(Editor’s Note: This is the second of a five-part series examining the conclusions in the Bureau of Land Management’s draft environmental impact statement regarding the proposed development of 5,000 oil and gas wells in Converse County during the next 10 years. The BLM hopes to have a final EIS released this month and Record of Decision issued by year’s end. The draft EIS lists the preferred alternative as full development, which is alternative B.)

Some Converse County ranchers worry about water almost constantly. With Converse County’s oil and gas development expected to more than double in the next few years, some ranchers positioned in the hub of proposed activity fear that the loss of billions of gallons of water used for fracking might directly harm their livelihoods.

The BLM’s environmental impact statement analysis for some of that oil and gas activity seems less than complete, mostly because, the BLM admitted, it doesn’t have accurate and current water data. 

 “It’s an obscene amount of water … just the sheer amount they’re proposing – 6,500 wells in five years.  I can’t even compute all the zeros,” said Stirling Moore, a rancher at the W.I. Moore Ranch. “The water is my biggest concern.”

The BLM’s oil and gas EIS for Converse County relies on data provided by the operator group — the group of companies proposing the development — as well as expected use. The EIS states each well would use about 13.1 acre-feet (4.25 million gallons) of water annually. The operator group estimates that 12.4 acre-feet of that water would come from groundwater drawn from aquifers, while the rest would come from surface sources. An acre-foot of water is the amount of water needed to submerge an acre of land 1 foot deep.

The operator group estimates it would need 7,000 acre-feet per year — almost 2.3 billion gallons of water — for the project, if the BLM selects the group’s full development proposal, which is alternative B in the draft EIS. That figure does not include water needed for dust abatement, or water required for existing development drilling outside of the operator group proposal. Existing development is estimated to need 2,250 acre-feet annually, meaning operators would require a minimum of 92,500 acre-feet of water — 29.9 billion gallons of water — in the first 10 years of development. For comparison, a 2005 study reported that the City of Douglas uses about 1,241 acre-feet annually.

The Moores question those data, not because industry provided them, but because state agencies say they’re outdated. 

“The water data that was used was from 2010,” Marel Bunker, part of the Moore’s legal team, said. “That is quite old. And (the BLM) said, ‘Well, production increased, but then it decreased again, so it should still be fairly accurate.’ That’s not the case at all.” 

Fracking methods have changed since the EIS was drafted, and because of that the modeling in the EIS does not take into account those technological advances. Bore sizes for wells have grown bigger, and larger bores require greater amounts of water to frack, opponents claim. 

“We’ve heard from quite a few sources that the state is not going to approve any more water wells and they’re not going to approve any more injection wells,” Bunker said. “This plan is dependent on them drilling 50 new water wells, so that’s a pretty big deal.” 

That would bring into question how the operator group plans to acquire the water it needs for drilling. The companies currently purchase much of their water from private landowners and, in the past, from the City of Douglas, which can be lucrative for sellers. 

“Most of the people around us sell water,” Moore said. “We don’t. That’s something that we’ve never done, and we don’t plan to do it.”

Converse County Commissioner Jim Willox, the county’s lead for the EIS, also charged that the EIS falls short in its water analysis. 

“I don’t know if they got the numbers quite right for the volume of water, and we’ve commented on that,” Willox said. “I do believe that the EIS didn’t do as good a job as it could have on the water.”

In the commissioners’ comments on the draft EIS, they expressed a concern that the activity might affect groundwater availability in private wells and requested that a mitigation guideline be established in order to protect private landowners in the event of depletion. 

“We are concerned with the amount of water that would be extracted from aquifers and the potential impacts on private domestic and livestock wells,” the commissioners said. “We are concerned that (site-specific) evaluations may not capture a cumulative or long-term impact on these private wells.” 

In addition to concern over groundwater supply, there are concerns about availability of resources for produced water disposal. Produced water is the contaminated water extracted with oil and gas during fracking and disposed of either by allowing it to evaporate in open-air pits or by injecting it below ground. The EIS proposes the drilling of more injection wells and disposal sites to accommodate increased disposal demands. 

