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Field Notes


Meeting the Moment: Planning for a Responsible Energy Future with the Western Solar Plan

Meeting the Moment: Planning for a Responsible Energy Future with the Western Solar Plan

Attend our virtual Conservation Cafeteria on the Western Solar Plan on Wednesday, April 3 at noon — RSVP here.


If you’ve been following national energy trends, you may have noticed that 2022 was a big year. It was the first year in recent history that renewable energy surpassed coal generation in the U.S. As the cost of renewable energy continues to decline, and numerous state and federal policies continue to encourage decarbonization, it’s clear that renewable energy is here to stay. And that means states like Wyoming need to start preparing for new types of energy infrastructure on their lands. 

For Wyoming, the implications of a transition to low-carbon and renewable energy are difficult to overstate, especially considering the footprint of utility-scale renewable energy and its potential impacts to wildlife, habitats, open spaces, and cultural resources across the state. Fortunately for one key renewable energy resource that Wyoming has in abundance — sunlight — we have a once-in-a-generation opportunity to ensure that this development is sited right from the start. That’s where the Western Solar Plan comes in.

The 2012 Western Solar Plan is getting updated — and Wyoming is included!

The Bureau of Land Management is currently proposing to expand and update its 2012 Western Solar Plan, which will help identify the best locations across the West for future utility-scale solar development — in this case, solar facilities that produce 5 megawatts or more on public lands. The plan aims to proactively screen for wildlife, sensitive habitats, cultural resources, and other values and resources that could conflict with solar energy development. Wyoming wasn’t included in the 2012 plan, back when solar energy cost roughly 10 times what it costs today. But the updated plan includes Wyoming and other newcomers, including Montana, Idaho, Oregon, and Washington.  

Having Wyoming included in the updated Western Solar Plan is great news! This policy update was a core recommendation of the Renewable Energy Siting Collaborative, a convening of industry, conservation groups, academics and other stakeholders that the Wyoming Outdoor Council helped facilitate in 2021. The large footprint that solar energy needs to produce electricity means that inappropriately sited projects could have devastating consequences for Wyoming’s migrating ungulate herds and fragile habitats. We’ve unfortunately witnessed this firsthand with the Sweetwater Solar Facility, the state’s first utility-scale solar project on public lands. This facility was placed along a pronghorn migration route north of Green River, creating a barrier along the animals’ path that funneled them onto a county highway, creating a dangerous situation for pronghorn and motorists alike. It’s an example that shows the impact these facilities can have on wildlife and just how important it is to site projects in ways that avoid sensitive habitats.

​​Help us achieve the best outcome for Wyoming

From now until April 18, the BLM is seeking comments on five different alternatives for the updated Western Solar Plan through its e-planning website. BLM’s preferred alternative (alternative 3) would leave 2.98 million acres (roughly 17 percent) of BLM land in Wyoming open for solar development applications. Stated simply — we think this is too much.

Wyoming is unique in its open spaces, unfragmented habitats, and iconic seasonal wildlife migrations. Solar development in particular presents an impenetrable barrier for big game that threatens connectivity on these landscapes. This is why we are urging our members to tell the BLM to select an alternative that further narrows where solar projects can exist, while still leaving enough acreage available to help our nation reach important climate goals.

Specifically, we urge our members to support alternative 5, which requires that solar energy development on public lands meet the following criteria: 

  • Be located on previously disturbed lands with diminished integrity
  • Be located within 10 miles of existing or proposed transmission corridors
  • Be located on slopes less than 10 degrees
  • Not conflict with 21 resource-based exclusions that BLM has identified for all alternatives. (A full list of these exclusions can be found starting on page 21 of the draft plan.)  

Even when considering these criteria, alternative 5 still allows for applications for solar development in 1.4 million acres of public lands in Wyoming. This is about 50 times more than the BLM expects will actually get developed by 2045 in their reasonably foreseeable development scenario for Wyoming (below). Alternative 5 also adds an additional safeguard by only considering applications on previously disturbed lands which would help ensure that the loss of unfragmented and healthy habitat is minimized and that future solar development is directed away from these areas.  

Figure 1: BLMS Reasonably Foreseeable Development Scenario. Available here.

Speak up for Wyoming’s wildlife

Finally, we need your help speaking up for Wyoming’s wildlife in the plan. As drafted, the Western Solar Plan excludes solar development from big game migration corridors and winter ranges only where this habitat is identified and explicitly singled out for exclusion in existing land use plans. Unfortunately, most of Wyoming’s resource management plans are severely outdated and provide little to inadequate acknowledgement for big game migrations and winter-range in relation to renewable energy projects. Biologists have collected huge amounts of data in recent years to delineate migratory routes and improve understanding of how animals are using crucial winter range in Wyoming. Very little of this has been included or updated in resource management plans.

