Our watershed matters in the new Resource Management Plan Amendment

You have a say on how our public lands are used. This is a big deal folks! A very dated Resource Management Plan (RMP) that was implemented in 2003 is finally being updated by the BLM. The decisions in this plan amendment affect us and our watershed as the plan appears to be geared for private oil and gas development, not multi-use public land planning. The 400-plus page draft amendment outlines a preferred alternative that would increase oil and gas activity in the Greater Chaco region and potentially on the Rio Chama Watershed’s western boundary. To view the full 400+ page RMPA document click here.

The RMP Amendment/Environmental Impact Statement (EIS) will analyze the impacts of additional development in what was previously considered a fully developed oil and gas play within the San Juan Basin in northwestern New Mexico. This “oil play” comes right up against our beautiful Rio Chama Watershed boundary. In the past we have protested new oil and gas leasing on that western boundary because we have been concerned that no proper hydrology study has ever been made in that Continental Divide area that marks the boundary between our watershed and the San Juan Basin Watershed. This lack of a hydrology study still our concern.

For industry, innovations in horizontal drilling (aka fracking) and multi-stage hydraulic fracturing that have occurred since the old 2003 Resource Management Plan was developed have unfortunately made it more economically profitable for industry to pursue development in the Mancos Shale/Gallup Formation. However, additional impacts to we the people and the environment could potentially occur alongside oil and gas profiteering. That is our concern. The Rio Chama Watershed becomes more vulnerable as does Greater Chaco where 91% of the land is already leased to oil and gas. Two things unmeasurably worth fighting for.

Until this September 25th, you have the opportunity to send your comments to the BLM. And we want to make that as painless as possible for you because your voice matters! We have created a comment letter on our website the gives you the opportunity to talk specifically about our watershed and how it may be made vulnerable via this new amendment.

The comments regarding Chaco are embedded in the comment letter and are being provided by San Juan Citizens Alliance, our neighbors over in the San Juan Basin. Sixty percent of Navajo Nation residents currently lack access to broadband making it more than difficult for them to meaningfully participate in this comment period. 

Your job is to write a paragraph or two about your life in the Rio Chama Watershed and how it could be affected by this new amendment. (We will provide Rio Chama Watershed talking point suggestions on the comment letter page.) 

And now the most beautifully easy part! As soon as you fill in your personal point of view and your name and address, you can click and send directly to the BLM. A copy of your comment letter will be sent to you as well as the Bureau of Land Management. 

Please take the time to speak up for Chaco and our beautiful Rio Chama Watershed! I estimate it will take you 15 minutes on average! Let’s turn up the volume in the number of voices coming from our area. We have to protect what we cannot live without.

Click here to access our website and the prepared comment letter so you can get started. 

You know it’s important to vote in this election. Want to know where and how to vote in our area? We have a detailed voter’s guide up on our website. Clink here to get detailed information about how to vote safely and easily in the November 3, 2020 General Election.

water on crops

How would you feel about some Frack Water on your local food crops and livestock pastures? 

As mentioned in previous RACC Newsletters, we are tracking the important issue of legal expansion of the use of Frack or “Produced Water” in our state. 

Frack or “Produced Water” commonly contains a dangerous cocktail of radioactive minerals and toxic fracking chemicals, which are protected as oil and gas companies’ “secret formulas” under Federal Law. 

Up until now, Produced Water was considered so undesirable, it was mainly pumped deep underground into “injection wells” to keep it from reentering the water cycle. Why then is the state now engaged in expanding the prevalence and uses of this toxic waste water? 

What is more valuable than oil and gold put together? AGUA FRESCA. FRESH WATER.   

In 2019 New Mexico passed its Produced Water Act. This law was designed, in part, to encourage oil and gas companies to reuse Produced Water in the fracking process instead of FRESH WATER. 

