization measures will be evaluated and, if necessary, Section 7 consultation reinitiated.
3. Project activities must be designed to avoid direct disturbance to populations and to individual plants:
a. Designs will avoid concentrating water flows or sediments into plant occupied habitat.
b. Construction will occur down slope of plants and populations where feasible; if well pads and roads must be
sited upslope, buffers of 300 feet minimum between surface disturbances and plants and populations will be
incorporated.
c. Where populations occur within 300 ft. of well pads, establish a buffer or fence the individuals or groups of
individuals during and post-construction.
d. Areas for avoidance will be visually identifiable in the field, e.g., flagging, temporary fencing, rebar, etc.
e. For surface pipelines, use a 10 foot buffer from any plant locations:
129
August 2019

f. If on a slope, use stabilizing construction techniques to ensure the pipelines don’t move towards the
population.
4. For riparian/wetland-associated species, e.g. Ute ladies-tresses, avoid loss or disturbance of riparian habitats.
5. Ensure that water extraction or disposal practices do not result in change of hydrologic regime.
8. Place signing to limit ATV travel in sensitive areas.
9. Implement dust abatement practices near occupied plant habitat.
10. All disturbed areas will be re-vegetated with native species comprised of species indigenous to the area.
11. Post construction monitoring for invasive species will be required.
reduce surface disturbance and eliminate drilling in plant habitat. Ensure that such directional drilling does not
compliance with the Endangered Species Act.
MEXICAN SPOTTED OWL
The Lessee/Operator is given notice that the lands in this parcel contain suitable habitat for Mexican spotted owl, a
federally listed species. The Lessee/Operator is given notice that the lands in this lease contain Designated Critical
Habitat for the Mexican spotted owl, a federally listed species. Critical habitat was designated for the Mexican spotted
owl on August 31, 2004 (69 FR 53181-53298). Avoidance or use restrictions may be placed on portions of the lease.
Application of appropriate measures will depend whether the action is temporary or permanent, and whether it occurs
T&E-06 (Outside
within or outside the owl nesting season.
Moab MLP)
A temporary action is completed prior to the following breeding season leaving no permanent structures and resulting
in no permanent habitat loss. A permanent action continues for more than one breeding season and/or causes a loss of
owl habitat or displaces owls through disturbances, i.e. creation of a permanent structure.
The following avoidance and minimization measures have been designed to ensure activities carried out on the lease
are in compliance with the Endangered Species Act. Integration of, and adherence to these measures, will facilitate
review and analysis of any submitted permits under the authority of this lease. Following these measures could reduce
130
August 2019

the scope of Endangered Species Act, Section 7 consultation at the permit stage. Current avoidance and minimization
measures include the following:
and available. All Surveys must be conducted by qualified individual(s).
2. Assess habitat suitability for both nesting and foraging using accepted habitat models in conjunction with field
reviews. Apply the conservation measures below if project activities occur within 0.5 mile of suitable owl
habitat. Determine potential effects of actions to owls and their habitat.
a. Document type of activity, acreage and location of direct habitat impacts, type and extent of indirect impacts
relative to location of suitable owl habitat.
b. Document if action is temporary or permanent.
reduce surface disturbance and eliminate drilling in canyon habitat suitable for Mexican spotted owl nesting.
6. For all temporary actions that may impact owls or suitable habitat:
a. If the action occurs entirely outside of the owl breeding season (March 1 – August 31), and leaves no
permanent structure or permanent habitat disturbance, action can proceed without an occupancy survey.
b. If action will occur during a breeding season, survey for owls prior to commencing activity. If owls are
found, activity must be delayed until outside of the breeding season.
c. Rehabilitate access routes created by the project through such means as raking out scars, re-vegetation,
gating access points, etc.
7. For all permanent actions that may impact owls or suitable habitat:
a. Survey two consecutive years for owls according to accepted protocol prior to commencing activities.
b. If owls are found, no actions will occur within 0.5 mile of identified nest site. If nest site is unknown, no
activity will occur within the designated Protected Activity Center (PAC).
c. Avoid drilling and permanent structures within 0.5 mi of suitable habitat unless surveyed and not occupied.
d. Reduce noise emissions (e.g., use hospital-grade mufflers) to 45 dBA at 0.5 mile from suitable habitat,
including canyon rims. Placement of permanent noise-generating facilities should be determined by a noise
analysis to ensure noise does not encroach upon a 0.5 mile buffer for suitable habitat, including canyon rims.
e. Limit disturbances to and within suitable habitat by staying on approved routes.
f. Limit new access routes created by the project.
131
August 2019

compliance with the Endangered Species Act.
SOUTHWESTERN WILLOW FLYCATCHER
The Lessee/Operator is given notice that the lands in this parcel contains riparian habitat that falls within the range for
southwestern willow flycatcher (Empidonax traillii extimus), a federally listed species. Avoidance or use restrictions
may be placed on portions of the lease. Application of appropriate measures will depend whether the action is
temporary or permanent, and whether it occurs within or outside the nesting season. A temporary action is completed
prior to the following breeding season leaving no permanent structures and resulting in no permanent habitat loss. A
permanent action continues for more than one breeding season and/or causes a loss of habitat or displaces flycatchers
through disturbances, i.e. creation of a permanent structure. The following avoidance and minimization measures have
been designed to ensure activities carried out on the lease are in compliance with the Endangered Species Act.
Integration of, and adherence to these measures, will facilitate review and analysis of any submitted permits under the
authority of this lease. Following these measures could reduce the scope of Endangered Species Act, Section 7
consultation at the permit stage. Current avoidance and minimization measures include the following:
T&E-07 and available. All Surveys must be conducted by qualified individual(s), and be conducted according to protocol.
(Outside Moab 2. Lease activities will require monitoring throughout the duration of the project. To ensure desired results are
MLP) being achieved, minimization measures will be evaluated and, if necessary, Section 7 consultation reinitiated.
reduce surface disturbance and eliminate drilling in suitable riparian habitat. Ensure that such directional drilling
5. Drilling activities will maintain a 300 ft. buffer from suitable riparian habitat year long.
6. Drilling activities within 0.25 mile of occupied breeding habitat will not occur during the breeding season of
May 1 to August 15.
7. Ensure that water extraction or disposal practices do not result in change of hydrologic regime that would result
in loss or degradation of riparian habitat.
8. Re-vegetate with native species all areas of surface disturbance within riparian areas and/or adjacent uplands.
132
August 2019
UTAH PRAIRIE DOG

The lessee/operator is given notice that lands in this lease may contain historic and/or occupied Utah prairie dog
habitat, a threatened species under the Endangered Species Act. Avoidance or use restrictions may be placed on
portions of the lease. Application of appropriate measures will depend whether the action is temporary or permanent,
and whether it occurs when prairie dogs are active or hibernating. A temporary action is completed prior to the
following active season leaving no permanent structures and resulting in no permanent habitat loss. A permanent action
continues for more than one activity/hibernation season and/or causes a loss of Utah prairie dog habitat or displaces
prairie dogs through disturbances, i.e. creation of a permanent structure. The following avoidance and minimization
measures have been designed to ensure activities carried out on the lease are in compliance with the Endangered
Species Act. Integration of, and adherence to these measures will facilitate review and analysis of any submitted
permits under the authority of this lease. Following these measures could reduce the scope of Endangered Species Act,
Section 7 consultation at the permit stage. Current avoidance and minimization measures include the following:
and available. All Surveys must be conducted by qualified individual(s).
T&E-09 being achieved, minimization measures will be evaluated and, if necessary, Section 7 consultation reinitiated.
reduce surface disturbance and eliminate drilling in prairie dog habitat.
4. Surface occupancy or other surface disturbing activity will be avoided within 0.5 mile of active prairie dog
colonies.
5. Permanent surface disturbance or facilities will be avoided within 0.5 mile of potentially suitable, unoccupied
prairie dog habitat, identified and mapped by Utah Division of Wildlife Resources since 1976.
6. The lessee/operator should consider if fencing infrastructure on well pad, e.g., drill pads, tank batteries, and
compressors, would be needed to protect equipment from burrowing activities. In addition, the operator should
consider if future surface disturbing activities would be required at the site.
7. Within occupied habitat, set a 25 mph speed limit on operator-created and maintained roads.
133
August 2019
CALIFORNIA CONDOR
The Lessee/Operator is given notice that the lands located in this parcel contain potential habitat for the California
Condor, a federally listed species. Avoidance or use restrictions may be placed on portions of the lease if the area is
known or suspected to be used by condors. Application of appropriate measures will depend on whether the action is
temporary or permanent, and whether it occurs within or outside potential habitat. A temporary action is completed
prior to the following important season of use, leaving no permanent structures and resulting in no permanent habitat
loss. This would include consideration for habitat functionality. A permanent action continues for more than one
season of habitat use, and/or causes a loss of condor habitat function or displaces condors through continued
disturbance (i.e. creation of a permanent structure requiring repetitious maintenance, or emits disruptive levels of
noise).
The following avoidance and minimization measures have been designed to ensure activities carried out on the lease
are in compliance with the Endangered Species Act. Integration of, and adherence to these measures will facilitate
review and analysis of any submitted permits under the authority of this lease. Following these measures could reduce
the scope of Endangered Species Act, Section 7 consultation at the permit stage. Current avoidance and minimization
measures include the following:
T&E-11 (Outside 1. Surveys will be required prior to operations unless species occupancy and distribution information is complete
Moab MLP) and available. All Surveys must be conducted by qualified individual(s) approved by the BLM, and must be
conducted according to approved protocol.
2. If surveys result in positive identification of condor use, all lease activities will require monitoring throughout
the duration of the project to ensure desired results of applied mitigation and protection. Minimization measures
will be evaluated during development and, if necessary, Section 7 consultation may be reinitiated.
4. Temporary activities within 0.5 miles of established roosting sites or areas will not occur during the season of
use, August 1 to November 31, unless the area has been surveyed according to protocol and determined to be
unoccupied.
7. Remove big game carrion 100 feet from lease roadways occurring within foraging range.
reduce surface disturbance and eliminate drilling in suitable habitat. Utilize directional drilling to avoid direct
impacts to large cottonwood gallery riparian habitats. Ensure that such directional drilling does not intercept or
degrade alluvial aquifers.
134
August 2019

employed to avoid or minimize effects to the species. These additional measures will be developed and
implemented in consultation with the U.S. Fish and Wildlife Service to ensure continued compliance with the
ESA.
development stages. These additional measures will be developed and implemented in consultation with the U.S. Fish
and Wildlife Service to ensure continued compliance with the Endangered Species Act.
PARIETTE CACTUS (SCLEROCACTUS BREVISPINUS) AND UINTA BASIN HOOKLESS CACTUS
[SCLEROCACTUS GLAUCUS (BREVISPINUS AND WETLANDICUS)]
The Lessee/Operator is given notice that the lands in this parcel contain suitable habitat for the Pariette cactus and
Uinta Basin hookless cactus, under the Endangered Species Act (ESA). The following avoidance and minimization
measures have been developed to facilitate review and analysis of any submitted permits under the authority of this
lease.
In order to minimize effects to the federally threatened Pariette cactus and Uinta Basin hookless cactus, the BLM in
coordination with the USFWS, developed the following avoidance and minimization measures. Integration of and
adherence to these measures will help ensure the activities carried out during oil and gas development (including but
not limited to drilling, production, and maintenance) are in compliance with the ESA. For the purposes of this
document, the following terms are so defined: Potential habitat is defined as areas which satisfy the broad criteria of
T&E-12 the species habitat description; usually determined by preliminary, in-house assessment. Suitable habitat is defined as
areas which contain or exhibit the specific components or constituents necessary for plant persistence; determined by
field inspection and/or surveys; may or may not contain Uinta Basin hookless cactus. Habitat descriptions can be found
in the U.S. Fish and Wildlife Service’s 1990 Recovery Plan and Federal Register Notices for the Uinta Basin hookless
cactus (http://www.fws.gov/endangered/wildlife.html). Occupied habitat is defined as areas currently or historically
known to support Uinta Basin hookless cactus; synonymous with “known habitat.” The following avoidance and
minimization measures should be included in the Plan of Development:
1. Pre-project habitat assessments will be completed across 100% of the project disturbance area within potential
habitat prior to any ground disturbing activities to determine if suitable Pariette cactus and Uinta Basin hookless
cactus habitat is present.
2. Within suitable habitat, site inventories will be conducted to determine occupancy. Inventories:
a. Must be conducted by qualified individual(s) and according to BLM and Service accepted survey protocols,
135
August 2019

b. Will be conducted in suitable and occupied habitat for all areas proposed for surface disturbance prior to
initiation of project activities and within the same growing season, at a time when the plant can be detected,
and during appropriate flowering periods:
i. Sclerocactus brevispinus surveys should be conducted March 15th to June 30th, unless extended by the
BLM
ii. Sclerocactus wetlandicus surveys can be done any time of the year, provided there is no snow cover,
c. Will occur within 300’ from the edge of the proposed right-of-way for surface pipelines or roads; and within
300’ from the perimeter of disturbance for the proposed well pad including the well pad,
e. Will be valid until March 15th the following year for Sclerocactus brevispinus and one year from the survey
date for Sclerocactus wetlandicus.
a. Reduce well pad size to the minimum needed, without compromising safety,
b. Limit new access routes created by the project,
c. Roads and utilities should share common right-of-ways where possible,
d. Reduce width of right-of-ways and minimize the depth of excavation needed for the road bed; where
e. Place signing to limit off-road travel in sensitive areas,
f. Stay on designated routes and other cleared/approved areas, and
g. All disturbed areas will be re-vegetated with native species comprised of species indigenous to the area and
non-native species that are not likely to invade other areas.
a. Follow the above (3.) recommendations for project design within suitable habitats,
b. Buffers of 300 feet minimum between the edge of the right of way (roads and surface pipelines) or surface
disturbance (well pads) and plants and populations will be incorporated,
c. Surface pipelines will be laid such that a 300 foot buffer exists between the edge of the right of way and the
plants, use stabilizing and anchoring techniques when the pipeline crosses the habitat to ensure the pipelines
don’t move towards the population,
d. Before and during construction, areas for avoidance should be visually identifiable in the field (e.g., flagging,
temporary fencing, rebar, etc.),
e. Where technically and economically feasible, use directional drilling or multiple wells from the same pad,
f. Designs will avoid concentrating water flows or sediments into occupied habitat,
136
August 2019

g. Place produced oil, water, or condensate tanks in centralized locations, away from occupied habitat, and
h. Minimize the disturbed area of producing well locations through interim and final reclamation. Reclaim well
pads following drilling to the smallest area possible.
5. Occupied Pariette cactus and Uinta Basin hookless cactus habitats within 300’ of the edge of the surface
pipelines’ right-of-ways, 300’ of the edge of the roads’ right-of-ways, and 100’ from the edge of the well pad
shall be monitored for a period of three years after ground disturbing activities. Monitoring will include annual
plant surveys to determine plant and habitat impacts relative to project facilities. Annual reports shall be
provided to the BLM and the USFWS. To ensure desired results are being achieved, minimization measures will
be evaluated and may be changed after a thorough review of the monitoring results and annual reports during
annual meetings between the BLM and the USFWS.
6. Re-initiation of Section 7 consultation with the USFWS will be sought immediately if any loss of plants or
occupied habitat for the Pariette cactus and Uinta Basin hookless cactus is anticipated as a result of project
activities.
7. The lessee will observe the management and conservation measures developed for the Level 1 and 2 Core
Conservation Areas that have been identified by the USFWS. These conservation measures include disturbance
caps (no further disturbance in Core 1 Areas and a 5% disturbance cap in Core 2 Areas).
Additional site-specific measures may also be employed to avoid or minimize effects to the species. These additional
measures will be developed and implemented in consultation with the USFWS to ensure continued compliance with
the ESA.
BARNEBY REED MUSTARD (Schoenocrambe Barnebyi)
In order to minimize effects to the federally threatened Barneby Reed Mustard, the Bureau of Land Management
(BLM), in coordination with the U.S. Fish and Wildlife Service (Service), has developed the following avoidance and
minimization measures. Implementation of these measures will help ensure the activities carried out during oil and gas
development (including but not limited to drilling, production, and maintenance operations) are in compliance with the
T&E-13 endangered Species Act (ESA). For the purposes of this document, the following terms are so defined: Potential
habitat is defined as areas which satisfy the broad criteria of the species habitat description; usually determined by
preliminary, in-house assessment. Suitable habitat is defined as areas which contain or exhibit the specific components
or constituents necessary for plant persistence; determined by field inspection and/or surveys; may or may not contain
Barneby Reed Mustard; habitat descriptions can be found in Federal Register Notice and species recovery plan links at
<http:www.fws.gov/endangered/wildlife.html>.
137
August 2019

Occupied habitat is defined as areas currently or historically known to support Barneby Reed Mustard; synonymous
with “known habitat.” The following avoidance and minimization measures should be included in the Plan of
Development:
habitat1 prior to any ground disturbing activities (including ATV use) to determine if suitable Barneby Reed
Mustard habitat is present.
2. Site inventories will be conducted within suitable habitat to determine occupancy. Where standard surveys are
technically infeasible and otherwise hazardous due to topography, slope, etc. suitable habitat will be assessed
and mapped for avoidance (hereafter, “avoidance areas”); in such cases, in general, 300’ buffers will be
maintained between surface disturbance and avoidance areas. However, site-specific distances will need to be
approved by FWS and BLM when disturbance will occur upslope of habitat. Where conditions allow,
inventories:
a. Must be conducted by qualified individuals(s) and according to BLM and Service accept survey protocols,
initiation of project activities and within the same growing season, at a time when the plant can be detected
(usually April 15th to June 5th, however, surveyors should verify that the plant is flowering by contacting a
BLM or FWS botanist or demonstrating that the nearest known population is in flower),
c. Will occur within 300’ from the centerline of the proposed right-of-way for surface pipelines or roads; and
within 300’ from the perimeter of disturbance for the proposed well pad including the well pad,
3. Design project infrastructure to minimize impacts within suitable habitat:
a. Where standard surveys are technically infeasible, infrastructure and activities will avoid all suitable habitat
(voidance areas) and incorporate 300’ buffers, in general; however, site-specific distances will need to be
approved by FWS and BLM when disturbance will occur upslope of habitat,
b. Reduce well pad size to the minimum needed, without compromising safety,
c. Where technically and economically feasible, use directional drilling or multiple wells from the samepad,
d. Limit new access routes created by the project,
e. Roads and utilities should share common right-of-ways where possible,
f. Reduce the width of right-of-ways and minimize the depth of excavation needed for the road bed; where
g. Place signing to limit off-road travel in sensitive areas, and
h. Stay on designated routes and other cleared/approved areas,
138
August 2019

i. All disturbed areas will be revegetated with native species comprised of species indigenous to the area and
4. Within occupied habitat, project infrastructure will be designed to avoid direct disturbance and minimize indirect
impacts to populations and to individual plants:
a. Follow the above recommendations (3.) for project design within suitable habitats,
b. To avoid water flow and/or sedimentation into occupied habitat and avoidance areas, silt fences, hay bales,
and similar structures or practices will be incorporated into the project design; appropriate placement of fill
is encouraged,
c. Construction of roads will occur such that the edge of the right of way is at least 300’ from any plant and
300’ from avoidance areas,
d. Roads will be graveled with occupied habitat; the operator is encouraged to apply water for dust abatement
to such areas from April 15th to June 5th (flowering period); dust abatement applications will be comprised of
water only,
e. The edge of the well pad should be located at least 300’ away from plants and avoidance areas, in general;
however, site-specific distances will need to be approved by FWS and BLM when disturbance will occur
upslope of habitat,
f. Surface pipelines will be laid such that a 300’ buffer exists between the edge of the right of way and plants
and 300’ between the edge of right of way and avoidance areas; use stabilizing and anchoring techniques
when the pipeline crossed suitable habitat to ensure pipelines don’t move towards the population; site-
specific distances will need to be approved by FWS and BLM when disturbance will occur upslope of
habitat,
g. Construction activities will not occur from April 15th through June 5th within occupied habitat,
h. Before and during construction, areas for avoidance should be visually identifiable in the field, e.g., flagging
temporary fencing, rebar, etc.,
i. Place produced oil, water, or condensate tanks in centralized locations, away from occupied habitat, and
j. Minimize the disturbed area of producing well locations through interim and final reclamation. Reclaim well
5. Occupied Barneby Reed Mustard habitats within 300’ of the edge of the surface pipelines’ right-of-ways, 300’ of
the edge of the roads’ right-of-ways, and 300’ from the edge of the well pad shall be monitored for a period of
three years after ground disturbing activities. Monitoring will include annual plant surveys to determine plant
and habitat impacts relative to project facilities. Annual reports shall be provided to the BLM and the Service.
To ensure desired results are being achieved, minimization measures will be evaluated and may be changed after
a thorough review of the monitoring results and annual reports during annual meetings between the BLM and the
Service.
139
August 2019

6. Re-initiation of section 7 consultation with the Service will be sought immediately if any loss of plants or
occupied habitat for the Barneby Reed Mustard is anticipated as a result of project activities.
measures will be developed and implemented in consultation with the U.S. Fish and Wildlife Service to ensure
LAST CHANCE TOWNSENDIA (TOWNSENDIA APRICA)
In order to minimize effects to the federally threatened Last Chance Townsendia, the Bureau of Land Management
endangered Species Act (ESA). For the purposes of this document, the following terms are so defined: Potential
Last Chance Townsendia; habitat descriptions can be found in Federal Register Notice and species recovery plan links
at <http:www.fws.gov/endangered/wildlife.html>. Occupied habitat is defined as areas currently or historically known
to support Last Chance Townsendia; synonymous with “known habitat.” The following avoidance and minimization
measures should be included in the Plan of Development:
T&E-14 1. Pre-project habitat assessments will be completed across 100% of the project disturbance area within potential
habitat1 prior to any ground disturbing activities (including ATV use) to determine if suitable Last Chance
Townsendia habitat is present.
technically infeasible and otherwise hazardous due to topography, slope, etc., suitable habitat will be assessed
inventories:
140
August 2019

c. Where technically and economically feasible, use directional drilling or multiple wells from the same pad,
i. All disturbed areas will be re-vegetated with native species comprised of species indigenous to the area and
is encouraged,
water only,
upslope of habitat,
141
August 2019

habitat,
j. Minimize the disturbed area of producing well locations through interim and final reclamation. Reclaim
5. Occupied Last Chance Townsendia habitats within 300’ of the edge of the surface pipelines’ right-of-ways, 300’
of the edge of the roads’ right-of-ways, and 300’ from the edge of the well pad shall be monitored for a period of
Service.
occupied habitat for the Last Chance Townsendia is anticipated as a result of project activities.
WRIGHT FISHHOOK CACTUS (SCLEROCACTUS WRIGHTIAE)
In order to minimize effects to the federally threatened Wright Fishhook Cactus, the Bureau of Land Management
T&E-15 endangered Species Act (ESA). For the purposes of this document, the following terms are so defined: Potential
Wright Fishhook Cactus; habitat descriptions can be found in Federal Register Notice and species recovery plan links
at <http:www.fws.gov/endangered/wildlife.html>. Occupied habitat is defined as areas currently or historically known
142
August 2019

to support Wright Fishhook Cactus; synonymous with “known habitat.” The following avoidance and minimization
habitat1 prior to any ground disturbing activities (including ATV use) to determine if suitable Wright Fishhook
Cactus habitat is present.
inventories:
i. All disturbed areas will be revegetated with native species comprised of species indigenous to the area and
143
August 2019

is encouraged,
water only,
upslope of habitat,
habitat,
5. Occupied Wright Fishhook Cactus habitats within 300’ of the edge of the surface pipelines’ right-of-ways, 300’
of the edge of the roads’ right-of-ways, and 300’ from the edge of the well pad shall be monitored for a period of
Service.
occupied habitat for the Wright Fishhook Cactus is anticipated as a result of project activities.
144
August 2019

WINKLER PINCUSHION CACTUS (PEDIOCACTUS WINKLERI)
In order to minimize effects to the federally threatened Winkler Pincushion Cactus, the Bureau of Land Management
Winkler Pincushion Cactus; habitat descriptions can be found in Federal Register Notice and species recovery plan
links at <http:www.fws.gov/endangered/wildlife.html>. Occupied habitat is defined as areas currently or historically
known to support Winkler Pincushion Cactus; synonymous with “known habitat.” The following avoidance and
minimization measures should be included in the Plan of Development:
T&E-16 habitat1 prior to any ground disturbing activities (including ATV use) to determine if suitable Winkler
Pincushion Cactus habitat is present.
inventories:
145
August 2019

is encouraged,
water only,
upslope of habitat,
habitat,
146
August 2019

5. Occupied Winkler Pincushion Cactus habitats within 300’ of the edge of the surface pipelines’ right-of-ways,
300’ of the edge of the roads’ right-of-ways, and 300’ from the edge of the well pad shall be monitored for a
and the Service. To ensure desired results are being achieved, minimization measures will be evaluated and may
be changed after a thorough review of the monitoring results and annual reports during annual meetings between
the BLM and the Service.
occupied habitat for the Winkler Pincushion Cactus is anticipated as a result of project activities.
SAN RAFAEL CACTUS (PEDIOCACTUS DESPAINII)
In order to minimize effects to the federally threatened San Rafael Cactus, the Bureau of Land Management (BLM), in
coordination with the U.S. Fish and Wildlife Service (Service), has developed the following avoidance and
T&E-17 habitat is defined as areas which satisfy the broad criteria of the species habitat description; usually determined by
San Rafael Cactus; habitat descriptions can be found in Federal Register Notice and species recovery plan links at
<http:www.fws.gov/endangered/wildlife.html>. Occupied habitat is defined as areas currently or historically known to
support San Rafael Cactus; synonymous with “known habitat.” The following avoidance and minimization measures
should be included in the Plan of Development:
147
August 2019

habitat1 prior to any ground disturbing activities (including ATV use) to determine if suitable San Rafael Cactus
habitat is present.
inventories:
148
August 2019

is encouraged,
water only,
upslope of habitat,
habitat,
5. Occupied San Rafael Cactus habitats within 300’ of the edge of the surface pipelines’ right-of-ways, 300’ of the
edge of the roads’ right-of-ways, and 300’ from the edge of the well pad shall be monitored for a period of three
years after ground disturbing activities. Monitoring will include annual plant surveys to determine plant and
habitat impacts relative to project facilities. Annual reports shall be provided to the BLM and the Service. To
ensure desired results are being achieved, minimization measures will be evaluated and may be changed after a
thorough review of the monitoring results and annual reports during annual meetings between the BLM and the
Service.
occupied habitat for the San Rafael Cactus is anticipated as a result of project activities.
149
August 2019

JONES CYCLADENIA (CYCLADENIA HYMILIS VAR JONESII)
In order to minimize effects to the federally threatened Jones Cycladenia, the Bureau of Land Management (BLM), in
coordination with the U.S. Fish and Wildlife Service (Service), has developed the following avoidance and
Jones Cycladenia; habitat descriptions can be found in Federal Register Notice and species recovery plan links at
<http:www.fws.gov/endangered/wildlife.html>. Occupied habitat is defined as areas currently or historically known to
support Jones Cycladenia; synonymous with “known habitat.” The following avoidance and minimization measures
T&E-19 (Outside habitat1 prior to any ground disturbing activities (including ATV use) to determine if suitable Jones Cycladenia
Moab MLP) habitat is present.
inventories:
150
August 2019

is encouraged,
water only,
upslope of habitat,
habitat,
151
August 2019

j. Minimize the disturbed area of producing well locations through interim and final reclamation. Reclaim
5. Occupied Jones Cycladenia habitats within 300’ of the edge of the surface pipelines’ right-of-ways, 300’ of the
edge of the roads’ right-of-ways, and 300’ from the edge of the well pad shall be monitored for a period of three
years after ground disturbing activities. Monitoring will include annual plant surveys to determine plant and
habitat impacts relative to project facilities. Annual reports shall be provided to the BLM and the Service. To
ensure desired results are being achieved, minimization measures will be evaluated and may be changed after a
thorough review of the monitoring results and annual reports during annual meetings between the BLM and the
Service.
occupied habitat for the Jones Cycladenia is anticipated as a result of project activities.
CLAY REED - MUSTARD (SCHOENCRAMBE ARGILLACEA)
The Lessee/Operator is given notice that the lands in this parcel contain suitable habitat for clay reed-mustard under the
Endangered Species Act. The following avoidance and minimization measures have been developed to facilitate
review and analysis of any submitted permits under the authority of this lease:
In order to minimize effects to the federally threatened clay reed-mustard, the Bureau of Land Management (BLM) in
coordination with the U.S. Fish and Wildlife Service (Service) developed the following avoidance and minimization
T&E-20 measures. Integration of and adherence to these measures will help ensure the activities carried out during oil and gas
development (including but not limited to drilling, production, and maintenance) are in compliance with the
Endangered Species Act (ESA). For the purposes of this document, the following terms are so defined: Potential
clay reed-mustard; habitat descriptions can be found in Federal Register Notice and species recovery plan links at
<http://www.fws.gov/endangered/wildlife.html>. Occupied habitat is defined as areas currently or historically known
152
August 2019

to support clay reed-mustard; synonymous with “known habitat.” The following avoidance and minimization measures
habitat prior to any ground disturbing activities to determine if suitable clay reed-mustard habitat is present.
technically infeasible and otherwise hazardous due to topography, slope, etc., suitable habitat will be assessed
and mapped for avoidance (hereafter, “avoidance areas”); in such cases, in general, 300-foot buffers will be
inventories:
a. Must be conducted by qualified individual(s) and according to BLM and Service accepted survey protocols,
(usually May 1st to June 5th, in the Uintah Basin; however, surveyors should verify that the plant is flowering
by contacting a BLM or FWS botanist or demonstrating that the nearest known population is in flower),
c. Will occur within 300 feet from the edge of the proposed right-of-way for surface pipelines or roads; and
within 300 feet from the perimeter of disturbance for the proposed well pad including the well pad,
e. Will be valid until May 1st the following year.
(avoidance areas) and incorporate 300-foot buffers, in general; however, site-specific distances will need to
be approved by FWS and BLM when disturbance will occur upslope of habitat,
c. Limit new access routes created by the project,
d. Roads and utilities should share common right-of-ways where possible,
e. Reduce the width of right-of-ways and minimize the depth of excavation needed for the road bed; where
f. Place signing to limit off-road travel in sensitive areas, and
g. Stay on designated routes and other cleared/approved areas.
153
August 2019

(avoidance areas) and incorporate 300-foot buffers, , in general; however, site-specific distances will need to
be approved by FWS and BLM when disturbance will occur upslope of habitat,
b. Follow the above recommendations (3.) for project design within suitable habitats,
c. To avoid water flow and/or sedimentation into occupied habitat and avoidance areas, silt fences, hay bales,
is encouraged,
d. Construction of roads will occur such that the edge of the right of way is at least 300 feet from any plant and
300 feet from avoidance areas,
e. Roads will be graveled within occupied habitat; the operator is encouraged to apply water for dust abatement
to such areas from May 1st to June 5th (flowering period); dust abatement applications will be comprised of
water only,
f. The edge of the well pad should be located at least 300 feet away from plants and avoidance areas, in
general; however, site-specific distances will need to be approved by FWS and BLM when disturbance will
occur upslope of habitat,
g. Surface pipelines will be laid such that a 300-foot buffer exists between the edge of the right of way and
plants and 300 feet between the edge of right of way and avoidance areas; use stabilizing and anchoring
techniques when the pipeline crosses suitable habitat to ensure pipelines don’t move towards the population;
site-specific distances will need to be approved by FWS and BLM when disturbance will occur upslope of
habitat,
h. Construction activities will not occur from May 1st through June 5th within occupied habitat,
i. Before and during construction, areas for avoidance should be visually identifiable in the field, e.g., flagging,
j. Where technically and economically feasible, use directional drilling or multiple wells from the same pad,
k. Place produced oil, water, or condensate tanks in centralized locations, away from occupied habitat, and
l. Minimize the disturbed area of producing well locations through interim and final reclamation. Reclaim well
5. Occupied clay reed-mustard habitats within 300 feet of the edge of the surface pipelines’ right of ways, 300 feet
of the edge of the roads’ right of ways, and 300 feet from the edge of the well pad shall be monitored for a
and the Service. To ensure desired results are being achieved, minimization measures will be evaluated and may
be changed after a thorough review of the monitoring results and annual reports during annual meetings between
the BLM and the Service.
154
August 2019

occupied habitat for the clay reed-mustard is anticipated as a result of project activities.
COLORADO RIVER ENDANGERED FISH
The lessee/operator is given notice in order to minimize effects to critical habitats of endangered fish in the Colorado
and Green Rivers, surface-disturbing activities within the 100-year floodplain of the Colorado River,
Green River, and all associated back waters would not be allowed. Other avoidance and minimization measures
include:
• Surveys would be required prior to operations unless species occupancy and distribution information is complete
and available. All surveys must be conducted by qualified individuals. Lease activities would require monitoring
throughout the duration of the project.
• To ensure desired results are being achieved, minimization measures would be evaluated and, if necessary,
Section 7 consultation reinitiated.
• Water production would be managed to ensure maintenance or enhancement of riparian habitat.
T&E-23 • Avoid loss or disturbance of riparian habitats.
(Moab Canyon • Conduct watershed analysis for leases in designated critical habitat and overlapping major tributaries in order to
Country District) determine toxicity risk from permanent facilities.
• Implement the Utah Oil and Gas Pipeline Crossing Guidance. In areas adjacent to 100-year floodplains,
particularly in systems prone to flash floods, analyze the risk for flash floods to impact facilities, and use closed
loop drilling, and pipeline burial or suspension according to the Utah Oil and Gas Pipeline Crossing Guidance to
minimize the potential for equipment damage and resulting leaks or spills.
• Water depletions from any portions of the Upper Colorado River drainage basin are considered to adversely
affected and adversely modify the critical habitat of the endangered fish species (bonytail, Colorado pikeminnow,
humpback chub, and razorback sucker). Section 7 consultation would be completed with the U.S. Fish and
Wildlife Service (USFWS) prior to any such water depletions.
• Additional measures to avoid or minimize effects to the species may be developed and implemented in
consultation with the USFWS between the lease sale stage and lease development stage to ensure continued
155
August 2019

