Document vVjEdRxKVNZ5384pZy8mxZZNb

SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 September 30, 2017 The following outlines the BLM response to the directives included in Secretarial Order 3355, Strea mlining National Environmental Policy Act Re views and Implementation of Executive Order 13807, "Establishing Discipline and Accountability in the Environmental Review and Permitting Process for Infrastructure Projects ' (August 31, 2017). S .0 Directive IM ethod to Ac hieve Directive Section 4.a. Settinq Paqe and Timing Limitations for Environmental Impact Statements. To implement the longstanding directives in 43 C.F.R. 46.405, and in 46.240 C.F.R. 1500.4 and 1502.7, all EISs 1) for which a bureau is the lead agency and 2) that have not reached the drafting stage shall not be more than 150 pages or 300 pages for unusually complex proje cts, excluding appendices. A pproval of the Assistant Secretary with responsibility for the matter, in coordination with the Solicitor, is required to produce an EIS exceeding the above stated page limitations. In instances of EISs prepared with bureaus serving as co-leads, each responsible Assistant Secretary shall I nstru cti on Memorandum (I M) (or other guidance) is forthcoming. The IM will provide step-down guidance on how to meet the requirements of this directive. In addition, to meet the flexibilities for time limits under 43 CFR 46.240(b), the I M will provide guidance on how to elevate environmental impact statements for review that will not meet page limits or target time limits, including Environmental Impact Statements (EIS) for which a Notice of Intent has already been published by the issuance date of the IM and those EISs associated with the following: resource management plans (RMP), RMP amendments; programmatic reviews; major energy, transmission line, utility corridor, transportation, or other infrastructure projects that require amendment of a land use plan or plans; and where BLM is the co-lead with a non Department of the Interior agency (federal or 2 state) that is not subject to the order . 1 The exemption for planning actions is based in part on timeframe requirements established in 43 CFR 1601 and 1610 that govern RMPs and RMP amendments (e.g., scoping, 90 -day comment period on draft RMPs, 60-day governor's consistency review, 30 -day protest period, and 60-da y review for Areas of Critical Environmental Concern (ACECs)). This makes completing an RMP or EIS level amendment in 12 months virtually impossible. Moreover, issue complexity and size of affected planning area automatically require greater scope and breadth of analysis, which require lengthy review for the RMPs; RMP amendments; programmatic reviews; and major energy, transmission line, utility corridor, transpo rtation, and other major infrastructure projects. 2 Executive Order 13807 on "Establishing Discipline and Accountability in the Environmental Review and Permitting Process for Infrastructure" establishes a target timeline of 2 years to complete environmental revie ws or analysis associated with major infrastructure projects. Executive Ord er 13807 does not apply to 1 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 approve any deviations from this policy. To meet the page limitations, each preparer should focus on various techniques such as tiering or incorporation by reference. (2) To ensure timely completion of EISs, and consistent with the timelines established for major infrastructure projects in E.O. 13807, each bureau shall have a target to complete each Final EIS for which it is the lead agency within 1 year from the issuance of a Notice of Intent (NOI) to prepare an EIS. T he initial timeline must be developed by the lead bureau before issuing the NOI in accordance with 43 C.F.R. 46.240, taking into account all relevant timing factors listed therein, including any constraints required by cooperating agencies. An updated timeline should be prepared as needed during the development of the EIS (e .g., at the completion of scoping or if additional time is provided for public comment). Timelines exceeding the target by more than 3 months must be approved by the Assistant Secretary with responsibility for the matter. In instances of EISs prepared with bureaus serving as co-leads, each responsible Assistant Secretary must approve any deviations from this policy. non-infrastructure projects. Coordinating and cooperating agencies outside of the Department of the Interior may not have the same 12 month time constraints agencies within the Department. 