I hope this finds you well, willing and able to circulate these materials in time for the BLM deadline of Friday the 15th.
If you have contacts among other organizations to whom you can pass this on, it could be very important as our outreach is woeful.
I am sending 4 documents which may or may not all be useful to you: 1) BLM specifications for an acceptable letter of protest; 2) a synopsis of the arguments against fracking in this watershed through which passes the majority of the entire water supply for the state of New Mexico; 3) Talking Points to pick and choose from when writing a letter so that each is unique and not disqualified; 4) a sample letter.
Blessings,
Mimi
The BLM Farmington Field Office is in the process of selling leases for 13 parcels of public land in the Santa Fe National Forest to oil and gas companies that may pollute our land, air and water. To allow this would endanger the Rio Chama Watershed and the Rio Grande with which it is joined. We need to protect the New Mexico’s primary watershed and this is our chance. The time is now! Please write your official letter of protest to stop the BLM from proceeding.
THE SPECIFICATIONS:
ALL PROTEST LETTERS MUST MEET THE FOLLOWING REQUIREMENTS for the October 22, 2014 Oil & Gas Lease Sale-Farmington Field Office:
By mail, by hand delivery or by fax (to 505-954-2010 Attn: Jesse Juen BLM) If you use mail, please pay for certified mail and send a copy to Rio Arriba Concerned Citizens at PO Box 835 Abiquiu NM 87510 Email will not be accepted at all. Address your protest: Attn: Jesse Juen, NM BLM State Director
301 Dinosaur Trail
PO Box 27115
Santa Fe, NM 8750
The protest must include your name RETURN ADDRESS. BLM must reply.
You must sign your protest as an individual citizen, not as an organization, unless fully ratified.
A protest must state the INTEREST of the protesting party in matter. E.g. I am a resident/rancher/land owner/hiker/visitor/acequiero.
Refer to the 13 parcels in the Santa Fe National Forest that should be deferred: NM 201410-001
NM-201410-004 through -015
The protest must include REASONS to support the protest. BLM will dismiss a protest filed without a statement of reasons. Use the talking points to help build your statement of reasons. The most important is the danger to the scant and precious supply of water in New Mexico. Procedurally, pointing out that the BLM’s has NOT fulfilled its responsibility to verify that studies conducted truly substantiate a “finding of no significant impact” (FONSI), is the most important objection we can make. Furthermore, we believe it’s impossible because you cannot fracture shale above the aquifer without contamination.
BLM must receive a protest no later than close of business on August 15, 2014.
As they said in school, USE YOUR OWN WORDS .The BLM disallows form letters. No email will be accepted.
THE ARGUMENT:
Hydraulic fracturing, “fracking”, uses millions and millions of gallons of water for each well, every time it is fracked. if the BLM sells leases to oil and gas companies, they will use water necessary for the life of all communities downstream. Water is far more valuable to us than oil and gas because el agua ES la vida. New Mexico has never had water to spare, especially now that the monsoon doesn’t deliver as it used to and because we are in drought.
50 to 60% of all of New Mexico’s water passes through the eastern side of Rio Arriba as surface and ground water and all of it is at risk because of the danger of contamination. In 2009, the County Commission attempted to protect the eastern side of the Continental Divide where the headwaters of the Rio Chama form by delineating a frontier district protected from oil and gas exploitation and the ordinance should be respected. The lands proposed for lease sale by the BLM in the Santa Fe National Forest around Regina, are on the eastern side of the Continental Divide, among the tributaries of the Rio Chama. They are beautiful and precious places in themselves – the Rio Galllina, the wetland areas of Parcel 12, archaeological sites and more.
37,000 oil and gas wells are operating in the San Juan Basin around Farmington, with many more planned – providing a lot of oil and gas and a lot of revenue for government. It makes sense to restrict oil and gas production to areas of basin west of the Continental Divide that cannot contaminate widely downstream.
The process of extraction uses hundreds of chemicals in formulas that are trade secrets. Although the oil and gas industry claims they are safe, the national House of Representatives made a study identifying 2500 chemicals used of which 650 are known to cause cancer.
