At first glance the Mesa southwest of Pinedale, Wyoming, is wide and empty. Perched in the sky at 7,600 feet, this table of land is an island floating between the distant Wyoming and Wind River mountain ranges. Not a single tree grows on 300 square miles of sagebrush and yellowed grass.

A drive along one of the myriad gravel roads reveals this place is not as empty as the lonesome wind makes it feel. Two of Wyoming’s most important resources—natural gas and big game—are hiding out here among the swales and slopes. Pronghorn pick their way between towering drill rigs and mule deer bound away from passing tanker trucks.

The geologic name for the Mesa is the Pinedale Anticline.  In 2008 a new Record of Decision for natural gas development in the Pinedale Anticline called for “Concentrated Phased Development.” Concentrated Phased Development sets up an experiment in which leases are suspended for five years on the margins of the gas field while development focuses in small patches in the center.  The plan hypothesizes that wildlife will find refuge in undisturbed and reclaimed areas while development proceeds year round in small dense patches.

“This managed development leaves large contiguous blocks of habitat available to big game and sage grouse and can help conserve migration corridors,” states a flyer published by three of the natural gas development companies.

At the heart of this new plan is the Wildlife Monitoring and Mitigation Matrix, which tests the hypothesis by examining how wildlife actually responds to the development.  The Matrix specifies how monitoring will proceed for mule deer, pronghorn, sage-grouse, and sensitive species—white-tailed prairie dogs and pygmy rabbits—and defines the levels of population decline that will trigger mitigation measures.

Under the Bureau of Land Management’s 2008 Record of Decision for the gas field, operators—as natural gas companies including Shell, QEP Energy, and Ultra Petroleum are known—were directed to help create the wildlife monitoring protocol.

For example, according to the Record of Decision, “Specific monitoring requirements for wildlife will be developed by the Wyoming Game and Fish Department, in cooperation with the operators and their contractors.”

Some critics contend the industry role in the process is too large.

“It is an outright conflict of interest for industry—who may have much to lose or gain by the implementation of the monitoring—to be part of this,” Stephanie Kessler, Wyoming Program Manager for the Wilderness Society, wrote to the Bureau of Land Management (or BLM) Pinedale Field Office in spring of 2009. “Stepping over this line will be like letting the fox guard the henhouse.”

Despite this criticism, in 2009 BLM allowed operators to help write not only the monitoring protocol, but also Requests for Proposals from contractors.  Operators also helped select contractors.

Industry spokesperson Darci Sinclair, representing major operators Shell, Ultra and QEP Energy(formerly Questar), said the companies have conformed strictly to Bureau of Land Management guidelines in all their dealings. “Our involvement to date is based on provisions in the [Record of Decision],” Sinclair said in an e-mail.

In addition, Sinclair noted, Shell, QEP and Ultra have voluntarily contributed millions of dollars to the Pinedale Monitoring and Mitigation fund “to provide certainty that financial support would be available in the future for monitoring and mitigating potential impacts directly related to our development activities in the Pinedale Anticline Project Areas.” Sinclair said the total contribution to the fund from the three companies is expected to reach $36 million for the duration of the development.

In response to continuing complaints from conservation groups, this winter the BLM revised the contracting process to reduce industry involvement.

Meanwhile, the Wilderness Society, joined by other Wyoming conservation groups, requested an independent review of the monitoring protocol that the operators helped write. Nationally recognized top-level biologists and statisticians with expertise for each of the designated species conducted the reviews, the last of which were recently posted to the Pinedale Anticline Project Office website.

The reviewers determined that wildlife-monitoring requirements outlined in the Wildlife Monitoring and Mitigation Matrix and co-authored by the natural gas operators are scientifically unsound and could never detect the levels of decline that would trigger protection measures under the management plan.

“It’s not really a review, it’s actually a critique of the monitoring protocol,” Game and Fish Director John Emmerich told WyoFile regarding these independent reports of monitoring protocol.  The Wyoming Game and Fish Department, which oversees the new contracting process, is reviewing the reviews of the monitoring protocol and will organize a public meeting later this summer to share their response, hear public input, and make any necessary changes to the monitoring protocol, which would go into effect next year.

