Town Council Response to BLM Drilling

Posted by on Feb 16, 2020 in News | 0 comments

Bureau of Land Management Attention: Cliff Giffen Recapture APDs
P.O. Box 7

Monticello, UT 84535 February 6, 2020

Dear Monticello Acting Field Manager Johnson, Assistant Field Manager of Resources Bulla, and Mr. Cliff Giffen:

The Bluff Town Council appreciates the opportunity to share its concerns with the Bureau of Land Management Monticello Field Office (BLM) regarding the Recapture APDs Environmental Analysis (DOI-BLM-UT-Y020-2016-0066-EA). As the elected representatives of Utah’s newest town, the Council is committed to protecting our aquifer, the sole source of potable water not only for Bluff, but for many residents in the larger area who haul water from Bluff to their homes. The Bluff aquifer is currently in good condition, according to a 2018 USGS Study and other information sources.

At a special meeting convened this morning, the Council unanimously voted to oppose drilling into the Bluff aquifer as proposed by the 2 APDs (Recapture 4-34H and 11-22H). To be clear, the Council is not voting against all oil and gas drilling; it voted against drilling into the aquifer that supplies the only drinking water available to the greater Bluff community. The potential development of two wells just 1-3 miles from the Town boundary prompts the Council to respectfully request your prudent consideration of the concerns and protections expressed in this letter.

Bluff has played a regional role in mining and energy development for over half a century. We recognize the significant economic role of these activities locally and statewide. Nonetheless, the present high quality of our water, the extensive need and use of Bluff’s aquifer by southern County residents, Bluff’s burgeoning economic presence as a tourist destination, and a history of the oil and gas industry indicating some lapses in safety precautions and accountability all lead Bluff to oppose the Recapture APDs. In reaching this conclusion, we respectfully register the following concerns.

Water Quality, Earthquake Potential and Seismological Effects of Fracking
From the Town beginnings, residents have taken great pride in the quality and quantity of Bluff’s water. Bluff’s water is well known and an outstanding asset. Water was the important driver of incorporation in 2018.

Bluff is in the middle of a 50-year water study by Sunrise Engineering to determine growth, water use, water supply, and water withdrawal rates. The existing USGS Study expresses a lengthy timeline for contamination based on current hydrological conditions, but it also finds that “increased groundwater withdrawals could reduce travel time [of contamination] in the vicinity of the wells.” Additionally, it fails to determine the impact of fracking upon subsurface structure and travel time.

We recognize that the public comment period ends today at 5:00 p.m., but the Council requests that BLM consider including the forthcoming “50-Year Water Study for the Town of Bluff,” anticipated May 13, 2020, in decision-making. The Council commits to sharing the final study with the BLM upon completion.

The Council recognizes that the Resource Management Plan and Reasonable Foreseeable Development Scenario for Oil & Gas in the Monticello Field Office was developed before fracking became the common production technology. While the BLM does not oversee the regulation of fracking, it still has the responsibility to analyze any impacts likely to result from the proposed action, including fracking. Neither the Resource Management Plan nor the EA analyzes nor mentions hydraulic fracturing. The Council asks the BLM to remedy its failure to analyze the impacts of fracking in the Environmental Analysis, including the cumulative impact of water contamination through horizontal and vertical migration through fault lines and orphan wells and induced seismic changes. Finally, the possible seismological effects, including earthquakes, from fracking need to be analyzed.

Venting and Flaring
The Council requests that the BLM update the Environmental Analysis to incorporate human health impacts, climate change impacts, and visual and auditory impacts of flaring, venting, and pump motors.

Who Uses Bluff Water
As noted above, many residents in surrounding communities continue to haul Bluff water for home use. The new Bluff Elementary school, with approximately 100 students, relies on safe, clean drinking water.
Since EOG Resources has a history of frequent oil and gas spills, the Council believes it prudent to recommend that a Condition of Approval be attached to the two APDs that commits the operator to notify the Town of Bluff within 24 hours (or less) of a spill or emergency. We request the BLM maximize bond coverage. Bluff residents and visitors remain very sensitive to impacts on human health and climate change as well as visual, auditory, and olfactory impacts through flaring and venting. Additionally, for reasons already named, the Town requests prior notification if and when hazardous materials will be transported through town.

Visitor Economy

Bluff is cognizant of increasing national and even international recognition of its role as a gateway community to two International Dark Sky Parks, Natural Bridges National Monument and Hovenweep National Monument. This role brings economic and other benefits to Bluff, to San Juan County, and to our State. Visitation to these Monuments fits within the State’s economic plans. In addition to the concerns already expressed, the Council believes it reasonable to ask that the BLM support dark skies near this location and put Conditions of Approval and/or BMPs on the two APDs that require light shielding and timing limitations of the operator.

Oversight
Our concerns, briefly listed above, are given particular urgency by the November 2019 audit of the Utah Division of Oil, Gas, and Mining (DOGM). It showed the agency failed its mandate to regulate by failing to levy any fines against oil and gas violators. It typically took two years, as opposed to the required 30 days, to respond to a violation. The Council asks that the BLM refuse to issue permits to drill into the Bluff aquifer as petitioned by EOG or any other entity in the future.

Respectfully submitted on behalf of the Bluff Town Council,

Ann K. Leppanen Mayor of Bluff

cc: Council Members Hook, Murray, Sayers, Sosa

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