The wells proposed around Regina will be drilled in shallow shale, using a new technology of horizontal drilling which has not been adequately tested and studied. Because the shale layer sits on top of the Morrison Formation holding our aquifer which is recharged by rain and snowmelt trickling through the shale, there is no way to protect water in the aquifer from chemicals injected under pressure sufficient to break shale during this process. Wells drilled into Morrison Foundation, such as the community well in Cebolla, have been tested and proven to provide some of the best water in the state.
Fracking has been linked to earthquakes in many places that have never experienced them before. The Abiquiu Dam and other sites sit atop fault lines and are already vulnerable.
Gas is a often merely a byproduct of fracking, not worth capturing for sale, though it may measure in the hundreds of millions of gallons, as in Oklahoma. It will be released into our air, or burned off by “flaring” – like lighting a giant blowtorch – in the midst of a region where catastrophic fires have raged in recent years. Such large volumes of gas are flared off from the main shale fields that they are visible from space. This past winter a well exploded in Pennsylvania so it can happen again.
Storage tanks release volatile chemicals constantly in an invisible smoke which can be revealed by infrared film and none of it is healthy. The industry claims that you can drink fracking fluid but 17 cows in Pennsylvania died after an hour’s exposure. The closer you live to a fracking operation the greater your chances of developing chronic rashes, headaches, nosebleeds, severe asthma and other respiratory problems. (Within 5 – 12 miles is the danger zone being studied.) 300 residents of a Texas fracking town filed formal complaints recently with the state authorities. It is too soon to trace the effect of exposure to birth defects and cancers, but newborn babies across the nation already show 200-300 chemical contaminants in the blood of their umbilical cords when tested, according to the National Academy of Pediatrics.
Every well requires 400 – 2000 trucks running 24 hours a day carrying sand, frack fluid and water in, and oil, possibly gas, and “produced”, (which means poisoned), “water” out. 24 hours a day of tremendous noise, dirt, fires and lights all night, hundreds of transient workers and big machines pounding up and down roads without ceasing during the entire life of the well.
Perhaps 30% of the water forced into the rock comes back up, but laden with chemicals in a thick soup of sand. Standard practice is to truck this elsewhere and re-inject it, which seems to be causing earthquakes. The other technique is to pump it into evaporation pits. When these pits and impoundments get breached, the contaminants have flowed directly into ponds and pastures. Half the cows grazing near one, in western Pennsylvania, gave birth to dead calves that year and the following year effects were very visible in an unusual lack of steers.
This means that something like 70% of the potentially poisonous water remains in the permeable shale rock layer, trickling slowly down. The Floresta/Forest Service takes responsibility for the surface of the land. The studies they‘ve conducted on the impact of proposed oil fracking focus on the surface of the land. But, as devastating as oil extraction is to land, the catastrophic consequences are likely to happen slowly underground.
The BLM is charged with making sure that the FS studies adequately address the movement of water underground which is based on thoroughly understanding the geology of an area. But the subject of recent FS studies has been the Spotted Owl and road erosion. This sale should not be allowed to happen because there is not any basis for a “finding of no significant impact” (FONSI), which is a precondition for the sale. THIS MAY BE THE MOST EFFECTIVE POINT OF PROTEST
Independent review is also needed and Rio Arriba Concerned Citizens is undertaking one.
TALKING POINTS:
INCOMPLETE STUDY AND DISREGARD FOR PROCEDURE – the BLM needs to update the 2003 Resource Management Plan (RMP) and Mancos Shale/Gallup formation RMPA/EIS alternatives. These two studies do not address shallow shale hydraulic fracturing (fracking) in this geologic situation. If the lease sale continues BLM will be in violation of the National Environmental Policy Act (NEPA).
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 are often used to dispose of waste-water and are known to cause seismic activity.
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. 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.
WILDLIFE – talk about endangerment of any particular species – disruption of migratory patterns, etc.
DARK SKY – talk about your feelings for an uninterrupted night sky view.
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.
Talk about your feelings in light of this statement and what you know about hydraulic fracturing as it relates to the Rio Arriba Frontier District.
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.”
Write about what you think about that.
DISRUPTS COMMUNITIES BY INCREASING NOISE POLLUTION AND TRAFFIC, OVERSTRESSES INFRASTRUCTURE – thousands of big rig trucks running on roads 24/7; generators, bright lights, hampered emergency response times, etc.
IN CLOSING – round out your letter with a reiteration 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.
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.
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.
P.O. Box 1116
Gallina, NM, 87017
Santa Fe Water Awareness Group 