Sounds ok. But the inescapable fact remains: Produced Water is toxic wastewater which poses severe Environmental and Public Health threats. Lack of regulation could expose our environment and communities to spills, leaks and other hazards. Legal amendments could open the door to known uses of Produced Water outside of the oil and gas sector, which include irrigation of crops, watering livestock, recharging aquifers and suppressing dust in construction uses including road construction. 

In fiercely debated “Produced Water” public hearings on July 30 & 31 at The NM Oil Conservation Division (OCD), which sits within the state Energy, Minerals and Natural Resources Department (EMNRD), the state  argued that the scope of rule making should be limited to the specific language of the Law, which stipulates vaguely that disposition of fracking waste must “protect public health, the environment and freshwater resources” without defining any standards to be followed. 

The position held by RACC and other Environmental and Social Justice groups is that science and data must inform the rules, and that all implications for health, the environment and affected communities must be clearly addressed. 

Unfortunately, although the hearing appeared to follow the principles of democratic process, the state is destined to come to a predetermined conclusion. The final proposed rule draft will be issued in the coming weeks and the Commission is likely to vote to accept the grossly inadequate “Produced Water” rule amendments.

Please know that we will continue to update you on this “expansion of Produced Water” in New Mexico in our future Newsletters. 

What You Can Do


During the deliberations, the Commissioners clarified language to prohibit surface application of Produced Water even on oil and gas sites. There is no question that they felt strong and concise legal language was warranted because YOU, the public, is watching. 


Express your opinion about state regulations which expand the use of Produced Water and do not provide for adequate legal or technical supervision of this toxic waste. 

Or write a card with the closing words spoken at the recent Produced Water hearings by a fellow lover of the Earth; 

“If you love your children: the only responsible action is to delay or abort the Produced Water rule amendments which are inconsistent with the obligation to protect public health, environment, & fresh water resources, which is your mandate”.

New Mexico Oil Conservation Division 
1220 South St. Francis Dr.
Santa Fe, NM 87505

The mandate of NM Oil Conservation Division is to monitor, regulate, control, and enforce against oil and gas pollution. It is OCD’s responsibility to ensure that the rules include specifics based on science and data, and that these rules address the full scope of dangers posed by hydraulic fracturing and the resulting fracking waste.

(Many thanks to board member Rebekah Henty for this special report.)

burning gas

Rio Arriba County Air Quality

New methane rules are currently being drafted for the State of New Mexico.
A surprising fact has come to our attention here at RACC via the report from the governor’s office entitled New Mexico Climate Strategy Initial Recommendations and State Update 2019. Apparently seven counties in New Mexico are approaching 95% of the ozone standard of 70 parts per billion (pub). Rio Arriba County is one of them! The other six counties are in or near oil and gas development in the Permian Basin in the southeast and also in the northwest San Juan Basin. These new rules will affect our air quality here in our watershed.

You can submit your comments and concerns via the Methane Matters NM.org site here

This from Methane Matters NM.org:

New Mexico’s Energy, Minerals and Natural Resources and the Environment departments have received so much feedback already on draft rules to cut methane and other air pollution that they are extending the public comment period to Sept. 16. We’re glad to see the agencies continue to prioritize stakeholder engagement so that the methane rules are “enduring and enforceable, and result in meaningful reductions in pollution” – their own words!

Since the draft rules have been released, analysis by our partners has discovered significant exemptions that reduce the rules’ effectiveness to protect public health and our climate. In some cases, waste of methane gas wouldn’t be halted under the draft rules. These issues must be addressed. Reducing methane waste and pollution is critical for New Mexico right now as we’re facing a confluence of crises in our economy, public health, and climate. New Mexicans lose more than $40 million each year in royalties that oil and gas operators are not required to pay for oil or gas produced on federal or state lands when they vent, flare, or leak methane rather than sell it. These are royalties that our schools and critical services like hospitals are in need of, especially now.

The draft methane rules are a good first step – and it’s up to us to make them the best rules they can be. Please join us to urge the state agencies to make the rules stronger so that they meet our collective goals of protecting public health, maximizing support for our schools and hospitals and taking action on climate change. Submit your public comment today.