U.S. Fish and Wildlife Service (Service) Measures to Minimize Effects of Surface Water Pumping to
Endangered Colorado River Fish
Issue: Endangered larval fish are very small (<0.5 inches total length) and incapable of directed swimming from the
time of hatching through the first 2-4 weeks of their life. Depending on the water year, larval fish may be present in the
Green, Colorado, Gunnison, and Yampa Rivers from as early as April 1 to as late as August 31 (earlier in dry years;
later in wet years). Young of the year endangered fish are the most susceptible to entrainment.
Goal: Minimize entrainment of Federally listed species into pumps.
Measures:
1. The best method to avoid entrainment is to pump from an off-channel location – one that does not connect to the
river during high spring flows. An infiltration gallery constructed in a Service approved location is best.
2. If the pump head is located in the river channel the following stipulations apply:
a. Do not situate the pump in a low-flow or no-flow area, as these habitats tend to concentrate larval fishes.
b. Limit the amount of pumping, to the greatest extent possible, during that period of the year when larval fish
may be present (see above).
c. Limit the amount of pumping, to the greatest extent possible, during the midnight hours (10 pm to 2 am), as
larval drift studies indicate that this is a period of greatest daily activity. Dusk and the afternoon are the
preferred pumping times, as larval drift abundance is lowest during this time.
3. Screen all pump intakes with 3/32” mesh material.
4. Approach velocities for intake structures should follow the National Marine Fisheries Service's document "Fish
Screening Criteria for Anadromous Salmonids." For projects with an in-stream intake that operate in stream
reaches where larval fish may be present, the approach velocity should not exceed 0.33 feet per second (ft/s).
5. Report any fish impinged on the intake screen or entrained into irrigation canals to the Service (801-975-3330) or
the Utah Division of Wildlife Resources:
Northeastern Region 152 East 100 North, Vernal, UT 84078 Phone: 435-781-9453
Southeastern Region 475 West Price River Drive, Suite C, Price, UT 84501 Phone: 435-636-0260
CALIFORNIA CONDOR – POTENTIAL HABITAT
The lessee/operator is given notice that the lands located in this parcel contain potential habitat for the California
T&E-28 condor. Avoidance or use restrictions may be placed on portions on areas known or suspected to be used by condors.
(Moab MLP) Application of appropriate measures would depend on whether the action is temporary or permanent, and whether it
occurs within or outside potential habitat. A temporary action is completed prior to the following important season of
use, leaving for habitat functionality. A permanent action continues for more than one season of habitat use, and/or
156
August 2019

causes a loss of condor habitat function or displaces condors through continued disturbance (i.e., creation of a
permanent structure requiring repetitious maintenance or emits disruptive levels of noise).
1. The Peregrine Fund will be contacted early and throughout project design and implementation to determine and
monitor the locations and status of California condors in or near the project area.
2. Surveys would be required prior to operations in suitable habitat, unless species occupancy and distribution
information is complete and available. All Surveys must be conducted by qualified individual(s) approved by the
BLM and must be conducted according to approved protocols.
3. All workers will be informed about potential condor presence.
4. If condors are present within the project area the Peregrine Fund will be contacted. If there is any potential that
the project will affect condors the USFWS will be contacted immediately.
5. The project area will be kept clean (e.g., trash disposed of, tools and materials picked up) in order to minimize the
possibility of condors accessing inappropriate materials.
6. To prevent water contamination and potential condor poisoning, a hazardous material (including vehicle fluids)
leakage and spill plan will be developed and implemented. The plan will include provisions for immediate clean-
up of any hazardous substance, and will outline how each hazardous substance will be treated in case of leakage
or spill. The plan will be reviewed by the district biologist to insure that condors are adequately addressed.
7. If surveys result in positive identification of condor use, all lease activities would require monitoring throughout
the duration of the project to ensure desired results of applied mitigation and protection. Minimization measures
would be evaluated during development and, if necessary, Section 7 consultation may be reinitiated.
8. Temporary activities within 1.0-mile of nest sites would not occur during the breeding season.
9. Temporary activities within 0.5-miles of established roosting sites or areas would not occur during the season of
use, which is from August 1 to November 30; unless the area has been surveyed according to protocols consulted
on with USFWS and determined to be unoccupied.
10. No permanent infrastructure would be placed within 1.0-mile of nest sites.
11. No permanent infrastructure would be placed within 0.5-miles of established roosting sites or areas.
12. Remove big game carrion to 100 feet from on lease roadways occurring within foraging range.
reduce surface disturbance and eliminate drilling in suitable habitat Utilize directional drilling to avoid direct
157
August 2019

impacts to large cottonwood gallery riparian habitats. Ensure that such directional drilling does not intercept or
degrade alluvial aquifers.
14. Re-initiation of Section 7 consultation with the USFWS would be sought immediately if mortality or disturbance
to California condors is anticipated as a result of project activities. Additional site-specific measures may also be
employed to avoid or minimize effects to the species. These additional measures would be developed and
implemented in consultation with the USFWS to ensure continued compliance with the ESA.
development stages. These additional measures would be developed and implemented in consultation with the USFWS
to ensure continued compliance with the ESA.
JONES CYCLADENIA – POTENTIAL, SUITABLE AND OCCUPIED HABITAT
The lessee/operator is given notice that the lands located in this parcel contain potential habitat for Jones cycladenia.
In order to minimize effects to the Federally threatened Jones cycladenia, the BLM, in coordination with the USFWS
has developed the following avoidance and minimization measures. Implementation of these measures will help ensure
the activities carried out during oil and gas development (including but not limited to drilling, production, and
maintenance operations) are in compliance with the ESA. For the purposes of this document, the following terms are
so defined: potential habitat is defined as areas that satisfy the broad criteria of the species habitat description, usually
determined by preliminary, in-house assessment. Suitable habitat is defined as areas that contain or exhibit the specific
components or constituents necessary for plant persistence determined by field inspection and/or surveys; it may or
may not contain Jones cycladenia; habitat descriptions can be found in Federal Register Notice and species recovery
T&E-29 plan links at <http:www.fws.gov/endangered/species/>. Occupied habitat is defined as areas currently or historically
(Moab MLP) known to support Jones cycladenia, synonymous with “known habitat.” The following avoidance and minimization
1. Pre-project habitat assessments will be completed across 100 percent of the project disturbance area within
potential habitat1 prior to any ground disturbing activities to determine if suitable Jones cycladenia habitat is
present.
2. Species surveys will be conducted within suitable habitat to determine occupancy. Where standard surveys are
technically infeasible and otherwise hazardous, due to topography, slope, etc., suitable habitat will be assessed
and mapped for avoidance (hereafter, “avoidance areas”); in such cases, 300 foot buffers will be maintained
between surface disturbance and avoidance areas. However, site specific distances will need to be approved by
USFWS and BLM when disturbance will occur upslope of habitat. Where conditions allow, surveys:
a. Must be conducted by qualified individuals(s) and according to BLM and Service accepted survey protocols.
158
August 2019

initiation of project activities and within the same growing season at a time when the plant can be detected
(usually April 15 to June 5; however, surveyors should verify that the plant is flowering by contacting a BLM
or USFWS botanist or demonstrating that the nearest known population is in flower),
c. Will occur within 300 feet from the edge of the proposed right-of-way (ROW) and/or project disturbance for
surface pipelines, roads, wellpads, and other facilities requiring removal of vegetation,
d. Will include, but not be limited to, plant species lists and habitat characteristics.
e. Will be valid until April 15 of the following year.
f. Clearance surveys in occupied habitat will be combined with historic plant location data for that particular
site to delineate the outer boundary of occupied habitat. The 300 foot avoidance buffer will then be applied to
the outer boundary of occupied habitat for that site. This evaluation will occur in coordination with the BLM
and Service to ensure that the appropriate buffer is applied to protect both active and dormant Jones
Cycladenia plants in occupied habitat.
g. Electronic copies of clearance survey reports (included appendices) and GIS shape files will be sent no later
than December 31st to each of the following:
- Utah Natural Heritage Program (with copies of NHP field survey forms);
- Applicable/affected land owners and/or management agencies; and
- U.S. Fish and Wildlife Service Utah Field Office (mailing address: 2369 West Orton Circle, Suite 50, West
Valley City, Utah 84119).
(avoidance areas) and incorporate 300 foot buffers, in general; however, site-specific distances will need to
be approved by USFWS and BLM when disturbance will occur upslope of habitat.
b. Reduce well pad size to the minimum needed without compromising safety.
c. Where technically and economically feasible, use directional drilling or multiple wells from the same pad.
d. Roads and utilities should share common ROWs where possible.
e. Reduce the width of ROWs and minimize the depth of excavation needed for the road bed; where feasible,
use the natural ground surface for the road within habitat.
f. Place signing to limit off-road travel in sensitive areas.
g. Stay on designated routes and other cleared/approved areas.
h. All disturbed areas will be re-vegetated with species native to the region, or seed mixtures approved by the
action agency and USFWS.
159
August 2019
4. Where there is occupied habitat, project infrastructure will be designed to avoid direct disturbance and indirect
a. Follow the above recommendations in Section 3 for project design within suitable habitats.
and similar structures or practices will be incorporated into the project design; appropriate placement of fill is
encouraged.
c. Construction of roads will occur such that the edge of the ROW is at least 300 feet from: 1) any plant; 2) the
outer boundary of occupied habitat and; 3) avoidance areas.
d. Existing roads will be graveled within 300 feet of occupied habitat; the operator is encouraged to apply water
for dust abatement to such areas from April 15 to June 5 (flowering period); dust abatement applications will
be comprised of water only.
e. The edge of the well pad should be located at least 300 feet away from plants and avoidance areas, in general;
however, site specific distances will need to be approved by USFWS and BLM when disturbance will occur
upslope of habitat.
f. Surface pipelines will be laid such that a 300 foot buffer exists between the edge of the ROW and plants and
300 feet between the edge of ROW and avoidance areas; use stabilizing and anchoring techniques when the
pipeline crossed suitable habitat to ensure pipelines don’t move towards the population; site specific
distances will need to be approved by USFWS and BLM when disturbance will occur upslope of habitat.
g. Construction activities will not occur within occupied habitat.
temporary fencing, rebar, etc.
i. A qualified botanist will be onsite during construction to monitor the surface disturbance activity and assist
with implementation of applicable conservation measures.
j. Place produced oil, water, or condensate tanks in centralized locations, away from occupied habitat.
k. Minimize the disturbed area of producing well locations through interim and final reclamation. Reclaim well
5. Dust abatement and reduced speed limits will be applied during flowering dates (April 15 through June 5) within
300 feet of suitable and occupied habitat, including unoccupied suitable habitat.
6. For projects that cannot implement the measures or avoidance buffers identified in number 4 above, site specific
conservation measures will be developed in coordination with USFWS. Occupied Jones cycladenia habitats
within 300 feet of the edge of the surface pipelines’ ROWs, 300 feet of the edge of the roads’ ROWs, and 300
feet from the edge of the well pad shall be monitored for a period of three years after ground disturbing activities.
160
August 2019

Monitoring will include annual plant surveys to determine plant and habitat impacts relative to project facilities.
Annual reports shall be provided to the BLM and the USFWS. To ensure desired results are being achieved,
minimization measures will be evaluated and may be changed after a thorough review of the monitoring results
and annual reports during annual meetings between the BLM and the USFWS.
7. Re-initiation of Section 7 consultation with the USFWS will be sought immediately if any loss of plants or
occupied habitat for the Jones cycladenia is anticipated as a result of project activities.
measures will be developed and implemented in consultation with the USFWS to ensure continued compliance with
the ESA.
WESTERN YELLOW-BILLED CUCKOO
The Lessee/Operator is given notice that the lands in or adjacent to this parcel contain potentially suitable habitat that
falls within the range for western yellow-billed cuckoo, a federally listed species. Avoidance or use restrictions may be
placed on portions of the lease. Application of appropriate measures will depend upon whether the action is temporary
or permanent, and whether it occurs within or outside the breeding and nesting season. A temporary action is
completed prior to the following breeding season leaving no permanent structures and resulting in no permanent
habitat loss. A permanent action could continue for more than one breeding season and/or cause a loss of habitat or
displace western yellow-billed cuckoos through disturbances. The following avoidance and minimization measures
have been designed to ensure activities carried out on the lease are in compliance with the Endangered Species Act.
Integration of, and adherence to, these measures will facilitate review and analysis of any submitted permits under the
authority of this lease. Following these measures could reduce the scope of Endangered Species Act, Section 7
T&E-31
consultation at the permit stage. Avoidance and minimization measures include the following:
Vernal, Salt Lake
1. Habitat suitability within, and within a 0.5-mile buffer, of the proposed project analysis area will be identified
prior to lease development to identify potential survey needs.
2. If suitable or proposed critical habitat is present, protocol Breeding Season Surveys will be required within, and
within 0.5-mile buffer, of the proposed project analysis area prior to operations unless species occupancy and
distribution information is complete and available. All Surveys must be conducted by permitted individual(s),
and be conducted according to protocol.
3. For all temporary actions that may impact cuckoo or suitable habitat:
a. If action occurs entirely outside of the cuckoo breeding season (June 1 – Aug 31), and leaves no structure or
habitat disturbance, action can proceed without a presence/absence survey.
b. If action is proposed between June 1 and August 31, presence/absence surveys for cuckoo will be conducted
prior to commencing activity. If cuckoo are detected, activity should be delayed until September 1. The
161
August 2019

cuckoo survey protocol requires four surveys across the breeding season to conclude absence, thus the survey
cannot conclude absence of cuckoos until mid-August.
c. Eliminate access routes created by the project through such means as raking out scars, revegetation, gating
access points, etc.
4. For all permanent actions that may impact cuckoo or suitable habitat:
a. Habitat suitability within and within a 0.5-mile buffer of the proposed project analysis area will be identified
prior to lease development to identify potential survey needs.
b. Protocol level surveys by permitted individuals will be conducted within, or within a 0.5-mile buffer, of the
proposed project analysis area prior to commencing activities.
c. Avoid drilling and permanent structures within 0.5 miles of suitable or proposed critical habitat unless
absence is determined according to protocol level surveys conducted by permitted individual(s).
d. During construction and operation phases of the project, ensure noise levels at the edge of suitable habitat do
not exceed baseline conditions. Placement of permanent noise-generating facilities should be determined by a
noise analysis.
5. Temporary or permanent actions will require monitoring throughout the duration of the project to ensure that
western yellow-billed cuckoo or its habitat is not affected in a manner or to an extent not previous considered.
Avoidance and minimization measures will be evaluated throughout the duration of the project.
6. Water produced as a by-product of drilling or pumping will be managed to ensure maintenance or enhancement
of riparian habitat.
reduce surface disturbance and eliminate drilling in suitable habitat. Ensure that such directional drilling does not
8. Ensure that water extraction or disposal practices do not result in change of hydrologic regime that would result
in loss or degradation of riparian habitat.
9. Re-vegetate with native species, where possible, all areas of surface disturbance within riparian areas and/or
adjacent uplands.
162
August 2019
Appendix C – Figures/Maps
• Parcel 024 and Parcel 025 Overview, Canyon Country District, Moab Field Office
• Parcel 035 Overview, Canyon Country District, Monticello Field Office.
• Parcel 031, Parcel 032, Parcel 033 and Parcel 034 Overview, Canyon Country District,
Monticello Field Office.
• Parcel 027 Overview, Canyon Country District, Monticello Field Office.
• Parcel 028, Parcel 029 and Parcel 030 Overview, Canyon Country District, Monticello Field
Office.
• Parcel 006 Overview, Color Country District, Richfield Field Office.
• Parcel 007 and Parcel 008 Overview, Color Country District, Richfield Field Office.
• Parcel 022 Overview, Green River District, Price Field Office.
• Parcel 014 and Parcel 017 Overview, Green River District, Price Field Office.
• Parcel 026 Overview, Green River District, Vernal Field Office.
163
August 2019
Figure 8. Parcel 024 and Parcel 025 Overview, Canyon Country District, Moab Field Office.
164
August 2019
Figure 9. Parcel 035 Overview, Canyon Country District, Monticello Field Office.
165
August 2019
Figure 10 Parcel 031, Parcel 032, Parcel 033 and Parcel 034 Overview, Canyon Country District,
Monticello Field Office.
166
August 2019
Figure 11 Parcel 027 Overview, Canyon Country District, Monticello Field Office.
167
August 2019
Figure 12 Parcel 028, Parcel 029 and Parcel 030 Overview, Canyon Country District, Monticello
Field Office.
168
August 2019
Figure 13 Parcel 006 Overview, Color Country District, Richfield Field Office.
169
August 2019
Figure 14 Parcel 007 and Parcel 008 Overview, Color Country District, Richfield Field Office.
170
August 2019
171
August 2019
172
August 2019
Figure 17 Parcel 022 Overview, Green River District, Price Field Office.
173
August 2019
Figure 18 Parcel 014 and Parcel 017 Overview, Green River District, Price Field Office.
174
August 2019
Figure 19 Parcel 026 Overview, Green River District, Vernal Field Office.
175
August 2019
Appendix D – Interdisciplinary Parcel Review Team Checklist

DETERMINATION OF STAFF:
NP = not present in the area impacted by the proposed or alternative actions
NI = present, but not affected to a degree that detailed analysis is required
PI = present with potential for relevant impact that need to be analyzed in detail in the EA
Moab Field Office
Determi- Rationale for Determination
Resource Parcel Reviewer
nation Moab Field Office
Resources And Issues Considered (Includes Supplemental Authorities Appendix 1 H-1790-1)
Air
Activities related to exploration, construction, drilling, completion, testing, and production of an oil
or gas well could result in emissions of pollutants (including those that are regulated) that could
affect air quality. All parcels are within an attainment area. Background information is contained in
Erik Vernon
PI Air Quality Appendix H.
8/28/2019
Application of notices UT-LN-96 (Air Quality Mitigation Measures), UT-LN-99 (Regional Ozone
Formation Controls), UT-LN-101 (Air Quality) and UT-LN-102 (Air Quality Analysis) is warranted
on all parcels.
Greenhouse Gases are composed mostly of CO2, CH4, N2O, HFCs, PFCs, & SF6. Primary sources of
GHG emissions include fossil fuel combustion, fugitive CH4, and combustion of produced oil and Erik Vernon
Greenhouse
PI gas. GHG emissions could occur from construction, drilling, and production equipment and end use
Gases 8/28/2019
of the product(s). Background information is contained in Appendix H. Refer to the notices applied
for Air Quality.
Recreation
Areas of
Critical Katie Stevens
NP The parcels do not intersect or occur adjacent to ACECs (see 2008 Moab Resource Management Plan)
Environmental 6/25/19
Concern
National Park The parcels are at least 18 miles from a National Park. The OSNHT is distant from the two parcels. Katie Stevens
NP
Service Units Parcel 024 is 6 miles from the OSNHT and Parcel 025 is 5.6 miles from the OSNHT. 6/25/19
176
August 2019

and Historic
Trails
National
Conservation
Areas/BLM- GIS review confirms there are no National Conservation Areas or BLM Administered National Sheri Wysong
NP
Administered Monuments proximate to the parcel. 8/16/2019
National
Monuments
Parcel 024 and 025 are within the Labyrinth Rims/Gemini Bridges SRMA. A controlled surface use
stipulation (UT-S-376) minimizes surface disturbance within SRMAs. The type of recreation which
occurs on those parcels is primarily motorized touring by four-wheel drive vehicle, motorcycle or Katie Stevens
NI Recreation
ATV/UTV. Parcel 025 is partially within the Dee Pass Motorized Focus Area. Parcel 025 also has a 6/25/19
developed recreation site, White Wash Sand Dune. The developed recreation site is managed with an
NSO stipulation, which would protect the recreation opportunities found at that location.
Travel/ Access to the parcels is available from the Ruby Ranch and Salt Wash Class D Roads. These have Sheri Wysong
NI
Transportation been claimed as RS 2477 Roads. 8/15/2019
Parcels 024 and 025 are managed as VRM Class III. In addition, Parcel 024 is entirely within the
Visual area managed to visually protect the rimlands of the Green River. These rimlands are managed with Katie Stevens
NI
Resources an NSO stipulation (UT-S-407). This stipulation would protect the relevant visual resources 6/25/19
associated with the Green River rimlands..
Wild and Katie Stevens
NP The parcels do not overlap the WSR corridor (one-quarter of a mile from the Green River).
Scenic Rivers 6/25/19
Wilderness/
Bill Stevens
NP Wilderness The parcels do not intersect any wilderness or WSAs. 6/24/19
Study Area
Lands with Bill Stevens
NP wilderness The parcels do not intersect any lands determined to possess wilderness characteristics by BLM.
characteristics 6/24/19
Cultural
177
August 2019

BLM archaeologists have compiled cultural resources data from the Moab field office cultural
resource libraries, GIS data (CURES), and the Preservation Pro database area. These data sources
contain information of all of the recorded cultural resource sites and cultural resource survey data for
the area available to BLM and the Utah Division of State History.
Archaeologist use this data to determine if oil and gas development could occur within each parcel
while avoiding know cultural sites. The parcels are reviewed for the application of stipulations and
lease notices as required by the Monticello RMP.
At this time, (08/16/2019) consultation with the Utah State Historic Preservation Office is ongoing.
Ashley Losey
BLM’s consultation with Native American Tribes is ongoing.
07/02/19
Cultural For future undertakings related to this lease sale, BLM will not approve any ground disturbing
NI
Resources activities until it completes its obligations to consider cultural resources under NEPA, NHPA and
other authorities specific to those future undertakings. Consideration of impacts to cultural resources Glenn Stelter
and adverse effects to historic properties will be taken into account during the review stage of site 08/16/2019
specific development plans.
Cultural: Resource Stipulations and Lease Notices:

Cultural Resource Stipulation as required by Handbook H-3120-1, UT-LN-66 (Cultural Resources
Located Sandy or Erodible Soils), and UT-LN-70 (High Potential for Cultural Resource Occurrence)
to all parcels.
The following Tribes were invited to consult on this project via certified letter on 06/25/2019: All
Pueblo Council of Governors , Cedar Band of Paiutes, Colorado River Indian Tribes, Confederated
Tribes of the Goshute, Eastern Shoshone Tribe, Indian Peaks Band of Paiutes, Jicarilla Apache
Nation, Kaibab Band of Paiute Indians, Kanosh Band of Paiutes, Moapa Band of Paiute Indians, Ashley Losey
Native 07/02/19
American Navajo Nation, Navajo Nation, Aneth Chapter, Navajo Nation, Dennehotso Chapter, Navajo Nation,
NI Kayenta Chapter, Navajo Nation, Mexican Water Chapter, Navajo Nation, Navajo Mountain Chapter,
Religious
Concerns Navajo Nation, Oljato Chapter, Navajo Nation, Red Mesa Chapter, Navajo Nation, Shonto Glenn Stelter
Community Governance, Navajo Nation, Teec Nos Pos Chapter, Navajo Utah Commission, 08/16/2019
Northwest Band of Shoshone Nation, Ohkay Owingeh, Paiute Indian Tribe of Utah , Pueblo of
Acoma, Pueblo of Cochiti, Pueblo of Isleta, Pueblo of Jemez, Pueblo of Kewa (Santo Domingo),
Pueblo of Laguna, Pueblo of Nambe, Pueblo of Ohkay Owingeh, Pueblo of Picuris, Pueblo of
178
August 2019

Pojoaque, Pueblo of San Felipe, Pueblo of San Ildefonso, Pueblo of Sandia, Pueblo of Santa Ana,
Pueblo of Santa Clara, Pueblo of Taos, Pueblo of Tesuque, Pueblo of Ysleta del Sur, Pueblo of Zia,
Pueblo of Zuni, San Juan Southern Paiute Tribe, Shivwits Band of Paiutes, Shoshone-Bannock, Skull
Valley Band of Goshute Indians, Southern Ute Indian Tribe, The Hopi Tribe, Uintah and Ouray Ute
Tribe, Ute Indian Tribe, Ute Mountain Ute Tribe, White Mesa Ute. At this time, Tribal consultation is
ongoing. The BLM will consult with Indian tribes on a government-to-government basis, if requested
by any Tribe.
Additional coordination and consultation would be initiated at the APD stage. BMPs, SOPs and site
specific mitigation may be applied at the APD stage as COAs.
Resources and locations of Native American religious and traditional concern may be present within
all of the proposed parcels and lease stipulations notices are warranted as follows:
Cultural Resources Protection (Handbook H-3120-1) – Parcels 024 & 025

UT-LN-137: Cultural Resources I – Parcels 024 & 025
UT-LN-138: Cultural Resources II – Parcels 024 & 025
UT-LN-139: Cultural Resources – High Potential for Cultural Sites – Parcels 024 & 025
Wildlife
Greater Sage- No habitat suitable for the Greater sage-grouse occurs in the parcels proposed for the December 2019 Karen Cathey
NP
Grouse lease sale located within the MOFO area. August 21, 2019
The following documents are incorporated: Utah Wildlife Action Plan (2015), Utah Partners in Flight
Avian Conservation Strategy Version 2.0. (Parrish et al. 2002), Birds of Conservation Concern
(USFWS 2008), Executive Order 13186: Responsibilities of Federal Agencies to Protect Migratory
Birds, MOU between the USDI BLM and USFWS to Promote the Conservation and Management of Karen Cathey
NI Migratory Birds Migratory Birds (4/2010), and Utah Supplemental Planning Guidance: Raptor Best Management
Practices (BLM UTSO IM 2006-096). August 21, 2019
Migratory birds are protected under the Migratory Bird Treaty Act (Executive Order 13186). MOU
between the BLM and United States Fish and Wildlife Service (USFWS) (BLM MOU WO-230-
2010-04) provides BLM further direction for project-level NEPA guidance for meeting MBTA
179
August 2019

conservation and compliance. Bald and golden eagles receive additional protections under the Bald
and Golden Eagle Protection Act of 1962. Potential for impacts to these eagle species is discussed
below, under BLM Sensitive Species.
Future oil and gas exploration may impact migratory birds, waterfowl and their seasonal habitats
through development, operation and maintenance activities. This stage occurs when a lessee files an
APD, outlining in detail the scope of the proposed development. At that time, impacts to migratory
birds and waterfowl could be fully analyzed in additional environmental documents through the
NEPA process. BMPs, SOPs and site specific mitigation may be applied at the APD stage as COAs.
Lease notice UT-LN-144: Migratory Bird, would be applied to all parcels notifying potential operators
of the possible need for actions to minimize impacts to migratory birds, particularly priority species
identified in Utah. BMPs, SOPs and site specific mitigation may be applied at the APD stage as
COAs, including timing limitation or buffers. Collectively, these measures will minimize impacts to
these sensitive species and no further analysis at the leasing stage is necessary.
The standard endangered species stipulation as per Handbook H-3120-1 is attached to all parcels.
An official endangered species act (ESA) species list was obtained from the USFWS Information,
Planning, and Conservation (IPaC) System for the RHA area on July 10, 2019. The IPaC lists the
following endangered animal species as potentially occurring: California condor, southwestern
willow flycatcher, Colorado River Fish (bonytail chub, Colorado pikeminnow, humpback chub,
razorback sucker). The IPaC also lists potential for the threatened Mexican spotted owl and yellow-
billed cuckoo. No designated critical habitat for these species occurs in the parcels proposed for the
Threatened, December 2019 lease sale.
Endangered, Karen Cathey
NI Candidate or California condor: Parcels 024 and 025 are within a Nonessential Experimental Population area, and
Proposed will have lease notice T&E 28: California condor applied. California condors prefer mountainous August 21, 2019
Animal Species country at low and moderate elevations, especially rocky and brushy areas near cliffs. Breeding
populations are restricted to California and Northern Arizona, near release sites, and no known nest
sites occur on the parcels. Application of T&E 28 will minimize risk to the condor, should it occur,
through requirements for best management practices to reduce likelihood of impacts (e.g., removal of
trash, carrion, and hazardous materials, surveys and monitoring, reduction of construction footprint,
etc.). Such requirements will minimize the potential for direct and indirect impacts to the species.
Southwestern willow flycatcher: No suitable or potential habitat occurs within the parcels. Parcel
024 does not contain or is not within 0.25 miles of any riparian areas. Parcel 025 is within 0.25 miles
180
August 2019

of an area mapped with riparian habitats; however evaluation indicates the habitat consists of sandy
and dry washes, having minimal vegetation through scattered cottonwoods and sparse, shrubby
tamarisks, with no continuous canopy or denseness. No effects are expected.
Colorado River Fish: No potential habitat for Colorado Endangered Fish species occurs on parcels
024 and 025. A portion of parcel 024 is within the ½ mile buffer for the Green River 100-year
floodplain delineated within USFWS data. The parcels occur within watersheds of the Upper
Colorado River, where water depletions may have potential to indirectly impact these species.
Effects from water depletion were analyzed in the biological assessment supporting 2016 MLP and
the 2016 MLP, in addition to the USFWS Biological Opinion for these plans. The application of
lease notice T&E 23: Colorado River Endangered Fish allows opportunity to make adjustments at the
site-specific level when an APD is received to reduce potential effects to the species, in addition to
requirements regarding measures to management of water production, avoiding disturbance to
riparian areas, and best management practices with regard to construction. Implementation of T&E
23 will minimize the potential for significant impacts to these species.
Mexican spotted owl: No suitable or potential habitat, or areas where MSO models (Willey/Spotskey
1997 & 2000) predict potential suitability, occurs within the lease parcels or FWS recommended
buffers. No effect is expected.
Yellow-billed cuckoo: Parcel 024 does not contain or is not within 0.5 miles of riparian habitat.
Parcel 025 is within 0.5 miles of an area mapped with riparian habitat but the area offers no potential
for cuckoo as the area consists of sandy and dry washes with minimal vegetation consisting of
scattered cottonwoods and sparse, shrubby tamarisks. No effects are expected.
Summary of attachments for threatened, endangered, candidate or proposed animal species, parcels
024 and 025:
• T&E-23: Colorado River Endangered Fish
• T&E-28 California Condor
BLM manages sensitive species in accordance with BLM Manual 6840. Utah BLM Sensitive Species
BLM Sensitive List (UT-IM-2019-005, March 4, 2019), lists 72 BLM sensitive animal species, including 22 species
which occur or potentially occur within the December 2019 lease sale analysis area. Available data Karen Cathey
NI Wildlife
sources, including BLM data layers and that available through Utah Conservation Data Center August 21, 2019
Species
(UCDC) were used to determine if the known or potential habitat falls within parcels 024 and 025,
with the following results for species with potential to occur. The application of lease notices for
181
August 2019

sensitive species, migratory birds and raptors, applied to every parcel, will allow for the opportunity
to make adjustments at the site specific level when an APD is received if circumstances change to
allow potential for occurrence of these species.
Great Plains toad: This species prefers grasslands with loose soil for burrowing, in and near riparian
corridors or wet areas. There is no specific data on occurrence; however, parcels 024 and 026 contain
substantial and high value habitat, including vernal/ephemeral pools, ephemeral and intermittent
streams; small unmapped desert seeps/springs, which would provide important breeding habitat.
Bald eagle: Winter habitat is identified, and the species occurs in Grand County, including several
nests along the Colorado River. Wintering areas are commonly associated with open water; although
eagles use habitats with little or no open water if other food resources (e.g., rabbit or deer carrion) are
readily available. No known winter roosts or nesting territories occur in or near any of the parcels.
Nesting eagles are not expected. UT-LN-143: Raptors implement guidelines for raptor protection.
Ferruginous hawk: Ferruginous hawks are distributed throughout most of Utah and may occasionally
occur in very open, dry habitat. Breeding ferruginous hawks are not expected. UT-LN-143: Raptors
will implement guidelines for raptor protection.
Short-eared owl: This species is known from open country, supporting high numbers of small
rodents. Only winter habitat is identified; and nesting is not likely. Occurrence of this species would
be migratory and transient. UT-LN-143: Raptors will implement guidelines for raptor protection.
Big free-tailed bat: The species is an insectivore which often roosts and forms maternity colonies in
massive sandstone cliffs near bodies of open water. There is substantial value habitat located within
the parcels; however, no known maternity roosts are within the lease parcels. The species is managed
under the Bat Conservation Plan.
Kit fox: Suitable and potential habitat occurs within the parcels, and the 2014 habitat model for kit
fox indicates a high probability of occurrence. Kit foxes live primarily in open desert, shrubby or
shrub-grass habitat; shadscale, greasewood or sagebrush. They feed on mostly nocturnal rodents, and
opportunistically on birds, reptiles, and insects. Several dens may be used, especially in summer (
(Natureserve 2019). Application of UT-LN-147: Kit Fox, requires surveys during pupping season,
and limits surface disturbing activity within 200 meters of an occupied natal den. Therefore, no
significant impacts are expected.
182
August 2019

Spotted bat: This species forages in many habitats, and roosts in cliffs and stony outcrops. There is
substantial value habitat in the MFO lease parcels; however, there are no known populations or
maternity roosts are within the lease parcels.
Townsend’s big-eared bat: This species forages in many habitats, including arid desert scrub, and
roosts in caves and other large open cover. There is substantial value habitat in the parcels; however,
there are no known populations or maternity roosts.
Monarch butterfly: This species mainly depend on milkweed species in the genus Asclepias, which
have been documented in the region where parcels 024 and 025 are located (Jepsen 2015).
Application of UT-LN-156: Pollinators and Pollinator Habitat will require specific measures
designed to protect this species, including the direct (e.g., restrictions on use of pesticides) and
indirect (e.g., avoidance of milkweed plants) impacts.
Western bumblebee: This species forages on multiple flowers, with some plant species depending on
their “buzz pollination.” They may fly in cooler temperatures and lower light levels than other bees.
(https://xerces.org/western-bumble-bee/) Application of UT-LN-156: Pollinators and Pollinator
Habitat on these parcels will require specific measures designed to protect this species, including the
direct (e.g., restrictions on use of pesticides) and indirect (e.g., avoidance of milkweed plants)
impacts.
Summary of lease notices applied to parcels 024 and 025 to protect BLM Sensitive Species:
• UT-LN-49: Sensitive Species
• UT-LN-143: Raptors
• UT-LN-147: Kit fox
• UT-LN-156: Pollinators and Pollinator Habitat
These lease notices were designed by the BLM to provide protections through general and specific
measures which would identify and protect BLM sensitive species. Where a specific lease notice is
not applied, UT-LN-49 will notify that the parcel has been identified as containing potential habitat
for BLM Sensitive Species and that modifications to the Surface Use Plan of Operations may be
required in order to protect these resources from surface disturbing activities. No surface use or
otherwise disruptive activity would be allowed that would result in direct disturbance to populations
or individual special status species.
183
August 2019

Parcels 024 and 025 were evaluated for State identified game species, including the including the
American bison, cougar, black bear, moose, Rocky Mountain elk, mule deer, pronghorn antelope,
mountain goat, California bighorn sheep, desert bighorn sheep, Rocky Mountain bighorn sheep,
snowshoe hare, wild turkey, chukar, California quail, band-tailed pigeon, sharp-tailed grouse, ruffed
grouse, dusky/blue grouse, white-tailed ptarmigan and ring-necked pheasant using UDWR data.
Habitat suitable for those not listed below is not expected to occur, although occasional, meandering
animals may be seen due to presence within riparian areas associated with the Green River, located
within ½ mile, particularly if there are attractants available at the site (e.g., trash, standing water).
Fish and
Wildlife Cougar: Both parcels fall in the La Sal subunit of the La Sal management unit for the cougar, Karen Cathey
Excluding managed for annual statewide limited-entry hunting season. Cougars live all across Utah, and prefer
NI pinyon-juniper and pine-oak brush areas where there are rocky cliffs, ledges and tall trees or brush UTSO
USFWS
Designated that can be used for cover. August 21, 2019
Species Pronghorn antelope: Year-long crucial habitats for pronghorn antelope is identified in both parcels
024 & 025. Stipulations developed in both the 2008 RMP and the 2016 MLP are developed to
protect habitats identified as crucial value fawning habitats, therefore the application of fawning
stipulations are not applicable to either parcel.
Desert bighorn sheep: Crucial and substantial year-long habitat occur within lease parcel 025 but
lambing and rutting is not identified or expected. Several multiple year GPS collar studies have
identified all suitable lambing areas in the region and both parcels are well outside of identified
lambing areas.
Plants
List (UT-IM-2019-005, March 4, 2019), lists 105 BLM sensitive plant species, including 12 species
which occur or potentially occur within the December 2019 lease sale analysis area. Lease notice Karen Cathey
UT-LN-49: Utah Sensitive Species will be applied to every parcel. Available data sources,
BLM Sensitive including BLM data layers and site specific BLM expertise were used to determine if the known or UTSO
NI
Plant Species potential habitat falls within parcels 024 and 025, with the following results: August 21, 2019
The following species are known to occur within the region, however are not expected to occur on
parcels 024 and 025, due to lack of suitable habitat: Desolation Canyon columbine, Isely's
Milkvetch, Peabody's milkvetch/green peabodianus, Cisco milkvetch, stage milkvetch, canyonlands
184
August 2019

lomatium, entrada rushpink, Shultz’ stickleaf, Trotter’s oreoxis, alcove rockdaisy, Jane’s
globemallow, strigose townsendia. Because areas specific to the lease parcels have not been
extensively surveyed, and because seasonal conditions may change over time to allow unexpected
species to occur, UT-LN-49 will notify that the parcel has been identified as containing potential
habitat for BLM Sensitive Species and that modifications to the Surface Use Plan of Operations may
be required in order to protect these resources from surface disturbing activities. No surface use or
following endangered plant species as potentially occurring: Navajo sedge, San Rafael cactus. The
IPaC also lists potential for the threatened Jones’ cycladenia.
Navajo sedge: There are no known occurrences of this species in Moab FO jurisdictional area.
Endemic to the canyons of San Juan County, Utah and Coconino County, Arizona., it is restricted to
seep, spring, and hanging garden habitats in Navajo type Sandstone (Navajo, Cedar Mesa, and
Kayenta formations) at elevations ranging from 1150 to 1823 meters (UNPS 2015, UDWR 2005).
Threatened, Karen Cathey
The formations associated with Navajo Sedge are not found within 1.25 miles of parcels.
Endangered, UTSO
NI Candidate or San Rafael cactus: There are no known occurrences of this species in Moab FO. Species endemic to
Proposed Plant Emery County of central Utah and most commonly occurs on southern exposures, in desert shrub and August 21, 2019
Species juniper woodland communities, between the elevations of 1,450–2,080 m (4,760–6,820 ft). The San
Rafael cactus (SRCA) is known to occur primarily on the Carmel Formation, the Sinbad member of
the Moenkopi formation, and the Brushy Basin member of the Morrison Formations, in fine textured
clays, mildly alkaline soils rich in calcium derived from limestone substrates. Both parcels fall into
USFWS IPaC data developed from mapping five large geological formations where these specific
members occur and therefore may potentially produce areas with similar soil characteristic as found
in distant SRCU populations. Lease notice T&E 17: San Rafael Cactus will be applied to notify the
operator of potential occurrence and the need for surveys to determine presence. Should the species
be detected, adjustment at the site-specific level will occur when an APD is received to reduce
potential effects to this species, should it occur.
185
August 2019