If this plan is to be successful for Wyoming and avoid harm to our wildlife, it needs to avail itself of the best available science on migrations and winter ranges. In your comments, tell the BLM that it needs to revise its big game exclusion criterion (criterion 9) to protect identified big game crucial winter range and migration corridors from utility-scale solar development regardless of the direction offered in applicable land use plans. The risks to our ungulate herds are too great to ignore the best available data waiting on land use plan revisions that may take decades. 

Help Us Meet the Moment

It’s not everyday in our work as conservation advocates that we get the chance to raise our voice in support of planning efforts with the potential to have such an impact as the Western Solar Plan. As many of you know, this work is so frequently driven by the need to react to bad ideas and policies that threaten conservation values. This plan is different. It sets the rules that will govern solar development on public land for decades to come. From our vantage point at WOC, we are entering a time when the country’s energy future is at a crossroads — and Wyoming stands to play an important role in choosing which path we take. With an updated Western Solar Plan, we have a rare opportunity to be proactive and reduce many of the resource conflicts that we’ve sadly grown accustomed to on our public lands. We can plan for the development that will be needed to power our country while also meeting our long-term climate goals and protecting the wildlife and the very things that make Wyoming special. 

Field Notes


New federal methane rules would curb climate change, benefit Wyoming

On Friday, Nov. 11, the U.S. Environmental Protection Agency took an important step toward protecting public health and reducing greenhouse gas emissions that contribute to climate change by strengthening proposed rules that will reduce wasteful methane emissions from the oil and gas industry.

If enacted, these common-sense rules would be the first action by the EPA to regulate methane emissions from the thousands of existing oil and gas wells in Wyoming, not just future development. The rules are expected to promote new cost-effective technologies to prevent waste, and make natural gas more competitive as consumers demand cleaner sources of energy.

The announcement of new measures to cut methane and other harmful pollutants from oil and gas operations is welcome news, and builds off of Wyoming’s own successes in reducing harmful emissions and will limit wasted methane from leak-prone equipment.

The updated proposal would require routine and cost-effective monitoring of well sites, encourage the development and use of new leak detection technologies, and set higher standards for flaring — a practice by which methane is burned as a waste product rather than captured and sold.

The Wyoming Outdoor Council sees these rules as essential to spurring future innovation around leak detection and repair and to creating a level playing field for methane regulation across the oil and gas industry. We’re encouraged by the efforts to address routine flaring, and hope that the final rule fully eliminates this wasteful practice.

Methane emissions from human activities are responsible for about 30 percent of global warming since the industrial revolution.

The case for cutting methane emissions

  • Methane regulation is supported widely by leading industry and conservation groups. Many oil and gas operators, including major Wyoming producers like Jonah Energy and Purewest Energy, are already working to reduce sources of wasted methane as consumers demand cleaner sources of energy.
  • The Inflation Reduction Act, which passed into law in August 2022, set aside roughly $1.5 billion to help operators to comply with new methane emissions rules.
  • Capturing methane is very cost effective. In many cases wasted natural gas can be captured and sold, paying for most, if not all, of the additional work needed to capture it. Recent data from the International Energy Agency suggest that up to 45 percent of wasted methane emissions can be prevented at no net cost.
  • Reducing methane leaks saves taxpayer dollars and stewards valuable resources for the future. In 2018, the Wyoming Outdoor Council and its partners estimated that between $51 million and $96 million of methane was vented and flared annually in Wyoming. This translated to $9-16 million lost in annual royalty payments to the state.
  • Reducing methane emissions from oil and gas production is widely regarded by scientists and policy makers as a critical first step to mitigate the worst impacts of climate change in the future. Methane is a powerful greenhouse gas responsible for about 30 percent of global warming since the industrial revolution. However, methane also leaves the atmosphere quickly compared to other greenhouse gases like carbon dioxide. Reducing wasted methane emissions now is one of the best opportunities to buy time to implement other climate solutions.
  • Reducing methane emissions has significant air quality and human health benefits. The same leak detection and repair practices used to reduce methane will also reduce harmful air pollutants such as volatile organic compounds (VOCs) that cause respiratory damage and contribute to poor air quality.

Field Notes


Two Ways to Reduce Methane Emissions, and Why Wyoming Needs them Both

Most policy experts agree that, along the long road to combating climate change and reducing greenhouse gas emissions, reducing wasted methane from oil and gas operations is “low-hanging fruit.”

In 2020 alone, wasted methane gas from oil and gas operations made up roughly one-third of all methane emissions from human activity. The obvious need to address this problem is why there are two proposed regulatory changes involving methane that could have major impacts on lowering greenhouse gas emissions from our country’s oil and gas sector. The rules — one from the Environmental Protection Agency and the other from the Bureau of Land Management — would seek to reduce methane waste, and their success is important for Wyoming’s environment and taxpayers alike.

