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Environmental Quality

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


This plan will protect Laramie’s drinking water. Add your voice today.

Posted on by Brandon Reynolds

Right now, Albany County and the City of Laramie are working together to update their plan for safeguarding the Casper Aquifer. This aquifer supplies slightly more than half of the drinking water for Laramie’s 31,000 residents, as well as all drinking water for nearby residents in rural Albany County.

The good news is that the consulting firm hired to update the aquifer protection plan has identified a number of new protections for drinking water that the Wyoming Outdoor Council supports. We’re preparing to submit our own, detailed comments, but if you’re a resident of the area I encourage you to send a brief message encouraging the city and county to adopt the recommendations for the Draft Aquifer Protection Plan.

SUBMIT A PUBLIC COMMENT

The Casper Aquifer Protection Area encompasses about 72 square miles that lie east of the City of Laramie, and is specially managed to prevent groundwater contamination. The Outdoor Council supports all the recommendations in the draft update, particularly that the city and county should:

— Prohibit livestock feedlots and commercial turf, such as golf courses, within the protection area. Both can contribute to groundwater pollution through runoff from nitrogen fertilizer and animal waste.

— Require consultation with a geologist or engineer prior to new development to identify geologic features like faults or springs that could serve as a conduit from the surface to the aquifer, confirm if development is appropriate in that location, and determine what protections might be required to do so responsibly.

— Add new strategies for managing possible contaminants — especially requirements for septic system inspections and maintenance, and expanding the network of monitoring wells to help detect pollutants before they contaminate drinking water sources.

The public scoping comment period closes at 5 p.m. Saturday, Oct. 8, so please send your comments today. If you have questions, feel free to reach out to me or visit the county’s website. We’ll keep you updated as the planning process proceeds, and let you know how and when you can get involved.

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


Beneath the Surface

Posted on by Brandon Reynolds

BENEATH THE SURFACE

The quiet work of watchdogging Wyoming’s water

Like the rest of the landscape, water in Wyoming is dramatic. Rivers carve through canyons, geysers erupt from below ground, reservoirs emerge from arid shrublands, and idyllic trout streams meander down from the mountains. And with water for agriculture and industry in limited supply, any conversation about water management is likely to turn heated. 

Clean water is vital to our health, economy, and quality of life in Wyoming — and to the fish, wildlife, and plant life that surrounds us. Protecting clean water is a core part of the Wyoming Outdoor Council’s mission. But with a few notable exceptions, it’s a quiet undertaking: Much of this work happens behind a desk or on the phone, pouring over technical documents to identify threats to water from industrial development or shifting regulations. 

The nitty gritty work of an advocacy group like the Outdoor Council is watchdogging government actions at the state level. This can involve reviewing proposed rule changes within the Department of Environmental Quality or actions by the legislature. Or we may focus on more discrete topics, like permits to allow companies to inject polluted water underground or to dispose of pollutants into bodies of water on the surface. Oftentimes, opportunities to review and comment on proposed actions escape the attention of citizens and other advocacy groups who can’t dedicate a full-time staff member to water quality. Fortunately, the Outdoor Council can serve this role. And we often work with partner groups around the state to divide and conquer, ensuring these issues have the attention they deserve. 

Reading public notices for draft wastewater discharge permits, proposed state agency rule changes, or legislative bill drafts is not what most folks consider exciting. Still, it’s essential: Sifting through these dense and technical documents is the front line of protection for clean water. Eventually we may show up at public meetings to ask tough questions. But if and when we decide to provide comments to regulators and decision makers on an issue and encourage citizens to do the same, we’ve done the legwork to identify and understand the problem and any possible solutions. 

The ability to engage with agency staff and lawmakers, and to access the draft permits and regulations as well as the underlying data, is critical. Transparency keeps government accountable to the public and gives everyday citizens the ability to take action. 

The Outdoor Council is working on some important water issues right now — like oilfield wastewater that’s flowing to Boysen Reservoir and could potentially be injected into the Madison Aquifer, and septic system rules and water quality planning in Teton County — but they weren’t dropped in our lap. We have to dig deep to uncover problems, bring them to the public’s attention, get agencies or decision makers to take a harder look or change their approach. It’s this work that often — but not always — yields positive outcomes. 