Though the Brushy Basin member of the Morrison Formations and the Carmel Formation occurs in
the Moab FO, the required soils are not known to not occur in parcels 024 and 025. Examination of
soil layers for these 2 parcels indicate deeper more loamy and sandy surface soils with lower pH.
Part of parcel 24 is a soil complex of deep sandy soils and also a shallow flaggy loam (20-39% clay)
with a pH of 7.4-9. All soils are considered loam soils not clay. The SRCA is known from alkaline
clay soils, so it is not expected to occur on the two parcels. If additional habitat characteristics are
identified that indicate occupancy potential and if occupancy is determined, the application of T&E-
17: San Rafael cactus will allow the opportunity to make adjustments at the site-specific level when
an APD is received to reduce potential effects to the species.
Jones’ cycladenia: There are known plants within the Moab FO jurisdictional area, with parcels 024
and 025 occurring over 25 miles from nearest known population. However, both parcels fall into
spatial models predicting low to medium low potential for occurrence therefore both parcels will
have lease notice T&E 29: Jones’ cycladenia attached. No critical habitat has been designated for
this species. Occurs on gypsiferous saline soils on the Chinle, Cutler, and Summerville Formations
and is associated with buckwheat and Mormon Tea, cool desert shrub and juniper communities
between 4,400’ and 6,000’ elevation. (UNPS 2015, UDWR 2005).
Summary of attachments for threatened, endangered, candidate or proposed animal species, parcels
024 and 025:
T&E-17: San Rafael Cactus
T&E-29: Jones Cycladenia
Noxious/invasive weed species may be present on the subject parcels. Constraints, including the use
of certified weed free seed and vehicle/equipment wash stations, would be applied as necessary at the
Invasive APD stage as documented in filing plans and COAs. Control measures would be implemented during
Karen Cathey
Species/Noxiou any ground disturbing activity and documented through a PUP/PAR. Additional control and
NI s Weeds procedural information is documented in the Programmatic EIS Vegetation Treatments Using UTSO
Herbicides on BLM Lands in 17 Western States and its Record of Decision, (September 2007). If August 21, 2019
(EO 13112) treatment occurs as part of regular operations, BMPs, SOPs and site specific mitigation are applied at
the APD stage as COAs. Negligible impacts would be expected as a result of leasing and exploration.
Application of notice UT-LN-52 (noxious weed) is warranted on all parcels.
Vegetation This proposed sale and issuance of an oil and gas leases would not authorize ground disturbances Karen Cathey
NI
Excluding which could affect vegetation resources. Leasing is an administrative action that does not result in UTSO
186
August 2019

Special Status any surface disturbance. Site-specific effects cannot be analyzed until an exploration or development August 21, 2019
Species application is received, after leasing has occurred. There would be no impacts to vegetation resources
through sale of leases. There is some expectation that exploration or development could occur, at
which time additional NEPA would be conducted should an APD be filed. The applied lease
stipulations and notices will notify buyers during sale of leases and allow for the opportunity to make
adjustments at the site specific level when an APD is received and will ensure impacts are addressed.
Future development proposals on the leases would be subject to the standard lease terms, and all
applicable laws, regulations and onshore orders in existence at the time of lease issuance. Additional
detailed analysis in this EA is not necessary.
Scattered sparse woodlands exist areas adjacent to parcels 024 and 025, but not in quantities
sufficient to establish public harvest areas. Exploration or development would not limit use or access Karen Cathey
Woodland /
NI to any established wood sale areas. BMPs, SOPs and site specific mitigation may be applied at the UTSO
Forestry
APD stage as COAs. Per 43 CFR 5400 Sale of Forest Products, permits are required for severance August 21, 2019
and removal of forest products regardless of whether the product is utilized or not.
Environmental Justice and Socioeconomics
As defined in EO 12898, minority and low income populations do occur within or use areas within
Grand County (2012 Moab Master Leasing Plan Amendment). All citizens can file an expression of
Environmental interest or participate in the bidding process (43 CFR 3120.3-2). The stipulations and notices applied Bill Stevens
NI
Justice to the subject parcels do not place an undue burden on these groups. Leasing the nominated parcels 6/24/2019
would not cause any disproportionately high and adverse effects on minority or low income
populations. BMPs, SOPs and site specific mitigation may be applied at the APD stage as COAs.
Based on the RFDS, no quantifiable additional or decreased economic impact to the local
area/counties would be caused by exploration or development. The parcel areas would still receive
use by county residents and other visitors including recreationists regardless of alternative selected.
Socio- Socioeconomic impacts from leasing these parcels would be minor, relative to the planning area’s Bill Stevens
NI overall economy. The principal local economic benefit could come in the form of mineral lease
Economics 6/24/2019
payments. These payments, however, are based largely on the market value of future production,
which is difficult, if not impossible, to estimate reliably.. Land uses in county and parcel areas would
continue. Land use plan (as amended) allocations would not be altered. BMPs, SOPs and site specific
mitigation may be applied at the APD stage as COAs.
187
August 2019

Water Resources
Potential site-specific impacts relating to future authorizations will be analyzed when an APD is
received. Prior to approving an APD, Hydrologic and Engineering reviews would be conducted on all
proposed down-hole activities, including hydraulic fracturing (if proposed). All appropriate regulatory
and mitigation measures would be included in the approved APDs and all potential impacts would be
identified and addressed during the site-specific NEPA process.
Groundwater quality protection for oil and gas leasing, exploration and development is outlined in
Instruction Memorandum (IM) No. UT 2010-055: Protection of Ground Water Associated with Oil
and Gas Leasing, Exploration and Development- Utah BLM. The purpose of this IM is to clarify the
process for the protection of usable ground water zones (< 10,000 mg/L as defined in Onshore Oil and
Gas Order No. 2) associated with oil and gas exploration and development activities. All potential
usable water aquifers would be cased and cemented. Well casings would be pressure tested to ensure
integrity.
The lease parcels are not within nor do they contain any Sole Source Aquifers or Public Drinking
Water Water Source Protection Zones. David Pals
Resources/ The requirements for oil and gas drilling operations are described in Onshore Oil and Gas Order 7/2/19
Quality (OOGO) No. 2 and the requirements for disposal of produced water from oil and gas activities are
NI
(drinking/ contained in OOGO No. 7. Adherence to these regulatory requirements will adequately mitigate Ann Marie Aubry
surface/ impacts from the Proposed Action to groundwater resources. Specific to groundwater protection, 7-23-19
ground) OOGO #2 requires that the proposed casing, cementing and abandonment programs shall be
conducted as approved to protect and/or isolate all usable water zones and requires pressure testing the
casing string. Known water bearing zones would be protected by drilling requirements and, with
proper practices, contamination of ground water resources is highly unlikely. As a result, groundwater
resources would not be impacted to the degree that would require detailed analysis in the EA.
The lessee/operator would submit an APD when oil and gas exploration and development activities
are proposed. The APD would be subject to site specific NEPA analysis. An approved APD is subject
to standard operation procedures (SOP) required by regulation, stipulations attached to the lease, best
management practices (BMP) included in the APD submission, and conditions of approval (COA)
developed during the NEPA analysis and documentation process. These SOPS, BMPs and COAs
mitigate impacts to water resources from oil and gas exploration and development activities. Standard
operating procedures including interim and final reclamation are required and site specific APD
approvals would provide mitigation for potential direct and indirect impacts to surface water quality.
Surface water quality could be impacted by surface disturbance (APD stage-well pads, roads and
188
August 2019

pipelines) in or near perennial or intermittent streams or springs. The Moab RMP provides for the
protection of surface water resources with Management Decision SOL-WAT-5 which states “allow no
surface occupancy and preclude surface disturbing activities within 100-year floodplains, within 100
meters of a natural spring or within public water reserves” (ROD p. 102).
To protect surface water resources, apply stipulation UT-S-386 to parcels #24 and #25. Stipulation
UT-S-386 (within the MLP area) does not allow surface occupancy within 100-year floodplains, and
within 500 feet of intermittent and perennial streams, rivers, riparian area, wetlands, water wells, and
springs. Parcel #25 contains a large intermittent stream (White Wash) and both parcels #24 and #25
contain large ephemeral streams with developed floodplains.
The SOPs, BMPs, COAs and stipulations will adequately mitigate impacts from the Proposed Action
to surface water resources. Surface water resources will not be impacted to the degree that will
require detailed analysis in the EA.
Water resources may be present or high potential for water at some time of the year may occur on the
parcels. Further examination and a thorough analysis would be included when an APD is received and
before drilling is allowed.
Leasing of parcels would not directly affect these resources.
Applying the following stipulations to parcel #25 will minimize potential impacts to wetland and
riparian resources. BMPs, SOPs, and site specific mitigation may be applied at the APD stage as
COAs.
UT-LN-53: Riparian Areas states no surface use or otherwise disruptive activity allowed within 100
meters of riparian areas. Subject to this lease notice are parcels 025 which intersects the 100 meter Gabe Bissonette
Wetlands/ riparian area buffer mapped during the 2008 MLP. 7/1/2019
NI Riparian Zones Applying the following stipulations to parcels #24 and #25 will minimize potential impacts to wetland,
/ Floodplains riparian and floodplain resources. BMPs, SOPs, and site specific mitigation may be applied at the Ann Marie Aubry
APD stage as COAs. With these stipulations and other site specific mitigation practices, no detailed 7-23-2019
analysis is required in this EA.
UT-S-386—NSO: Water Resources applies to the MLP area and mandates no surface occupancy
within 100-year floodplains, and within 500 feet of intermittent and perennial streams, rivers, riparian
area, wetlands, water wells, and springs. Subject to this stipulation are parcels #24 and #25. Parcel
#25 contains a large intermittent stream (White Wash) and both parcels #24 and #25 contain large
189
August 2019

ephemeral streams with developed floodplains. Parcel #25 contains riparian resources along White
Wash.
UT-S-387—NSO: Ephemeral Streams applies to the MLP area and states no surface occupancy
allowed within 100 feet of ephemeral streams. Subject to this stipulation are parcels #24 and #25
which have ephemeral streams mapped in the MLP data.
UT-LN-128: Floodplain Management mandates avoiding adverse impacts to floodplains. Both parcels
#24 and #25 contain large ephemeral streams with floodplains. Parcel #25 also intersects the 500’
buffer for mapped riparian areas and intermittent streams as mapped in the 2008 MLP and National
Wetlands Inventory data.
are proposed. The APD would be subject to site-specific NEPA analysis. An approved APD is
subject to standard operation procedures (SOP) required by regulation, stipulation attached to the
lease, best management practices (BMP) included in the APD submission, and conditions of approval
(COA) developed during the NEPA analysis and documentation process. These SOPs, BMPs, COAs
mitigate impacts to soils from oil and gas exploration and development activities.
At this stage (lease sale) there would be no impacts to soil resources. There is some expectation that Katherina Diemer
Soils: exploration or development could occur, at which time additional NEPA would be conducted should 7/2/2019
NI Physical/ an APD be filed. If additional site specific resource protection measures are needed to prevent
Biological unnecessary or undue degradation, these would be developed at the time of the site specific NEPA. It Ann Marie Aubry
is expected that reclamation procedures would be required to ensure long-term soil impacts are
7-23-2019
minimized. Reclamation provisions/procedures would include re-vegetation (utilizing appropriate
seed mix based on the ecological site, elevation and topography), road reclamation, noxious weed
controls, etc.
BMPs and SOPs to protect soil resources are defined in the Moab RMP and MLP. Site-specific
design features and reclamation requirements would be applied at the APD stage as COAs.
Application of UT-S-384 to parcels 024 and 025 is warranted depending on placement of disturbance.
Rangeland Health
190
August 2019

Farmlands
The Moab FO does not include any prime farmland, nor do any of the alternatives impact any prime Ann Marie Aubry
NI (Prime or farmland soils, therefore no further analysis is required in the EA. 7-23-2019
Unique)
are proposed. The APD would be subject to site-specific NEPA analysis. Appropriate measures Josh Relph
Fuels/Fire
NI contained in the APD or developed during the NEPA process would mitigate impacts to fuels and fire
Management 7/2/2019
management. Fuels and fire management is not impacted to the degree that would require detailed
analysis in the EA.
are proposed. The APD would be subject to site-specific NEPA analysis. An approved APD is
subject to standard operation procedures (SOP) required by regulation, stipulation attached to the
lease, best management practices (BMP) included in the APD submission, and conditions of approval
(COA) developed during the NEPA analysis and documentation process. These SOPs, BMPs, COAs
mitigate impacts to livestock from oil and gas exploration and development activities.
All parcels are located within livestock grazing allotments. Any activity that involves surface
Livestock disturbance or direct resource impacts would have to be authorized as a lease operation through Alan Bass
NI future NEPA analysis, on a case-by-case basis, at the ADP stage. Impacts to livestock grazing may
Grazing 6/26/2019
occur as a result of subsequent actions including exploration development, production, etc.
Therefore, reclamation provisions/procedures including re-vegetation (utilizing appropriate seed mix
based on the ecological site, elevation and topography), and road reclamation. Standard terms of the
lease agreements include the ability to move the well 200 meters, which would avoid most range
improvements and rangeland trend studies. Changes to grazing permit terms and conditions,
exchange of use agreements or assignments of range improvements would not occur as a result
leasing or exploration. For reasons listed above, there are no affects to livestock grazing to a degree
that detailed analysis is required.
Wild Horses Angela Wadman
NP The parcels do not intersect herd areas or herd management areas.
and Burros 8/20/2019
Lands and Minerals
191
August 2019

The lease parcels would be subject to all valid existing rights. Impacts to individual rights-of-way
would be determined at the time a specific development proposal is received and any required
modification or mitigation would be included in the authorization
Impacts to lands/access would be analyzed in project specific NEPA documentation and modification
and/or mitigation included in the project specific approved APD. Lands/Access is not impacted to a Jonathan Jew
NI Lands/Access degree that would require detailed analysis.
7/02/19
There are no withdrawals or Recreation and Public Purpose Act leases present on the proposed lease
parcels.
Application of stipulation UT-S-364-Moab, concerning high use filming locations, to parcels 024 and
025 is warranted. Application of lease notice UT-LN-83, concerning the presence of existing right-of-
way, to parcel 025 is warranted.
Oil and gas exploration could lead to an increased understanding of the geologic setting, as
subsurface data obtained through lease operations may become public record. This information
promotes an understanding of mineral resources as well as geologic interpretation. While conflicts
could arise between oil and gas operations and other mineral operations, these could generally be
mitigated under 43 CFR 3101.1-2 and under standard lease terms (Sec. 6) where sitting and design of
facilities may be modified to protect other resources.
Depending on the success of oil and gas drilling, non-renewable natural gas and/or oil would be
Geology / extracted and delivered to market. Production would result in the irretrievable loss of these resources.
David Pals
Mineral The RFDS is documented at section 2.2.1. The proposed action would not exceed the level of activity
predicted in the RFDS. 7/02/19
NI Resources/
Energy If the parcels are developed, wells within the parcels may be completed using hydraulic fracturing Angela Wadman
Production techniques. Additional information is provided in Appendix G. “FracFocus,” is a database available 8/14/2019
to the public online at http://fracfocus.org/. Public has expressed concerns that:
• Spills during the management of hydraulic fracturing fluids and chemicals or produced water
that result in large volumes or high concentrations of chemicals reaching groundwater
resources;
• Injection of hydraulic fracturing fluids into wells with inadequate mechanical integrity,
allowing gases or liquids to move to groundwater resources; and,
• Discharge of inadequately treated hydraulic fracturing wastewater to surface water resources.
192
August 2019

Before operators or service companies preform hydraulic fracturing treatment, a series of tests are
preformed to ensure well, casing, and well equipment are in proper order and will safely withstand
the application of the fracture treatment pressures and flow rates. Operators must comply with O.O.
#2 and O.O. # 7. If fracking should occur in an area where there is no vertical separation between the
hydraulically fractured rock formation and the bottom of the potential underground drinking water
source, fracking fluid may be introduced into the source. However, the occurrence of fracking within
a potential drinking water source is low for the Box Elder County Parcels (EPA 2016 p. 27).
The majority of flow back water from hydraulic fracturing in Utah is recycled and used in future
hydraulic fracturing completions. Therefore, the underground injection of hydraulic fracturing flow
back in Utah is very limited and presents little potential for inducing seismic activity. In fact, there
has been no reported induced seismicity in Utah that was from water injected into Class II wells. Oil
and gas wells produce a great amount of wastewater. The majority this water has high salt brine
content and must be disposed of in an environmentally safe manner. In Utah, a majority (95%) of this
produced water is pumped into Class II injection wells. In certain parts of the country, water injection
has caused some induced seismicity in the form of small earthquakes. Two major factors play a role
in induced seismicity from water injection. First, the amount of water being injected. Secondly, the
local geology of the water injection site. In Utah, the volumes are lower than those states
experiencing induced seismicity. Also, the geology is different than those states experiencing induced
seismicity. The injection zones are stratigraphically thousands of feet above the basement rock that
may contain large unknown faults. Therefore, at this time it appears that induced seismicity from
water injection is not a problem in the oil fields of Utah. (Personal communication from John Rogers,
Utah Division of Oil, Gas and Mining (UDOGM), March 27, 2018).
.
The sale and issuance of an oil and gas lease is an administrative action that does not result in any
surface disturbance. However, the issuance of a lease is considered to be an irretrievable commitment
of resources because the BLM generally cannot deny all surface use of a lease unless the lease is
issued with a no surface occupancy stipulation. David Pals
NI Paleontology
The lessee/operator would submit an APD when oil and gas exploration and development activities 07/02/19
are proposed. The APD would be subject to site-specific NEPA analysis.
Lease parcel 024 contains an area of high potential for paleontological resources. The Moab Master
Leasing Plan contains management decisions to protect paleontological resources (Moab MLP – PAL,
193
August 2019

p. 23). Apply a CSU stipulation requiring survey and monitoring (where appropriate) for all surface-
disturbing mineral activities in potential fossil yield classification (PFYC) Class 4 and 5 areas. GIS
was used to determine the potential fossil yield classification (PFYC) for each parcel. It was
determined that parcel 024 had PFYC of 4 or 5. Therefore, lease notice UT-LN-72: High Potential
Paleontological Resources will be attached to all parcels. This lease notice notifies the lessee that if
they develop their lease, they may have to conduct paleontological surveys. Application of stipulation
UT-S-370 to parcel 24 is warranted.
The lessee/operator is given notice that lands in this lease have been identified as having high
potential for paleontological resources. Surveys will be required and modifications to the Surface Use
Plan of Operations Statewide may be required in order to protect paleontological resources from
surface disturbing activities in accordance with Section 6 of the lease terms and 43 CFR 3101.1 -2. In
addition, monitoring may be required during surface disturbing activities.
Hazardous materials are not known to exist on the parcels. Refer also to the Air Quality discussion
for specific information on hazardous air pollutants (HAPs). Hazardous materials, if not handled
properly that are associated with operations, have the potential to be spilled at the lease/drill site.
However, the spill would be contained, reported, and cleaned up by the operator. BMPs, SOPs and
Wastes
site specific mitigation may be applied at the APD stage as COAs. David Pals
NI (hazardous or
The construction, drilling, completion, testing, and production of an oil and gas well would produce 07/02/2019
solid)
waste products including drilling and completion fluids and produced water. SOP, BMPs, and COAs
will mitigate impacts and ensure proper containment and disposal of wastes generated from oil and
gas activities. Wastes will not cause impacts to the degree that would require detailed analysis in the
EA.

nation Monticello Field Office
Air
194
August 2019

Erik Vernon
8/28/2019
on all parcels.
Greenhouse
Gases 8/28/2019.
for Air Quality.
Recreation
Areas of
Critical Sheri Wysong
NP The parcels do not intersect any ACECs.
Concern
National Park There are no Congressionally designated National Historic Trails proximate to the project area.
Service Additionally, there are no segments of trails under the National Trail Feasibility Study nor trails Sheri Wysong
NP
Lands/National recommended as suitable for Congressional designation, but not yet designated. The parcels are also 8/15/2019
Historic Trails not in the proximity of any NPS lands.
BLM- The parcels are over five miles from the Canyons of the Ancients National Monument, and over nine Sheri Wysong
NI Administered miles from the Bears Ears National Monument. Development of the parcels as anticipated in the
Monuments Reasonably Foreseeable Development Scenario is not anticipated to have impacts to the Monuments. 8/15/2019
Parcel 035 is within an area utilized by a Wilderness Therapy permittee. Development of this parcel
and/or adjacent leases may result in the permittee having to relocate part of its operating area. Sheri Wysong
NI Recreation However, development of the parcel as anticipated in the Reasonably Foreseeable Development
Scenario is not anticipated to cause a substantial change in its operations. BMPs, SOPs and site 8/15/2019
195
August 2019

There are no Backcountry Byways in the area. Exploratory access to all nominated lease parcels may
Travel/ necessitate the use of the Bicentennial – Trail of the Ancients Scenic Byway. Improvements and Sheri Wysong
NI
Transportation regular maintenance may be necessary to public access roads throughout the project area. BMPs, 8/15/2019.
SOPs and site specific mitigation may be applied at the APD stage as COAs.
All nominated parcels occur within a Scenic Quality Class B area., and are parcels are located in Sheri Wysong
Visual
NI VRM Class IV areas. The proposed action would not conflict with standard management goals for
Resources 8/15/2019
VRM Class IV areas.
Wild and Sheri Wysong
NP The lease parcels do not overlap any suitable WSR segments.
Wilderness/Wil Sheri Wysong
NI derness Study No parcel is closer than 3 miles from any Wilderness Study Area.
Area 8/15/2019
Lands with Sheri Wysong

Parcel 035 is entirely within the Monument Canyon Lands with Wilderness Characteristics Unit.
NI wilderness
Rationale for the finding that no detailed analysis is necessary is in Section 1.8 of the EA. 8/15/2019
characteristics
Cultural
BLM archaeologists have compiled cultural resources data from the Monticello field office cultural
Cultural lease notices as required by the Monticello RMP. Glenn Stelter
NI
Resources The Monticello RMP requires stipulation UT-S-170: CSU – Cultural to be attached to all parcels. 08/16/2019
For future undertakings related to this lease sale, BLM will not approve any ground disturbing
activities until it completes its obligations to consider cultural resources under NEPA, NHPA and
other authorities specific to those future undertakings. Consideration of impacts to cultural resources
196
August 2019

and adverse effects to historic properties will be taken into account during the review stage of site

Cultural Resource Stipulation as required by Handbook H-3120-1, UT-LN-66 (Cultural Resources
Located Sandy or Erodible Soils), and UT-LN-70 (High Potential for Cultural Resource Occurrence)
to all parcels.
The following Tribes were invited to consult on this project via certified letter on 07-25-2019: All
Nation, Kaibab Band of Paiute Indians, Kanosh Band of Paiutes, Moapa Band of Paiute Indians,
Navajo Nation, Navajo Nation, Aneth Chapter, Navajo Nation, Dennehotso Chapter, Navajo Nation,
Kayenta Chapter, Navajo Nation, Mexican Water Chapter, Navajo Nation, Navajo Mountain Chapter,
Navajo Nation, Oljato Chapter, Navajo Nation, Red Mesa Chapter, Navajo Nation, Shonto
Community Governance, Navajo Nation, Teec Nos Pos Chapter, Navajo Utah Commission,
Native Northwest Band of Shoshone Nation, Ohkay Owingeh, Paiute Indian Tribe of Utah , Pueblo of
American Acoma, Pueblo of Cochiti, Pueblo of Isleta, Pueblo of Jemez, Pueblo of Kewa (Santo Domingo), Glenn Stelter
NI Pueblo of Laguna, Pueblo of Nambe, Pueblo of Ohkay Owingeh, Pueblo of Picuris, Pueblo of
Religious 08/16/2019
Concerns Pojoaque, Pueblo of San Felipe, Pueblo of San Ildefonso, Pueblo of Sandia, Pueblo of Santa Ana,
by any Tribe.
Wildlife
Karen Cathey
Greater Sage- No habitat suitable for the Greater sage-grouse occurs in the parcels proposed for the December 2019
NI UTSO
Grouse lease sale located within the MtFO area.
August 21, 2019
197
August 2019

The following documents are incorporated: Utah Wildlife Action Plan (2015), Utah Partners in Flight
Avian Conservation Strategy Version 2.0. (Parrish et al. 2002), Birds of Conservation Concern
Birds, MOU between the USDI BLM and USFWS to Promote the Conservation and Management of
Migratory Birds (4/2010), and Utah Supplemental Planning Guidance: Raptor Best Management
Practices (BLM UTSO IM 2006-096).
2010-04) provides BLM further direction for project-level NEPA guidance for meeting MBTA Karen Cathey
NI Migratory Birds conservation and compliance. Bald and golden eagles receive additional protections under the Bald UTSO
and Golden Eagle Protection Act of 1962. Potential for impacts to these eagle species is discussed August 21, 2019
Lease notice UT-LN-45: Migratory Bird, would be applied to all parcels. BMPs, SOPs and site
following endangered animal species as potentially occurring: California condor, southwestern
Threatened, willow flycatcher, and the Colorado River fish (bonytail chub, Colorado pikeminnow, humpback
Endangered, chub, razorback sucker). The IPaC also lists potential for the threatened Mexican spotted owl, and Karen Cathey
NI Candidate or yellow-billed cuckoo. No designated critical habitat for these species occurs in the parcels proposed UTSO
Proposed for the December 2019 lease sale. August 21, 2019
Animal Species
California condor: All parcels within the MTFO area identified for the December 2019 lease sale are
located within the condor endangered species designated area, and will have stipulation UT-S-294:
CSU/TL – California Condor and lease notice T&E 11: California Condor Potential Habitat applied.
California condors prefer mountainous country at low and moderate elevations, especially rocky and
brushy areas near cliffs. Breeding populations are restricted to California and Northern Arizona, near
198
August 2019

release sites, and no known nest sites occur on the parcels. Application of stipulations and notices
will minimize risk to the condor, should it occur, through requirements for best management
practices to reduce likelihood of impacts (e.g., removal of trash, carrion, and hazardous materials,
surveys and monitoring, reduction of construction footprint, etc.). Such requirements will minimize
the potential for direct and indirect impacts to the species.
Southwestern willow flycatcher: Parcels 027 and 030 contain or are within 0.5 miles of riparian
areas, which is potential habitat for the species. Stipulation UT-S-290: CSU/TL – Southwestern
Willow Flycatcher and lease notice T&E-07: Southwestern Willow Flycatcher will be applied to
these parcels, which will avoid or restrict activities on the parcels that may cause stress and
disturbance during nesting and rearing of their young. Surveys and monitoring may be required, and
additional measures to avoid or minimize effects may be required to ensure compliance with the
Endangered Species Act. These requirements minimize the likelihood of effects to this endangered
species.
Colorado River Fish: No potential habitat for Colorado Endangered Fish species occurs on parcels
within the MTFO area identified for the December 2019 lease sale. However, the parcels occur
within watersheds of the Upper Colorado River, where water depletions may have potential to
indirectly impact these species. Water depletions from any portion of the Upper Colorado River
drainage basin above Lake Powell are considered to adversely affect or adversely modify the critical
habitat of the four resident endangered fish species. The application of stipulation UT-S-182: NSO
Critical Habitat of the Colorado River Endangered Fish allows opportunity to make adjustments at
the site-specific level when an APD is received to reduce potential effects to the species, in addition
to requirements regarding measures to management of water production, avoiding disturbance to
riparian areas, and best management practices with regard to construction. Implementation of this
stipulation will minimize the potential for significant impacts to these species.
Mexican spotted owl: No critical habitat is within the lease parcels but some of the parcels do fall
into modeled habitat or are within 0.5 miles of modeled habitat. (Based upon Willey/Spotsky 1997
model, none falls into the Lewis 2014 model). Stipulation UT-S-288: CSU/TL – Mexican Spotted
Owl and T&E-06: Mexican Spotted Owl will be applied to all parcels. Collectively these
attachments will require conservation measures to ensure activities will not occur and habitat will be
protected from disruption when the species is present. These measures will minimize the likelihood
of impacts to the threatened species.
199
August 2019

Yellow-billed cuckoo: Parcels 027 and 030 contain or are within 0.5 miles of riparian habitat.
Stipulation UT-S-297: CSU-TL – Yellow-billed Cuckoo, and UT-LN-113: Yellow-billed Cuckoo
would require conservation measures to ensure activities will not occur and habitat will be protected
from disruption when the species is present. These measures will minimize the likelihood of impacts
to the threatened species.
Summary of attachments for threatened, endangered, candidate or proposed animal species, as noted:
• UT-S-182: NSO Critical Habitat of the Colorado River Endangered Fish – All parcels
• UT-S-288: CSU/TL – Mexican Spotted Owl – All parcels
• UT-S-290: CSU/TL – Southwestern Willow Flycatcher – Parcels 027, 030
• UT-S-294: CSU/TL – California Condor – All parcels
• UT-S-297: CSU/TL – Yellow-billed Cuckoo - Parcels 027, 030
• T&E-06: Mexican Spotted Owl – All parcels
• T&E-07 Southwestern Willow Flycatcher Parcels 027, 030
• T&E-11: California condor – Potential Habitat – All parcels
• UT-LN-113: Yellow-billed Cuckoo – Parcels 027, 030
List (UT-IM-2019-005, March 4, 2019), lists 72 BLM sensitive animal species, including 22 species
which occur or potentially occur within the December 2019 lease sale analysis area. Lease notice
UT-LN-49: Utah Sensitive Species and UT-LN-44: Raptors and UT-LN-45: Migratory Bird, will be
applied to every parcel. Available data sources, including BLM data layers and that available
through Utah Conservation Data Center (UCDC) were used to determine if the known or potential
BLM Sensitive habitat falls within parcels within the MtFO area identified for the December 2019 lease sale. The Karen Cathey
NI Wildlife following species may occur: UTSO
Species August 21, 2019
Kit fox: Suitable habitat occurs within the lease parcels. The 2014 habitat model for Kit fox indicates
a high probability of kit fox occurrence within the parcels identified for leasing. Kit foxes live
primarily in open desert, shrubby or shrub-grass habitat; shadscale, greasewood or sagebrush. The
primary food item is usually the most abundant nocturnal rodent or lagomorph in the area. Kit foxes
may also feed opportunistically on birds, reptiles, and insects. Several dens may be used, especially in
summer (Natureserve 2008).
200
August 2019

Gunnison’s prairie-dog: Active colonies are found in Grand and San Juan Counties. This species is
managed under the Utah Gunnison‘s prairie dog and white-tailed prairie dog conservation plan. Lease
notice UT-LN-25: Gunnison Prairie Dog will be attached to all parcels.
Spotted bat: There is documentation of this species in the MtFO area. (www.utahbats.com) Suitable
roosting and foraging habitat occurs within the lease parcels; however, there are no known
populations at this time. Spotted bats are managed under the Utah Bat Conservation Plan. They are
found in desert to montane coniferous stands, including pinyon juniper woodland, canyons, open
pasture, and hayfields, roosting in caves, cracks, and crevices in cliff/canyon habitats.
Townsend’s big-eared bat: These species potentially occurs throughout Utah and there is
documentation of this species in the MtFO area (www.utahbats.com). Suitable foraging habitat
(marginal) occurs within the lease parcels; however, there are no known populations. The species
depends on caves and mines year round for maternity colonies and hibernacula.
Bald eagle: The lease parcels contain suitable foraging habitat, although of marginal to low quality.
Bald eagles occur in San Juan county, chiefly during the winter. Wintering areas are commonly
associated with open water, although in some areas, eagles use habitats with little or no open water if
other food resources (e.g., rabbit or deer carrion) are readily available. Winter roosting areas may
occur within the parcels; but, there are no known nests. Implementation of stipulation UT-S-275
Bald Eagles and lease notice UT-LN-107 Bald Eagles on parcels 029, 030, 031, 032, and 034, to
avoid nesting seasons, would eliminate potential disturbance to a nesting eagles if found, and allow
the opportunity to make adjustments at the site-specific level when an APD is received to reduce
potential effects to the birds in the area.
Golden eagle: Golden eagles are distributed throughout most of Utah, and suitable foraging and
nesting habitat occurs in all lease parcels. This species prefers open country, especially around
mountains, hills and cliffs.
Ferruginous hawk: Ferruginous hawks are distributed throughout most of Utah and may occasionally
occur in very open, dry habitat. Foraging habitat occurs in all parcels located in the MtFO area,
proposed for the December 2019 lease sale. Juniper trees are the primary nesting substrate in Utah,
but they will also nest on the ground or on power line structures.
Burrowing owl: Suitable habitat occurs within all the lease parcels within the MtFO area proposed in
the December 2019 lease sale. This species prefers open areas within deserts, grasslands, and
sagebrush steppe communities; and nests/roosts in underground burrows in open and short-grass
201
August 2019

habitats. Habitat consists of well-drained, level to gently sloping areas characterized by sparse
vegetation and bare ground.
Lewis’ woodpecker: Marginal suitable habitat for this species occurs within the lease parcels;
transient birds may occur, but it is not known to be a permanent resident. Breeding habitat consists of
mainly open park-like ponderosa pine forests, but they are also found in mixed conifer, pinyon-
juniper, riparian and oak woodlands. Wintering grounds are spread over a wide range of habitats.
Bobolink: There are no known occurrences of the bobolink within the MtFO but the lease parcels
potentially overlap with high value habitat value according to UDWR conservation data. This species
breeds, nests, and forages in wet meadow, wet grassland, and irrigated agricultural areas that tend to
be associated with riparian or wetland areas.
Desert night lizard: While occurrences are rare in Utah, mainly associated with Joshua trees in the
Mojave desert, there are a few documented collections and sightings of this lizard in the MtFO area.
None were within the parcels identified for the December 2019 lease sale. The UDWR identifies
critical habitat for the species, in the Utah Conservation Data Center.
Great Plains toad: There are no known occurrences of this species in the MtFO; however, the DWR
natural heritage data identifies areas in the lease parcels mapped as high to substantial value habitat.
This species prefers grasslands with loose soil for burrowing, in and near riparian corridors or wet
areas. Substantial and high value habitat may include vernal/ephemeral pools, ephemeral and
intermittent streams or small unmapped desert seeps/springs, which would provide important
breeding habitat.
Summary of lease notices applied to all parcels identified within the MtFO area specific to the
December 2019 lease sale unless otherwise noted, to protect BLM Sensitive animal species:
• UT-S-275: CSU/TL Bald Eagles – Parcels 029, 030, 031, 032 and 034
• UT-LN-25: White-tailed and Gunnison Prairie Dog
• UT-LN-45: Migratory Bird
• UT-LN-49: Utah Sensitive Species
• UT-LN-107 Bald Eagles – Parcels 029, 030, 031, 032 and 034
These stipulations and lease notices were designed by the BLM in coordination with UDWR and the
USFWS to provide protections through general and specific measures which would identify and
202
August 2019

protect BLM sensitive species. Where a specific lease notice is not specifically noted above,
implementation of lease notices for sensitive species, migratory birds and raptors, applied to every
parcel, will allow for the opportunity to make adjustments at the site specific level when an APD is
received if circumstances change to allow potential for occurrence of these species.
Parcels located within the MtFO area which are proposed for the December 2018 lease sale were
evaluated for State identified game species, including the American bison, cougar, black bear, moose,
Rocky Mountain elk, mule deer, pronghorn antelope, mountain goat, California bighorn sheep, desert
bighorn sheep, Rocky Mountain bighorn sheep, snowshoe hare, wild turkey, chukar, California quail,
band-tailed pigeon, sharp-tailed grouse, ruffed grouse, dusky/blue grouse, white-tailed ptarmigan and
ring-necked pheasant using UDWR data. Habitat for those not listed below is was not identified.
Cougar: All parcels fall in the San Juan subunit of the Abajo management unit for the cougar,
managed by UDWR for annual statewide limited-entry hunting season. Cougars live all across Utah,
and prefer pinyon-juniper and pine-oak brush areas where there are rocky cliffs, ledges and tall trees
or brush that can be used for cover.
Fish and Black bear: No specific habitat exists on the proposed parcels, but year-long crucial habitat for the
Wildlife black bear is located within 5 miles of parcels 027 and 035. And transient individuals may be
attracted to trash or stored food. Best management practices should be practiced with regard to these Karen Cathey
Excluding
NI attractants. UTSO
USFWS
Designated Mule deer: Parcel 033 and portions of parcels 030, 032, and 034 occur in winter substantial habitat August 21, 2019
Species for this species. Parcels 027, 028, 029, 031 and 035, and portions of parcel 030, 032 and 034 occur in
winter crucial habitat. Implementation of UT-S-234: Crucial Deer Winter Range will restrict surface
disturbing activities to times outside of winter range use, thus minimizing impacts caused by stress
and disturbance to the species during crucial winter months.
December 2019 lease sale unless otherwise noted, to protect fish and wildlife excluding USFWS
designated species:
• UT-S-234: TL – Crucial Deer Winter Range - 027, 028, 029, 030, 031, 032, 034 and 035
These stipulation was designed by the BLM in coordination with UDWR to provide protections
through general and specific measures which would identify and protect BLM sensitive species.
Where a specific lease notice is not specifically noted above, implementation of lease notices for
203
August 2019

sensitive species applied to every parcel, will allow for the opportunity to make adjustments at the
site specific level when an APD is received if circumstances change to allow potential for occurrence
of these species. No surface use or otherwise disruptive activity would be allowed that would result in
direct disturbance to populations or individual special status species.
Plants
List (UT-IM-2019-005, March 4, 2019), lists 105 BLM sensitive plant species, including 12 species
which occur or potentially occur within the December 2019 lease sale analysis area. Lease notice
UT-LN-49: Utah Sensitive Species will be applied to every parcel. Available data sources, including
BLM data layers and site specific BLM expertise were used to determine if the known or potential
habitat falls within the parcels identified for the December 2019 lease sale, with the following results:
Alcove rockdaisy - There are no known plants in the lease parcels but the habitat could occur. Found
only in "hanging gardens" along streams and near seeps in Grand and San Juan counties. Occurs at
elevations between 1100–2300 m (UNPS 2015).
Jane’s globemallow - There are no known plants in the lease parcels but the habitat could occur.
Endemic to the Utah Canyonlands, along the Colorado and Green Rivers in southwestern Grand,
northwestern San Juan, and western Wayne counties. Occurs in warm, salt, and mixed desert shrub Karen Cathey
BLM Sensitive
NI communities on the Shinarump and Moenkopi formations and White Rim and Organ Rock members UTSO
Plant Species of the Cutler Formation; fequently on sandy and gravelly soils of the weathered underlying August 21, 2019
formations, often on river benches and roadsides.1200-1400m elevation. (UNPS, 2015; BLM,
2008a; BLM, 2008c)
Cronquists milkvetch - There are no known plants in the lease parcels but the habitat could occur.
This species is a narrow regional endemic of the Colorado Plateau found from San Juan County,
Utah to Montezuma County, Colorado. Low, sandy or gravelly ridges and sandy washes in
blackbrush and salt desert shrub communities on sandstone or red sandstone of the Cutler and
Morrison formations. Occurs at elevations between 1200-1525m. (UNPS 2015).
Kachina daisy - There are no know plants in the lease parcels but the habitat could occur. This
species is endemic to the Colorado Plateau region of southeastern Utah and southwestern Colorado.
Low elevation seeps, springs, and hanging gardens to high elevation mesic sandstone outcrops in
aspen and ponderosa pine communities from 1400 to 2600 m elevation (UNPS 2015).
204
August 2019