Not everyone agrees that water will be a huge long-term issue. The BLM states in the EIS that any issues would be short-lived, with aquifers being replenished within 20 years. 

State Sen. Brian Boner, R-Converse, said, “I’m confident that they (operators) have learned a lot, being in Converse County over the last few years. It’s going to be a challenge but one that’ll be manageable.”


According to the EIS, industry is currently the largest user of groundwater in the Converse County Project Area, accounting for approximately 68 percent and 75 percent for the Cheyenne and North Platte River basins, respectively. If the BLM selects its preferred alternative (B), groundwater use in the CCPA will increase by 46 percent. Alternative C would require 40 percent less water than B because it requires the implementation of water recycling. The county does not have water recycling, but operators anticipate it. Devon Energy are scheduled to meet with the Converse County commissioners about a new facility Sept. 5.

The operator group plans on drawing most of its supply from 70 existing water wells. The EIS says that those wells are authorized to produce up to of 12,400 acre-feet annually, while the operator group will only need 7,000 acre-feet annually. In the event that the available wells are found insufficient for the operator group’s needs, an additional 50 water wells would be drilled to meet demand, the EIS states. Those wells would increase groundwater capacity by 8,050 acre-feet. They would be expected to tap into the same aquifers being used by ranchers, cities and other oil and gas producers. 

“We’re all pulling from essentially one aquifer,” Moore said. 

The State Engineer’s Office, the agency in charge of permitting water wells, would have the ability to deny new water well applications if it determined that they did not represent a beneficial use. The SEO frequently denies permit applications when it has concerns about local depletion. 

The BLM believes that any impacts on groundwater resources, such as a lowering of aquifer levels, would be relatively short-lived. They write, “drawdown would reach a maximum after 10 years of pumping and then return to pre-pumping levels after 20 years of recovery.”

In localized zones around some wells, depletion may be substantially greater and recharge may take longer. The EIS admits that some areas will see depletion of 40 feet or more, and that “the impact of withdrawal would be irreversible because the rate of aquifer recharge is unknown.” 

Karl Taboga, a Wyoming State Geological Survey hydrogeologist whose work frequently appears in the EIS, said that the 40-foot drawdown is an accurate projection. 

“The projected drawdowns of 40 feet or less in limited areas around all water supply wells but one (which would have around 100 feet of drawdown) seem to be reasonable estimates,” he said.

Taboga explained that recharge occurs rapidly once pumping stops but slows after an initial rebound. 

“In a well with a 40-foot drawdown, water levels may recover by 50 percent (20 feet) in the first three years following the cessation of pumping and then take hundreds of years to recover the remaining 20 feet,” Taboga said. 

The Environmental Protection Agency expressed concerns about the BLM’s calculations, writing, “The maximum groundwater extraction rate (8,000 acre-feet) freshwater supply per year listed in the draft EIS is greater than the 7,000 acre-feet per year maximum that was used in the groundwater model.” 

That discrepancy between the actual numbers and the data used in the modeling would appear to call the BLM’s projected drawdown rates into question, and the EPA pointed out that drawdown may be significantly greater when taking the actual groundwater extraction rates into account.

The EPA expressed concern that the BLM’s estimates could fail to protect groundwater wells, surface waters and groundwater dependent ecosystems, writing that the preferred alternative “may result in a substantial underestimation of both the magnitude and extent of drawdown caused by pumping.” 

Despite the variability and uncertainty surrounding recharge rates, the BLM expresses little to no concern about aquifer depletion, stating that industry will only use a fraction of the annual available resource. 

The Converse County Conservation District, contradicting the EIS assertion, wrote in a comment that it does “not consider groundwater impacts to be ‘negligible’ when the withdrawal of groundwater will be an irretrievable and irreversible commitment of the resources.”

If the proposed development causes wells to run dry, the experience won’t be new to ranchers, many of whom have already had to drill expensive, new wells.

“We’ve seen already in the past few years having to drill deeper and deeper to find water,” CCCD Manager Michelle Huntington said.

Unsurprisingly, development and depletion tend to happen in the same areas. Huntington noted that many of the wells that have run dry are “north of town, where all the activity’s occurring.”