2 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Section 4.b. Settinq Tarqet Paqe and Timinq Limitations for the P reparation of Environmental Assessm ents. ^Vithin 30 days, each bureau head shall Both the Council on Environmental Quality's (CEQ) regulations implementing NEPA3 4a5n6 d provide to the Deputy Secretary through its DOI s NEPA regulations include considerations related to establishing time limits supervising Assistant Secretary a proposal for target page limitations and time deadlines for the preparation of environmental associated with NEPA documents, including those that would apply to Environmental Assessments (EAs). In addition, CEQ guidance provides a general page range and additional considerations regarding the appropriate length of EAs. assessments. Any common impediments to achieving the proposed targets should also be The BL M solicited field input when developing recommendations for EA page and time identified. In developing its proposal, each limits associated with this Directive. BLM State offices identified several tools, such as bureau should consider guidance from CEQ incorporation by reference and applying principles of Process Improvement and on the page length of environmental assessments. (F o rty Most Asked Questions Concerning CEQs National Environmental Policy Act Regulations, 46 Fed. Reg. 18,026, 18,037, Question and Answer 36a. (Mar. 23, 1981)). Operational Risk M anagement, that can save time and page length, however, they also identified risks if these approaches require the decision maker and public to review several documents to understand the full context of an issue. Additionally, State Offices requested that consequences of page and time limits be considered relative to approaches which are intended to provide flexibility in project implementation, such as adaptive management strategies, that requires more rigorous analysis at the site-specific stage. 3 Although the CEQ has decided that prescribed universal time limits for the entire NEPA process are too inflexible, Federal agencies are encouraged to set time limits on a case-by-case basis appropriate to individual actions, considering the factors in the CEQ regulations at 40 CFR 1501.8 and 40 CFR 1506.10. 4 On a case-by-case basis, each proposed action shall set target time limits, in consultation with cooperating agencies, that reflect the availability of Department and bureau personnel and funds (43CFR46.240). 5 CEQ guidance indicates that 10-15 pages is generally appropriate for EAs (S ee Question 36a in Forty Most Asked Questions). In addition, subsequent guidance expanded upon the subject and allows for greater page length when preparing complex EA. (S ee Final Guidance on Improving the Process for Preparing Effi cient and Timely Environmental Reviews Under the National Environmental Policy Act, 2012). 6 Incorporation by reference is useful when a BLM office needs to utilize an analysis prepared by a non- DOI agency or for a previous BLM action. For example, the Anchorage Field Office incorporated by reference a CX prepared by the US DOT's Federal Highway Administration (FHWA) on a cooperating agency project. BLM NEPA regulations do not allow the BLM to adopt a CX prepared by a non- DOI Ag ency, and BLM cannot tier off a CX- level document. However, the Anchorage FO was able to incorporate the CX into their own CX to save on the time of preparing two different federal analyses. Th is is also helpful when an agency such as the FHWA prepares a CX with an EA -level analysis, and the BLM wants to incorporate the analysis into their own EA. The BLM NEPA Handbook also states you cannot tier an EA off of a CX. 3 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Based on the considerations included in the CEQ and DOI NEPA regulations and guidance and feedback from the field, the BLM recommends the following EA page and time limits. Simple proposals (such as wildlife improvement projects, recreation permits, minor timber sales with no critical habitat, Appl ications for Permit to Drill (APD) in already disturbed areas) for which only a few issues are identified can generally be adequately analyzed within 10-25 pages (not including appendices) and, unless a planning decision is needed, take 1-2 months to produce (depending on the amount of public involvement included). Complex or controversial proposals , oil and gas full field development projects, ti mber sales in spotted owl habitat, RMP decisions supported by an EA, and programmatic EAs) typically require 25-50 pages (or more on a case-by-case basis) to adequately analyze the environmental impacts associated with issues related to the proposal (page length does not include appendices) and should generally take no more than 5 months to produce (depending on the amount of public involvement included). Achieving the timeline targets noted above will require streamlined compliance with Section 106 of the National Historical Preservation Act and Section 7 of the Endangered Species Act. E xamples of concise, focused EA analyses include, Appl ications for P ermit to Drill, M idway-Sunset, Bakersfield F ield Offi ce in Cali fornia, Oil APD Drilling EA T imber Harvest in Godiva Rim Area from Little Snake F ield Offi ce in Colorado, Timber Harvest F ocused EA Focused EA example from the F orest Service, Commercial Harvest of Spruce Tips (Special F orest Products) from Sitka Ranger District, Tongass National F orest, Special Recreation/F orest P roduct F ocused EA Instances where analyses extend beyond 50 pages should be exceptions, and represent a minor fraction of analyses performed. Offi ces are strongly encouraged to utilize programmatic NEPA to address instances where projects are typically of a complex or controversial nature. 