Redroot buckwheat - There are no known plants in the lease parcels but the habitat could occur.
This species inhabits areas of oak, maple, snowberry, serviceberry, pinyon-juniper, juniper
manzanita, and ponderosa pine at elevations of 4,250-5,000 feet. (UNPS 2015)
Paradox breadroot - There are no known plants in the lease parcels but the habitat could occur. This
species occurs in open pinyon-juniper woodlands, with sandy or clay soils. Occurs from 4,623 -
6,693ft in elevation.
Beaman’s townsendia: Endemic to San Juan County, found in piñon-juniper and ponderosa pine
communities from 6,200–7,215 (Welsh et al. 2011)
December 2019 lease sale unless otherwise noted, to protect BLM Sensitive Species:
• UT-LN-49 Sensitive Species

Threatened, Planning, and Conservation (IPaC) System for the RHA area on July 10, 2019. The IPaC lists the
Endangered, following threatened plant species as potentially occurring: Jones’ cycladenia. However, there are Karen Cathey
NP Candidate or There are no known plants within the MtFO and none of the parcels fall into spatial modeled habitat. UTSO
Proposed Plant No critical habitat has been designated for this species. Occurs on gypsiferous saline soils on the August 21, 2019
Species Chinle, Cutler, and Summerville Formations. Associated with buckwheat and Mormon Tea, cool
desert shrub and juniper communities between 4,400’ and 6,000’ elevation. (UDWR 2005, UNPS
2015)
Invasive Noxious/invasive weed species may be present on the subject parcels. Constraints, including the use
of certified weed free seed and vehicle/equipment wash stations, would be applied as necessary at the Karen Cathey
Species/Noxiou
NI s Weeds APD stage as documented in filing plans and COAs. Control measures would be implemented during UTSO
any ground disturbing activity and documented through a PUP/PAR. Additional control and August 21, 2019
(EO 13112)
procedural information is documented in the Programmatic EIS Vegetation Treatments Using
205
August 2019

Herbicides on BLM Lands in 17 Western States and its Record of Decision, (September 2007). If
treatment occurs as part of regular operations, BMPs, SOPs and site specific mitigation are applied at
the APD stage as COAs. Negligible impacts would be expected as a result of leasing and exploration.
Application of notice UT-LN-52 (noxious weed) is warranted on all parcels.
This proposed sale and issuance of an oil and gas leases would not authorize ground disturbances
which could affect vegetation resources. Leasing is an administrative action that does not result in
any surface disturbance. Site-specific effects cannot be analyzed until an exploration or development
application is received, after leasing has occurred. There would be no impacts to vegetation resources
Vegetation Karen Cathey
through sale of leases. There is some expectation that exploration or development could occur, at
Excluding
NI which time additional NEPA would be conducted should an APD be filed. The applied lease UTSO
Special Status
stipulations and notices will notify buyers during sale of leases and allow for the opportunity to make August 21, 2019
Species
adjustments at the site specific level when an APD is received and will ensure impacts are addressed.
Future development proposals on the leases would be subject to the standard lease terms, and all
applicable laws, regulations and onshore orders in existence at the time of lease issuance. Additional
detailed analysis in this EA is not necessary.
Scattered sparse woodlands exist areas adjacent to all parcels within the MtFO area included in the
proposed lease sale, but not in quantities sufficient to establish public harvest areas. Exploration or Karen Cathey
Woodland / development would not limit use or access to any established wood sale areas. BMPs, SOPs and site
NI UTSO
Forestry specific mitigation may be applied at the APD stage as COAs. Per 43 CFR 5400 Sale of Forest
Products, permits are required for severance and removal of forest products regardless of whether the August 21, 2019
product is utilized or not.
San Juan County. All citizens can file an expression of interest or participate in the bidding process
(43 CFR 3120.3-2). The stipulations and notices applied to the subject parcels do not place an undue
Environmental burden on these groups. Leasing the nominated parcels would not cause any disproportionately high Cliff Giffen
NI
Justice and adverse effects on minority or low income populations. Potential impacts to Environmental 2019.06.25
Justice from oil and gas leasing are adequately analyzed and documented in the environmental
analysis prepared for the Monticello RMP. Actions and impacts are not changed from those disclosed
in the existing NEPA documents.
206
August 2019

Potential impacts to socio economics from oil and gas leasing are adequately analyzed and Cliff Giffen
Socio-
NI documented in the environmental analysis prepared for the Monticello RMP. Actions and impacts are
Economics 2019.06.25
not changed from those disclosed in this NEPA document.
Water Resources
There are no identified ground or surface drinking water protection zones within the lease parcels,
although there is a protection zone adjacent to parcel #33.
Multiple water rights held by both BLM and individuals are located in or near the lease parcels.
These water rights have beneficial uses of stockwater, irrigation, and domestic. Water quality must
continue to be acceptable to meet the beneficial uses of the water right. Exploration and development
could cause impacts. Potential impacts to surface water resources from oil and gas leasing are
adequately analyzed and documented in the environmental analysis prepared for the 2008 Monticello
RMP.
The following notice would be added to all parcels to inform potential lessees of the requirements of
EO 11988: UT-LN-128: Floodplain Management.
Water If an APD is filed, SOPs required by regulation and design features would be sufficient to isolate and
protect all usable ground or surface water sources before drilling or exploration begin. The SOPs Melissa Wardle
Resources/ 7/03/2019
Quality include the requirements for disposal of produced water contained in Onshore Oil and Gas Order
NI (O.O.) No. 7 and the requirements for drilling operations contained in O.O No. 2. Potential fresh
(drinking/
surface/ water aquifers zones would be protected by the requirement of casing and cementing the drill hole to Ann Marie Aubry
ground) total depth. The casing would be pressure tested to ensure integrity prior to drilling out the surface 7-23-2019
casing shoe plug.
Potential impacts would be addressed and a design features would be included utilizing UT IM 2010-
055 (Protection of Ground Water Associated with Oil and Gas Leasing, Exploration and
Development) prior to APD approval. Standard protocols would minimize possibility of releases
(cased drill holes, no surface disturbance or occupancy would be maintained within 660 feet of any
natural springs, new disturbance would be not be allowed in areas equal to the 100-year floodplain or
100 meters on either side of the center line of any stream, stream reach, or riparian area).
BMPs, SOPs and site specific mitigation may be applied at the APD stage as COAs.
The SOPs, BMPs, COAs and stipulations will adequately mitigate impacts from the Proposed Action
to water resources. Water resources will not be impacted to the degree that will require detailed
analysis in the EA.
207
August 2019

Although leasing of parcels would not directly affect these resources, applying stipulation UT-S-128:
NSO – Floodplains, Riparian Areas, Springs, and Public Water Reserves to parcels 027, 028, 029,
030, 031, 032, 033, 034 and 035 would minimize potential impacts to floodplain resources in these N. Noyes
Wetlands/ 6/25/19
parcels. Applying stipulation UT-S-128: NSO – Floodplains, Riparian Areas, Springs, and Public
NI Riparian Zones
Water Reserves to parcels 027, 028, 029, 030, 031, 032 and 035 would minimize potential impacts to Ann Marie Aubry
/ Floodplains
riparian resources. BMPs, SOPs, and site specific mitigation may be applied at the APD stage as 7-23-2019
COAs and will adequately mitigate impacts from the Proposed Action to these resources. Therefore
these resources will not be impacted to the degree that will require detailed analysis in the EA.
At this stage (lease sale) there would be no impacts to soils resources. Once a lease is issued there is
some expectation that exploration or development could occur. The lessee/operator would submit an
APD when oil and gas exploration and development activities are proposed. The APD would be
subject to site specific NEPA analysis. An approved APD is subject to standard operating procedures
(SOP) required by regulation, stipulations attached to the lease, best management practices (BMP)
included in the APD submission, and conditions of approval (COA) developed during the NEPA
analysis and documentation process. These SOPs, BMPs, and COAs, mitigate impacts to other
resources and users from oil and gas exploration and development activities.
The Monticello RMP contains management decisions and stipulations to protect fragile soils on steep Cliff Giffen
slopes and reduce erosion. All of the parcels except 034 contain slopes in excess of 20%. Stipulations
Soils: 2019.06.25
UT-S-98:NSO—Fragile Soils/Slopes Greater than 40 Percent will be attached to parcels 027 and 031;
NI Physical/Biolog and UT-S-106 CSU—Fragile Soils/Slopes 21-40 Percent and will be attached to all parcels except
ical 034. Ann Marie Aubry
When an applicant submits an APD, the location would be reviewed by a BLM resource specialist for 2019.07.24
conformance with the slope stipulations. A well location, access road, or other surfacing disturbing
activity located on slopes inconsistent with these stipulations would require modification of the
location or denial of the APD.
These lease stipulations, SOPs BMPs and COAs, including erosion control and reclamation
standards, would adequately mitigate impacts to the soil resource.
Potential impacts to soils from oil and gas leasing are adequately analyzed and documented in the
environmental analysis prepared for the Monticello RMP. Actions and impacts are not changed from
those disclosed in these NEPA documents.
Rangeland Health
208
August 2019

N. Noyes
Farmlands As stated in the Monticello FO Proposed RMP and Final EIS (page 4-7), “All alternatives in this 03/07/2019
PRMP/FEIS coincide with the intent of the Secretary of Agriculture's Memorandum 1827 for prime
NI (Prime or land. The Monticello PA does not include any prime farmland, nor do any of the alternatives impact
Unique) any prime farmland soils (NRCS 1993)”. Ann Marie Aubry
7-24-2019
Exploration or development would not conflict with the Fire Management Plan goals and objectives.
Fuels/Fire The implementation of appropriate reclamation standards at the APD stage would prevent an increase P.Plemons
NI
Management of hazardous fuels. Fuels and fire management would not be impacted by the lease process. BMPs, 6/26/19
SOPs, and site specific mitigation may be applied at the APD stage as COAs.
Some of the parcels are located within livestock grazing allotments or private pastures. Leasing or
production activities would not cause changes to grazing permit terms and conditions. Any activity
that involves surface disturbance or direct resource impacts would have to be authorized as a lease
operation through future NEPA analysis, on a case-by-case basis, at the APD stage. Impacts to
livestock grazing may occur as a result of subsequent actions including exploration development,
production, etc. Therefore, reclamation provisions/procedures including re-vegetation (utilizing N. Noyes
Livestock
NI appropriate seed mix based on the ecological site, elevation and topography), road reclamation, range
Grazing 06/25/2019
improvement project replacement/restoration (e.g., fences, troughs and cattle guards), noxious weed
control, would be identified in future NEPA/decision documents on a case-by-case basis (at the APD
stage). In addition, if any range improvement projects could be impacted by wells or associated
infrastructure, well pads could be moved 200 meters to avoid rangeland improvements or vegetation
monitoring plots as per 43 CFR 3101.1-2. BMPs, SOPs and site specific mitigation may be applied at
the APD stage as COAs.
Wild Horses N. Noyes
Lands and Minerals
Leasing parcels would have no effect on property boundaries. In accordance with WO IM 2011-122,
cadastral survey reviews and verifies the legal land descriptions prior to lease issuance. Stone N. Norton
NI Lands/Access monuments may be present and would need to be avoided the same as metal cap monuments.
Detailed land surveys may be warranted at the APD stage. BMPs, SOPs and site specific mitigation 07/03/2019
may be applied at the APD stage as COAs.
209
August 2019

The proposed lease parcels are located within the Blanding Basin. Oil and gas resources in this area
of the Paradox Basin occur primarily in the Porous Carbonate Buildup Play (2102), as delineated by
the U.S. Geological Survey in its 1995 National Assessment of United States Oil and Gas Resources
(Gautier and others, 1996). The parcel area has a high potential for occurrence of oil and gas (BLM
Mineral Report, December 2005, pg. 33 and map 7a). Pursuant to the 2008 Monticello Field Office
Resource Management Plan (RMP), the parcel area is available for oil and gas leasing and
development subject to standard terms and timing limitations (RMP Appendix A, map 18).
The proposed action would not exceed the level of activity predicted in the Reasonably Foreseeable
Development Scenario (RFDS) prepared for the RMP. The RFDS is documented at section 2.2.1.
Potential impacts to mineral resources and energy production from oil and gas leasing and
development are adequately analyzed and documented in the Proposed RMP and Final
Environmental Impact Statement (FEIS). Actions and impacts are not changed from those disclosed
in the existing NEPA document.
Geology / subsurface data obtained through lease operations may become public record. This information
Mineral promotes an understanding of mineral resources as well as geologic interpretation. While conflicts Angela Wadman
NI Resources/ could arise between oil and gas operations and other mineral operations (i.e., uranium/vanadium,
Energy 8/14/2019
sand and gravel), these could generally be mitigated under 43 CFR 3101.1-2 and under standard lease
Production terms (Sec. 6) where siting and design of facilities may be modified to protect other resources.
extracted and delivered to market. Production would result in the irretrievable loss of these resources.
If the parcels are developed, wells within the parcels may be completed using hydraulic fracturing
techniques. Additional information is provided in Sections 2.2.2 through 2.2.6 “FracFocus,” is a
database available to the public online at http://fracfocus.org/. Public has expressed concerns that:
resources;
210
August 2019

source, fracking fluid may be introduced into the source.
Utah Division of Oil, Gas and Mining (UDOGM), March 27, 2018). In conclusion, there would be no
negative affects to mineral resources.
Potential impacts to paleontology from leasing are adequately analyzed and documented in the
environmental analysis prepared for the Monticello RMP. Actions and impacts are not changed from
those disclosed in these NEPA documents.
All lease parcels contain areas of high potential for paleontological resources. The Monticello RMP
contains management decisions to protect paleontological resources. Lease notice UT-LN-72: High
Potential Paleontological Resources will be attached to all parcels as specified by the Monticello A. Bulla
NI Paleontology RMP. Attachment of this lease notice will adequately mitigate impacts to paleontological resources.
7/2/2019
are proposed. The APD would be subject to site specific NEPA analysis. If an APD is filed, specific
clearances would be conducted and incorporated into that NEPA process. If paleontological resources
are located, the AO would be contacted. BMPs, SOPs and site specific mitigation may be applied at
211
August 2019

Wastes for specific information on hazardous air pollutants (HAPs). Hazardous materials, if not handled N. Noyes
NI (hazardous or properly that are associated with operations, have the potential to be spilled at the lease/drill site.
However, the spill would be contained, reported, and cleaned up by the operator. BMPs, SOPs and 06/25/2019
solid)
site specific mitigation may be applied at the APD stage as COAs.

nation Richfield Field Office
Air
Activities related to exploration, construction, drilling, completion, testing, and production of an
oil or gas well could result in emissions of pollutants (including those that are regulated) that
could affect air quality. All parcels are within an attainment area. Background information is
Erik Vernon
PI Air Quality contained in Appendix H.
8/28/2019
Application of notices UT-LN-96 (Air Quality Mitigation Measures), UT-LN-99 (Regional
Ozone Formation Controls), UT-LN-101 (Air Quality) and UT-LN-102 (Air Quality Analysis)
is warranted on all parcels.
Greenhouse Gases are composed mostly of CO2, CH4, N2O, HFCs, PFCs, & SF6. Primary
sources of GHG emissions include fossil fuel combustion, fugitive CH4, and combustion of Erik Vernon
PI Greenhouse Gases produced oil and gas. GHG emissions could occur from construction, drilling, and production
equipment and end use of the product(s). Background information is contained in Appendix H. 8/28/2019.
Refer to the notices applied for Air Quality.
Recreation
Areas of Critical Sheri Wysong
NP Environmental There are no ACECs proximate to the parcels.
Concern 8/15/2019
212
August 2019

National Park There are no National Parks in the vicinity of the parcels. Parcels 002 and 003 are within 2-3 Sheri Wysong
NP/NI Service Units and miles of a non-high-potential segment of the Old Spanish Trail. Impacts from the trail would be
Historic Trails screened by topography. 8/15/2019
Recreation resources are dispersed in nature and no/negligible impact is expected to recreation Sheri Wysong
NI Recreation
resources (NI). 8/15/2019
Travel/ Sheri Wysong
NI The parcels are not along any Scenic Byways. Access to them would be from County roads.
Transportation 8/15/2019
The parcels with public surface are designated Class III and VI VRM, which is consistent with Sheri Wysong
NI Visual Resources
the VRI rating. Oil and Gas development is consistent with the VRM designation. 8/15/2019
Wild and Scenic Sheri Wysong
Rivers 8/15/2019
Wilderness/Wilderne Sheri Wysong
NP None of the parcels intersect wilderness areas or wilderness study areas.
ss Study Area 8/15/2019
Lands with Sheri Wysong
NP wilderness The parcels do not intersect any BLM-identified lands with wilderness characteristics.
characteristics 8/15/2019
Cultural
BLM archaeologists have compiled cultural resources data from the Richfield field office
cultural resource libraries, GIS data (CURES), and the Preservation Pro database area. These
data sources contain information of all of the recorded cultural resource sites and cultural
resource survey data for the area available to BLM and the Utah Division of State History.
Archaeologist use this data to determine if oil and gas development could occur within each
parcel while avoiding know cultural sites. The parcels are reviewed for the application of Glenn Stelter
NI Cultural Resources stipulations and lease notices as required by the Monticello RMP.
08/16/2019
At this time, (08/16/2019) consultation with the Utah State Historic Preservation Office is
ongoing.
213
August 2019

other authorities specific to those future undertakings. Consideration of impacts to cultural
resources and adverse effects to historic properties will be taken into account during the review
stage of site specific development plans.

Cultural Resource Stipulation as required by Handbook H-3120-1, and UT-LN-66 (Cultural
Resources Located Sandy or Erodible Soils),
The following Tribes were invited to consult on this project via certified letter on 07/25/2019:
All Pueblo Council of Governors , Cedar Band of Paiutes, Colorado River Indian Tribes,
Confederated Tribes of the Goshute, Eastern Shoshone Tribe, Indian Peaks Band of Paiutes,
Jicarilla Apache Nation, Kaibab Band of Paiute Indians, Kanosh Band of Paiutes, Moapa Band
of Paiute Indians, Navajo Nation, Navajo Nation, Aneth Chapter, Navajo Nation, Dennehotso
Chapter, Navajo Nation, Kayenta Chapter, Navajo Nation, Mexican Water Chapter, Navajo
Nation, Navajo Mountain Chapter, Navajo Nation, Oljato Chapter, Navajo Nation, Red Mesa
Chapter, Navajo Nation, Shonto Community Governance, Navajo Nation, Teec Nos Pos
Chapter, Navajo Utah Commission, Northwest Band of Shoshone Nation, Ohkay Owingeh,
Paiute Indian Tribe of Utah , Pueblo of Acoma, Pueblo of Cochiti, Pueblo of Isleta, Pueblo of
Native American Jemez, Pueblo of Kewa (Santo Domingo), Pueblo of Laguna, Pueblo of Nambe, Pueblo of Glenn Stelter
NI
Religious Concerns Ohkay Owingeh, Pueblo of Picuris, Pueblo of Pojoaque, Pueblo of San Felipe, Pueblo of San 08/16/2019
Ildefonso, Pueblo of Sandia, Pueblo of Santa Ana, Pueblo of Santa Clara, Pueblo of Taos,
Pueblo of Tesuque, Pueblo of Ysleta del Sur, Pueblo of Zia, Pueblo of Zuni, San Juan Southern
Paiute Tribe, Shivwits Band of Paiutes, Shoshone-Bannock, Skull Valley Band of Goshute
Indians, Southern Ute Indian Tribe, The Hopi Tribe, Uintah and Ouray Ute Tribe, Ute Indian
Tribe, Ute Mountain Ute Tribe, White Mesa Ute At this time, Tribal consultation is ongoing.
The BLM will consult with Indian tribes on a government-to-government basis, if requested by
any Tribe.
Additional coordination and consultation would be initiated at the APD stage. BMPs, SOPs and
Wildlife
On March 14, 2019, the BLM approved the Utah Greater Sage-Grouse Resource Management Karen Cathey
NI Greater Sage-Grouse Plan Amendment (ARMPA), which guides management actions for greater sage-grouse (GRSG)
UTSO
214
August 2019

habitat management areas (BLM 2019). The ARMPA identifies priority habitat management August 21, 2019
areas (PHMA) for BLM-administered GRSG habitat across Utah, and provides measures to
minimize impacts to PHMA where they cannot be avoided. There are no known occurrences of
the greater sage grouse, with the closest known lek located over 25 miles east, and closest
identified PHMA located over 6 miles east. However, 18.7 of the total 78.8 acres contained in
lease parcel 007 potentially overlaps with seasonal summer and winter habitat located outside
PHMA. Greater sage grouse inhabit sagebrush plains, foothills, and mountain valleys. Greater
sage grouse are a sagebrush obligate species, therefore require quality sagebrush habitat,
especially for brood rearing and wintering habitat. Implementation of UT-LN-49 on lease parcel
007, will allow the BLM to require modifications to the Surface Use Plan of Operations may be
required to minimize impact to GRSG seasonal summer habitat and individuals of the species
that may occur in these parcels. Collectively the stipulation and notice will minimize impacts to
the species to the degree that no additional detailed analysis in this EA is necessary.
The following documents are incorporated: Utah Wildlife Action Plan (2015), Utah Partners in
Flight Avian Conservation Strategy Version 2.0. (Parrish et al. 2002), Birds of Conservation
Concern (USFWS 2008), Executive Order 13186: Responsibilities of Federal Agencies to
Protect Migratory Birds, MOU between the USDI BLM and USFWS to Promote the
Conservation and Management of Migratory Birds (4/2010), and Utah Supplemental Planning
Guidance: Raptor Best Management Practices (BLM UTSO IM 2006-096).
Migratory birds are protected under the Migratory Bird Treaty Act (Executive Order 13186).
MOU between the BLM and U.S Fish and Wildlife Service (USFWS) (BLM MOU WO-230- Karen Cathey
NI Migratory Birds UTSO
conservation and compliance. Bald and golden eagles receive additional protections under the
Bald and Golden Eagle Protection Act of 1962. Potential for impacts to these eagle species is August 21, 2019
discussed below, under BLM Sensitive Species.
through development, operation and maintenance activities. This stage occurs when a lessee
files an APD, outlining in detail the scope of the proposed development. At that time, impacts to
migratory birds and waterfowl could be fully analyzed in additional environmental documents
through the NEPA process. BMPs, SOPs and site specific mitigation may be applied at the APD
stage as COAs.
215
August 2019

specific mitigation may be applied at the APD stage as COAs, minimizing risk to these species.
The standard endangered species stipulation as per Handbook H-3120-1 is attached to all
parcels.
An Endangered Species Act (ESA) species list was obtained from the USFWS Information,
Planning, and Conservation (IPaC) System on July 12, 2019. The IPaC lists the endangered
California condor, and the threatened Utah prairie dog and yellow-billed cuckoo as potentially
occurring in the vicinity of the parcels proposed for the December 2019 lease sale. No
designated critical habitat for these species occurs in the parcels proposed for the December
2019 lease sale.
California condor: Parcels 002 and 003 identified for the December 2019 lease sale are located
within the condor endangered species designated area, and will have stipulation UT-S-293
CSU/TL – California Condor and lease notice T&E 11: California condor applied. California
Threatened, condors prefer mountainous country at low and moderate elevations, especially rocky and
Endangered, brushy areas near cliffs. Breeding populations are restricted to California and Northern Arizona, Karen Cathey
NI Candidate or near release sites, and no known nest sites occur on the parcels. Application of T&E 11 will UTSO
Proposed Animal minimize risk to the condor, should it occur, through requirements for best management August 21, 2019
Species practices to reduce likelihood of impacts (e.g., removal of trash, carrion, and hazardous
materials, surveys and monitoring, reduction of construction footprint, etc.). Such requirements
will minimize the potential for direct and indirect impacts to the species.
Utah prairie dog: Most of the RFO area is within located in areas of historical habitat for the
Utah prairie dog. While there are no known prairie dog colonies within the lease parcels, there
are known colonies in the vicinity of lease parcels 002 and 003, within the Parker Mountain
area. No critical habitat occurs within the lease parcels. Utah prairie dogs are diurnal, burrowing
animals, who breed in March with young born in April. Emergence of the pups usually occurs
from mid- to late May. Stipulation/notice UT-S-221: CSU/TL – Utah Prairie Dog and T&E-09
Utah Prairie Dog will be applied to all parcels; implementation of these protections will require
surveys/monitoring, buffers to protect colonies identified, reduce speeds and limitation on off
road traffic to protect individuals on the site, minimizing the potential for impact.
216
August 2019

Yellow-billed cuckoo: No habitat occurs within the lease parcels proposed for the December
2019 lease sale. This species prefers dense wooded habitat, near water, which is unavailable in
the proposed parcels.
Summary of attachments for threatened, endangered, candidate or proposed animal species, as
noted:
• UT-S-221: CSU/TL – Utah Prairie Dog – All parcels
• UT-S-293: CSU/TL – California Condor – Parcels 002 and 003
• T&E-09 Utah Prairie Dog – All parcels
• T&E-11: California condor – Parcels 002 and 003
BLM manages sensitive species in accordance with BLM Manual 6840.
Instruction Memorandum (IM) No. 2016-013 directs Federal departments and agencies to
evaluate and use their resources, facilities, and land management responsibilities to expand
knowledge of pollinator health and increase habitat quality and availability. The State of Utah
supports a highly diverse assemblage of native and endemic bees (Davidson et al. 1996, p. 100-
101). Implementing the mitigation measures in lease notice UT-LN-156: Pollinators and
Pollinator Habitat, along with other mitigation measures specifically associated with sensitive
plants discussed below, would minimize potential direct and indirect effects to pollinators and
would improve pollinator habitat over the long-term.
Karen Cathey
BLM Sensitive Utah BLM Sensitive Species List (UT-IM-2019-005, March 4, 2019), lists 72 BLM sensitive
NI UTSO
Wildlife Species animal species, including 22 species which occur or potentially occur within the December 2019
lease sale analysis area. Lease notice UT-LN-49: Utah Sensitive Species, UT-LN-44: Raptors August 21, 2019
and UT-LN-45: Migratory Bird, will be applied to every parcel. Available data sources,
including BLM data layers and that available through Utah Conservation Data Center (UCDC)
were used to determine if the known or potential habitat falls within parcels within the FFO area
identified for the December 2019 lease sale, with the following results:
Species listed as sensitive to the BLM in Utah which are likely to occur in parcels proposed for
the December 2019 lease sale include:
The following species may occur. Implementation of UT-LN-49: Utah Sensitive Species, UT-
LN-44: Raptors and UT-LN-45: Migratory Bird will alert to lease to the potential for
217
August 2019

occurrence, and allow for the opportunity to make adjustments at the site specific level when an
APD is received thus minimizing potential for impact.
• Kit fox: Suitable habitat does currently not occur within the lease parcels; however, Kit fox
were observed within the areas of lease parcels 002 and 003 according to UDWR species
occurrence records in 1976. Kit foxes live primarily in open desert, shrubby or shrub-grass
habitat; shadscale, greasewood or sagebrush.
• Big free-tailed bat: This species is rare in Utah, and there is no known documentation of this
species in the lease parcels (www.utahbats.com). However, but there is suitable value habitat
which may overlap with lease parcels 002 and 003, according to UDWR conservation data.
The species is managed under the Bat Conservation Plan. The species is an insectivore, which
often roots and forms maternity colonies in massive sandstone cliffs near bodies of open
water.
• Townsend’s big-eared bat: There is documentation of this species in the RFO area
(www.utahbats.com) High value habitat occurs within the lease parcels 002 and 003. These
species potentially occur throughout Utah. However, they depend on caves and mines year
round for maternity colonies and hibernacula.
• American white pelican: According to UDWR, American white pelican was found in the
area of the town of Salina in 1989; parcels 002 and 003 are located near Salina. There are a
few small lakes and reservoirs in the Salina area that could be used by American white
pelican, likely during migrations.
• Bald eagle: Bald eagles occur in Sanpete and Sevier counties, chiefly during the winter, and
lease parcels 002, 003, 007, and 008 contain suitable foraging habitat, although of marginal to
low quality. Wintering areas are commonly associated with open water, although in some
areas, eagles use habitats with little or no open water if other food resources (e.g., rabbit or
deer carrion) are readily available. There are no known nests, but the implementation of
stipulation UT-S-276: CSU/TL – Bald Eagle and lease notice UT-LN-107: Bald Eagle, to
avoid nesting seasons would eliminate potential disturbance to a nesting eagles if found.
• Burrowing owl: There are no known occurrences of the burrowing owl within the lease
parcels but the lease parcels potentially overlap with high value habitat value according to
UDWR conservation data base. This species prefers open areas within deserts, grasslands,
and sagebrush steppe communities. This small owl nests and roosts in underground burrows
in open and short-grass habitats.
218
August 2019

• Ferruginous hawk: There are no known occurrences of the ferruginous hawk within the lease
parcels but the lease parcels potentially overlap with high value habitat value according to
UDWR conservation data base. Ferruginous hawks are distributed throughout most of Utah.
Breeding ferruginous hawks rely on grassland or shrub steppe terrain and in many parts of
Utah Juniper trees are the primary nesting substrate in Utah, but they will also nest on the
ground or on power line structures.
• Greater sage-grouse: There are no known occurrences of the greater sage grouse, with the
closest known lek located over 25 miles east, and closest identified PHMA located over 6
miles east. However, lease parcel 007 potentially overlaps with seasonal summer habitat
located outside PHMA. Greater sage grouse inhabit sagebrush plains, foothills, and mountain
valleys. Greater sage grouse are a sagebrush obligate species, therefore require quality
sagebrush habitat, especially for brood rearing and wintering habitat.
• Bobolink: There are no known occurrences of the bobolink within the lease parcels but the
lease parcels potentially overlap with high value habitat value, according to UDWR
conservation data. This species breeds, nests, and forages in wet meadow, wet grassland, and
irrigated agricultural areas that tend to be associated with riparian or wetland areas.
• Western (boreal) toad: While there are no known occurrences in the lease parcels, lease
parcel 008 potentially overlaps with limited value habitat. UDWR conservation data
indicates the species may occur in the area near the north end of the San Pete Valley, with the
last observation in 1939. This toad inhabits wetland habitats, usually between 8,000 and
11,500 feet.
• Columbia spotted frog: While there are no known occurrences in the lease parcels, lease
parcels 006 and 008 potentially overlap with limited value habitat. UDWR conservation data
indicates the species occurs in the area near the north end of the San Pete Valley, with the last
observation in April 2012. This species generally occurs near permanent water; lease parcels
006 and 008 may overlap potential habitat.
• Bonneville cutthroat trout: No suitable habitat occurs within lease parcels; however UDWR
indicates that in 2001, 2008, and 2012 Bonneville cutthroat trout were found in the area of the
lease parcels on the north end of the San Pete Valley, in the vicinity of lease parcels 006, 007,
and 008. Bonneville cutthroat trout are found in a number of habitat types, ranging from high-
elevation mountain streams and lakes to low-elevation grassland streams. Bonneville
cutthroat trout require functional riparian zones, which provide cover, shade, and bank
stability.
219
August 2019