Methane is the second-most significant greenhouse gas in terms of impact on global warming. It is responsible for approximately a quarter of the Earth’s warming since the Industrial Revolution and, when compared to carbon dioxide, it has roughly 80 times the global warming potential over a 20-year period (International Energy Agency). However, despite how methane’s potency, it cycles out of the atmosphere much quicker than carbon dioxide: This means methane emission reductions now can help lower greenhouse gas concentrations and buy time to make the necessary societal changes we need to achieve net zero emissions over the coming decades.

But putting aside the many climate and environmental benefits of reducing wasted methane, it also just makes sense as a cost-effective policy solution. Wasted methane, after all, is essentially natural gas that can be captured and brought to market. As a quick comparison, in 2019 alone, oil and gas operators wasted enough methane from venting and flaring (common ways operators manage methane waste) to power 2.1 million U.S. homes (Environmental Defense Fund).

In fact, the International Energy Agency estimates nearly 50 percent of wasted methane can be captured with no net cost to producers (IEA). This is because investments made in reducing methane emissions pay for themselves over the long term by keeping more natural gas in route to energy consumers and out of the atmosphere.

Which brings us to the new EPA and BLM methane rules — federal efforts the Wyoming Outdoor Council supports to help curb this wasteful practice. Last November, the EPA released new draft rules that would regulate wasted methane emissions for both new and existing sources for the first time. (Historically, in most cases, methane has only been regulated from “new and modified” emissions sources, and older “existing sources” of wasted methane have largely been left alone). The EPA rules would apply under the authority of the Clean Air Act, treating methane as an air pollutant. Importantly, the rules would regulate methane emissions from oil and gas facilities across all jurisdictions and land ownerships (including private, federal, and tribal lands) and, if they go into effect, could dramatically cut emissions and uniformly raise the bar for responsible energy development. The EPA’s rules are widely supported by both environmental and industry groups alike, because they are good for the environment, create an equal playing field for businesses by setting uniform standards, and establish regulatory certainty under which companies can predictably operate and plan.

Separately, the Department of the Interior is also considering a BLM methane waste rule that would apply more narrowly to oil and gas production on federal and tribal lands. The BLM’s rules take their authority from the waste prevention mandate in the Mineral Leasing Act of 1920. This mandate allows the Secretary of the Interior to “use all reasonable precautions to prevent waste of oil or gas developed on the land.” In states like Wyoming, where the majority of oil and gas development occurs on public lands, the application of this rule could help the public realize higher returns on the development of natural resources by charging royalties for wasted natural gas.

In 2018, the Outdoor Council estimated that Wyoming lost as much as $96 million worth of natural gas in a single year due to intentional flaring, venting, and careless leaks. This translates into roughly $16.1 million lost in annual royalty payments to the state. These are critical revenue streams that taxpayers and budget-strapped Wyoming communities deserve to see for the depletion of natural resources (WOC Oil and Gas Waste Report). And of course, the rule would provide further incentive for producers to keep methane in the pipeline and out of the atmosphere.

Both the BLM’s authority under its waste prevention mandate and the EPA’s authority under the Clean Air Act to regulate air pollutants are needed to address climate concerns and ensure that Wyomingites receive a fair value for the one-time use of their non-renewable resources. While some leading companies like Jonah Energy, Occidental, and Devon Energy are taking action to cut methane and support federal methane regulation, that simply isn’t enough. Most oil and gas operators are not doing frequent, thorough inspections for leaks and we need stronger state leadership to support these common sense federal rules that will benefit our environment and our pocketbooks.

Looking forward, both the EPA and BLM rules have procedural and administrative hurdles to clear before they go into effect, hopefully later this year. Our commitment is to continue tracking and advocating strong methane rules as well as keeping you informed of the opportunities to get these policies over the finish line in 2022. The long-term outlook of Wyoming’s climate, budget and residents depends on it.

Field Notes


Everything in its Place

EVERYTHING IN ITS PLACE

How do we make sure the coming boom in renewable energy
isn’t a bust for our wildlife and public lands? 

This story, like much of the good work that happens in Lander, began as a meeting over coffee at the Lander Bake Shop. Staff from several conservation groups, including the Wyoming Outdoor Council, had gathered to look at GPS tracking collar data from pronghorn around Sweetwater Solar, Wyoming’s first large-scale solar project on public land.

 The map of the pronghorn’s movement was infuriating — the 700-acre solar development had been placed right in the middle of crucial winter habitat. Fences surrounding the project had funneled many of the animals onto Highway 372 north of the city of Green River, creating hazards for both wildlife and drivers. The impacts of the Sweetwater Solar project on pronghorn were completely predictable and avoidable. But aside from a brief Environmental Assessment required by the Bureau of Land Management, there was little in the existing permitting process to direct the developers to a better location where wildlife conflicts could have been avoided. 

