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How unseen emissions continue to impair air quality in Wyoming’s Upper Green River Basin

MORE THAN MEETS THE EYE

HOW UNSEEN EMISSIONS CONTINUE TO IMPAIR AIR QUALITY IN WYOMING’S UPPER GREEN RIVER BASIN

Whether you ranch, farm, hunt, fish, or ski, there is a season for most things in Wyoming. But there are some seasons that we could do without. Topping that list is “winter ozone season” in the Upper Green River Basin of Sublette County.  

For nearly two decades, the Wyoming Outdoor Council and Pinedale-based Citizens United for Responsible Energy Development (CURED) have been actively working to improve winter ozone conditions in this region, which is home to the state’s largest natural gas fields. This seasonal phenomenon typically occurs when the right combination of weather patterns, surface reflectivity from snow and ice, and emissions like nitrogen oxides and volatile organic compounds (known as VOCs) all combine to create ozone molecules. When the ground-level ozone concentration exceeds 70 parts per billion, it can have harmful respiratory effects and cause lung damage in people who breathe the polluted air.

While there have been some modest improvements in the region’s air quality since development in the basin started, the basic fact remains that the UGRB, which once boasted some of the cleanest air in the country, remains dangerously close to violating the Clean Air Act’s standards for ozone. The consequences of this violation could be significant not only for the people living, working, and breathing in Sublette County, but for the industry operators who would likely see new regulations to bring the region back into compliance with air quality standards. 

The UGRB, which once boasted some of the cleanest air in the country, remains dangerously close to violating the Clean Air Act’s standards for ozone.

To better understand why this area continues its seasonal struggle with high ozone levels, the Outdoor Council teamed up with CURED and a trained thermographer from Earthworks, a community-based advocacy organization, to visit the Upper Green in November 2020 and inspect roughly a dozen oil and gas sites on the Jonah and Pinedale Anticline fields. Our goal was simple: to document examples of permitted emissions from oil and gas facilities on public lands and consider what appropriate next steps regulators can take to continue improving this region’s air quality.

Engine stack emissions from the Enterprise Products’ Bridger Compressor Station are an obvious example of a “major source” facility permitted under the Clean Air Act. This footage shows the stark contrast between what an observer can see with the naked eye versus through the lens of specialized infrared camera equipment. (Infrared video footage by Earthworks, Nov. 19, 2020.)

Almost all of the sites our team visited had some detectable levels of fugitive emissions — none of which would have been visible without the use of a state of the art forward-looking infrared camera. These FLIR cameras, which individually cost as much as a high end sports car, provide a glimpse of the otherwise invisible emissions occurring across the Jonah and Pinedale Anticline oil and gas fields.

As part of their operating permits, companies are typically allowed to emit certain levels of pollutants into the atmosphere. Sometimes emissions are vented and released intentionally, while other times they are accidental and the result of old or leaky equipment that needs to be updated or repaired. Both contribute to poor air quality and the region’s ozone season.

Natural gas producers operate thousands of facilities in Wyoming’s Upper Green River Basin. These facilities collectively leak or vent thousands of tons of methane and VOCs each year.

Fugitive emissions seen on Jonah Energy LLC’s Stud Horse Butte Tanks #10-28. The basin’s windy conditions can make it more difficult to see the gas plumes leaking from infrastructure in the UGRB. The region’s poorest air quality is typically on calm days during inversions when concentrations of pollutants build up. (Infrared video footage by Earthworks, Nov. 19, 2020.)

One routine and permitted practice in the Upper Green that contributes to the region’s wintertime ozone problems is when oil and gas wells are intentionally “blown down” to clear them of debris and sludge that accumulates over time. Blowdown tanks are often used to hold the residual fluids and gases that are expelled during these events, but this process frequently results in large volumes of fugitive gasses and VOCs escaping into the atmosphere. During a two-month period in the winter of 2020, Jonah Energy reported 1,008 blowdown events totaling over 159 hours of uncontrolled emissions venting. Dozens of other production companies operate in the region and, collectively, blowdowns result in hundreds of thousands of dollars in wasted gas annually and thousands of tons of vented methane and VOCs.

Emissions venting from tanks at Ultra Resource’s Stud Horse Butte Tanks #7-21. (Infrared video footage by Earthworks, Nov. 19, 2020.)

