Scoping Comments – Saddle Butte Piñon Pipeline Project

The Western Environmental Law Center, along with Amigos Bravos, Chaco Alliance, Diné Citizens Against Ruining our Environment, Earthworks, Natural Resources Defense Council, San Juan Citizens Alliance, and WildEarth Guardians (together “Conservation Groups”), submit the following Scoping Comments regarding the Bureau of Land Management (“BLM”) Farmington Field Office (“FFO”) Environmental Assessment (“EA”) regarding the Saddle Butte San Juan Midstream LLC’s Piñon Pipeline Project (hereinafter “Piñon Pipeline”). The Piñon Pipeline is approximately 140 miles in length—including 49.5 miles of gathering pipeline and 89.5 miles of transport pipeline—and includes a 75-foot right-of-way, accounting for 10,500 square miles of surface disturbance. These lengths are consistent with the application submitted by Saddle Butte San Juan Mainstream, LLC, (Application No. NMNM 133052). However, BLM’s scoping notice identifies only 80 miles of transport pipeline. BLM should revise its scoping notice to be consistent with the pipeline lengths identified by the project proponent, and future analysis should reflect the correct pipeline length. The Pipeline includes an anticipated capacity to transport 50,000 barrels per day (“BPD”) of crude oil to transport facilities along the Burlington Northern Santa Fe (“BNSF”) rail line for export. Of note, BLM’s scoping notice is misleading in that it only identifies “initial startup volumes of 15,000 barrels per day” rather than total pipeline capacity. Although actual pipeline volumes can fluctuate, the public should be made aware, and BLM’s analysis should account for, the pipeline’s total 50,000 BPD capacity.