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Climate Change

THE WESTERN SOLAR PLAN IS FINALIZED. WHAT DOES IT MEAN FOR WYOMING?

Posted on by John Burrows

Where we site large-scale solar matters — and with the final draft of the Bureau of Land Management’s Western Solar Plan, we now have a useful template for proactively deciding where solar projects should (and should not!) be built on federal lands.

Back in April, we asked our supporters to engage in the public comment process for the updated Western Solar Plan, a once-in-a-generation opportunity to get solar siting right. If you submitted a comment on the draft plan, we can’t thank you enough! Because of your engagement, the final plan offers greater protections for Wyoming’s wildlife.

From draft to final, the BLM made a number of changes to the plan. Some are good, and some we’re not huge fans of. But on the whole, we’re pleased with how things shook out. Since the plan is rather hefty, we’ve compiled this guide to help you understand what it contains. (We’ll start with main takeaways, then, if you want them, we’ll dive into the nitty-gritty details.)

At the highest level, here’s what we know about the final plan:

  • The plan includes BLM lands in Wyoming. (The previous Western Solar Plan did not include Wyoming.)
  • 3.8 million acres of land in Wyoming are available for lease, or roughly 27 percent of BLM lands in the state. However, the BLM anticipates only 27,000 acres of actual development in Wyoming by 2045 to meet market demand for solar energy — roughly one percent of the total potential area available for leasing.
  • The plan limits solar development using 21 resource-based exclusion criteria including Areas of Critical Environmental Concern, threatened and endangered species habitat, and Tribal Interest Areas, among others.
  • The final plan adds significant protections for big game species. It excludes solar development from crucial winter range, parturition areas, and portions of migration corridors including high-use, stopover, and bottleneck habitat. The plan also helps clarify how new information and research could be used to update maps of big game habitat where development is not allowed. (We still have questions about how this process will work between BLM and state wildlife agencies and how frequently local land use plans will be updated.)
  • The final plan adds features to improve environmental justice considerations and community benefit agreements that WOC and others advocated for. However, we think the BLM did not adequately take into consideration Tribal perspectives and should do more to collaborate with Tribes on when and where solar is authorized, as well as how to address conflicts in priority areas for Tribal communities.
  • Areas available for solar leasing are limited to lands within 15 miles of existing or planned transmission and/or locations with previously disturbed lands.
  • The final plan excludes development on Lands with Wilderness Characteristics that have been protected in local land use plans.

The final Western Solar Plan: A deeper dive

To understand why we needed an updated Western Solar Plan, we have to begin with some context. An update has been long overdue for three key reasons: First, the cost of solar energy has plummeted nearly 90 percent over the last decade. In many places, solar is the cheapest way to add energy capacity to the grid. Second, the technology surrounding solar energy has improved significantly, making solar energy more efficient and viable in northern latitudes and over a wide range of conditions. In fact, the efficiency of solar panels has increased roughly 40 percent in the last decade. Finally, federal policy is currently promoting incentives around renewable energy and decarbonization to address concerns over greenhouse gas emissions and climate change.

Taken together, these trends have led to rapid growth in the solar industry. For perspective, solar and battery storage made up over 80 percent of new U.S. electric generation capacity in 2024 — surpassing even the most optimistic projections around solar development.

These changes point to accelerating demand for locations to site large-scale solar projects, which in turn means that we need to proactively assess where future solar development on public lands is and is not appropriate. This is why BLM’s updated plan is so important: Failing to put protective side-rails in place now to direct future development could mean losing many of the conservation, wildlife, recreation, and cultural values that are so important to Wyoming.

(If you’d like to read more about why the Western Solar Plan is our chance to meet an important moment, see our blog about the draft plan from earlier this year.)

Now that we have the context in place, what follows is WOC’s analysis of the final plan’s important parts.

BLM lands in Wyoming were included in the plan.

This was not a sure bet initially and, in fact, a number of prominent leaders in Wyoming opposed Wyoming’s inclusion. We think that including Wyoming in the new update is a good thing, as it takes some of our best habitat and intact landscapes off the table before projects are being considered.

Wyoming-specific map showing lands available for solar leasing (green) and locations where leasing will not be allowed (pink). This map does not include critical winter range exclusions for big game. Approximately 27 percent of BLM lands in Wyoming are open for leasing. (Note that BLM only anticipates 27,000 acres of actual solar development by 2045.)

The final plan combines aspects of various alternatives within the draft.

The final plan limits solar development to:

  • Areas outside of 21 key resource-based exclusion criteria. This includes exclusions for resources like Areas of Critical Environmental Concern, certain Lands with Wilderness Characteristics, Big Game Habitats, and Critical Habitat Areas for Threatened and Endangered Species. See the full table of exclusions here.
  • Areas with a slope of less than 10 percent.
  • Areas within 15 miles of existing or planned 69kW transmission or greater, and/or areas identified as previously disturbed lands, ​​which generally have diminished resource integrity based on the U.S. Geological Survey Landscape Intactness model.

