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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />116 <br /> <br />Without implementation of a precautionary approach to these risks, BLM will continue to <br />place the health of our community and our environment at risk. <br />2. The UFO failed to sufficiently consider issues of water supply related <br />to fracking. <br /> <br />In addition to impacts on water quality, mineral development processes, and particularly <br />fracking, may result in significant impacts on water quantity. To frack a single well one time <br />requires 2-8 million gallons of water.328 Annually, the EPA estimates that 70-140 billion gallons <br />of water are used to frack wells in the United States – enough to supply drinking water to 40-80 <br />cities of 50,000.329 This massive use of water is of particular concern in states in the interior <br />west, like Colorado, were water supplies are scarce and already stretched.330 Indeed, as the <br />Department of Energy has recognized, “[a]vailable surface water supplies have not increased in <br />20 years, and groundwater tables and supplies are dropping at an alarming rate.”331 Because of <br />the chemicals that are added to fracking water, the water may not be reused.332 Removing water <br />for fracking can stress existing water supplies by lowering water tables and dewatering aquifers, <br />decreasing stream flows, and reducing water in surface reservoirs.333 This can result in changes <br />to water quality, can alter the hydrology of water systems, and can increase concentrations of <br />pollutants in the water. <br /> <br />There is also potential for the reductions in water quantity to impact aquatic and riverine <br />species and habitat by affecting water flows and natural river processes: this, in turn, could lead <br />to fish declines, changes to riparian plant communities, and alterations to sediment.334 Further, <br />water resources in Colorado are in many locations stressed or over-allocated, and oil and gas <br />development has already lead to unpermitted and illegal water withdrawals.335 <br /> <br />Here, in its NEPA analysis BLM must closely assess the direct, indirect, and cumulative <br />impacts of lease development on water supplies. 40 C.F.R. §§ 1508.7, 1508.8. This analysis must <br />consider the potential sources of water in the UFO that would be used for oil and gas <br /> 328 J. David Hughes, Will Natural Gas Fuel America in the 21st Century?, May 2011, at 23 <br />(attached as Exhibit 184). 329 See U.S. Envtl. Protection Agency, Draft Plan to Study the Potential Impacts of Hydraulic <br />Fracturing on Drinking Water Resources (Feb. 2011) at 20 (attached as Exhibit 185). 330 See Western Organization of Resource Councils, Gone for Good: Fracking and Water Loss in <br />the West (2013) at 7-8 (attached as Exhibit 186) (noting water scarcity in west and significant <br />water demands of fracking). 331 U.S. Dep’t of Energy, Energy Demands on Water Resources: Report to Congress on the <br />Interdependency of Energy and Water, Dec. 2012, at 12 (attached as Exhibit 187). 332 See EPA Draft Plan to Study the Impacts of Hydraulic Fracturing on Drinking Water at 20 <br />(attached as Exhibit 185). 333 Id. 334 Nat’l Parks Conservation Ass’n, National Parks and Hydraulic Fracturing: Balancing <br />Energy Needs, Nature, and America’s National Heritage (2013) at 23 (attached as Exhibit 188). 335 See WORC, Gone for Good at 21 (attached as Exhibit 186).