• Southern leatherside chub: Suitable habitat occurs within lease parcels 002, 003, 006, and
007, and there are occurrences within the areas of the lease parcels according to UDWR
observations recorded in 2005 and 2009. Southern leatherside chub occupy riparian areas
with a large range of physical characteristics within both rivers and small streams below 7200
ft.
Summary of lease notices applied to all parcels identified within the RFO area specific to the
December 2019 lease sale applied to all parcels unless otherwise noted, to protect BLM
Sensitive animal species:
• UT-S-276 – CSU/TL Bald Eagles – Lease parcels 002, 003, 007, 008
• UT-LN-107 Bald Eagles – Lease parcels 002, 003, 007, 008
These stipulations and lease notices were designed by the BLM in coordination with UDWR and
the USFWS to provide protections through general and specific measures which would identify
and protect BLM sensitive species. Implementation of lease notices for sensitive species,
migratory birds and raptors, applied to every parcel, will allow for the opportunity to make
adjustments at the site specific level when an APD is received for all parcels, including those if
circumstances change to allow potential for occurrence of species currently not expected to
occur. No surface use or otherwise disruptive activity would be allowed that would result in
Parcels located within the RFO area which are proposed for the December 2018 lease sale were
evaluated for State identified game species, including the American bison, cougar, black bear,
moose, Rocky Mountain elk, mule deer, pronghorn antelope, mountain goat, California bighorn
Fish and Wildlife sheep, desert bighorn sheep, Rocky Mountain bighorn sheep, snowshoe hare, wild turkey, Karen Cathey
NI Excluding USFWS chukar, California quail, band-tailed pigeon, sharp-tailed grouse, ruffed grouse, dusky/blue UTSO
Designated Species grouse, white-tailed ptarmigan and ring-necked pheasant using UDWR data. Habitat for those August 21, 2019
not listed below is was not identified.
Cougar: Parcels 002 and 003 fall in the Central Mountains unit of the Southwest Manti
management unit for the cougar; parcels 004, 005, and 006 fall in the Central Mountains subunit
220
August 2019

of the Nebo management unit; and parcels 007 and 008 fall in the Central Mountains subunit of
the Northwest Manti management unit. These areas are managed by UDWR for annual
statewide limited-entry hunting season. Cougars live all across Utah, and prefer pinyon-juniper
and pine-oak brush areas where there are rocky cliffs, ledges and tall trees or brush that can be
used for cover.
Rocky Mountain elk: Elk calving areas occurs on parcels 004, 005, 006, 007 and 008. Crucial,
winter range occurs within lease parcels 005, 006 and 008. These habitats include foothills and
valleys. Elk migrate to lower elevations to escape the higher snow depths found in the
mountains where they summer. Implementation of UT-S-233 Crucial Elk Winter Habitat will
restrict surface disturbing activities in crucial mule deer and elk habitats during the times critical
to the species.
Moose: Substantial, year-long habitat occurs within the lease parcels 004, 005, 006, 007, and
008. Moose prefer forest habitats, especially those locations with a mixture of wooded areas and
open areas near lakes or wetlands.
Mule deer: Crucial winter range occurs within all the lease parcels. Mule deer migrate to lower
elevations to escape the higher snow depths found in the mountains where they summer.
Implementation of UT-S-233: Crucial Mule Deer and Elk Winter Habitat will restrict surface
disturbing activities to times outside of winter range use, thus minimizing impacts caused by
stress and disturbance to the species during crucial winter months.
Band-tailed pigeon: Parcels 002, 003, 005 and 008 contain substantial value habitat, with parcel
005 identified as crucial spring/early fall habitat for this species, which lives mainly in in
wooded or semi-open habitats, foraging along springs in drier areas.
Wild turkey: Portions of parcels 004 and 005, and the majority of parcel 006 extend into wild
turkey habitat. (Rio Grande) This species frequents woodlands and open clearings, preferring
cottonwood river bottoms associated with oak-pine and pinyon-juniper forests.
Ruffed grouse: Parcel 003 contains substantial, year-long habitat occurs within the lease
parcels. Thickets of alder, willow, aspen, maple, and other deciduous shrubs and trees
interspersed with conifers provide the most desirable habitat.
221
August 2019

Dusky/blue grouse: Parcels 002, 003, 004, 006, and 008 extend into dusky grouse habitat.
Crucial, year-long habitat occurs within the lease parcels. Typical habitat is coniferous forests.
Open stands of conifer or aspen with an understory of brush are preferred habitat.
California quail: Parcels 002 and 003 extend in to crucial, year-long habitat. Typical habitat is
coniferous forests. The species inhabits brushy areas adjacent to cultivated lands, particularly
along streams.
Chukar: Parcels 004 and 005 contain year-long habitat. The species needs steep, rocky, semi-
arid slopes. Preference for juniper and large boulders on talus slopes. The lack of available water
limits the value of the potential habitat.
Ring-necked pheasant: Parcel 006 contains substantial year-long habitat. Primarily found near
agricultural areas, valley bottoms.
December 2019 lease sale, to protect fish and wildlife excluding USFWS designated species:
• UT-S-233: TL – Crucial Mule Deer and Elk Winter Habitat
• UT-LN-11: Crucial Elk Calving and Deer Fawning Habitat
Stipulation UT-S-233 was designed by the BLM in coordination with UDWR to provide
protections through general and specific measures which would identify and protect BLM
sensitive species. Where a specific lease notice is not specifically noted above, implementation
of lease notices for sensitive species applied to every parcel, will allow for the opportunity to
make adjustments at the site specific level when an APD is received if circumstances change to
allow potential for occurrence of these species. No surface use or otherwise disruptive activity
would be allowed that would result in direct disturbance to populations or individual special
status species.
Plants
BLM Sensitive BLM manages sensitive species in accordance with BLM Manual 6840. Instruction Karen Cathey
NI
Plant Species Memorandum (IM) No. 2016-013 directs Federal departments and agencies to evaluate and use UTSO
222
August 2019

their resources, facilities, and land management responsibilities to expand knowledge of August 21, 2019
pollinator health and increase habitat quality and availability. The State of Utah supports a
highly diverse assemblage of native and endemic bees (Davidson et al. 1996, p. 100-101).
Implementing the mitigation measures in lease notice UT-LN-156: Pollinators and Pollinator
Habitat, along with other mitigation measures specifically associated with sensitive plants
discussed below, would minimize potential direct and indirect effects to pollinators and would
improve pollinator habitat over the long-term.
Utah BLM Sensitive Species List (UT-IM-2019-005, March 4, 2019), lists 105 BLM sensitive
plant species, including 12 species which occur or potentially occur within the December 2019
lease sale analysis area. Lease notice UT-LN-49: Utah Sensitive Species will be applied to
every parcel. Available data sources, including BLM data layers and site specific BLM
expertise were used to determine if the known or potential habitat falls within the December
2019 proposed lease parcels within the RFO area, with the following results:
Arapien stickleaf: Documented habitat or known occurrences in parcels 002, 003; possible
occurrence in 002. This species is adapted to steeply sloping talus or scree slopes of the
Arapien shale in Utah, and the Green River formation shale in Colorado (NatureServe, accessed
July 15, 2019).
Shultz’ stickleaf: Documented habitat or known occurrences in Parcels 002; possible
occurrence in 003. This species occurs in Mixed desert shrub communities on the Moenkopi
and Paradox formations at 1280-1829 m elevation (NatureServe, accessed July 15, 2019).
Ward’s penstemon: Documented habitat or known occurrences in Parcels 002, 003. This
species occurs in semi-barren, light-colored clays (often calcareous or gypsiferous) in desert
shrub and pinyon-juniper communities at 1645-2075 m elevation (NatureServe, accessed July
15, 2019).
Utah phacelia: Documented habitat or known occurrences in parcels 003; possible occurrence
in 002. An obligate gypsophile, this species is confined to the barren clay slopes of the Arapien
Shale Formation at 1660-1740 m elevation within salt desert shrub communities (NatureServe,
accessed July 15, 2019).
Jones’ townsendia: Documented habitat or known occurrences in parcels 003; possible
occurrence in 002. This species is known to occur in salt desert and mixed desert shrub and
juniper-sagebrush communities on Arapien shale and clays in volcanic rubble at 5495 to 6316 ft
(NatureServe, accessed July 15, 2019).
223
August 2019

sensitive species applied to every parcel, will allow for the opportunity to make adjustments at
the site specific level when an APD is received if circumstances change to allow potential for
occurrence of these species. No surface use or otherwise disruptive activity would be allowed
that would result in direct disturbance to populations or individual special status species.
The standard endangered species stipulation as per Handbook H-3120-1 is attached to all
parcels.
An official endangered species act (ESA) species list was obtained from the USFWS
Information, Planning, and Conservation (IPaC) System for the RHA area on July 15, 2019.
The IPaC lists the threatened plant Jones’ cycladenia as potentially occurring.
There are no known Jones’ cycladenia occurrences, but parcels 002 and 003 fall into spatial
Threatened, modeled habitat. Most of parcel 002 and a large portion of parcel 003 fall into spatial models
that predict low to medium low potential for occurrence therefore both parcels will have lease
NI Candidate or notice T&E 19: Jones Cycladenia (Cycladenia hymilis var jonsii) applied. No critical habitat UTSO
Proposed Plant has been designated for this species. Occurs on gypsiferous saline soils on the Chinle, Cutler, August 21, 2019
Species and Summerville Formations and is associated with buckwheat and Mormon Tea, cool desert
shrub and juniper communities between 4,400’ and 6,000’ elevation. (UDWR 2005, UNPS
2015)
December 2019 lease sale unless otherwise noted, to protect listed plant species:
• T&E-19: Jones Cycladenia (Cycladenia hymilis var jonsii) – Parcels 002, 003
Noxious/invasive weed species may be present on the subject parcels, see a listing of noxious and
invasive weeds is available in the Noxious Weed Field Guide for Utah available at:
Invasive Karen Cathey
Species/Noxious https://extension.usu.edu/fieldguides/ou-files/Noxious-Weed-Field-Guide-for-Utah.pdf.
NI Weeds Constraints, including the use of certified weed free seed and vehicle/equipment wash stations, UTSO
would be applied as necessary at the APD stage as documented in filing plans and COAs. August 21, 2019
(EO 13112)
Control measures would be implemented during any ground disturbing activity and documented
through a PUP/PAR. Additional control and procedural information is documented in the
224
August 2019

Programmatic EIS Vegetation Treatments Using Herbicides on BLM Lands in 17 Western
States and its Record of Decision, (September 2007). If treatment occurs as part of regular
operations, BMPs, SOPs and site specific mitigation are applied at the APD stage as COAs.
Negligible impacts would be expected as a result of leasing and exploration. Application of
notice UT-LN-52: Noxious Weed is warranted on all parcels.
This proposed sale and issuance of an oil and gas leases would not authorize ground
disturbances which could affect vegetation resources other than potential as discussed above.
Leasing is an administrative action that does not result in any surface disturbance. Site-specific
effects cannot be analyzed until an exploration or development application is received, after
leasing has occurred. There would be no impacts to vegetation resources through sale of leases. Karen Cathey
Vegetation
There is some expectation that exploration or development could occur, at which time additional
NI Excluding Special UTSO
NEPA would be conducted should an APD be filed. The applied lease stipulations and notices
Status Species August 21, 2019
will notify buyers during sale of leases and allow for the opportunity to make adjustments at the
site specific level when an APD is received and will ensure impacts are addressed. Future
development proposals on the leases would be subject to the standard lease terms, and all
applicable laws, regulations and onshore orders in existence at the time of lease issuance.
Additional detailed analysis in this EA is not necessary.
Scattered sparse woodlands exist areas adjacent to all parcels within the RFO area included in
the proposed lease sale, but not in quantities sufficient to establish public harvest areas. Karen Cathey
Exploration or development would not limit use or access to any established wood sale areas.
NI Woodland / Forestry UTSO
BMPs, SOPs and site specific mitigation may be applied at the APD stage as COAs. Per 43 CFR
5400 Sale of Forest Products, permits are required for severance and removal of forest products August 21, 2019
regardless of whether the product is utilized or not.
As defined in EO 12898, minority and low income populations do occur within or use areas
within Sevier and Sanpete Counties. All citizens can file an expression of interest or participate
Environmental in the bidding process (43 CFR 3120.3-2). The stipulations and notices applied to the subject Brandon Jolley
NI
Justice parcels do not place an undue burden on these groups. Leasing the nominated parcels would not 6/20/2019
cause any disproportionately high and adverse effects on minority or low income populations.
225
August 2019

area/counties would be caused by exploration or development. The parcel areas would still
receive use by county residents and other visitors including recreationists regardless of
alternative selected.
Refer to the Economic Profile System Reports prepared on 10/18/2018 (EPS 2018) (A Profile of
Agriculture, Public Land Amenities, A Profile of Demographics, A Profile of Federal Land
Payments, A Profile of Government Employment, A Profile of Land Use, A Profile of Mining, Brandon Jolley
NI Socio-Economics
Including Oil & Gas, A Profile of Non-Labor Income, A Profile of Service Sectors, A Profile of 6/20/2019
Socioeconomic Measures, A Profile of Timber and Wood Products, A Profile of Industries that
Include Travel & Tourism, A Profile of Development and the Wildland-Urban Interface, and A
Summary Profile). Additional information is contained in the county general plan and its
corresponding resource management plan. Land uses in county and parcel areas would continue.
Land use plan (as amended) allocations would not be altered. BMPs, SOPs and site specific
Water Resources
There are no identified ground or surface drinking water protection zones in the area of the lease
parcels.
These water rights have beneficial uses of stockwater, irrigation, and domestic. Water quality
must continue to be acceptable to meet the beneficial uses of the water right. Exploration and
development could cause impacts. Mark Dean
6/27/2019
Water Resources/
NI Quality (drinking/ The following notice would be added to all parcels (002, 003, 004, 005, 006, 007, 008) to inform
surface/ ground) potential lessees of the requirements of EO 11988: UT-LN-128: Floodplain Management. Ann Marie Aubry
7-23-2019
If an APD is filed, SOPs required by regulation and design features would be sufficient to isolate
and protect all usable ground or surface water sources before drilling or exploration begin. The
SOPs include the requirements for disposal of produced water contained in Onshore Oil and Gas
Order (O.O.) No. 7 and the requirements for drilling operations contained in O.O No. 2.
Potential fresh water aquifers zones would be protected by the requirement of casing and
cementing the drill hole to total depth. The casing would be pressure tested to ensure integrity
226
August 2019

prior to drilling out the surface casing shoe plug. Potential impacts would be addressed and a
design feature would be included utilizing UT IM 2010-055 (Protection of Ground Water
Associated with Oil and Gas Leasing, Exploration and Development) prior to APD approval.
Standard protocols would minimize possibility of releases (cased drill holes, no surface
disturbance or occupancy would be maintained within 660 feet of any natural springs, new
disturbance would be not be allowed in areas equal to the 100-year floodplain or 100 meters on
either side of the center line of any stream, stream reach, or riparian area). BMPs, SOPs and site
\The SOPs, BMPs, COAs and stipulations will adequately mitigate impacts from the Proposed
Action to water resources therefore water resources will not require detailed analysis in the EA.
Through resource knowledge and/or GIS analysis of the National Wetlands Inventory layer. Mark Dean 6/27/2019
Wetlands/ Riparian
NP There were no parcels identified as containing riparian and/or wetland systems, therefore these Ann Marie Aubry
Zones / Floodplains
resources will not require detailed analysis in the EA. 7-23-2019
The lessee/operator would submit an APD when oil and gas exploration and development
activities are proposed. The APD would be subject to site-specific NEPA analysis. An
approved APD is subject to standard operation procedures (SOP) required by regulation,
stipulation attached to the lease, best management practices (BMP) included in the APD
submission, and conditions of approval (COA) developed during the NEPA analysis and
documentation process. These SOPs, BMPs, COAs mitigate impacts to soils from oil and gas
exploration and development activities.
Soils: At this stage (lease sale) there would be no impacts to soil resources. There is some expectation Brant Hallows 7/2/19
NI that exploration or development could occur, at which time additional NEPA would be Ann Marie Aubry
Physical/Biological
conducted should an APD be filed. If additional site specific resource protection measures are 7-26-2019
needed to prevent unnecessary or undue degradation, these would be developed at the time of
the site specific NEPA. It is expected that reclamation procedures would be required to ensure
long-term soil impacts are minimized. Reclamation provisions/procedures would include
stockpiling topsoil and re-vegetation (utilizing appropriate seed mix based on the ecological site,
elevation and topography), road reclamation, noxious weed controls, etc.
BMPs and SOPs to protect soil resources are defined in the Richfield RMP. Site-specific design
features and reclamation requirements would be applied at the APD stage as COAs. The parcels
227
August 2019

contain steep topography and UT-S-102 would be applied to all parcels (parcels #002, 003,
004,005, 006, 007, 008). Therefore these resources will not require detailed analysis in the EA.
Rangeland Health
Soil map units that are classified by the NRCS as farmland only occur in parcel #003. About 70
acres are classified as ‘prime if irrigated’. However, to be classified as ‘prime’ it is required to
have a dependable moisture supply that comes from either precipitation or irrigation. Because all Brant Hallows 7/2/2019
Farmlands water is already allocated throughout the water basin, and precipitation does not provide
NI Ann Marie Aubry
(Prime or Unique) adequate amounts, there is no dependable water source for those lands classified as ‘prime if
irrigated’ even if they, at some future time, became private lands. Therefore, they do not 7-26-2019
warrant special protective measures. There are no other prime or unique farmlands within the
lease sale parcels. Therefore these resources will not require detailed analysis in the EA.
Exploration or development would not conflict with the Fire Management Plan goals and
objectives. The implementation of appropriate reclamation standards at the APD stage would Bob Bate
Fuels/Fire
NI prevent an increase of hazardous fuels. Fuels and fire management would not be impacted by the
Management 6/27/19
lease process. BMPs, SOPs, and site specific mitigation may be applied at the APD stage as
COAs.
Some of the parcels are located within livestock grazing allotments or private pastures. Leasing
or production activities would not cause changes to grazing permit terms and conditions. Any
activity that involves surface disturbance or direct resource impacts would have to be authorized
as a lease operation through future NEPA analysis, on a case-by-case basis, at the APD stage.
Impacts to livestock grazing may occur as a result of subsequent actions including exploration
development, production, etc. Therefore, reclamation provisions/procedures including re- Jeff Reese
NI Livestock Grazing vegetation (utilizing appropriate seed mix based on the ecological site, elevation and
topography), road reclamation, range improvement project replacement/restoration (e.g., fences, 6/24/2019
troughs and cattle guards), noxious weed control, would be identified in future NEPA/decision
documents on a case-by-case basis (at the APD stage). In addition, if any range improvement
projects could be impacted by wells or associated infrastructure, well pads could be moved 200
meters to avoid rangeland improvements or vegetation monitoring plots as per 43 CFR 3101.1-2.
Wild Horses and Jeff Reese
Burros 6/24/2019
228
August 2019

Lands and Minerals
Parcels 004-008 are split estate and the BLM does not own or manage surface occupancy. As
such, standard leasing and occupancy practices for split estate lands should be adhered, as well
as the requirements in O.O. # 1 to in order to avoid infringement of the private property owners’
rights.
There are no withdrawals or Recreation and Public Purpose Act leases present on the proposed Michael Utley
NI Lands/Access lease parcels.
Leasing parcels would have no effect on property boundaries. In accordance with WO IM 2011- 6/27/2019
122, cadastral survey reviews and verifies the legal land descriptions prior to lease issuance.
Stone monuments may be present and would need to be avoided the same as metal cap
monuments. Detailed land surveys may be warranted at the APD stage. BMPs, SOPs and site
promotes an understanding of mineral resources as well as geologic interpretation. While
conflicts could arise between oil and gas operations and other mineral operations, these could
generally be mitigated under 43 CFR 3101.1-2 and under standard lease terms (Sec. 6) where
sitting and design of facilities may be modified to protect other resources.
Depending on the success of oil and gas drilling, non-renewable natural gas and/or oil would be Devin McLemore
Geology / Mineral extracted and delivered to market. Production would result in the irretrievable loss of these 6/27/2019
NI Resources/ Energy resources. The RFDS is documented at section 2.2.1. The proposed action would not exceed the
Production level of activity predicted in the RFDS. Angela Wadman
Any oil and gas development can be managed to avoid or work within other mineral resources. 8/14/2019
Mining claims and Mineral Materials were checked on 6/27/2019. No active placer claims or
Mineral Material sites were found to be associated within any parcel.
If the parcels are developed, wells within the parcels may be completed using hydraulic
fracturing techniques. Additional information is provided in Appendix G. “FracFocus,” is a
database available to the public online at http://fracfocus.org/. Public has expressed concerns
that:
229
August 2019

• Spills during the management of hydraulic fracturing fluids and chemicals or produced
water that result in large volumes or high concentrations of chemicals reaching
groundwater resources;
• Discharge of inadequately treated hydraulic fracturing wastewater to surface water
resources.
Before operators or service companies preform hydraulic fracturing treatment, a series of tests
are preformed to ensure well, casing, and well equipment are in proper order and will safely
withstand the application of the fracture treatment pressures and flow rates. Operators must
comply with O.O. #2 and O.O. # 7. If fracking should occur in an area where there is no vertical
separation between the hydraulically fractured rock formation and the bottom of the potential
underground drinking water source, fracking fluid may be introduced into the source.
hydraulic fracturing completions. Therefore, the underground injection of hydraulic fracturing
flow back in Utah is very limited and presents little potential for inducing seismic activity. In
fact, there has been no reported induced seismicity in Utah that was from water injected into
Class II wells. Oil and gas wells produce a great amount of wastewater. The majority this water
has high salt brine content and must be disposed of in an environmentally safe manner. In Utah,
a majority (95%) of this produced water is pumped into Class II injection wells. In certain parts
of the country, water injection has caused some induced seismicity in the form of small
earthquakes. Two major factors play a role in induced seismicity from water injection. First, the
amount of water being injected. Secondly, the local geology of the water injection site. In Utah,
the volumes are lower than those states experiencing induced seismicity. Also, the geology is
different than those states experiencing induced seismicity. The injection zones are
stratigraphically thousands of feet above the basement rock that may contain large unknown
faults. Therefore, at this time it appears that induced seismicity from water injection is not a
problem in the oil fields of Utah. (Personal communication from John Rogers, Utah Division of
Oil, Gas and Mining (UDOGM), March 27, 2018).
In conclusion, there would be no negative affects to mineral resources. Lease stipulations and
notices are created to mitigate impacts of oil and gas development on other resources.
230
August 2019

Parcels 002, 003, 004, 005, 006, 007, 008 are located within a PFYC 4, which are geologic units
that are known to contain a high occurrence of paleontological resources. UT-LN 72 High
Potential Paleontological Resources applies to the listed parcels therefore no additional analysis Devin McLemore
NI Paleontology is required at this time.
If an APD is filed, specific clearances would be conducted and incorporated into that NEPA 6/27/2019
process. If paleontological resources are located, the AO would be contacted. BMPs, SOPs and
Hazardous materials are not known to exist on the parcels. Refer also to the Air Quality
Wastes discussion for specific information on hazardous air pollutants (HAPs). Hazardous materials, if Devin McLemore
NI not handled properly that are associated with operations, have the potential to be spilled at the
(hazardous or solid) lease/drill site. However, the spill would be contained, reported, and cleaned up by the operator. 7/1/2019

Price Field Office
nation Price Field Office
Air
Erik Vernon
8/28/2019
on all parcels.
Greenhouse Greenhouse Gases are composed mostly of CO2, CH4, N2O, HFCs, PFCs, & SF6. Primary sources of Erik Vernon
PI GHG emissions include fossil fuel combustion, fugitive CH4, and combustion of produced oil and
Gases 8/28/2019
gas. GHG emissions could occur from construction, drilling, and production equipment and end use
231
August 2019

for Air Quality.
Recreation
Areas of The parcels do not intersect any designated ACECs. They do intersect the proposed Mussentuchit
Critical ACEC that was nominated for consideration in the 2008 Price Field Office RMP. The relevant and Sheri Wysong
NP
Environmental important values of the proposed ACEC were Cultural due to the presence of quarries used by 08/16/2019
Concern prehistoric economies.
National Park
There are no Congressionally designated National Historic Trails within the project area. Sheri Wysong
Service Units
NP Additionally, there are no segments of trails under the National Trail Feasibility Study nor trails
and Historic 08/16/2019
recommended as suitable for Congressional designation, but not yet designated.
Trails
BLM-
Administered There are no Congressionally designated BLM Administered National Monuments within the project Sheri Wysong
NP
National area. 8/16/2019
Monuments
Parcel 010 intersects the San Rafael Swell Special Recreation Management Area (SRMA) which was
established in the 2008 Price RMP which designated most of it for management as “semi-primitive”.
However, the Price RMP did not close the SRMA to oil and gas leasing and development, which
contradicted the intent to manage as semi-primitive, as stated in the RMP EIS “Opportunities for
semi-primitive recreation would decrease because of the presence of mineral extraction facilities.
Increased traffic from mineral development personnel would add to conflicts with recreational uses of Sheri Wysong
NI Recreation
these areas.” (BLM, Proposed Resource Managment Plan and Final Environmental Impact Statement 08/16/2019
for the Price Field Office 2008, 4-253) Given that Section 1221 of the John D. Dingell, Jr.
Conservation, Management and Recreation Act established the San Rafael Swell Recreation Area,
closed it to mineral entry and leasing, and left the remainder of the SRMA open to leasing, indirectly
confirms the RMP decision to allow leasing in the SRMA. The fore-quoted analysis in the RMP FEIS
is sufficient disclosure of the impacts.
An operator/lessee must state the routes it intends to use to access a drill site when submitting an
Travel/ APD. It is possible the potential lessee would propose to access the parcels via the Hartnet- Sheri Wysong
NI
Transportation Cathedral Road Class B road in Wayne County, a road claimed by Wayne County as an RS 2477 08/16/2019.
Right-of-Way. The road crosses into the northeast corner of the CNP. The County’s claim has not
232
August 2019

been adjudicated and the NPS would likely object to commercial use of it through CRNP. However,
the logistics of accessing the parcels from this route rather than the Class B Last Chance Loop Route
through Emery County makes it unlikely the operator would propose the Hartnet Cathedral Road. A
Lease Notice is attached to the parcels stating that the BLM does not guarantee access to the parcels
from the south across Park Service lands
The area encompassed by Parcels 009 and 010 rates high for scenic quality, but is managed for Sheri Wysong
Visual
NI VRM III. Development could lead to the degradation of some scenic quality, but since there would
Resources 08/16/2019
be no anticipated oil extraction from the parcels, the visual disturbances could be minimized.
Wild and Sheri Wysong
None of the parcels are in the proximity of wilderness study areas. Two parcels, 009 and 010, are
almost adjacent to the Lower Last Chance Wilderness Area that was designated in Subtitle C part II
of the John D. Dingell, Jr. Conservation, Management and Recreation Act. Section 1232(e) of the
Wilderness/ Act states:
(1) IN GENERAL.—Congress does not intend for the designationof the wilderness areas to Sheri Wysong
PI Wilderness create protective perimeters or buffer zonesaround the wilderness areas. 08/16/2019
Study Area (2) NONWILDERNESS ACTIVITIES.—The fact that nonwilderness activities or uses can
be seen or heard from areas within a wilderness area shall not preclude the conduct of those
activities or uses outside the boundary of the wilderness area.. (United States Congress
2019) (2019, 121)
Lands with About 170 acres of the Cedar Mountain Lands with Wilderness Characteristics Unit would be within Sheri Wysong
NP wilderness the Parcel 10. Development of the parcel could result in surface impacts to the Unit, but would not
characteristics result in a substantial reduction of the size still considered to have wilderness character.. 08/16/2019
Cultural
LM archaeologists have compiled cultural resources data from the Price field office cultural
contain information of all of the recorded cultural resource sites and cultural resource survey data
Cultural for the area available to BLM and the Utah Division of State History. Glenn Stelter
NI
lease notices as required by the Monticello RMP.
233
August 2019


Resources Located Sandy or Erodible Soils),
Kayenta Chapter, Navajo Nation, Mexican Water Chapter, Navajo Nation, Navajo Mountain
Chapter, Navajo Nation, Oljato Chapter, Navajo Nation, Red Mesa Chapter, Navajo Nation, Shonto
Pueblo of Zuni, San Juan Southern Paiute Tribe, Shivwits Band of Paiutes, Shoshone-Bannock,
Skull Valley Band of Goshute Indians, Southern Ute Indian Tribe, The Hopi Tribe, Uintah and
Ouray Ute Tribe, Ute Indian Tribe, Ute Mountain Ute Tribe, White Mesa Ute. At this time, Tribal
consultation is ongoing. The BLM will consult with Indian tribes on a government-to-government
basis, if requested by any Tribe.
234
August 2019

Wildlife
On March 14, 2019, the BLM approved the Utah Greater Sage-Grouse Resource Management Plan
Amendment (ARMPA), which guides management actions for greater sage-grouse (GRSG) habitat
management areas (BLM 2019). The ARMPA identifies priority habitat management areas (PHMA)
for BLM-administered GRSG habitat across Utah, and provides measures to minimize impacts to
PHMA where they cannot be avoided. There are no known occurrences of the GRSG in the parcels
identified for the December 2019 lease sale, and the closest PHMA boundary slightly less than 0.5
miles north and east, and the closest known lek located over 17 miles southeast. However, Karen Cathey
Greater Sage-
NI approximately 60.4 of the total 198.9 acres contained in lease parcel 014 overlaps with potential UTSO
Grouse
seasonal summer and winter habitat located outside PHMA. GRSG inhabit sagebrush plains, August 21, 2019
foothills, and mountain valleys. GRSG are a sagebrush obligate species, therefore require quality
sagebrush habitat, especially for brood rearing and wintering habitat. Implementation of UT-LN-49
on lease parcel 014 will allow the BLM to require modifications to the Surface Use Plan of
Operations may be required to minimize impact to GRSG seasonal summer habitat and individuals
of the species that may occur in these parcels. Collectively the stipulation/notice will minimize
impacts to the species to the degree that no additional detailed analysis in this EA is necessary.
The following documents are incorporated: Utah Wildlife Action Plan (2015), Utah Partners in
Flight Avian Conservation Strategy Version 2.0. (Parrish et al. 2002), Birds of Conservation
Concern (USFWS 2008), Executive Order 13186: Responsibilities of Federal Agencies to Protect
Migratory Birds, MOU between the USDI BLM and USFWS to Promote the Conservation and
Management of Migratory Birds (4/2010), and Utah Supplemental Planning Guidance: Raptor Best
Management Practices (BLM UTSO IM 2006-096).
Migratory birds are protected under the Migratory Bird Treaty Act (Executive Order 13186). MOU Karen Cathey
NI Migratory Birds between the BLM and U.S Fish and Wildlife Service (USFWS) (BLM MOU WO-230-2010-04) UTSO
provides BLM further direction for project-level NEPA guidance for meeting MBTA conservation August 21, 2019
and compliance. Bald and golden eagles receive additional protections under the Bald and Golden
Eagle Protection Act of 1962. Potential for impacts to these eagle species is discussed below, under
BLM Sensitive Species.
235
August 2019

An Endangered Species Act (ESA) species list was obtained from the USFWS Information,
Planning, and Conservation (IPaC) System on July 12, 2019. The IPaC lists the endangered
California condor and southwestern willow flycatcher, and bonytail chub, Colorado pikeminnow,
humpback chub, and razorback sucker (collectively, “Colorado River endangered fish”) as
potentially occurring. The threatened Mexican spotted owl and yellow-billed cuckoo are also listed
as potentially occurring in the vicinity of the parcels proposed for the December 2019 lease sale. The
Utah prairie dog is also known to occur in areas located southwest of parcels 009 and 010. No
designated critical habitat for these species occurs in the parcels proposed for the December 2019
lease sale.
Utah prairie Dog: The southwest portion of southwest quadrant of parcel 009 falls within survey
Threatened,
buffer for the Utah prairie dog. During review of an APD, the implementation of lease notice, T&E- Karen Cathey
Endangered,
09: Utah Prairie Dog, will require surveys for this species and the potential for design modifications
NI Candidate or UTSO
to minimize potential for impacts to these sensitive species.
Proposed August 21, 2019
Animal Species California condor: Designated critical habitat is over 200 miles to the southwest. There are no
known occurrences or nesting sites within the lease area. Parcels 009 and 010 occur within the area
identified for the Nonessential Experimental Population. While California condors not known from
Carbon County, Condor historical habitat occurs in Emery County, which immediately abuts the
southern border of parcel 017. Condors prefer mountainous country at low and moderate elevations,
especially rocky and brushy areas near cliffs. Breeding populations are restricted to California and
Northern Arizona, near release sites, and no known nest sites occur on the parcels. Implementation
of UT-S-293 CSU/TL – California Condor and T&E-11: California Condor prior to development of
parcels 009 and 010 will minimize risk to the condor, should it occur, through requirements for best
management practices to reduce likelihood of impacts (e.g., removal of trash, carrion, and hazardous
materials, surveys and monitoring, reduction of construction footprint, etc.). Such requirements will
minimize the potential for direct and indirect impacts to the species.
236
August 2019

