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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />76 <br />analysis of GHG mitigation measures applicable to the Uncompahgre RMP. In particular, Table <br />V-I identifies Best Management Practices and Air Emission Reduction Strategies for Oil and Gas <br />Development, which displays some emission reduction measures, their potential environmental <br />benefits and liabilities, and feasibility. These methane measures are applicable to all new oil and <br />gas development and are not dependent on conditions in leasing areas or site-specific conditions <br />for individual APDs or MDPs, so they may and should be identified and required at the RMP <br />stage. <br /> <br /> The RMP/EIS, at 4-28, identifies several mitigation measures that are “assumed” to apply <br />to all alternatives and that would address methane emissions and waste: <br /> <br />While the levels of oil and gas development differ by alternative, emissions <br />controls were assumed to be the same for all alternatives, as follows: <br /> <br />• Drill rig and completion engines that meet or exceed Tier II engine <br />emission standards as defined in 40 CFR Part 89 <br /> <br />• Fugitive dust control from pad, road, and pipeline construction using <br />frequent watering and speed control with an assumed control efficiency of <br />50 percent <br /> <br />• Control of waste gas from well stimulation and completion assuming 90 <br />percent capture of all vented emissions, then 50 percent sent to flare and <br />50 percent sent to “green completion” <br /> <br />• 100 percent of drilling/completion fluids are delivered and disposed of by <br />truck <br /> <br />• 88 percent well pad tank emissions are captured and flared at conventional <br />gas wells; no well pad tank control is assumed for coalbed natural gas <br />wells <br /> <br />• 100 percent disposal of produced water and condensate is by truck <br /> <br />Measures identified in the CARPP (Appendix H) target sources of methane emissions <br />that contribute significant amounts of waste from natural gas production, processing and <br />transmission, and include pneumatic devices, compressors, liquids unloading, pipeline <br />maintenance and repair, and equipment leaks. Measures to control emissions and waste from <br />these sources include: <br /> <br />• Reducing the pace of development or phasing development to ensure that <br />methane can be used in the field or that gathering, boosting and processing <br />infrastructure is in place to get gas produced to a sales line; <br /> <br />• Requiring natural gas-fired drill rig engines; <br />