Today 1,500 natural gas wells pierce the Pinedale Anticline and hundreds of miles of road lattice its surface.  An earlier industry-funded study of mule deer in the Anticline showed a 30% decline from 2001 to 2007. And the Mesa can expect only further industrialization. Less than a tenth of recoverable gas reserves in the Pinedale Anticline have been extracted so far. Drilling is scheduled to continue through the year 2025, with production continuing until 2065. A total of 4,399 wells are allowed under the current management plan.

As managers sort out contracting processes and monitoring protocol, some of America’s most spectacular wildlife populations still await protection in their home ranges.

Adaptive management in the Pinedale Anticline Project Area

A decade ago Wyoming was poised to lead the United States into a new era of environmental planning for oil and gas development projects with the 2000 Environmental Impact Statement Record of Decision for the Pinedale Anticline.

“The Pinedale Anticline Project was the BLM’s first attempt to use adaptive management to extract oil or gas. The project was intended to showcase adaptive management and its potential to mitigate environmental concerns while facilitating development,” writes Melinda Harm Benson in her review of what has happened on the Mesa, a paper titled “Integrating Adaptive Management and Oil and Gas Development,” published in October of 2009. A professor of geography at the University of New Mexico, Benson has worked as a lobbyist and attorney for several western conservation groups, and as a lecturer and research scientist at the Haub School and Ruckleshaus Institute of Environment and Natural Resources at the University of Wyoming.

“Adaptive management represents a breakthrough in the complexity of our thinking about natural resource challenges,” she writes.

The theory behind adaptive management is, rather than making a set plan that relies on assumptions, to collect information as development proceeds and apply that new knowledge by modifying operations as needed.  Adaptive management uses a cyclical process—monitor for changes, analyze monitoring data, recommend and enact mitigation, monitor for changes, and so on—in which new information is constantly being gathered. Such a process is more responsive to real-world situations and allows for more flexibility than simply following a prescribed plan.

In 2000, many people concerned with gas development on the Mesa, from operators to environmental groups to long-time area residents, attended hearings to make sure the BLM hammered out a management plan they found acceptable. Most people welcomed adaptive management as the best scientific approach to allow gas development with the least possible environmental damage.

For wildlife, adaptive management would mean monitoring how permitted gas development affects populations and habitat use, and enacting mitigation if wildlife appeared to be in trouble. No one could predict how mule deer or sage-grouse would respond to an influx of drill rigs and traffic, and adaptive management provided a way for the BLM to gather information as development proceeded and adjust accordingly.

In 2000, the Environmental Impact Statement Record of Decision for the Pinedale Anticline allowed development of up to 700 producing wells from as many as 900 wellheads (assuming that some wells would not strike gas). It also specified seasonal restrictions.  For example, crucial wintering areas for pronghorn and mule deer would be closed to surface activity from November 15 to April 30 and sage-grouse and raptor breeding and nesting grounds would be closed February 1 through July 31.

A group of stakeholders including representatives from the public, environmental organizations, Wyoming Game and Fish Department, BLM, natural gas operators, and others was assembled. This stakeholder group, called the Pinedale Anticline Working Group, was assigned, among other things, to oversee wildlife monitoring, analyze data, and recommend mitigation measures should they be needed.

The federal Environmental Protection Agency awarded the BLM’s draft Environmental Impact Statement for the Pinedale Anticline the highest rating ever given to an oil and gas project due to the innovative use of adaptive management as a way to manage real-world uncertainty in environmental problems.

However, as Benson writes, “From an adaptive management perspective, the project has been unsuccessful. The stakeholder group designed to implement the process fell apart, wildlife populations in the area are in significant decline, and oil and gas extraction is escalating, despite increasing concerns over wildlife and air quality.”

Right after publication of the innovative Record of Decision, Yates Petroleum, one of the operators in the Pinedale Anticline gas field, sued the stakeholder group for not registering under the Federal Advisory Committee Act. Immediately, the stakeholder group was tied up in litigation lasting four years. From 2000 to 2004, no adaptive management took place because the stakeholder group did not exist. Yet development continued and hundreds of wells were drilled without any monitoring or mitigation.

Finally in 2004 a federal judge dismissed the suit and the stakeholder group had to start at square one, doing what they could to catch up to continuing development on the Anticline with limited data about responses from wildlife.