We’re a small staff with a broad mission, and we can’t read every permit — much less conduct an in-depth review. But we’ve found success in focusing on geographic areas that are particularly sensitive or vulnerable to pollution, and on specific issues we’ve worked with communities on in the past. The quiet work of watchdogging water helps Wyoming citizens make their voices heard, loud and clear.

Continue reading Beneath the Surface →

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


Risks must be addressed before “advanced” nuclear reactors come to Wyoming

Posted on by John Rader

Risks must be addressed before “advanced” nuclear reactors come to Wyoming

Wyoming’s energy sector is a critical element of our state’s economy, providing revenue for public services and good-paying jobs that support our communities. Most of the energy we produce is exported and, as such, our energy economy is heavily influenced by the global market, which is rapidly turning towards decarbonization. Nuclear energy is a carbon-neutral power source, one that the federal Department of Energy considers critical for combating climate change. But boondoggles in other states and countries demonstrate that the new, untested technologies supported by the federal government pose economic, environmental, and safety risks that must be thoroughly considered before “advanced” nuclear reactors are constructed in Wyoming. 

Elected officials in Wyoming have voiced support for an experimental nuclear power plant known as the Natrium project, proposed by Rocky Mountain Power and TerraPower, a nuclear design and development firm founded by Bill Gates. 

Gates, Gov. Mark Gordon, and U.S. Department of Energy Secretary Jennifer Granholm unveiled the proposal to much fanfare this June, touting the potential for diversifying the state’s energy economy and job market while adding zero-emissions power generation to the grid. The reactor is planned to be built on the site of one of several coal-fired power plants that Rocky Mountain Power’s parent company PacifiCorp plans to close in the coming years — in the communities of Kemmerer, Rock Springs, Glenrock, and Gillette. It comes with a $1 billion minimum price tag (capped at a potential $4 billion), half of which will be funded by the federal government, and is a sodium-cooled fast reactor that uses molten metal rather than water as coolant. The developers want to have the plant in service by 2028. 

Some elements of the proposed project are sound. Building the demonstration reactor on the site of an existing coal-fired power plant reduces the need to disturb undeveloped land. Equally important, taking advantage of existing electrical transmission lines will minimize impacts on the surrounding land, simplify the permitting process, and avoid potential conflicts with private landowners. And endeavoring to train and employ local workers could provide a new source of economic stability in coal communities. 

But there are reasons to question the hype around this project. 

Economics

Natrium is not a silver bullet to solve Wyoming’s economic woes. While nuclear plants could fill some gaps in the workforce left by closing coal-fired power plants, they would not replace the mineral royalties that provide the bulk of funding for state services, local governments, and schools. Revenue for the state would come from taxes on the electricity that is generated, and TerraPower and Rocky Mountain Power have already approached the Wyoming Legislature seeking tax cuts. 

Nuclear power is expensive and getting pricier, while other existing, properly-vetted energy technologies are already cheaper than coal and continue to become more affordable. Between 2009 and 2020, the cost of solar power generation went down by 90 percent and the cost of wind energy declined 70 percent. Natural gas also became more affordable. Meanwhile, the cost of electricity from coal stayed largely stable and the cost of nuclear power increased by 33 percent. 

Around the country, other advanced reactor projects have invariably been over budget, years behind schedule, and underperforming — if they work at all.

  • Duke Energy abandoned a recent nuclear energy project with an estimated cost of $5 billion when costs ended up exceeding $22 billion, but not before the Florida Public Service Commission approved passing on $800 million in excess costs to ratepayers for a project that never produced a kilowatt of energy.
  • South Carolina’s Public Service Commission approved a massive nuclear energy project at a cost of $9 billion. The project was ultimately abandoned, never producing energy and leaving ratepayers to pick up the tab.
  • The Vogtle plant in Georgia — currently under construction and six years behind schedule — had an estimated cost of $14 billion but costs have now soared to at least $26 billion. In mid-October that state’s Public Service Commission struck an agreement allowing Vogtle to pass on $2.1 billion in construction costs to ratepayers. 

The seven-year timeline for completing the Natrium project is ambitious in itself. Combined with the many additional hurdles the developers face — scaling up an unproven technology, conducting an environmental review of the yet-unknown location, the potential need for state lawmakers (who have their own concerns) to pass legislation to facilitate the project — delays seem all but inevitable. As we’ve seen, that means higher costs. 

