Why We Believe the San Luis Valley Must Remain a NO-GO (No Gas and Oil drilling) Zone!
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Figure 1. Wetlands in the Baca National Wildlife Refuge; Sangre de Cristo Mountains in background.
I have always told people that the San Luis Valley is more than home to me. It is a spiritual place unlike any other on earth.
Senator Ken Salazar (Valley of the Dunes)
Our Spectacular and Unique San Luis Valley
We volunteers of Water Watch Alliance (WWA) and residents of the San Luis Valley know that this valley is unique, sacred, and irreplaceable. There is no other place like this in all the world. It is amongst North America's highest and largest agricultural valleys, with elevations ranging from 7,500 to over 8,000 feet. Although it is true desert that gets less than 8 inches of precipitation a year, the San Luis Valley is underlain by perhaps the largest reservoir of fresh groundwater in North America. Our abundant groundwater gives rise to many ephemeral lakes, wetlands, springs and flowing wells that support considerable irrigation in the valley. The valley is surrounded by spectacular, alpine mountains. The rugged, spectacular Sangre de Cristo Range on the east side of the valley includes nine peaks over 14,000' and 36 peaks over 13,000' elevation. The San Juan Mountains to the west include unique volcanic formations, as seen in Penitente Canyon (a favorite of expert rock climbers) and the Wheeler Geologic Area. The San Luis Valley is home to almost every kind of wildlife in the west (including elk, mule deer, antelope) and has numerous natural hot springs. It has a herd of buffalo. It contains the most spectacular and highest sand dunes in North America in the Great Sand Dunes National Park and Preserve. Just east of the Sand Dunes National Park are some of the oldest archaeological sites in North America, dating back some 11,500 years. Indeed, archaeological sites in the Valley probably span virtually all the nearly 500 generations from the time of the Paleoindians to the present. For Native Americans, including the Puebloan, Ute and Navajo tribes, this valley is the world's single most sacred place and Mt. Blanca is the most sacred mountain. And over the last few decades, numerous Tibetan Buddhists and Tibetan masters have come to live in this valley because because of it's pristine qualities and profound silence.
Figure 4. Challenger Peak from the Baca Grande community.
Today, however, two giant energy corporations, Lexam Explorations, Inc. and Conoco-Philips, are planning to drill three 14,000 foot exploratory gas wells on Colorado’s newly-formed Baca National Wildlife Refuge (BNWR). The three proposed wells are located on sensitive wetlands within 2 miles of the Crestone/Baca community and the new Great Sand Dunes National Park and Preserve (Figure 3). Lexam officials believe there is potential for discovering billions of dollars worth of natural gas in the San Luis Valley. Their seismic studies show San Luis Basin“remarkably similar” to those of the nearby San Juan and Raton Basins, about 100 miles to the southwest and 60 miles to the southeast, respectively (www.lexamexplorations.com). (However, whereas the surrounding basins are Laramide structures, the San Luis Basin is part of the much younger Rio Grande Rift and hence, is geologically quite different, see page 3). The San Juan and Raton Basins have already produced trillions of cubic feet (tcfs) of natural gas; and most production there is from coal-bed methane (CBM) gas, which is significantly messier and more polluting to mine than "conventional" natural gas.
Thus, if Mesozoic source rocks are preserved in the San Luis Valley, as
Lexam/Conoco-Philips hope, there is a significant possibility that
formations in the San Luis Valley would also contain coal beds yielding CBM gas.
Although Lexam acquired the mineral rights beneath the BNWR through a series of suspicious deals (see WWA Page 2), we are certain the wealth of the "surface estate" and water resources in our San Luis Valley
far exceed that of any conceivable amount of gas or oil that could be
recovered here. Indeed, it is impossible to place a monetary value on
the aesthetic beauty and majesty of the "surface estate" here and of the freshwater aquifer that underlies the San Luis Valley. This aquifer is considered one of the largest freshwater aquifers in North America. Because gas drilling operations here would contaminate our air and water and would destroy the pristine quality of our "surface estate," we are convinced that protecting the special values and qualities that drew us to this special place requires that we say NO-GO (NO Gas and Oil) drilling operations should be allowed to destroy our pristine and beautiful San Luis Valley!
