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Climate Change

Field Notes


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

Posted on by John Burrows

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

Posted on by John Burrows

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


Q&A with Kara Choquette, Wyoming Energy Authority

Posted on by Alan Rogers

Kara Choquette is director of communications and government relations for wind energy developer Power Company of Wyoming, as well as the TransWest Express transmission line project. Earlier this year, she joined the board of the Wyoming Energy Authority. She shared her thoughts about the Energy Authority and the role of renewable energy in Wyoming’s future in a quick Q&A with the Outdoor Council.

Share a little about your background, and your experience in the energy industry. What motivates you to work in the energy sector in Wyoming, and how did that lead you to serve on the board of the WEA?

I’ve been working directly in the renewable energy space since 2009. That’s when I joined a company that is developing the nation’s largest single wind power project, in Carbon County, Wyoming, and is also developing a major new interregional electricity transmission line for Wyoming. It was a natural career transition for me and a compelling opportunity after spending over a decade working in the technology and water industries – which each include important energy-related aspects. I liked the fact that wind turbines create electricity without requiring any water. Having grown up on a family farm/ranch, I wanted to help bring more kinds of good-paying, stable, family-supporting jobs to a rural area. And I liked that wind energy is compatible with agricultural operations and multiple environmental objectives.


I’ve been an active participant in some manner with the Wyoming Energy Authority and with one of its predecessors, the Wyoming Infrastructure Authority, since 2009. Recently, I’ve been part of two multi-stakeholder state groups – the governor’s Platte Valley Mule Deer Local Area Working Group, and the University of Wyoming-led Renewable Energy Siting Collaborative. I was honored to join the WEA board because the WEA is at the forefront of “all things energy,” in the nation’s top Energy State, during a fascinating period of energy opportunity and evolution.

How do you see renewable energy fitting into the future of Wyoming’s economy and way of life?

To me, renewable energy is entirely consistent with Wyoming’s pioneering and pathfinding DNA. Wyoming’s history is filled with so many stories about developing new trails, exploring diverse opportunities, and responding creatively and decisively to changing markets and conditions. Renewable energy also can help maintain Wyoming’s longstanding leadership as an energy producer and exporter. The completion of the Union Pacific Railroad in 1869 opened up new access to new markets for otherwise-stranded resources in Wyoming, such as coal produced from Wyoming’s original coal-mining county (Carbon County). Similarly, new high-voltage interregional transmission lines will open up access to new markets for otherwise-stranded clean electricity resources in Wyoming. The state does not have in-state demand for all of the abundant mineral and non-mineral resources it can provide. When new non-mineral power plants can compete and can secure customers out-of-state, that will create more new energy jobs and new sources of energy revenues in-state.

What are your hopes for your time with the Wyoming Energy Authority? What would you like to see WEA achieve?

The Wyoming Energy Authority is a relatively new entity, created by the state in 2019 (via Senate File 37). The WEA’s primary purpose is straightforward: “diversify and expand the Wyoming economy through improvements in the state’s electric and energy transmission infrastructure and facilitate Wyoming’s production, development and transmission of energy and associated natural resources.” I would like to be part of the WEA continuing to grow and achieve its purpose, especially in areas related to the clean energy technologies that are increasingly in demand today and in the near future. I hope to add value by bringing diverse expertise specifically in the renewable energy sector, and an enthusiasm for other important energy aspects like energy efficiency. The WEA is fortunate to have an outstanding executive director, smart and dedicated staff, and top mineral and non-mineral energy experts who have been on the board since its inception; I’m glad to be part of this team.

Field Notes


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

Posted on by John Burrows

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


A Message from the Director

Posted on by Lisa McGee

Advocating for conservation in Wyoming is demanding work, both for the Wyoming Outdoor Council’s staff and for passionate members like you. Not only are there more issues than we can possibly address as a small organization in a geographically large state, but for people with big hearts and a love for the wild, open spaces of Wyoming, the outcomes are personal. 

We don’t always win. When we do find success, as frequent as it may be, it’s often in the form of a quiet victory or incremental change. The forces working against us — whether it’s government inertia or downright hostile opposition from other stakeholders — can often feel overwhelming. 

But we aren’t in this alone. After all, we have each other. 

Poll after poll shows that the vast majority of our fellow Wyomingites — even if they don’t consider themselves “conservationists” — value public lands, wide open spaces, wildlife, clean air, and clean water. Our challenge is to meet people where they are and attempt to find common ground. The more we make these connections, value multiple perspectives, and seek input from a diversity of people outside of our organization in Wyoming and beyond, the more likely we are to succeed in our mission.

However difficult it may be, an honest and respectful conversation with a person who disagrees with our position does more good than assuming we have all the answers. 

Everything we hope to accomplish depends on relationships. Wyoming is a state where a small group of thoughtful, committed citizens can seek creative solutions to tough problems and make a difference. And, as you’ll read in the coming pages, positive things can happen when a group of people with diverse perspectives put their heads together around an issue of mutual concern instead of staying in their own camps. 

Everything we hope to accomplish depends on relationships. Wyoming is a state where a small group of thoughtful, committed citizens can seek creative solutions to tough problems and make a difference.