By increasing the allowable distance from transmission corridors in the final plan, the overall acreage available for leasing on BLM lands in Wyoming increased substantially. The practical effect of this change would give industry more acreage to consider development on.

It’s important to note that the reasonably foreseeable development scenario has not changed — the best guess is demand for solar projects on public land in Wyoming will not exceed 27,000 acres by 2045. It’s also worth noting as a comparison number that there are more than 8 million acres of BLM land in Wyoming with existing oil and gas leasing. Table 6-1 below provides a state-by-state accounting of total lands available for application and exclusion areas.

The plan better protects big game species.

The resource exclusion criterion for big game was significantly improved to protect critical habitats and migration corridors. In the initial draft, solar development would have been allowed in migration corridors, crucial winter range, and parturition areas unless local BLM offices had their own protections in place (which is not the case for most Field Offices in Wyoming). Now, future solar development on BLM lands will be excluded in portions of big game migration corridors mapped as “high use,” migration pinch points, bottlenecks, and stopover areas, not to mention parturition areas and crucial winter range habitat. Additionally, BLM created a new “avoidance designation” for lands intersecting migration corridors mapped as “medium and low use.” This new designation would require developers to work with state wildlife agencies like the Wyoming Game and Fish Department to avoid harm to wildlife in order to proceed with proposed projects in avoidance areas.

This is a huge win and something that WOC and our allies fought hard to ensure. From the beginning, one of the most significant concerns with utility-scale solar development is its impact on wide-ranging wildlife that need open space to move freely across the landscape. The strengthening of this exclusion criterion gives us confidence that future projects will avoid situations like the one that unfolded at Sweetwater Solar, where thousands of pronghorn were pushed into a narrow road corridor because the project was built in a pathway used by the animals to access critical winter range habitat.

The plan clarifies how new information could be used.

BLM clarified the process by which new information, research, and habitat maps could be updated into the final plan as we learn more and refine our knowledge of the important movement patterns and habitat needs of wildlife. This provides a compelling incentive and opportunity to map additional migration corridors and update habitat maps for big game in the state.

Notably, a lack of mapped and published migration corridors in Wyoming reduced the amount of land designated as either “exclusion” or “avoidance” areas. Compared to some other states (like Nevada), Wyoming has a relatively small number of exclusion and avoidance areas for big game migration corridors, despite having some of the best habitat and copious data to draw on to model additional migration corridors. From our perspective, this provides another compelling reason why Wyoming must continue mapping and recognizing migration corridors, not to mention updating big game crucial winter range maps, so that this critical information can be used to better protect our state’s wildlife resources in future federal land management processes. Figure 6-3 below shows areas where solar leasing would currently be excluded and avoided based upon migration corridor data.

The plan excludes Lands with Wilderness Characteristics.

For Lands with Wilderness Characteristics, we are extremely pleased to see the BLM acknowledge the value of lands that still hold their wildness by excluding designated LWCs outright and considering all others — including those nominated by citizens — during project-level decisions. These areas are an important piece of the interconnected whole. They safeguard the ecological integrity of the greater landscape and provide meaningful opportunities for Tribal members and local communities to connect with and sustainably steward the land.

Other considerations

During the public comment period on the draft plan, WOC and the Wyoming Wilderness Association raised a number of other important issues. These were addressed (to various degrees) as programmatic design features in the plan. These included:

  • A requirement to identify whether the lands within and immediately adjacent to the proposed solar energy project have been assessed for wilderness characteristics or have been included in a citizen’s wilderness inventory or proposal.
  • Requirements around Tribal consultation considerations and the avoidance of impacts to resources and landscapes important to Tribal communities.
  • Requirements around environmental justice considerations and guidelines encouraging the use of community benefit agreements by developers.

We are still working to understand the exact implications and nuances of these requirements, especially as they relate to Tribal consultation and what mitigation looks like when impacts to Tribal resources occur. The mitigation concepts proposed in the final plan fail to recognize the place-based importance of these resources for Tribal communities. As such, mitigating impacts by guaranteeing access to a resource in a different location, or by transplanting species, misses the point of those areas themselves being important — not just the area’s plants, minerals, or animals.

Conclusion: Looking forward

All in all, BLM’s final plan shook out positively for big game species and a number of the other resources and values that are critical from a conservation perspective. Given the relatively small amount of development forecasted in Wyoming, WOC would have preferred the final alternative to be more prescriptive in limiting development to only the least impactful locations.

As we think about the future of renewable energy development, it is only going to become more important to focus on project-specific NEPA analyses to understand the local and overall cumulative effects of proposed development. Decisions made at the project level, even down to the type of fencing and ways that solar panels are mounted, can have a huge impact on the environment and wildlife. Similarly, as with other forms of development, careful attention needs to be given to lifecycle considerations such as impacts from raw material extraction, component recycling, and reclamation for utility scale solar projects. Our commitment to Wyoming and our supporters is to scrutinize these projects as they’re proposed and take action when changes or improvements are necessary.