Mexican spotted owl: Designated critical habitat is approximately 10 miles to the southwest of
parcels 009 and 010, 25 miles east of parcel 022, and 37 miles east of parcels 014 and 017. The
spotted owl occupies a variety of habitats in different parts of its range, including various forest
types and steep rocky canyons. There are no confirmed reports of Mexican spotted owls, and
surveys are mostly lacking for the lease area. Cliffs and canyons within and near parcel 014 provide
suitable nesting habitat for the species. The area provides minimal quality for foraging and nesting.
The application of the lease notice and stipulation allow the opportunity to make adjustments at the
site-specific level when an APD is received to reduce potential effects to the birds in the area.
Implementation of the avoidance and mitigation measures identified in T&E-06: Mexican spotted
owl would help ensure minimal impacts to owls.
Southwestern willow flycatcher: No critical habitat within the proposed lease parcels. Designated
critical habitat is greater than 100 miles to the southwest. The southwestern willow flycatcher is
most frequently found in riparian habitats, especially in areas of dense willow. No nesting activity
has been documented in or near the planning area. The closest riparian habitat, located along the
Price River and Muddy Creek, is over 10 miles south and east of the parcels 009 and 010. Based on
elevation and lack of suitable riparian habitats, there is minimal likelihood of occurrence on or
within ¼ mile of the December 2019 lease sale parcels.
Yellow-billed cuckoo: Proposed critical habitat is approximately 100 miles to the southeast, along
the Green River. Yellow-billed cuckoos are considered a riparian obligate and are usually found in
large tracts of cottonwood/willow habitats with dense sub-canopies (below 10 m [33 ft]). The
riparian habitats along the Price River and Muddy Creek, located over 10 miles south and east of the
parcels 009 and 010, could provide suitable nesting habitat for the species. No nesting activity has
been documented in or near the planning area. Based on elevation and lack on suitable riparian
habitats, there is minimal likelihood of occurrence on or within ¼ mile of the December 2019 lease
sale parcels.
Colorado River Endangered Fish: None of the proposed parcels occur near critical or potential
habitat for this group of species, but parcels 014, 017 and 022 occur within watersheds of the Upper
Colorado River drainage basin. Water depletions from any portion of the Upper Colorado River
drainage basin above Lake Powell are considered to adversely affect or adversely modify the critical
habitat of the four resident endangered fish species. Formal consultation with USFWS is required
for all depletions at the site specific analysis. All depletion amounts must be reported to BLM. As
analyzed in the RMP and the BO, the application of the stipulation UT-S-182: Endangered Fish of
237
August 2019

the Colorado allows the opportunity to make adjustments at the site-specific level when an APD is
received to reduce potential effects to the species.
Summary of attachments for threatened, endangered, candidate or proposed animal species, as
noted:
• UT-S-293 CSU/TL – California Condor – Parcels 009, 010
• T&E-06: Mexican spotted owl – Parcel 014
• T&E-11: California Condor – Parcels 009, 010
• T&E-23: Colorado River Endangered Fish – Parcels 014, 017, 022
BLM manages sensitive species in accordance with BLM Manual 6840. Instruction Memorandum
(IM) No. 2016-013 directs Federal departments and agencies to evaluate and use their resources,
facilities, and land management responsibilities to expand knowledge of pollinator health and
increase habitat quality and availability. The State of Utah supports a highly diverse assemblage of
native and endemic bees. Implementing the mitigation measures in lease notice UT-LN-156:
Pollinators and Pollinator Habitat, along with other mitigation measures specifically associated with
sensitive plants discussed below, would minimize potential direct and indirect effects to pollinators
and would improve pollinator habitat over the long-term.
Utah BLM Sensitive Species List (UT-IM-2019-005, March 4, 2019), lists 72 BLM sensitive animal
species, including 22 species which occur or potentially occur within the December 2019 lease sale
BLM Sensitive analysis area. Lease notice UT-LN-49: Utah Sensitive Species, UT-LN-44: Raptors and UT-LN- Karen Cathey
NI Wildlife 45: Migratory Bird, will be applied to every parcel. Available data sources, including BLM data UTSO
Species layers and that available through Utah Conservation Data Center (UCDC) were used to determine if August 21, 2019
the known or potential habitat falls within parcels identified for the December 2019 lease sale. The
following species may occur.
• Kit fox: Suitable habitat occurs within proposed lease parcels 009, 010, and 022 (UDWR 2006)
and the 2014 habitat model for Kit fox indicates a high probability of kit fox occurrence. Habitat
is primarily open desert, shrubby or shrub-grass habitat; shadscale, greasewood or sagebrush.
Primary prey is usually the most abundant nocturnal rodent or lagomorph in the area, but they
opportunistically take birds, reptiles, and insects. Several dens may be used, especially in summer
(Natureserve 2008).
• White-tailed prairie dog (WTPD): This species is managed under the Utah Gunnison’s Prairie
Dog and White-Tailed Prairie Dog Conservation Plan. Suitable habitat occurs in proposed lease
238
August 2019

parcel 022 (UDWR 2006) (PFO habitat model). WTPD requires deep, well-drained soils for
development of burrows; which occurs in semi-arid to arid areas with mixed shrubs/grasses.
• Fringed myotis: This species is managed under the Bat Conservation Plan and it is documented
in the PFO area (www.utahbats.com). Fringed myotis are primarily found in desert, grassland,
and woodland habitats; roosting in caves, mines, rock crevices, and other protected sites. They
are insectivorous, with beetles are common prey. The greatest threat is human disturbance of
roost sites, especially maternity colonies, and the species is subject to white nose syndrome. The
application of the LNs allow for the opportunity to make adjustments at the site specific level
when an APD is received to reduce potential effects to the species in the area.
• Spotted bat: This species is managed under the Bat Conservation Plan and it is documented in
the PFO area (www.utahbats.com). Suitable roosting and foraging habitat occurs within the
proposed lease parcels. They are found in habitats from desert to montane coniferous stands,
including pinyon juniper woodland, canyon bottoms, open pasture, and hayfields. They roost in
caves, cracks, and crevices in cliffs and canyons, primarily feeding on noctuid moths.
• Townsend’s big-eared bat: This species is managed under the Bat Conservation Plan and it is
documented in the PFO area (www.utahbats.com). Suitable foraging habitat occurs within the
proposed lease parcels. These species potentially occur throughout Utah. However, they depend
on caves and mines year round for maternity colonies and hibernacula.
• Bald eagle: The proposed lease parcels contain suitable foraging habitat, although of marginal to
low quality. UDWR Gap Analysis (1997) shows wintering habitat throughout Carbon and Emery
counties including the proposed lease parcels. Wintering areas are commonly associated with
open water, although in some areas, eagles use habitats with little or no open water if food
resources (e.g., carrion) are readily available. The implementation of stipulations to avoid nesting
seasons would eliminate potential disturbance to a nesting eagle if found.
• Golden eagle: High to critical value habitat occurs in all proposed lease parcels. Parcel 014
contains multiple historic golden eagle nests and may include active nests (UDWR Raptor Data
2011). Typically found in open country, especially in mountainous regions. It feeds mainly on
small mammals, especially rabbits, marmots, and ground squirrels, but it also eats insects, snakes,
birds, juvenile ungulates, and carrion. Nests are constructed on cliffs or in large trees.
• Burrowing owl: Suitable habitat occurs within proposed lease parcel 022 (UDWR 2006 T, E, and
SS occurrence data). This species prefers open areas within deserts, grasslands, and sagebrush
steppe communities. This small owl nests and roosts in underground burrows in open and short-
239
August 2019

grass habitats. Habitat consists of well-drained, level to gently sloping areas characterized by
sparse vegetation and bare ground such as moderately or heavily grazed pasture.
• Ferruginous hawk: Suitable foraging habitat occur in proposed lease parcels 014, 017, and 022
(UDWR 2006). Ferruginous hawks are distributed throughout most of Utah. Breeding
ferruginous hawks rely on grassland or shrub steppe terrain and in many parts of Utah Juniper
trees are the primary nesting substrate in Utah, but they will also nest on the ground or on power
line structures.
• Greater sage-grouse: See separate discussion in this table.
• Lewis’ woodpecker: Marginal suitable habitat occurs within proposed lease parcels. The bird
may fly through the areas but is not known to be a permanent resident. (Utah Gap Analysis 1999).
Lewis’ woodpeckers are attracted to burned-over douglas fir, mixed conifer, pinyon-juniper,
riparian, and oak woodlands, but are also found in riparian corridors.
• Long-billed curlew: Gap analysis (UDWR 1999) shows primary and secondary breeding habitat
occurs in all proposed parcels. Long-billed curlew is a migratory species present within Emery
and Carbon counties. Typically nest in habitats that contain short grasses, a bare ground
component, shade, and abundant vertebrate prey, usually in uncultivated rangelands and pastures.
• Great Plains toad: UDWR gap analysis database (1997) shows areas in the proposed lease
parcels mapped as high to substantial value habitat. The Great Plains Toad prefers desert,
grassland, and agricultural habitats where, during cold winter months, they burrow underground
and become inactive, so possibility of disturbance is year round.
• Colorado River cutthroat trout: No occurrences within the proposed lease parcels, but the
streams within the lease parcels have potential to provide the needed habitat and food. Need cool,
well-oxygenated water. Occur in streams and high lakes in the Colorado River Basin.
• Monarch butterfly: Suitable habitat is open field and meadows with milkweed which occurs
throughout Carbon and Emery Counties including the proposed lease parcels. The monarch is a
milkweed obligate, requiring the plant as a host for its larvae. Implementation of UT-LN-156 will
allow opportunity to make adjustments at the site specific level when an APD is received, to
mitigate potential effects.
• Western bumble bee: Suitable habitat is open grassy areas, meadows, and shrublands, which
occurs throughout Carbon and Emery counties and within the proposed lease parcels.
Bumblebees are generalist, foraging on a wide variety of flowering plants. They nest in
underground cavities or abandoned burrows. Bumble bees require plants that bloom and provide
adequate nectar and pollen throughout the colony’s life cycle, which is from early February to
240
August 2019

late November. Implementation of UT-LN-156 will allow opportunity to make adjustments at
the site specific level when an APD is received, to mitigate potential effects.
Summary of lease notices applied to all parcels identified within the PFO area specific to the
December 2019 lease sale applied to all parcels unless otherwise noted, to protect BLM Sensitive
animal species:
• UT-LN-25: White-tailed prairie dog – Parcel 022
• UT-LN-104: Burrowing Owl Habitat – Parcel 022
• UT-LN-107: Bald Eagle
• UT-LN-156 Pollinators and Pollinator Habitat
• UT-S-260: TL – Raptor Habitat
• UT-S-285: TL – Migratory Bird Nesting
protect BLM sensitive species. Implementation of lease notices for sensitive species, migratory birds
and raptors, applied to every parcel, will allow for the opportunity to make adjustments at the site
specific level when an APD is received for all parcels, including those if circumstances change to
allow potential for occurrence of species currently not expected to occur. No surface use or
Parcels located within the PFO area which are proposed for the December 2018 lease sale were
evaluated for State identified game species, including the American bison, cougar, black bear,
Fish and moose, Rocky Mountain elk, mule deer, pronghorn antelope, mountain goat, California bighorn
Wildlife sheep, desert bighorn sheep, Rocky Mountain bighorn sheep, snowshoe hare, wild turkey, chukar, Karen Cathey
Excluding California quail, band-tailed pigeon, sharp-tailed grouse, ruffed grouse, dusky/blue grouse, white-
NI UTSO
USFWS tailed ptarmigan and ring-necked pheasant using UDWR data. Habitat for those not listed below is
Designated August 21, 2019
was not identified.
Species
• Cougar: Parcels 009 and 010 fall in the San Rafael management unit for the cougar; parcels 014,
017, and 022 fall in the Northeast Manti management unit. These areas are managed by UDWR
241
August 2019

for annual statewide limited-entry hunting season. Cougars live all across Utah, and prefer
pinyon-juniper and pine-oak brush areas where there are rocky cliffs, ledges and tall trees or
brush that can be used for cover.
• Black bear: Crucial yearlong habitat occurs within proposed parcels 009, 014 and 017, according
to UDWR.
• Rocky Mountain elk: Proposed lease parcels 014 and 017 contain crucial and substantial winter
and migratory habitats according to recent UDWR data (2006). Elk migrate to lower elevations to
escape the higher snow depths found in the mountains where they summer. Implementation of
UT-S-232 TL Mule Deer and Elk Crucial Winter Range will restrict surface disturbing activities
in crucial mule deer and elk habitats during the times critical to the species.
• Moose: Crucial winter habitat occurs within the lease parcels 014 and 017. Moose prefer forest
habitats, especially those locations with a mixture of wooded areas and open areas near lakes or
wetlands. UT-S-257 – Moose Winter Range will restrict surface disturbing activities in crucial
habitats during the times critical to the species.
• Mule deer: According to UDWR shapefiles (2006) and the Price RMP designated crucial winter
habitat for deer occurs within proposed parcels 014, 017, and substantial winter habitat for deer
occurs in 022. Implementation of UT-S-232: Crucial Mule Deer and Elk Winter Habitat will
restrict surface disturbing activities to times outside of winter range use, thus minimizing impacts
caused by stress and disturbance to the species during crucial winter months.
• Pronghorn antelope: Crucial yearlong habitat occurs within proposed parcels 009, 010, 022
according to UDWR shapefiles (2018) and the Price RMP.
• Wild turkey: Turkeys occur in Carbon and Emery Counties. Prefers cottonwood river bottoms
associated with oak-pine and pinyon-juniper forests, UDWR 2006 occurrence map shows habitat
within 0.5 mi of parcels 014 and 017. This species frequents woodlands and open clearings,
preferring cottonwood river bottoms associated with oak-pine and pinyon-juniper forests.
• Dusky/blue grouse: Suitable habitat within proposed lease parcels 014 and 017. A forest grouse,
open stands of conifer or aspen are preferred habitat (UDWR 2006).Typical habitat is coniferous
forests. Open stands of conifer or aspen with an understory of brush are preferred habitat.
• Chukar: Pockets of delineated crucial winter habitat near or within proposed lease parcel 010,
with general habitat likely to occur within proposed lease parcels as well. Chukar are an
introduced species from the middleeast and southern Asia. The species needs steep, rocky, semi-
arid slopes, with preference for juniper and large boulders on talus slopes. The lack of available
water limits the value of the potential habitat.
242
August 2019

• Ring-necked pheasant: This introduced bird prefers agricultural areas, irrigated farmlands.
Mapped critical value habitat occurs in Carbon and Emery Counties within 0.5 mi of parcel and
transient individuals may occur.
December 2019 lease sale, to protect fish and wildlife excluding USFWS designated species:
• UT-S-232: TL Mule Deer and Elk Crucial Winter Range – Parcels 014 and 017
• UT-S-257 – Moose Winter Range– Parcels 014 and 017
Stipulation UT-S-232 was designed by the BLM in coordination with UDWR to provide protections
sensitive species as noted above, applied to every parcel, will allow for the opportunity to make
adjustments at the site specific level when an APD is received if circumstances change to allow
potential for occurrence of these species. No surface use or otherwise disruptive activity would be
allowed that would result in direct disturbance to populations or individual special status species.
Plants
(IM) No. 2016-013 directs Federal departments and agencies to evaluate and use their resources,
facilities, and land management responsibilities to expand knowledge of pollinator health and
increase habitat quality and availability. The State of Utah supports a highly diverse assemblage of
native and endemic bees (Davidson et al. 1996, p. 100-101). Implementing the mitigation measures
in lease notice UT-LN-49: Sensitive Species and UT-LN-156: Pollinators and Pollinator Habitat,
would minimize potential direct and indirect effects to plants and their pollinators and would Karen Cathey
BLM Sensitive improve pollinator habitat over the long-term.
NI UTSO
Plant Species
Utah BLM Sensitive Species List (UT-IM-2019-005, March 4, 2019), lists 105 BLM sensitive plant August 21, 2019
species, potentially occurring in Utah. Lease notice UT-LN-49: Utah Sensitive Species will be
applied to every parcel. Available data sources, including BLM data layers and site specific BLM
expertise were used to determine if the known or potential habitat falls within the December 2019
proposed lease parcels within the RFO area, with the following results:
• Cruetzfeldt flower: No plants have been identified within the proposed lease parcels, per review
of BLM special status plant data. However, this species is endemic to Carbon, Emery, and Sevier
243
August 2019

Counties, Utah. Occurs in shadscale and mat saltbush communities on the Mancos Formation
between 5,250’ and 6,500’ elevation. Suitable habitat for this species may occur within the
proposed lease parcels 009 and 010.
• Horse Canyon stickleaf: There are no known plants in the proposed lease parcels but the habitat
could occur in parcels 014, 017. Occurs in sagebrush, rabbitbrush, and pinyon-juniper
communities ~6,200ft in elevation, on the Mancos Shale and Price River Formations (Utah Rare
Plants 2019). Parcels are higher in elevation, but species occurrence is poorly documented and
underlying geology and surrounding plant community suggest the possibility of occurrence.
• Mussentuchit gilia: There are no known plants in the proposed lease parcels but habitat could
occur. Individuals have been recorded on similar geology < 10 miles away. This species is found
with shadscale, ephedra, wyethia, indian ricegrass, pinyon-juniper, and mountain mahogany
communities, often on the Curtis formation on fine-textured, pale, poorly cemented limestone,
also in Dakota and Navajo Sandstone, between 5,200 and 7,100ft in elevation (Utah Rare Plants
2019).
• Trotter’s oreoxis: No known plants in the proposed lease parcels, but habitat could occur in lease
parcels 009, 010, which are at the proper elevation with the right geology and vegetation
community. Found in crevices or in sandy pockets on the Moab Tongue and (occasionally) the
Slick Rock members of the Entrada Sandstone. Found in the open, although usually on sites with
a northern aspect, and, less frequently, in alcoves and along shaded cliff bases. Associated with
warm desert shrub and mixed juniper communities at 4,700 to 6,000 ft in elevation.
• UT-LN-51: Special Status Plants: Not Federally Listed
site specific level when an APD is received if circumstances change to allow potential for
occurrence of these species. No surface use or otherwise disruptive activity would be allowed that
would result in direct disturbance to populations or individual special status species.
244
August 2019

endangered Barneby reed-mustard and Wright fishhook cactus, and the threatened plants Jones’
cycladenia, last chance townsendia, Navajo sedge and San Rafael cactus and Winkler cactus as
potentially occurring.
Barneby reed-mustard: Suitable habitat is present within proposed lease parcels 009 and 010. No
Critical Habitat has been designated for this species. This species is endemic to Emery and Wayne
Counties, Utah. Known populations are within the boundary of Capitol Reef National Park west of
Fruita, and in the southern portion of the San Rafael Swell near Muddy Creek. In the PFO this plant
grows on steep rocky hillsides within the suitable geology (Moenkopi, Chinle, Cutler, Kaibab
Limestone and Carmel Formations) between 4,800’ and 6,500’ elevation. In addition, the occupied
sites are typically north-facing along mid to upper slopes.
Threatened, Wright fishhook cactus: Suitable habitat has been identified within proposed lease parcels 009 and
Endangered, 010 (UDWR T,E, and SS Occurrence data 2006) and individuals have been plotted by the Utah Karen Cathey
NI Candidate or Natural Heritage Program both within and adjacent to proposed lease parcels. No critical habitat has UTSO
Proposed Plant been designated for this species. This species is endemic to Utah in Emery, Seveier, and Wayne August 21, 2019
Species counties. It occurs on the Bluegate, Tununk, Emergy, and Ferron members of the Mancos Shale, and
the Curtis, Dakota, Morrison, Summerville, and Entrada Formations, often on fine-textured
gypsiferous or saline soil. Associated with salt desert shrub and shrub-grass communities at 4,200 to
7,600 ft in elevation.
Jones’ cycladenia: Suitable habitat is present within proposed lease parcels 009 and 010. The 2014
habitat model completed for the BLM shows possibility of occurrence in the southwest portion of
the PFO. No Critical Habitat has been designated for this species. Endemic to Emery, Garfield,
Grand, and Kane Counties in Utah and Coconino County, Arizona. Occurs on gypsiferous saline
soils on the Chinle, Cutler, and Summerville Formations. Associated with buckwheat and Mormon
Tea, cool desert shrub and juniper communities between 4,400’ and 6,000’ elevation. Populations
are found on all aspects and on slopes that range from moderate to steep.
Last chance townsendia: Little suitable habitat has been identified within the proposed lease parcels
(UDWR T,E, and SS Occurrence data 2006), but individuals have been plotted by the Utah Natural
Heritage Program less than a mile from proposed lease parcels 009 and 010 on similar substrate. No
245
August 2019

critical habitat has been designated for this species. Endemic to Emery, Sevier, and Wayne Counties,
Utah. Occurs on clay or clay silt soils of the Mancos Shale (Bluegate member). Associated with salt
desert scrub and pinyon-juniper communities between 6,100’ and 8,000’ elevation.
Navajo sedge: No suitable habitat occurs on the parcels proposed for the December 2019 lease sale.
San Rafael cactus: Suitable habitat for this species is present within the proposed lease parcels 009
and 010, per review of suitable habitat and UDWR shapefiles. The species range is centered on the
San Rafael Swell and extends into southwestern Emery County. It is known from several geological
formations: Carmel, the Sinbad member of the Moenkopi, the Brushy Basin member of the
Morrison formation and Mancos shale. The cacti occur in small, widely scattered clusters, typically
on benches, hilltops, and gentle slopes in open pinon-juniper and salt desert scrub communities
between 6,000 and 6,700 ft in elevation.
Winkler cactus: Suitable habitat for this species is present within the proposed lease parcels 009 and
010, per review of suitable habitat and UDWR shapefiles. No Critical Habitat has been designated
for this species. This species is endemic to Emery and Wayne counties. It occurs on alkaline hills,
small-gravel barrens, or clay desert pavements. Typically associated with salt desert shrub
communiteies and pinyon-juniper between 4,800 and 5,300 feet in elevation.
December 2019 lease sale unless otherwise noted, to protect listed plant species:
• T&E-05: Listed Plant Species – Parcels 009 and 010
• T&E-13: Barneby Reed Mustard (Schoenocrambe barnebyi) – Parcels 009 and 010
• T&E-14: Last Chance Townsendia (Townsendia aprica) – Parcels 009 and 010
• T&E-15: Wright Fishhook Cactus– Parcels 009 and 010
• T&E-16: Winkler Pincushion Cactus– Parcels 009 and 010
• T&E-17: San Rafael Cactus– Parcels 009 and 010
• T&E-19: Jones Cycladenia– Parcels 009 and 010
In addition to implementation of lease notices for specific species applied as noted above, measures
contained in UT-LN-49: Sensitive Species will allow for the opportunity to make adjustments at the
site specific level when an APD is received if circumstances change to allow potential for
occurrence of these species. No surface use or otherwise disruptive activity would be allowed that
would result in direct disturbance to populations or individual special status species.
246
August 2019

Noxious/invasive weed species may be present on the subject parcels, see a listing of noxious and
invasive weeds is available in the Noxious Weed Field Guide for Utah available at:
https://extension.usu.edu/fieldguides/ou-files/Noxious-Weed-Field-Guide-for-Utah.pdf. Constraints,
Invasive including the use of certified weed free seed and vehicle/equipment wash stations, would be applied
Karen Cathey
Species/Noxiou as necessary at the APD stage as documented in filing plans and COAs. Control measures would be
NI s Weeds implemented during any ground disturbing activity and documented through a PUP/PAR. Additional UTSO
control and procedural information is documented in the Programmatic EIS Vegetation Treatments August 21, 2019
(EO 13112) Using Herbicides on BLM Lands in 17 Western States and its Record of Decision, (September
2007). If treatment occurs as part of regular operations, BMPs, SOPs and site specific mitigation are
applied at the APD stage as COAs. Negligible impacts would be expected as a result of leasing and
exploration. Application of notice UT-LN-52 (noxious weed) is warranted on all parcels.
which could affect vegetation resources other than potential as discussed above. Leasing is an
administrative action that does not result in any surface disturbance. Site-specific effects cannot be
analyzed until an exploration or development application is received, after leasing has occurred.
Vegetation There would be no impacts to vegetation resources through sale of leases. There is some Karen Cathey
Excluding expectation that exploration or development could occur, at which time additional NEPA would be
NI UTSO
Special Status conducted should an APD be filed. The applied lease stipulations and notices will notify buyers
Species during sale of leases and allow for the opportunity to make adjustments at the site specific level August 21, 2019
when an APD is received and will ensure impacts are addressed. Future development proposals on
the leases would be subject to the standard lease terms, and all applicable laws, regulations and
onshore orders in existence at the time of lease issuance. Additional detailed analysis in this EA is
not necessary.
Scattered sparse woodlands exist areas adjacent to all parcels within the RFO area included in the
NI UTSO
Products, permits are required for severance and removal of forest products regardless of whether August 21, 2019
the product is utilized or not.
247
August 2019

Uintah County. All citizens can file an expression of interest or participate in the bidding process
Environmental (43 CFR 3120.3-2). The stipulations and notices applied to the subject parcels do not place an undue Stephanie Howard
NI
Justice burden on these groups. Leasing the nominated parcels would not cause any disproportionately high 7/17/2019
and adverse effects on minority or low income populations. BMPs, SOPs and site specific mitigation
The direct, indirect, and cumulative impacts to socioeconomics from oil and gas leasing was
considered in detail in the Environmental Impact Statement for the Price Field Office Resource
Socio- management Plan throughout Section 4.6 and 4.7. In general, the analysis discuss direct economic Stephanie Howard
NI
Economics benefits from oil and gas development, indirect economic activity from electricity generation, 7/17/2019
transportation, and other services, resource conflicts, and the quality of life in the surrounding
communities resulting from oil and gas development. Additional information is contained in the
county general plan and its corresponding resource management plan. Land uses in county and
parcel areas would continue. Land use plan (as amended) allocations would not be altered. BMPs,
SOPs and site specific mitigation may be applied at the APD stage as COAs.
Water Resources
The lease parcels do not occur within any Sole Source Aquifers or Drinking Water Source
Protection Zones (DWSPZs). Compliance with IM UT 2010-055 would be completed prior to APD
approval. Maintenance and refueling of equipment could impact water quality. However, standard
Water protocols would minimize possibility of releases. Drill holes will be cased to an elevation below
Resources/ 5800 feet or when groundwater is encountered. No surface disturbance or occupancy would be
Quality maintained within 660 feet of any natural springs to protect the water quality of the spring. No new Jerrad Goodell
NI
(drinking/ disturbance will be allowed in areas equal to the 100-year floodplain or 100 meters on either side of 7/3/19
surface/ the center line of any stream, stream reach, or riparian area. At the time of development, drilling
ground) operators will conform to the provisions of the operational regulations and Onshore Oil & Gas Order
Number 2, which requires the protection and isolation of all useable quality waters. High-country
watershed areas would be closed seasonally from December 1 to April 15 to surface disturbing
activity at elevations above 7,000 feet.
248
August 2019

All soils with high erosion potential need care to prevent accelerated erosion that could be
transported to streams that are already listed on the 303d list. This will be accomplished by careful
placement of drill pads and access routes. Regular maintenance on roads and pads in highly erosive
soils will be required.
Leasing would not, by itself, authorize any ground disturbances which could affect these resources.
Site-specific effects cannot be analyzed until an exploration or development application is received,
Wetlands/ after leasing has occurred. However, any development proposal on the leases would be subject to the Jerrad Goodell
NI Riparian Zones standard lease terms, and all applicable laws, regulations and onshore orders in existence at the time
/ Floodplains of lease issuance. The before mentioned conditions along with stipulation UT-S-127 applied to all 7/3/19
parcels will result in negligible expected impacts to these resources therefore detailed analysis is not
required.
The soils within Parcels 014 & 017 are currently semi-stable with vegetation growing. Removing
the vegetation will expose the soils and the soils could become unstable. The soils could become
Soils: unstable due to steep slopes with large precipitation events. Soils within Parcels 009, 010 & 022
are highly erodible and unstable. Soils in these parcels are mainly affected by wind and high Stephanie Bauer
NI Physical/Biolog precipitation events and increased disturbance could enhance erosion. Soils within these parcels are
7/15/19
ical mainly comprised of high contents of sand and mancos shale clay. Leasing however, will not have
any effect on soils as that is an administration action. Other stipulations would be required at the
APD stage.
Rangeland Health
Farmlands
According to the NRCS soil survey and knowledge of the soils, there are no prime/unique farmlands Stephanie Bauer
NI (Prime or within the project area. 7/15/19
Unique)
Exploration or development would not conflict with the Fire Management Plan goals and objectives.
Fuels/Fire The implementation of appropriate reclamation standards at the APD stage would prevent an Stuart Bedke
NI
Management increase of hazardous fuels. Fuels and fire management would not be impacted by the lease process. 7/17/19
BMPs, SOPs, and site specific mitigation may be applied at the APD stage as COAs.
Livestock Leasing or production activities would not cause changes to grazing permit terms and conditions. Mike Tweddell
NI Any activity that involves surface disturbance or direct resource impacts would have to be
Grazing 7/18/19
authorized as a lease operation through future NEPA analysis, on a case-by-case basis, at the APD
249
August 2019

stage. Impacts to livestock grazing may occur as a result of subsequent actions including exploration
development, production, etc. Therefore, reclamation provisions/procedures including re-vegetation
(utilizing appropriate seed mix based on the ecological site, elevation and topography), road
reclamation, range improvement project replacement/restoration (e.g., fences, troughs and cattle
guards), noxious weed control, would be identified in future NEPA/decision documents on a case-
by-case basis (at the APD stage). In addition, if any range improvement projects could be impacted
by wells or associated infrastructure, well pads could be moved 200 meters to avoid rangeland
improvements or vegetation monitoring plots as per 43 CFR 3101.1-2. BMPs, SOPs and site specific
The subject lease parcels (009 and 010) are within the Muddy Creek Herd Area, but are not within Mike Twedell
Wild Horses
NI the Muddy Creek Herd Management Area. Leasing of the parcels will not affect WH&B
and Burros 7/18/19
management.
Lands and Minerals
cadastral survey reviews and verifies the legal land descriptions prior to lease issuance. Stone
monuments may be present and would need to be avoided the same as metal cap monuments.
Detailed land surveys may be warranted at the APD stage. BMPs, SOPs and site specific mitigation
may be applied at the APD stage as COAs. Jaydon Mead
NI Lands/Access Coordination with existing Right-of-Way holders in the proposed lease parcels would occur if their
right-of-way would be affected. There are existing Rights-of-Ways UTU-54689 within parcel 010 7/17/2019
and SL-015794 within parcel 014 so lease notice UT-LN-83 will be applied on those parcels.
There are a couple identified Emery County roads within the lease parcels 009 and 010. Coordination
with the County would need to occur if these roads are to be used or upgraded to see if any county
permits are required.
The 2008 RMP FEIS adequately addresses the impacts of oil and gas leasing. Oil and gas
Geology / exploration could lead to an increased understanding of the geologic setting, as subsurface data Rebecca Anderson
Mineral obtained through lease operations may become public record. This information promotes an 7/8/19
NI Resources/ understanding of mineral resources as well as geologic interpretation. Depending on the success of
Energy Angela Wadman
future oil and gas drilling, non-renewable oil and/or natural gas may be extracted from productive
Production wells and delivered to market. Production of oil and/or gas would result in the irretrievable loss of 8/14/2019
these resources. While conflicts could arise between oil and gas operations and other mineral
250
August 2019

operations, these could generally be mitigated under the regulations 3101.1-2, where proposed oil
and gas operations may be moved up to 200 meters or delayed by 60 days and also under the
standard lease terms (Sec. 6) where siting and design of facilities may be modified to protect other
resources. There no known locatable, salable or leasable minerals within this block.
techniques. Additional information is provided in Appendix G. “FracFocus,” is a database available
to the public online at http://fracfocus.org/. Public has expressed concerns that:
resources;
content and must be disposed of in an environmentally safe manner. In Utah, a majority (95%) of
this produced water is pumped into Class II injection wells. In certain parts of the country, water
injection has caused some induced seismicity in the form of small earthquakes. Two major factors
play a role in induced seismicity from water injection. First, the amount of water being injected.
Secondly, the local geology of the water injection site. In Utah, the volumes are lower than those
states experiencing induced seismicity. Also, the geology is different than those states experiencing
induced seismicity. The injection zones are stratigraphically thousands of feet above the basement
rock that may contain large unknown faults. Therefore, at this time it appears that induced seismicity
251
August 2019

from water injection is not a problem in the oil fields of Utah. (Personal communication from John
Rogers, Utah Division of Oil, Gas and Mining (UDOGM), March 27, 2018).
In conclusion, there would be no negative affects to mineral resources. Lease stipulations and
notices are created to mitigate impacts of oil and gas development on other resources.
Lease parcels 009, 010, and 022 lie in Class 2 and Class 3 areas on the Potential Fossil Yield
Classification. The geologic units are not likely to contain or contain moderate or infrequent Rebecca Anderson
NI Paleontology occurrence of paleontological resources. Lease parcels 014 and 017 lie in Class 4, these geologic
units are known to contain a high occurrence of paleontological resources. Stipulations UT-S-176 7/8/19
and UT-S-177 and Lease Notice UT-LN-72 will be applied to Parcels 014 and 017 .
Wastes Hazardous materials are not known to exist on the parcels. Hazardous materials, if not handled
properly that are associated with operations, have the potential to be spilled at the lease/drill site. Angela Wadman
NI (hazardous or However, the spill would be contained, reported, and cleaned up by the operator. BMPs, SOPs and
8/14/2019
solid) site specific mitigation may be applied at the APD stage as COAs.
252
August 2019
Vernal Field Office

nation Vernal Field Office
Air
Erik Vernon
8/28/2019
on all parcels.
Greenhouse
Gases 8/28/2019.
for Air Quality.
Recreation
Areas of
The parcel intersects a small portion of the Lower Green River Corridor ACEC, which is designated Sheri Wysong
Critical
NI No Surface Occupancy... The Adjacent to the No Suface Occupancy, the western half of the parcel is
VRM class II which would constrain development and “buffer” impacts to the ACEC.
Concern
National Park Sheri Wysong
NP GIS review confirms there are NPS Units proximate to the parcel.
Service Units 08/16/2019
National Sheri Wysong
NP Conservation GIS review confirms there are no National Conservation Areas proximate to the parcel.
Areas 08/16/2019
Noise impacts from development could detract from the experiences of recreational users of the Sheri Wysong
NI Recreation Green River corridor. LN 125 has been added to the parcel to inform the lessee/operator that
additional measures may be required to prevent noise impacts to users of the river. 08/16/2019
253
August 2019

Travel/ Exploratory access to the nominated lease parcels would be from an existing road that access the Sheri Wysong
NI
Transportation adjacent SITLA section to the north. 08/16/2019.
The issue of concern for visual resources is the viewshed from the Green River. This was considered Sheri Wysong
Visual
NI in the RMP analysis, and over 50% of the parcel has been designated No Surface Occupancy or VRM
Class II to protect the viewshed.
The lease parcels do not overlap any suitable WSR segments. However, one corner of Parcel 026 is
Wild and within a quarter mile of a suitable segment of the Green River. LN Notice 125 has been added to the Sheri Wysong
NI
Scenic Rivers parcel to inform the lessee/operator that additional measures may be required to prevent noise 08/16/2019
impacts to the suitable segment.
Wilderness/Wil Sheri Wysong
NI derness Study None of the parcels intersect wilderness areas or wilderness study areas.
Area 08/16/2019
Lands with Parcel 026 is within a unit of the Desolation Canyon Non –WSA Lands with Wilderness Sheri Wysong
NI wilderness Characteristics Analyzed in the 2008 RMP EIS, and was not carried forward in the ROD to preserve
characteristics the wilderness characteristics. 08/16/2019
Cultural
BLM archaeologists have compiled cultural resources data from the Price field office cultural
Cultural lease notices as required by the Monticello RMP. Glenn Stelter
NI
Resources At this time, (08/16/2019) consultation with the Utah State Historic Preservation Office is ongoing. 08/16/2019
254
August 2019


Resources Located Sandy or Erodible Soils).
Kayenta Chapter, Navajo Nation, Mexican Water Chapter, Navajo Nation, Navajo Mountain Chapter,
Navajo Nation, Oljato Chapter, Navajo Nation, Red Mesa Chapter, Navajo Nation, Shonto
by any Tribe.
Wildlife
Parcel 026 is not within general or priority habitat for greater sage-grouse. The nearest suitable Karen Cathey
Greater Sage- habitat (winter) is over 6 miles distant, and the nearest lek is over 18 miles distant.
NI UTSO
Grouse
August 21, 2019
The following documents are incorporated: Utah Wildlife Action Plan (2015), Utah Partners in Flight Karen Cathey
NI Migratory Birds Avian Conservation Strategy Version 2.0. (Parrish et al. 2002), Birds of Conservation Concern UTSO
Birds, MOU between the USDI BLM and USFWS to Promote the Conservation and Management of August 21, 2019
255
August 2019

Migratory Birds (4/2010), and Utah Supplemental Planning Guidance: Raptor Best Management
Practices (BLM UTSO IM 2006-096).
conservation and compliance. Bald and golden eagles receive additional protections under the Bald
and Golden Eagle Protection Act of 1962. Potential for impacts to these eagle species is discussed
An Endangered Species Act (ESA) species list was obtained from the USFWS Information, Planning,
and Conservation (IPaC) System for the RHA area on July 15, 2019. The IPaC lists the endangered
bonytail chub, Colorado pikeminnow, humpback chub and razorback sucker (collectively known as
the “Endangered Fish of the Upper Colorado River”) and the threatened Canada lynx, Mexican
spotted owl and yellow-billed cuckoo as potentially occurring in the vicinity of the parcels proposed
Threatened, for the December 2019 lease sale. No designated critical habitat for these species occurs in the
parcels proposed for the December 2019 lease sale, other than that meeting the definition for the
NI Candidate or endangered fish, discussed below. UTSO
Proposed August 21, 2019
Animal Species Canada lynx - No critical or suitable habitat occurs in the vicinity of the parcel 026. This species are
most likely to persist in boreal forest areas that receive deep snow and have high-density populations
of snowshoe hares, the principal prey of lynx.
Mexican spotted owl: No Designated Critical, suitable or potential habitat or areas where MSO
models (Willey/Spotskey 1997 & 2000) predict potential suitability is found within lease parcel 026
or FWS recommended buffers. Nesting/roosting habitat typically occurs either in well-structured
forests with high canopy cover, large trees, and other late seral characteristics, or in steep and narrow
256
August 2019

rocky canyons formed by parallel cliffs with numerous caves and/or ledges within specific geologic
formations (USFWS 2012).
Yellow-billed cuckoo: There is no designated Critical habitat within parcel 026; however, the parcel
is within 0.5 miles of riparian areas may provide possible habitat for YBCU. Parcel 026 would will
be covered under the avoidance and minimization measures outlined in Stipulation UT-S-297:
CSU/TL – Yellow Billed Cuckoo, in addition to lease notice T&E31: Western Yellow Billed
Cuckoo. Implementation of this stipulation and notice will require suitable habitat be surveyed and
monitored during construction, and restricts activities which may disturbed the birds present,
management of produced water, and revegetation with native species. Collectively, the requirements
of UT-S-297 and T&E-31 minimizes the potential for impact to the species.
Endangered Fish of the Upper Colorado River: Portions of the 100-year floodplain that contain
primary constituent elements necessary for survival of the species; in addition, water depletions from
any portion of the Upper Colorado River drainage basin are considered to adversely affect or
adversely modify the critical habitat of the four resident endangered fish species, and must be
evaluated with regard to the criteria described in the Upper Colorado River Endangered Fish
Recovery Program. Formal consultation with USFWS is required for all depletions. Lease Notice
T&E-03: Endangered Fish of the Upper Colorado River Drainage Basin provides measures that may
avoid and minimize adverse effects to these sensitive fish, including the need to report depletion
amounts to the BLM and possible need for consultation with the USFWS.
Summary of attachments for threatened, endangered, candidate or proposed animal species:
• UT-S-297: CSU/TL – Yellow Billed Cuckoo
• T&E-03: Endangered Fish of the Upper Colorado River Drainage Basin
• T&E-31: Western Yellow Billed Cuckoo
BLM manages sensitive species in accordance with BLM Manual 6840. Utah BLM Sensitive
Species List (UT-IM-2019-005, March 4, 2019), lists 72 BLM sensitive animal species, including 23
species which occur or potentially occur within the December 2019 lease sale parcel 026. Available
BLM Sensitive data sources, including BLM data layers and that available through Utah Conservation Data Center Karen Cathey
NI Wildlife (UCDC) were used to determine if the known or potential habitat falls within parcels within the FFO UTSO
Species area identified for the December 2019 lease sale. August 21, 2019
The following species may occur. Implementation of UT-LN-49: Utah Sensitive Species, UT-LN-
44: Raptors and UT-LN-45: Migratory Bird to all parcels will alert to lease to the potential for
257
August 2019

occurrence, and allow for the opportunity to make adjustments at the site specific level when an APD
is received thus minimizing potential for impact.
Townsend’s big-eared bat: There is documentation of this species in the VFO area region
(www.utahbats.com). Suitable foraging habitat (marginal) occurs within the lease parcels. These
species potentially occur throughout Utah. However, they depend on caves and mines year round for
maternity colonies and hibernacula.
Big free-tailed bat: Species is rare in Utah and there is limited documentation of this species in the
VFO area region (www.utahbats.com). The insectivorous species is managed under the Bat
Conservation Plan. The species often roots and forms maternity colonies near bodies of open water.
Fringed myotis: There is documentation of this species in the region (www.utahbats.com). Fringed
myotis are found primarily in desert, grassland, and woodland habitats; and roost in caves, mines,
rock crevices, buildings, and other protected sites. The species is managed under the Bat
Conservation Plan. They are insectivorous, with beetles a common prey item.
Spotted bat: There is documentation of this species in the region. (www.utahbats.com) Suitable
roosting and foraging habitat occurs within the lease parcels. There are no known populations at this
time. Spotted bats are found in various habitats from desert to montane coniferous stands, including
pinyon juniper woodland, canyon bottoms, open pasture, and hayfields. They roost in caves, in
cracks, and crevices in cliffs and canyons. Spotted bats apparently feed primarily on noctuid moths
and sometimes beetles. They are managed under the Utah Bat conservation Plan.
Bald eagle: The lease parcel contain suitable winter habitat of marginal to low quality. Wintering
areas are commonly associated with open water, although in some areas, eagles use habitats with little
or no open water if other food resources (e.g., rabbit or deer carrion) are readily available. Winter
roosting areas are within parcel 026. There are a several known nests in the within the region but no
known nests on parcel 026; implementation of stipulation UT-S-278: CSU – Bald Eagle Nesting Sites
and lease notice UT-LN-107: Bald Eagle, to avoid nesting seasons would eliminate potential
disturbance to a nesting eagles if found.
Burrowing owl: Suitable habitat occurs within the lease parcel 026. This species prefers open areas
within deserts, grasslands, and sagebrush steppe communities. This small owl nests and roosts in
underground burrows in open and short-grass habitats. Habitat consists of well-drained, level to
gently sloping areas characterized by sparse vegetation and bare ground.
258
August 2019