4 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Section 4. c. Additional NEPA-Streamlininq R eview. (1) The Deputy Secretary will coordinate a 1^mpedmants.ao^^icianLaad^^fecLive.^Raviaws review of the Departments NEPA Recommendations contained elsewhere in the body of the BLM Report in Response to procedures to identify additional ways to streamline the completion of NEPA Secretarial Mem orandum on Improving P, anning and NEPA Processes and Secretarial Order 3355cover a spectrum of approaches to improve the BLM's resource management responsibilities. The review will include, but planning and NEPA processes. Based on a review of BLM NEPA procedures, policies and is not limited to, the following areas: (a) bureau/office NEPA regulations, policies, guidance, the following were identified as impediments to efficient and effective reviews: U nderuse of existing Categorical Exclusions (CX) and a lack of newly developed guidance, and processes to identify: 1) CX s for routine actions conducted by many BLM programs. impediments to efficient and effective reviews; 2) best practices and whether they L ack of a robust analysis of resources at the planning level, which restricts the ability to utilize a Determination of NEPA A dequacy (DNA) to cover certain can be implemented more widely; and 3) whether the Department should consider implementation level decisions, especially for oil and gas leasing decisions. Current policies and guidance, specifically BLM's NEPA handbook, do not establishing additional categorical exclusions effectively promote mechanisms for streamlining such as tiering to related NEPA or revising current ones; analyses that have already been prepared; conducting issue-based analyses; and engaging external stakeholders earlier in the process. L imited or no involvement of cooperating agencies, particularly from regulatory agencies whose participation may be required due to their own statutory obligations (e.g., Endangered Species Act Sec. 7 consultation), early in the NEP A process- specifically before scoping. L ack of accountability for the development of competencies related to a BLM employee's role in the NEPA review process (e.g., line officer, NEPA practitioner, ID T eam member, project manager). L imited access to a national contracting vehicle for use on future actions requiring compliance with NEPA. I nefficient, inconsistent, or untimely State and/or ^W ashington Offi ce briefings and F ederal Register Notice reviews and procedures. BestPLacLicesfor NEPA Strea miining The following recommendations were identified elsewhere in the body of the BL M Re port in Response to Secretarial Mem orandum on Improving Pl anning and NEPA Processes and 5 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Secretarial Order 3355 as best practices that can be applied more broadly throughout the BLM to improve the NEPA process. These best practices demonstrate greater responsiveness to local needs, achieving cost and time savings, and reducing litigation risk, while continuing to fulfill the BLM's legal and resource stewardship respons ibiliti es. Conduct the lowest level of NEPA review required. M aximize opportunities for adopting NEPA documents, tiering from completed NEPA documents, and using DNAs. Utilize an issue-based approach to identifying and eliminate specific issues for detailed analysis. Conduct outreach prior to publication of a Notice of Intent (NOI) to develop an EIS to identify and address issues early in the NEPA process, with a particular focus on outreach to impacted regulatory agencies that may affect the project outcomes. Provide a public review period on preliminary EIS alternatives, prior to formal publication of preferred alternatives in a notice of availability of the EIS. This "front loading" may add time initially, but time will be saved at the end by greater consensus and lessening chances for protest/appeal. Institute a corporate approach to document and data management for core data, while still allowing for incorporation of locally generated data that meets established data quality standards. Enhanced use of contracting, including utilizing nation-wide contracts and improved protocols and guidance for evaluating NEPA contract performance. C. (CXs) Based on BLM's review, there are significant opportunities to expedite the NEPA process by exploring new and modifying existing categorical exclusions (CXs), either through issuance of legislation or policy, in order to provide greater clarity and efficiency to NEPA compliance. BLM's NEPA and Planning Streamlining Report proposed the modification or creation of specific CX s for many routine actions undertaken by various BLM programs; including wild horse and burro, oil and gas, fire and fuels management, range management, recreation, and land use planning. (see Section on Improving the NEPA P rocess). 