Revisions to the Pinedale Anticline management plan

Two other important changes occurred during the early 2000s. The 2000 development plan only accounted for vertical wells from individual surface locations, but directional drilling—a method that allows operators to drill several wells from a single surface location—came into widespread use in the Pinedale Anticline gas field.

Second, geologic exploration led to the discovery that gas reserves had been severely underestimated. In 2000, allowance for 700 producing wells seemed radical, but by 2004 it was clear this would not be anywhere near enough to extract the natural gas reserves of the area.

Eventually these changes led to the need for a new Environmental Impact Statement that would update the document published in 2000. Industry representatives worked closely with the State of Wyoming to help the BLM craft a revised document. The Wyoming Game and Fish Department, environmental groups, and the public were involved to a lesser extent. In 2008 a new Record of Decision was published.

The new plan eliminated seasonal restrictions in big game and sage-grouse habitat in favor of Concentrated Phased Development, which would occur year round.  It also required pipelines that would transport gas, water, and condensates from the wellheads, a process that is predicted to reduce truck traffic in the gas field by up to 165,000 truck trips per year.  The new plan allows for 4,399 producing wells—a more than six-fold increase from the 2000 plan—to be drilled from only 600 surface locations, down from 900 in the original plan.

Under the new plan, once an area has been drilled, pipelines transport the natural gas, the drills are removed, and the surrounding area is reclaimed. Then drilling activity moves to a new location. Concentrated Phased Development means more natural gas can be extracted and transported quickly with reduced surface disturbance.

In the management plan of 2008, leases are suspended on the flanks of the project area and Concentrated Phased Development happens in the central core for the first five years. Suspending drilling in the flanks is meant to give wildlife space to live while development happens year-round. After five years, suspended leases will be reopened once “a comparable acreage in the core area (not needed for production operations) has been returned to functioning habitat,” according to the Record of Decision.

To determine whether habitat is functioning for wildlife, the document includes the Wildlife Monitoring and Mitigation Matrix, stipulating changes in wildlife populations that will trigger mitigation measures for several wildlife species. This chart describes the monitoring that is supposed to protect wildlife from unintended negative consequences of natural gas extraction.

Concentrated Phased Development is an experiment in wildlife management. It is based on the hypothesis that mule deer, sage-grouse, and other species will move to areas protected from year-round drilling activity and return to reclaimed areas once drilling is complete. Adaptive management is at the foundation of the process. Thorough and accurate wildlife monitoring is crucial to test the Concentrated Phased Development hypothesis and trigger mitigation if the wildlife doesn’t respond as predicted.

Putting the plan into action: Industry involvement

The Wildlife Monitoring and Mitigation Matrix specifies thresholds for population or habitat declines at which point mitigation measures will be enacted to further protect mule deer, antelope, sage grouse, pygmy rabbits and white-tailed prairie dogs.

For example, according to the Matrix, if the number of active sage-grouse leks declines by 30% or if the number of pronghorn declines by 15%, mitigation steps are implemented one after another as needed in the following order:

1)    habitat enhancement and protection within the Pinedale Anticline Project Area,

2)    conservation easements or property rights acquisitions elsewhere in the region,

3)    and finally “modification of operations.”

QEP Energy, Shell, and Ultra Petroleum contribute $7,500 per wellhead each year to a monitoring and mitigation fund. The staff and board of the Pinedale Anticline Project Office then distribute this fund though monitoring contracts and mitigation projects.

A chain of documents has grown from this Matrix including a Wildlife Monitoring and Mitigation Plan, Requests for Proposals for wildlife monitoring contracts, and a third-part independent review of all of these documents.

In April 2009, to meet the requirement outlined in the Matrix and Record of Decision, the BLM, the Wyoming Game and Fish Department, and the Pinedale operators wrote a Wildlife Monitoring and Mitigation Plan.  This document was posted to the BLM and Pinedale Anticline Project Office websites, but the Acting Director of the Project Office does not know when it was posted.  Kessler of the Wilderness Society did not find the Wildlife Monitoring and Mitigation Plan until months after it was written. Environmental groups, local residents, and representatives of other interests were left out of the creation of the wildlife monitoring system while operators were involved.

