The Aquifer when fracked

The Aquifer when fracked

Tuesday, November 27, 2018

The rising risks of the West’s latest gas BOOM!

An explosion in suburban Colorado raises questions on safety and accountability.


Republished with permission from High Country News This story was originally published at High Country News ( on OCt.19, 2018.

A few days before Christmas last year, a dispatcher for the Weld County Sheriff’s Office was working through a routine set of calls, ranging from missing cats and parking ticket warrants to domestic disturbances, drunk drivers and a possibly armed meth-head menacing a neighbor. Then, at 8:48 p.m., came a jarring alert: The Windsor Severance Fire Rescue frequency reported a unit “responding to an explosion at an oil well site.”

Excerpts of previously unreleased dispatch tapes from first responders reveal details that differ from what officials originally told the public.

It was 32 degrees and clear on Dec. 22, 2017. A thin, fresh blanket of snow covered Windsor, Colorado, an increasingly suburban community about 60 miles north of Denver. The dispatcher’s tones scrambled rural firefighters more accustomed to grass fires and car accidents than an explosion at a hydrocarbon factory. Stress levels skyrocketed as the first responders described the scene over their radios.

“We’ve got oil burning from an oil fracking truck,” one said, reading the operator’s name from a sign: “Extraction Oil. Extraction.”
“I can see flames about 30 feet in the air, and smoke.”
More than 350 homes were within a mile of the site, and 911 calls from residents flooded the switchboard. The Greeley Police Department emergency call center summed up a report: “Heard big boom. Shook the house. Looks like an oil rig is on fire. Can see flames.”

The first engine laid down two hoses and called for another 2,000-gallon water tender, but the incident commander realized that with so much flammable material, they’d need specialized foam concentrate designed to smother hydrocarbon fires. “Water’s not going to put the fire out,” he said over the radio. “Our best bet is to cool everything around it until we can get foam.”
Karley Robinson, a 25-year-old medical assistant, was playing Dungeons & Dragons at home with her husband and brother when they were shaken back to reality by a huge “boom.” They stepped outside to see the night illuminated, flames shooting skyward, flashing lights rushing to the scene. Robinson figured it was coming from the massive oil and gas site less than a mile away. But then she remembered the well-pad complex, sitting just 130 feet from her kitchen window.
Robinson’s 5-year-old daughter padded up to her parents. “Mommy, is everything going to be OK?” she asked.
Robinson reassured her daughter, “I think everything’s going to be OK.” Still, she called Extraction Oil and Gas, the operator of the exploded well, and left a message: “Hey, I’m right down the street from where one of your rigs blew up.” Even though a different operator owned her backyard wells, she hoped for “some assurance that my house wouldn’t explode.”
It’s a situation that could unfold in any of the dozens of Western communities that have been stampeded by drilling rigs during the latest oil and gas boom: An inferno fueled by toxic, flammable hydrocarbons in backyards, near schools and baseball fields and suburban dwellings. The potential for catastrophe has grown especially high in neighborhoods like Robinson’s. Nearly half of Colorado’s 55,000 active wells are in Weld County, where Robinson lives and thousands more are on their way. Locals call it “Welled County.”
Robinson’s D&D campaign sat abandoned on the kitchen table while she comforted her daughter. But the phone never rang.
When Windsor Severance Fire and Rescue Battalion Chief Todd Vess heard the blast, he thought something had fallen in his basement; that’s how close it sounded. The department’s alert system flashed “oil and gas explosion” on his phone, but at first Vess wasn’t too concerned. Dispatchers received plenty of false alarms regarding drilling sites, especially concerning the fiery nighttime flaring of excess fuel.
Another battalion chief called and told Vess this was the real deal: Flames were consuming an oil and gas site, and a trauma unit was on its way. Vess calmly “prepared for the worst” as more than a dozen neighboring fire districts and regional airport rescue squads converged on the Stromberger well pad with fire engines, water tenders, and trucks carrying firefighting foam. Responders reported flames at least 50 feet high. One firefighter called in for directions and received some deadpan guidance over his radio:
“You’re not gonna miss this, Joe.”
Flames erupt from an Extraction Oil and Gas well site in Windsor, Colorado, after an explosion that injured one worker.
Fox 31/2 News video capture from Dec. 22, 2017


On the well pad site, every oil worker’s nightmare flashed to life with the first terrifying explosion. The crew had been conducting “flowback operations,” probably the most dangerous stage of oil and gas development. After drilling, operators “complete” the well via hydraulic fracturing, or pumping a mixture of sand, water, and chemicals at high pressure to release hydrocarbons from tight rock formations more than a mile underground. Afterward, the fracking fluids, along with other toxic chemicals, dissolved solids, and heavy metals flow back to the surface at high pressure. The liquids are sorted, stored and eventually moved off-site. The Stromberger facility, which sprawled across an area larger than eight football fields, contained 19 flowing wells, along with an assortment of other industrial apparatus, much of it filled or flowing with a salty, flammable chemical and hydrocarbon stew.
“Do an emergency shut in. SHUT IN NOW!” supervisors yelled, desperate to ensure that no more oil and gas leaked out and caused an even bigger blast.

“It could’ve been like an atomic bomb going off.”

—Ernie Bouldin, supervisor for one of Extraction Oil and Gas’ contractors
Workers darted around frantically, shutting off valves, with some of them wielding fire extinguishers. Ernie Bouldin, 57, a supervisor for one of Extraction’s contractors, Colter Energy, who was on-site that night, said that the workers’ quick action helped avoid the worst-case scenario. If they hadn’t shut everything down, Bouldin later said, “It could’ve been like an atomic bomb going off.”
Pressurized pipelines popped beneath their feet and heat singed their coveralls on the freezing night. As workers hustled to shut valves before heading to a designated “muster” area, two of them saw a figure silhouetted against the flames. Houston “Ty” Pirtle staggered aimlessly, arms hanging awkwardly by his sides. They rushed over and heard him wheezing through a damaged airway. That’s when the chilling reality sunk in: The explosion had touched one of their own.

[caption id="attachment_1805" align="alignright" width="479"]Karley Robinson with newborn son Quill on their back porch in Windsor, CO. A multi-well oil and gas site sits less than 100 feet from their back door, with holding tanks and combustor towers that burn off excess gases. Quill was born 4 weeks premature. Pictured here at 6 weeks old. published Oct 19, 2018 Republished with permission[/caption]
Karley Robinson with her newborn baby outside her home in Windsor. She heard the “boom” and saw the ensuing inferno from the Stromberger well explosion last December.
Ted Wood/The Story Group
Denver media and official reports portrayed the events of that winter night as a quickly contained fire that posed little danger to the public or the environment. But first responder dispatch tapes not made public until now, along with newly released documents and interviews with workers, experts, and first responders, paint a darker picture, one of chaos on the verge of catastrophe.
The Windsor explosion highlights what many neighbors wonder: Who is looking out for their safety? Neither the state agency overseeing the oil and gas industry nor the health and environment department conducted an independent investigation of the disaster or its environmental impact. The only fine levied was a small one against an on-site contractor for workplace safety violations. The Colorado Oil and Gas Conservation Commission, or COGCC, issued a “Notice of Alleged Violation” against Extraction in August, which has the “potential to result in a penalty.” But no penalty has been announced. And even as Extraction Oil and Gas acknowledges that it still doesn’t know exactly what happened in Windsor, the company continues to receive approval to drill more wells in even more densely populated towns.
Nevertheless, fallout from the incident continues to ripple across the state, particularly along the Front Range, where drilling rigs are popping up in backyards while brand-new housing developments sprout next to old oil and gas fields. It’s become a rallying point in an intense campaign around a November ballot measure that would require oil and gas wells to be located farther away from homes and schools.
The incident also reminded Robinson, the young mother, that she may have traded her family’s safety for the low cost of their home. Robinson just had her second child in August, a boy born four weeks premature, and now it’s always on her mind.
“I feel like I’m playing Russian roulette with my family,” she said.
Herb Brady, former chief of Windsor Severance Fire Rescue, stands for a portrait in Houston, Texas, where he now works for an EMS vehicle manufacturer.
Jeff Lautenberger for High Country News
In his eight years as fire chieffor the city of Windsor, Herb Brady had watched the steady encroachment of oil and gas wells on new subdivisions, and vice-versa. He had become accustomed to gratefully receiving the “baubles and trinkets” the energy companies offered his rural fire department, including expensive gas monitors and financial donations. He thought “fracktivists” bent on shutting down the industry were hysterical troublemakers.
The Stromberger explosion reshaped his worldview.
Now living in Houston, the 55-year-old said he sees how industry money manipulates public opinion and local politicians, projecting a false aura of competence and oversight over “petrochemical plants in people’s backyards.” The industry wields influence throughout Colorado, blocking even modest legislative reforms, pressuring regulators and using the courts to get huge tax breaks and intimidate opponents. Brady now recognizes what he calls his “detrimental reliance” on state and federal agencies that oversee the industry. “I always thought that the COGCC and OSHA (the federal Occupational Safety and Health Administration) were on top of things, and all I had to do was do my job.”
Now, he said, “The public has a right to be concerned. It is a dangerous situation.”
For Brady, seeing that firefighters responding that night lacked the necessary protective gear and training underscored just how unprepared rural departments are for an event of this magnitude. “It was just a roll of the dice, the fact that nobody died. We were lucky.”
Ernie Bouldin, oil and gas contractor, now retired on medical leave.
Ted Wood/The Story Group
Right before the blast,the Stromberger crew of 13 “flow-back operations assistants” and three supervisors ticked through their routine rounds, inspecting the wells and aboveground storage tanks, 23 separators, seven combustors and miles of piping around the site. Bouldin, one of the site supervisors on duty, said the workers were “like family” to each other, even as they bitched about the cold and the long hours.
Bouldin, who is on medical retirement unrelated to his oil and gas work, spoke on the record about the explosion; another worker spoke with a promise of anonymity because he still works in the industry. Others relayed through intermediaries that they were told not to speak to journalists, or that they “don’t want to relive it again.” Pirtle and his family did not respond to multiple interview requests, although they did share information publicly as he was convalescing.
Houston Pirtle was known for being a hard worker, the kind you’d want on your team. With less than a year of experience, the 6-foot-tall, 190-pound man was still a “green hat” on the Stromberger site. According to a social media post from his mother, Pirtle had been through some rough patches in his personal life recently, but the Colter job provided stability and good pay (employees typically start at $16 an hour, plus a per diem). The weeks-long blocks of work, sometimes 14 hours a day, were tough, but things were looking up for the 26-year-old, his wife, Rachel Darrah, and their two toddlers.
That night, Pirtle was working in a shack and making hourly rounds to monitor the levels, pressure and temperature readings for the valves, flow-back storage tanks, and separators. The generator that powered his shack’s light and a nearby portable heater had been acting up lately. A sensor is supposed to shut the generator down if it detects unsafe gas levels, but it kept blinking off, seemingly at random. Repairmen had repeatedly tried troubleshooting it, but hadn’t replaced it.
The troublesome generator, which was not “spark-proof,” was placed about 10 feet from the trailer, much closer than the 100 feet recommended to reduce fire risk under best industry practices by the American Petroleum Institute. Everyone knew that was a bad idea, but it’s one of the many small concessions that complex sites make to keep running. Elsewhere, a flameless heater, which also was not “spark-proof,” had been moved to within about 10 feet of the flow-back storage tanks to keep a set of pipes warm on frigid winter nights. Wires and pipes weren’t arranged as neatly as usual, creating a high-octane obstacle course. No Extraction employees were on-site, but company spokesman Brian Cain said “an experienced contractor” served as a company representative.
Extraction’s accident report filed with the COGCC does not identify a root cause for the explosion, but the investigations support one theory. According to an OSHA investigative report obtained through a Freedom of Information Act request, a third-party forensic team that Extraction hired after the fact found leaks in piping designed to contain hydrocarbon gas emitted from the flow-back storage tanks. Leaked gas may have pooled in a corner surrounded on two sides by 32-foot-high, flesh-colored sound barriers, trapped close to the ground by an inversion of cold air.
The balky generator went out, possibly because the gas sensor triggered a shutdown. Pirtle’s trailer went dark, so he bundled up to go check on it.
Once there’s a pool of gas, any spark can light it. When Pirtle tried to restart the generator, something — the engine kicking on, two pipes scraping together, a bit of static from a fleece jacket — provided that spark. The tank went up in a fireball in an earth-shaking blast, sending the workers scrambling to protect the site. Smaller explosions set off other fires around the site, threatening to spread into a chain reaction of flame.

