Coalbed Methane Produced Water In The Western Us

• For water to be disposed of in injection wells, operators must also submit a copy of the Underground Injection Control (UIC) permit (unless the well is authorized by rule).

• An application must be submitted for CBM water produced on federal lands that is to be disposed of "off-lease" on state and privately owned lands; a copy of the UIC permit for injection wells or pit permit may also be required (BLM, 1993).

Additionally, this order identifies informational requirements for injection wells and pits; requirements governing pit design, construction, maintenance, abandonment, and reclamation; requirements for other disposal methods; and reporting requirements for disposal facilities. Operators may request different considerations from the standards of the OOGO.

Collectively, the Federal Land Policy and Management Act, the CWA (see below), and related executive orders guiding BLM's management of public land and resources require the agency to comply with all federal and state laws and regulations governing water pollution that may result from BLM permitted projects and activities. Operations from the point of origin (primarily the well head) to the point of discharge are under the jurisdiction of the BLM. Operations from the point of discharge downstream are under the jurisdiction of EPA or the primacy state.


The USFS is primarily responsible for managing surface resources on national forest lands, while the U.S. Department of the Interior, through the BLM, has statutory responsibility for issuing and supervising mineral leases on all federal lands including national forests. The USFS cooperates with the Department of the Interior in administering exploration and development of leasable minerals, including the review of permit and lease applications and making recommendations to protect surface resources (USFS, 1994). For example, the USFS and BLM worked jointly to develop the EIS for the Northern San Juan Basin CBM Project. The EIS examined potential impacts of new CBM wells on USFS, BLM, state, and private land in southwestern Colorado (USFS, 2006). As is the case with BLM, the USFS is required to take into account NEPA provisions in its management of surface resources.

Bureau of Indian Affairs

The Bureau of Indian Affairs (BIA) manages 55 million acres of surface and 57 million acres of subsurface minerals estates held in trust by the United States for American Indians, Indian tribes, and Alaska Natives. The Office of Indian Energy and Economic Development within the BIA is responsible for assisting tribes in developing their energy and eco nomic resources. The BIA Office ofTrust Services' Division of Natural Resources oversees issues and provides guidance related to development and protection of natural resources, including protection of Indian water rights and fish and wildlife on Indian lands.11

The Omnibus Indian Mineral Leasing Act of 1938 and the Indian Mineral Development Act of 1982 require the Bureau of Indian Affairs (BIA) to authorize energy leases. The BLM processes Applications for Permit to Drill (APD), Master Development Plans, and Sundry Notices on tribal and allotted oil and gas leases in a way that is similar to federal leases. However, approval procedures, such as cultural resource and other environmental requirements, may vary depending on tribal ordinances and whether tribes have assumed the functions of a State Historic Preservation Office. Both the tribe and BIA may recommend further conditions of approval to the APD. NEPA applies to these decisions, although qualifying tribes are permitted to enforce environmental laws, set regulations that are more stringent than federal minimum standards, and regulate aspects not covered by federal laws or programs (Bryner, 2002). For processing APDs, BLM considers the BIA to be the surface management agency for all Indian lands unless a tribe has contracted the BIA realty function for its lands. Oil and gas operators are responsible for obtaining any special use or access permits from appropriate BIA and/or tribal offices (BLM and USFS, 2007).

Tribal governments each have their own departments in areas of environmental protection and natural resources. These departments are directly engaged in research, analysis, monitoring, and regulation of oil and gas development (including CBM) and environmental management in concert with relevant federal agencies (see Appendix F and next section on EPA).

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