(Editor’s Note: This is the third 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 soon and the final record of decision issued by year’s end. The draft EIS lists the preferred alternative as full development, which is alternative B.)

When the haze gets bad, you can’t see Laramie Peak from Douglas. The horizon along Wyoming Highway 59 takes on an unnatural blur, and the outlines of pump jacks and compressor stations grow fuzzy from dust and emissions. You probably don’t drive the rural roads of northern Converse County often, but when you do, you can’t help but notice the haze during some times of the year.

Those who have lived here for decades haven’t only seen the effects of air pollution with their eyes. They’ve felt it in their lungs.

If the Bureau of Land Management selects its preferred alternative to allow 5,000 new wells over 10 years, the pollution levels in the air here will more than double, according to the Converse County environmental impact statement.

The BLM claims in the EIS that those emissions will only occasionally exceed national ambient air quality standards. The EIS states that when construction of proximate, multiple-well pads overlaps, PM10 (inhalable particles) could exceed NAAQS by 329 percent.

Several agencies have expressed concern that the modeling used within the EIS could lead to an under-prediction of emissions.

And some ranchers worry that excessive dust will make their livestock sick.


For Converse County ranchers, dust is the most serious airborne pollutant. During dry months, traffic along roads kicks up particles that can sicken livestock and render critical pastures inedible. The EIS states that if development proceeds according to the preferred alternative, traffic is expected to increase by between 16 percent and 1,319 percent on Wyoming Highways 59, 93 (Ross Road) and 95. With the possibility of truck traffic growing more than tenfold, the county is likely to get dustier.

Sen. Brian Boner, R-Converse, expressed his support for the project, but said that, as a rancher, he knows dust can cause problems.

“Gosh, two years ago we got our cows and our yearlings from a pasture that had a road being constructed and you could tell that they had significantly more cases of pneumonia,” he said. “It was manageable, but we had to treat more cows that year.”

Other ranchers have experienced similar difficulties. Tammy Delyea of the Irene Ranch on Highland Loop Road said she has to work around dust and take special caution to keep her cattle away from dusty areas. When working cattle, she said she waters down corrals, but along county roads the dust can be more than a mere nuisance.

“The dust on that (Highland Loop Road) is so bad that it makes it really hard to use that land around the county road,” Delyea said. “It really cuts into my profits.”

She explained that dust on private roads tends to be less of an issue because ranchers negotiate agreements with operators, who are then legally obligated to keep the roads watered regularly in order to suppress dust.

Delyea explained the difficulty of grazing her cattle on dusty land.

“Imagine a salad, and somebody dumped a bucket of dirt on it,” she said. “Think about what that does to your teeth and how well you digest it. The cattle don’t want to eat it, but sometimes that’s all there is.”

Carolee Hornbuckle, a northern Converse County rancher, noted that Jenne Trail – County Road 34 – can become hazardous at times because of the swirling dust.

“The dust there was so bad, and it was semi truck after semi truck after semi truck,” she said, referring to a day in mid-August. “I literally could not see where I was going.”


The Wyoming Department of Environmental Quality, the agency to which the EPA delegates its authority in Wyoming, expressed concern regarding some estimates presented in the EIS.

“They (our comments) were particularly around the modeling and data inputs and the modeling results,” said WDEQ Natural Resources Program Manager Brian Hall.

The WDEQ, which worked with the BLM on the draft EIS, said its Air Quality Division submitted those comments on the draft in February of 2018, but they were not posted on the EIS public comments page. The Douglas Budget submitted a public records request in late August to view those documents but did not receive them. The WDEQ says they are waiting for the Wyoming Attorney General to grant them permission to release the comments. The WDEQ comments on groundwater and surface water concerns, however, were posted online.