“If you don’t shut those off right away, a lot of people are going to die.”

—Ernie Bouldin, supervisor for one of Extraction Oil and Gas’ contractors
Even though the workers trained daily for such an emergency, Bouldin said the true test for any crew only comes in the face of real fire. “None of them ran,” he said proudly. Bouldin, three hours into his 13-hour shift, was 150 feet from the exploded tank. Alert workers darted around to manually close ball and wheel valves to stop the hydrocarbons flowing to tanks and through the miles of pipes around the site. “If you don’t shut those off right away,” Bouldin said, “a lot of people are going to die.”
The blast badly burned Pirtle’s hands and face and seared his windpipe. Two workers carried him away and applied cream from an on-site first aid kit to his second- and third-degree burns, while supervisors kept a running headcount. Bouldin sped his pickup truck through “ungodly” heat and helped hoist Pirtle into the cab. An ambulance met them at the edge of the site to take the injured man to North Colorado Medical Center in Greeley.
The rest of the crew was taken to a nearby hotel, where many of the men stayed during their 28-day-on, 14-day-off shifts, for a standard emergency debriefing, then returned to the well pad to meet their worried families.
Bouldin acknowledged that there were “things (Extraction) should have fixed,” but said that ultimately they were small issues. “We wouldn’t have done it if we thought it would have put anyone in danger,” he said.
Jason Brooks, general manager for U.S. operations for Colter Energy, which is headquartered in Canada, said the company would “not reply to any inquiries surrounding the fire.” Extraction spokesman Cain said in an email that the company “considers safety to be our utmost priority and our record of operations in this basin reflects that commitment.”
Even though he’s not in the field anymore, Bouldin still wakes up at night thinking about what happened to his younger co-worker. “He got burned pretty danged good,” Bouldin said. “We were pretty tore up about that.”
Bouldin’s voice faltered when asked if his mind had changed about how the site was managed. “Right now,” he said, “I’d tell you this was unacceptable.”
The GoFundMe page for Houston “Ty” Pirtle, who was badly burned in the explosion.
The Windsor explosionand its aftermath reflect an unnerving aspect of life under the latest — and largest — oil and gas boom to hit the West, whether in Wyoming, North Dakota, New Mexico, Utah or here on Colorado’s Front Range. Over the past two decades, new horizontal drilling and hydraulic fracturing techniques have allowed the industry to access oil and gas locked up in deep shale formations and to cluster multiple wells on single pads. They’ve concentrated these mini-industrial sites closer to communities, taking advantage of laws and regulations put into place during earlier demographic and technological eras. As Colorado’s population has increased from 4.3 million to more than 5.6 million since 1999, the number of active oil and gas wells over the same time period has increased from less than 22,000 to almost 55,000 today — a 150 percent increase.

Zoom out to view wells in all stages of development and production on Colorado’s Front Range, where most of the state’s 5.6 million people live.Colorado Oil and Gas Commission data compiled by The Denver Post via CARTO
These twin growth spurts mean that large drilling operations and vast residential developments are spreading like competing invasive species, often right on top of each other. Subdivisions near the exploded Stromberger pad sport bucolic names like “Peakview Estates,” “Greenspire” and the ironic “Windmill Homes.” Meanwhile, residents deal with constant thumping sounds, foul smells, industrial lights and toxic emissions from fracking operations a Frisbee-toss away from backyard play areas.
Fearful and frustrated citizens in towns from Lafayette to Loveland and beyond have educated themselves about arcane subsurface mineral rights law while fighting for greater local control. Some cities passed fracking bans, which were overturned by the Colorado Supreme Court. Two months before the Windsor explosion, nine local governments signed a letter to Gov. John Hickenlooper, D, stating: “There is a large and growing consensus that this intensive industrial activity does not belong in residential neighborhoods, near schools or hospitals, or in close proximity to drinking water supplies.”
Even some industry officials have publicly stated that safety issues are getting short shrift. Citing former executives saying that top management had de-emphasized safety considerations, Anadarko shareholders filed a class action suit late last year, claiming the company’s Colorado operations were a “ticking time bomb.”

An oil and gas rig serves as the backdrop of an Erie, Colorado, park.
Ted Wood/The Story Group
When Battalion Chief Vess arrived on the scene, small explosions rocked the chilly night as pockets of pressure blew and ignited. The firefighters approached the fire as they would any other, sending firefighters and engines as close to the burning equipment as seemed prudent. The incident commander determined that Engine 1 would be their “line in the sand” at what seemed like a safe distance from the facility.
With flammable fluid still leaking and the danger of re-ignition high, firefighters couldn’t extinguish the blaze with water. So they started calling in specialized firefighting foam from regional responders, companies and local airports.
Extraction employees arrived on-site, urging firefighters to protect the well heads and warning them about new hazards. Firefighters relayed the information to Command. At one point, a “little house” near Engine 7 was Extraction’s “primary concern” because it contained valves that checked the back pressure. “If that goes, all the back pressure’s going to go.”

New events raised more alarms. “The separator is something that’s at high risk,” said a voice on the radio. “We need to get some water on that quickly.”
Smaller explosions continued to go off. A voice broke in over the firefighter frequency, relaying a message from Extraction’s liaison: “We’ve got a serious hazard behind the green heaters on the east side where the real heavy black smoke is coming up. He described those as ‘bombs.’ If they go, then we’re all getting hurt.”