What became clear in that meeting and in subsequent discussions was that the Sweetwater Solar project was likely a harbinger of what’s to come in the next decade as the cost of developing solar and wind energy continues to fall dramatically. 

The expected boom in renewable energy puts advocates for conservation in Wyoming in a challenging spot. We understand the dire importance of transitioning to cleaner energy sources, and at the same time recognize the significant development footprint that utility-scale renewables can have on Wyoming’s wildlife and open spaces. The question and dilemma on many of our minds is this: How does Wyoming decarbonize its electricity production while not sacrificing the crucial wildlife habitat and open space that make it so unique? 

As with many of the challenges our state faces, there is no silver bullet to solve this problem, but common sense and science both tell us that focusing our efforts on responsible siting and permitting processes for renewables is the logical place to start. That’s exactly what WOC tried to do with its effort to jumpstart the Wyoming Renewable Energy Siting Collaborative. 

As with many of the challenges our state faces, there is no silver bullet to solve this problem, but common sense and science both tell us that focusing our efforts on responsible siting and permitting processes for renewables is the logical place to start.

After the 2020 legislative session, WOC started reaching out to stakeholders around the state to understand the perception of renewable energy and ways we might be able to improve our siting and permitting policies. We worked closely with faculty at the University of Wyoming to convene a group of policy thinkers representing conservation, industry, local government, landowners, and independent consultants to explore opportunities for the state to improve how renewable energy is sited. 

During 2021 this group met nine times over Zoom to discuss issues related to renewable energy in Wyoming, including tax policy, federal and state revenue sharing, transmission development, supply chain manufacturing, and other topics. The group also learned from and consulted with experts from the Wyoming Industrial Siting Division, the Wyoming Game and Fish Department, and the Wyoming Wildlife and Natural Resource Trust. The group’s final recommendations were published in November 2021 and can be found on UW’s Ruckelshaus Institute website

These recommendations are a start. They form an important foundation for future policy and advocacy work, especially as our country moves to decarbonize electricity production and accelerate the growth of renewables. They also show that industry and conservation can work together to agree on important concepts moving forward. 

Some of the most important points of agreement in these recommendations address the need for more proactive planning for renewable development on public lands, the need for early and frequent consultation with the Wyoming Game and Fish Department to avoid wildlife conflicts, and the need to evaluate previously disturbed locations as places to site renewable energy. There is also strong agreement on the importance of public transparency and engagement as projects move forward so impacted citizens and communities have opportunities for meaningful input on project proposals. 

We know that more wind and solar energy is on the horizon, and the development of these resources will present historic challenges and opportunities for Wyoming. But as with all development, we must insist that this growth be done on our terms — in a responsible and measured way — that does not degrade and diminish the very things clean energy is supposed to protect. Holding that line will require leadership at the state level. It will also take collaborative efforts like the one that played out last year at the University of Wyoming — with the full spectrum of experts and advocates coming together with a shared goal of making sure future development is sited appropriately. We’ve already seen the impacts on wildlife when things go wrong. But done right, renewable energy development could be an asset, not a liability, to Wyoming’s environment and quality of life.

Field Notes


Run the Red to Celebrate Wyoming Public Lands Day with Community Events in South Pass City

Hundreds of runners from across the nation and their families, members of the public, speakers, and Tribal members will kick off the Wyoming Public Lands celebration on September 25 in South Pass City. This holiday recognizes the millions of acres of public lands in Wyoming that belong to everyone. The celebration coincides with Run the Red, where runners race across the desert, competing in half marathon, 50K, and 100K distances.

Gov. Mark Gordon in March 2019 signed legislation that recognized the fourth Saturday of each September as a day to celebrate the public lands that are central to Wyoming’s quality of life, economy and heritage. Wyoming was the third state in the country to declare a state public land’s day.  The public is encouraged to attend or simply get outside to enjoy a national forest, national monument, wildlife refuge, or any public land. 

Run the Red began in 2014 to mark the 50th anniversary of the Wilderness Act of 1964 and the 30th anniversary of the Wyoming Wilderness Act. In 2019 the race was also coordinated to celebrate the inaugural Wyoming Public Lands Day. The event has grown over the years, starting with just 30 runners and growing to over 200 with multiple courses. Last fall, a short film from Patagonia further elevated the race to a national profile. Run the Red begins in the former gold mining community of South Pass City and takes runners through the Northern Red Desert — a maze of buttes, canyons, badlands, wilderness study areas, and miles of open country. Parts of the course even traverse the Oregon, California, and Mormon trails where some 500,000 emigrants traveled in search of new beginnings in the 1800s. 

