Laserfiche WebLink
CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />115 <br /> <br />A lines of reasoning approach utilized at this site best supports an explanation that <br />inorganic and organic constituents associated with hydraulic fracturing have <br />contaminated ground water at and below the depth used for domestic water <br />supply…. A lines of evidence approach also indicates that gas production <br />activities have likely enhanced gas migration at and below depths used for <br />domestic water supply and to domestic wells in the area of investigation. Id. at 39 <br />(emphasis added). <br /> <br />Although the Pavillion Report was never finalized, EPA shared preliminary data with, <br />and obtained feedback from, Wyoming state officials, EnCana, Tribes, and Pavillion residents, <br />prior to release. Even in draft form, the Pavillion Report and its troubling findings – as well as <br />other evidence of fracking related contamination from around the country – satisfies the low <br />threshold for consideration of the impacts described therein in the NEPA analysis for the UFO <br />RMP.325 <br /> <br />Historically, BLM has been dismissive of possible impacts to water quality from <br />hydraulic fracturing. However, given the weight of both new and old evidence documenting the <br />risk of water contamination from gas drilling across the country and within the planning area, <br />BLM’s approach is becoming increasingly untenable. Indeed, even an industry report prepared <br />for Gunnison Energy Corporation – a major oil and gas developer with leases just south of the <br />UFO – has acknowledged the potential for significant impacts to water resources from <br />fracking.326 The simple fact of the matter is that natural gas development has the potential for <br />poisoning our water with toxic, hazardous, and carcinogenic chemicals as well as naturally <br />occurring radioactive radium, and BLM has failed to provide a thorough hard look analysis of <br />these potentially significant impacts in its analysis for UFO RMP. <br /> <br />Recent reporting from New Mexico has acknowledged a proliferation of “frack hits,” or <br />“downhole communication,” where new horizontal drilling for oil is communicating with both <br />historic and active vertical wells.327 This is a significant development that could result in well <br />blowouts, contamination of resources, and issues over who is responsible for liabilities and costs <br />of such impacts. <br /> <br />325 For the results of a recent investigation of the potential contamination in Pavillion, see <br />Dominic DiGiulio and Robert B. Jackson, Impact to Underground Sources of Drinking Water <br />and Domestic Wells from Production Well Stimulation and Completion Practices in the <br />Pavillion, Wyoming, Field, Environmental Science and Technology (March 29, 2016), available <br />at: http://pubs.acs.org/doi/pdf/10.1021/acs.est.5b04970. 326 See Gunnison Energy Corporation, Analysis of Potential Impacts of Four Exploratory Natural <br />Gas Wells to Water Resources of the South Flank of the Grand Mesa, Delta County, Colorado <br />(March 2003) at 42, 56 (attached as Exhibit 181). 327 See, e.g., Gayathri Vaidyanathan, In N.M., a sea of ‘frack hits’ may be tilting production, <br />E&E News, (March 18, 2014) (attached as Exhibit 182); Tina Jensen, Fracking fluid blows out <br />nearby well, KQRE (October 19, 2013), available at: <br />https://www.earthworksaction.org/media/detail/fracking_fluid_blows_out_nearby_well#.WBJuh <br />MnN6T9 (attached as Exhibit 183).