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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />78 <br />• Quarterly inspection of leaks with optical gas imaging and immediate repair <br /> <br />In BLM’s proposed methane waste rule, there are many sources of methane emissions <br />from oil and gas development that are identified and a few significant sources that are not <br />included. The proposed rule also includes widely recognized methane emissions mitigation <br />measures and best management practices (“BMPs”). The sources of methane emissions which <br />will be present within the area of development, and the mitigation measures available, must be <br />considered by BLM in its analysis of the proposed action. <br /> <br />Important sources of methane emissions include: <br /> <br />• Well drilling <br />• Well completion <br />• Production testing <br />• Pneumatic controllers <br />• Pneumatic pumps <br />• Separators and dehydrators <br />• Compressors <br />• Pipelines <br />• Storage tanks <br />• Liquids unloading <br />• Leaks <br />• Associated gas from oil wells <br /> <br />A key area of concern to Conservation Groups is the effectiveness of the mitigation <br />measures adopted to ensure that methane is captured and able to make it to market for sale and <br />not be vented or flared. Such considerations must be included in the agency’s NEPA analysis. <br />This includes, inter alia, how the agency will assess whether the gathering and processing <br />investments proposed are adequate. That is, the agency is obligated to identify and describe how <br />the infrastructure investments identified in the EIS (i.e., gathering pipelines, compressor stations <br />and processing facilities) will be located and adequately sized to accommodate estimated levels <br />of production of natural gas for the duration of the proposed project. <br /> <br />Notably, at least one BLM Field Office has already taken pioneering steps to address <br />methane emissions and waste through mandatory mitigation measures at the RMP stage. <br />Specifically, in a joint Land and Resource Management Plan (“LRMP”), BLM: 1610 (CO-933), <br />adopted by BLM Colorado’s Tres Rios Field Office (“TRFO”) and the San Juan National Forest <br />(“SJNF”), the agencies broke new and essential ground in both acknowledging that significant <br />GHG pollution would result from oil and gas development on TRFO lands, and then establishing <br />required methane mitigation standards at the planning stage that will bind future leases and <br />permits to drill to comply with these measures. Given that the TRFO is directly adjacent to the <br />UFO, including shared geologic formations and mineral resources, it is arbitrary and capricious <br />for BLM here to ignore or not adopt mitigation measures consistent with those included by the <br />TRFO. At the very least, BLM has an obligation to explain why such measures are not applied in <br />the Uncompahgre planning area, which it has failed to do. As provided in the Final EIS for the <br />TRFO LRMP: