Rio Arriba Concerned Citizens is a grassroots organizations whose mission is to
“To protect the public health and land, air, and water of the Rio Chama Watershed, Rio Arriba County, and the State of New Mexico, and to promote sustainable development through education, collaborative planning, community action, and policy advocacy”
WRITE A PROTEST LETTER AND HAVE YOUR VOICE HEARD.
Thank you for sending your comments in May! Now we have one more chance to stop this lease sale.
The protest period to express your objections to the October 22, 2014 oil and gas lease sales began July 16, 2014 and will end on August 15, 2014.
Please forward this information to your personal contacts!
The more information we share, the more these unconscionable BLM actions will be scrutinized. The surest way to pass disastrous and irresponsible laws is to cloak them in illegible bureaucracy where they languish in secrecy. Let your community know that you want BLM to take our land off the auction block!
Without your opposition, the BLM will begin drilling in the Santa Fe National Forest near Gallina.
OUR COMMUNITIES ARE WORTH FIGHTING FOR. WE CAN MAKE A DIFFERENCE!
What’s Going On Now?
A little history.
BLM has made their intention of fostering oil and gas development on public lands in the Rio Chama Watershed clear to us. Earlier this year, 16 parcels near Cebolla were scheduled to be offered for lease to private oil and gas companies by the Taos BLM Field Office. Public comments and a protest from Western Environmental Law Center helped to defer that sale. In the official BLM statement the deferrals were due to considered conflicts and risks.
As you may know, the BLM Field Office in Farmington is now in the process of an oil and gas lease sale near Gallina. There have been some new developments since the comment period this May.
11 Victories!
Thanks to your commitment and proactivity the BLM admitted to receiving a substantial number of comments. One of the most effective comments sent addressed BLM procedure. In order to continue with a sale BLM must complete a series of studies in order to obtain a Finding of No Significant Impact (FONSI). One of these studies is the Mancos Shale/Gallup Formation RMP/EIS that has not been updated since 2003. When these studies were completed shallow shale fracking was not a concern, and it was not addressed in the study. There for, if the lease sale continued about half of the parcels up for lease and the BLM would have been in violation of the National Environmental Policy Act (NEPA).
As a result of this finding, 11 parcels were deferred from the sale because of insufficient study. Good news!
What happened to the other 13 parcels that were included in this lease sale?
They are in the Santa Fe National Forest and under a different set of bureaucratic guidelines that allowed them to have already procured a FONSI. Unfortunately, these 13 parcels that were not deferred are all in the Rio Chama Watershed area that RACC has been protesting.
So why are we still protesting and making our voices heard?
Because the BLM still has the power to defer the sale. We know that the geology and hydrology of the parcels in the Santa Fe National Forest are the same as the parcels that were deferred by the BLM. This is a bureaucratic technicality, and the dangers of drilling in the National Forest are just as great as they would be in the other deferred parcels.
What can I do to stop this sale?
Write a letter of protest to the BLM. The protest period to express your objections to this lease sale began July 16 and will end on August 15. There are a set of guidelines to address the BLM and have your protest letter counted. While the requirements are particular, they are easy to follow.
More about the letter.
Your protest letter can be as simple or as complicated as you like. RACC has compiled three documents to help you write an effective letter in a format that the BLM will accept. Remember, only an original letter will be counted, form letters will be dismissed. Use the suggested talking points below to inform your reasons for protesting.
- To read a sample protest letter click here
- To read BLM protest letter requirements click here
- To read suggested talking points or ‘statements of reasons’ click here
You can also read the documents below or visit our website PLEASE to learn more about accepted guidelines and requirements.
Read a Sample Letter
Jesse Juen
U.S. Bureau of Land Management
New Mexico State Office
PO Box 27115
Santa Fe, New Mexico 87502
7/26/2014
Dear Director Juen,
My name is Felicity Garcia and I am writing to protest the proposed sales of parcels NM-201410-001, 004 thru 015 that will be offered up for lease in the BLM Competitive Oil and Gas Lease Sale, October 22, 2014.
Interest in Protesting
I am a lifetime resident of Gallina, and my family has farmed and raised livestock in this area for hundreds of years. My income is based on the integrity and productivity of the land.
Reasons for Protesting
I understand the importance of clean water, and a functioning ecosystem for the health of our community. Without clean water we cannot hope to thrive in our traditional lands. We live with a limited amount of water in our part of the world, and I am concerned about the 2-10 million gallons of water that is used for each well in this process. I highly protest this misuse of the limited resource of water.
Chemicals used in hydraulic fracturing are known to cause cancer, neurological, and other health problems. There have been many examples of spills and groundwater contamination, despite the efforts of private oil and gas companies. The risk of polluting our precious water is too great. If our water is affected it is the residents who will have to live with the consequences, not these companies.
The waters in Gallina and Regina flow into the Rio Chama and any pollution will also affect our neighbors down river all throughout the state.
Our forests are vulnerable to forest fires because of extreme drought, and the hydraulic fracturing process involves many fire risks. Wells have exploded and caught fire, and the flaring of natural gas burn off can cause the dry forest to catch fire. Our forests are a part of our livelihoods and heritage as we use them for firewood, livestock forage, and wildlife habitats as we have for hundreds of years. After a fire burns the exposed soil can cause flooding that and also pollutes our rivers.
I again protest and ask you to defer the 13 parcels up for lease in the October 22, 2014 BLM Lease Sale.
Sincerely,
Felicity Garcia
Felicity Garcia
Please send your mandatory response to my address:
P.O. Box 1116
Gallina, NM, 87017
BLM Guidelines for Protest Letters
All protests must meet the following requirements or they will be dismissed:
- BLM must receive a protest no later than close of business on August 15, 2014.
- A protest must state the ‘interest’ of the protesting party in the matter. E.g. I am a resident/rancher/land owner/hiker/visitor/acquiero.
- You may file a protest either by mail in hardcopy form or by fax (see number and address below). You may not file a protest by electronic mail. A protest filed by electronic mail will be dismissed.
- Your protest must reference specific parcels up for lease. We are protesting parcels NM-2014-001, 004 through 015, which are in the Rio Chama Watershed and East of the Continental Divide.
- The protest must include a ‘statement of reasons’ to support the protest (Eg. I am concerned about geology, water, lack of oversight, spills). BLM will dismiss a protest filed without a statement of reasons.
- Only a letter whose text is essentially unique will be accepted. Form letters will not be counted. We recommend you be personal, express your concerns and perspective, but try to refer back to scientific facts about hydraulic fracturing.
- You must include your name and return address. BLM is legally required to announce receipt of your protests at the beginning of the sale. They will also announce a decision to either withdraw the parcel or proceed with offering it at the sale.
- You must sign your protest as an individual citizen. Only if an entire organization authorizes it may you use the name of an organization.
To whom should the letter be addressed?
You may send your letter, preferably a certified letter, to:
Jesse Juen
U.S. Bureau of Land Management
New Mexico State Office
PO Box 27115
Santa Fe, New Mexico 87502
Alternatively, you may also register your protest letter by faxing it to:
Jesse Juen
U.S. Bureau of Land Management
New Mexico State Office
Fax: 505-954-2010
We are gathering copies of all Protest Letters so we can hold the authorities accountable. Please email a copy of your letter, or mail a hard copy to:
Cinda Graham (member of Rio Arriba Concerned Citizens)
Email: grahamcinda@gmail.com
P.O. Box 934
Abiquiu, NM 87510
Suggested Statement of Reasons
Much of the protest is based on our challenging the BLM Environmental Assessment (EA). THE PROTEST LETTER MUST INCLUDE A ‘STATEMENT OF REASONS’ TO SUPPORT THE PROTEST. You can use the talking points below as ideas or prompts for the ‘statement of reasons’ in your own original protest letter.
THE FOLLOWING STATEMENTS HAVE BEEN DEEMED TO BE RELEVANT TO THE BLM:
INCLUDE THIS SENTENCE: A finding of No Significant Impact (FONSI) for the October 22, 2014 Oil and Gas Lease Sale is not adequately supported by the Environmental Assessment as it now stands.
FRAGILE GEOLOGY AND AN IRREPLACABLE AQUIFER – The geology east of the Continental Divide has not been sufficiently studied to safely utilize Shallow Shale Hydraulic Fracturing, a risky new technology. This process occurs ABOVE the aquifer and carries a greater potential to drive toxic fracturing chemicals down into the aquifer and contaminate it.
The Morrison Formation is a vital aquifer in the Rio Chama Watershed. The Rio Chama flows to the Rio Grande and together they deliver over half of the water for the entire state. This water is already legally allocated to downstream users. Contamination of the Morrison Formation aquifer would have disastrous effects for us all.
West of the Continental Divide, the aquifer consists of brine and is not considered potable. East of the Continental Divide, the Morrison Formation aquifer continually recharges and is a potable source of drinking water that feeds springs, acequias and wells. The Rio Gallina, which could be affected by drilling in the lease sale parcels, flows directly into the Rio Chama Watershed.
INCOMPLETE STUDY – The Santa Fe National Forest Finding of No significant Impact (FONSI) is unwarranted because of a lack of sufficient study. The geology of the parcels deferred by the BLM and the geology of the parcels within the national forest are the same.