In the EIS comments, experts and agencies expressed concerns that the county lacks sufficient air quality monitoring. The WDEQ has one air quality monitoring station in rural Converse County near the Smith-Highland Ranch and one in Casper, compared to five in the Upper Green River Basin/Pinedale area. The UGRB monitor stations went online between 2005 and 2011, and the Converse County site started monitoring in 2015, replacing the Converse County Mobile Monitoring Station, which began operating in 2012.

The Environmental Protection Agency expressed concern with the BLM’s modeling, stating that it presents a “likely under-prediction of air quality impacts.”

The Environmental Defense Fund, a private environmental protection group, expressed the same concern regarding underestimation and also accused the BLM of writing an EIS “rife with inaccuracies regarding emission reduction federal requirements applicable to new wells.”

On top of that, the EDF charged the BLM has not suggested any mitigation in the event of air quality issues.

“Despite the significant amounts of estimated pollutants from the project, BLM has proposed zero control strategies,” the EDF said.

The EPA had a similar concern and commented that the data used to generate the models within the EIS are outdated. For instance, compressor stations and gas plants built since the BLM’s analysis will be significant pollution emitters. Had those new facilities been considered, the models would have predicted different results.

The BLM did not respond to the Budget’s repeated requests but stated in the EIS that it does not believe the rises in airborne pollutants will pose a serious health risk. The BLM does not provide extensive interpretation of its projections and modeling beyond stating that air quality standards will, in general, comply with ambient air quality standards set at the federal level by the Clean Air Act and enforced by the WDEQ.


Like the EPA, environmental groups including the Powder River Basin Resource Council, Wyoming Outdoor Council, The Wilderness Society and Audubon Society have been outspoken in their concerns with the EIS. PRBRC Executive Director Jill Morrison believes that the county could see significant reductions in air quality if the BLM does not amend its plans.

“They admit in the document, it (the air pollution) is going to exceed air quality standards,” she said. “And these are things that make people ill.”

Morrison argued the BLM is “not even going to meet the legal standard, let alone the higher standard.”

The PRBRC is already attempting to get the state to improve upon its leak detection and repair requirements for oil and gas. It would like to see the air quality standards used in the western part of the state in the Jonah Field included in Converse County’s EIS.

A joint letter by the Audubon Society, The Wilderness Society and the Wyoming Outdoor Council said that alternative B – the BLM’s preferred alternative for development -- “presents a number of grave air quality concerns” and proposes inadequate monitoring and mitigation measures. These groups believe those shortcomings will pose significant risks to Wyoming’s environment and the health of state residents.

“By the (BLM’s) own analysis of monitoring data obtained from the USEPA air quality system for six Wyoming Department of Environmental Quality monitoring stations, portions of the Converse County Project Area will exceed ozone thresholds and be in noncompliance with both (National Ambient Air Quality Standards) and (Wyoming Ambient Air Quality Standards) upon the October 1, 2018, deadline,” Audubon wrote.

The group wrote that the EIS fails to comply with the Clean Air Act and state air quality standards. Its comment points to a “troubling lack of risk analysis and mitigation for volatile organic compounds” in the EIS.

The PRBRC’s qualms with air quality don’t end with the health components. The financial implications in the preferred alternative involve flaring, the burning of gas at the wellhead. Environmental groups and government officials alike express concerns over the amount of flaring allowed in alternative B.

“BLM completely failed to disclose how much impact and waste is going to occur from not capturing all the emissions and all the vented and flared gas,” Morrison said.

She believes Wyoming will lose millions of dollars by allowing the flaring of natural gas. The BLM had an obligation to calculate and disclose the value of that lost revenue, she insisted.

The Audubon group estimates that the state will lose just under $150 million in royalty and tax dollars over the life of the project if the BLM fails to add an effective flaring plan to the final EIS.

The BLM dismissed a flare-less alternative as being unfeasible and did not include an estimate of revenue lost due to flaring.