6 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Ensure that the BLM and cooperating agencies follow transparent and coordinated processes with State, Tribal, and local agencies for conducting environmental reviews and making authorization decisions. Coordination can be conducted outside of the timeframes for the preparation of an EA. Use a performance accountability system for EIS-level projects (possibly as a new feature in ePlanning) involving cooperating Federal agencies. Use the following criteria to evaluate performance accountability: o EIS- level projects shall use a permitting tracking system; o BLM and cooperating agencies shall track the time it takes to complete the processing of environmental reviews and authorizations for each EIS -level project; o EIS- level projects shall follow an effective process that automatically elevates instances in which permitting tracking milestones are missed or extended, or are anticipated to be missed or extended, to appropriate senior agency officials; o BLM and cooperating agencies shall meet established dates for their permitting requirements; and o BLM and cooperating agencies shall develop and utilize a process to routinely track costs 11 of the environmental reviews and authorizations for each EIS- level proje ct. The BLM and cooperating/lead Federal agencies will record all agency decisions in one combined Record of Decision (referred to in E.O. 13807 as "One Federal Decision,"), unless: o Project sponsor/applicant requests that each agency prepare a separate decision o NEPA obligations of a cooperating/lead agency have already been met, or o L ead Federal agency determines that a single ROD would not best facilitate completion of the project's environmental review and authorization process 11 Whil e the BLM as a lead agency may not have the authority currently to req `infrastructure projects' under Executive Order 13807. re other a gencies to track their costs, the BLM s mandated to do so on 8 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 (d) Recommendations for actions to streamline CEQ NEP A regulations and guidance to assess whether to recommend changes to facilitate agency processes. (2) ^Within 30 days of the effective date of this Order, each Assistant Secretary, in coordination with bureau heads, should If a combined ROD is chosen, the BL M and cooperating/lead agencies will all agree to a timeframe and dates for the completion the of the ROD, as well as timeframes and dates for federally required permits and authorizations, All Federal authorization decisions for the construction of an EIS_level project shall be completed within 90 days of the issuance of a ROD by the BL M or lead Federal agency, provided that the final EIS includes an adequate level of detail to inform agency decisions pursuant to their specific statutory authority and requirements, The B LM/lead F ederal agency may extend the 90_day deadline if. O B LM/lead F ederal agency determines that F ederal law prohibits the agency from issuing its approval or permit within the 90_day period O The project sponsor/applicant requ ests that the permit or approval be delayed past 90 days O There is an appeal under BL M regulations or to IB LA O B LM/lead Federal agency determines that an extension would better promote 12 completion of the projects environmental review and authorization process In order to facilitate agency processes, elsewhere in the body of the BL M Re port in Response to Secretarial Memorandum on Improving Planning and NEPA Processes and Secretarial Order 3355 identified the following potential changes to CEQ NEPA regulations and guidance. Modify CEQ NEP A regulations to allow for adoption of state and tribal environmental documents, Provide guidance on further defining reasonably foreseeable future aCtlOnS SO aS tO address the scope of a cumulative impacts analysis and clarify the effects of connected nonfederal actions on the determination of significance for federal actions, See above items that address this action, 12 Note that while this BMP may allow flexibility on non-infrastructure EIS projects, this BMP is taken from Executive Ord er 13807. I nfrastructure projects as defined in Executive Ord er 13807 mandate the BLM to follow the 90 day deadline, and be requ ired to demonstrate why they canno t meet such a deadline. 