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 west 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 312 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 longterm 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, OVERSTRESSES 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.