Emissions from leaking equipment or intentional venting can combine to create ground-level ozone, which can cause respiratory problems and lung damage.

When added up across the landscape, blowdown events and other forms of permitted emissions have the potential to play a big role in the seasonally unhealthy air that impacts the Upper Green. In our day in the field, we were able to document these emissions coming from blowdown tanks, combustor units, and dehydrators. It’s not hard to imagine what that impact could be when multiplied by the thousands of permitted facilities currently operating in the basin.

A leaking tank at Pinedale Energy Partners’ Mesa #1 well. Oil and gas companies operate thousands of facilities in the Upper Green River Basin. (Infrared video footage by Earthworks, Nov. 19, 2020.)
Pinedale Energy Partners’ Mesa well #3-17 shows blowdown tanks that are badly venting emissions. The harmful gasses being released into the atmosphere could be controlled by flaring which would turn these emissions into less harmful ones like carbon dioxide and water vapor. (Infrared video footage by Earthworks, Nov. 19, 2020.)

If the oil and gas industry is going to continue to serve Wyoming as it has historically, it needs to adapt and change to meet the expectations of mostly out-of-state consumers who are increasingly holding energy production to higher environmental and social standards. Based upon our own field observations, a good starting point for Wyoming regulators would be to reduce, and ultimately end, the common practice of using uncontrolled blowdown tanks to vent emissions from oil and gas operations. These emission sources and others should be minimized by being routed to combustors, and more work is needed to reduce the amount of wasted gas that is vented into the atmosphere. While blowdowns are just one of many emissions sources that need to be addressed by operators and regulatory agencies, this would protect public health and air quality. It would also be in the best interest of the industry in the long term.

We look forward to a future trip to the UGRB where the only things to see through a FLIR camera would be the silhouettes of mountains and clouds. But for that future to become a reality, there is still clear work to be done. With states like New Mexico and Colorado taking strong steps to clamp down on uncontrolled venting and set high standards for leak detection and repair, Wyoming’s operators should be following suit to address growing concerns over fugitive emissions, air pollution, and climate change.

Despite public outcry, Wyoming’s net metering law will again be on the chopping block

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Last week, we asked many of you to speak up at the Wyoming Legislature’s Joint Corporations Committee meeting and oppose a bill that would have undercut rooftop solar and small scale renewables in this state. And wow‚ that’s exactly what you did. The impact of your letters, calls, emails, and testimony was undeniable. The committee heard you. Because of you, the bill was dead upon arrival.

But, as many of you know, things at the legislature can change quickly and often unexpectedly. After the committee acknowledged that the votes were not there to pass the original bill, several members pulled the rug out from under the discussion by making a motion to substitute that bill with entirely different language and intentions. No one, including some members of the committee, saw this coming, and apart from a brief screen-share of a private document, the new bill was not even publicly available.

To the many members of the public who had taken time out of their day to participate — some of them taking time out of work — this was a shockingly sneaky maneuver. The last minute bill swap undermined the ability of the public to meaningfully weigh in on the topic while pushing through these committee members’ own agenda on net metering.

Consider for a moment, that the committee hadn’t been assigned net metering as an interim topic, and that the interim is supposed to be a time for thoughtful consideration of complex issues that require public input. Voting to advance a bill that neither the public or many members of the committee had ever seen before flies in the face of that. For those of you who spent time preparing testimony on the original bill that was not even considered, we are sorry.

We’re also sorry that after nearly three and a half hours of public testimony overwhelmingly against changing our existing net metering law, the committee decided to advance the new bill to the 2021 legislative session. This new bill charges the Public Service Commission to study net metering and set new rates and conditions for customers who currently have net-metered systems. The problem is this new bill leaps to the conclusion that net-metered customers are being subsidized by other ratepayers in Wyoming. This is not necessarily true. By thinking about net metering only as a “subsidy,” without also directing the Public Service Commission to consider the economic, social, and environmental that this policy generates, this bill’s narrow focus will make rooftop solar more expensive and kill jobs in this growing sector of our economy.

So what comes next? We believe that rooftop solar and small scale renewables can and should play an important part in diversifying our state’s economy and helping us address growing concerns about carbon emissions and climate change. The Wyoming Outdoor Council, along with a large coalition of solar and renewable energy supporters, will continue working on this issue and preparing for its appearance at the 2021 legislative session. Stay tuned as there will be plenty of opportunities to defeat or amend this bill. This fight is not over.