The renewable energy boom is coming, and one of the biggest challenges we face is the need to simultaneously reduce our carbon emissions to address a changing climate, while also protecting the best of the habitat and natural resources we have left. Locally, these goals can find themselves at odds, despite the fact that globally, they are largely the same.

In this transition, it’s important to recognize that Wyoming sits in a place of abundance — for its renewable energy potential and its outstanding habitat, recreation, and cultural resources. With so much to lose, we must proceed carefully and thoughtfully. The Western Solar Plan is a step in the right direction, but much more work still needs to be done to ensure that all large scale energy development is done responsibly with both environment and people in mind.

Header image: Bureau of Land Management | Flickr CC

Wyoming Supreme Court Rules in Favor of Just Compensation for Solar Owners

Posted on by Max Owens

Powder River Basin Resource Council & Wyoming Outdoor Council welcome the opportunity for more energy freedom in Wyoming

 In a precedent-setting decision issued last week, the Wyoming Supreme Court struck down High Plains Power’s policy to cut by approximately 80 percent the compensation paid to rooftop solar owners for the power they produce and share with the electric grid. The decision now forces the Wyoming Public Service Commission to reconsider what is a just and reasonable rate to compensate solar owners.

Had the PSC’s approval of High Plains Power’s policy been upheld, it would have negatively impacted hundreds of existing and future solar homeowners and businesses and the roughly dozen Wyoming small businesses that install solar panels across the state, providing jobs and revenue for Wyoming’s future.

“Most businesses and homeowners invest in on-site solar generation to gain a degree of energy independence, a source of clean energy, AND a reasonable financial return on investment. Today’s decision helps to preserve a simple and fair compensation structure for future solar investors and, most importantly, prevents HPP from reducing the compensation expected by their members already using solar,” said Scott Kane, co-owner of Lander-based Creative Energies, the company responsible for installing many of the rooftop solar systems within the High Plains service area. 

The Court struck down the PSC’s 2023 decision authorizing High Plains Power to reduce the compensation it gives to customers who generate solar power and send it to the grid. Wyoming’s net metering statute requires utilities to credit customers for the excess solar power they provide at the same retail rate they pay for the electricity they consume from the grid. However, High Plains switched to compensating net-metered customers for their excess generation by paying them on a monthly basis at a much lower rate, called avoided cost. This change meant that customers could no longer roll over generation credits, dramatically reducing the financial benefit of having solar panels.

Not wanting the precedent of High Plains Power’s action to stand or influence other utilities, and seeking to represent the interests of their membership, Powder River Basin Resource Council and Wyoming Outdoor Council intervened in the PSC proceedings reviewing High Plains Power’s proposal in 2022 and later appealed the PSC’s split 2–1 decision to the Wyoming Supreme Court.

“We’re pleased that the Wyoming Supreme Court has ruled that the High Plains and the PSC actions were in violation of the law. If left to stand, it would have paved the path for other electric utilities to enact similar policies rendering customers’ solar investments much less economic and gravely threatening Wyoming’s growing solar industry,” said Bob LeResche, Powder River Basin Resource Council Board Member, and solar-owner member of the rural electric cooperative Powder River Energy Corporation near Clearmont, Wyoming. 

“We are grateful that the terms on which we chose to make an investment in a solar system will be maintained. We hope that the rooftop solar industry will continue to grow, providing more jobs and more distributed electricity,” stated Elizabeth Aranow, a High Plains Power solar owning customer.

Meeting the Moment: Planning for a Responsible Energy Future with the Western Solar Plan

Posted on by John Burrows

Attend our virtual Conservation Cafeteria on the Western Solar Plan on Wednesday, April 3 at noon — RSVP here.

If you’ve been following national energy trends, you may have noticed that 2022 was a big year. It was the first year in recent history that renewable energy surpassed coal generation in the U.S. As the cost of renewable energy continues to decline, and numerous state and federal policies continue to encourage decarbonization, it’s clear that renewable energy is here to stay. And that means states like Wyoming need to start preparing for new types of energy infrastructure on their lands. 

For Wyoming, the implications of a transition to low-carbon and renewable energy are difficult to overstate, especially considering the footprint of utility-scale renewable energy and its potential impacts to wildlife, habitats, open spaces, and cultural resources across the state. Fortunately for one key renewable energy resource that Wyoming has in abundance — sunlight — we have a once-in-a-generation opportunity to ensure that this development is sited right from the start. That’s where the Western Solar Plan comes in.

The 2012 Western Solar Plan is getting updated — and Wyoming is included!

The Bureau of Land Management is currently proposing to expand and update its 2012 Western Solar Plan, which will help identify the best locations across the West for future utility-scale solar development — in this case, solar facilities that produce 5 megawatts or more on public lands. The plan aims to proactively screen for wildlife, sensitive habitats, cultural resources, and other values and resources that could conflict with solar energy development. Wyoming wasn’t included in the 2012 plan, back when solar energy cost roughly 10 times what it costs today. But the updated plan includes Wyoming and other newcomers, including Montana, Idaho, Oregon, and Washington.  