What would be the effects of major gas operations in the San Luis Valley if Lexam's exploratory wells "hit" natural gas?
1) Contamination of the priceless aquifers. The BNWR overlies one of North America’s largest and most valuable freshwater aquifers. This aquifer includes an estimated 140+ million acre-feet of water (Pearl, 1974) that is potentially worth many hundreds of billions of dollars! Surface and subsurface water in the northern San Luis ValleyRio Grande River, which is allocated to three states (Colorado, New Mexico, and Texas) as well as MexicoRio Grande Compact. Lexam is proposing to drill it's three first wells (Wells 5, 6, and 7) directly over sensitive wetlands where the Willow, Spanish and Cottonwood Creeks widen onto the Valley floor.
For this reason, and based on the track record of gas drilling activities elsewhere, there is a virtual certainty that the processes of drilling, hydraulic fracturing, "cavitation," pumping "produced" water out of the aquifers, as well as seepage and evaporation from toxic surface ponds, would contaminate both surface water and the aquifer. Contamination of the aquifer could have profound negative impacts on agriculture in the valley as well as downstream users throughout the Rio Grande Basin.
According to Dr. Theo Colborn of TEDX (The Endocrine Disruption Exchange, (www.endocrinedisruption.org), of the 245 the chemical compounds commonly used in drilling and hydraulic fracturing, 91% have adverse health effects and there is no information on the other 9%. Fracturing operations may require up to a million gallons of fluid per well (Gwen Eifle, Oil and Gas Accountability Project, or OGAP, 2005, www.ogap.org). Some of the most toxic chemicals include B-TEX (benzene, tolumene, ethylbenzene and xylene) which are carcinogenic, as well as methane, diesel fuel, hydrogen sulfide, heavy metals, VOCs (volatile organic compounds), formaldehyde and PAHs
(Colborn, 1997). Many of these chemicals have been found in
contaminated wells and in grab samples for air quality near gas wells
in Colorado and elsewhere in the west (OGAP, 2005).
According to OGAP’s Gwen Lachelt, due to the current industry-friendly administration, every chemical used is considered propriety by the gas and oil drilling industry and this industry is now legally exempt from following the Clean Water Act and other laws that limit and regulate use of toxic chemicals in the U.S. Drillers also use propylene glycol (an antifreeze) on well pads. When ingested, this chemical is fatal for animals. Hence, pad areas always need to be fenced. However, in practice, they typically are not fenced (OGAP, 2005). Even closed-loop drilling systems utilize open evaporation pits, which often contaminate surface water, poison creatures, and add toxic pollutants to the air.
The Colorado Oil and Gas Conservation Commission (COGCC) has issued permits to Lexam specifying that they only need to use double concrete casing for the upper 3000’ of the 14,000’ wells. Clearly, there is great potential for contamination of the confined aquifer if the well hits gas and oil and if the casing leaks in the future. If coal-beds are encountered and Coal-Bed Methane (CBM) gas is extracted, contamination of the aquifer becomes a certainty. It is well-known that cement casings lose their integrity over time and can become a source of groundwater contamination for decades and centuries (OGAP, 2005). It is also commonly known that one quart of oil can contaminate up to 250,000 gallons of water. In addition, methane gas itself is toxin and includes benzene, a known carcinogenic. In addition, when methane concentrations in water are 10mg/l or higher, that water is ignitable and can cause houses and other structures to explode. Thus, the bare minimum of protection of the aquifer would require double concrete casing extending the entire depth of any well from source to surface- as well as a complete ban on production of CBM gas and the use of "cavitation" and hydraulic fracturing enhancement techniques.