WATER – Anything you’d like to say about water; quality, availability, importance of clean water, etc. Millions of gallons of water are required for each proposed well and oil and gas companies will use our water. Fracking risks poisoning local water and that of millions of downstream users because the geologic layer containing oil and gas east of the Continental Divide sits above the aquifer.
CHEMICALS – oil and gas companies are not legally required to disclose the chemicals they inject into the wells. In 2011 the House of Representatives reported that of 2,500 fracking products, 650 contain known carcinogens. Spills in New Mexico’s oil and gas fields set records in 2012, with nearly 700 self-reported accidents. At least thirty reported spills during 2011 and 2012 impacted a waterway or a groundwater supply. Toxic waste -water will be produced by the millions of gallons and there is no reference in the BLM Assessment to how they will dispose of it.
EARTHQUAKES – The Abiquiu Reservoir and Heron Lake are placed near several known fault lines. Injection wells, which are often used to dispose of waste-water, as well as degradation of bedrock, are know to cause seismic activity. Earthquakes have not been addressed at all in the BLM Environmental Assessment (EA). Imagine the impacts that earthquakes could have on these damns and the catastrophic effects for residents and downstream water users.
AIR QUALITY AND CLIMATE CHANGE – Flaring is a common practice used in fracking in which huge amounts of hydrocarbons are released directly into the atmosphere. Flaring also poses an extreme fire danger in our Santa Fe National Forest. A 3- 12 miles radius has been identified as dangerous to human and animal health. Waste- water pits are another means of disposing of the toxic sludge. These are open pits that are filled with waste-water and left to evaporate.
SOIL RESOURCES – In this high desert climate the soil can be fragile. There are concerns about soil exposed to heavy traffic from big rigs used in fracking, erosion caused by roads and construction of drilling pads, toxic chemical spills and anything else that might damage the soil.
WILDLIFE – Mention concerns you have about endangerment of any particular species – disruption of migratory patterns, etc.
DARK SKY – Each hydraulic fracturing pad may be to 2 to 3 acres in size, and will be brightly lit throughout the night. Light pollution also comes from the headlights of constant nighttime truck traffic driving to and from these pads. This light pollution could severely affect the uninterrupted night sky view we currently enjoy.
CULTURAL RESOURCES AND LANDSCAPES – talk about what is dear to your heart in this area – what resources and landscapes you want to remain. A section of the Old Spanish Trail runs through these parcels. The BLM has also identified hundreds of multi-cultural historic sites in the area of these parcels that are listed in the Environmental Assessment.
ENVIRONMENTAL JUSTICE – Quoting from the EA:
Environmental justice refers to the fair treatment and meaningful involvement of people of all races, cultures, and incomes with respect to the development, implementation, and enforcement of environmental laws, regulations, programs, and policies. It focuses on environmental hazards and human health to avoid disproportionately high and adverse human health of environmental effects on minority and low-income populations.
Oil and gas development would disproportionately impact Hispanic and Indigenous peoples who have consistently and historically experienced poverty, a lack of infrastructure, and environmental degradation in Rio Arriba County.
SOCIO ECONOMIC – Quoting from the EA: “An assumption is that the No Action Alternative (no lease option) would not affect current domestic production of oil and gas.” In other words, there are not major oil and gas reserves. They go on to say:
“If the BLM were to forego leasing and potential development of the proposed parcels, the assumption is that the public’s demand for the resource would not be expected to change. Instead, the mineral resource foregone would be replaced in the short-and long-term by other sources that may include a combination of imports, using alternative energy sources (e.g. wind, solar), and other domestic production. This offset in supply would result in a no net gain for oil and gas domestic production.”
How do you feel about the conclusion of the BLM that deferring the lease sale and development of these parcels would encourage alternative energy?
DISRUPTS COMMUNITIES BY INCREASING NOISE POLLUTION AND TRAFFIC, OVER STRESSES INFRASTRUCTURE – Thousands of big rig trucks running on roads 24/7; generators, bright lights, hampered emergency response times, etc.
IN CLOSING –Reiterate of your demand/request to defer the remaining 13 parcels in this Lease Sale. Use your own words. The BLM Farmington Field Office has the authority, as the sale agent, to defer these remaining parcels. These 13 parcels in the Santa Fe National Forest pose the same issues as their neighboring parcels that have been deferred and the same risks to the Rio Chama Watershed east of the Continental Divide.
Stay Informed
Free informative booklets detailing our counties history with oil and gas and our concerns about it are available at the Abiquiu Library, El Rito Library, and the Rising Moon Gallery. Pick one up today!
Rio Arriba is the name of our county and our group but more then that it means “Up River” and is a reminder that in New Mexico we are “up river” and what happens here will affect many downstream. Get involved today.
Visit us at www.rioarribaconcernedcitizens.com