In addition to the races, a series of tours, speakers, music, and food is planned for the day. Beginning at 6:30 a.m., a pancake breakfast will be served for volunteers and members of the public and numerous nonprofit organizations will be tabling including the Equality State Policy Center, Citizens for the Red Desert, Red Desert Audubon, and others. The bulk of the family and community events begin around 9:30 a.m., which include tours of the Carissa Mine and the Flood & Hindle Trails, a nature hike lead by ethnobotanist John Mionczynski, and an Oregon Trail presentation by Randy Weiss. Kids will also be able to enjoy gold panning, and a kids fun run will be held around 10:30 a.m. Two local food trucks — Hungry Buddha from Rock Springs and Monahooboo Hut from Wind River — will provide food options for the public and beer will be served by Square State Brewing from Rock Springs.

Big Wind Singers, a traditional drum group, and dancing by the Wind River Dancers will kick off the main celebration at noon. Following the cultural celebration, members of the Eastern Shoshone and Northern Arapaho Tribes will speak about the cultural significance of the Red Desert and the meaning of their dance and song. Elected officials and state leaders have been invited to speak about the importance of public lands to all people. Music by Ten Cent Stranger begins at 2 p.m. and an old time piano and accordion performance by John Mionczynski will wrap up the celebration in the evening. The festivities are open to all. To see the full schedule of events, go to www.runthereddesert.com

Field Notes


How unseen emissions continue to impair air quality in Wyoming’s Upper Green River Basin

MORE THAN MEETS THE EYE

HOW UNSEEN EMISSIONS CONTINUE TO IMPAIR AIR QUALITY IN WYOMING’S UPPER GREEN RIVER BASIN

Whether you ranch, farm, hunt, fish, or ski, there is a season for most things in Wyoming. But there are some seasons that we could do without. Topping that list is “winter ozone season” in the Upper Green River Basin of Sublette County.  

For nearly two decades, the Wyoming Outdoor Council and Pinedale-based Citizens United for Responsible Energy Development (CURED) have been actively working to improve winter ozone conditions in this region, which is home to the state’s largest natural gas fields. This seasonal phenomenon typically occurs when the right combination of weather patterns, surface reflectivity from snow and ice, and emissions like nitrogen oxides and volatile organic compounds (known as VOCs) all combine to create ozone molecules. When the ground-level ozone concentration exceeds 70 parts per billion, it can have harmful respiratory effects and cause lung damage in people who breathe the polluted air.

While there have been some modest improvements in the region’s air quality since development in the basin started, the basic fact remains that the UGRB, which once boasted some of the cleanest air in the country, remains dangerously close to violating the Clean Air Act’s standards for ozone. The consequences of this violation could be significant not only for the people living, working, and breathing in Sublette County, but for the industry operators who would likely see new regulations to bring the region back into compliance with air quality standards. 

The UGRB, which once boasted some of the cleanest air in the country, remains dangerously close to violating the Clean Air Act’s standards for ozone.

To better understand why this area continues its seasonal struggle with high ozone levels, the Outdoor Council teamed up with CURED and a trained thermographer from Earthworks, a community-based advocacy organization, to visit the Upper Green in November 2020 and inspect roughly a dozen oil and gas sites on the Jonah and Pinedale Anticline fields. Our goal was simple: to document examples of permitted emissions from oil and gas facilities on public lands and consider what appropriate next steps regulators can take to continue improving this region’s air quality.

Engine stack emissions from the Enterprise Products’ Bridger Compressor Station are an obvious example of a “major source” facility permitted under the Clean Air Act. This footage shows the stark contrast between what an observer can see with the naked eye versus through the lens of specialized infrared camera equipment. (Infrared video footage by Earthworks, Nov. 19, 2020.)

Almost all of the sites our team visited had some detectable levels of fugitive emissions — none of which would have been visible without the use of a state of the art forward-looking infrared camera. These FLIR cameras, which individually cost as much as a high end sports car, provide a glimpse of the otherwise invisible emissions occurring across the Jonah and Pinedale Anticline oil and gas fields.

As part of their operating permits, companies are typically allowed to emit certain levels of pollutants into the atmosphere. Sometimes emissions are vented and released intentionally, while other times they are accidental and the result of old or leaky equipment that needs to be updated or repaired. Both contribute to poor air quality and the region’s ozone season.

Natural gas producers operate thousands of facilities in Wyoming’s Upper Green River Basin. These facilities collectively leak or vent thousands of tons of methane and VOCs each year.

Fugitive emissions seen on Jonah Energy LLC’s Stud Horse Butte Tanks #10-28. The basin’s windy conditions can make it more difficult to see the gas plumes leaking from infrastructure in the UGRB. The region’s poorest air quality is typically on calm days during inversions when concentrations of pollutants build up. (Infrared video footage by Earthworks, Nov. 19, 2020.)