According to the Wildlife Monitoring and Mitigation Plan, co-authored by industry representatives, the operators were to also help write wildlife monitoring Requests for Proposals, to select contractors, and even to oversee reviews of wildlife monitoring reports.

In spring and early summer of 2009, following the behind-closed-doors creation of the Wildlife Monitoring and Mitigation Plan, Requests for Proposals were issued for contracts to monitor white-tailed prairie dogs, pygmy rabbits, pronghorn, and mule deer. The wildlife monitoring Requests for Proposals were sent out by email rather than posted through a government-wide Internet portal as required by law for contracts over $25,000, which these were.

Sage-grouse and raptor monitoring Requests for Proposals had been sent out before the Wildlife Monitoring and Mitigation Plan was written. The sage-grouse contract was highlighted as part of the conservation groups’ protest.

“The award of the sage-grouse contract to K.C. Harvey Soil & Water Resource Consulting, purportedly the only bidder (among six that submitted bids) which had no prior experience capturing and banding sage-grouse, raises obvious and legitimate questions whether the contract was awarded to a qualified, leave alone the most qualified, applicant,” wrote Dan Heilig of Western Resource Advocates in an October 2009 letter signed by six other conservation groups to the Pinedale BLM Field Office. “The fact that Pinedale operators had a say in the selection of wildlife contractors only adds to our concerns.”

K.C. Harvey Soil & Water Resource Consulting specializes in managing soil and water resources associated with oil and gas development, and is a subsidiary of EnerCrest, an oilfield services company. When asked about the sage-grouse monitoring, K.C. Harvey told WyoFile, “We’re no longer doing it.  They changed the whole program and aren’t monitoring right now. I don’t feel authorized to comment on that.”

“To put it bluntly, it appeared to us that the oil and gas industry was attempting to influence wildlife science in order to achieve the most desirable results,” conservation groups continued in the same 2009 letter. Among the signatory groups were Western Resource Advocates, Audubon Wyoming, the Greater Yellowstone Coalition, Trout Unlimited, the Wilderness Society, the Upper Green River Valley Coalition, and the Wyoming Outdoor Council.

“It is important to recognize that the matrix is the underpinning for wildlife monitoring and mitigation on the Pinedale Anticline,”  industry spokesperson Sinclair wrote WyoFile in an email. “We strongly support the matrix as a tool to aggressively monitor for emerging wildlife population and habitat trends.”

As of this winter the Pinedale Anticline Project Office transferred the job of writing monitoring protocol and the hiring of monitoring firms exclusively to the hands of the Wyoming Game and Fish Department. Industry has been relegated to joining conservation groups and the public in simply reviewing proposed contract requirements when the Game and Fish seeks bids from monitoring firms.

The monitoring requirements and their flaws

A concerned scientist who bid for one of the contracts noticed flaws in the scientific design of the monitoring and contacted the Wilderness Society, who pressured Game and Fish to conduct a review of the monitoring protocol.  Last summer the Wyoming Game and Fish Department agreed to pursue a third-party review of the Requests for Proposals. The Pinedale Anticline Project Office funded this review, which was overseen by the Wyoming Cooperative Fish and Wildlife Research Unit at the University of Wyoming.

The Wyoming Cooperative Unit is a collaboration between five different wildlife research organizations: the U.S. Fish and Wildlife Service, the Wyoming Game and Fish Department, the Wildlife Management Institute, U.S. Geologic Survey, which oversees the program, and the University of Wyoming where the program is housed.  Under the Wyoming Cooperative Unit, these entities conduct research to inform agency management decisions.

During the winter of 2010, the Cooperative Unit employed independent, expert biologists and statisticians from around the West to review the wildlife monitoring protocol. The reviews asked the following questions:

  • Are the experimental designs and methods for monitoring described in the Monitoring Plans adequate to detect changes in the criteria identified by the Matrix within a reasonable timeframe?
  • If changes in an identified criteria (i.e., change in pronghorn survival) do occur in response to energy development on the Pinedale Anticline Project Area, how likely are the monitoring methods described to detect this change and identify when stated thresholds have been met or surpassed?

