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The BLM comment period for a proposed carbon sequestration project in Carter County is now open until November 27, 2023.
According to a BLM news release, "The Bureau of Land Management is seeking public comment on a proposal to permanently store carbon dioxide in underground rock formations on public land in Carter County. The Denbury Carbon Solutions, LLC project would store carbon dioxide in more than 100,000 acres of subsurface pore space."
The proposal is referred to as the Snowy River Carbon Dioxide (CO2) Sequestration Project.
Denbury Carbon Solutions, LLC, a subsidiary of Denbury, Inc., which was recently purchased by ExxonMobil has used a process called enhanced oil recovery for more than 20 years. A pipeline already exists across much of Wyoming and into Montana and North Dakota. The proposed carbon sequestration site would be peripheral to the current pipeline. New supply lines would be built to meet up with 15 new injection wells, which would push the CO2 deep underground.
Carter County
Carter County Commissioner Pam Castleberry is concerned that her constituents have not had enough time to learn about the project and will not be able to research the concept and submit meaningful comments by the deadline.
"Our main concern right now is that the public needs more time to learn about this," said Castleberry, who said she herself is still trying to gather details on the proposal.
Castleberry said that the Carter County Commission will, at some point, need to meet with Denbury to draw up road use agreements.
She also said that at an Oct. 12, 2023 BLM informational meeting, a good showing of concerned landowners attended, and many seemed taken aback by the idea.
"I felt like the folks were a little alarmed just finding out about this and not really being informed," she said.
Castleberry said she asked the BLM to extend the comment deadline and was told that an official request would need to be made.
Castleberry and her husband ranch in the Ekalaka area, but their ranch is north of the proposed site.
TSLN learned that The Northern Plains Resource Council did, on Oct. 13, 2023, request a 90-day extension of the comment period, saying that ranchers are busy shipping cattle and have not had time to fully evaluate the proposal.
On Tuesday, the Bureau of Land Management announced that it would be extending the public scoping period by 30 days for an overall 60-day comment period.
"We want to ensure everyone who would like to, has the opportunity to provide their comments on this project application," said Eric Lepisto, Miles City Field Manager. "This is part of the process; to solicit public input on issues, impacts, and potential alternatives the BLM needs to inform the environmental analysis, on this proposal."
The new scoping period will end November 27, 2023.
Landowner concerns
Because the project requires additional pipeline to be built, 15 wells to be dug, and local roads to be used, local landowners are concerned.
Ekalaka rancher Mike Hansen, who has ranched in the area for over 40 years, and whose adult children are now involved in the business, said some of the privately owned land in the middle of the sequestration project is his.
He is not pleased that he is just now finding out about the project. He learned at the recent BLM informational meeting in Ekalaka that BLM and Denbury have been in negotiations on the project for a couple of years.
He is concerned for the condition of the roads, as well as the potential for noxious weeds to be introduced, water to be negatively affected, and more. He fears that no amount of public comment will stop the project.
He said one of the meeting-goers asked the BLM how much the agency is being compensated but the BLM responded that payment is still in negotiation.
"We're going to tear up our roads. Gravel will have to come all the way from Belle Fourche or Miles City, they'll tear up the highway," he said. Hansen said the main gravel road in the area is just one lane – when his family hauls semi loads of cattle out, they send a flagger down the road to stop traffic because there isn't room for two vehicles to meet on the road. He said the equipment needed to build and maintain the carbon wells will likely damage the roads and could be dangerous to other drivers.
Hansen is concerned that a CO2 leak could contaminate water. His cattle graze on BLM allotments on the surface of the land being considered for the sequestration project. They drink water from shallow wells and also reservoirs and other surface water.
At this time, the BLM is not proposing any changes to grazing permits as a result of the carbon sequestration project, he said.
Three of the proposed injection wells are located on his grazing permits, and some are within a mile or a mile and a half of his private land.
Hansen also believes his mineral rights and surface rights could be violated if the CO2 affects minerals under the surface of his private land or the forage itself.
He asked the BLM about this at the meeting. The BLM representative said they will address those concerns if and when they happen. The BLM representative also reportedly assured him that the CO2 will remain underground.
For now, Hansen doesn't believe his grazing permit will be affected directly, but he worries about fences being destroyed, possible CO2 leaks causing harm either directly or indirectly, and has other concerns.