One routine and permitted practice in the Upper Green that contributes to the region’s wintertime ozone problems is when oil and gas wells are intentionally “blown down” to clear them of debris and sludge that accumulates over time. Blowdown tanks are often used to hold the residual fluids and gases that are expelled during these events, but this process frequently results in large volumes of fugitive gasses and VOCs escaping into the atmosphere. During a two-month period in the winter of 2020, Jonah Energy reported 1,008 blowdown events totaling over 159 hours of uncontrolled emissions venting. Dozens of other production companies operate in the region and, collectively, blowdowns result in hundreds of thousands of dollars in wasted gas annually and thousands of tons of vented methane and VOCs.

Emissions venting from tanks at Ultra Resource’s Stud Horse Butte Tanks #7-21. (Infrared video footage by Earthworks, Nov. 19, 2020.)

Emissions from leaking equipment or intentional venting can combine to create ground-level ozone, which can cause respiratory problems and lung damage.

When added up across the landscape, blowdown events and other forms of permitted emissions have the potential to play a big role in the seasonally unhealthy air that impacts the Upper Green. In our day in the field, we were able to document these emissions coming from blowdown tanks, combustor units, and dehydrators. It’s not hard to imagine what that impact could be when multiplied by the thousands of permitted facilities currently operating in the basin.

A leaking tank at Pinedale Energy Partners’ Mesa #1 well. Oil and gas companies operate thousands of facilities in the Upper Green River Basin. (Infrared video footage by Earthworks, Nov. 19, 2020.)
Pinedale Energy Partners’ Mesa well #3-17 shows blowdown tanks that are badly venting emissions. The harmful gasses being released into the atmosphere could be controlled by flaring which would turn these emissions into less harmful ones like carbon dioxide and water vapor. (Infrared video footage by Earthworks, Nov. 19, 2020.)

If the oil and gas industry is going to continue to serve Wyoming as it has historically, it needs to adapt and change to meet the expectations of mostly out-of-state consumers who are increasingly holding energy production to higher environmental and social standards. Based upon our own field observations, a good starting point for Wyoming regulators would be to reduce, and ultimately end, the common practice of using uncontrolled blowdown tanks to vent emissions from oil and gas operations. These emission sources and others should be minimized by being routed to combustors, and more work is needed to reduce the amount of wasted gas that is vented into the atmosphere. While blowdowns are just one of many emissions sources that need to be addressed by operators and regulatory agencies, this would protect public health and air quality. It would also be in the best interest of the industry in the long term.

We look forward to a future trip to the UGRB where the only things to see through a FLIR camera would be the silhouettes of mountains and clouds. But for that future to become a reality, there is still clear work to be done. With states like New Mexico and Colorado taking strong steps to clamp down on uncontrolled venting and set high standards for leak detection and repair, Wyoming’s operators should be following suit to address growing concerns over fugitive emissions, air pollution, and climate change.

Field Notes


Despite public outcry, Wyoming’s net metering law will again be on the chopping block

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Last week, we asked many of you to speak up at the Wyoming Legislature’s Joint Corporations Committee meeting and oppose a bill that would have undercut rooftop solar and small scale renewables in this state. And wow‚ that’s exactly what you did. The impact of your letters, calls, emails, and testimony was undeniable. The committee heard you. Because of you, the bill was dead upon arrival.

But, as many of you know, things at the legislature can change quickly and often unexpectedly. After the committee acknowledged that the votes were not there to pass the original bill, several members pulled the rug out from under the discussion by making a motion to substitute that bill with entirely different language and intentions. No one, including some members of the committee, saw this coming, and apart from a brief screen-share of a private document, the new bill was not even publicly available.

To the many members of the public who had taken time out of their day to participate — some of them taking time out of work — this was a shockingly sneaky maneuver. The last minute bill swap undermined the ability of the public to meaningfully weigh in on the topic while pushing through these committee members’ own agenda on net metering.

Consider for a moment, that the committee hadn’t been assigned net metering as an interim topic, and that the interim is supposed to be a time for thoughtful consideration of complex issues that require public input. Voting to advance a bill that neither the public or many members of the committee had ever seen before flies in the face of that. For those of you who spent time preparing testimony on the original bill that was not even considered, we are sorry.

We’re also sorry that after nearly three and a half hours of public testimony overwhelmingly against changing our existing net metering law, the committee decided to advance the new bill to the 2021 legislative session. This new bill charges the Public Service Commission to study net metering and set new rates and conditions for customers who currently have net-metered systems. The problem is this new bill leaps to the conclusion that net-metered customers are being subsidized by other ratepayers in Wyoming. This is not necessarily true. By thinking about net metering only as a “subsidy,” without also directing the Public Service Commission to consider the economic, social, and environmental that this policy generates, this bill’s narrow focus will make rooftop solar more expensive and kill jobs in this growing sector of our economy.

So what comes next? We believe that rooftop solar and small scale renewables can and should play an important part in diversifying our state’s economy and helping us address growing concerns about carbon emissions and climate change. The Wyoming Outdoor Council, along with a large coalition of solar and renewable energy supporters, will continue working on this issue and preparing for its appearance at the 2021 legislative session. Stay tuned as there will be plenty of opportunities to defeat or amend this bill. This fight is not over.