Dr. Robert Field, a professor of atmospheric science at the University of Wyoming, has been a leading expert on air quality as it pertains to oil and gas projects in Wyoming. He studied air quality and ozone at the Jonah Field until the Wyoming Department of Environmental Quality halted funding of his work in 2012, right before he was to embark on a winter ozone study. That decision by the WDEQ was received with considerable frustration by some Sublette County residents. In addition to teaching at the University of Wyoming, he also holds a contract with the BLM.

Field does not believe Converse County will see air pollution effects at the levels experienced in Pinedale, in part because Converse County sits in an advantageous wind corridor.

“For similar critical conditions to occur in Converse County, it is my estimation that there are insufficient emissions, inappropriate meteorological conditions and geography to lead to such episodes,” Field said. “However, we must always err on the side of caution.”

Field also believes that ozone levels would remain below dangerous levels in the event that the BLM selects alternative B, though he agreed that there is not enough monitoring of the area.

“My measurements in Converse County reported ozone precursor levels generally much lower than similar measurements in the Upper Green River Basin,” Field said.

That does not mean that ozone is not a concern. Field also noted that besides being concerned about ozone and small particles suspended in the air, it is important, when considering oil and gas emissions, to be mindful about exposure to benzene, a carcinogen that can cause leukemia. He said that emissions of methane and associated volatile organic compounds, including benzene, from oil and gas developments are reduced with good air pollution control measures, in particular when supported with leak detection and repair programs.

The WDEQ does not require quarterly leak analyses in Converse County, although it is proposing a change in its fugitive emissions requirements, necessitating biannual analyses statewide.

Field said the best way for residents to avoid health hazards is to reduce exposure. Assessing what qualifies as safe or unsafe is difficult when discussing toxic air pollution, he explained. Individuals should always consider their personal exposures, the way they do with smoke, tobacco and traffic fumes. All of those pollutants contain benzene and particulates, but in potentially lower amounts compared to oil and gas development sources.

The EIS also states that county lands will potentially see some degree of degradation as a result of nitrogen deposition.

“The predicted high levels of nitrogen deposition could have long-term effects causing increased soil acidification at areas within and surrounding the CCPA,” the EIS states.

For more detailed potential pollution increases, see the graphic included with this story.


Chief Medical Officer for Memorial Hospital Dr. James Morgan said that, in general, he sees more respiratory illnesses when activity increases, particularly among those with chronic obstructive pulmonary diseases.

“I wish we had more reliable measurements and reporting on exactly what is found in our air,” Morgan said. “I haven’t seen it publicized, and I’m the county health officer.”

That lack of data makes it difficult to talk definitively about the correlations between industrial activity and health.

Shannon Anderson, the PRBRC’s lawyer, pointed out that Converse County’s air is already far from immaculate.

“There’s already been a lot of development,” she said. “Converse County ozone is already somewhat of a problem . . . (we’re) very concerned that BLM isn’t really taking a hard look at the air impacts.”

She also pointed out that the modeling provided in the EIS amounts to nothing more than a best guess on what will occur.

While modeling can be valuable in providing a general projection of future air quality, monitoring is key for understanding the extent of real air quality effects. Much of the baseline testing of Converse County air quality began during the last boom, not before it, which is important to consider given the past four years make up the WDEQ background baseline data.

The WDEQ argued it has sufficient monitoring in place with its Converse County station and doesn’t anticipate sending another mobile air quality monitoring van here, as it did in 2012, WDEQ Air Quality Monitoring Supervisor Cara Keslar said.

“We’re going to take a look at the Converse County monitor and how that responds to the development,” Keslar said. “We do a network assessment every five years and the next one is due just at the beginning of 2020. So when we’re preparing that, we will look at that 5,000 well development and take a look to see if something else is needed.”

PRBRC’s Anderson worries about the likelihood of enforcement and mitigation if Converse County’s air quality degrades.

“What we really need is good monitoring, good enforcement and good analysis going forward and realizing if we do start to exceed these air quality standards, what’s the check on that and how do we correct things going forward?” Anderson said. “BLM doesn’t really lay out a good plan for that.”

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