Another explosion, and the tone of the communications took on more urgency. The incident commander took over. “We need to pull our people back. Everybody pull back. We’re going emergency traffic ... All units pull back to a safe location at least to the command post. All units begin clearing out. You guys get your people and your engine out of there, now.”
One of the firefighters wanted to make sure that he heard correctly, because there was no way to remove hundreds of thousands of dollars worth of equipment without sending personnel closer to the burning site. “If you want apparatus, we’re going to have to make another trip back in.”
“That’s negative. Go ahead and just get your people out.”
Two firefighters started to go back in anyway, trying to retrieve equipment. The incident commander ordered them to stop.
“All units, from command,” he said. “We’re abandoning the site. We’re letting it go.”
The Stromberger site as it looks today, after remediation from the 2017 explosions and fire.
Ted Wood/The Story Group
Water tenders and trucks kept arriving, bearing 265-gallon “totes” of foam in 4-by-4-foot tanks and 55-gallon drums, requiring a ratio of 97 parts water to three parts foam. Initially, water supply was tight. It took five minutes to drive each way to the closest hydrant and five minutes to fill each tender, plus waiting time as drivers lined up for their turns. Firefighters called around for a second water source, and at one point sought a highway flare to thaw a frozen connection to a second hydrant. Extraction, which has contracts for emergency water, trucked in more in 18-wheelers.
Uncertain about how soon the fires would be contained and lacking specialized expertise even in well-heavy Colorado, Extraction called in Houston-based Wild Well Control, a company that’s responded to oil disasters from Kuwait to the Deepwater Horizon spill in the Gulf of Mexico. A crew mobilized in Texas but didn’t arrive on-site until daybreak.
All night long, firefighters kept a steady stream of foam and water aimed at the facility. Eventually, the abandoned equipment was no longer in danger. Firefighters worked throughout the next morning, monitoring flames that occasionally licked up and popped like bottle rockets.
Firefighters ended up using more than 3,500 gallons of foam. Retired Fire Chief Brady said that figure doesn’t include an undisclosed amount that was rounded up from private sources, including other energy companies like Noble Energy. Windsor Severance Fire only had two totes. “We used pretty much all the foam in northern Colorado,” Brady recalled, leaving many first responders without any on hand after the fire. Replacement foam had to be trucked in from Texas.
The specification sheets for the foams state that they contain anywhere from 10 to 30 percent of some form of ethylene glycol, a major component of antifreeze, plus an undisclosed percentage of “proprietary” materials that contain chemicals known as PFAS, or polyfluoroalkyl substances. Dubbed “forever chemicals,” they are long-lasting in groundwater and of concern to public health officials and oil and gas industry operators alike. They have been notably linked to contamination near Colorado’s Buckley Air Force Base and other military sites.
During the night, a mixture of water and firefighting foam began flowing towards the site perimeter. Firefighters brought earth-moving equipment in to contain the runoff. Brady said that a “caravan” of big trucks brought in by Extraction were loaded with the runoff and carted away. Extraction refuses to say where the material was disposed of, and the state does not require such a disclosure. Extraction’s Cain said in an email: “The material was taken to a licensed commercial disposal facility. That’s all I have to share.”
Ultimately, Extraction Oil and Gas “remediated” the Stromberger site by carting away 406 tons of dirt over a week in April, according to manifests filed with the COGCC. They deposited that dirt in the North Weld County landfill, a clay-lined facility that does not accept hazardous waste. The soil was classified as “Non-regulated solid: E&P Contaminated Soil” on a “non-hazardous manifest.”
That nonspecific description of “Exploration and Production” wastes exemplifies the opaque regulations governing the industry. In 2002, for example, the Environmental Protection Agency reclassified fluids emitted from oil and gas drilling operations as non-toxic waste that did not need to be reported. These wastes include produced water containing multiple contaminants, as well as drilling fluids, stimulation fluids, liquid hydrocarbons, and hydrocarbon-bearing soil.
The so-called shale revolution took off, and reclassification soon led to exemption. In 2005, then-Vice President Dick Cheney’s “Energy Task Force” led to legislation that exempted hydraulic fracturing fluids from every major federal environmental law.
Doc Nyiro, environmental protection manager for Waste Management, which operates the North Weld landfill, wrote that firefighting foam-contaminated soil is acceptable at the site. Both the Colorado Department of Public Health and Environment and the COGCC said there is no requirement to report the use of firefighting foam, nor to test for related chemicals when companies dump potentially contaminated soil in landfills.
As one consequence, Health Department spokesman Mark Salley wrote in an email, “The extent of PFAS contamination in Colorado’s groundwater is unknown.”
A screen capture from television news footage shows a Firestone, Colorado, home fully engulfed by flames in April 2017. Two men died and a woman was severely injured in the fire, which was caused by a leak in an underground pipeline.
YouTube Video capture from Denver7
Colorado’s most infamous gas explosionoccurred on April 17, 2017, when a leak in an underground pipeline exploded a suburban home in Firestone, less than 25 miles north of the Denver city limits. The blast killed two men, Mark Martinez and his brother-in-law, Joe Irwin, and severely burned Martinez’s wife, Erin.
It was followed by a flurry of “never-again” statements. Though Colorado has not seen another household explosion, natural gas infrastructure continues to pose dangers around the country. In January this year, five workers were killed in an oil well explosion in Oklahoma. In September, explosions linked to natural gas pipelines killed one person and destroyed several homes in three Boston neighborhoods, just a week after a western Pennsylvania town was evacuated for its own pipeline fire.
The Windsor blast is a reminder that the hazard remains high, stoking the fears of communities potentially in harm’s way. According to a 2017 study by the Colorado School of Public Health that analyzed state accident reports, there were 116 reported fires or explosions at Colorado oil and gas sites between 2006 and 2015 — an average of almost one per month. But those numbers only reflect incidents covered by the state’s reporting requirements at the time, which, as the authors noted, were less stringent than those in Utah, a state hardly renowned for its strict environmental rules.
Until recently, Colorado only required companies to report explosions and fires if they resulted in an injury to the general public that required medical treatment, or if there was “significant damage” to a well or equipment, a judgment left to the operator’s discretion.
The authors say the number of actual fires and explosions in Colorado likely would be almost two and half times higher — more than one incident every two weeks — if the state had stronger reporting requirements. They noted: “The increased size and complexity of operations at multi-well pads will likely continue in the future, particularly in urban and suburban areas, increasing the potential risk for those living and working in close proximity to these sites.”

“The volume of activity that occurs without serious incident in such a large and dispersed industry is also worth noting alongside the accidents that unfortunately do at times occur.”

—Todd Hartman, spokesman for the Department of Natural Resources, which oversees the Colorado Oil and Gas Conservation Commission
Todd Hartman, spokesman for the Department of Natural Resources, which oversees COGCC, said, “Any spill or fire is one too many, and we continue to work hard to reduce those events.” Hartman added that with more than 55,000 active wells in the state, 116 accidents is “equal to one event every 1,573,276 well/days,” or days a well is operated. “The volume of activity that occurs without serious incident in such a large and dispersed industry is also worth noting alongside the accidents that unfortunately do at times occur.”
Still, operators have reported more than 40 fires and explosions at oil and gas facilities since the end of 2015, when the Colorado School of Public Health team stopped their data analysis — more than one a month. The incident descriptions are often vague and are buried in the COGCC’s difficult-to-navigate website. Several incidents caused fatalities, including an oil tank battery explosion in Mead a month after Firestone, which killed one worker and injured three.
State oil and gas inspector Mike Leonard, who was on the scene in Windsor that night, says people outside the industry tend to conflate the causes of these oil and gas accidents. “What happened at Windsor is not what happened at Firestone,” Leonard said. “It’s not what happened at Mead.”
Those distinctions may indeed be lost on Colorado communities where wellpads and infrastructure loom over houses and schools. Whatever the cause of individual explosions and fires, keeping neighborhoods safe poses a daunting challenge for under-resourced first responders. “Nobody is really talking much about the low-probability, high-consequence events,” said Don Whittemore, a former assistant fire chief for Rocky Mountain Fire and an internationally recognized expert on disaster response. “Your average Joe Firefighter isn’t prepared for these kinds of events.”
In February 2018, partly in response to the Firestone tragedy, COGCC tightened its reporting requirements to include “any accidental fire, explosion, or detonation, or uncontrolled release of pressure.” A bill to make those agency rules permanent passed the Democrat-controlled state House last session. But industry officials opposed the bill, and the Republican-controlled state Senate killed it.
Concerns about oil and gas development go well beyond explosions. The same gases that fueled the Windsor explosion can also harm human health and the climate.
Methane, a powerful greenhouse gas that warms the planet more quickly than carbon dioxide, can leak during the extraction and transportation of oil and gas. It is often accompanied by volatile organic compounds, or VOCs, a major contributor to the ozone problem in Colorado, where some areas have violated federal ozone health standards for years. Studies from around the country have linked proximity to those emissions with multiple health and environmental impacts, including increased cancer risks and adverse birth outcomes. According to COGCC, there were 17,254 detected leaks in 2017 from compressors, pressure relief devices, pump seals and other sources. (Most were repaired.)
In Colorado, those oil-and-gas-related VOCs aren’t being adequately measured. The Windsor explosion brought that into sharp relief. Detlev Helmig, a scientist at the University of Colorado’s Institute of Alpine and Arctic Research, ran an air-monitoring station in Boulder tracking levels of known carcinogens like benzene and toluene. A Windsor resident emailed Helmig after the blast, wondering if his monitors had picked up anything. If enough gas had leaked to cause a well-pad fireball, they wondered, couldn’t there be toxic levels of benzene in the air?
Helmig was stunned to see sharp spikes in ethane and benzene levels that night, the highest levels measured before or since. “With very, very high certainty,” Helmig said, there was a huge release of gases in the hours before the explosion. Given the wind patterns at the time, the gases most likely came from the direction of Windsor, but because Helmig’s monitor is about 40 miles away from the explosion site — and there’s not a similar monitor closer — the exact source couldn’t be pinpointed.
In August, Boulder County’s funding for Helmig’s monitoring station ran out.
In this case, Helmig believes, what people don’t know can hurt them.
“There’s an expectation that changes in regulations will cause improvements to air quality. But the only way to know is to measure,” he said. The state health and environment agency, Helmig says, “doesn’t seem to have the resources or the interest.”
A well pad near a subdivision in Windsor, Colorado.
Ted Wood/The Story Group, for High Country News
Industry advocates acknowledge the dangers of oil and gas work, but prefer to highlight new technology and training that makes it safer. On Aug. 22, at the 30th annual Colorado Oil and Gas Association Energy Summit in Denver, attendees — some sporting “Frack Yeah” ribbons on their badges — talked up their role as “good neighbors.”
COGA distributed pamphlets detailing more than $9 million in donations from members last year. Executives encouraged giving employees paid time off to volunteer, or paying to maintain schools and libraries.
Yet critics continue to push back. The upcoming 2018 election will allow voters to weigh in on one of the most influential policy measures in years. Proposition 112 would require wells to be at least 2,500 feet from homes, schools, parks and other buildings, a distance that industry says would severely curtail new production in the state, but advocates say will make neighborhoods safer.
Also on the November ballot is an industry-backed measure, Amendment 74. It would regard any government law or regulation that could have an impact on private property values — including basic zoning codes and subsurface mineral rights — as a “taking” that would require governments to reimburse property owners. The environmental group Conservation Colorado wrote that Amendment 74 would “paralyze state and local governments in their capacity to protect the health and safety of citizens.” The Colorado Municipal League, hardly a firebrand on these issues, circulated a memo exhorting its members to defeat 74 because of its “far reaching and potentially disastrous consequences.”
The oil and gas industry has launched an all-out blitz, fighting the setback initiative and promoting the takings amendment, at times using dubious methods — harassing signature gatherers and spending millions of dollars on public relations campaigns. Chip Rimer, senior vice president of global operations for Noble Energy, told the August COGA conference that the 2018 midterms would be “one of the most influential elections for our industry.” He cited a Common Sense Policy Roundtable report predicting 147,000 lost jobs over 12 years if the setback initiative passed, telling attendees to imagine a town the size of Boulder going dark. “If that doesn’t get your blood boiling,” he urged the crowd, “you’ve got to get your passion up.”
Protect Colorado, a political action committee opposing any ballot initiatives that would limit fossil fuel development, had pulled in more than $30 million in 2018 as of early October, and had spent more than $20 million that year in part on radio, television and digital advertising. Extraction has contributed nearly $3 million this year to Protect Colorado, while Noble Energy and Anadarko have collectively contributed more than $10 million.
At the mid-August COGA conference, Colorado’s gubernatorial candidates — Democratic Congressman Jared Polis and Republican State Treasurer Walker Stapleton — both stated their opposition to Proposition 112. Even though Polis famously advocated for stricter controls on fracking in the past, including a 2,000-foot setback, he said the latest measure was “simply the wrong solution for Colorado.”
Often lost in the debate are regulations, or the lack thereof, restricting how close new homes can be built to existing oil and gas infrastructure. In Firestone, the exploded house was built just 170 feet from an unregulated and abandoned gas line owned by Anadarko Petroleum, 20 feet further than the required setback in the town.
In Windsor, new homes are supposed to be 350 feet from oil wells. But Karley Robinson’s home ended up less than the distance of an Olympic swimming pool lap from tank batteries and combustors, due to a setback loophole used by developers and energy companies. “Once the plat is approved, the property owner has the right to build,” said Town of Windsor Planning Department Director Scott Ballstadt. “The setbacks don’t apply to building permits.” The wells, in turn, were approved before the houses were all built, meaning that the oil and gas commission’s setback rules apparently didn’t apply. Even if they did apply, the town setbacks are measured from the wellheads, not other oil and gas infrastructure that can leak or explode. This kind of play by housing developers, many of whom lease their mineral rights to oil and gas companies, occurs throughout the state.
A young girl at the Erie Skate Park, Colorado, where a maintenance rig looms.
Ted Wood/The Story Group
Randy Ahrens, the mayor of Broomfield, a booming burg halfway between Denver and Boulder, couldn’t get the Windsor blast off his mind. Ahrens had spent six years working in oil and gas but was skeptical of the industry’s impact on his community, which some residents were starting to call “Doomfield” because of the influx of well permit applications. Extraction had been seeking approval to drill 84 new wells in his town; how could he assure residents that what happened in Windsor wouldn’t happen there?
He still hasn’t gotten a good answer. The Colorado Oil and Gas Conservation Commission never conducted an independent investigation, instead relying on an accident report from Extraction that failed to identify a “root cause” for the incident. Instead, the company laid out possibilities for the source of the leak (possibly an open valve or a depressurized tank) and the source of the spark, including a vague mention of “unknown worker activities.” The state accepted the filings.
Asked if Extraction’s self-investigation into the Windsor explosion was sufficient, the COGCC’s Leonard said, “Everything they put in that report lines up with what I saw that night.” He explained that the state primarily wants to ensure that another accident like that won’t happen again; inspectors now know to look for where heaters and generators are sited.
The state agency’s authority is limited, so its investigation and any discipline had to focus on Extraction, not on contractors like Colter that may share the blame. Industry insiders say that essentially creates a system of plausible deniability, allowing companies to hire contractors for the most dangerous work. “That’s part of the game that gets played,” says Bouldin, the former Colter supervisor. “They keep their fingers out of it so they can blame somebody else.”
Meanwhile, the Colorado Department of Health and Environment says that the cleanup from any oil and gas fire, explosion or spill is not their responsibility.
None of this offered much comfort to Mayor Ahrens, who emailed Extraction’s inconclusive report to staff and voters alike, vowing to push for more information. “At the end of the day,” he said in an interview, “I don’t think they (Extraction) really know what happened.” At one testy city council meeting, Extraction executives walked out when asked about their safety record.