The results of all four of the reviews have been consistent “no” answers to the above questions. For example, for pygmy rabbits, “the monitoring plan does not permit an estimate of density of burrows or of abundance of pygmy rabbits. So, the criterion of a 15% decline in individuals over three years cannot be evaluated using the methods proposed.”

Or for sage grouse, “the change requiring mitigation does not have a temporal component. Is the 30% decline calculated on a per year basis or is it cumulative over several years? If the change is calculated over a single year then conceivably 29% of leks could be lost each year until no leks were left and mitigation would never be invoked.”

For pronghorn, “Sample sizes for estimating individual survival rates are too low,” and “Survival rates of individual males are not part of the study, but should be.”  Furthermore, the study, “treats a 15% annual decline and a 15% cumulative decline in the same manner.  Obviously, these could imply very different population dynamics.  Annual decline of 15% will cut a population in half in four years.”

The experts determined that wildlife-monitoring requirements co-authored by the natural gas operators are scientifically unsound. Levels of decline enough to trigger mitigation under the management plan are almost impossible to detect.

Meanwhile a previous and separate project to monitor mule deer on the Pinedale Anticline—the “Sublette Mule Deer Study” published in 2009 by Western Ecosystems Technology, Inc. and funded by QEP, Shell, Ultra, and the BLM—showed 30% declines in mule deer numbers from 2001-2007. Over this same time period mule deer declined only 10% throughout the whole Sublette herd unit spanning the surrounding Green River Basin.

Specifically, the abundance in the 2005 was 45% lower than abundance in 2001 when natural gas development ramped up on the Anticline (see table on page 5-7 of the report). From 2005 to 2007, mule deer increased slightly on the Anticline, but the Wildlife Monitoring and Mitigation Matrix specifies the low population from 2005 as the benchmark against which future changes will be assessed.

Changing the system

Wildlife conservation groups across Wyoming have attended meetings and written letters to BLM, Wyoming Game and Fish Department officials, and the Governor’s Office asking that operators be removed from the wildlife monitoring process and that the Wyoming Cooperative Unit reviews of the monitoring protocol be taken seriously.

These groups have requested that the BLM amend the Record of Decision for gas extraction in the Pinedale Anticline to remove operators from wildlife monitoring, stop accepting recommendations from the current wildlife teams which include operator representatives, revise the Wildlife Monitoring and Mitigation Plan to exclude operators, and limit operator access to any elements of the wildlife monitoring to the same that is afforded the public.

The BLM and Pinedale Anticline Project Office have responded by making the contracting process more transparent. This year the Requests for Proposals are available on their website for public comment, and the actual selection of contractors is handled by Wyoming Game and Fish rather than by Pinedale Anticline Project Office. Industry no longer has a special role in the process.

The Record of Decision, the directing document that outlines industry’s involvement, has not been revised. To change it, “You’d have to go through a whole new scoping process. I don’t know if that will or will not occur,” said Brian Davis, acting director of the BLM Pinedale Office in regards to amending the Record of Decision, in a phone interview with WyoFile.

“Right now we are just looking at the contracts, which is the biggest complaint. We’re addressing the contracting and working with the state of Wyoming. In the new process the Requests for Proposals will be out for public review. We’ll be following the protocol from the Wyoming Game and Fish Department.”

This summer the Wyoming Game and Fish Department will meet with BLM, operators, and the public including conservation groups to discuss the results of the Wyoming Cooperative Unit review of monitoring protocol. At the planned open meeting this summer, Game and Fish will lead the discussion toward any needed restructuring of wildlife monitoring protocol. Changes will go into the Requests for Proposals for next year.

“Wyoming Game and Fish in conjunction with BLM is reviewing those critiques,” Game and Fish Director John Emmerich told WyoFile in reference to the Wyoming Cooperative Unit reviews of species monitoring protocol. “For example, with sage-grouse, they misinterpreted what we’re doing. We’re actually counting every known lek within whole area. With mule deer we probably do need to make some adjustments and increase the study area.”

Shell, QEP, and Ultra Petroleum submitted comments about the sage-grouse and sensitive species reviews including expressions of concern about the increased costs of the monitoring changes suggested by the reviewers.