Water from the Rio Grande River is allocated to three states (Colorado, New Mexico, and Texas) and Mexico. Because of the aridity of the Rio Grande Basin, the recent drought has seriously exacerbated water shortages in these basin states. Hence, the potential degradation of water in our San Luis Valley aquifers could severely affect the quality of surface water available to downstream users in the future. Thus, we hope that the Rio Grande Water Conservation District, ranchers, and other downstream stake holders will become more involved in this issue in order to help protect their water supplies in the future.
there is no statutory regulation in Colorado that requires gas or oil
companies to pay for damage they do to aquifers.
2) Air pollution. The chemicals used in natural gas development are dangerous to the health of humans, animals, and plants who happen to live near the drilling operations. Emissions from drilling pads emit carcinogenic toxic chemicals into surrounding public lands and communities. Ground-level ozone is the #1 cause of asthma and causes degenerative health problems for humans, wildlife, plants, and agricultural crops. It is heavier than air and sinks into low-lying areas. Because ground-level ozone is produced at every gas well pad, each well needs a special permit to exceed air quality standards required by the state and U.S. government. In fact, the air pollution emitted at each pad would exceed the minimum air quality standards set by the Clean Air Act. In addition, after gas comes to the surface, a dehydrator is used to separate the gas from the condensate. This process involves a complex of volatile carcinogens (VOC or volitile organic compounds), most notably B-TEX, which includes ethyl benzene, xylene, and tolumene and fracking fluids. In addition, PM-10 (airborne particulate matter less than 10 microns in diameter) has serious negative impacts on human health and crops.
In order to monitor air quality in the BNWR, it would be necessary to coordinate monitoring activities with many agencies, including the Colorado Air Quality Control Commission, Colorado Water Quality Control Commission, Colorado Division of Wildlife, Local county weed programs, Bureau of Land Management, and Saguache County. Preliminary baseline studies on present air quality would also have to be made prior to any drilling activity whatsoever. A Colorado Bill (2004) limits ground level ozone that comes off condensate tanks Colorado Air Quality Commission).
A Laundry List for Chemical Warfare
3) Health Concerns. Based on anaylses of data reported in Chemicals Used in Natural Gas Development, Dr. Theo Colborn found that 49% of the chemicals used can cause skin/sensory organ toxicity, 47% can cause respiratory problems, 47% are neurotoxins, 43% are gastro-intestinal/liver toxicants, 38% are kidney toxicants, 33% are carcinogenic, 29% are cardio/vascular/blood toxicants, 27% are immune system toxicants, 25% are developmental toxicants, and 13% are endocrine disruptors. And 20% are biocide products that kill all life. Of the 13% chemicals that are soluble in water, 72% are neurotoxicants, 61% are gastro-intestinal/liver toxicants, 61% are reproductive toxicants, 61% are skin and sensory organ toxicants, 56% are respiratory toxicants, 50% are kidney toxicants, 39% are cardiovascular toxicants, 28% are endocrine disruptors, and 22% are wildlife toxicants. And of the chemicals used that vaporize, 66% are neurotoxicants, 60% are gastro-intestinal/liver toxicants, 52% are respiratory toxicants, 45% are kidney toxicants, 43% are reproductive toxicants, 37% are cardiovascular/blood toxicants, 33% are carcinogens, 27% are immuno-toxicants, 14% are endocrine disruptors, and 4% are wildlife toxicants (www.endocrinedisruption.org). Indeed, Professor Clay Bridgeford, an ex-military man living in Crestone, Colorado, remarked that the chemicals used amount to "a laundry list for chemical warfare."