9 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 provide recommendations for actions to strea mline the NEPA process to include potential regulatory revisions, development of revised or additional categorical exclusions, revised or new guidance or policies, and recommendations on streamlining the surnaming process. 4. d. The Deputy Secretary will also coordinate implementation of E.O. 13807. (1) In order to begin implementation of E.O. 13807, each Assistant Secretary, in The BLM identified the following impediments and potential solutions to implementing E.O. 13807: coordination with the bureau heads, is hereby directed to identify: (a) potential impediments to efficient and effective reviews for ... infrastructure and develop an action plan to address such impediments as a subset of the review required in Sec. 4c(l) (a) above; Reasonable alternatives: CEQ guidance is not clear on how agencies should address alternatives outside of their jurisdiction. Solution. Provide clarity on when agencies must consider alternatives outside of their jurisdiction, especially when such alternatives conflict with laws, policy, or guidance. Timeframes working with the Federal Energy Regulatory Commission (FERC): FERC (b) potential actions that could be taken by has more critical timeframes for completing its EISs than the BLM , and its NEPA CEQ to facilitate a review of major documentation does not always include all the information BLM needs to meet its own infrastructure projects, as a subset of the review required in Sec. 4c(l)(d) above; and NEPA requirements. As a result, the BLM often must complete supplemental NEPA analysis to cover what FERC has omitte d. The BLM is also often not contacted by, for instance, a pipeline company for a right-of-way (ROW) across BLM l and until FERC is months into its review. Solution. CEQ has been tasked with creating an interagency working group under Executive Order 13807 to identify and recommend solutions to impediments to successful interagency infrastructure projects. BLM and FERC should implement solutions that the working group formulates. Solution. Develop/update MOU with FERC on roles and responsibilities on interagency projects. Include ^W estern Are a Power Administration, Bonneville 10 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Po Administration, Department of E nergy, an d Department of Defense in the MOU. Tribal Consultation timeframes: Time needed for effective government-to-government consultation can be longer than what the Secretarial Order allows for project timeframes. Solution. Conduct ongoing consultation with tribes to pursue sufficient working relationships. Begin consultation on specific proposals early in the pre-application p T 13 phase. Ensure that early communication with Iribes is consistently initiated. W orking with project applicants: Impediment. Applicant requests that project be put on hold indefinitely. Solution: Establish a method to take these projects offline or stop the clock on the NEPA processing timeline until the project either continues or request is withdrawn. I mpediment: Applicant fails to submit a complete package. Solution. Create a thorough application package checklist and work with applicants to ensure they submit needed materials in a timely manner. Do not start the NEPA processing "clock" until application is complete. M ultiple levels of NEPA: S ome programs involve multiple decision points, and therefore may require multiple "layers" of NEPA to support each of these decisions. For instance, regarding one oil and gas well, lease issuance requires NEPA compliance (completed either through the resource management process, or as a stand-alone analysis) as does site-specific approval of the Appl ication for Permit to Drill (APD) on that lease and another (or multiple) approvals for the pipelines/roads/powerlines/injection wells that might be associated with that lease or well. Solution. Obtain the proposed pipeline application or application information with the APD. C hange BLM regulations to require the APD applicant to provide this information if it is available, or require that those without associated pipelines be relegated to the bottom of the priority pile. 13 States should note when Tribal consultation timeframes will be notably long, i.e. Tribes not available fo r consultation during seasonal subsistence in Alaska, and small Tribes with limited resources requiring more time with staff for effective consultation. n SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Endangered Species Act C onsu Itation . FWS biological opinions (BOs) for Section 7 consultations can be very time consuming processes (i.e. over a year). Solution: EEssttaabblliisshh u up pffrro on ntt MOUs or programmatic BOs on how BLM and FWS 1415 will handle certain situations. (c) pending proposals for major infrastructure