“I’d pay you a million dollars a year not to drill.”

—Broomfield, Colorado, Mayor Randy Ahrens, who tried to keep new wells from being drilled in his city
In response to Broomfield’s concerns, Eric Jacobsen, Extraction’s senior vice president of operations, wrote a letter stating that the company had identified probable gas and ignition sources that might have contributed to the Windsor explosion. “Because it is difficult to pinpoint the exact contributing gas or ignition source as the definitive cause of the incident, we have implemented corrective actions that address all of these possible sources in our operations going forward.” Among those: enhanced supervision of flowback operations, better on-site gas monitoring and new contractor training.
Despite Ahrens’ ongoing concerns, state law makes it difficult for Broomfield to say no to new drilling. After Extraction executives originally told Ahrens that Broomfield could receive a million dollars a year in new revenue, Ahrens says he told them, “I’d pay you a million dollars a year not to drill.”
As of mid-October, the COGCC had approved 71 new wells in Broomfield.
With his family by his side,Houston Pirtle was stabilized at the hospital. Speaking to CBS Denver on Jan. 3, His wife said that Pirtle’s first words when they removed the tubes from his throat were to ask how she was doing. “That’s just who he is,” Darrah said. “(He) wanted to make sure me and the kids were okay.”
Pirtle’s family had to set up a GoFundMe campaign that raised $11,000 to help keep his wife and two infant children afloat as he recovered. Bouldin, the retired supervisor, splutters with contempt when asked about the way Pirtle was treated. “The big leaders of this chain are too cowardly to step up and take responsibility,” he said.
Pirtle’s family got through his initial convalescence with help from the funds they raised. Within months, Pirtle was back in the field, still physically and mentally scarred. A friend said Pirtle is “up and down.”
OSHA investigated the accident, but the agency’s legal mandate is narrowly focused on worker safety issues, not dangers to the public. It’s even more limited because there are no federal safety standards for oil and gas industry workers. Instead, OSHA relies on “best industry practices” collected by the American Petroleum Institute, the industry trade group.
“This doesn’t necessarily mean the best practices,” said Richard “Dean” Wingo, a former OSHA regional manager based in Dallas. “The best practices could be beyond what the industry recognizes, but OSHA is not going to hold them to that.”
Colter Energy, the contractor whose workers were on-site, was ultimately cited for a handful of workplace safety violations. OSHA levied a $7,068 fine, but that was negotiated down to just $3,534 for two “serious” violations: keeping the generator and heater too close to a separator.
According to SEC filings, Extraction Oil and Gas listed $8.8 million in net income in the second quarter of 2018, selling 73,563 “barrels of oil equivalent” per day in crude oil and gas. The company’s top two executives earned more than $25 million each in 2016 after it went public. XOG’s stock value has since halved, but the state has approved applications from Extraction and its subsidiaries for nearly 400 wells since October 2017; the companies have nearly 700 more permits pending.
For its role as operator in the Windsor fire, Extraction escaped without a fine from the federal or state government. It did, however, reimburse 13 local government entities a total of $140,013.02 for more than 20 hours of firefighting and support.
The Stromberger well pad’s neighbors, still reeling from that night, realize that they have to live with the risks or pay a high price to move. Heidi Jette, a mother of five who lives within a mile of the blast, said it helped pierce the industry’s assurances that everything is safe. “When you realize everything that’s out there, it’s just scary,” said Jette. “There’s so much that gets brushed under the carpet. Everyone is kind of in denial.”
In the weeks following the fire, former Windsor Fire Chief Brady said his conscience bothered him. “I’m scared for the firefighters, and I’m scared for these communities,” he said. He began sharing his views, but said that nobody wanted to hear them. “Between the lack of information and the cover-up,” he told himself, “I’m done.”
He doesn’t know what will happen if things don’t change. However, he does know that he no longer wants to be responsible for Colorado’s neighborhood oil rush. “Is this situation really OK with the citizens?” he wondered.
“If it is, well, there you go.”
Daniel Glick is a co-founder of The Story Group. Previously, he worked for Newsweek for 13 years and has also written for National Geographic, Smithsonian, Audubon, The New York Times Magazineand more than a dozen other periodicals.
Jason Plautz is a journalist based in Denver, Colorado. His work has appeared in Science, HuffPost, 5280, Undark, National Journal, Ars Technica, Industry Dive, and Greenwire. He was a Ted Scripps Fellow in Environmental Journalism at the University of Colorado.
Glick, Plautz, and photographer Ted Wood are members of The Story Group, an independent, multimedia journalism company based in Boulder. TSG produces print and video stories for publications and electronic media, focusing on environmental and resource issues in the West.
Email HCN at or submit a letter to the editor
This coverage is supported by contributors to the High Country NewsEnterprise Journalism Fund.

Infrastructure degradation with sitting of heavy industrialization in Rio Rancho Estates

One of the issues that are not being addressed in the Sandoval County Ordinance is the degradation of roadways. This is a big issue in the county since the City and County conservative council and commission screwed up on bonds and set road repair back 10 years. Our roads and bridges are crumbling.  The Sandoval County Commission will pass the burden on to the taxpayers with the sitting of heavy industrialization of fracking and oil drilling in Rio Rancho Estates and throughout the Albuquerque Basin. On Thursday Evening Nov. 29th 6 pm at the Sandoval County Admin. Bldg 3rd-floor chambers on 1500 Idalia Bernalillo NM 87004  Please make your voice heard.

The hatchet job bad ordinance has been published and this is the first public comment on the issues present in the 2018 version of the "Stoddard" oil and gas - an industry-written ordiance. The siting of over 1000 wells in Rio Rancho Estates means a degradation of impacts and risks with no accountability from the County in the ordinance.

There has been no cost-benefit analysis done on infrastructure degradation, or water use, where the water is coming from and if the county plans to sell water to fracking operators while allowing increased emission and health degradation to the citizens of Sandoval County.  (Rio Rancho Source Water Protection Plan shows a baseline of the water issues in Rio Rancho  Northern and Encinos well collapsed and is being redrilled for $$$ big bucks yet the City is silent on Planning Director David Heil and County Commissioner who made the floor amendment allowance for Thrust Energy and AMREP to profit.) Again the County Commission passed the buck to taxpayers to pick up the tab.  See CGR Homepage for contact info and where to submit comments online and to the commissioners.

The following is a reprint of the degradation that comes with heavy industrialization. Rio Rancho Estates Master Plan  (Map of Area enclosed) was zoned Rural Residential when people bought their property. Now there is a big change without the transparency to residents of Rio Rancho and Rio Rancho Estates and the Abq basin potential risk to health and environment with literally no accountability.

Focus of Fracking in Illinois has been on Selling Benefits

By Brent Ritzel []

On May 31, 2013, the Illinois Senate passed SB1715, the Hydraulic

Fracturing Regulation Act, by a vote of 52-3, the day after it passed the House by a vote of 108-9. The passage of this bill, signed by Governor Pat Quinn into law on June 17, 2013, will open the doors to massive fracking industrialization of Southern Illinois once regulations and the regulatory infrastructure are in place.

Draft fracking regulations, which were drafted without the benefit of a single scientific study, are currently in the public comment part of the process, which ends on January 3, 2014. While the potential benefits of mass fracking industrialization for Southern

Illinois has been frequently highlighted by the oil & gas industry, Illinois politicians, and mainstream media (jobs, lease fees, severance tax revenues, energy independence, etc.), the potential negative impacts of mass fracking industrialization on Southern Illinois have been at best de-emphasized, and at worst completely denied. This politically facilitated industry-driven initiative does not particularly have popular public support either in Southern Illinois, with 40.7% supporting it, 39.7% opposed, and 19.6% no opinion (Leonard, 2013) or nationwide, with 44% favoring increased fracking and 49% being opposed. In the six-month period from March to September 2013 public opposition to fracking grew by 11% (Pew Research Center, 2013).