In the meantime, there are some real heroes on the committee that questioned and fought for the integrity of the public process that could use recognition and a quick thank you. Senator Tara Nethercott, in particular, was a passionate defender against the tactics we saw used last Wednesday. If you have a moment, we would encourage you to send a thank you to her and the other four members of the committee listed below who appreciate the value of public process, and who voted not to move any legislation forward under such circumstances.

Sen. Tara Nethercott
Tara.Nethercott@wyoleg.gov, 307.399.7696
Rep. Dan Furphy
Dan.Furphy@wyoleg.gov, 307. 760.0148
Rep. Shelly Duncan
Shelly.Duncan@wyoleg.gov,  307.575.2894
Rep. Andi Clifford
Andrea.Clifford@wyoleg.gov, 307.840.4327
Rep. Jim Blackburn
Jim.Blackburn@wyoleg.gov, 307.514.4318

 

 

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Field Notes


Climate change: the new front line for conservation in Wyoming

Wyoming is changing, faster now than any of us could have predicted even six months ago. In our last issue of Frontline, we addressed the reality of climate change and what it means for Wyoming’s future. Climate change is not a separate issue, but one that is deeply intertwined with all aspects of our work — from protecting our state’s big game populations to reducing harmful air emissions, to safeguarding our clean water, public lands, and ultimately our way of life. And if we are to succeed in our mission, we must advocate for policies that directly confront the real and growing threat of human-caused climate change.

Wildlife and migration

As you know,  the Wyoming Outdoor Council’s wildlife work over the last several years has focused on protecting Wyoming’s big game migration corridors — and for good reason. The science is clear about the crucial role these corridors play in maintaining ungulate populations that in turn support our state’s recreation economy and outdoor heritage. Yet, a changing climate could easily undermine many of these hard-fought efforts. For one, changing precipitation patterns and drought increasingly threaten the ability of animals to “surf the green waves” that connect their seasonal habitats. Wyoming has seen warming temperatures and drought intensify over the last 20 years and most experts agree that, at least for our state, this trend only gets worse. If we are to ensure that our state’s wildlife remain protected for the long term, we must also consider how these populations stay resilient and capable of adapting to these changes, while taking responsibility to mitigate the most damaging forecasted climate scenarios. 

Clean air

It’s hard to talk about clean air and the policies necessary to maintain it without acknowledging the relationship between climate change and the greenhouse gases at the heart of Wyoming’s air quality problems. We often think of natural gas as a cleaner fuel than coal — and it is, if we minimize the amount of fugitive emissions that leak into the atmosphere as it is produced and processed. The Outdoor Council has repeatedly called on Wyoming’s Department of Environmental Quality and the oil and gas industry to address air quality concerns, by advocating improved Leak Detection and Repair requirements for oil and gas infrastructure and opposing rollbacks of critical methane capture rules. With natural gas expected to play a major role in energy production for years to come, Wyoming must keep on raising the bar for air quality standards not only to protect our health, but to reduce our greenhouse gas footprint and stay competitive in energy markets that are favoring cleaner energy.

Clean water

One of the most alarming aspects of climate change in Wyoming is its impacts on our arid state’s already limited water resources. If current projections for warming hold, Wyoming could see significant loss of coldwater fisheries and native trout habitat by the end of this century due to increased water temperatures and loss of instream flows as our snowfields and glaciers shrink. These conditions exacerbate water quality concerns the Outdoor Council has been working hard to address, such as reducing harmful E. coli concentrations in our waterways. Warming temperatures are also projected to increase the amount of rainfall as opposed to snow, which reduces the amount of stored water potential available in the summer and fall. This spells increasing challenges and conflicts for ranchers, farmers, cities, recreators, and, again, our wildlife.

Our public lands

Advocating responsible energy development has been at the heart of the Outdoor Council’s public lands policy work — whether that’s fighting back against efforts to privatize public lands, urging the protection of special landscapes, or watchdogging development in crucial wildlife areas. We’ve recently reported on the rampant and largely speculative oil and gas leasing taking place across large swaths of the state. Not only do these lease sales come at the expense of other uses of our public lands, for those that are developed, they come at the expense of the quality of the environment that future generations will inherit. Remarkably, nearly one quarter of all greenhouse gas emissions produced in the United States originate from public lands — lands that are supposed to be managed with both current and future generations in mind. This is not sustainable. To the greatest extent possible, our public lands should be managed in ways that mitigate climate change and help surrounding communities be more resilient into the future. 

Confronting climate change also means addressing our economy

Climate change is a reality that ripples through the conservation issues the Outdoor Council has been engaged in for decades. It is something that our founder, Tom Bell, understood early on and urged us to address directly.

If we cannot find ways to address and mitigate this looming crisis and do our part as a state, our conservation work in all of our traditional program areas will fall short. 

