Chris Holten

Registered Professional Engineer



777 Overland Trail, Suite 221

Casper, Wyoming


April 5, 2007


Matt Anderson

Bureau of Land Management

Post Office Box 768

Pinedale, WY 82941


Subject: Year round drilling and completions on the Pinedale Anticline-Support of the Operators’ proposed action (Alternative B). 


I support the Operators’ proposed action (Alternative B).  I would like the following comments to be considered as a part of the planning and decision process in regard to year round drilling on the Pinedale Anticline. Based on my past 4 years of working on the Pinedale anticline, and 30+ years experience in working in many other environmentally sensitive areas, I believe that the impact of year round drilling has been reduced to a minimal, quite acceptable level.  It will have much less impact than seasonal drilling, which requires a “wave” of rigs moving in during May, and another, some times intense “wave” of rigs moving out by November 15th.  I have photo-documented the deer and their interaction with the winter pad drilling operations for the past two winters. Some photos are included in this letter as a sample, and I have attached a CD-ROM with at least 100 photographs from the winter pad of 2006 and 2007, sorted by day and year. There is one .MPG video file with sound that shows a herd of at least 20 to 25 deer grazing within 50 feet of the location while Halliburton is performing a cement job. From my experience, in the cycle of drilling a multi-well pad, this is the one time highest level of activity and sound that will occur on a “winter pad”. You will clearly see from that video, the grazing deer are not affected by such sound and activity.  The 100+ photos I took over the past two years will also show that the winter pad drilling activity I am involved with has little, if any, effect on the deer herds that are wintering on the Pinedale Anticline.


As a background, I come from a family of Wyoming outdoorsman and hunters and was raised to appreciate Wyoming’s wildlife, outdoors and hunting.  I was born in Sheridan, raised Casper and Glenrock and am a University of Wyoming graduate. I have lived and worked in several small Wyoming towns. My wife, also a native and UW graduate, and I chose to live in Wyoming and raise our family. My wife is a Junior High French teacher. My son, with a new degree in Mechanical Engineering, to be near his family and to keep his Wyoming lifestyle, has chosen to work for an oil field service company in Wyoming. He may not of been able to work in Wyoming as an engineer had it not been for the Oil and Gas industry and the number of good jobs they are able to offer to young Wyomingites.


I began part time work in the Glenrock “oil patch”, using the money I earned to pay my way through college. I have over 35 years experience working as a roustabout, maintenance man, field technician, engineer and supervising engineer, manager and on site consultant in the Wyoming oil patch.  I have both a personal responsibility and economic stake in protecting Wyoming’s environment and wildlife.  If I, like some 25,000 others working in the Wyoming oil and gas industry don’t protect it, we won’t have the really good jobs our industry provides. With a lessening of the oil and gas industries tax base, which historically has paid the lion’s share of taxes to our local, county and state governments, we won’t have the quality educational system and infrastructure most of us find as a important reason for living in Wyoming. Like everyone else who lives in our great state, it is in the Wyoming oil and gas communities best interests to “do it right”, protecting our environment and wildlife, and, from my 4 years personal experience on the Mesa, I am proud to say, that is just what we are doing.


Please take a look at the following photographs which are just a sampling of what is on the CD.


Photos – Winter of 2006-2007-Mesa 3-21 Winter Pad

Photos taken 2-24-2007 Mesa 3-21 Winter Pad show the deer to be in good shape and a sizeable number.

Above Photos taken 2-24-2007 indicate the Deer to be in good shape at the end of the winter.


Winter Pad 3-21 showing the close proximity grazing deer get to the drilling location.

Above photo taken 2-19-2007

Above photo taken 1-24-2007 from Mesa 3-21 location across Lovatt Draw


Photos Winter of 2005-2006-Mesa 3-20 Winter Pad


Photo taken January 12, 2006 from Mesa 3-20 Winter pad.


Photo Taken Feb 12, 2006 winter pad 3-20 from floor of Rig (Floor is 38’ above ground level)


Photo taken 3-12-2006 3-20 Winter Pad, Rig Floor.

Photo taken 3-12-2006 3-20 Winter Pad, Rig Floor.


Thank you very much for your consideration,

Chris Holten, PE