"I said, 'If this comes up and contaminates our water, we are out of business. The bank will foreclose on us,'" Hansen said.
Hansen points out what he sees as the irony of a project intended to limit carbon emissions, which will require large equipment, soil interruptions and more. "We are going to tear up our roads, bring in noxious weeds, so Denbury or ExxonMobile can make money off a tax credit," he said.
In January 2021, the U.S. Treasury amended and expanded the 45Q tax credit providing a $35/ton incentive for CO2 capture and use in EOR operations and $50/ton incentive for captured CO2 that is permanently stored, according to the Denbury website.
BLM could not immediately be reached for comment.
Background on Denbury and "the Project"
On Nov. 28, 2021, Denbury submitted rights of way application for a 30 year term to construct: access roads, well pads, main bulklines (i.e., main supply pipelines), flowlines (i.e., branch supply pipelines), pump stations and offices, and for use of federal underground pore space to sequester CO2, according to a Denbury Plan of Development.
According to the proposal, about 15 class VI injection wells will be dug. Those wells will inject CO2 from the existing Denbury Cedar Creek Anticline Pipeline, which is a 105-mile pipeline transporting CO2 from the Bell Creek Oilfield in Powder River County, Montana, to the CCA Enhanced Oil Recovery (EOR) unit development in Fallon County, Montana.
The Denbury plan reports that the carbon sequestration location would encompass pore space under about 110,100 acres in southeastern Montana. About 91 percent or 100,616 acres are BLM, about eight percent, or 8,299 acres are state (school) land, and about one percent or 1,185 acres are privately owned.
Denbury said that the Project location and subsurface pore space formation were selected for the following reasons:
• Proximity to existing pipelines and CO2 sources
• Reduced number of affected landowners
• Low mineral development potential in the Project area
• Suitable reservoir porosity, capacity, and seal continuity.
• Low risk of seismic activity.
Denbury Carbon Solutions, LLC, a subsidiary of Denbury, Inc., which was recently purchased by ExxonMobil has used a process called enhanced oil recovery for more than 20 years. This process, according to the US Department of Energy, can utilize gas injection, "which uses gases such as natural gas, nitrogen, or carbon dioxide (CO2) that expand in a reservoir to push additional oil to a production wellbore, or other gases that dissolve in the oil to lower its viscosity and improves its flow rate. Gas injection accounts for nearly 60 percent of EOR production in the United States."
According to the Denbury website, "Denbury owns and operates the largest CO2 pipeline network in the world and has extensive experience managing the safe transportation, injection, and monitoring of CO2." Denbury operates two carbon pipelines, one in the Gulf Coast region, the other in Wyoming, Montana and North Dakota.
From Denbury: "Denbury began operations in the Rocky Mountain region in 2010, and we currently have interest in 18 separate oil fields located in Wyoming, Montana, and North Dakota.
"Currently, more than half of our production comes from secondary oil recovery whereby we are flooding the producing reservoirs with water to displace oil which is then produced to the surface. Our largest waterflood project, the (Montana) Cedar Creek Anticline ("CCA"), is also currently undergoing carbon dioxide ("CO2") flooding for the first time.
"Within our Rocky Mountain Enhanced Oil Recovery ("EOR") operations, we utilize CO2 captured entirely from industrial sources which would otherwise be released into the atmosphere, to increase oil production. This captured CO2 helps us recover additional oil from mature fields, while lowering emissions by storing CO2 underground."
Denbury didn't respond to a request for an interview, and it is not known whether the CO2 that Denbury proposes injecting into the site will have been already used for enhanced oil recovery. In addition it is not known whether the CO2 could, at a future date, be used for enhanced oil recovery.
According to Denbury, the project is being completed in order to achieve "the Administration's" goals to reduce carbon emissions and to help the company meet its pledge to fully offset CO2 emissions by 2029.
Denbury estimates the project area injection potential to be approximately 450 million cubic feet per day over the course of 20 years, for an estimated 150 million tons of CO2 injected.
According to Denbury, approximately 40 miles of pipelines, including bulklines and flowlines, will be required for the project.
Reprinted with permission from Tri-State Livestock News. This article was updated to include the new comment period.
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