To promote development and multiple use of the
Minimize the size and location of surface disturbance.
Minimize the number of operators
within the
Design drilling activity to promote directional drilling and cluster drilling where possible to mitigate the impacts to wildlife, watersheds, and environmental and recreational values.
Avoid critical wildlife areas.
Avoid scenic locations, as agreed upon by the BLM and cooperating agencies.
Concentrate drilling activities in a way that provides for orderly development across the whole landscape.
Consolidate natural gas and oil production ancillary facilities, roads, pipelines and drill site locations.
Implement current state of the art reclamation and performance procedures based on monitoring standards. This would include, but not limited to, the BLM Surface Operating Standards for Oil and Gas Exploration and Development.
The Cooperators believe the BLM should include
stipulations on all leases that would require the successful bidders of
individual leases to join two undivided federal oil and gas units (north
and south Vermillion) that would include all of the acreage within the
Vermillion Basin (approx. 90,000 acres).
By creating two undivided federal units “upfront” after all leases are
offered and before exploration and production occur
would assist the BLM in controlling the pace of development and would provide
for a responsible and orderly development of the natural gas resource. Benefit of this concept is that all lease
stipulations or required mitigation are agreed to and known
by operators upfront. In
conjunction with this concept BLM would need to require a Unit Development
Plan, as well as an annual operations and reclamation report that industry
would be required to follow – and this would be known and available to all
stakeholders throughout the development of the federal units. By creating an undivided
units upfront, the expectations of how these units would be developed would
be clear and understood to industry, local community, the public and the BLM
from the beginning. This area is not presently leased by BLM for any portion within the
In general the Cooperators propose the following:
Simultaneous leasing of the
Stipulate that all successful bidders for leases would be required to immediately join the federal units covering all the 90,000 acres of the basin (approximately 45,000 acres each). By taking this approach multiple leases could occur but there would be just one operator, and as such, one set of pipelines, compressor stations and staging grounds, etc per unit.
Stipulate that there would be no
more than 1% total surface disturbance at any one time for the
Stipulate that surface disturbing activities would need to be approved on a case-by-case basis that would allow necessary flexibility to minimize impacts. BLM could implement a “zero” net new roads approach and still accommodate the recreation and multiple-use needs of the public.
Stipulate that drilling, where possible, within the federal units would be directional drilled or clustered (using directional drilling and more than one drilling site per well pad) in a manner so as to provide minimal impact on wildlife, watersheds, environmental, recreation values, and visual view sheds, etc. Clustering would reduce surface impacts from reduced number of well sites, roads, pipelines and ancillary facilities by focusing impact to one site versus several sites. Geology would certainly influence or dictate where this could occur. To facilitate responsible development from the very beginning, BLM should provide for an initial phase of exploration in which the unit operator identifies highest potential areas “sweet spots” within the lease block – the configuration, which would be drawn by the BLM in consultation with all necessary parties.
Ultimately, all phases of oil and gas exploration, drilling, completion, production and reclamation would be stipulated upfront.
Stipulate that any final
Stipulate that surface well pad density would be no closer than 2640 feet (based on 160 acre density) with reasonable flexibility for topographic factors and other land use considerations that could reasonably dictate where the actual location of a well site should established. This would support and encourage the directional/cluster drilling technology as a responsible mechanism by which the oil and gas resources could be recovered. Using distance rather than acreage would allow drill sites to be located where less environmentally intrusive.
Provide incentive to industry to achieve even less well-pad surface densities (i.e. 640 acres) over the life of the plan whereby the utilization of wildlife mitigation strategies (e.g. off-site mitigation, mitigation banking, habitat enhancement projects, etc.) and the effective implementation of performance-based reclamation would allow for a more streamlined and efficient permitting process.
Conclusion
It is recognized that