4) Impacts upon wildlife. Rare flora and fauna in the San Luis Valley, some found nowhere else in the world, include, the Great Sand Dunes tiger beetle, the giant sand treader cricket, the Rio Grande cutthroat trout, the Rio Grande sucker, the Rio Grande chub, the southwestern willow flycatcher, and the slender spiderflower. The Rio Grande sucker, found on the BNWR in a 2006 survey, is listed by state of Colorado as an endangered species. Other species found in the area include the bald eagle, sandhill crane, pronghorn antelope, elk, mule deer, bighorn sheep, mountain goats, mountain lion and black bear. Full-scale gas development entails production facilities would require the construction of staging areas, airstrips, drill pads, and hundreds of miles of pipelines and roads. The Wilderness Society notes: "These developments fragment wildlife habitat into increasingly smaller and less usable areas, until animals can no longer survive in these areas at all" (Too Wild To Drill, Executive Summary, The Wilderness Society).
Wildlife biologists consider the newly-formed Great Sand Dunes National Park and Preserve to be a B-1 Site. This means that as a critical habitat for rare and threatened species, it is irreplaceable.
There are six or seven endemic species of insects that are found in
this Park that are found nowhere else in the world. These insects are
there because of the sand. And the sand is there because of the water
in the Valley aquifers. And the Great Sand Dunes National Park is located within 2 miles
of where Lexam wants to drill their exploratory wells. There are 30
B-1 sites in Colorado. Although there are no sites listed as B-1 in the Baca National Wildlife Refuge, there are many, many sites classified as B-2 and B-3, which also constitute critical habitat and which need federal protection.
5) Noise, light, and dust pollution.
The proposed drill sites are located about 1.5 to 2 miles west of the
Baca residential community, and hence, would produce significant noise,
light, and dust pollution that would degrade the quality of life for
members of the Baca community as well as the wildife habitats on the BNWR.
In addition, heavy truck traffic associated with various aspects of the
operation would significantly increase noise and dust. Compressor
stations, if built, would produce noise as loud as a jet airliner
“24-7” (24 hours a day, 7 days a week). Crestone/Baca includes many
spiritual groups and individuals who have moved here because of the
pristine beauty of nature and the profound silence that the area
affords. These spiritual groups would be adversely impacted by the
drilling operations, in particular.
6) Damage to local roads due to use of heavy vehicles. We can expect that heavy traffic by heavy vehicles would result in damage to local roads and an increase in traffic accidents. Would Lexam or Conoco-Philips pay for the damage their operation causes to our existing infrastructure?
7) Infrastructure requirements. There is currently no infrastructure in the San Luis Valley or the BNWR that would support gas production. Building such an infrastructure would require construction of gas pipelines, gas compressors, innumerable gas well pads, extra roads, etc. The synergistic effects of these operations would significantly degrade the pristine quality and quality of life in the San Luis Valley and would certainly destroy the BNWR as a pristine and protected habitat for wildlife. Oil spills, truck crashes and highway deaths resulting from those crashes would be highly likely.
8) Boom-town effects. If Lexam were to strike gas, we could expect a suite of highly disruptive “boom-town effects” would accompany the gas boom. Other communities which have been subjected to this process have experienced varying degrees of chaos, social upheaval, negative impacts on schools, emergency services, crime rates, increased use of drugs and alcohol, etc. And typically, after gas companies create problems, local tax payers have to pay the cost of the damages, road repair, etc. This pattern repeats in many ways, with local communities paying for extra schools, roads, etc. that the gas industry requires in order to function. Meanwhile, what percentage of profits are shared with local counties and communities? Often, little to none.
9) Damage to local cultural, spiritual and native American values. The NEPA (National Environmental Policy Act) process requires that the US Fish and Wildlife Service try to understand the cultural values of the Crestone/Baca community. Our community is comprised of numerous spiritual communities and individuals committed to the preservation of pristine nature, developing sustainable living models, and pursuing spiritual retreat in one of the world’s truly magnificent natural settings. Every fall, Crestone sponsors an energy fair, which displays alternative and renewable means of creating energy. And the Baca community has become home to many international spiritual centers and spiritual masters of various faiths including Carmelite Catholics, Zen Buddhist, Tibetan Buddhists, Hindus, and others. These diverse cultures, faiths, and retreat centers provide the sanctuary and retreat opportunities that both residents and visitors seek.