“It does not appear that the reviewers took into consideration that last summer was a baseline data collection year from which future information will be based on and further analysis collected,” the operators wrote in response to the Cooperative Unit review of sensitive species monitoring. “It also appears as though many of the recommendations are very costly.

Even if BLM and Game and Fish do increase the study areas and control areas for wildlife monitoring and include data that covers a longer time frame to make the monitoring more statistically accountable, the fund for such monitoring is already drawn down too low to pay for increased monitoring over the next 20 or more years.

According to a budget posted on the Pinedale Anticline Project Office website in April of this year, a third of the available fund for monitoring and mitigation has already been spent. Of the $36 million Wildlife Monitoring and Mitigation Fund set up in 2008 and meant to last for 25 years, almost $10 million is used up.  Some of that money has gone to off-site mitigation such as $6 million earmarked for an off-site conservation easement called the Sommers/Grindstone Conservation Project.

Industry contributors to the Wildlife Monitoring and Mitigation Fund stated in an email to WyoFile, “We (the Operators) are concerned that the Board has already committed funds for mitigation, however monitoring done to date has not deemed mitigation necessary. It must be noted that the fund is finite and was designed to pay for wildlife monitoring over the life of the project.”

If the demands of conservation groups and the suggestions outlined in the Wyoming Cooperative Unit reviews are met, correcting the monitoring protocol will be only a first step toward protecting wildlife.  The pronghorn, mule deer, sage-grouse, and other species in the Pinedale Anticline Project Area still await not only an honest assessment of the affects of natural gas development, but also a quick response to shelter them from habitat loss and population declines, especially during their crucial winter and breeding seasons.  Considering that decreases in sage-grouse and pronghorn can currently slip through the Wildlife Monitoring Matrix, another year or two of decision-making may be too late for these wild animals.

Emilene Ostlind

Emilene Ostlind is communications coordinator for the Haub School of Environment and Natural Resources at the University of Wyoming, and edits Western Confluence magazine, a publication of the UW Ruckelshaus...

Join the Conversation


Want to join the discussion? Fantastic, here are the ground rules: * Provide your full name — no pseudonyms. WyoFile stands behind everything we publish and expects commenters to do the same. * No personal attacks, profanity, discriminatory language or threats. Keep it clean, civil and on topic. *WyoFile does not fact check every comment but, when noticed, submissions containing clear misinformation, demonstrably false statements of fact or links to sites trafficking in such will not be posted. *Individual commenters are limited to three comments per story, including replies.

Your email address will not be published. Required fields are marked *

  1. These are the facts:

    1) BLM allowed operators to help write not only the monitoring protocol, but also Requests for Proposals from contractors. Operators also helped select contractors.

    2) …after publication of the innovative Record of Decision, Yates Petroleum, one of the operators in the Pinedale Anticline gas field, sued the stakeholder group for not registering under the Federal Advisory Committee Act. Immediately, the stakeholder group was tied up in litigation lasting four years.

    3) An earlier industry-funded study of mule deer in the Anticline showed a 30% decline from 2001 to 2007.

    Industry wrote the protocol, had significant input into the selection of contractors and conducted its own study that showed declines in wildlife. And they sued to delay the implementation process (to which they had agreed).

    Sounds to me like the fox is in the hen house. And one more point — whatever money industry is ‘contributing’ to process and implementation is derived from reserves that belong to the people of the United States. We should neither thank them nor apologize for that expenditure — its a cost of doing business.

  2. The simple truth that affixing collars to sage-grouse will in no way help to determine population declines (unless the mortalities are at the hands of the researcher) is the fundamental problem with the PAPOs route toward meeting many of the objectives of the matrix. Having spoken with the operators, they seem to feel the same. The real problem on the anticline is that the henhouse is being guarded by federal and state biologists that feel that they should spend the pool of money as quickly as they possibly can, hence a 6 million dollar easement that does nothing to enhance wildlife habitat, but rather lines the pockets of politically connected individuals

  3. All anyone has to do is visit the Lost Cabin / Lysite Gas Fields to see that all the hand wringing is for not. the exploration there has gone on for years and Deer and Antelope abound.
    The Hypocrisy of these Wildlife advocates is astounding ! Yellowstone is being Raped by the wolf and no one is saying a word. Mean while right of way fences block migration routes and imprison Deer and antelope in a patch work quilt of Barb wire thru out much of the Red Desert. None of these groups mention anything about that, because they don’t want to chance hitting one on the hiway but won’t push for a speed reduction at dusk and dawn in those areas where Wildlife cross .

