December 3, 2015
Santa Fe National Forest
Attn: Forest Plan Revision
11 Forest Lane
Santa Fe, New Mexico 87508
Submitted via email to: email@example.com
Re: SCOPING COMMENTS RE: SANTA FE NATIONAL FOREST PLAN REVISION
Thank you for the opportunity to comment on the Santa Fe National Forest’s Plan Revision. We are a diverse, citizen-based, non-profit, educational organization whose mission is to protect the public health, land, air and water of the Rio Chama Watershed.
Our main area of concern is the potential for oil and gas exploration and development in the Rio Chama Watershed within the Santa Fe National Forest. Our research and resident-based knowledge of the cultural and physical richness of this watershed confirm that the Rio Chama Watershed is a productive and indispensible watershed in New Mexico and deserves to be protected from any possibility of damage from oil and gas development or exploration. We have concluded that standards and guidelines that would prohibit hydro-fracking within the Rio Chama Watershed would be in line with the SFNF agency’s duty “to provide for social, economic, and ecological sustainability” within the Santa Fe National Forest. In the interim, it is our recommendation that a moratorium on any future fossil fuel leasing and development be implemented pending completion of the Forest Plan Revision.
The Rio Chama Watershed is of vital importance to the state of New Mexico. This watershed supplies a significant amount of water to both Santa Fe and Albuquerque
and is also a productive and important watershed in its inestimable cultural and community value to this region.
The Rio Chama Watershed is located in a unique bioregion and community. John Wesley Powell, the great explorer of the dry lands of the American west, understood that a watershed is “ that area of land, a bounded hydrologic system, within which all living things are inextricably linked by their common water course and where, as humans settled, simple logic demanded that they become part of a community.” Indigenous Native Americans were the first to sustain themselves using dry land farming in this watershed, followed by Hispano settlers who brought agro-pastoral farming and acequia culture to the region. This sharing and respecting of water resources within the watershed community continues to this day to bind inhabitants together and reinforce local traditions that are intertwined with the health of this river ecosystem and broader watershed. The voices of current day residents can be heard in Rio Arriba County planning documents, in particular the Rio Arriba County Oil and Gas Ordinance, and these voices reflect a land ethic that believes in protecting the land that sustains us.
Because of the physical and cultural importance of this watershed, we believe protections should be put in place in the SFNF Plan Revision against any oil and gas exploration or development. The dangers associated with hydro-fracking, and in particular, proposed shallow shale fracking in the case of our watershed, is well documented. A recent Associated Press investigation found that between 2009 and 2014 New Mexico spilled 13.3 million gallons of hydro-fracking wastewater. New Mexico ranked third highest of the states for amount of wastewater spilled. Also, the inadequate enforcement of existing laws regarding wastewater disposal inevitably guarantees irresponsible oil and gas development. The risk of polluting any part of the Rio Chama Watershed system with toxic chemicals associated with hydo-fracking is unacceptable.
Another concern is the depletion of water resources. Between two and five million gallons of water are used per well for horizontal drilling of a fracking well and this water would in all likelihood come from our watershed. The state of New Mexico is experiencing a long -term drought. Due to climate change stressors, the southern part of the state will be more and more dependent on water flowing from the Rio Chama Watershed. It is well documented that wetlands are among the ecosystems at highest risk from climate change. Less than 1% of New Mexico is currently covered in wetland and riparian areas. If the SFNF incorporates, as they should, a future vision that includes a climate change scenario in their revised plan, then the calculation will inform the agency decision that protection of all water resources is vital. Our watershed in particular should be a priority for maintenance and restoration, not industrial development.
We would like to recommend that the SFNF study the document entitled 14 Illustrated Points from the Rio Arriba Concerned Citizens website under the Resources tab. You can link to our website here. This document shows that the aquifers in the current study area for oil and gas exploration within the watershed sit right below the targeted Mancos shale. The targeted areas are not thousands of feet below the aquifers with an impermeable strata separating the water from the oil or natural gas. This mainly illustrates the geology underlying the Taos Field Office and the Cebolla Parcels that have been indefinitely deferred and which border both National Forests.
We also would like to bring your attention to Joseph Hewitt’s study entitled Geologic Review of the Oil and Gas Potential in the Southern Portion of Chama Basin, North Central New Mexico: Eastern Rio Arriba County. This document illustrates the BLM’s study of this area in the Rio Chama Watershed and their findings of “low” potential for oil and gas in the Southern area and “moderate” in the Northern area suggest further exploration is unwarranted. There are no producing wells in the study area along the San Juan Basin Rim, which borders the Carson and Santa Fe National Forests.
The BLM has stated that “lease parcels may be deferred based on any number of reasons and geology may have no bearing whatsoever on the cause of deferment; geology may merely be incidental. And, though certain aspects of geology may be similar, such as stratigraphy, hydrocarbon potential may be quite different from one area to the next.” Our understanding of NEPA is that it is required to take a “hard look”, not a pass over of “incidental”, when it comes to assessing potential environmental damage.
The SFNF Forest Revision Plan Draft goes so far as to say (page 261) “The San Juan Basin has the potential to continue to produce both oil and natural gas in the foreseeable future, but there is no evidence that new discoveries will significantly increase production on the Santa Fe National Forest.” We question why leases are sold only to turn into assets with no oil and gas potential. We have serious concerns in general regarding the strategy behind the federal land purchase of parcels as “assets” which in turn become “stranded assets”. Our watershed becomes vulnerable to oil and gas development in this scenario. This is not acceptable from what we know and have learned about the watershed.
Another consideration is the function of Federal Lands as carbon sinks to help reduce net greenhouse gas emissions. Oil and gas development within the watershed and elsewhere on public lands is untenable in this regard. If NEPA analysis compliance includes, as it should, climate change mitigation, than it becomes obvious that we need to leave these carbon resources in the ground and look for alternative use plans that are geared toward a sustainable energy future.
In conclusion we wish to thank you for considering our comments regarding the Revised Santa Fe National Forest Plan. Please contact us if we can be of further service in developing a plan that recognizes the vital importance of the Rio Chama Watershed. In a future that in all likelihood will include climate change challenges, it is of the utmost importance to protect New Mexico’s water resources.
President of Rio Arriba Concerned Citizens
Cebolla, New Mexico 87530
Board Member of RACC
El Rito, New Mexico 87530