The San Luis Valley itself has long been acknowledged as one of the great spiritual centers of the world. It is commonly claimed that since pre-historic times when several Native American nations would gather in this “Bloodless Valley,” bloodshed
between peoples was not permitted. And Mount Blanca, at the southern
end of the Valley, is one of the four sacred mountains of creation for
Hopi, other Puebloan, and Navajo Indians. In practice, both the San
Luis Valley and Mount Blanca are recognized as cultural/spiritual sites
of great importance to numerous Native American groups.
Finally, we believe that our cultural identity, our “sense of place,” and the continued health and integrity of our human and natural ecosystems is far more important than the potential for short-term, windfall profits on the Toronto stock exchange that Lexam covets. In practice, these “wild-cat” speculators seek not only to exploit and exhaust (gas and water?) resources that make up our "commons," they also mine their own investors. Like most foreign corporations, they have no commitment to the future of our community or our environment. And the fact that they are from Canada means they have little or no understanding of or regard for the values of our community. To us, national security or “homeland security” means protecting our clean air and water, our healthy environment and communities, safe neighborhoods, healthy food, etc. Certainly, our idea of prosperity is not compatible with a quick “wild-cat” gas play. And we also believe than any exploratory drilling on the BNWR is completely incompatible with the mission of that wildlife refuge.
10) Problem of accidents and limited access. Our Crestone/Baca community has the serious problem of very limited access. There is only one road in and out of our community- the County T road. If there were an accident or fire associated with gas operations, there could be a real disaster here. Therefore, Lexam should not be allowed to drill on the BNWR until alternative escape routes have been identified and engineered for our community.
11) Threats to archaeological sites on the BNWR. World-class archaeological sites dating back some 11,500 years have been found on the nearby Great Sand Dunes National Park and Preserve. And since pre-historic peoples typically camped near seasonal wetlands and local water sources, which are extremely abundant on the BNWR, there are probably countless archaeological sites and artifacts on the BNWR that have not yet been discovered, recorded and catalogued. These sites need to be protected for posterity, not destroyed for short-term greed and profit.
One Inspector for Every 3,625 Wells!!
12) Inadequacy of inspections. Whereas the number of oil and gas wells in Colorado has climbed 30% to 29,000 since 2000, COGCC inspections
have not kept pace. The state has just 8 inspectors, or only one for
every 3,625 wells! Therefore, we believe that there would be no
responsible monitoring of any exploratory or production gas wells. Peggy Utesch, a member of the Grand Valley Citizen’s Alliance
in Garfield County, stated: “We know that every day there are accidents
and incidents in the field- just look at the commissioner’s reports.”
Based on the track record of the COGCC, we at WWA do not believe they have the capability to adequately monitor drilling activities on the BNWR.
13) Absurdity of $10,000 (or even $10 million) bond. Given the potential value of water stored in San Luis Valley aquifers (probably in the hundreds of trillions of dollars!), a more adequate bonding amount might be $100 trillion. The amount now posted ($10,000) is a cruel and sick joke. Even a bond of $100 trillion would be inadequate. Once the water is contaminated, it is unusable.
14) All this for one or two weeks of electricity and space heating for America?! If comparisons with other magnificent areas in our Rocky Mountain West are extended to this region, it is most probable that the potential total amount of gas that could be recovered here might be less than the U.S. consumers of electricity would go through in two weeks! Are we willing to sell off the future well being and prosperity of the over 10 million people in the Rio Grande Basin who depend upon the purity and abundance of water in the headwaters of the Rio Grande Basin for two weeks worth of electricity?
Pearl, R.H., 1974, Geology of Ground Water Resources in Colorado. Denver: Colorado Geological Survey, Department of Natural Resources.