Having Wyoming included in the updated Western Solar Plan is great news! This policy update was a core recommendation of the Renewable Energy Siting Collaborative, a convening of industry, conservation groups, academics and other stakeholders that the Wyoming Outdoor Council helped facilitate in 2021. The large footprint that solar energy needs to produce electricity means that inappropriately sited projects could have devastating consequences for Wyoming’s migrating ungulate herds and fragile habitats. We’ve unfortunately witnessed this firsthand with the Sweetwater Solar Facility, the state’s first utility-scale solar project on public lands. This facility was placed along a pronghorn migration route north of Green River, creating a barrier along the animals’ path that funneled them onto a county highway, creating a dangerous situation for pronghorn and motorists alike. It’s an example that shows the impact these facilities can have on wildlife and just how important it is to site projects in ways that avoid sensitive habitats.

​​Help us achieve the best outcome for Wyoming

From now until April 18, the BLM is seeking comments on five different alternatives for the updated Western Solar Plan through its e-planning website. BLM’s preferred alternative (alternative 3) would leave 2.98 million acres (roughly 17 percent) of BLM land in Wyoming open for solar development applications. Stated simply — we think this is too much.

Wyoming is unique in its open spaces, unfragmented habitats, and iconic seasonal wildlife migrations. Solar development in particular presents an impenetrable barrier for big game that threatens connectivity on these landscapes. This is why we are urging our members to tell the BLM to select an alternative that further narrows where solar projects can exist, while still leaving enough acreage available to help our nation reach important climate goals.

Specifically, we urge our members to support alternative 5, which requires that solar energy development on public lands meet the following criteria: 

  • Be located on previously disturbed lands with diminished integrity
  • Be located within 10 miles of existing or proposed transmission corridors
  • Be located on slopes less than 10 degrees
  • Not conflict with 21 resource-based exclusions that BLM has identified for all alternatives. (A full list of these exclusions can be found starting on page 21 of the draft plan.)  

Even when considering these criteria, alternative 5 still allows for applications for solar development in 1.4 million acres of public lands in Wyoming. This is about 50 times more than the BLM expects will actually get developed by 2045 in their reasonably foreseeable development scenario for Wyoming (below). Alternative 5 also adds an additional safeguard by only considering applications on previously disturbed lands which would help ensure that the loss of unfragmented and healthy habitat is minimized and that future solar development is directed away from these areas.  

Figure 1: BLMS Reasonably Foreseeable Development Scenario. Available here.

Speak up for Wyoming’s wildlife

Finally, we need your help speaking up for Wyoming’s wildlife in the plan. As drafted, the Western Solar Plan excludes solar development from big game migration corridors and winter ranges only where this habitat is identified and explicitly singled out for exclusion in existing land use plans. Unfortunately, most of Wyoming’s resource management plans are severely outdated and provide little to inadequate acknowledgement for big game migrations and winter-range in relation to renewable energy projects. Biologists have collected huge amounts of data in recent years to delineate migratory routes and improve understanding of how animals are using crucial winter range in Wyoming. Very little of this has been included or updated in resource management plans.

If this plan is to be successful for Wyoming and avoid harm to our wildlife, it needs to avail itself of the best available science on migrations and winter ranges. In your comments, tell the BLM that it needs to revise its big game exclusion criterion (criterion 9) to protect identified big game crucial winter range and migration corridors from utility-scale solar development regardless of the direction offered in applicable land use plans. The risks to our ungulate herds are too great to ignore the best available data waiting on land use plan revisions that may take decades. 

Help Us Meet the Moment

It’s not everyday in our work as conservation advocates that we get the chance to raise our voice in support of planning efforts with the potential to have such an impact as the Western Solar Plan. As many of you know, this work is so frequently driven by the need to react to bad ideas and policies that threaten conservation values. This plan is different. It sets the rules that will govern solar development on public land for decades to come. From our vantage point at WOC, we are entering a time when the country’s energy future is at a crossroads — and Wyoming stands to play an important role in choosing which path we take. With an updated Western Solar Plan, we have a rare opportunity to be proactive and reduce many of the resource conflicts that we’ve sadly grown accustomed to on our public lands. We can plan for the development that will be needed to power our country while also meeting our long-term climate goals and protecting the wildlife and the very things that make Wyoming special. 

New federal methane rules would curb climate change, benefit Wyoming

Posted on by John Burrows

On Friday, Nov. 11, the U.S. Environmental Protection Agency took an important step toward protecting public health and reducing greenhouse gas emissions that contribute to climate change by strengthening proposed rules that will reduce wasteful methane emissions from the oil and gas industry.