  4. Kudos on this thorough, well-researched, and informative article. I think it provides a constructive “reality check” on the concept of using “adaptive management” in making federal land planning decisions. Accurate, objective, timely, and effective monitoring is essential to the practical success of this concept. Absent such monitoring, the concept and associated federal lands management decisions lose their credibility. BLM and other federal land management agencies often do not “walk their talk” in terms of adequately keeping promises in planning and environmental analysis documents. The Council on Environmental Quality (CEQ) recently acknowledged this chronic deficiency in their draft guidance on mitigation and monitoring. If these federal land management agencies want or need to use adaptive management going forward, the public should retain healthy skepticism until their track record substantially improves.

  5. By logger, 7-13-10

    The pinedale anticline is around 35,000 acres. Thats an area of about 10 miles by 6 miles. It’s a drop in the bucket-period. It’s so symptomatic of the micro world the enviros live in where logic and proportion don’t mean anything at all.

    The real question is not whether pygmy rabbits will survive while drilling rigs are pounding away a quarter mile away-the real question is whether they will survive once the field is developed. Have you ever seen a natural gas field? Unlike an oil field there is virtually no moving parts. There are many “mature” oil and gas fields nearby of similar habitat where comparisons could be made of “post development” wildlife populations. Why do I suspect that Antelope populations are the exact same as the adjacent undrilled areas?. I’m thinking the Big Piney labarge area. Has any of the enviro scientists ever considered examining those fields? Of course not. Lack of any such proposals only highlights the fact that they are biased. They don’t wanna know if wildlife populations return to background levels.

    Guess where most of the Gas is going? Ten years ago a couple of 46″ diameter pipelines were built to California. After the blackouts in the 90’s, California built 6,000 megawatts of generation-almost all of it natural gas. A little of it was token wind and no coal. I love it!! So we have California greens who are demanding clean green but “reliable” electricity driving Wyoming enviros nuts.
    I think we can handle a “dip” in Antelope numbers on a 10 X 6 mile strip so California greens can feel good about themselves can’t we?

    Once again the greens show their lack of perspective. They’re on their hands and knees looking at the micro, and not seeing the macro. It’s not as complicated as all the above. Its as simple as a 10 X 6 mile strip. It’s about as laughable as “Wyofile” claiming to be ” non-partisan”.

    P.S. The Casper Star Tribune commisioned a poll a few years ago. It found that only 18% of wyomingites thought that “oil or gas drilling harmed the environment”. 70% thought it didn’t. Keep trying in the New West.

  6. By Reality Check, 7-13-10

    Where to even start with an article like this? There is such a limited perspective on all of the players involved that the “story” being told here is offensive to those of us that actually know anything about this at all.

    (1) Why wouldn’t an operator be involved in the hiring of a firm whose work they are paying for? The underlying assumption of the author is that operators were able to skirt or avoid regulations by being involved in the process – does she not realize that operators are only part of the equation? They didn’t make up the rules but they certainly have to play by them.

    (2) The author was incredibly negligent in the portrayal of KC Harvey. FYI – EnerCrest isn’t even in business anymore. Was this written a year ago? Maybe if the author had bothered to look beyond the company website she would know that they have equally qualified wildlife experts as these “nationally recognized” scientists. Maybe if she had talked to anyone but the disgruntled biologist who was upset that he didn’t get a contract she would have a different opinion. And maybe, just maybe, if she had spent real time in this community she would know these dynamics a little better before reporting on them.

    (3) Sure, remove operators from deciding contracts. Put the government in charge and see how fast anything gets done. If you want a bunch of college undergraduate interns walking around counting plants and pygmy rabbit poop, you’re on the right track. The problem is more about the science and protocol – which enviro groups, agencies and the public are involved in deciding – not just the operators. They play the role they are asked to and get the job done by hiring some of the best biologists out there. Just because they aren’t professors doesn’t mean they don’t know what they’re doing – and just because they work for oil and gas doesn’t mean that they aren’t trying to do what’s best for wildlife and habitat.

