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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />117 <br />development, and the impacts of these water withdrawals on water availability for drinking, <br />agriculture, and wildlife. The analysis must further address the impacts to water quantity at <br />different annual, seasonal, monthly, and daily time scales because the impacts of such water <br />withdrawals could be more acute during times, months, and seasons of scarcity. For example, <br />increased withdrawal and irretrievable contamination of waters will be particularly harmful <br />during times – like the present – when much of the state is experiencing drought conditions.336 <br />Based on the estimated 1,271 wells to be drilled over the life of the RMP, this will result in 2.5- <br />10.1 billion gallons of water that will be removed from the hydrologic system. Nowhere does <br />BLM disclose or analyze the impact of this withdrawal on the planning area or resource values. <br />3. The UFO failed to sufficiently consider impacts to surface water <br />related to fracking. <br /> <br /> The BLM briefly considers the potential for hydraulic fracturing fluid spills, recognizing <br />that “[h]ydraulic fracturing could disturb surface water and groundwater hydrology and impact <br />water quality.” EIS at 4-130. Although Appendix G does contain some best management <br />practices directed at reducing the potential for contaminating water resources with hydraulic <br />fracturing spills, EIS at G-9 to G-10, the UFO has failed to address several fundamental <br />questions that are central to fulfilling the agency’s hard look mandate. It is undisputed that <br />millions of gallons of water are needed to frack a single well. This raises several issues which the <br />UFO has failed to fully address in the RMP/EIS. See State of New Mexico v. BLM, 656 F.3d 963, <br />714-15 (10th Cir. 2009) (providing that the EIS failed to take hard look at water quality impacts <br />from proposed oil and gas lease sale where wells would generated significant amounts of waste <br />water). For example: <br /> <br />• What source waters will be used for well development, and what are the direct, <br />indirect, and cumulative impacts of extracting high volumes of these waters from <br />surface or groundwater sources in this area? <br /> <br />• How would the produced water be disposed of? If produced water is returned to the <br />surface as toxic waste for evaporation, where will such wastewater ponds be located? <br />And, if produced water is re-injected in wastewater wells, where will such wells be <br />located? <br /> <br />• What kind of treatment, if any, will be required of the producer for treating fracking <br />wastewater? <br /> <br />• What is the potential footprint and location of the necessary treatment facilities, and <br />what is the direct, indirect, and cumulative impact of such facilities? <br /> <br />• What mitigation measures and best management practices will BLM require, or at <br />least recommend, to ensure that wastewater does not contaminate surface or <br />groundwater resources, or impact threatened and endangered populations and <br />designated critical habitat in the planning area? <br /> 336 See id. at 8.