If enacted, these common-sense rules would be the first action by the EPA to regulate methane emissions from the thousands of existing oil and gas wells in Wyoming, not just future development. The rules are expected to promote new cost-effective technologies to prevent waste, and make natural gas more competitive as consumers demand cleaner sources of energy.

The announcement of new measures to cut methane and other harmful pollutants from oil and gas operations is welcome news, and builds off of Wyoming’s own successes in reducing harmful emissions and will limit wasted methane from leak-prone equipment.

The updated proposal would require routine and cost-effective monitoring of well sites, encourage the development and use of new leak detection technologies, and set higher standards for flaring — a practice by which methane is burned as a waste product rather than captured and sold.

The Wyoming Outdoor Council sees these rules as essential to spurring future innovation around leak detection and repair and to creating a level playing field for methane regulation across the oil and gas industry. We’re encouraged by the efforts to address routine flaring, and hope that the final rule fully eliminates this wasteful practice.

Methane emissions from human activities are responsible for about 30 percent of global warming since the industrial revolution.

The case for cutting methane emissions

  • Methane regulation is supported widely by leading industry and conservation groups. Many oil and gas operators, including major Wyoming producers like Jonah Energy and Purewest Energy, are already working to reduce sources of wasted methane as consumers demand cleaner sources of energy.
  • The Inflation Reduction Act, which passed into law in August 2022, set aside roughly $1.5 billion to help operators to comply with new methane emissions rules.
  • Capturing methane is very cost effective. In many cases wasted natural gas can be captured and sold, paying for most, if not all, of the additional work needed to capture it. Recent data from the International Energy Agency suggest that up to 45 percent of wasted methane emissions can be prevented at no net cost.
  • Reducing methane leaks saves taxpayer dollars and stewards valuable resources for the future. In 2018, the Wyoming Outdoor Council and its partners estimated that between $51 million and $96 million of methane was vented and flared annually in Wyoming. This translated to $9-16 million lost in annual royalty payments to the state.
  • Reducing methane emissions from oil and gas production is widely regarded by scientists and policy makers as a critical first step to mitigate the worst impacts of climate change in the future. Methane is a powerful greenhouse gas responsible for about 30 percent of global warming since the industrial revolution. However, methane also leaves the atmosphere quickly compared to other greenhouse gases like carbon dioxide. Reducing wasted methane emissions now is one of the best opportunities to buy time to implement other climate solutions.
  • Reducing methane emissions has significant air quality and human health benefits. The same leak detection and repair practices used to reduce methane will also reduce harmful air pollutants such as volatile organic compounds (VOCs) that cause respiratory damage and contribute to poor air quality.

Q&A with Kara Choquette, Wyoming Energy Authority

Posted on by Alan Rogers

Kara Choquette is director of communications and government relations for wind energy developer Power Company of Wyoming, as well as the TransWest Express transmission line project. Earlier this year, she joined the board of the Wyoming Energy Authority. She shared her thoughts about the Energy Authority and the role of renewable energy in Wyoming’s future in a quick Q&A with the Outdoor Council.

Share a little about your background, and your experience in the energy industry. What motivates you to work in the energy sector in Wyoming, and how did that lead you to serve on the board of the WEA?

I’ve been working directly in the renewable energy space since 2009. That’s when I joined a company that is developing the nation’s largest single wind power project, in Carbon County, Wyoming, and is also developing a major new interregional electricity transmission line for Wyoming. It was a natural career transition for me and a compelling opportunity after spending over a decade working in the technology and water industries – which each include important energy-related aspects. I liked the fact that wind turbines create electricity without requiring any water. Having grown up on a family farm/ranch, I wanted to help bring more kinds of good-paying, stable, family-supporting jobs to a rural area. And I liked that wind energy is compatible with agricultural operations and multiple environmental objectives.


I’ve been an active participant in some manner with the Wyoming Energy Authority and with one of its predecessors, the Wyoming Infrastructure Authority, since 2009. Recently, I’ve been part of two multi-stakeholder state groups – the governor’s Platte Valley Mule Deer Local Area Working Group, and the University of Wyoming-led Renewable Energy Siting Collaborative. I was honored to join the WEA board because the WEA is at the forefront of “all things energy,” in the nation’s top Energy State, during a fascinating period of energy opportunity and evolution.

How do you see renewable energy fitting into the future of Wyoming’s economy and way of life?

To me, renewable energy is entirely consistent with Wyoming’s pioneering and pathfinding DNA. Wyoming’s history is filled with so many stories about developing new trails, exploring diverse opportunities, and responding creatively and decisively to changing markets and conditions. Renewable energy also can help maintain Wyoming’s longstanding leadership as an energy producer and exporter. The completion of the Union Pacific Railroad in 1869 opened up new access to new markets for otherwise-stranded resources in Wyoming, such as coal produced from Wyoming’s original coal-mining county (Carbon County). Similarly, new high-voltage interregional transmission lines will open up access to new markets for otherwise-stranded clean electricity resources in Wyoming. The state does not have in-state demand for all of the abundant mineral and non-mineral resources it can provide. When new non-mineral power plants can compete and can secure customers out-of-state, that will create more new energy jobs and new sources of energy revenues in-state.