The BLM acknowledges in the EIS that its understanding of available groundwater resources is limited. Describing groundwater resources, the EIS reads, “This section provides a general review of the groundwater resources in the CCPA. Given the large size of the area, the natural variability within the aquifers, and the available data, this discussion is meant to provide only a general description of groundwater conditions.” The EIS also states, “Groundwater flow in the entire CCPA is not well documented due to a lack of monitoring wells,” citing a 2017 Taboga paper. 

In her letter to the BLM, rancher Frankie Addington wrote, “This EIS acknowledges that there are few to no monitor wells in the EIS area. This results in all information contained in the EIS in regard to the amount of groundwater being nothing more than a guess.”

Not only are the monitor wells few in number, they’re concentrated in areas of existing oil and gas development, but much of the oil and gas proposal would occur in less developed lands. 

“The monitor wells are not well distributed in the CCPA but concentrated in central Converse County,” Taboga said. “The monitor wells may not be owned by the companies involved in the CCPA and thus not accessible for their use.”

The Moores live in northwestern Converse County, by the Campbell border, an area expected to see much of the new development. 

The State Engineer’s Office (SEO)  has not conducted an analysis on groundwater supply in the CCPA “in order to validate the sustainability of appropriated groundwater,” the EIS states. 


Shortcomings of the BLM’s analysis of water availability are not limited to errors, a reliance on old data and a lack of monitor wells. The BLM also has a dispute with the SEO about the designation of the Wasatch and Tongue River aquifers, which provide much of the area’s water. The SEO believes that the two should be referred to as separate, not a single aquifer, and expressed its concern in multiple comments to the BLM. 

“It’s very possible that the analysis that went into the EIS is drastically underestimating (water usage),” said Beth Callaway, River Basins Coordinator at the SEO. “It sounds like we’re at an impasse.” 

The Wasatch is the shallower and younger of the two. By lumping it and the Tongue River together and considering them one unconfined aquifer, the BLM could be overestimating the availability of groundwater. 

“If you look at them together, you could target all of that for water production, that would also change some gradients maybe, and allow higher quality water to mix with maybe some lower quality water,” SEO Groundwater Specialist Jeremy Manley said.

Considering the two as one — and not recognizing the differences between them — could limit ranchers’ abilities to provide water to their livestock by leading to greater than expected drawdown, opponents and the SEO agree. 

“Potentially, it could,” Manley said. “Quite a few of the shallower, older wells are Wasatch completions. But it kind of really depends on where you’re at.”

Taboga argues the greatest impacts would be most likely in Ft. Union formation - which includes the Wasatch and Tongue River - water supply wells.

“Ranchers should make sure that their Surface Use Agreements with the energy companies address these potential impacts to their livestock operations,” he said. 

The BLM disagrees with the SEO’s determination and has decided to continue referring to the Wasatch and Tongue River as a singular aquifer.

Manley said that the SEO is concerned with water availability throughout the state. 

“I will just say generally, we have a big concern statewide, when we have a large potential for development of an aquifer system,” he said. “It’s not only geared toward Converse County.”


Private landowners are mostly on their own when it comes to negotiating water agreements with operators because the BLM’s regulatory measures regarding water resource protection only apply to federal lands. 

“In most cases, it’s only going to pertain to the federal estate, whether that’s the federal mineral estate or surface,” Manley said. 

Municipalities aren’t immune to the effects of water shortages, even though the strains on city water resources differ from those felt by ranchers. 

City of Douglas Water and Wastewater Chief Operator Supervisor Josh Oberlander said he has concerns about the city’s ability to provide water to residents if populations spike. 

“Water within the next 15 to 20 years is going to become one of our most valuable resources,” Oberlander said. “I think the days of ultra cheap energy, water, and infrastructure are going to come to an end.” 

The county commissioners also expressed concerns about demands on municipal supplies. The EIS also lists that as a concern: “Demands under alternative B could exceed the effective delivery capacity of some municipal and regional systems during periods of peak demand.” 

In their comment letter to the BLM, the commissioners wrote, “This is a real concern. What would these municipal water providers really be able to do to meet demands, especially in peak periods? What would the impact to customers be from these actions?”

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