Thank you for being part of the Outdoor Council community in 2022. I take comfort in knowing, despite the obstacles and the slow pace of change, we’re all in this together. I hope you’ll remember that as well. 

Field Notes


Everything in its Place

Posted on by John Burrows

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


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

Posted on by John Burrows

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


    ARIEL GREENE: Local climate action takes root in Wyoming

    Posted on by Guest Author

    In the past few years, all around the world, the problem of climate change has been coming to the fore. Now, there is a growing local climate action movement taking root in Wyoming. 

    In different corners of the state, grassroots organizations like the Alliance for Renewable Energy in Laramie, Lander Climate Action Network in Lander, and Jackson Hole Climate Action Collective in Teton County are spreading awareness, fostering engagement, and embarking on the long-term project of reducing their communities’ greenhouse gas emissions.

    These movements are pragmatic, non-partisan, and involve a younger generation in civic affairs. Their parallel efforts form a loose network that is creating collective momentum whereby one group’s progress reinforces the others.  

    In one way, this local action is a surprising development given Wyoming’s deep and long standing economic dependence on the export of fossil fuels — energy sources that power civilization but have the unfortunate side effect of releasing heat-trapping gases into the atmosphere. Moving away from carbon-intensive resources means diminishing state revenues that fund our schools, libraries, police, roads, health offices, and other critical public services.

    On the other hand, changing energy markets have already been shrinking these revenues for years now, and a changing climate has the potential to degrade Wyoming’s quality of life in an even more costly and profound way. Among other things, rising temperatures are projected to increase droughts and forest fires while negatively impacting water supplies and stream flows and the fish, wildlife, and human populations that rely on them. This, in turn, threatens the outdoor recreation, tourism, and agricultural sectors which together form the other main pillars of Wyoming’s economy, and are primary threads in the fabric of our state’s way of life.

    In the past few years, the world has changed in two significant ways:

    First, the cost of solar, wind, and energy storage technologies has plummeted. Low-carbon, renewable energy is now the cheapest form of new electricity production in much of the world. And the cost declines are expected to accelerate as capital investment, economies of scale, and industry competition ramp up.

    Second, a worldwide tectonic shift is taking place as nations seek to decarbonize their economies because of growing concern over climate change. This will only increase the demand for renewable energy sources.

    Whether Wyoming wants it or not, the entire globe is moving quickly away from fossil fuels. This includes not only much of the United States (the traditional market for Wyoming’s mineral sales) but also China, Japan, South Korea, the UK, the European Union, New Zealand, and Canada — countries that together make up more than half of all global economic activity. All have recently announced intentions to reduce their net greenhouse gas emissions to zero in coming decades — plans that will radically transform their societies and promote the development of technologies that will move them away from fossil fuels.

    While working on the nuts and bolts of local policy, Wyoming’s climate movements can not only help reduce our own emissions, save municipalities money in a time of contracting budgets, and prepare communities to be resilient in the face of changing environmental conditions, but they can also draw attention to these larger forces at work. They can play a crucial role in helping us adapt to the historic economic transformation that is underway and envision a viable future for the state. They can create a new sense of what is possible. And if this can be done in Wyoming, it shows it can be done anywhere.

    The task is daunting, but filled with possibility. We are lucky that Wyoming happens to be naturally endowed with the very elements needed to thrive in a new, low-carbon landscape: lots of sun and wind, clean air and clean water, cooler temperatures, big wilderness, easy access to nature, strong communities, and a high quality of life. We’re realizing, more and more, these might be the most precious resources we have.

    Ariel Greene is a Lander resident and member of the steering committee for the Lander Climate Action Network.

    Field Notes


    Playing the long game for conservation policies that endure

    Posted on by Lisa McGee

    A change in federal administrations — and the policies that follow — is cause for either excitement or anxiety depending on how you voted. And for good reason: Elections have consequences. National policies affect our health, our economy, and our environment. And in Wyoming, where nearly half of the land is managed by the federal government, national policies have a disproportionate impact. 

    Members of the Wyoming Outdoor Council fall all along the political spectrum. We agree to disagree on many issues, but find common ground when it comes to conservation. Conservation is not — and should not be — a partisan issue. 

    From the standpoint of conservation and environmental justice, the legacy of the outgoing administration is dire. From climate change denial and the loosening of air and water quality safeguards to oil and gas leasing in areas important to Indigenous people and in crucial wildlife habitats, there have been more than 100 documented rollbacks to existing protections or short-sighted policies that threaten public health and our air, water, wildlife, and lands. 

    Many of the administrative wins we celebrated over the last decade were among those rolled back. The fate of others — like the Bureau of Land Management’s methane waste prevention rule — remains uncertain as challenges are still working their way through the courts. And while there are some rules that the incoming administration will be able to restore and it will certainly abandon some public land policies like “energy dominance,” we’ve lost important ground. 