Fracking’s Liabilities

This shift is at least in part due to increased public awareness of the many potential negative impacts that accompany mass fracking industrialization, which include (but are not limited to): air pollution due to methane leakage and industrial equipment operation; water contamination from methane migration and leaks, spills and intentional dumping of frack fluid; toxic and radioactive fracking flowback and produced water; fracking wastewater disposal induced earthquakes; infrastructure destruction and roadway degradation; increased greenhouse gas emissions; habitat segmentation and ecosystem degradation;permanent destruction of water; social ills including increased crime, drugs,prostitution, homelessness; and the most dangerous workplace in the United States.

Though readily monetizable, general efforts to attach price tags to these various economic, environmental and social ills have lagged immensely behind efforts to project potential revenues from mass fracking industrialization. However, several state departments of transportation have more recently raised important concerns regarding damage to infrastructure, and roadway degradation in particular, due to the immense drilling and fracking-related truck traffic. The issue of roadway degradation touches upon a number of extremely important public interests, including economic concerns (are taxpayers responsible for road repairs and reconstruction in generally rural counties with relatively small road budgets?), safety concerns (dangerous degraded roadway and bridge conditions, along with an increasing gravelization of rural U.S.) and quality of life concerns (dust, traffic, noise and air pollution). As mass fracking industrialization continues to proliferate around the United States, these concerns are starting to become more and more of an issue nationwide.

Scale of Mass Fracking Industrialization

The most comprehensive list of total HVHF (fracking) wells by the state has been compiled by Ridlington and Rumpler (2013), who found that between 2005 and 2012 more than 82,000 fracking wells were drilled or permitted in 17 states, with 22,326 fracking wells being drilled in 2012, 13,540 of which were drilled in Texas. Current industry plans for continued mass fracking industrialization nationwide includes the drilling of one to two million wells over the next 10 to 20 years, with production at each well running for approximately 30 years. Estimated total projected wells for individual states include 100,000 in Pennsylvania (Yeoman, 2013), 50,000 in North Dakota (Scheyder, 2013), and 40,000 for the State of New York (Kennedy & Gallay, 2012). In terms of total fracking wells already drilled, Texas has more than 33,000 wells, followed by Colorado with in excess of 18,000, and Pennsylvania with nearly 7,000 (Ridlington and Rumpler, 2013).

With more than $250 million invested in buying up drilling leases on a half million acres of private land in southeastern Illinois (Yeagle, 2013), the oil and gas industry is planning on fracking 50,000 to 100,000 wells in a 19-county area of state’s southeast corner including Jasper, Crawford, Clay, Richland, Lawrence, Wayne, Edwards, Wabash, Franklin, Hamilton, White, Williamson, Saline, Gallatin, Johnson, Pope, Hardin, Pulaski and Massac Counties (Bieneman, 2013)

High Density of Well Placement

The cause of the greatest harm is not particularly the high volume hydraulic fracturing (HVHF) or fracking technology itself, as it is the scale of industrialization required to engage in this form of fossil fuel extraction. As Columbia University’s Dr. Anthony Ingraffea relates, the problem with shale gas and oil is that it is fundamentally distributed everywhere equally throughout a shale play, which means that the industry has to drill everywhere to access it. Everywhere can mean a five to fifteen-acre drilling pad, with each one supporting six to twelve wells and spacing of one well for every 40 (in the Marcellus Shale Play) to 65-acre (in the Eagle Ford Shale Play) area in a given county to be fracked. With the industry standard of fracking 70% of targeted counties, individual rural counties in southeastern Illinois in the sweet spot of the New Albany Shale Play could conservatively be looking at upwards of 3,500 wells each. This total is based upon one well for every 65-acres, clustered in 6- well-drilling pads over 70% of a county, with an average of 14 townships per county and each township averaging 36 square miles in area (Podulka & Podulka, 2010).

Intensity of Fracking-Related Truck Traffic

The amount of truck traffic required to service each individual fracking well is immense. Podulka and Podulka (2010) estimate that it takes between  1,760 and 1,904 truck trips hauling equipment, materials, and water to build, drill and high volume hydraulically fracture a single well. A typical Marcellus fracked well requires 5.6 millions gallons of water during the hydraulic fracturing of the shale, of which approximately half returns to the surface as flowback and produced wastewater, which is summarily shipped away in tanker trucks to disposal wells. Currently, more than 95% of fracking wastewater produced in the United States is injected into deep disposal wells (Clark and Veil, 2009). Moss (2008) estimates that it can require more than 3,000 truck trips to bring water to and remove waste from a single typical fracking well, with an additional 220 to 364 trips being necessary for hauling equipment, materials, and employees. The New York State Department of Transportation (2011) found that while the drilling phase can require 290 truck trips over a 28 day period, due to total water and waste needs the hydraulic fracturing of a single well can require more than 2,300 truck trips in just a 3 day period. The New York State Department of Environmental Conservation [NYDEC] estimates a single well requires 1,800 to 2,600 total truck drive-bys (truck trips) through all phases, with an 8 well site requiring 14,400 to 20,800 total truck trips.

A comprehensive study prepared by Underbrink (2012) for the DeWitt County Texas Commissioners utilized Equivalent Axle Load Factors (EALF), roughly equivalent to both a truck trip and an Equivalent Single Axle Load (ESAL), to define traffic demand in the Eagle Ford Shale region. A typical country road will last about twenty years when being subjected to about 500 EALF’s per year, requiring reconstruction after a total of 10,000 EALF’s. Underbrink estimates that the total EALF’s in the first year of a single fracking well’s development and production is 2,430, with annual EALF total of 1,250 thereafter, for a total of 26,680 for one single well in production over 20 years.

Known Roadway Degradation Costs Due to Mass Fracking Industrialization

The New York State of Transportation estimated that the total road maintenance costs to mitigate impacts from truck traffic to 40,000 proposed wells across New York State would total as much as $378 million annually. This total is based upon state roads having an estimated cost between $90 million and $156 million per year, and local roads and bridges having an estimated cost between $121 million to $222 million per year (Barth, 2013; Kennedy and Gallay, 2012; New York State Department of Transportation, 2011). Arkansas estimates that the costs from road damage due to fracking truck traffic are $450 million, finding that roads designed to last 20 years require major repairs after only 5 years due to fracking’s constant stream of overweight vehicles ferrying water and equipment to and from well sites (Heinberg, 2013; Rogers, 2013).

According to David Flynn, the Director of the University of North Dakota Bureau of Business and Economic Research, North Dakota allocated nearly $1 billion for infrastructure, primarily for roads damaged by heavy energy-related truck traffic (Gunderson, 2012; White, 2013). Alan Dybing, a researcher at the Upper Great Plains Transportation Institute, states, “Simply put, the roads are falling apart in many cases,” as each new well requires more than 2,000 truck trips, and the massive trucking rigs are demolishing the state’s roadways (Holeywell, 2011).

Pennsylvania Department of Transportation officials reported that in 2010 more than $265 million was needed to repair roads damaged due to Marcellus Shale drilling (Christie, 2010; Dutzik et al., 2012). Additionally, state officials reported that as their rural roads were not designed to withstand the volume or weight of the level of truck traffic, they have sometimes been degraded into impassability (Randall, 2010). By 2013, the state estimated that it would cost $3.5 billion just to maintain the states existing roadway assets, and an additional $8.7 billion for necessary bridge repairs (Rogers, 2013), with fewer than 7,000 existing wells.

An engineering study from the Eagle Ford Shale Task Force regarding anticipated fracking-related truck traffic in DeWitt county Texas indicated that with an estimated 3,250 wells that will be accessed by county roads, the total cost for DeWitt County to provide a road system (331 miles) to meet projected industry and public needs would be approximately $432 million, or almost $133,000 per well (Underbrink, 2012).

The Texas Department of Transportation [TDOT] has estimated that the cost of maintaining the roadway infrastructure degraded by the fracking traffic statewide is $4 billion a year (Heinberg, 2013; Rogers, 2013). That includes $1 billion for farm-to-market roads, $1 billion for local roads, and $2 billion for interstate and state highways (Barth, 2013). TDOT additionally estimates that $2 billion of that total is road damages to the East Ford Shale region of South Texas alone (Remington, 2013). Due to the overwhelming extent and expense of the destruction in that area, the TDOT plans to convert at least 83 miles of asphalt roads into gravel roads in those areas experiencing increased fracking-related truck traffic (Batheja, 2013).


Barth, J. M. (2013). The Economic Impact of Shale Gas Development on State and Local Economies: Benefits, Costs, and Uncertainties. NEW SOLUTIONS: AJournal of Environmental and Occupational Health Policy, 23(1), 85-101.

Batheja, A. (2013). Cash for Road Repair in Shale Areas Proves Elusive. The Texas Tribune. April, 26.

Bieneman, D. (2013). The Fracking Industry and Its Potential Impact on the Illinois Economy. Illinois Department of Employment Security. Economic Information and Analysis Division. July. Retrieved from

Christie, S. (2010). Protecting Our Roads. Testimony before the Pennsylvania House Transportation Committee. June, 10. Retrieved from

Clark, C., & J. Veil (2009), Produced water volumes and management practices in the United States. Rep. ANL/EVS/R-09/1, Argonne National Laboratory.

Dutzik, T., Ridlington, E., & Rumpler, J. (2012). The Costs of Fracking: The Price Tag of Dirty Drilling’s Environmental Damage. Penn Environment Research & Policy Center, Fall.

Gunderson, D. (2012). Oil Boom and the North Dakota Economy. Minnesota Public Radio. January, 4. Retrieved from

Heinberg, R. (2013). Snake Oil: Chapter 5 – the economics of fracking: Who benefits? Resilience. October, 23. Retrieved from

Holeywell, R. (2011). North Dakota’s Oil Boom is a blessing and a curse: The state’s oil boom is bringing unmatched growth and unanticipated problems. Governing the States and Localities. August. Retrieved from

Kennedy Jr., R.F., & Gallay, P. (2012). Letter: The Costs of Fracking. New YorkTimes. April, 2. Retrieved from

Leonard, D. (2013). Poll: Southern Illinois voters divided over fracking. Southern Illinois University Carbondale News Archives. October, 29. Retrieved from

Moss, K. (2008). Potential Development of the Natural Gas Resources in the Marcellus Shale: New York, Pennsylvania, West Virginia, and Ohio. Denver, CO. National Park Service, US Department of the Interior, Geologic Resources Division.