Tackling climate issues in Wyoming will require hard and honest conversations about the dependency of our state’s economy on fossil fuels, and it will require creativity and investment into bold new ideas. The new front line for conservation means wading into policy issues that, at least on the surface, seem less directly tied to it — like helping communities transition from fossil fuels, promoting economic diversification, and supporting new sources of state revenue. As daunting and intimidating as this might feel, we believe it’s critical. Our state’s economy and conservation policies are interconnected. Wyoming’s outsized influence on climate change means that the policies and actions we take in our communities can have national — even global — impacts. 

Field Notes


Scholarships support students committed to conservation

This year the Wyoming Outdoor Council is proud to award $1,500 scholarships to five graduating high school seniors from Wyoming — who all have demonstrated a commitment to conservation values and protecting Wyoming’s environment and quality of life. The five students plan to study a wide range of topics in conservation and resource management and will be pursuing related degrees. These scholarships were made possible thanks to the generous support of the Blue Ridge Fund of Wyoming. Congratulations! 

  • Tessa Coughenour (Natrona County High School) will study environmental design at Montana State University.
  • Parker Goodwin (Cody High School) will study engineering at the University of Wyoming.
  • Mallie Gray (Natrona County High School) will study reclamation and restoration ecology at the University of Wyoming.
  • Kai Lynn (Cody High School) will study biology at Northwest College with plans to transfer to the University of Wyoming to complete a degree in wildlife biology. 
  • Rachel Stoinski (Lander Valley High School) will study wildlife and fisheries biology and  management at the University of Wyoming

We will continue to offer these scholarships each year to help support the next generation of conservation-minded Wyomingites. If you know a young person who may qualify, please spread the word and watch for the next opportunity to apply in early 2021.

Field Notes


With winter on its way, it’s time to talk ozone in the Upper Green

The winter of 2019 was a bad season for ozone pollution in the Upper Green River Basin, particularly near Boulder where monitoring stations recorded nine days in which ozone levels exceeded federal standards. 

Winter ozone is not new for this region, but increasing concentrations over the last several years have called into question whether the regulations governing fugitive emissions from oil and gas operations — and our clean air — need tightening. This was the context that led members of the local Pinedale advocacy group Citizens United for Responsible Energy Development and the Wyoming Outdoor Council to tour the Jonah and Pinedale Anticline natural gas fields with Wyoming’s Department of Environmental Quality. Our goal was to better understand current operations — and learn what state regulators are doing in response to last season’s unhealthy ozone conditions.


CURED member Jana Weber looks at the emissions from a combustor through a flare camera. These cameras can cost more than $100,000 and are used to quickly identify emission leaks.


As one might expect, there’s a lot to see in the state’s largest natural gas field. Our group visited facilities owned by the three major energy companies in the area: Pinedale Energy, Ultra Energy, and Jonah Energy. We examined lake tanks, pig launchers, combusters, disposal facilities, production units, and dehydrators with state-of-the-art flare cameras used to detect leaking emissions from a distance. Looking into these cameras is like looking under a microscope where the invisible world of gasses and heat is revealed in ghostly detail. Technological advances like this are essential for quickly identifying leaks and monitoring emissions and are a key component of what’s known as Leak Detection and Repair.

New technologies might make inspections easier and more efficient, but it remains a daunting task over such a large area. Currently, the Upper Green River Basin has more than 8,000 permitted facilities and only two full-time DEQ air quality inspectors. Even with each inspector performing hundreds of inspections annually, the vast majority of these facilities will go uninspected each year. 

Fortunately, DEQ has ways of prioritizing the most important inspections based upon factors like the facility’s previous violations, its potential for emissions, and when it was last inspected. With low compliance rates a lingering concern and priority, it was also refreshing to learn that inspectors took enforcement actions against several operators this summer for permit violations.

Touring the Jonah and Pinedale Anticline fields was a reminder of the good work and intentions of our state’s Department of Environmental Quality in the Upper Green River Basin. But, while we were pleased with what we saw, the bar for whether or not current efforts are enough will be determined by the ozone levels we see in future winters. We’re encouraged that the DEQ seems to be taking last year’s violations seriously and has set ambitious goals for engine monitoring and working to bring on a third air quality inspector in the basin this winter. However, funding for the department’s two current full-time inspectors will need to be added to the DEQ’s budget next year, due to the elimination of the federal contribution for this work. 

We have to make sure that DEQ has the resources it needs to prioritize inspections and improve compliance rates to achieve better air quality in the Upper Green. You can be sure that the Outdoor Council will be advocating for this at the 2020 legislative session in Cheyenne. 

The DEQ’s annual pre-season ozone meeting is slated for November 18 at the Boulder Community Center in Boulder, WY. Outdoor Council staff and CURED members will be in attendance. More information can be found here