    To be sure, the Outdoor Council looks forward to an incoming administration that is less hostile to our mission. At the same time, we are wary of ambitious campaign goals that don’t take Wyoming values into account. For example, in the urgency to transition away from fossil fuels, proposals for industrial-scale wind and solar development on public lands in Wyoming shouldn’t be rushed. Development should be encouraged in already disturbed areas so that, in our effort to mitigate climate impacts, we don’t harm intact habitat and our most cherished open spaces and public lands. 

    And we’ll be careful not to rely too heavily on federal policy for solutions to the specific challenges we face in Wyoming. We don’t relish what has come to feel like a game of administrative ping-pong. 

    Instead, what we strive for — regardless of who occupies the White House — are common-sense conservation initiatives and environmental policies that endure. Although incremental progress isn’t as newsworthy as sweeping change, we’re playing a long game. We’d much rather build on measured steps forward than have fleeting successes that can’t withstand the next election. 

    What we strive for — regardless of who occupies the White House — are common-sense conservation initiatives and environmental policies that endure.

    Assuming they work as promised, we support state-level initiatives. Past examples include  rules for detecting and fixing methane leaks in new and modified oil and gas fields and requiring baseline water testing before oil and gas drilling. We’ve also supported executive orders for sage-grouse conservation and big game migration corridors, although we continue to scrutinize their implementation.

    And when we advocate for big policy solutions with the power to deliver conservation wins, we also champion strong public processes. We’re dedicated to empowering citizens in local communities to help craft lasting solutions. In the coming year we’ll build on the groundwork we laid in 2020 to seek consensus recommendations for large-scale renewable energy siting, support community-led climate change resolutions like the one recently adopted in Lander, and work with Tribal partners and other citizens toward permanent protection for parts of the incredible Northern Red Desert. 

    Our approach to conservation keeps us grounded in Wyoming. This doesn’t mean that we are always successful. There are frequent setbacks, but it’s this approach that accounts for the conservation gains we’ve celebrated over the last 54 years. With your support, I’m confident we’ll continue this progress — not just in the coming year or coming four years, but for the long haul. 

    Field Notes


    Field Notes: December updates from the Wyoming Outdoor Council

    Posted on by Alan Rogers

    PLATTE VALLEY DEER NEED YOUR HELP

    On December 11, the Platte Valley mule deer migration corridor working group met for the first time. The seven people appointed to the group — representing agriculture, industry, conservation and recreation — are the first corridor working group established under Gov. Mark Gordon’s migration corridor executive order. Unfortunately, the initial meeting indicated that this group will likely consider removing the Platte Valley migration corridor designation, and weakening protections for this important herd. We’ll be blunt: the governor’s office appears to be prepared to yield ground to a small, loud group of voices that oppose the designation of migration corridors. But we know that many more of you value our big game and support common sense, locally-driven conservation protections.

    If the Platte Valley is a special place to you, or if you know the iconic Platte Valley mule deer herd well, we encourage you to reach out to us as soon as possible. As the inaugural working group created under the governor’s order, Platte Valley will set an example for how other corridor working groups will operate in the future. And it’s important that this working group hear that the public supports science-based wildlife management that will help sustain our herds — and local wildlife economies — long into the future.

    Mark your calendars for our next Conservation Cafeteria on Wednesday, January 6 — we’ll discuss the Platte Valley working group and all things migration. And if you are passionate about Platte Valley deer, please reach out to Kristen Gunther at kristen@wyomingoutdoorcouncil.org.

    HOBACK RV PARK RESIDENTS AT RISK

    Early this month the owner of Hoback RV Park informed tenants that they can stay on site through the winter, but their water and septic connections will be cut off after December 31. Residents will have the option to hire a private company to provide septic service to their trailers. This is a slight improvement — longtime residents previously faced eviction at the end of the year — but not a workable solution for all.

    The owner, Crowley Capital, faces a number of serious violations of state and county regulations stemming from an inspection of the Teton County property that was requested by the Wyoming Outdoor Council, including liquid sewage seeping up from a failed septic system, disposal of concentrated nitrate waste into an unpermitted sump on the property, discharges exceeding permitted capacity limits, and water treatment equipment that was installed without a permit.

    The Wyoming Department of Environmental Quality and the Teton County Commission have the authority to potentially fine the owners hundreds of thousands of dollars for the violations, some of which may date back 20 years and which left residents living in an unsanitary environment. The responsible parties, not their vulnerable tenants, should face the consequences, and the Outdoor Council has encouraged the regulatory agencies to work with the owners on a solution that is considerate of residents’ needs.

    If you want to chip in, you can help support residents of the park with a donation through their GoFundMe page. The funds will help tenants pay for alternative septic services or the cost of moving their trailers.

    RENEWABLES SITING GROUP BEGINS WORK

    The Outdoor Council is taking part in the Wyoming Renewable Energy Siting Collaborative, an effort organized by the University of Wyoming to study issues related to utility-scale wind and solar energy development. Members of the group represent a wide range of interests and will be working together on policy recommendations that would minimize conflicts with wildlife, viewsheds, and other resources.

    With sunny skies, plenty of wind, and a skilled workforce, Wyoming has great potential for renewable energy. But like all types of energy development, renewables projects can have unintended consequences if not sited in appropriate locations. A proactive approach to siting will help ensure future development is done right.