“Once you hit a certain point, you have created a sacrifice zone”
by Crystal Kotowski
On March 7, Gunnison County attorney David Baumgarten outlined the county’s scoping comments on Gunnison Energy’s proposed 35-well North Fork Mancos Master Development Plan (NFMMDP) to be sent to the Bureau of Land Management (BLM).
Baumgarten asked the commissioners to analyze the comments for any potential gaps or points of emphasis to be addressed before the comment deadline of March 22. Considering the extent of the master development plan, Baumgarten stressed the importance of including the ramifications of the cumulative impacts in the comments.
Long-term operational life of the project is estimated at 30 years, with an estimated production of up to 700 billion cubic feet of natural gas. Located in Gunnison County near Paonia, the project is adjacent to the proposed 146-well Bull Mountain Master Development Plan, and is the first phase of a planned 13-pad development in the NFMMDP area.
According to the scoping comments, the county is focusing on drainage and erosion control, public roadway and traffic impacts, wildlife and wildlife habitat, livestock and livestock grazing, impacts on recreation, water quality, wells and public water supply, water body buffers, air quality and airsheds, cultural and historic resources, pits, management of hazardous materials, geologic hazards, emergency response, pipeline integrity, impact mitigation costs, demobilization and eventual retirement.
The proposed scoping comments also include such general requests as locating well pads and other facilities in close proximity to existing well pads, pipelines and infrastructure and drilling multiple wells from as few pads as possible. As the development impacts will cross jurisdictional lines with Delta County, Baumgarten noted the significance of heeding the concerns of North Fork citizens.
“Mostly I think we want to bring—in a way we have not brought to comment previously—its cumulative impacts. Cumulative impacts are a fact and are often not considered. There are mechanisms available; the state has three or four systemic ways to address cumulative impacts. And I think it would be right to suggest to the federal government that cumulative impacts be considered,” Baumgarten explained.
He noted that Gunnison Energy participated in the first real cumulative impact analysis effort in the state.
“What we don’t want is this area to become dominated by oil and gas in the near horizon, mid-horizon or long-term horizon. We don’t want to use the word ‘sacrifice zone,’ but we really want to make sure there is a balance. There is a cap beyond which there is no more assimilative capacity; I am not sure what that assimilative capacity is, but we want to explore it. Because once you hit a certain point, you have created a sacrifice zone,” continued Baumgarten, noting the importance of introducing assimilative capacity and the idea of a tipping point to the conversation.
Assimilative capacity refers to the ability of the environment or a portion of the environment (such as a stream, lake, air mass, or soil layer) to carry waste material without adverse effects on the environment or on users of its resources.
“Gunnison County’s intent is to foster non-adversarial, multi-jurisdictional, public-private long-term planning,” the draft scoping comment letter reads. The commissioners did not have substantive changes to the comments, and Baumgarten will be sending working drafts of county scoping comments to various citizen groups. He is seeking feedback. The county will send the official comment letter to the Bureau of Land Management by the deadline, March 22.