In the meantime, there are some real heroes on the committee that questioned and fought for the integrity of the public process that could use recognition and a quick thank you. Senator Tara Nethercott, in particular, was a passionate defender against the tactics we saw used last Wednesday. If you have a moment, we would encourage you to send a thank you to her and the other four members of the committee listed below who appreciate the value of public process, and who voted not to move any legislation forward under such circumstances.

Sen. Tara Nethercott
Tara.Nethercott@wyoleg.gov, 307.399.7696
Rep. Dan Furphy
Dan.Furphy@wyoleg.gov, 307. 760.0148
Rep. Shelly Duncan
Shelly.Duncan@wyoleg.gov,  307.575.2894
Rep. Andi Clifford
Andrea.Clifford@wyoleg.gov, 307.840.4327
Rep. Jim Blackburn
Jim.Blackburn@wyoleg.gov, 307.514.4318

 

 

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Climate change: the new front line for conservation in Wyoming

Wyoming is changing, faster now than any of us could have predicted even six months ago. In our last issue of Frontline, we addressed the reality of climate change and what it means for Wyoming’s future. Climate change is not a separate issue, but one that is deeply intertwined with all aspects of our work — from protecting our state’s big game populations to reducing harmful air emissions, to safeguarding our clean water, public lands, and ultimately our way of life. And if we are to succeed in our mission, we must advocate for policies that directly confront the real and growing threat of human-caused climate change.

Wildlife and migration

As you know,  the Wyoming Outdoor Council’s wildlife work over the last several years has focused on protecting Wyoming’s big game migration corridors — and for good reason. The science is clear about the crucial role these corridors play in maintaining ungulate populations that in turn support our state’s recreation economy and outdoor heritage. Yet, a changing climate could easily undermine many of these hard-fought efforts. For one, changing precipitation patterns and drought increasingly threaten the ability of animals to “surf the green waves” that connect their seasonal habitats. Wyoming has seen warming temperatures and drought intensify over the last 20 years and most experts agree that, at least for our state, this trend only gets worse. If we are to ensure that our state’s wildlife remain protected for the long term, we must also consider how these populations stay resilient and capable of adapting to these changes, while taking responsibility to mitigate the most damaging forecasted climate scenarios. 

Clean air

It’s hard to talk about clean air and the policies necessary to maintain it without acknowledging the relationship between climate change and the greenhouse gases at the heart of Wyoming’s air quality problems. We often think of natural gas as a cleaner fuel than coal — and it is, if we minimize the amount of fugitive emissions that leak into the atmosphere as it is produced and processed. The Outdoor Council has repeatedly called on Wyoming’s Department of Environmental Quality and the oil and gas industry to address air quality concerns, by advocating improved Leak Detection and Repair requirements for oil and gas infrastructure and opposing rollbacks of critical methane capture rules. With natural gas expected to play a major role in energy production for years to come, Wyoming must keep on raising the bar for air quality standards not only to protect our health, but to reduce our greenhouse gas footprint and stay competitive in energy markets that are favoring cleaner energy.

Clean water

One of the most alarming aspects of climate change in Wyoming is its impacts on our arid state’s already limited water resources. If current projections for warming hold, Wyoming could see significant loss of coldwater fisheries and native trout habitat by the end of this century due to increased water temperatures and loss of instream flows as our snowfields and glaciers shrink. These conditions exacerbate water quality concerns the Outdoor Council has been working hard to address, such as reducing harmful E. coli concentrations in our waterways. Warming temperatures are also projected to increase the amount of rainfall as opposed to snow, which reduces the amount of stored water potential available in the summer and fall. This spells increasing challenges and conflicts for ranchers, farmers, cities, recreators, and, again, our wildlife.

Our public lands

Advocating responsible energy development has been at the heart of the Outdoor Council’s public lands policy work — whether that’s fighting back against efforts to privatize public lands, urging the protection of special landscapes, or watchdogging development in crucial wildlife areas. We’ve recently reported on the rampant and largely speculative oil and gas leasing taking place across large swaths of the state. Not only do these lease sales come at the expense of other uses of our public lands, for those that are developed, they come at the expense of the quality of the environment that future generations will inherit. Remarkably, nearly one quarter of all greenhouse gas emissions produced in the United States originate from public lands — lands that are supposed to be managed with both current and future generations in mind. This is not sustainable. To the greatest extent possible, our public lands should be managed in ways that mitigate climate change and help surrounding communities be more resilient into the future. 

