In 2014 Hydration Engineering attended a BIA Public meeting where the BIA previewed an effort to update a historic "operator's manual". That led to extensive participation in the evolving regulatory situation where the BIA has struggled to respond to court orders, compliance with the Endangered Species Act, the National Environmental Policy Act, and an antiquated minerals management system. Hydration Engineering has written extensively on these issues, pro bono, and on behalf of the Osage Producers Association.
1. OSAGE EA 1979
May 1997 - This is a copy of the difficult to find 1979 Environmental Assessment for the Oil and Gas Leasing Program of the Osage Indian Tribe, Osage County, Oklahoma. Prepared by the BIA in response to the National Environmental Policy Act it has proven to be a reasonable forecast of the environmental consequences of the Osage leasing program.
2. AMERICAN BURYING BEETLE (ABB)
Sept. 2015 - This paper discusses the status of Osage streams relative to the fishable-swimmable goals of the Clean Water Act. Osage streams generally fail to achieve swimmable quality water due to bacterial contamination by cattle.
Aug. 2015 - This is a chronology of the regulatory history of the American Burying Beetle with emphasis on events related to Osage County.
3. NO SWIMMING IN OSAGE COUNTY
4. APPLICATION OF NEPA TO OSAGE MINERAL ESTATE
Nov. 2015 - This paper was presented at the 14th Annual Osage Minerals Summit to review the history leading to the BIA's decision to replace the 1979 Environmental Assessment with an Environmental Impact Statement and to encourage participation on the process to follow.
5. DRAFT ENVIRONMENTAL IMPACT STATEMENT COMMENTS
Dec. 2015 - Detailed comments on the Draft EIS which was published in November then effectively withdrawn in April 2016.
6. 37 YEARS
June 2016 - This paper compares the forecasts presented in the BIA's 1979 EA with environmental consequences 37 years later. The 1979 BIA conclusion, "that significant environmental impacts would not result from the proposed action", was accurate.
7. OSAGE O&G LAND USE
Sept. 2016 - This paper presents a methodology and estimate of land used for oil and gas development in Osage County. Current land use is about 1/2 of the forecast for the year 2000 presented in the BIA's 1979 Environmental Assessment. Now estimated at 12,000 acres (2016), oil and gas land use declines as old wells are abandoned and legacy scars are reclaimed and healed. About 100 new wells per year can be drilled without increasing the total area required for oil and gas.