Safety

Sodium-cooled fast reactors are theoretically less prone to meltdown than conventional nuclear reactors because they use liquid metal as coolant, rather than water. Sodium’s boiling point is higher than the reactor temperature, meaning the coolant can never boil or vaporize and the system does not need to be pressurized. But there’s a catch: Liquid sodium catches fire if exposed to air or water. Sodium-cooled reactors in other countries have experienced leaks that have led to fires and shutdowns, including the Monju project in Japan and the Superphénix in France.

The Nuclear Regulatory Commission is looking to streamline public processes for advanced nuclear projects, including safety and environmental reviews. The agency is considering a “generic” environmental impact statement for all advanced nuclear reactors across the country, rather than reviewing specific sites in detail. We shouldn’t be cutting corners on health and safety to rush through an untested technology, and Wyoming’s harsh climate and seismic activity underscore the need for site-specific reviews. It’s also important to note that the NRC is considering placing advanced reactors in rural areas as an added “safety” measure so fewer people would be harmed in the event of a catastrophe. 

Nuclear power plants must store all their waste on site, encased in concrete casks. Yucca Mountain in Nevada was identified by Congress in 1987 as the nation’s permanent underground nuclear waste repository, but it was never constructed and all progress has been halted for more than a decade. No state in the U.S. is willing to accept long-term or permanent storage of spent nuclear fuel — and the Wyoming Outdoor Council and our members have long opposed legislative proposals that would allow Wyoming to accept and “temporarily” store spent fuel rods. Our advocacy and a multitude of citizen voices resulted in the defeat of the legislature’s most recent storage proposal in 2019. 

Initially, TerraPower suggested that it would implement a “breed and burn” reactor that would effectively recycle its own waste by accepting depleted uranium. The company has since changed plans to a more conventional “once through” approach that would create more waste. And, even if a “breed and burn” reactor was used, it would take hundreds of years to recycle a significant portion of the fuel. 

Questions remain

Generally, the Wyoming Outdoor Council supports diversifying our energy sector and addressing decarbonization, both to combat climate change and shore up our state economy that for too long has been dependent on volatile fossil fuel markets. But we are skeptical of unproven, fast-tracked technologies that rely on taxpayer funding to be economically viable. And we are unwilling to gamble with this level of risk to the environment, public health and safety, and Wyoming’s ratepayers. 

Nuclear power will continue to play a role as U.S. utilities move toward zero-emissions energy, and there is the potential for new, advanced nuclear plants to complement renewables like wind and solar that are rapidly being added to the grid. The Natrium project itself has the potential to help at least one Wyoming community stay strong in the face of a coal plant closure. But there can be no half measures if Natrium is to become a reality. The people of Wyoming must have thorough, site-specific safety and environmental reviews before this experimental project moves forward. Ratepayers need to be protected from runaway construction costs. And all of us, especially our elected officials, need to remember that building a single power plant is not the silver bullet that will diversify Wyoming’s economy and provide a good quality of life for future generations. 

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


    Field Notes: February updates from the Wyoming Outdoor Council

    Posted on by Alan Rogers

    NITRATE RULE SETBACK

    In a disappointing move, the Teton District Board of Health declined to adopt a proposed rule that would alert residents when increasing levels of harmful nitrates are detected in drinking water. The rule, drafted by the Wyoming Outdoor Council and Protect Our Water Jackson Hole, would have required the county health department to notify the public when elevated levels of nitrates are detected in any of the county’s 114 public water systems and investigate the source of the pollution.

    While this is an unfortunate delay, the residents of Teton County have made it clear that clean, safe drinking water should be a priority in their community. Together with our partners, the Outdoor Council will continue working with county officials to enact this important safeguard. 

    OIL AND GAS LEASING

    In late January, the Biden administration announced an executive order pausing new oil and gas leasing on public lands so the Department of the Interior can conduct a “rigorous review of all existing leasing and permitting practices related to fossil fuel development on public lands and waters.” 

    The oil and gas industry is an important part of Wyoming’s economy and, when done properly, development has a place on our public lands. However, the federal leasing program is decades out of date. We’ll continue to push for common-sense leasing reforms that will place the many other uses and values of our public lands (like wildlife habitat, historic cultural sites, and outdoor recreation) on equal footing with development, while also ensuring a fair return for taxpayers. Importantly, we want to see an end to noncompetitive “over-the-counter” leases as well as leasing of lands with low potential for producing oil and gas.

    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.