Confronting climate change also means addressing our economy

Climate change is a reality that ripples through the conservation issues the Outdoor Council has been engaged in for decades. It is something that our founder, Tom Bell, understood early on and urged us to address directly.

If we cannot find ways to address and mitigate this looming crisis and do our part as a state, our conservation work in all of our traditional program areas will fall short. 

Tackling climate issues in Wyoming will require hard and honest conversations about the dependency of our state’s economy on fossil fuels, and it will require creativity and investment into bold new ideas. The new front line for conservation means wading into policy issues that, at least on the surface, seem less directly tied to it — like helping communities transition from fossil fuels, promoting economic diversification, and supporting new sources of state revenue. As daunting and intimidating as this might feel, we believe it’s critical. Our state’s economy and conservation policies are interconnected. Wyoming’s outsized influence on climate change means that the policies and actions we take in our communities can have national — even global — impacts. 

Scholarships support students committed to conservation

This year the Wyoming Outdoor Council is proud to award $1,500 scholarships to five graduating high school seniors from Wyoming — who all have demonstrated a commitment to conservation values and protecting Wyoming’s environment and quality of life. The five students plan to study a wide range of topics in conservation and resource management and will be pursuing related degrees. These scholarships were made possible thanks to the generous support of the Blue Ridge Fund of Wyoming. Congratulations! 

  • Tessa Coughenour (Natrona County High School) will study environmental design at Montana State University.
  • Parker Goodwin (Cody High School) will study engineering at the University of Wyoming.
  • Mallie Gray (Natrona County High School) will study reclamation and restoration ecology at the University of Wyoming.
  • Kai Lynn (Cody High School) will study biology at Northwest College with plans to transfer to the University of Wyoming to complete a degree in wildlife biology. 
  • Rachel Stoinski (Lander Valley High School) will study wildlife and fisheries biology and  management at the University of Wyoming

We will continue to offer these scholarships each year to help support the next generation of conservation-minded Wyomingites. If you know a young person who may qualify, please spread the word and watch for the next opportunity to apply in early 2021.

With winter on its way, it’s time to talk ozone in the Upper Green

The winter of 2019 was a bad season for ozone pollution in the Upper Green River Basin, particularly near Boulder where monitoring stations recorded nine days in which ozone levels exceeded federal standards. 

Winter ozone is not new for this region, but increasing concentrations over the last several years have called into question whether the regulations governing fugitive emissions from oil and gas operations — and our clean air — need tightening. This was the context that led members of the local Pinedale advocacy group Citizens United for Responsible Energy Development and the Wyoming Outdoor Council to tour the Jonah and Pinedale Anticline natural gas fields with Wyoming’s Department of Environmental Quality. Our goal was to better understand current operations — and learn what state regulators are doing in response to last season’s unhealthy ozone conditions.


CURED member Jana Weber looks at the emissions from a combustor through a flare camera. These cameras can cost more than $100,000 and are used to quickly identify emission leaks.


As one might expect, there’s a lot to see in the state’s largest natural gas field. Our group visited facilities owned by the three major energy companies in the area: Pinedale Energy, Ultra Energy, and Jonah Energy. We examined lake tanks, pig launchers, combusters, disposal facilities, production units, and dehydrators with state-of-the-art flare cameras used to detect leaking emissions from a distance. Looking into these cameras is like looking under a microscope where the invisible world of gasses and heat is revealed in ghostly detail. Technological advances like this are essential for quickly identifying leaks and monitoring emissions and are a key component of what’s known as Leak Detection and Repair.

New technologies might make inspections easier and more efficient, but it remains a daunting task over such a large area. Currently, the Upper Green River Basin has more than 8,000 permitted facilities and only two full-time DEQ air quality inspectors. Even with each inspector performing hundreds of inspections annually, the vast majority of these facilities will go uninspected each year. 

Fortunately, DEQ has ways of prioritizing the most important inspections based upon factors like the facility’s previous violations, its potential for emissions, and when it was last inspected. With low compliance rates a lingering concern and priority, it was also refreshing to learn that inspectors took enforcement actions against several operators this summer for permit violations.