What are your hopes for your time with the Wyoming Energy Authority? What would you like to see WEA achieve?

The Wyoming Energy Authority is a relatively new entity, created by the state in 2019 (via Senate File 37). The WEA’s primary purpose is straightforward: “diversify and expand the Wyoming economy through improvements in the state’s electric and energy transmission infrastructure and facilitate Wyoming’s production, development and transmission of energy and associated natural resources.” I would like to be part of the WEA continuing to grow and achieve its purpose, especially in areas related to the clean energy technologies that are increasingly in demand today and in the near future. I hope to add value by bringing diverse expertise specifically in the renewable energy sector, and an enthusiasm for other important energy aspects like energy efficiency. The WEA is fortunate to have an outstanding executive director, smart and dedicated staff, and top mineral and non-mineral energy experts who have been on the board since its inception; I’m glad to be part of this team.

Two Ways to Reduce Methane Emissions, and Why Wyoming Needs them Both

Posted on by John Burrows

Most policy experts agree that, along the long road to combating climate change and reducing greenhouse gas emissions, reducing wasted methane from oil and gas operations is “low-hanging fruit.”

In 2020 alone, wasted methane gas from oil and gas operations made up roughly one-third of all methane emissions from human activity. The obvious need to address this problem is why there are two proposed regulatory changes involving methane that could have major impacts on lowering greenhouse gas emissions from our country’s oil and gas sector. The rules — one from the Environmental Protection Agency and the other from the Bureau of Land Management — would seek to reduce methane waste, and their success is important for Wyoming’s environment and taxpayers alike.

Methane is the second-most significant greenhouse gas in terms of impact on global warming. It is responsible for approximately a quarter of the Earth’s warming since the Industrial Revolution and, when compared to carbon dioxide, it has roughly 80 times the global warming potential over a 20-year period (International Energy Agency). However, despite how methane’s potency, it cycles out of the atmosphere much quicker than carbon dioxide: This means methane emission reductions now can help lower greenhouse gas concentrations and buy time to make the necessary societal changes we need to achieve net zero emissions over the coming decades.

But putting aside the many climate and environmental benefits of reducing wasted methane, it also just makes sense as a cost-effective policy solution. Wasted methane, after all, is essentially natural gas that can be captured and brought to market. As a quick comparison, in 2019 alone, oil and gas operators wasted enough methane from venting and flaring (common ways operators manage methane waste) to power 2.1 million U.S. homes (Environmental Defense Fund).

In fact, the International Energy Agency estimates nearly 50 percent of wasted methane can be captured with no net cost to producers (IEA). This is because investments made in reducing methane emissions pay for themselves over the long term by keeping more natural gas in route to energy consumers and out of the atmosphere.

Which brings us to the new EPA and BLM methane rules — federal efforts the Wyoming Outdoor Council supports to help curb this wasteful practice. Last November, the EPA released new draft rules that would regulate wasted methane emissions for both new and existing sources for the first time. (Historically, in most cases, methane has only been regulated from “new and modified” emissions sources, and older “existing sources” of wasted methane have largely been left alone). The EPA rules would apply under the authority of the Clean Air Act, treating methane as an air pollutant. Importantly, the rules would regulate methane emissions from oil and gas facilities across all jurisdictions and land ownerships (including private, federal, and tribal lands) and, if they go into effect, could dramatically cut emissions and uniformly raise the bar for responsible energy development. The EPA’s rules are widely supported by both environmental and industry groups alike, because they are good for the environment, create an equal playing field for businesses by setting uniform standards, and establish regulatory certainty under which companies can predictably operate and plan.

Separately, the Department of the Interior is also considering a BLM methane waste rule that would apply more narrowly to oil and gas production on federal and tribal lands. The BLM’s rules take their authority from the waste prevention mandate in the Mineral Leasing Act of 1920. This mandate allows the Secretary of the Interior to “use all reasonable precautions to prevent waste of oil or gas developed on the land.” In states like Wyoming, where the majority of oil and gas development occurs on public lands, the application of this rule could help the public realize higher returns on the development of natural resources by charging royalties for wasted natural gas.

In 2018, the Outdoor Council estimated that Wyoming lost as much as $96 million worth of natural gas in a single year due to intentional flaring, venting, and careless leaks. This translates into roughly $16.1 million lost in annual royalty payments to the state. These are critical revenue streams that taxpayers and budget-strapped Wyoming communities deserve to see for the depletion of natural resources (WOC Oil and Gas Waste Report). And of course, the rule would provide further incentive for producers to keep methane in the pipeline and out of the atmosphere.