    (4) So let’s be clear – the DATA coming out of these studies and field work isn’t wrong, the operators aren’t “cooking the books” and they aren’t somehow unfairly influencing the results. They follow the protocol that is set out for them and that they don’t solely decide on for themselves. The point of this article SHOULD be what science can offer wildlife monitoring in a way that works for everyone – not painting the false picture that oil and gas companies have ruined a landscape with reckless abandon.

    (4) Maybe the REAL story here is the JIO-PAPO and how they have horribly mismanaged funds and become tied up in their own bureaucracy and inability to budget…. just a thought.

    Blaming operators is always easy and sometimes justified – but looking at the real problems (and limitations of what science can and CAN’T offer to working lands) is just not very fun for those that would rather start working groups, write academic papers, and point the finger at big bad industry while they drive around in a mid-size SUV and heat their homes.

    This is just another example of how a good story went recklessly green.

  7. I agree with you random biologist. As with most media reporting these days this article is a one-sided view of the development on the anticline-not to mention all of the man hours that were put into the precarious balancing act of dealing with oil and gas. just one more notch for the enviro’s who are always willing to put a wrench in things rather than coming to the table with reasonable and credible solutions. like anon2 said. there was a time and a place for their involvement…mayb thats where all those trees went-had to get the paper for all those preprinted postcards somewhere.

  8. Little known fact…..many if not almost all of the active leks on the Mesa are on a man-made disturbance (reclaimed well pad, reclaimed road, next to a reservoir, in the middle of a road). Could it be that the development actually helped create more suitable areas for leks?

    Believe it or not there are some of us biologists out there that after graduating, chose not to go to work for groups whose best skill is their ability to write scathing letters, but instead to work with and even for the oil and gas industry to help them supply a product that everyone reading this letter wants and needs. I have read too many articles that tear apart the industry, the BLM, Game and Fish, ect, without taking into consideration that there are knowledgeable, dedicated and passionate biologists working behind the scenes to come up with a plan that tries to make everyone happy. I assure you none of us want to see sage grouse go away or pronghorn corridors cut off.

    When reading articles like this I always wonder….Where were the “nationally recognized top-level biologists and statisticians” when the decisions were being made and monitoring protocol being developed? I’ll tell you where, in their corner offices in Washington or at a university somewhere far away from where hard working and equally talented biologists were on the ground trying to make all this right.

  9. If these conservation groups were so concerned why didn’t they file a lawsuit when the Record of Decision was signed? Conversely, wouldn’t we be upset if it said they would be written by the BLM G&F and the NGO’s? Like they have a balanced take on things. While I don’t disagree that there appear to be issues with the way things have been carried out, but this article is very biased in that the original Wildlife monitoring protocol was written primarily by a G&F employee based in the PFO and was reviewed MULTIPLE times by the Wildife Task Group–so I guess the question is that the only authority for managing wildlife are the NGO’s. Hell they have never done anything wrong.

  10. In the first paragraph, she states that “Not a single tree grows on 300 square miles of sagebrush and yellowed grass.” This entirely untrue and is also the point where I stopped reading. No need delving into a heap of half-truths and mis-information.

    If she had actually spent any time out there, she would have seen that cottonwoods line the rivers, pine trees pepper the bluffs, and secret stands of aspens pop up when you least expect it. Indeed she is missing the forest for the tress, becuase f you think of all that sage as pygmy tress, you’ve got a micro-forest out there.

    It is obvious she did not do her research and covered very little of those 300 square miles. And, the grass in only yellow in the fall. It is usually brown.

    My opinion – try being less dramatic and more informed. Your pseudo-prose serves only to highlight your ignorance.

  11. Gee, I sure wish that graduate students spent a little more time talking to less biased sources to get the story straight – and admit their own limitations in covering a topic that requires more understanding than just driving around and taking pictures for a summer or two. Instead of getting an accurate and fair picture of the actual science of monitoring in the field, this article is nothing more than a compilation of opinions from conservation groups that couldn’t be more removed from how this whole process works. Trout Unlimited? the Wilderness Society? Give me a break. This is SO disappointing – not because industry should go without criticism – but because this article isn’t even close to presenting a worthwhile argument.