New York State Department of Transportation. (2011). Transportation Impacts of Potential Marcellus Shale Gas Development. Draft Discussion Paper. June. Retrieved from Pew Research Center. (2013). Continued Support for Keystone XL Pipeline. Pew Research Center for the People & the Press. September, 26. Retrieved from

Podulka, S.G, & Podulka, W.J. (2010). Comments on the Science Advisory Board’s 5/19/2010 Draft Committee Report on the EPA’s Research Scoping Document Related to Hydraulic Fracturing (“Report”).

Randall, C.J. (2010). Hammer Down: A Guide to Protecting Local Roads Impacted by Shale Gas Drilling. Working Paper Series: A Comprehensive Economic Impact Analysis of Natural Gas Extraction in the Marcellus Shale. December.

Remington, C. (2013). Differing views on frackingʼs impact. PBS: Public Broadcasting Service. Need to Know. April, 24. Retrieved from

Ridlington, E., & Rumpler, J. (2013). Fracking by the Numbers. Retrieved from

Rogers, D. L. (2013). Externalities of shales: Road damage. Energy Policy Forum. April, 1. Retrieved from

Scheyder, E. (2013). $100M in natural gas being burned off monthly in ND. MSN News. July, 29. Retrieved from

Underbrink, D. (2012). Road Damage Cost Allocation Study. Prepared for the DeWitt County (Texas) Commissioners Court. Naismith Engineering. June, 27.

Retrieved from Cost-Allocation-Study.pdf

White, N. E. (2013). A Tale of Two Shale Plays. 2012 SRSA Fellows Address. The Review of Regional Studies, 42(2), 107-119.

Yeagle, P. (2013). The cost of fracking: What are the risks of tapping Illinois’ trapped oil and natural gas? Illinois Times. March, 28. Retrieved from

Yeoman, B. (2013). The shale rebellion: In Pennsylvania, a band of unlikely activists fights the fracking boom. The American Prospect. Retrieved from

City of RR SWPP City of Rio Rancho Source Water Protection Plan

Rio Rancho Estates Master Plan   Maps of the Rio Rancho Estates Master Plan. See our blog for more Info on What is happening on the Sandoval County Fracking Issue.

Friday, November 23, 2018

SPEAK OUT:Sandoval County Oil and Gas Ordinance-What you can do to Protect Water, Air, Health and Safety

Final Vote and First and Last Public Comment 11/29/18      6 pm 
County Commission chambers 1500 Idalia Rd  Bernalillo NM 87004 

Fracking, pumping brine for fracking 100,000 gas wells on private and public lands, and the fires that Climate Change that holds dire consequences for people in NM. Sandoval County Oil and Gas Ordinance vote it down, revise and vet it and come back with a series of community meetings. Three possible lawsuits pending pay $100,000. They already paid NM Tech for Oil and gas info.
Fracking slated for Rio Rancho Estates with high probability for drinking water contamination and high emissions causing respiratory illnesses and additional road degradation. Commissioner Block and heil setting oil and gas to sue then they will go into private negotiations with industry locking out public altogether. Stop State Capture Stop these commissioners from causing taxpayers more money from needless lawsuits when they can avoid this. 
PLEASE EMAIL and start calling:

"David J. Heil (Sandoval County NM, Commissioner - Chairman, ph 505-252-6085)" <>,
"Dr. James F. Holden-Rhodes (Sandoval County NM, Commissioner, ph 505-235-5628)"
"Jay C. Block (Sandoval County NM, Commissioner, ph 505-252-6218)" <>,
"Don G. Chapman (Sandoval County NM, Commissioner, ph 505-414-6247)" <>,
"F. Kenneth Eichwald (Sandoval County NM, Commissioner - Vice-Chairman, ph 505-252-7412)"

Tell The Commissioners To:

1.) Please contact these commissioners and tell them to make a motion to vote this ordinance down.

2.) Make a motion to hire the FerlicPlanning group and Attorney vet the 2 CWG ordinances because of dueling opinions in science and law.

3.) Call the County on working FOR Thrust Energy, the Oil and gas industry, as stated by Don Chapman in the last meeting Heil is working with Thrust energy to Write the amendments while Ignoring Public health and safety Countywide.

4.) Ask the County to Issue FINDINGS on the Public Comments submitted as to Why they have accepted and rejected items from the Citizens Working Group Ordinances a and the public Comments submitted online: 
Sandoval County Oil and Gas Ordinance Public Comments <>

5.) Ask the County to Read the 4th Assessment on Climate and Issue findings on why they accept or reject this assessment on the ordinance impact to climate and emissions. According to EDF, 80% of emissions in NM are from Oil and Gas Production that created a methane cloud over the 4 Corners the size of Delaware.
Taxpayers money needs investment in a strong ordinance.

Final Vote and First and Last Public Comment 11/29/18      6 pm 
County Commission chambers 1500 Idalia Rd  Bernalillo NM 87004 

It's time to call these people out #ClimateFriday

Wednesday, November 7, 2018

NOV 8 MR-COG Meeting Canceled by Chair and Vice Chair: No Shows Excuses With More O&G Shenanigans

The MRCOG Board Meeting scheduled for tomorrow morning was canceled today by the Chairperson.  We think that these are shenanigans to avoid a vote outcome that would be contrary to what Vice Chair David Heil of the Sandoval County Commission is trying to do with their pro-oil and gas ordinance agenda. The current amendment Heil proposes will destroy the drinking water supply for the City of Rio Rancho. Mayor Hull has ignored our request as to whether he and the City Council approve of what the County is doing by asking for an exemption in the "Ban Fracking District B" and to exempt nearly all of the Rio Rancho Estates.  Heil and Hull are doing the bidding for Thrust Energy who purchased AMREP's  55,000 parcels of mineral rights that may also extend into Bernalillo County. This is what "State Capture"* is and they do not appear to be worried about ethics and or corruption charge.

The MRCOG Chair, Mayor Greg Hull, canceled the meeting because of he and his co-chair Sandoval
County Commissioner David Heil, are suddenly unavailable. Commissioner Heil is also the PZ chair for the City of Rio Rancho. The meeting will reportedly take place in December which could be AFTER the Sandoval County Commission passes an Oil & Gas Ordinance very friendly to fracking and inadequate to the protection of air, land, and water in the region of the Albuquerque Basin. In fact, the City of Rio Rancho is paying over a million dollars to repair one of the main municipal drinking water wells in this area that will be impacted by fracking, despite any groundwater monitoring the USGS can do. These drinking water wells supply water to over 90,000 residents in Rio Rancho and beyond. The Water Authority should be up in arms with this move as well as the citizens in the Upper Middle Rio Grande Basin AKA Albuquerque Basin, that depends on groundwater.

MRCOG_10112018-114 Agenda for 10-11-18

This link is the agenda of the board meeting in October that has the resolution of what MRCOG full Board will consider as a template to a regional solution for oil and gas that will not have adverse impacts to water, air, and public health and safety.  This is also the area that both the City of Rio Rancho and County of Sandoval say in response to IPRA requests that they have no maps on the Route of the Paseo de Vulcan by-pass that will allow trucking traffic for fracking operators. Paseo de Vulcan is now being built without impacts fees to oil and gas operators on the creation and maintenance of the additional roads in the area putting costs on the taxpayers.

If you want to call MRCOG and ask what is going on for yourself, the number is 505-247-1750.

* Definition of State Capture “State Capture" is defined as the efforts of individuals or firms to shape the formation of laws, policies, and regulations of the state to their own advantage by providing illicit private gains to public officials. The key distinction in this typology is not, for example, the size of a bribe nor the level in the political system where bribery occurs, but rather whether the corruption is directed to distort the intended implementation of laws or to shape the formation of the laws themselves.

Tuesday, November 6, 2018

BLM Lease Sale Public Comment for DEC 5th Quarterly Lease Sale: overview of issues impacting Sandoval County Public and Private Lands