Both the BLM’s authority under its waste prevention mandate and the EPA’s authority under the Clean Air Act to regulate air pollutants are needed to address climate concerns and ensure that Wyomingites receive a fair value for the one-time use of their non-renewable resources. While some leading companies like Jonah Energy, Occidental, and Devon Energy are taking action to cut methane and support federal methane regulation, that simply isn’t enough. Most oil and gas operators are not doing frequent, thorough inspections for leaks and we need stronger state leadership to support these common sense federal rules that will benefit our environment and our pocketbooks.

Looking forward, both the EPA and BLM rules have procedural and administrative hurdles to clear before they go into effect, hopefully later this year. Our commitment is to continue tracking and advocating strong methane rules as well as keeping you informed of the opportunities to get these policies over the finish line in 2022. The long-term outlook of Wyoming’s climate, budget and residents depends on it.

A Message from the Director

Posted on by Lisa McGee

Advocating for conservation in Wyoming is demanding work, both for the Wyoming Outdoor Council’s staff and for passionate members like you. Not only are there more issues than we can possibly address as a small organization in a geographically large state, but for people with big hearts and a love for the wild, open spaces of Wyoming, the outcomes are personal. 

We don’t always win. When we do find success, as frequent as it may be, it’s often in the form of a quiet victory or incremental change. The forces working against us — whether it’s government inertia or downright hostile opposition from other stakeholders — can often feel overwhelming. 

But we aren’t in this alone. After all, we have each other. 

Poll after poll shows that the vast majority of our fellow Wyomingites — even if they don’t consider themselves “conservationists” — value public lands, wide open spaces, wildlife, clean air, and clean water. Our challenge is to meet people where they are and attempt to find common ground. The more we make these connections, value multiple perspectives, and seek input from a diversity of people outside of our organization in Wyoming and beyond, the more likely we are to succeed in our mission.

However difficult it may be, an honest and respectful conversation with a person who disagrees with our position does more good than assuming we have all the answers. 

Everything we hope to accomplish depends on relationships. Wyoming is a state where a small group of thoughtful, committed citizens can seek creative solutions to tough problems and make a difference. And, as you’ll read in the coming pages, positive things can happen when a group of people with diverse perspectives put their heads together around an issue of mutual concern instead of staying in their own camps. 

Everything we hope to accomplish depends on relationships. Wyoming is a state where a small group of thoughtful, committed citizens can seek creative solutions to tough problems and make a difference.

Thank you for being part of the Outdoor Council community in 2022. I take comfort in knowing, despite the obstacles and the slow pace of change, we’re all in this together. I hope you’ll remember that as well. 

Everything in its Place

Posted on by John Burrows

EVERYTHING IN ITS PLACE

How do we make sure the coming boom in renewable energy
isn’t a bust for our wildlife and public lands? 

This story, like much of the good work that happens in Lander, began as a meeting over coffee at the Lander Bake Shop. Staff from several conservation groups, including the Wyoming Outdoor Council, had gathered to look at GPS tracking collar data from pronghorn around Sweetwater Solar, Wyoming’s first large-scale solar project on public land.

 The map of the pronghorn’s movement was infuriating — the 700-acre solar development had been placed right in the middle of crucial winter habitat. Fences surrounding the project had funneled many of the animals onto Highway 372 north of the city of Green River, creating hazards for both wildlife and drivers. The impacts of the Sweetwater Solar project on pronghorn were completely predictable and avoidable. But aside from a brief Environmental Assessment required by the Bureau of Land Management, there was little in the existing permitting process to direct the developers to a better location where wildlife conflicts could have been avoided. 

What became clear in that meeting and in subsequent discussions was that the Sweetwater Solar project was likely a harbinger of what’s to come in the next decade as the cost of developing solar and wind energy continues to fall dramatically. 

The expected boom in renewable energy puts advocates for conservation in Wyoming in a challenging spot. We understand the dire importance of transitioning to cleaner energy sources, and at the same time recognize the significant development footprint that utility-scale renewables can have on Wyoming’s wildlife and open spaces. The question and dilemma on many of our minds is this: How does Wyoming decarbonize its electricity production while not sacrificing the crucial wildlife habitat and open space that make it so unique? 

As with many of the challenges our state faces, there is no silver bullet to solve this problem, but common sense and science both tell us that focusing our efforts on responsible siting and permitting processes for renewables is the logical place to start. That’s exactly what WOC tried to do with its effort to jumpstart the Wyoming Renewable Energy Siting Collaborative. 

As with many of the challenges our state faces, there is no silver bullet to solve this problem, but common sense and science both tell us that focusing our efforts on responsible siting and permitting processes for renewables is the logical place to start.

After the 2020 legislative session, WOC started reaching out to stakeholders around the state to understand the perception of renewable energy and ways we might be able to improve our siting and permitting policies. We worked closely with faculty at the University of Wyoming to convene a group of policy thinkers representing conservation, industry, local government, landowners, and independent consultants to explore opportunities for the state to improve how renewable energy is sited. 