Touring the Jonah and Pinedale Anticline fields was a reminder of the good work and intentions of our state’s Department of Environmental Quality in the Upper Green River Basin. But, while we were pleased with what we saw, the bar for whether or not current efforts are enough will be determined by the ozone levels we see in future winters. We’re encouraged that the DEQ seems to be taking last year’s violations seriously and has set ambitious goals for engine monitoring and working to bring on a third air quality inspector in the basin this winter. However, funding for the department’s two current full-time inspectors will need to be added to the DEQ’s budget next year, due to the elimination of the federal contribution for this work. 

We have to make sure that DEQ has the resources it needs to prioritize inspections and improve compliance rates to achieve better air quality in the Upper Green. You can be sure that the Outdoor Council will be advocating for this at the 2020 legislative session in Cheyenne. 

The DEQ’s annual pre-season ozone meeting is slated for November 18 at the Boulder Community Center in Boulder, WY. Outdoor Council staff and CURED members will be in attendance. More information can be found here

Run the Red 2019 was the biggest on record, and it’s not over yet

DECEMBER 2019 UPDATE: In early 2020, the Bureau of Land Management anticipates releasing the long-awaited draft land use plan for the Red Desert and surrounding areas. The plan will determine which resources are protected and which areas are open to industrial development. This means that important wildlife, cultural, scenic, and archeological resources — like Steamboat Mountain and its resident desert elk herd, the Red Desert to Hoback mule deer migration corridor, Native American petroglyphs and sacred sites, and historic trails like the Oregon and Mormon trails — could be at risk. Stay tuned for updates on the draft and for opportunities to tell BLM and Governor Gordon to stand up for balanced use and to protect the Red Desert. 

The Red Desert is a land of extremes and poetic contrasts. Depending on the time of year, you could find yourself panting for breath in oppressive heat, stuck axle deep in the mud, or shivering despite being bundled in every layer you own. These challenges — and the chance to test one’s mettle against them — are what make the rugged Red Desert the perfect place to host Run the Red, one of Wyoming’s emerging endurance races.

Run the Red is Wyoming’s only ultramarathon designed to raise awareness and advocacy for the Red Desert. This year’s race was held on the state’s first Wyoming Public Lands Day on September 28, with a newly designed course that started and finished at historic South Pass City. Two new distances were also added — a 45K and 90K — so that participants could experience the best of the Northern Red Desert:  imposing views of Continental Peak, the towering Oregon Buttes, and undulating high desert bisected by the Sweetwater River. Despite the challenging weather, which shifted from snow to rain to wind to sun, this year’s race was the most successful on record, bringing 155 runners from all over Wyoming and as far away as Texas and Oregon. 

“Wyoming people are tough,” said Shaleas Harrison of the Wyoming Wilderness Association. She organized this year’s race and the Wyoming Public Lands Day events that followed at South Pass City, along with partners from NOLS and the Wyoming Outdoor Council. The day was full of wet, smiling runners, laughs from hardy aid station volunteers, memories made around drum circles and banjos, and, most importantly, a deeper appreciation for a wild place many Wyomingites hold dear. 

Following the race, runners and locals from Lander and Rock Springs enjoyed a series of events  to celebrate the newly created Wyoming Public Lands Day. A range of speakers — including representatives from the Northern Arapaho and Eastern Shoshone tribes, state legislators, Red Desert experts, and sponsored athletes shared their perspectives about the importance of landscapes like the Red Desert in maintaining Wyoming’s quality of life, wildlife, and rich outdoor heritage. 

Although the race has changed over the years, the goal of Run the Red — to build a connection to a wild landscape — has remained the same. Jonathan Williams, Environmental Stewardship Coordinator for NOLS, couldn’t have said it better:

“The great thing about Run the Red is that it gives people the opportunity to create a deep sense of place for themselves and then carry that forward as advocates for the desert.” 

– Jonathan Williams,
Environmental Stewardship Coordinator for NOLS

In coming months, the Bureau of Land Management, will release its revised land-use plan for much of the Red Desert. There’s a lot at stake. Our hope is that all the runners, volunteers, and participants — along with anyone who cares about this wild landscape — will weigh in and urge the BLM to protect what makes this place so unique. Stay tuned … the race isn’t over yet!