Located 100 miles southeast of Grand Teton National Park, Wyoming’s Upper Green River Valley consists of sagebrush mesas punctuated by meandering rivers and verdant ribbons of forest and wetlands. This vast mountain-to-high-desert ecosystem is a land of wide-open vistas and provides critical habitat for migratory big game, songbirds and raptors within the southern reaches of the Greater Yellowstone Ecosystem. Some of the world’s largest herds of mule deer and pronghorn winter here, relying on the Valley’s snow-free forage to get them through harsh winter weather. Ancient migratory pathways lace the area, connecting winter range with the alpine terrain in five nearby mountain ranges. The Valley features the southern half of the continent’s second longest overland migration route, the path a band of pronghorn follows twice a year between the Upper Green and its summer range in Grand Teton. These lands are also a stronghold for sage grouse, the West’s signature native game bird now being considered for listing under the Endangered Species Act.

The Upper Green River Valley encompasses several million acres of mostly public lands hemmed by the Wyoming, Gros Ventre and Wind River ranges. The Bureau of Land Management administers much of the Valley, with its highland flanks administered by the Bridger-Teton National Forest. Conservation groups have long sought to protect the Valley’s mountainous periphery, which abounds in roadless lands of high scenic and recreational value.

Much of this region is leased for oil and gas development, but the BLM and Forest Service have imposed leasing moratoriums on some sensitive areas, such as the Wind River Range foothills. A natural gas boom is in full swing in the Valley, where federal land managers are in varying stages of processing industry requests to expand drilling operations. Measures to protect the Valley’s non-energy resources, such air quality and wildlife, are proving to be ineffective in the face of weak enforcement and poor government oversight. For example, the Pinedale Anticline gas field, which happens to support crucial winter range for mule deer, is supposedly protected by seasonal drilling closures, but these restrictions are routinely waived, and recently released BLM documents show that the agency has failed to follow through with mitigation and monitoring commitments. Nonetheless, the BLM is reviewing a proposal to allow significant year-round drilling here.

The Upper Green is becoming one of the nation’s most significant natural gas plays. Trillions of cubic feet of this energy resource lie two to three miles under the Valley in “tight” sandstone deposits. New drilling technologies and rising energy prices have made tapping this gas very lucrative. As a result, more than 3,000 wells have been drilled in the Valley, and another 10,000 are anticipated in the coming decade. Meanwhile, the Valley’s once pristine air and clear views have been degraded by industrial emissions, principally in the form of diesel exhaust from drill rigs.

A disturbing experiment is under way in the Valley, where we are learning what happens when an extractive industry is turned loose in a sensitive region blessed with numerous natural assets.

The threats oil and gas development pose to the Upper Green are legion. And yet federal land managers are authorizing massive drilling proposals without adequately analyzing this development’s accumulating impacts on the region’s air, wildlife, economy and quality of life. A disturbing experiment is under way in the Valley, where we are learning what happens when an extractive industry is turned loose in a sensitive region blessed with numerous natural assets.

The Valley’s mountain-to-mountain views are now more often obscured in a brown haze that frequently clogs the skies over Pinedale. The town’s rural pace of life has been shattered by social problems associated with the sudden influx of development. Sublette County is experiencing rising crime (particularly methamphetamine use, poaching and domestic violence), overstressed social services and infrastructure, escalating home prices, and labor shortages.

Government studies have documented declines in the air quality at Yellowstone and Grand Teton National Parks and alpine lakes in nearby wilderness areas are beginning to show alarming levels of acid deposition. These disturbing trends coincide with the boom in natural gas development in the Upper Green. In the Valley, meanwhile, ambient levels of pollutants such as ozone and particulate matter are at times approaching thresholds set for protecting human health, and nitrous oxide emissions from the gas fields are triple the levels anticipated by land managers.

The Valley’s wildlife is also taking a beating. Industry-funded wildlife researchers have documented a 46 percent decline in the number of mule deer wintering on the Pinedale Anticline and have shown that deer and pronghorn tend to avoid their preferred winter range near industrial facilities. Conservation biologists are concerned that development in and near migration corridors could sever the crucial biological link between the Valley’s winter range and the mountains, where vast numbers of free-roaming ungulates spend the summer and birth their young. Meanwhile, by ignoring the advice of a citizens’ advisory panel, the BLM has virtually abandoned adaptive management as a strategy for mitigating industry’s impacts.

More than 3,000 wells have been drilled in the Valley, with more than 300 new wells drilled every year. Much of this activity is centered in the Pinedale Anticline and Jonah gas fields, which account for the bulk of the Upper Green natural gas production, valued at more than $4 billion a year. Initially approved for about 500 wells, the Jonah was recently given the green light for “infill” development that will result in up to 3,100 new wells, essentially turning the 30,000-acre field into an industrial sacrifice zone. The Wilderness Society has challenged the Jonah infill Record of Decision on the grounds that the BLM’s approval would allow unacceptable air quality impacts on visibility, human health, and wilderness lake quality.

Important precedents are at stake. Industry expects to pursue a similar infill proposal for the Pinedale Anticline, which overlaps crucial winter range for mule deer. These two gas fields were developed far more rapidly than had been anticipated, rendering their environmental reviews inadequate.

New energy leasing in the Valley should be halted until the BLM revises its Resource Management Plan (RMP) for the Pinedale area. The Wilderness Society, in concert with the local grassroots group Upper Green River Valley Coalition, has issued a Responsible Energy Development proposal to guide the RMP revision process. We are asking the BLM to pace development, cluster infrastructure, adhere to seasonal drilling restrictions, require immediate reclamation of disturbed areas, and permanently withdraw certain critical areas from future leasing.

The BLM should consider taking steps to curtail drilling if certain thresholds regarding air quality and wildlife health are breached. The agency must also make honest assessments of industry’s impacts on the environment, taking into account its cumulative and regional effects. Wildlife migration routes, critical winter range and river corridors need to be formally delineated and permanently closed to development. Finally, for adaptive management to succeed, the BLM must support the Pinedale Anticline Working Group and heed its recommendations.

Peter Aengst, The Wilderness Society, 406/586-1600
Linda Baker, Upper Green River Valley Coalition, 307/367-3670
Bruce Pendery, Wyoming Outdoor Council, 435/752-2111
Lloyd Dorsey, Greater Yellowstone Coalition, 307/734-6004

Web site: www.uppergreen.org