Hello fellow Rio Chama Watershed Protectors! Here are instructions and talking points to help facilitate your comments to the BLM regarding the 12 new oil and gas leases that will appear on BLM’s online only Spring Lease Sale. The parcels are within the our watershed. Let’s get to work!
DATE: THE PROTEST PERIOD RUNS FROM DECEMBER 6, 2017 UNTIL JANUARY 4TH, 2018. THE BLM WILL ACCEPT PROTEST LETTERS RECEIVED NO LATER THAN 4:30 PM ON JANUARY 4TH, 2018.
ADDRESS TO SEND YOUR COMMENTS:
by fax: 1-505-954-2010
BLM State Office
Atten: State Director
301 Dinosaur Trial
Santa Fe, New Mexico 87508
HOW TO MAIL: YOU MAY MAIL YOUR LETTERS “RETURN RECEIPT”, HAND DELIVER YOUR LETTERS TO THE BLM AND REQUEST A RECEIPT, OR FAX YOUR LETTER AND REQUEST A RECEIPT FAXED BACK. ( Acu-Copy on Riverside drive in Espanola will fax at $1.25 for first page, $1.00 for each additional page and the El Rito Library will fax for free.)
YOU CAN ALSO ATTEND RACC’S LETTER WRITING EVENT (OR DROP OFF YOUR LETTER) AT THE EL RITO LIBRARY ON SATURDAY, DEC.9TH FROM 10 UNTIL 2PM, AND WE WILL FAX OR DELIVER YOUR COMMENT LETTER TO THE CORRECT BLM ADDRESS FOR FREE!
THERE ARE THREE POINTS OF PARTICULAR RELEVANCE THAT SHOULD BE INCLUDED WHEN WRITING YOUR COMMENT LETTERS!! THEY ARE AS FOLLOWS:
1) THE BLM HAS NOT COMPLETED AN INDEPENDENT, OFFICIAL
STUDY OF THE HYDROLOGY OF THE PROPOSED OIL AND GAS LEASE SALE AREA IN OUR WATERSHED.
2) THE BLM IS USING INFORMATION FROM AN OUTDATED,
2003 RESOURCE MANAGEMENT PLAN, WHICH DOES NOT
TAKE INTO CONSIDERATION THE EFFECTS OF NEW FRACKING
TECHNOLOGIES, LIKE HYDRAULIC FRACTURING.
3) ANY AND ALL HYDRAULIC FRACTURING BEGINS TO DEFEAT THE CREATION OF THE FRONTIER DISTRICT BROUGHT TO LIFE IN RIO ARRIBA COUNTY’S “2009 OIL & GAS ORDINANCE”. THIS ORDINANCE IS IN PLACE TO PROTECT RIO ARRIBA COUNTY CITIZENS AND ENVIRONMENT FROM OIL AND GAS DEVELOPMENT.
Letter template and talking points for the Spring 2018 Oil and Gas Lease Sale:
Dear Ross Klein,
My name is ( )
My interest in protesting is; “I am a resident”/”I am a rancher”/”I am a
frequent visitor…” (SPECIFICALLY STATE IF YOU RESIDE IN THE WATERSHED AND WHY YOUR INTERACTION WITH THE RIO CHAMA WATERSHED IS SO IMPORTANT TO YOU.)
“I am writing to protest the inclusion of parcel numbers 1,2,3,4,5,6,7,8,9,10,11 and 12 that are within the Rio Chama Watershed and near the communities of Llaves, Regina and Gallina, and that are included in the MARCH 8, 2018 Oil and Gas Lease Sale, Farmington Field Office.”
“I am (demanding/asking/requesting) that these parcels, east of the Continental Divide and within the Rio Chama Watershed, be dropped from the MARCH 8, 2018 Lease Sale, pending further study on groundwater flow and geology.”
(YOUR PROTEST LETTER MUST INCLUDE ANY STATEMENT OR STATEMENTS OF REASONS TO SUPPORT THE PROTEST. THE FOLLOWING ISSUES HAVE BEEN DETERMINED RELEVANT.)
SUGGESTED TALKING POINTS:
LACK OF A HYDROLOGIC STUDY BY THE BLM- the Bureau of Land
Management has not completed an independent and official study of the underground water flow and the surface water pathways, into the Rio Chama Watershed, in the proposed lease sale area near the Continental Divide and the communities of Llaves, Regina and Gallina.
There is a blatant failure by the BLM to delineate, or portray precisely, the Eastern San Juan Basin’s complex hydrology. (The BLM Farmington Field Office chief geologist, Joseph Hewitt, has stated numerous times that no underground water on the parcels proposed, even those east side of the Continental Divide, will reach the Rio Chama Watershed.) This area is on the southeastern edge of the San Juan Basin and is adjacent to, or part of, a strong geological uplift area that is characterized by complex folded layers known as the Nacimiento Uplift.
The EA (Environmental Assessment) for these parcels does not give any reference to the impacts via groundwater in the Rio Chama Watershed. What is known is that if there are any springs, seeps, sumps or ephemeral washes in these parcels, they could come out on our side of the Continental Divide and into the Rio Chama Watershed. Certainly any spills or loss of fracking wastewater would drain towards the Chama Watershed and Rio Gallina.
BLM’S USE OF INFORMATION FROM OUTDATED STUDIES – The BLM
repeatedly cites information on the upcoming lease sale EA (Environmental Assessment), from the BLM Resource Management Plan (RMP) EA, which was written in 2003 and is now 15 years out of date.