Ferruginous hawk: Suitable foraging habitat occur in the lease parcel 026. Suitable nesting habitat is
found throughout the VFO. Ferruginous hawks are distributed throughout most of Utah, and suitable
nesting habitat is found in the region of the parcel. Breeding ferruginous hawks rely on grassland or
shrub steppe terrain and in many parts of Utah Juniper trees are the primary nesting substrate in Utah,
but they will also nest on the ground or on power line structures.
Greater sage-grouse: Parcel 026 is not within general or priority habitat for greater sage-grouse. The
nearest suitable habitat (winter) is over 6 miles distant, and the nearest lek is over 18 miles distant.
Bobolink: There are no known occurrences of the bobolink within the VFO but the lease parcel
potentially overlap with high value habitat value according to UDWR conservation data base. This
species breeds, nests, and forages in wet meadow, wet grassland, and irrigated agricultural areas that
tend to be associated with riparian or wetland areas.
Great Plains toad: There are no known occurrences of this species in the VFO parcel 026. But the
DWR natural heritage database identifies areas in the lease parcels mapped as high to substantial
value habitat. Parcels containing desert seeps and springs will have the greatest potential the toad.
Bluehead sucker: Catch records indicate this species occurs in downstream reaches of the Green
River. While the Green River is located within 0.5 mile of parcel 026, terrain in and immediately east
slopes rapidly toward the river and releases from activities should be managed to assure adjacent
habitat is not affected.
Flannelmouth sucker: Catch records indicate this species occurs in downstream reaches of the Green
River. While the Green River is located within 0.5 mile of parcel 026, terrain in and immediately east
slopes rapidly toward the river and releases from activities should be managed to assure adjacent
habitat is not affected.
Summary of lease notices applied to all parcels identified within the VFO area specific to the
December 2019 lease sale applied to all parcels unless otherwise noted, to protect BLM Sensitive
animal species:
• UT-S-261: Raptor Timing and Buffer
• UT-S-278: CSU – Bald Eagle Nesting Sites
259
August 2019

• UT-LN-107 Bald Eagle
protect BLM sensitive species. Where an unexpected occurrence of a BLM sensitive species may
occur, or where a lease notice is not specifically noted above, implementation of lease notices for
sensitive species, migratory birds and raptors, applied to every parcel, will allow for the opportunity
to make adjustments at the site specific level when an APD is received if circumstances change to
allow potential for occurrence of these species. No surface use or otherwise disruptive activity would
be allowed that would result in direct disturbance to populations or individual special status species.
Parcel 026 located within the VFO area which are proposed for the December 2019 lease sale was
evaluated for State identified game species, including the American bison, cougar, black bear, moose,
Rocky Mountain elk, mule deer, pronghorn antelope, mountain goat, California bighorn sheep, desert
bighorn sheep, Rocky Mountain bighorn sheep, snowshoe hare, wild turkey, chukar, California quail,
band-tailed pigeon, sharp-tailed grouse, ruffed grouse, dusky/blue grouse, white-tailed ptarmigan and
ring-necked pheasant using UDWR data. Habitat for those not listed below is was not identified.
American bison: Parcel 026 falls within UDWR designated crucial bison winter habitat. Individuals
and small groups of bison from the Ute Indian herd have begun frequenting ranges outside the trust
Fish and boundary, with observations reported on Wild Horse Bench located approximately 4 miles east of
Wildlife parcel 026. Karen Cathey
Excluding
NI Cougar: Parcel 026 falls in the Book Cliffs management unit for the cougar, managed by UDWR for UTSO
USFWS
Designated annual statewide limited-entry hunting season. Cougars live all across Utah, and prefer pinyon- August 21, 2019
Species juniper and pine-oak brush areas where there are rocky cliffs, ledges and tall trees or brush that can
be used for cover.
Pronghorn: A portion of parcel 026 falls within UDWR designated crucial year-long habitat.
Implementation of UT-LN-13: Pronghorn Winter Habitat and UT-LN-14: Pronghorn Fawning
Habitat will allow that surface use or otherwise disruptive activity may be restricted for up to 60 days
during critical seasons to encourage conservation of this species.
Mule deer: Portions of parcel 026 falls within UDWR identified year-long crucial habitat. Mule deer
migrate to lower elevations to escape the higher snow depths found in the mountains where they
summer. Implementation of UT-S-231: Crucial Mule Deer Winter Range and UT-S-247: Crucial Elk
260
August 2019

Calving and Deer Fawning Habitat will restrict surface disturbing activities to times outside of crucial
range use, thus minimizing impacts caused by disturbance to the species during sensitive periods.
Rocky Mountain bighorn sheep: All of parcel 026 falls within UDWR designated year-long crucial
habitat. Implementation of UT-LN-20: Rocky Mountain/Desert Bighorn Sheep Crucial Lambing and
Rutting Habitat will assist in conservation of this species by allowing restriction of disruptive activity
for up to 60 days during sensitive periods.
Chukar: Parcel 026 occurs in year-long crucial habitat for the game bird chukar. Chukar are an
introduced species from the middle east and southern Asia which require steep, rocky, semi-arid
slopes. Preference for juniper and large boulders on talus slopes.
Summary of lease notices applied to parcel 026 to protect fish and wildlife excluding USFWS
designated species:
• UT-S-231: CSU – Crucial Deer Winter Range
• UT-S-247 Crucial elk Calving and Deer Fawning Habitat
• UT-LN-13: Pronghorn Winter Habitat
• UT-LN-14: Pronghorn Fawning Habitat
• UT-LN-20: Rocky Mountain/Desert Bighorn Sheep Crucial Lambing and Rutting Habitat
These stipulations were designed by the BLM in coordination with UDWR to provide protections
Plants
(IM) No. 2016-013 directs Federal departments and agencies to evaluate and use their resources, Karen Cathey
BLM Sensitive facilities, and land management responsibilities to expand knowledge of pollinator health and
NI UTSO
Plant Species increase habitat quality and availability. The State of Utah supports a highly diverse assemblage of
native and endemic bees (Davidson et al. 1996, p. 100-101). Implementing the mitigation measures in August 21, 2019
lease notice UT-LN-156: Pollinators and Pollinator Habitat, along with other mitigation measures
261
August 2019

specifically associated with sensitive plants discussed below, would minimize potential direct and
indirect effects to pollinators and would improve pollinator habitat over the long-term.
Utah BLM Sensitive Species List (UT-IM-2019-005, March 4, 2019), lists 105 BLM sensitive plant
species, including 12 species which occur or potentially occur within the December 2019 lease sale
analysis area. Lease notice UT-LN-49: Utah Sensitive Species will be applied to every parcel.
Available data sources, including BLM data layers and site specific BLM expertise were used to
determine if the known or potential habitat falls within the December 2019 proposed lease parcels
within the VFO area, with the following results:
Barneby’s catseye: This species may be found on white semi-barren shale knolls of the Green River
Formation in shadscale, rabbitbrush, sagebrush, and pinyon-juniper communities, between 6000-
7900 ft.
Green River greenthread: This species occurs in sparsely vegetated cushion plant communities with
little or no cover of graminoids or shrubs, on white shale benches and windswept slopes of the Green
River and Uinta formation with pinyon and mountain mahogany. 5900-8400 ft.
Sterile yucca: Known occurrences of the species are found growing in sandy soils. However, this
species has not been extensively surveyed for nor is the range and exact habitat requirements fully
understood. Therefore, at this time, any sandy soils within the proposed lease parcels have to be
assumed to be potential habitat for the species. UT-LN-51: Special Status Species Not Federally
Listed will provide specific measures to protect any individuals identified on the parcel.
In 2014, an interagency team comprised of representatives from SITLA, Uintah County (UT),
UDWR, Rio Blanco County (CO), Utah Public Lands Policy Coordination Office, BLM, and
USFWS signed a Conservation Agreement and Strategy for Graham’s beardtongue and White River
beardtongue (SWCA 2014). This agreement established Conservation Areas across the range of the
two species. The Conservation Areas are managed to identify, mitigate, and minimize impacts to
Graham’s and White River beardtongue, and establish a threshold for the amount of surface
disturbance that can occur in these areas on both Federal and non-Federal lands. The parcel was
evaluated with regard to potential occurrence for these species, with the following results:
Graham’s beardtongue: This species is covered under a conservation agreement, and approximately
the western ½ of parcel 026 is within a Conservation Area and proposed critical habitat for this
species. It occurs on semi-barren, white to tan shale and oil shale slopes, hills, and ridges of the
Green River Formation in shadscale, Salina wildrye, and pinyon-juniper plant communities from
262
August 2019

5,000 to 6,300 ft. Implementation of UT-LN-90: Graham’s beardtongue (Penstemon grahamii); UT-
LN-134: Graham’s beardtongue (Penstemon grahamii) & White River beardtongue (P. scariosus var.
albifluvis) Conservation Area; in addition to UT-LN-49: Utah Sensitive Species and UT-LN-51
(Special Status Plants: Not Federally Listed) will require surveys prior to and monitoring during
construction, in addition to specific measures to protect any individuals found to minimize impacts.
White River beardtongue: This species is covered under a conservation agreement, and parcel 026 is
within a Conservation Area and proposed critical habitat for this species. It occurs on semi-barren,
white to tan shale and oil shale slopes, hills, and ridges of the Green River Formation in shadscale,
Salina wildrye, and pinyon-juniper plant communities from 5,000 to 6,300 ft. Implementation of UT-
LN-134: Graham’s beardtongue (Penstemon grahamii) & White River beardtongue (P. scariosus var.
albifluvis) Conservation Area; in addition to UT-LN-49: Utah Sensitive Species and UT-LN-51
(Special Status Plants: Not Federally Listed) will require surveys prior to and monitoring during
construction, in addition to specific measures to protect any individuals found to minimize impacts.
Summary of lease notices applied to all parcels identified within the VFO area specific to the
• UT-LN-49 Sensitive Species
• UT-LN-51: Special Status Plants: Not Federally Listed
• UT-LN-90: Graham’s beardtongue (Penstemon grahamii)
• UT-LN-134: Graham’s beardtongue (Penstemon grahamii) & White River beardtongue (P.
scariosus var. albifluvis) Conservation Area
Threatened, threatened plants clay reed-mustard, Uinta Basin hookless cactus and Ute ladies’-tresses as
potentially occurring.
NI Candidate or UTSO
Proposed Plant Clay reed-mustard: This species may occur on parcel 026. It normally occurs in the lower Uinta and August 21, 2019
Species upper Green River formations in shadscale, Indian ricegrass, pygmy sagebrush, and other mixed
desert shrub communities. 4800-5600 ft. Implementation of T&E-05: Listed plant species in addition
to T&E-20: Clay Reed Mustard (Schoencrambe argillacea) will ensure conservation measure to
minimize direct and indirect impacts are minimized.
263
August 2019

Uinta Basin hookless cactus: Typically, this species grows on gravelly terraces and benchlands, and
it may also be found in locations with desert pavement, shale outcrops, and mudstone deposits at
4500-6000 feet. Implementation of T&E-05 and T&E12 (Pariette brevispinus) and Uinta Basin
hookless cactus (Sclerocactus wetlandicus) will ensure conservation measures for direct and indirect
impacts are minimized.
Ute ladies’-tresses: This species requires wet meadows, stream banks, abandoned oxbow meanders,
marshes and raised bogs, usually at between 4500 and 6850 feet. No habitat for Ute ladies’-tresses
occurs on the site.
Summary of lease notices applied to parcel 026 identified within the VFO area specific to the
December 2019 lease sale unless otherwise noted, to protect Federally-listed species:
• Implementation of T&E-05: Listed Plant Species
• T&E-12: (Pariette brevispinus) and Uinta Basin hookless cactus (Sclerocactus wetlandicus)
• T&E-20: Clay Reed Mustard (Schoencrambe argillacea)
Noxious/invasive weed species may be present on the subject parcels, including cheatgrass, saltlover,
Russian thistle, tall tumblemustard and African mustard. Constraints, including the use of certified
weed free seed and vehicle/equipment wash stations, would be applied as necessary at the APD stage
Invasive as documented in filing plans and COAs. Control measures would be implemented during any Karen Cathey
Species/Noxiou ground disturbing activity and documented through a PUP/PAR. Additional control and procedural
NI s Weeds UTSO
information is documented in the Programmatic EIS Vegetation Treatments Using Herbicides on
(EO 13112) BLM Lands in 17 Western States and its Record of Decision, (September 2007). If treatment occurs August 21, 2019
as part of regular operations, BMPs, SOPs and site specific mitigation are applied at the APD stage as
COAs. Negligible impacts would be expected as a result of leasing and exploration. Application of
notice UT-LN-52 (noxious weed) is warranted on all parcels.
which could affect vegetation resources other than potential as discussed above. Leasing is an
Vegetation administrative action that does not result in any surface disturbance. Site-specific effects cannot be Karen Cathey
Excluding analyzed until an exploration or development application is received, after leasing has occurred.
NI UTSO
Special Status There would be no impacts to vegetation resources through sale of leases. There is some expectation
Species that exploration or development could occur, at which time additional NEPA would be conducted August 19, 2019
should an APD be filed. The applied lease stipulations and notices will notify buyers during sale of
leases and allow for the opportunity to make adjustments at the site specific level when an APD is
264
August 2019

received and will ensure impacts are addressed. Future development proposals on the leases would be
subject to the standard lease terms, and all applicable laws, regulations and onshore orders in
existence at the time of lease issuance. Additional detailed analysis in this EA is not necessary.
Scattered sparse woodlands exist areas adjacent to all parcels within the VFO area included in the
NI UTSO
Products, permits are required for severance and removal of forest products regardless of whether the August 19, 2019
product is utilized or not.
Uintah County. All citizens can file an expression of interest or participate in the bidding process (43
Environmental CFR 3120.3-2). The stipulations and notices applied to the subject parcels do not place an undue
NI David Gordon 7/1/2019
Justice burden on these groups. Leasing the nominated parcels would not cause any disproportionately high
and adverse effects on minority or low income populations. BMPs, SOPs and site specific mitigation
Refer to the Economic Profile System Reports prepared on 10/18/2018 (EPS 2018) (A Profile of
Agriculture, Public Land Amenities, A Profile of Demographics, A Profile of Federal Land
Socio- Payments, A Profile of Government Employment, A Profile of Land Use, A Profile of Mining,
NI Including Oil & Gas, A Profile of Non-Labor Income, A Profile of Service Sectors, A Profile of David Gordon 7/1/2019
Economics
Socioeconomic Measures, A Profile of Timber and Wood Products, A Profile of Industries that
Include Travel & Tourism, A Profile of Development and the Wildland-Urban Interface, and A
Summary Profile). Additional information is contained in the county general plan and its
corresponding resource management plan. Land uses in county and parcel areas would continue.
Land use plan (as amended) allocations would not be altered. BMPs, SOPs and site specific
Water Resources
265
August 2019

Leasing would not, by itself, authorize any ground disturbances which could contribute runoff
affecting surface water quality. Site-specific effects cannot be analyzed until an exploration or
development application is received, after leasing has occurred. However, any development proposal
on the leases would be subject to the standard lease terms, and all applicable laws, regulations and
onshore orders in existence at the time of lease issuance. Site-specific analysis would be required prior
to the approval of any ground disturbance proposal on the lease parcels.
There are no identified ground or surface drinking water protection zones in the area of the lease
parcels.
These water rights have beneficial uses of stockwater, irrigation, and domestic. Water quality must
continue to be acceptable to meet the beneficial uses of the water right. Exploration and development
could cause impacts.
Water The following notice would be added to all parcels to inform potential lessees of the requirements of
Resources/ EO 11988: UT-LN-128: Floodplain Management. Jerrad Goodell 7/3/2019
Quality If an APD is filed, SOPs required by regulation and design features would be sufficient to isolate and
NI
(drinking/ protect all usable ground or surface water sources before drilling or exploration begin. The SOPs Ann Marie Aubry
surface/ include the requirements for disposal of produced water contained in Onshore Oil and Gas Order 7-23-2019
ground) (O.O.) No. 7 and the requirements for drilling operations contained in O.O No. 2. Potential fresh
water aquifers zones would be protected by the requirement of casing and cementing the drill hole to
total depth. The casing would be pressure tested to ensure integrity prior to drilling out the surface
casing shoe plug. Potential impacts would be addressed and a design feature would be included
utilizing UT IM 2010-055 (Protection of Ground Water Associated with Oil and Gas Leasing,
Exploration and Development) prior to APD approval. Standard protocols would minimize
possibility of releases (cased drill holes, no surface disturbance or occupancy would be maintained
within 660 feet of any natural springs, new disturbance would be not be allowed in areas equal to the
100-year floodplain or 100 meters on either side of the center line of any stream, stream reach, or
riparian area). BMPs, SOPs and site specific mitigation may be applied at the APD stage as COAs.
No additional impacts beyond those analyzed in the Vernal PRMP FEIS Section 4.15.2.4 and 4.23.13
are anticipated to water resources from the leasing of this parcel, therefore no further detailed analysis
is required in the EA.
266
August 2019

No Riparian areas or Wetlands exist within this parcel but there is an intermittent stream and
associated floodplain. Leasing would not, by itself, authorize any ground disturbances which could
affect these resources. Site-specific effects cannot be analyzed until an exploration or development
application is received, after leasing has occurred. However, any development proposal on the leases
Wetlands/ would be subject to the standard lease terms, and all applicable laws, regulations and onshore orders in Jerrad Goodell 7/3/2019
NI Riparian Zones existence at the time of lease issuance. No additional impacts beyond those analyzed in the Vernal Ann Marie Aubry
/ Floodplains PRMP FEIS Section 4.15.2.4 and 4.23.13 are anticipated to water resources from the leasing of this 7-23-2019
parcel.
In addition, The following notice would be added to parcel #26 to inform potential lessees of the
requirements of EO 11988: UT-LN-128: Floodplain Management.
At this stage (lease sale) there would be no impacts to vegetation resources. There is some
expectation that exploration or development could occur, at which time additional NEPA would be
conducted should an APD be filed. If additional site specific resource protection measures are needed
to prevent unnecessary or undue degradation, these would be developed at the time of the site specific
Soils: NEPA. It is expected that reclamation procedures would be required to ensure long-term vegetation David Gordon 7/1/2019
NI Physical/ impacts are minimized. Reclamation provisions/procedures would include re-vegetation (utilizing Ann Marie Aubry
Biological appropriate seed mix based on the ecological site, elevation and topography), road reclamation, 7-26-2019
noxious weed controls, etc.
Parcel 026 contains steep topography. Apply lease Stipulations UT-S-96, UT-S-99, and UT-S-100 to
minimize potential impacts. SOPs, BMPs and site specific design features applied at the APD stage
including reclamation, may be applied as COAs. Therefore no further analysis is required in this EA.
Rangeland Health
Farmlands Soil map units that are classified by the NRCS as farmland may intersect these parcels. None of these David Gordon 7/1/2019
would be irrigated due to exploration or development activities. These soils would not be utilized in
NI (Prime or Ann Marie Aubry
agricultural practices while retained in BLM ownership. BMPs, SOPs and site specific mitigation
Unique) may be applied at the APD stage as COAs. Therefore no further analysis is required in this EA. 7-26-2019
Fuels/Fire Exploration or development would not conflict with the Fire Management Plan goals and objectives. Blaine Tarbell 7/5/19
NI
Management The implementation of appropriate reclamation standards at the APD stage would prevent an increase
267
August 2019

of hazardous fuels. Fuels and fire management would not be impacted by the lease process. BMPs,
SOPs, and site specific mitigation may be applied at the APD stage as COAs.
The parcels are located within Wildhorse Bench and Green River AMP, which are active livestock
grazing allotments. Leasing or production activities would not cause changes to grazing permit terms
and conditions. Any activity that involves surface disturbance or direct resource impacts would have
to be authorized as a lease operation through future NEPA analysis, on a case-by-case basis, at the
APD stage. Impacts to livestock grazing may occur as a result of subsequent actions including
exploration development, production, etc. Therefore, reclamation provisions/procedures including re- Travis Decker
Livestock
NI vegetation (utilizing appropriate seed mix based on the ecological site, elevation and topography),
Grazing 7/8/2019
road reclamation, range improvement project replacement/restoration (e.g., fences, troughs and cattle
guards), noxious weed control, would be identified in future NEPA/decision documents on a case-by-
case basis (at the APD stage). In addition, if any range improvement projects could be impacted by
wells or associated infrastructure, well pads could be moved 200 meters to avoid rangeland
improvements or vegetation monitoring plots as per 43 CFR 3101.1-2. BMPs, SOPs and site specific
The parcels do not intersect herd areas or herd management areas. However, animals may stray from
their designated boundaries outside of their established Herd Area. Immigration and emigration does
Wild Horses Dusty Carpenter
NP occur within a reasonable distance of the established and unfenced boundaries. Therefore, although
the parcel does not intersect the Herd Area Boundaries; physical sightings of horses from the Hill
Creek Herd Area may still occur.
Lands and Minerals
cadastral survey reviews and verifies the legal land descriptions prior to lease issuance. Stone
monuments may be present and would need to be avoided the same as metal cap monuments.
Detailed land surveys may be warranted at the APD stage. BMPs, SOPs and site specific mitigation
may be applied at the APD stage as COAs. Brandi Perry
NI Lands/Access Coordination with existing Right-of-Way holders in the proposed lease parcels would occur if their
6/26/2019
right-of-way would be affected.
There are existing Rights-of-Way on parcel 026 and lease notice UT-LN-83 will be applied.
There are several identified Uintah County roads within the lease parcel. Coordination with Uintah
County would need to occur if the roads need upgrading or other permits are required.
268
August 2019

promotes an understanding of mineral resources as well as geologic interpretation. While conflicts
could arise between oil and gas operations and other mineral operations, these could generally be
mitigated under 43 CFR 3101.1-2 and under standard lease terms (Sec. 6) where sitting and design of
facilities may be modified to protect other resources.
extracted and delivered to market. Production would result in the irretrievable loss of these resources.
The RFDS is documented at section 2.2.1. The proposed action would not exceed the level of activity
predicted in the RFDS.
Any oil and gas development can be managed to avoid or work within other mineral resources.
Mining claims and Mineral Materials were checked on 7/5/2019. No active placer claims or Mineral
Material sites were found to be associated within any parcel.
Geology / techniques. Additional information is provided in Appendix G. “FracFocus,” is a database available Dallas F. Nutt
Mineral to the public online at http://fracfocus.org/. Public has expressed concerns that: 7/5/2019
NI Resources/
• Spills during the management of hydraulic fracturing fluids and chemicals or produced water Angela Wadman
Energy
that result in large volumes or high concentrations of chemicals reaching groundwater 8/14/2019
Production
resources;
269
August 2019

Utah Division of Oil, Gas and Mining (UDOGM), March 27, 2018).
In conclusion, there would be no negative affects to mineral resources.
There are no known paleontological resources within the parcels. If an APD is filed, specific
clearances would be conducted and incorporated into that NEPA process. If paleontological resources Dallas F. Nutt
NI Paleontology
are located, the AO would be contacted. BMPs, SOPs and site specific mitigation may be applied at 7/5/2019
Wastes for specific information on hazardous air pollutants (HAPs). Hazardous materials, if not handled
NI (hazardous or properly that are associated with operations, have the potential to be spilled at the lease/drill site. David Gordon 7/2/2019
solid) However, the spill would be contained, reported, and cleaned up by the operator. BMPs, SOPs and
270
August 2019
Appendix E – Air Quality and Green House Gas Information and Calculations
General Conformity Applicability
Under the Clean Air Act the BLM is required to make a general conformity determination for reasonably
foreseeable emissions that result from actions in that area (40 CFR 93.153.k). In August 2019, the
General Conformity rules grace period ends for the Uinta Basin nonattainment area. The general
conformity rules are not applicable to this lease sale because: 1) onshore lease sales are analogous to
offshore leases for the Outer Continental Shelf which are explicitly exempt in the Clean Air Act, 2)
leasing does not directly authorize pollutant emitting activities, and no direct emissions would result, and
3) emissions are not reasonably foreseeable as defined in 40 CFR § 93.152 as it is unknown what design
features or mitigation measures an operator will use. The BLM has evaluated the proposed lease sale in
accordance with the provisions of 40 CFR Part 93, Subpart B. Based on a review of 40 CFR § 93.153(c),
BLM has determined that the requirement to perform a full conformity determination is not required for
the proposed action for the following reasons:
• Under 40 CFR 93.153(c)(2), a conformity determination is not required for actions “which would
result in no emissions increase or an increase in emissions that is clearly de minimis.” Leasing
does not authorize emissions generating activities, and therefore does not directly result in an
emissions increase.
• A conformity determination also is not required “where the emissions (direct or indirect) are not
reasonably foreseeable.” 40 CFR § 93.153(c)(3). As defined in the CAA, “Reasonably
foreseeable emissions are projected future direct and indirect emissions that are identified at the
time the conformity determination is made; the location of such emissions is known and the
emissions are quantifiable as described and documented by the Federal agency based on its own
information and after reviewing any information presented to the Federal agency.” 40 CFR §
93.152 While this EA provides information for the factors that should be considered to determine
a reasonable estimate of foreseeable emissions for the proposed lease parcels and overall for the
region for purposes of NEPA cumulative impacts analysis, it does not have specific information
about whether or how the specific parcel under consideration will be developed during the initial
10 year lease period, such that a more precise emissions inventory could be reasonably estimated
and compared to the thresholds provided in 40 CFR § 93.153(b).
• An onshore lease sale is analogous to the example provided in 40 CFR § 93.153(c)(3)(i), “Initial
Outer Continental Shelf lease sales which are made on a broad scale and are followed by
exploration and development plans on a project level.” Similarly, development of an onshore
lease requires subsequent BLM review and NEPA analysis of a specific development proposal.
There are several factors to consider for estimating potential emissions that are highly variable
depending on the project, and although potential emissions from parcel development are used for
analysis and discussion in this EA, “reasonably foreseeable emissions” are not definitive until the
BLM receives actual plans of development (i.e. APDs).
• Furthermore, 40 CFR § 93.153(d) provides, “[notwithstanding the other requirements of this
subpart, a conformity determination is not required for:
o The portion of an action that includes major or minor new or modified stationary sources
that require a permit under the new source review (NSR) program (Section 110(a)(2)(c)
and Section 173 of the [CAA]) or the prevention of significant deterioration program
(title I, part C of the [CAA]).” 40 CFR 93.153(d)(1). It is uncertain at this time, but
highly likely, that several project design features, for example equipment sets, such as
tanks, truck loading, wellsite stationary engines, VOC control devices, dehydration units,
and other equipment will require at least a minor new source review (permit) prior to
271
August 2019
constructing such facilities to implement any subsequent development proposals.

Emissions from such permitted facilities would not be subject to the general conformity
analysis provisions. BLM expects that much of the new oil and gas development that may
occur on the proposed lease parcels would use similar equipment and processes that will
require similar permitting to the recent oil and gas development projects for the area. For
example emissions sources include in Utah Administrative Code R307-504-511 or the
Federal Implementation Plan for the Indian Country Minor New Source Review Program
for the Oil and Natural Gas Industry ( 80 FR 51991) would not be included.
For all of these reasons, a conformity determination is not required for the sale of the leases under
consideration.
Criteria Air Pollutant Emissions
A summary of existing criteria air pollutant emissions for the State of Utah is provided in Table 25.
Table 25. 2014 Criteria Air Pollutant Emissions (tpy) in Utah by Source
Source CO NOx PM10 PM2.5 SOx VOCs
Area Sources 36,713.5 13,937.5 153,057.8 22,816.2 170.6 33,417.2
Area Sources Oil

15,444.7 16,404.2 790.5 564.5 291.5 178,518.3
and Gas
Non-Road
121,315.9 17,287.8 1,528.1 1,449.4 214.3 20,066.5
Mobile
On-Road Mobile 203,288.5 60,952.1 12,425.8 4,277.6 294.6 20,487.0
Point Sources 23,175.9 63,141.8 10,303.5 5,635.7 25,561.6 5,848.1
Point Portable 83.5 228.4 93.1 17.8 38.9 51.
Biogenics 143,712.4 0.0 0.0 0.0 0.0 692,037.
Wildfires 5,793.3 164.9 701.0 630.9 0.0 989.
State Total 549,528 172,117 178,900 35,392 26,572 951,41
Hazardous Air Pollutant Emissions

A summary of existing HAP emissions for counties in which lease parcels are located is presented in
Table 26.
272
August 2019
Table 26. Triennial Inventory of HAPs (2014).