The Greater Chaco region is being impacted by the land grab in Northwest Sandoval County and impacting the cultural historic Chaco Canyon. This illustration shows how the oil and gas industry has encroached on the  imposed buffer zone for Chaco Canyon. There is over 89,000 acres in the Rio Chama, Rio Puerco and Rio Grande watershed being impacted by the BLM lease sales and frcking. this is some ofhte most pristine wildlands inthe country being spoiled by the haevy industry blight.  Dec 5th is the date for the quarterly sale BLM has until November 26th to determine whether they will be pulled fromthe the online auction. 
BLM New Mexico State Office                                                       10-28-2018
Attention the State Director 301 Dinosaur Trail Santa Fe, NM 87508
RE: Protest of the Proposed December 2018 oil and gas Lease Sales by the BLM Rio Puerco Field, Farmington District, and Pecos District Offices. 
Farmington District office parcels—
NM-201812-071, NM-201812-089, NM-201812-090, NM201812-091, NM-201812-105, NM-201812-106, NM-201812-107, NM-201812-108, NM-201812-109, NM-201812-110, NM-201812-111, NM-201812-112, NM-2018-113
Rio Puerco Field Office parcels: – 
NM-201812-072, NM-201812-073, NM-201812-074, NM-201812-075, NM-201812-076, NM-201812-077, NM-201812-078, NM-201812-079, NM-201812-080, NM-201812-081, NM-201812-082, NM-201812-083, NM-201812-084, NM-201812-085, NM-201812-086, NM-201812-087, NM-201812-088, NM-201812-092, NM-201812-093, NM-201812-094, NM-201812-095, NM-201812-096, NM-201812-097, NM-201812-098, NM-201812-099, NM-201812-100, NM-201812-101, NM201812-102, NM-201812-103, NM-201812-104
Pecos District Office parcels: – 
NM-201812-039, NM-201812-040, NM-201812-041, NM-201812-043, NM-201812-044, NM-201812-045, NM-201812-046, NM-201812-047, NM-201812-048, NM-201812-049, NM-201812-050, NM-201812-051, NM-201812-052, NM-201812-053, NM-201812-054, NM-201812-058, NM-201812-001, NM-201812-002, NM-201812-003, NM-201812-004, NM-201812-005, NM-201812-006, NM-201812-007, NM-201812-008, NM-201812-009, NM-201812-010, NM-201812-011, NM-201812-012, NM-201812-013, NM-201812-014, NM-201812-015, NM-201812-016, NM-201812-017, NM-201812-018, NM-201812-019, NM-201812-020, NM-201812-021, NM-201812-022, NM-201812-023, NM-201812-024, NM-201812-025, NM-201812-026, NM-201812-027, NM-201812-028, NM-201812-029, NM-201812-030, NM-201812-031, NM-201812-032, NM-201812-033, NM-201812-034, NM-201812-035, NM-201812-036, NM-201812-037, NM-201812-038, NM-201812-042, NM-201812-055, NM-201812-056, NM-201812-057, NM-201812-059, NM-201812-060, NM-201812-061, NM-201812-062, NM-201812-063, NM-201812-064, NM-201812-065, NM-201812-066, NM-201812-067, NM-201812-068, NM-201812-069, NM-201812-070, NM-201812-133
I protest the lease sale of 113 nominated parcels of public lands in New Mexico managed by the Bureau of Land Management (BLM) at the December 2018 lease sale. The Farmington Field Office Resource Management Plan amendment and the Rio Puerco Resource Management Plan revision processes are still ongoing.
A full analysis of the impacts of horizontal drilling and multistage hydraulic fracturing has yet to be addressed. Interior Secretary Zinke deferred the March 2018 lease sale calling for more cultural consultation and admitted that the Greater Chaco region needs more cultural study. But the BLM has made no attempt to survey over 5,400 cultural resources in the region.
Therefore, the BLM is violating the National Environmental Protection Act and the National Historic Preservation Act and is breaking its commitment to consult with tribal governments and impacted communities before these areas are offered for lease. People living in the Greater Chaco region are suffering the impacts of oil and gas exploration, including increased levels of asthma and cancer, air contamination, unsafe traveling conditions, dust pollution, and the desecration of sacred landscapes.
The Navajo Nation, All Pueblo Council of Governors, New Mexico Congressional delegation, New Mexico state legislature, and many NGOs and concerned citizens have called for a moratorium on all new leasing until the BLM has completed management plans that address the impacts of horizontal drilling and fracking. Furthermore, oil and gas companies in the Permian Basin are completing wells at an astounding rate. Now, the BLM is developing a new plan that would open up 97% of all public lands in this area for oil and gas development. Even worse, up to 50,000+ acres of public lands would be sold and privatized.
By going forward with this lease sale, the BLM is failing in its obligation to fulfill the agency’s multiple-use mandate. Over 91% of public lands in the San Juan Basin are already leased for oil and gas, and the Permian Basin is already experiencing the negative consequences of intensive oil and gas extraction. Please cancel the December 2018 lease sale for the listed parcels included in the letter.
We believe that every New Mexican regardless of race, ethnicity, or class has a right to be properly informed and engaged in the decisions regarding our land, our communities, and the future development from economic development to community development. The struggle for land rights continues for Native American, traditional Hispanic and low -income communities.
The current lease sales will bring disparate and disproportional impacts upon the communities with the slated oil and gas lease sales. This is not only troubling; it is an indication of systemic bias bent on industry-mandated extractions. It would not be hard to lodge a federal complaint to address a decades-old systemic discrimination, where more affluent communities are protected and low-income minority communities are left out of the process, or not allowed public hearings or comments through private ordinance jurisdictions further disenfranchising minority and low-income communities. How jurisdictional multi-level government and the oil and gas industry make a decision without stakeholder’s participation in putting profit over people and our land.
Transparency and accountability are foremost in any good functioning government. Governments must actively account for all their actions and take public responsibility for their actions and decisions. Practices and policies are designed to encourage collaboration and co-creation at all stages of the process. This is what good government looks like. There is attention to diversity and inclusion. Women, the disabled, minorities and/or vulnerable are included. Attention includes the use of appropriate languages, technologies, and methodologies to include minorities.
Open data is also a criterion, part of that criteria includes open, complete, primary, timely, accessible, machine processable, non-discriminatory, non-proprietary, license-free data must be made available and in accordance with international standards for publishing data on the Web. In many areas of the state, there are no broadband services available and minorities and low-income residents are more likely not to have computer access in the home. Public information must circulate to reach its full potential, in simple easy ways to understand, in the correct languages, and easy to use and make a comment
In accordance with Title VI of the Civil Rights Act of 1964, each Federal agency shall ensure that all programs or activities receiving Federal financial assistance that affects human health or the environment do not directly, or through contractual or other arrangements, use criteria, methods, or practices that discriminate on the basis of race, color, or national origin.
Any Federal and State funding may be jeopardized by the continued disproportionate and disparate impacts. BLM approval of lease sales holds the federal government responsible for civil rights violations. The federal government is not ensuring against the high adverse human health and environmental effects on minority and low-income populations without implementing a full EIS and/or RMP.
Title VI of the Civil Rights Act prohibits recipients of federal financial assistance (states, grantees, etc.) from discriminating based on race, color, or national origin in any program or activity.
Executive Order 12898, on the other hand, directs federal agencies to identify and address, as appropriate, disproportionally high adverse human health and environmental effects of their programs, policies, and activities on minority populations and low-income populations.
However, a Title VI civil rights complaint may raise environmental justice issues when challenging a recipient’s activity. For instance, if a state agency receives funds from EPA to run a clean air program, that state recipient is legally prohibited from discriminating on the basis of race, color or national origin under Title VI when engaging in clean air enforcement activities.
The EPA, in complying with Executive Order 12898, can also ensure the programs it funds consider disproportionately high adverse human health and environmental effects on minority and low-income populations.
This includes the BLM’s consideration of land use protections for health and safety and best practices. The follow-up actions by BLM to continue the RMP is better placed, and not ignore the RMP and NEPA process. BLM is seen bulldozing the lease sales over the objections of the minority and low-income communities being impacted. These complaints are troubling.  BLM apparently has ignored the health and safety concerns voiced by Tri-Chapter tribal leaders and those living on tribal trust lands and private lands in the current impacted areas. These lack of actions indicate a deep bias against Indigenous and Hispanic communities because their concerns are dismissed and BLM proceeded with Lease sales without following NEPA regulations and whittling away public participation with shorter comment periods, Fewer public meetings. Lost comments. Federal agencies are making it more difficult for citizens to weigh in on environmental rules and actions and are seen as a ‘pattern and practice’.  
Public Participation and Notification The current policy change is not allowing the many minority communities and hundreds of residents, many low-income, the information of the intended sales and the impacts on their property values, health and safety. Public comment shortened from 30 days to 10 days does not allow enough time for a response for working residents to attend informational meetings and respond in the shortened timeframe.
The BLM Lease Sale will disenfranchise community participation in the RMP and EIS process, BLM’s actions that will permanently impact the lives of residents. The expedited comment period;
  1. Will further exacerbate effectual communications due to language barriers that require multiple conferences to ensure that the information is understood and minority and low-income members are able to express concerns to be addressed.
  2. Further, disallows members of the public the opportunity for redress in the Notice of intent (NOI) or in the NEPA process further along in the RMP or EIS process as stakeholders.
Clearly, under the administrative law, the federal agency is required to follow NEPA, Required to give a 45-day comment period, provide information to a community without Broadband Technology in hard copy form. BLM’s duty under the law is to communicate and include the emergency response plan, fire, and road safety requirements, and the healthcare impacts of sitting heavy toxic polluting industry on 50,000 parcels that will contain migrating pollution. BLM Santa Fe office including Farmington and the Rio Puerco offices know full well they are practicing environmental racism without adequate notification (a 10-day commenting period) prior to completing the RMP or EIS federal process.
To allow this BLM must not care to understand the ramifications that there appears to be a violation of civil rights and basic human rights. BLM is obviously out of touch with the reality and gravity of the federal complaint regarding a history of discriminatory practices and violations of the Civil Rights of Hispanics, Chicanos, Native, and African Americans in New Mexico.
LACK OF A HYDROLOGIC STUDY BY THE BLM– the Bureau of Land Management has not completed an independent and official study of the underground water flow and the surface water pathways, into the Rio Chama Watershed, in the proposed lease sale area near the Continental Divide and the community of Lybrook (PARCEL #71).
There is a blatant failure by the BLM to delineate, or portray precisely the Eastern San Juan Basin’s complex hydrology. This area is on the southeastern edge of the San Juan Basin and is adjacent to, or part of, a strong geological uplift area that is characterized by complex folded layers known as the Nacimiento Uplift. BLM has not included watersheds surface and groundwater flora and fauna impacted, in the Lower Colorado (Watershed Yellow area in NW corner map (above) of Sandoval County), Espanola Basin Sole Source Aquifer Designation, the Rio Grande AKA Santa Fe Sub Basin Group, and San Juan Basin. All comingling of the waters between surface and groundwater should be taken into account since there is reliance on groundwater for drinking water source in nearly 80 % of New Mexico. These considerations are paramount in the RMP along with a full EIS of the area, The poisoning of drinking water resources and supplies by the extensive fracking and drilling outside the geological boundary of the San Juan Basin is most likely to destroy groundwater sources.  Both hydrological and geological studies should be made public and evaluated in the RMP before approving and launching online lease sales when they will not accept online public comments.