projects, as defined in E.O. 13807 and that are not yet the subject of a NOI issued by the Department, that could be candidates for the "One Federal Decision" process. projects (2) W ithin 30 days of the effective date of this Order, each Assistant Secretary, in coordination with the bureau heads, should provide the information requested in Sec. 4d(l)(a)-(c) above. State Alaska Pending Proposals for M^ ajor Infrastructure Projects164 15 Field Offi ce Arctic FO Name of Project Applicant Greater Mooses ConocoPhillips Tooth Two Alaska, Inc. (CPAI) Type of Project Plan of development to support up to 48 oil wells, including a production pad, pipeline, and road. A N oti ce of I nte nt has already been issued for this EIS, but the effort is still in its early stages. 14 Th e time to prepare MOU s fo r projects should be factored into timeframes for projects, especially EAs. 15 Note that the Fish and ildlife Service has a minimum of 120 days to complete a Biological Opinion f o r a proposed action. 16 This list is not comprehensive and could also include additional infrastructure development supported by locatable minerals, leasable coal, other leasable fluid mineral project authorizations not already listed herein, and in some cases timber sales. Proje cts listed meet the following criteria, 1) those that have not yet issued a Notice of Intent (NOI) to prepare an environmental impact statement (per SO 3355 directives), those that would require multiple agency authorizations, e.g. a ROW from the Forest Service or a Biological Opinion from the Fish and Wildlife Service (per definition of "authorization" in E.O. 13807); 3) meet t he definition of "infrastructure project" in E.O. 13807, including energy projects. 12 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Alaska Alaska Cali fornia Cali fornia Cali fornia Cali fornia Cali fornia Central Yukon FO Alaska State Office Ambler Mining District Alaska Industrial 211 mile access Development road (subject to Industrial Access and Export Road Author ity (aidea) public scoping requirements of ANILCA). A Notice of Intent has already been issued for this EIS, National P etroleum Reserve-Alaska Integrated Acti vity Plan Alaska B LM but the effort is still in its early stages. Oil and Gas Developm ents/ leasing Palm Springs South Coast FO El Centro FO Bakersfield FO Palm Springs South Coast FO Palm Springs South Coast FO Crimson Solar Sonoran West 350 mega watts (MW) photovoltaic (PV)17 North Gila to I mperial Valley ^Willow to Santa Southwest Trans Partners LLC 500 kilovolt (kV) 18 line w/ loop Pacific Gas and 230 kV / 115 kV Maria Mesa Wind Ele ctric Brookfield loop 30 MW Wind Project Renewable Farm Coachella Valley Coachella Valley Water facility W hitewater Water District 17 Photovoltaic refers to generating electricity from semiconductin g materials, i.e. solar panels in a solar energy farm. A loop refers to an electricity distribution system that loops arou nd the service area and returns to the original power gene rating so a wind farm looping around a town and returning to the wind farm rce 13 a power line from SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Montana Montana New Mexico New Mexico New Mexico Nevada Montana SO Coal LMA MTM-94378 Montana SO Coal LBA MTM-105513 Farmington FO Clean Path Energy Project million tons of Coal over 1,263 Spring Creek Coal, LLC BNI Coal, LTD Clean Path Energy Center acres Lease Modification to develop 7.5 million tons of coal over 150 acres Lease by Application to develop 11.6 million tons of coal over 630 acres 345 kV line, Solar (PV) generati ng station, natural gas generating station Socorro FO Borderlands Catron Wind Project Borderlands Wind, LLC 100 MW Wind Energy Facility Las Cruces DO Copper Flat Copper Mine LVFO Yellow Pine Solar New Mexico Copper Corporation NextEra Approve a Plan of Operations for 2,190 acre copper mine. 250 MWs (PV) over 6000 acres, NOI pending 16 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 over 1,720 acres W yoming Rawlins FO W yoming Various Montana and W yoming Various Lost Creek Uranium Mine Expansion Lost Creek ISR, Approve a Plan of LLC Operations Amendment and Reclamation Permit for an additional 5,750 acres to an existing uranium operation. 2.2 million pounds of uranium/yr. Wyoming Pipeline Corridor I nitiative BLM - WSO Boreas Intertie Transmission Line Project Absaroka Energy, LLC Right of ^Vay for CO2 pipelines. If approved project would facilitate network of 1,150 miles of CO2 pipelines to existing oil fields to aid in enhanced oil recovery (EOR). Right of way 500 kV Transmission (MT & WY) 19 SPECIFIC BUREAU OF LAND MANAGEMENT ITEMS ADDRESSING SECRETARIAL ORDER 3355 Ar izona and Utah AZ Strip FO, Kanab FO, St. George FO Lake Powell Pipeline State of Utah Right of way for 69 Diam eter Water Pipeline & Hydro System from Glen Canyon Dam, AZ, to San Hollow Reservoir, UT 20