ELECTRONIC SUBMISSION – NO HARD COPY TO FOLLOW
February 10, 2017
Bureau of Land Management, Farmington Field Office
Attn: Richard Fields, Field Manager
6251 College Blvd. Suite A
Farmington, NM 87402
Bureau of Indian Affairs, Navajo Region
Attn: Sharon Pinto, Regional Director
P.O. Box 1060,
Gallup, NM 87301
RE: Scoping Comments on BLM / BIA Resources Management Plan Amendment EIS
Dear Regional Director Pinto and Field Manager Fields:
On behalf of all who value America’s heritage, the Coalition to Protect America’s National Parks is writing to respectfully submit scoping comments on the Bureau of Land Management (BLM) Farmington Field Area Resource Management Plan (Mancos-Gallup) Amendment (RMPA) Environmental Impact Statement (EIS), concerning the Bureau of Indian Affairs (BIA) formally joining the EIS process as a joint lead agency. We understand that the BLM and BIA will use this planning effort to inform their subsequent mineral leasing and associated activity decision-making processes. Specifically, the EIS will serve as the analytical basis for decisions pertaining to BIA-managed mineral leasing of Tribal trust and individual Indian allotted minerals within the Planning Area.
The Planning Area is located in San Juan, Rio Arriba, McKinley, and Sandoval Counties in New Mexico, and encompasses approximately 4,200,000 acres of land, including approximately 1,900,000 acres of Tribal surface land, 1,300,000 acres of BLM-managed land, across 17 Navajo Nation chapters, individual Indian allotments, and numerous Chapter House residents. Within this Planning Area there are also units of the National Park Service (NPS), including Chaco Culture National Historic Park (NHP) and Aztec Ruins National Monument (NM).
We understand that the primary potential interest in further oil and gas development is located in the southern portion of the Project Area, within the Mancos Shale / Gallup Sandstone Formation that lies within close proximity to Chaco Culture NHP. Thus, our comments in large part reflect our concerns about potential impacts to Chaco Culture NHP. However, given the Planning Area also formally includes Aztec Ruins NM, our comments also reflect concerns for potential impacts to that NPS unit should oil and gas development be considered nearby.
Both Chaco Culture NHP and Aztec Ruins NM collectively preserve ancient ruins that are reflective of the largest, best preserved and architecturally advanced of all ancient Southwestern villages. These two NPS units are listed on the National Register of Historic Places and are part of a larger UNESCO World Heritage Site that also includes five smaller Chacoan sites managed by the BLM. Chaco Culture NHP in particular preserves ancient Anasazi Chacoan villages that during their more than 300 years of occupation became the ceremonial, administrative and economic center of the San Juan Basin. What remains today is a walled village with almost 400 rooms on three levels, over a dozen kivas (circular ceremonial areas). Chaco’s dozens of Great Houses were connected by roads to more than 150 great houses located throughout the region.
Analyses have shown the improvements in directional drilling and hydraulic fracturing, commonly called “fracking,” have renewed the oil and gas industry’s interest in the San Juan Basin, in particular for the Mancos Shale and Gallup Sandstone. The potential role of this technology in the San Juan Basin, and the size and scale of horizontally drilled hydraulically fractured wells is projected to likely dwarf anything seen in the area previously.[i]
Effects of horizontal drilling and hydraulic fracturing may include the following:
- Water contamination related to drilling and disposal of drilling fluids;
- Reductions in stream flow and groundwater levels from operational water requirements;
- Air quality degradation from flaring, internal combustion engines on drill rigs and trucks, and fugitive dust from equipment transportation and operation; and
- Safety concerns and impacts to wildlife associated with the necessary transportation to support drilling operations.
Potential impacts from vibration during the fracking process are also a significant concern. In Chaco Culture NHP, vibration studies established guidance for “safe distances” from archeological structures. Seismic risk to the larger archeological structures has also been studied. Based on normal blasting practices in the Chaco Culture NHP area, conventional rail traffic, use of road building equipment, and vehicular traffic patterns, King et al. (1985) recommended that structures be a minimum of 1.2 km (0.7 mi) from blasting, 0.5 km (0.3 mi) from railroad traffic, 45 m (150 ft) from road building, and 25 m (80 ft) from vehicular traffic. King et al. (1991) recommended that heavy vehicular traffic on a rough road be at least 30 meters (100 ft) from a sensitive site. With respect to horizontal drilling and hydraulic fracturing in the vicinity of Aztec Ruins National Monument, a typical “safe distance” would be delineated by the well site pad.
Installation and operation of injection wells is also a concern due to the probability for casing failures (leading to groundwater contamination) and permanent “noisy” facilities needed for the injection process. In addition, injection wells have the potential to induce earthquakes. Understandably, generation of such an earthquake is highly dependent on the geophysical properties of an injection site, the amount of fluid injected, and the number of injection wells at a site. Seismic risks and potential impacts to Chaco Culture NHP from injection wells should be assessed.
It’s notable that oil and gas operations can also include adverse impacts to natural darkness (or “night skies”) from facility lighting and gas flaring, and adverse impacts to natural soundscapes from noisy construction and facility operations. These impacts can be effectively avoided or minimized if adequately evaluated and addressed during the planning process.
To proactively address the above concerns, we recommend that the National Park Service be formally invited to join the planning effort as a Cooperating Agency, and that an interagency workgroup and associated planning framework be established to facilitate discussions and allow all parties to resolve issues early. Within this context, we further believe a collaborative planning process or “master leasing plan” be prepared by bringing together a diverse set of stakeholders, including local community members, industry representatives, recreation enthusiasts, tribes, and other interested parties. This collaborative plan should take a landscape-level approach to balancing the protection of the iconic historic sites, scenery and landscapes in the BLM Farmington Field Area. The collaborative master leasing plan process adopted near Moab, Utah can be a model for how to support thoughtful development while protecting world-class environmental, cultural and recreational resources.
Finally, it is our view that a core zone surrounding Chaco Culture NHP be defined and prioritized for protection. A starting point for determining a core protection zone of public and tribal lands surrounding Chaco Culture can begin with the All Pueblo Council of Governors proposal of roughly 10-miles from the NHP’s boundaries. This zone contains an extremely high concentration of significant, well preserved cultural and natural resources, including segments of the Great North Road, the view shed of the national park and portions of the World Heritage Site.
On behalf of our more than 1,100 members and millions of national park enthusiasts across the nation, the Coalition to Protect America’s National Parks, thanks you for the opportunity to comment on the BLM Farmington RMPA EIS. If you have any questions concerning our comments please contract the Coalition’s Executive Director, Amy Gilbert at firstname.lastname@example.org.
Maureen Finnerty, Chair
Coalition to Protect America’s National Parks
Mark Ames, BLM RMP Amendment Project Manager
Harrilene Yazzie, BIA Supervisory Environmental Protection Specialist
Michael Quijano-West, Superintendent, Chaco Culture NHP & Aztec Ruins NM
[i] Aztec Ruins National Monument, Geologic Resources Inventory Report, Natural Resource Report NPS/NRSS/GRD/NRR—2016/1245