During 2021 this group met nine times over Zoom to discuss issues related to renewable energy in Wyoming, including tax policy, federal and state revenue sharing, transmission development, supply chain manufacturing, and other topics. The group also learned from and consulted with experts from the Wyoming Industrial Siting Division, the Wyoming Game and Fish Department, and the Wyoming Wildlife and Natural Resource Trust. The group’s final recommendations were published in November 2021 and can be found on UW’s Ruckelshaus Institute website. 

These recommendations are a start. They form an important foundation for future policy and advocacy work, especially as our country moves to decarbonize electricity production and accelerate the growth of renewables. They also show that industry and conservation can work together to agree on important concepts moving forward. 

Some of the most important points of agreement in these recommendations address the need for more proactive planning for renewable development on public lands, the need for early and frequent consultation with the Wyoming Game and Fish Department to avoid wildlife conflicts, and the need to evaluate previously disturbed locations as places to site renewable energy. There is also strong agreement on the importance of public transparency and engagement as projects move forward so impacted citizens and communities have opportunities for meaningful input on project proposals. 

We know that more wind and solar energy is on the horizon, and the development of these resources will present historic challenges and opportunities for Wyoming. But as with all development, we must insist that this growth be done on our terms — in a responsible and measured way — that does not degrade and diminish the very things clean energy is supposed to protect. Holding that line will require leadership at the state level. It will also take collaborative efforts like the one that played out last year at the University of Wyoming — with the full spectrum of experts and advocates coming together with a shared goal of making sure future development is sited appropriately. We’ve already seen the impacts on wildlife when things go wrong. But done right, renewable energy development could be an asset, not a liability, to Wyoming’s environment and quality of life.

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

Posted on by John Burrows

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.

    ARIEL GREENE: Local climate action takes root in Wyoming

    Posted on by Guest Author

    In the past few years, all around the world, the problem of climate change has been coming to the fore. Now, there is a growing local climate action movement taking root in Wyoming. 

    In different corners of the state, grassroots organizations like the Alliance for Renewable Energy in Laramie, Lander Climate Action Network in Lander, and Jackson Hole Climate Action Collective in Teton County are spreading awareness, fostering engagement, and embarking on the long-term project of reducing their communities’ greenhouse gas emissions.

    These movements are pragmatic, non-partisan, and involve a younger generation in civic affairs. Their parallel efforts form a loose network that is creating collective momentum whereby one group’s progress reinforces the others.  

    In one way, this local action is a surprising development given Wyoming’s deep and long standing economic dependence on the export of fossil fuels — energy sources that power civilization but have the unfortunate side effect of releasing heat-trapping gases into the atmosphere. Moving away from carbon-intensive resources means diminishing state revenues that fund our schools, libraries, police, roads, health offices, and other critical public services.

    On the other hand, changing energy markets have already been shrinking these revenues for years now, and a changing climate has the potential to degrade Wyoming’s quality of life in an even more costly and profound way. Among other things, rising temperatures are projected to increase droughts and forest fires while negatively impacting water supplies and stream flows and the fish, wildlife, and human populations that rely on them. This, in turn, threatens the outdoor recreation, tourism, and agricultural sectors which together form the other main pillars of Wyoming’s economy, and are primary threads in the fabric of our state’s way of life.

    In the past few years, the world has changed in two significant ways:

    First, the cost of solar, wind, and energy storage technologies has plummeted. Low-carbon, renewable energy is now the cheapest form of new electricity production in much of the world. And the cost declines are expected to accelerate as capital investment, economies of scale, and industry competition ramp up.

    Second, a worldwide tectonic shift is taking place as nations seek to decarbonize their economies because of growing concern over climate change. This will only increase the demand for renewable energy sources.

    Whether Wyoming wants it or not, the entire globe is moving quickly away from fossil fuels. This includes not only much of the United States (the traditional market for Wyoming’s mineral sales) but also China, Japan, South Korea, the UK, the European Union, New Zealand, and Canada — countries that together make up more than half of all global economic activity. All have recently announced intentions to reduce their net greenhouse gas emissions to zero in coming decades — plans that will radically transform their societies and promote the development of technologies that will move them away from fossil fuels.

    While working on the nuts and bolts of local policy, Wyoming’s climate movements can not only help reduce our own emissions, save municipalities money in a time of contracting budgets, and prepare communities to be resilient in the face of changing environmental conditions, but they can also draw attention to these larger forces at work. They can play a crucial role in helping us adapt to the historic economic transformation that is underway and envision a viable future for the state. They can create a new sense of what is possible. And if this can be done in Wyoming, it shows it can be done anywhere.

    The task is daunting, but filled with possibility. We are lucky that Wyoming happens to be naturally endowed with the very elements needed to thrive in a new, low-carbon landscape: lots of sun and wind, clean air and clean water, cooler temperatures, big wilderness, easy access to nature, strong communities, and a high quality of life. We’re realizing, more and more, these might be the most precious resources we have.

    Ariel Greene is a Lander resident and member of the steering committee for the Lander Climate Action Network.