The BLM has an internal administrative policy that allows this use of outdated documents until a new one is prepared. What about the option of a deferral of drilling until the 2003 Resource Management Plan is properly updated?
CHEMICALS– many chemicals are used in fracking; some known, some not – most are toxic or can be radioactive at low levels. Radium found naturally in lower rock levels would be contained in rocks, even if brought to the surface. However, Radium turns in a radioactive gas called Radon, and that will be dispersed into the air. The Brine water will also contribute to a larger waste stream within the Region that is radioactive agents of uranium and full of lead, arsenic and other heavy metals and minerals and VOCs. This is another waste stream additional to the fracking operations that will impact the region with the use of Sandoval County Raw Brine and injection of highly radioactive produced water.
BLM should take seriously the comments on the RMP tests, survey results, and statements by Tri-Chapter leaders regarding the health and safety impacts experienced by many residents who live on trust lands and private lands. We have not seen any public statement on what the BLM intends to consider regarding the Tri-Chapter complaint. The BLM also will need to consider the migrating pollution plumes of air and water on other jurisdictions. This outreach is crucial to a collaborative citizen engagement, which is key to good public administration.
SEISMIC ACTIVITY– Has not been sufficiently considered in the Watersheds impacted, not in the Lower Colorado Watershed, Espanola Basin Sole Source Aquifer Designation, the Rio Grande AKA Santa Fe Sub Basin Group, and San Juan Basin where there are several known fault lines near our water sources and in the geological formation of the Rio Grande (Nacimiento) Rift. Injection wells are often used to dispose of wastewater and these are known to cause seismic activity. There is also increasing evidence in New Mexico, Texas and Oklahoma that fracking is associated with significantly more earthquakes.
AIR QUALITY AND CLIMATE CHANGE– Flaring is a common practice used in fracking in which huge amounts of hydrocarbons are released directly into the atmosphere. A 3- 12 miles radius near flaring pits has been identified as dangerous to human and animal health. In 2014, scientists working on a NASA study discovered a 2,500-square-mile cloud of methane hovering over the Four Corners region. The BLM seems to dismiss this as being of unknown origin, although recent studies clearly indicate that oil and gas development is the largest source of emissions contributing to this massive methane “hotspot”. Environmental health studies have found impacts of respiratory illnesses up to 10 miles from fracking wells, according to the peer-reviewed studies by Physicians for Social Responsibility.
The BLM attempted to rescind the Obama Administration Rules and now is under court order to address climate emissions from this industry and other environmental and public health and safety issues. We face an onslaught with over 50,000 parcels scheduled for lease sales from oil and gas extraction, fracking and drilling, in the region and the BLM is now required to consider emissions.Case 4:16-cv-00021-BMM Document 111 Filed 03/26/18 Page 1 of 52
  1. RMP Development under FLPMA 
The Federal Land Policy and Management Act of 1976 (“FLPMA”) directs the Secretary of the United States DOI, through BLM, to “manage the public lands under principles of multiple use and sustained yield.” 43 U.S.C. § 1732(a). BLM accomplishes this directive by developing, maintaining, and revising RMPs. 43 U.S.C. § 1712(a); 43 C.F.R. § 1601.0–5(n). RMPs “guide and control future management actions.” 43 C.F.R. § 1601.0–2. RMPs establish “[l]and areas for limited, restricted or exclusive use” and determine “[a]llowable resource uses (either singly or in combination) and related levels of production or use to be maintained.” 43 C.F.R. § 1601.0-5(n)(1)–(2).
BLM should “coordinate the land use, inventory planning, and management activities” for lands covered by an RMP. 43 U.S.C. § 1712(c)(9). BLM should coordinate these activities “with the land use planning and management programs of other federal departments and agencies of the States and local governments within which the lands are located.” Id. BLM obtains this federal, state, and local
cooperation in the RMP process by inviting relevant state and local governments and federally recognized Indian tribes to participate as “cooperating agencies.” 43 C.F.R. § 1610.3–1(b). BLM provides cooperating agencies with “opportunity for review, advice, and suggestion on issues and topics that may affect or influence other agency or other government programs.” 43 C.F.R. § 1610.3–1(c).
RMP approval represents a major federal action that significantly affects the quality of the human environment. 43 C.F.R. § 1601.0–6. RMP approval triggers the preparation of an Environmental Impact Statement (“EIS”) under NEPA. Id. The EIS and RMP shall be “published in a single document” whenever possible. …
Pg 48 Claim #5 An EIS must provide “a full and fair discussion of significant environmental impacts.” 50 C.F.R. § 1502.1. This discussion must be based on “high quality” information and “accurate scientific analysis.” 40 C.F.R. § 1500.1(b). BLM violated NEPA where it failed to justify its use of GWPs based on a 100-year time horizon rather than the 20-year time horizon of the RMPs. BLM also violated NEPA where it failed to acknowledge evolving science… 
The BLM, in the entirety of the 50,000 + parcels is REQUIRED TO DO AN RMP/EIS.  We request that the RMP/EIS cover every Lease Sale that the BLM has scheduled in its entirety before conducting the any online or “in-person” lease sales in December 2018 and beyond.
SOIL RESOURCES– in this high desert climate, the soil can be fragile. Our concerns for the soil in light of heavy traffic from big rigs used in fracking; the traffic and erosion caused by roads and construction of drilling pads; toxic chemical spills and the hauling of water have caused in other counties in the nations that have similar populations. The EPA and State authorities state that in some areas soils are fragile, but this is of “minor concern due to the remoteness of parcels”. In other words, out-of-sight is out-of-mind, if they can’t see it, it doesn’t matter. Surely, this is not the message the BLM wants to be sending.
WILDLIFE– The endangerment of the particular species to the BLM of the specifics species endangers in these areas, and the disruption of migratory patterns, etc. Here is a list of species candidate, threatened and endangered:
      Yellow-billed Cuckoo -Coccyzus americanus -Bird Candidate
      Rio Grande cutthroat trout- Oncorhynchus clarki virginalis- Fish Candidate
      New Mexican meadow jumping mouse- Zapus hudsonius luteus -Mammal Candidate
      Southwestern willow flycatcher- Empidonax traillii extimus- Bird Endangered
      Rio Grande silvery minnow- Hybognathus amarus- Fish Endangered
      Black-footed ferret- Mustela nigripes- Mammal Endangered
      Mexican spotted owl- Strix occidentalis lucida- Bird Threatened
      Plus Migratory birds and animals
Wastewater pits, with indeterminate lining, are another means of disposing of fracking’s toxic sludge.
1.) What are the provisions to keep birds and animals from drinking, or landing in, the open pit storage water?
2.) What assurance that each parcel application has been inspected for threatened and Endangered Species?
DARK SKY–NOISE. The BLM has not inserted from the hours of previous comments, the protection of the night sky and protection from noise in rural settings and is a taking of property values that impact health and safety of its citizens.
CULTURAL RESOURCES AND LANDSCAPES of Indigenous Nations and Tribal Communities are not being appropriately addressed.  Here is a map of Wells in question that has not been adequately addressed that are in violation of the buffer zone. Those wells that breach of the buffer zone should be included in an expanded boundary to include the watershed and boundary edge of the SE San Juan Basin of the Lower Colorado.
Our suggestion is to enter into a formal collaboration with tribal communities on trust lands and those on private lands being impacted by the BLM decision.  Mediation on collaboration is needed because the BLM actions have shown its inability to address the process adequately.
LOW SOCIOECONOMIC POTENTIAL FROM OIL AND GAS– The BLM’s assumption if there is a “No Action Alternative” (no lease option) in the environs of impacted watersheds.  IN OTHER WORDS, IF THERE IS NOT ENOUGH OIL AND GAS TO BE OF ANY REAL COMMERCIAL VALUE, then why move forward without a socio-economic cost-benefit analysis or fiscal impact analysis. The BLM barreling towards oil and gas exploration at grave risks of chemical and mechanical pollution without proper notification and not allowing a longer time for public comments exposes a corrupt closed process that will rubber stamp oil and gas production with FONSI’s.
The INFRASTRUCTURE required for oil and gas production has not been addressed nor has its impacts on the environment including pipelines, compressor stations and gathering lines.  The systemic segregation of a seating of heavy industry in places of pristine wilderness and rural minority communities without a master plan oversight of over 50,000 oil and gas parcels; sets to deceive the public on the scope of the heavy industrial onslaught that BLM is set to approve without giving our communities the right to be properly informed and engaged in the decisions regarding our land, our communities, and the future development from economic development to community development. The struggle for land rights continues for Native American, traditional Hispanic and low -income communities.
The costs of inspections, mitigation, and cleanup including road repair always fall on the taxpayers.  BLM has not informed the public of what costs will burden them when there are not enough inspectors on the current operating and abandon wells. Currently, a well is inspected once in 5 years.  Many of the inspection reports have shown that the inspectors could not have inspected the number of wells in a day they say they had due to time, distance, and issues reported.
INADEQUATE response to issues
Infrastructure concerns – Pipelines, Compressor stations, gathering lines
No regs on road closures
No regs on gathering lines
No emergency response plan was given to community
No public health concerns addressed
No road impact fees
No lighting regulations
Did not require better noise standards
Not enough impact fees on erosion control
No operational restrictions,
No requirements on produced water and injections that may cause seismic activity in known thermal areas
No requirements on the type of Water used
No requirement for additional air monitoring of schools inside and outside air quality.
No Real-time air monitoring for oil and gas particulates including FLIR Cameras to report real-time emission violations on fracking rigs.
HEALTH CONCERNS–According to peer-reviewed studies, (already submitted previously to the BLM), respiratory illnesses from fracking operations healthcare costs would soar upwards to $275,000 a day. Are the BLM administrators aware of types of illnesses that are currently being experienced and the impact on the minority community in order to address these health issues?
BLM’s definition of  “environmental justice refers to the fair treatment and meaningful involvement of people of all races, cultures, and incomes, with respect to the development, implementation, and enforcement of environmental laws, regulations, programs, and policies. It focuses on environmental hazards and human health to avoid disproportionately high and adverse human health of environmental effects on minority and low-income populations.”  BLM appears to violate their own regulations through an insider policy decision that are driven by the current administration’ s disregard for the rule of law, and its a racist implementation of a policy that disproportionately impacts economics, the health and safety of the communities adjacent to and in the parcels being sold.  These are regional impacts. How does BLM plan to address these issues after they commit genocide and ecocide by their decisions?
The observations of citizens regarding the BLM’s disregard for environmental justice issues and the lack of appropriate action to wait for NEPA and the RMP only adds to the disdain for the government of an agency that is supposed to protect the land, water, air, and uphold the public health and safety. Instead, BLM is implementing a policy of genocide and amount of over 50,000+ parcels of lease sales slated surmounts to a crime against humanity.  Additionally, there has been no concern for the emissions that are drivers for climate change that these lease sales would impact in light of the recently released IPCC report.
Please defer any lease sale until the RMP and EIS are complete and BLM has fully addressed the concerns with a formal Environmental justice investigation regarding the disparate impact of the seating of the heavy industry expansion in the region.
Elaine Cimino
Ecimino10 (at)  Citizens Group