HAPS (tpy) Carbon Emery Grand San Juan Sanpete Sevier Uintah
County County County County County County County
Acetaldehyde 1.234 -- 0.107 0.001 0.000 -- 0.010
Benzene 2.476 0.407 1.522 3.525 0.000 -- --
Ethylbenzene 0.323 -- 0.058 0.044 -- -- --
Formaldehyde 16.371 0.333 5.380 0.242 0.003 0.760 0.180
Hexane 1.259 -- 3.450 0.954 0.060 0.360 --
Methanol 0.211 -- 14.000 -- -- -- --
Naphthalene 0.003 -- -- 0.001 0.000 --- --
Toluene 4.710 -- 0.778 0.745 0.000 -- --
Xylenes 0.746 -- 1.560 0.121 0.000 -- --
Fishlake National Forest Oil and Gas Modeling Results

Impact analyses, from the Fishlake National Forest Oil and Gas Leasing FEIS (USDAFS 2013), were
conducted for distances ranging from 0.25 to 200 km (124.3 miles) from the source and at seven receptor
elevations that ranged from 2,500 feet above to 2,500 feet below the source. The highest receptor impacts
occurred when the model receptors were at or near the same elevation as the source. Table 27documents
the maximum predicted criteria pollutants NO2, SO2, and PM10/PM2.5 concentrations (μg/m3) as well
as the maximum visibility impairment impacts at a variety of distances, for the scenario where the
receptors were at the same elevation as the source. The tabulated impacts represent the maximum impact
at the given distance for any of the elevation scenarios. For the impact assessment of primary PM2.5
PM10 impacts were used as a conservative assessment given that primary PM2.5 is a subset of primary
PM10.
273
August 2019
Table 27 Air Quality Impacts from Drilling a Single Well

Criteria Class I Class II 1km 5km 10km 20km
Pollutant Period Increment Increment
Concentrations (µg/m3) at Various

Distances
1-hour NA NA 0.11 0.03 0.01 0.01
3-hour 25 µg/m3 512 µg/m3 0.16 0.05 0.02 0.01
SO2 24-hour 5 µg/m3 91 µg/m3 0.07 0.02 0.01 0.00
Annual 2 µg/m3 20 µg/m3 0.02 0.01 0.00 0.00
1-hour NA NA 54.6 14.7 7.2 3.1
NO2 Annual 2.5 µg/m3 25 µg/m3 10.1 3.39 1.63 0.77
24-hour 8 µg/m3 30 µg/m3 12.40 2.77 1.20 0.53
PM10 Annual 4 µg/m3 17 µg/m3 3.09 0.69 0.30 0.13
24-hour NA NA 12.40 2.77 1.20 0.53
PM2.5 Annual NA NA 3.09 0.69 0.30 0.13
NO2 Dep 0.005 kg/hect/yr 0.0262 0.0050 0.0020 0.0007
Deposition SO2 Dep 0.005 kg/hect/yr 0.0001 0.0000 0.0000 0.0000
Days Δdv > Less than NA 4 1 1 1

0.5 Baseline
Visibility Days Δdv > Less than NA 0 0 0 0

1.0 Baseline
State, National, and Global GHG Emissions

Reported GHG emissions from major sources in Utah in 2017 totaled 35.0 million metric tons (MMT) of
CO2e. A total of 64 facilities reported GHG emissions in 19 of Utah’s 29 counties. Annual emissions in
Utah for each year from 2010 to 2017 are shown in Figure 20. From 2013 to 2017, emissions in Utah
decreased 9.4 MMT CO2e, or 19.6%.
274
August 2019
Utah Annual GHG Emissions

46,000,000
44,000,000
42,000,000
Metric Tons CO2e
40,000,000
38,000,000
36,000,000
34,000,000
32,000,000
30,000,000
2010 2011 2012 2013 2014 2015 2016 2017
Year
Source: EPA GHG Reporting Program FLIGHT tool (EPA 2018)

Figure 20 Annual GHG emissions from major industrial sources in Utah in MMT CO2e
Total U.S. greenhouse gas emissions in 2017 were 6,456.7 MMT of CO2e, as shown in Table 28. This
represents a 1.3% increase in emissions compared to the 1990 baseline year presented in the report.
Emissions decreased from 2016 to 2017 by 0.5 percent (35.5 MMT CO2e), driven in large part by a
decrease in CO2 emissions from fossil fuel combustion (EPA 2019). The energy sector accounts for 84%
(5,424.8 CO2e) of GHG emissions in the United States.
Table 28. Recent Trends in U.S. Greenhouse Gas Emissions (MMT CO2e)
1990 2013 2014 2015 2016 2017
Total U.S. Emissions 6,371.0 6,710.2 6,760.0 6,623.8 6,492.3 6,456.7
Global emissions information is available in the European Commission Emissions Database for Global
Atmospheric Research (EDGAR) (Janssens-Maenhout, et al. 2017). The EDGAR database provides a
comprehensive picture of anthropogenic CO2 emissions through 2016, and includes all IPCC sectoral
classifications. Emissions data for all other GHGs is available through 2012. More recent estimates for all
GHGs are not possible since no recent information is available about emissions from global agriculture, a
major source sector for CH4 and N2O.
Total global GHG emissions in 2012 were 46,423.3 MMT CO2e. Figure 21 shows the annual global
emissions from 1990-2012. The global GHG emissions trends have increased since the beginning of the
21st century, driven mainly by increases in CO2 emissions from China and other emerging economies.
Methane and N2O emissions were 19% and 6%, respectively, of total emissions in 2012.
275
August 2019
Source: European Commission Emissions Database for Global Atmospheric Research (EDGAR) (Janssens-
Maenhout, et al. 2017).
Figure 21 Total global GHG emissions in gigatons CO2e/yr.
Energy related GHG emissions in the U.S. are presented in Table 29 (EPA 2019). Fossil fuel combustion
is the largest source of energy-related GHG emissions in the U.S. Energy related emissions increased
1.5% from 1990 to 2017. These increases were largely from fossil fuel combustion, non-energy use of
fuels, and petroleum systems. Emissions decreases were seen in natural gas systems, coal mining, and
mobile combustion.
Table 29. Recent Trends in U.S. Energy Sector Greenhouse Gas Emissions (MMT CO2e)
1990 2013 2014 2015 2016 2017
Fossil Fuel Combustion 4,738.8 5,157.4 5,199.3 5,047.1 4,961.9 4,912.0
Natural Gas Systems 223.1 190.8 190.6 192.2 191.2 191.9
Non-Energy Use of Fuels 119.6 123.5 119.9 126.9 113.7 123.2
Petroleum Systems 51.0 66.8 71.7 71.2 60.4 61.0
Coal Mining 96.5 64.6 64.6 61.2 53.8 55.7
Stationary Combustion 33.7 41.5 41.9 39.0 38.0 36.4
Mobile Combustion 55.0 26.6 24.3 22.4 21.2 20.1
Incineration of Waste 8.4 10.6 10.7 11.1 11.1 11.1
Abandoned Oil and Gas Wells 6.6 7.0 7.1 7.1 7.2 6.9
Abandoned Underground Coal 7.2 6.2 6.3 6.4 6.7 6.4
Mines
Total 5,339.8 5,695.0 5,736.4 5,584.7 5,465.3 5,424.8
276
August 2019
Source: EPA Inventory of US Greenhouse Gases Emissions and Sinks 1990-2017 (EPA 2019)
Gas wells tend to have higher methane emissions due to the nature of the fossil fuel being extracted. The
U.S. natural gas systems include hundreds of thousands of wells, hundreds of processing facilities, and
over a million miles of transmission and distribution pipelines. Details on methane emissions from natural
gas systems are provided in Table 30, and include emissions from well exploration, production,
processing, transmission and storage, and distribution. Methane emissions occur from un-combusted
exhaust, venting and flaring, pressure relief systems, and equipment or pipeline leaks. In 2017, 1% of
non-combustion methane emissions from natural gas systems came from exploration, 65% from
production, 7% from processing facilities, 20% from transmission and storage, and 7% from distribution.
Table 30. Methane Emissions from U.S. Natural Gas Systems (MMT CO2e)
1990 2013 2014 2015 2016 2017
Exploration 4.0 3.0 1.0 1.0 0.7 1.2
Production 67.0 108.5 108.5 108.8 107.1 108.4
Processing 21.3 10.8 11.1 11.1 11.4 11.7
Transmission and Storage 57.2 31.0 32.4 34.2 34.5 32.4
Distribution 43.5 12.3 12.2 12.0 12.0 11.9
Total 193.1 165.6 165.1 167.2 165.7 165.6
GHG Emissions from Constructing and Operating Oil or Gas Wells

The construction and operation emissions are identified for a single well by field office and then
multiplied by the lease sale RFD from the respective May 2015 and February 2016 NEPA documents.
This results in an estimate of the total emissions for the lease sale, by field office. These figures are
overestimates, because more parcels were analyzed in the EAs than were ultimately offered in the May
2015 and February 2016 lease sales.
Direct GHG emissions from oil and gas activates occur during construction and operations of a well.
Construction related emissions occur from the use of heavy machinery during pad construction, drilling,
testing and completion, venting and flaring, interim reclamation, and vehicles. Construction emissions are
typically a onetime occurrence. Operation related emissions occur from well workovers, pump engines,
heaters, tanks, truck loading, fugitive leaks, pneumatics, dehydrators, compressor engines, reclamation,
and vehicle traffic. Emissions from operation activities occur throughout the life of a well. Several factors
may influence actual emissions including location, geological formation, well depth, equipment used,
supporting infrastructure, and other factors. For these reasons, this document presents GHG emissions by
BLM District Office from typical oil and gas well activity occurring in each area.
Green River District Direct Emissions

GHG emissions estimates for the Green River District are incorporated from the Monument Butte FEIS
(BLM 2016), Alternative B No Action Alternative. All methods and assumptions used to develop the
emissions in the Monument Butte FEIS apply, and are incorporated by reference. The Alternative B (No
Action alternative) emissions inventory is used because it does not include applicant committed emissions
reduction measures, and represents potential wells that may result from leasing in the Green River
District. Emission estimates for construction and operation of a single well are presented in Table 31.
Emissions are listed by well type, with gas wells having higher construction emissions mainly due to
deeper drilling depths and oil wells having higher operation emissions mainly from heaters and pump
engines. Well types are not easily identifiable when calculating the total emissions from existing and
reasonably foreseeable wells, so calculations for the Green River District are based on gas well
277
August 2019
construction emissions (678.5 CO2e/yr. per well) combined with oil well operation emissions (427.7
CO2e/yr per well). This provides a conservative estimate when well type is unknown.
Table 31. Single Well GHG Emissions Based on the Monument Butte FEIS Alternative B Inventory
Single Oil Well Emissions Metric Tons per year
Development Phase CO2 CH4 N2O CO2e
Construction 89.3 0.08 0.0007 91.8
Operations 388.6 1.40 0.0007 427.7
Total 477.9 1.48 0.001 519.5
Single Gas Well Emissions Metric Tons per year
Construction 676.3 0.03 0.005 678.5
Operations 1.3 3.00 0.000004 85.3
Total 677.6 3.03 0.005 763.8
Canyon Country District Direct Emissions

Emissions estimate for the Canyon Country District are incorporated by reference from the Moab Master
Lease Plan (MLP) FEIS (BLM 2016). All methods and assumptions used to develop the emissions in the
Moab MLP FEIS apply, and are incorporated by reference. Single well annual emissions were computed
by taking the total annual GHG emissions from the Moab MLP FEIS high emissions scenario and
dividing by the number of wells constructed each year for the construction emissions, and divided by the
number of producing wells for the operations emissions. Emissions were also converted from short tons
to metric tons, and the CO2e was updated using GWP from the IPCC Fifth Assessment Report. This
emissions inventory (Table 32) represents oil and gas operations occurring within the Canyon Country
District.
Table 32. Single Well GHG Emissions Based on the Moab MLP FEIS Inventory
Single Well Emissions Metric Tons per year
Construction 2115.6 8.44 0.039 2363.0
Operations 149.7 49.55 0.005 1538.9
Total 2265.2 57.99 0.045 3900.8
Color Country and West Desert District Direct Emissions

The Color Country and West Desert Districts have lower oil and gas potential than the Green River and
Canyon Country Districts. As a result, existing wells tend to be farther from supporting infrastructure and
processing facilities. The emissions inventory (Table 33) from the Grand Staircase Escalante National
Monument and Kanab RMP FEIS, Appendix M Air Technical Support Document (p. M-46) (BLM 2019)
accounts for emissions from wells that are far from supporting infrastructure. The emissions inventory
and all methods and assumptions from the Grand Staircase Escalante National Monument and Kanab
RMP DEIS are incorporated by reference, and considered to be a to represent GHG emissions inventory
for oil and gas development on parcels within the Color Country and West Desert Districts.
278
August 2019
Table 33 Single Well GHG Emissions Based on the GSENM Kanab DEIS Inventory
Single Well Emissions Metric Tons per year
Construction 836.5 3.60 0.021 806.7
Operations 1756.2 9.38 0.021 2024.6
Total 2592.7 13.0 0.042 2967.5
GHG Emissions from the Combustion of Produced Oil or Gas
Combustion emissions from foreseeable development are difficult to quantify since the amount of
produced oil and gas is unknown until after a well is drilled. For the purpose of this supplemental EA,
BLM assumed that future wells will produce oil and gas in similar amounts as other existing nearby
wells. BLM used annual data from 2008 to 2018 to determine the average production per well. However,
some wells may produce more or less than the average. To better inform decision makers and the public,
low and high production estimates are used for calculating combustion emissions.
Estimates of production and combustion GHG emissions for a single well are presented in Table 34. The
average annual production and standard deviation of annual production between the years 2008 and 2018
was first calculated for each field office using data from the Utah Division of Oil, Gas and Mining
(UDOGM 2018). A standard deviation is a statistical measure used to quantify the amount of variation in
a set of data. BLM based low and high production estimates on values two standard deviations below and
above the average annual production. Two standard deviations account for 95% of the variation, assuming
the dataset of annual production is a Gaussian distribution (equally varies above and below the average).
Since two standard deviations only cover 95% of the variation, it’s possible, but unlikely, that an
individual well could produce more or less oil and gas than the estimated production range. A well is
most likely to produce higher amounts of oil and gas immediately after it is drilled, and produce less at
the end of its lifespan due to production decline. At the field office level, BLM assumed that active wells
produce both oil and gas since the Utah Division of Oil, Gas and Mining reports only identify total
producing wells at the county level and the number for each well type (oil or gas) is only reported for the
entire state. Using the state wide well type information for comparison, the low, average, and high
combustion emissions for an oil well in Utah are 1,857 mt CO2e/yr, 3,156 mt CO2e/yr, and 4,455 mt
CO2e/yr respectively. Gas well combustion emissions are 2,410 mt CO2e/yr (low), 3,483 mt CO2e/yr
(average), and 4,556 mt CO2e/yr (high). State average emissions by well type are in a similar to the
average emissions for all field offices. The statewide average emissions per well from Table 18 is used for
field offices where no well production data is available to estimate GHG emissions.
Table 34. Production of Oil and Gas for a Single Well and Associated GHG Combustion Emissions
2008-2018 Range of Oil 2008-2018 Range of Gas Range of Emissions per
Production (bbl/well) Production (mcf/well) well (metric tons CO2e/yr)
Field Office Low Ave High Low Ave High Low Ave High
Moab - 1,002 2,649 5,407 8,576 11,746 298 904 1,786
Monticello 4,753 5,555 6,356 10,264 13,635 17,006 2,609 3,140 3,670
Price 25 49 73 28,508 62,133 95,758 1,581 3,445 5,308
Richfield 28,727 74,408 120,089 - 13,028 41,557 12,352 32,713 53,928
Vernal 797 2,254 3,711 14,344 29,171 43,997 1,133 2,577 4,020
Average 963 2,329 3,694 15,069 31,106 47,142 1,244 2,715 4,186
EPA Emissions factors: 0.43 metric tons CO2e/bbl, and 0.0551 metric tons CO2e/mcf. (EPA 2019).
Production data obtained from the Utah Division of Oil, Gas and Mining (UDOGM 2018).
279
August 2019
Uncertainty
The GHG emissions estimates discussed in this EA are an estimate of the GHGs that may be released into
the atmosphere as a result of initial wellsite construction, well drilling and completion, production, and
end use in connection with potential development of the leases associated with the proposed action. GHG
emissions estimates involve significant uncertainty due to unknown factors including well depth, actual
production, how produced minerals are used, the form of regulation of GHG parameters by delegated
agencies, and whether any Best Available Control Technologies are utilized at the upstream or
downstream emissions location(s). Deeper wells require engines with a greater horsepower. The British
thermal unit content of the product can also vary substantially which will ultimately influence any
estimates of GHGs from combustion, as can the total volume of liquids produced with the gas stream,
which also requires handling, and may generate fugitive emissions. Ultimately, while estimates in this EA
are based on the best available data, including information from existing operators regarding future
drilling plans and targets, these estimates are subject to many conditions that are largely beyond the
BLM’s control. Unforeseen changes in factors such as geologic conditions, drilling technology,
economics, demand, and federal, state, and local laws and policies could result in different quantities of
GHG emissions than those estimated in this supplemental EA.
The rough estimates of combustion CO2e emissions presented in this EA are qualified by uncertainty in
potential future production, and in predicting the end uses for the fuels extracted from a particular
leasehold. Future production is uncertain with regard to the actual levels of development over time, levels
of development over the life of the lease, new technology, geologic conditions, and the ultimate level of
production from any given well (whether reservoir related, or for economic reasons). For the analysis in
this supplemental EA, BLM used average per-well production estimates for each relevant field office.
This approach may overestimate or underestimate production in areas where resource conditions depart
from “average,” because it assumes, for purposes of analysis, that all lands have equal potential for
production, and all lands may be produced at some point in the future. While this may not hold true based
on site-specific geology, it is a reasonable method for developing estimates of GHG emissions at the
leasing stage.
After extraction from federal leases, end uses of oil and gas may include refining for transportation fuels,
fuel oils for heating and electricity generation, or production of asphalt and road oil. Oil and gas may also
be used in the chemical industry, for the manufacture of medicines and everyday household items,
plastics, military defense and for the manufacture of synthetic materials. Further, fossil fuels can be
consumed, but not combusted, when they are used directly as construction materials, chemical feedstock,
lubricants, solvents, waxes, and other products. Common examples include petroleum products used in
plastics, natural gas used in fertilizers, and coal tars used in skin treatment products.
The BLM does not control the specific end use of the oil and gas produced from federal leases. As a
result, the BLM can only provide an estimate of potential GHG emissions by conservatively assuming
that all produced oil and gas would eventually be combusted.
Existing and Foreseeable Total Oil and Gas GHG Emissions
Existing GHG emissions from the operations of all (federal and non-federal) producing oil and gas wells
are presented in Table 35. Emissions are presented for existing wells in each field office and as a state
total.
280
August 2019
Table 35. Estimated Annual Operating Emissions from Existing Federal and Non-Federal Oil and
Gas Wells
Operation
Number of Total (Metric Tons
Field Office Emissions
Active Wells CO2e/yr)
(CO2e/yr/well)
Moab 1788 454 811,943
Monticello 1,788 716 1,280,509
Price 428 1366 584,252
Richfield 2025 31 62,763
Vernal 428 11,112 4,752,716
State Total 7,639,980
Emissions of GHGs from combustion for all oil and gas produced within Utah in 2018 are presented in
Table 36. BLM used 2018 production data, by county, reported by the Utah Division of Oil, Gas and
Mining database (UDOGM 2018) for all (federal and non-federal) producing wells. Emissions were
calculated by multiplying the production amounts by EPA equivalency emission factors (EPA 2019).
Table 36. Annual GHG Emissions from Combustion of Produced Oil and Gas (2018)
2018 Total Production Metric Tons CO2e/yr
Field Office Oil (bbl) Gas (mcf) Oil Gas Total
Moab 349,430 3,059,650 150,255 168,587 318,842
Monticello 3,916,113 9,631,838 1,683,929 530,714 2,214,643
Price 47,597 49,181,909 20,467 2,709,923 2,730,390
Richfield 1,345,937 708,139 578,753 39,018 617,771
Vernal 30,929,312 230,867,520 13,299,604 12,720,800 26,020,405
Total 36,895,510 295,438,197 15,865,069 16,278,645 32,143,714
EPA Emission factors: 0.43 metric tons CO2e/bbl, and 0.0551 metric tons CO2e/mcf. (EPA 2019)
Production data obtained from the Utah Division of Oil Gas and Mining (UDOGM 2018).
Estimated GHG emissions from drilling, operation, maintenance, and reclamation of foreseeable oil and
gas wells are presented in Table 37. Foreseeable development includes approved APDs (Federal and non-
federal) as reported by the Utah Division of Oil, Gas, and Mining (UDOGM 2018). Since APDs are valid
for a 2 year period, this analysis only includes APDs from 2017 through 2019. Wells that have been
drilled to completion from the APDs are included in the existing emissions.
281
August 2019
Table 37. Estimated Annual Direct GHG Emissions from Development of APDs
Drilling Operations
APDs Total
Drilling Operatio Total
Field (Federal
CO2e/yr n CO2e/yr Metric Metric
Office and non-
per well per well Tons Tons
federal)
CO2e/yr CO2e/yr
Moab 2,362 1,539 10 54,334 35,386

Monticello 2,362 1,539 13 80,319 52,309
Price 678 428 3 40,708 25,663
Richfield 943 2,025 6 49,973 107,305
Vernal 678 428 486 1,135,750 715,987
State Total 520 1,404,457 1,029,781
Federal Land Fossil Fuel GHG Emissions

Data from the USGS report on Federal Land fossil fuel emissions is presented in Table 38 (Gross
Emissions) and Table 39 (Net Emissions) (USGS 2018). Data is presented for Utah and adjacent states.
Figure 22, shows the gross emissions for Utah and the linear trend over the ten year period.
Table 38. Gross Fossil Fuel Emissions from Federal Lands (MMT CO2e)
State 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
Colorado 63.43 63.62 63.32 64.22 60.49 63.19 66.2 65.71 51.77 55.78
New
Mexico 91.4 89.48 84.36 78.94 78.65 73.74 72.44 78.18 80.68 91.63
Utah 51.52 52.92 45.36 49.77 42.74 37.71 42.12 51.57 49.06 46.75
Wyoming 775.1 798.9 836.4 908.9 858.6 875 855.4 779.4 730.6 744.2
Nationally 1422 1438.8 1458.5 1490.2 1482.6 1489.3 1424.3 1338.2 1264.7 1332.1
282
August 2019
Table 39. Net (Gross Emissions - Carbon Storage) Fossil Fuel Emissions from Federal Lands
(MMT CO2e)
State 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
Colorado 29.3 34.4 32.8 52.8 37.1 52.1 43.2 68.7 30.7 12.1
New Mexico 68 66.6 67.6 63.3 71 58.7 72.5 79.7 63.5 68.6
Utah 4.8 37.1 50.7 55 31.6 28.5 14.4 55.3 38.8 25.2
Wyoming 736 789.6 818.2 871 814.9 836.3 824.2 783.3 708.2 701.5
Nationally 668.9 1130.6 1239.9 1151.4 912 821 918.6 1098.8 808.7 759
Utah Federal GHG Emission Trends

60
50
40 y = -0.4053x + 49.181
30
20
10
0
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
Figure 22. Utah Federal fossil fuel GHG emissions (MMT CO2e) and trend for the period of 2005-
2014.
283
August 2019
Appendix F – Acronyms/Abbreviations
AO Authorized Officer NESHAP National Emission Standards For
Hazardous Air Pollutants
APD Application for Permit to Drill NHPA National Historic Preservation Act
ARMPA Approved Resource Management NRHP National Register of Historic Places
Plan Amendments
BCR Bird Conservation Region NSO No Surface Occupancy
BLM Bureau of Land Management O.O. Onshore Oil and Gas Order
BMP Best Management Practice PLPCO Public Lands Policy Coordinating Office
CAA Clean Air Act PARFDS GRSG Population Area Reasonably
Foreseeable Development Scenario
CFR Code of Federal Regulations PFO Price Field Office
CIAA Cumulative Impact Analysis Area RFDS Reasonably Foreseeable Development
Scenario
COA Condition of Approval RFO Richfield Field Office
CWCS Comprehensive Wildlife RMP Resource Management Plan
Conservation Strategy
DR Decision Record ROD Record of Decision
EA Environmental Assessment ROW Right of Way
EAR Environmental Analysis Record S Stipulation
EIS Environmental Impact Statement SHPO State Historic Preservation Office
EOI Expression of Interest SITLA State Institutional Trust Lands
Administration
EPA Environmental Protection Agency UDAQ Utah Division of Air Quality
ESA Endangered Species Act UDWR Utah Division of Wildlife Resources
FFO Fillmore Field Office USFS United States Forest Service
FLPMA Federal Land Policy and USFWS United States Fish & Wildlife Service
Management Act
FONSI Finding of No Significant Impact UT Utah
GIS Geographical information System UTSO Utah State Office
GWP Global Warming Potential VFO Vernal Field Office
H Handbook WA Wilderness Area
IDPRT Interdisciplinary Parcel Review WO Washington Office
Team
IM Instruction Memorandum
LLCWA Lower Last Chance Wilderness Area
LN Lease Notice
MbFO Moab Field Office
MtFO Monticello Field Office
MBTA Migratory Bird Treaty Act
284
August 2019
Appendix G – Reasonable Foreseeable Development of Leases Scenario

Development of the parcels under the Proposed Action can be conceived of in three phases and their
associated activities: Implementation phase (pad construction, drilling of the well using a conventional pit
system or closed-loop system, hydraulically fracturing the well, development of any needed access roads,
or expansion of existing roads, installation of pipeline), production phase (vehicle traffic, engines to pump
oil if necessary, compressor engines to move gas through a pipeline, venting from storage tanks, hauling
produced fluids, regularly monitoring the well, and completing work-over tasks throughout the life of the
well if and when necessary), plug and reclamation phase (plugging the well, reclaiming the well pad and
other associated disturbances to include access roads and pipelines).
Standard terms, conditions, and stipulations listed would apply as appropriate to each lease. In addition,
site specific mitigation measures and best management practices (BMPs) would be attached as Conditions
of Approval (COAs) for each proposed exploration and development activity authorized on a lease.
Additional site-specific impacts would be addressed in a subsequent NEPA document at the Application
for Permit to Drill (APD) stage. Drilling of wells on a lease would not be permitted until the lease owner
or operator secures approval of a drilling permit and a surface use plan of operations as specified under
Onshore Oil and Gas Orders (43 CFR 3162), nor until site-specific NEPA analysis is conducted.
Oil and gas leases are issued for a 10-year period and continue for as long thereafter as oil or gas is
produced in paying quantities. However, it should be noted that if a leaseholder fails to produce oil and
gas, does not make annual rental payments, does not comply with the terms and conditions of the lease, or
relinquishes the lease, the lease defaults back to the Federal Government and the lease can be re-offered
in another lease sale.
Well Pad and Road Construction

Where the surface is not federally owned, the operator is required to obtain a Surface Access Agreement.
Surface Access Agreement is addressed in Onshore Oil and Gas Order No. 1 (O.O. #1.III.D.4).
Equipment for well pad construction could consist of dozers, scrapers, excavators and graders.
Disturbance for each well pad could range from 1.0 acre up to 6.8 acres depending on numerous factors
such as depth and type of well (vertical, directional, horizontal). All available topsoil from each well pad
would be stripped and stockpiled around the edge of the pad for future reclamation. When needed, topsoil
would be spread over interim reclamation areas, seeded, left in place for the life of the well, and the
remaining topsoil would be used during the final reclamation process. All well pads would be reclaimed.
During interim and/or final reclamation, disturbed land would be seeded with a mixture (certified weed
free) and rate as required by the BLM.
Depending on the locations of the proposed wells, some new or upgraded access roads are anticipated to
be required to access well pads and maintain production facilities. Any new roads constructed for the
purposes of oil and gas development would be utilized year-round for maintenance of the proposed wells
and other facilities, and for the transportation of fluids and/or equipment, and would remain open to other
land users. Construction of new roads or upgrades to existing roads would require a 30-foot construction
width and would be constructed of native material. After completion of road construction activities, the
30-foot construction width would be reclaimed to an 18-foot wide crowned running surface as well as
drainage ditches. The location of the wells would not be known until the APD stage.
Well Drilling and Completion Operations
A drilling rig would be transported to the well pad (along with other necessary equipment). Drilling
would commence with well spud. Typical drilling operations would include: adding joints of drill pipe at
the surface as the hole deepens; circulating drilling fluids to cool the drill bit and remove the drill
285
August 2019
cuttings; pulling the drill pipe from the hole to replace worn drill bits; and setting strings of casing and
cementing them in place. Air and/or water-based drilling fluid may be used to drill the hole. Prior to
setting the production casing, open-hole well logs may be run to identify potentially productive horizons.
If the evaluation concludes that sufficient natural gas and/or oil are present and recoverable, steel
production casing would be installed and cemented in place. Drilling activities on a well would typically
occur 24 hours per day, seven days per week, and would require approximately 20 workers. Depending
on the depth and complexity of the well, drilling could last from a few days to one week.
Once a well has been drilled and evaluated to have sufficient oil and/or natural gas, completion operations
would begin. Well completion involves perforating the production casing in target zones, followed by
hydraulic fracturing (also known as, fracking) of the formation (see below for more information on
hydraulic fracturing). The next phase of completion would be to flow and test the well to determine rates
of production.
Typical equipment and vehicles used during completion activities might include carbon dioxide tanker
trucks; sand transport trucks; water trucks; oil service trucks used to transport pumps and equipment for
fracking; flat beds and gin trucks to move water tanks, rigs, tubing, and fracking chemicals; logging
trucks (cased hole wireline trucks); pickup trucks to haul personnel and miscellaneous small materials;
and workover rigs.
Completion activities on individual wells may occur 24 hours per day, seven days per week, and would
require approximately 20 to 40 workers. Completion of an individual well could take from 7 to 30 days,
depending on the number of completion zones.
Hydraulic Fracturing
Hydraulic fracturing (also known as fracking) is a well stimulation technique used to increase oil and gas
production from underground rock formations. Fracking would also be evaluated at the APD stage should
the lease parcel be sold/issued and a development proposal submitted. The following paragraphs provide
a general discussion of the fracking process that could potentially be implemented if development were to
occur, including well construction information and general conditions encountered.
Fracking involves the injection of fluids through a wellbore under pressures great enough to fracture the
oil and gas producing formations. The fluid is generally comprised of a liquid such as oil, carbon-dioxide
or nitrogen, and proppant (commonly sand or ceramic beads), and a minor percentage of chemicals to
give the fluid desirable flow characteristics, corrosion inhibition, etc. The proppant holds open the newly
created fractures after the injection pressure is released. Oil and gas flow through the fractures and up the
production well to the surface.
Fracking has been used by oil and natural gas producers since the late 1940s and for the first 50 years was
mostly used in vertical wells in conventional formations. Fracking is still used in these settings, but the
process has evolved. Technological developments (including horizontal drilling) have led to the use of
fracking in unconventional hydrocarbon formations that could not otherwise be profitably produced.
The use of horizontal drilling through unconventional reservoirs combined with high-volume water based
multi-stage fracking activities has led to an increase in oil and gas activity in several areas of the country
which has, in turn, resulted in a dramatic increase in domestic oil and gas production nationally. However,
along with the production increase, fracking activities are suspected of causing contamination of fresh
water by creating fluid communication between oil and gas reservoirs and aquifers. The Environmental
Protection Agency (EPA) recently conducted an assessment of fracking on drinking water resources
(https://www.epa.gov/hfstudy) [EPA 2016]. Presently, there are no unconventional reservoirs that are
being exploited using high-volume water based hydraulic fracturing techniques.
286
August 2019
Production Operations
If wells were to go into production, facilities would be located at the well pad and typically include a well
head, two storage tanks, a truck load-out, separator, and dehydrator. Construction of the production
facility would be located on the well pad and not result in any additional surface disturbance.
All permanent surface structures would be painted a flat, non-reflective color (e.g., covert green) specified
by the BLM in order to blend with the colors of the surrounding natural environment. Facilities that are
required to comply with the Occupational Safety and Health Act (OSHA) would be excluded from
painting color requirements. All surface facilities would be painted immediately after installation and
under the direction and approval of the BLM.
If oil is produced, the oil would be stored on location in tanks and transported by truck to a refinery. The
volume of tanker truck traffic for oil production would be dependent upon production of the wells.
If natural gas is produced, construction of a gas sales pipeline would be necessary to transport the gas. An
additional Sundry Notice, right of way (ROW) and NEPA analysis would be completed, as needed, for
any pipelines and/or other production facilities proposed across public lands. BLM Best Management
Practices (BMPs), such as burying the pipeline and/or installing the pipeline within the road, would be
considered at the time of the proposal.
All operations would be conducted following the “Gold Book”, Surface Operating Standards for Oil and
Gas Exploration and Development (United States Department of the Interior and United States
Department of Agriculture 2007). The Gold Book was developed to assist operators by providing
information on the requirements for conducting environmentally responsible oil and gas operations on
federal lands. The Gold Book provides operators with a combination of guidance and standards for
ensuring compliance with agency policies and operating requirements, such as those found at 43 CFR
3000 and 36 CFR 228 Subpart E; Onshore Oil and Gas Orders (Onshore Orders); and Notices to Lessees.
The Gold Book includes environmental BMPs designed to provide for safe and efficient operations while
minimizing undesirable impacts to the environment.
Exploration and development on split-estate lands are also addressed in the Gold Book, along with IM
2003-131, Permitting Oil and Gas on Split-Estate Lands and Guidance for Onshore Oil and Gas Order
No. 1, and IM 2007-165, Split-Estate Report to Congress – Implementation of Fluid Mineral Leasing and
Land Use Planning Recommendations. Proper planning and consultation, along with the proactive
incorporation of these BMPs into the APD Surface Use Plan of Operations by the operator, would
typically result in a more efficient APD and environmental review process, increased operating
efficiency, reduced long-term operating costs, reduced final reclamation needs, and less impact to the
environment.
Produced Water Handling
Water is often associated with either produced oil or natural gas. Water is separated out of the production
stream and can be temporarily stored in the reserve pit for 90 days. Permanent disposal options include
discharge to evaporation pits or underground injection for enhanced recovery. Handling of produced
water is addressed in Onshore Oil and Gas Order No. 7.
Most injection wells do not cause earthquakes. In the United States, there is approximately 35,000 active
waste-water disposal wells, 80,000 active enhanced oil-recovery wells, and tens of thousands of wells,
and tens of thousands of wells are hydraulically fractured every year in the United States. The earthquake
rate increased in Oklahoma, southern Kansas, central Arkansas, and multiple parts of Texas (Rubinstein
2015). In Utah, the volumes are lower than those states experiencing induced seismicity. Also, the
geology is different than those states experiencing induced seismicity. The injection zones are
stratigraphically thousands of feet above the basement rock that may contain large unknown faults.
287
August 2019
Therefore, at this time it appears that induced seismicity from water injection is not a problem in the oil
fields of Utah (BLM 2018).
Maintenance Operations
Traffic volumes during production would be dependent upon whether the wells produced natural gas
and/or oil, and for the latter, the volume of oil produced. Well maintenance operations may include
periodic use of work-over rigs and heavy trucks for hauling equipment to the producing well, and would
include inspections of the well by a pumper on a regular basis or by remote sensing. The road and the
well pad would be maintained for reasonable access and working conditions. Portions of the well pad not
needed for production of the proposed well, including the reserve pit, would be re-contoured and
reclaimed, as an interim reclamation of the site.
Plugging and Abandonment
If the wells do not produce economic quantities of oil or gas, or when it is no longer commercially
productive, the well would be plugged and abandoned. The wells would be plugged and abandoned
following procedures approved by a BLM Petroleum Engineer, which would include requiring cement
plugs at strategic positions in the well bore. All fluids in the reserve pit would be allowed to dry prior to
reclamation work. After fluids have evaporated from the reserve pit, sub-soil would be backfilled and
compacted within 90 days. If the fluids within the reserve pit have not evaporated within 90 days (weather
permitting or within one evaporation cycle, i.e. one summer), the fluid would be pumped from the pit and
disposed of in accordance with applicable regulations. The well pad would be re-contoured, and topsoil
would be replaced, scarified, and seeded within 180 days of the plugging the well.
288
August 2019
Appendix H – Comments and Responses [Reserved]

As defined in the NEPA Handbook (page 40), “an ‘issue’ is a point of disagreement, debate, or dispute with a proposed action based on some anticipated environmental effect. An issue is more than just a position statement, such as disagreement
with grazing on public lands. An issue:
• Has a cause and effect relationship with the proposed action or alternatives;
• Is within the scope of the analysis;
• Has not been decided by law, regulation, or previous decision; and
• Is amenable to scientific analysis rather than conjecture.”
Comments that express a professional disagreement with the conclusions of the analysis or assert that the analysis is inadequate may or may not lead to changes in the EA. Substantive comments and non-substantive comments are defined in the
NEPA Handbook, H-1790-1, and section 6.9.2. The BLM National Environmental Handbook (H-1790-1) states that substantive comments do one or more of the following:
• Question, with reasonable basis the accuracy of information in the EIA or EA
• Question, with reasonable basis, the adequacy of methodology for, or assumptions used for the environmental analysis
• Present new information relevant to the analysis
• Present reasonable alternatives other than those analyzed in the EIS or EA
• Cause changes or revisions in one or more of the alternatives.
Comments that are not substantive or comments received after the close of the public comment period may not receive a response.
All comments received will be posted on ePlanning.
Commenter Comment Response
289

BLM Environmental Assessment

Загружено:

Сведения о документе

Авторское право

Доступные форматы

Поделиться этим документом

Поделиться или встроить документ

Параметры публикации

Этот документ был вам полезен?

Это неприемлемый материал?

Авторское право:

Доступные форматы

BLM Environmental Assessment

Загружено:

Авторское право:

Доступные форматы

U.S.

Department of the Interior

December 2019 Competitive Oil and Gas Lease Sale

Utah State Office

Chapter 1 Purpose & Need

1.1 Project Location and Legal Description

002 RFO Sevier 024 MbFO Grand

003 RFO Sevier 025 MbFO Grand

004 RFO Sanpete 026 VFO Uintah

005 RFO Sanpete 027 MtFO San Juan

006 RFO Sanpete 028 MtFO San Juan

007 RFO Sanpete 029 MtFO San Juan

008 RFO Sanpete 030 MtFO San Juan

009 PFO Emery 031 MtFO San Juan

010 PFO Emery 032 MtFO San Juan

014 PFO Carbon 033 MtFO San Juan

017 PFO Carbon 034 MtFO San Juan

022 PFO Carbon 035 MtFO San Juan

1.6 Plan Conformance Review

Policies/Instruction Memoranda (IM) 7

State of Utah Plans/Rules

BLM Activity Plans/Strategies/Practices

BLM Land Use Plans

Monticello RMP, October 2008, as amended

Moab Master Leasing Plan and RMP, December 2016, as maintained

Color Country District

Green River District

Utah Greater Sage Grouse

1.7 Relationship to Statutes, Regulations, Policies or Other Plans

Issue Issue Statement Impact Indicator

UT-LN-128— Floodplains Management mandates avoiding adverse impacts to floodplains.

1.10 Public Comment Period

Chapter 2 Description of Alternatives

Moab 2 393.39 1 well 10 acres

Monticello 9 5,536.26 1 well 10 acres

Richfield 7 3,914.82 14 wells 30 acres

Price 5 3,267.11 5 wells 41 acres

Vernal 1 310.62 1 well 5 acres

Total 24 13,422.20 22 wells 96.0 acres

Canyon Country District

Color Country District

Green River District

2.3 Alternative A – Proposed Action

Chapter 3 Affected Environment

3.2 General Setting

Table 5. Leasing Category Acreages for Moab Field Office.

234,814 93,381 40% 4,368 0 0%

1,776,5123 530,580 30% 23,515 395 <1%

Table 6. Leasing Category Acreages for Monticello Field Office.

432,296 99,051 23% 27,896 4,779 1%

Moderate Stipulations (CSU and 586,736 92,143 16% 2,004 33,578 5%

1,101,2483 243,736 22% 29,900 38,905 4%

Table 7. Leasing Category Acreages for Richfield Field Office.

608,741 56,213 9% 9,483 29 <1%

Moderate Stipulations (CSU and 715,798 38,112 5% 34,282 2,577 <1%

NA 41,727 NA 12,674 1,288 NA

1,876,1593 186,003 10% 56,452 3,900 <1%

Green River District

Table 8. Leasing Category Acreages for Price Field Office

Standard Stipulations (Open) 1,146,083 290,447 25% 0 2,956 <1%

Moderate Stipulations (CSU and

Major Stipulations (NSO) 460,116 34,442 8% 35 <1%

No Leasing Decision Category NA 58,844 NA 2,561 0 0

Closed2 577,216 6,426 NA 0 0 0