The Bureau of Land Management (BLM) in Wyoming has prepared a toolkit for estimating greenhouse gas (GHG) emissions from oil and gas development. The toolkit estimations should be completed by Wyoming operators and submitted to the BLM, so the provided data can be used for GHG analysis by the agency. This analysis is now a requirement in Wyoming for all Applications for Permit to Drill (APDs). In addition, GHG analyses will be required of all previously submitted pending APDs.
The Contreras Decision
This new requirement is in response to a court case brought by environmental groups that argued the National Environmental Policy Act (NEPA) review associated with oil and gas development on federal land in Colorado, Utah, and Wyoming was inadequate. The court ruled (in what is called the "Contreras Decision") that BLM had violated NEPA because it "failed to take a 'hard look' at greenhouse gas emissions" for 303,000 acres offered in lease sales in Wyoming. The judge remanded, but did not vacate, actions associated with the Wyoming sales back to BLM to satisfy NEPA obligations.
The Emissions Inventory Toolkit
The Wyoming BLM will use GHG emissions information submitted by operators to prepare the analyses required to comply with NEPA. The estimated GHG emissions submitted will be used to analyze direct and indirect GHG emissions from the proposed action, any action alternatives, and from reasonably foreseeable cumulative actions. The agency strongly encourages operators to include GHG data for all proposed actions on a well pad, and all proposed future wells (regardless of jurisdiction) on each pad, when submitting the first APD for a new multi-well pad. If a pending APD has been completed but is missing GHG data, a 30-day deferral notice will be sent to the operator requesting the required additional GHG information be submitted in order to complete the APD processing.
The toolkit is available on the BLM website; use the Quick Links on the right side of the page to select the "Emissions Inventory Toolkit". According to BLM staff, the most frequent problem users have encountered with the toolkit is forgetting to unzip the folder; make sure to complete this step first.
- In the unzipped folder, is a brief draft guidance document, which has step-by-step instructions
- When using the "Input Interface Revised 08-2019" excel file, make sure you enable macros before entering data; within this excel file are separate tabs for oil, gas, coal bed methane, and water wells
- BLM will use the information submitted in the O&G_Production_Schedule_Calcs worksheet in the Activity_Data_Needs folder to estimate indirect emissions, assuming 100% of the product will eventually be combusted
A review of the spreadsheets will be helpful to allow you to determine the data you will need to collect; including data related to:
- Anticipated production over the life of the project, including percentage of federal production for wells with multiple mineral estates
- Disturbed area and dust controls
- Equipment usage for road, pad, pipeline, and compressor station development, as well as drilling, completion, and workovers (horsepower, load, hours/days of operation);
- Vehicle travel
- Dehydration operations
- Heaters and equipment components (valves, pumps, etc.)
- Flaring and venting
- Storage and transport of oil, condensate, and produced water
Operators are required to include documentation describing how production was calculated and the assumptions used.
While this toolkit is currently only required for applications to drill in Wyoming, BLM offices in other states are considering how to evaluate GHG impacts of oil and gas development in light of the Contreras Decision.
If you have any problems or concerns with the toolkit, contact the BLM office in Cheyenne. Trinity staff also have a great deal of experience with air emission estimates and NEPA requirements. Please email Trinity's Wyoming office manager, Lori Bocchino, or call (307) 421-0021.