The BLM 2003 Plan and associated Reasonably Foreseeable Development Plan, DOES NOT ADDRESS FRACKING IN THE MANCOS SHALE, A LAYER FROM 0-5000 FEET BELOW THE SURFACE, SOME OF WHICH OVERLIES GROUNDWATER. THIS IS NOT CONSIDERED A PREFERRED OR NECESSARILY SAFE GEOLOGIC STRUCTURE TYPE FOR FRACKING.
The BLM has an internal administrative policy that allows this use of
outdated documents until a new one is prepared. What are your thoughts on this? What about the option of a deferral of drilling until the 2003 Resource Management Plan is properly updated?
RIO ARRIBA COUNTY’S OIL AND GAS ORDINANCE PROTECTION –
Further introduction of hydraulic fracturing (unconventional drilling, horizontal drilling, fracking), with all its contaminants, pollutants, carcinogens, and spillage to the Rio Chama Watershed, is not in the best interest of Rio Arriba County and the residents of the county.
Parcels 1,2,3,4,5,6,7,8,9,10,11,and 12 in the BLM March 8, 2018 Farmington Field Office Oil and Gas Lease Sale are east of the Continental Divide in the Rio Chama Watershed and pose a threat to the watershed. East of the Continental Divide in the Frontier District means all the water flows east into the Rio Chama and into Abiquiu Reservoir.
It is too great a risk to bring hydraulic fracturing into the Rio Chama Watershed. Over 60% of the State of New Mexico gets water from the Rio Grande Watershed and the Rio Chama is its largest tributary.
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 want to use our water. The BLM Environmental Assessment (EA) states that all water for well development and fracking will be taken from “permitted sources,” but it does not state how or where, the quantities and how waste water will be disposed.
CHEMICALS – many chemicals are used in fracking, some known, some not – most are toxic or can be radioactive at low levels. BLM makes the statement that the Radium found naturally in lower rock levels will be contained in rocks, even if brought to the surface. However, Radium turns in a radioactive gas called Radon, and that will be dispersed into the air.
Talk about your concerns for clean air, especially for children and older people.
Ingesting food from local farms in areas where air, water and soil can
become contaminated, is a real concern.
Toxic wastewater will be produced by the millions of gallons and there
is no reference in the BLM Assessment about how they will dispose of it.
SEISMIC ACTIVITY – especially around Abiquiu Reservoir where there are several known fault lines near this water source. Injection wells are often used to dispose of wastewater and these are known to cause seismic activity. There is also increasing evidence in Texas and Oklahoma that fracking is associated with significantly more earthquakes.
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. A 3- 12 miles radius near flaring pits has been identified as dangerous to human and animal health.
In 2014, scientists working on a NASA study discovered a 2,500-square-mile cloud of methane hovering over the Four Corners region. The BLM seems to dismiss this as being of unknown origin, although recent studies, (sited by the Environmental Defense Fund), clearly indicate that oil and gas development is the largest source of emissions contributing to this massive methane “hotspot”.
SOIL RESOURCES – in this high desert climate, the soil can be fragile. Talk about your concerns for the soil in light of heavy traffic from big rigs used in fracking; erosion caused by roads and construction of drilling pads; toxic chemical spills and anything else you might have to say about the earth. The BLM states that in some areas, soils are fragile but this is of minor concern due to remoteness of parcels.
WILDLIFE – talk about the endangerment of any particular species – disruption of migratory patterns, etc. Wastewater pits, with indeterminate lining, are another means of disposing of fracking’s toxic sludge. These are open pits. What are the provisions to keep birds and animals from drinking, or landing in, the open pit storage water?
DARK SKY – talk about your feelings for an uninterrupted night sky view, especially along NM Route 112 and surrounding ranches and communities.
CULTURAL RESOURCES AND LANDSCAPES – talk about what is dear to
your heart in this area – what resources and landscapes you want to
remain intact? For instance, Gallina Canyon Ranch, San Pedro Wilderness, and hiking, camping and rafting in the Rio Chama River could be affected by traffic, noise and pollution, and an interruption of the night sky view. How would cultural use of the Watershed change with active oil and gas leasing?
ENVIRONMENTAL JUSTICE – According to the BLM, “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.”
Talk about your feelings in light of this statement and what you understand about the effects hydrofracking would potentially have on the Rio Chama Watershed environment and culture.
SOCIO ECONOMIC – According to the BLM’s current Environmental Assessment (EA) on the parcels in question, “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 IS NOT ENOUGH OIL AND GAS HERE IN
OUR WATERSHED TO BE OF ANY REAL COMMERCIAL VALUE.)
Also, according to the BLM:
“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.”
Write about what you think about that.
IN CLOSING – round out your letter with a reiteration of your demand/request to defer parcels 1,2,3,4,5,6,7,8,910,11 and 12 in this Lease Sale. Use your own words. The BLM Farmington Field Office has the authority, as the sale agent, to defer leasing these parcels.
The BLM is required to respond to your protest. Don’t forget to put your mailing address below signing your name at the bottom of your letter. Thank you!
RACC is documenting Protest Letters so we can hold the BLM authorities
accountable. Please email us at firstname.lastname@example.org and let us know that you sent a comment to the BLM. Keep your receipt from the post office or the fax machine!
Thank you for all that you are doing to protect the Rio Chama Watershed!