Outcome of Comments to Bureau of Land Management

Once again activism in monitoring gas and oil activities in Huerfano County has been recognized.  OXY has been made aware of our vigilance. 

We have located the Environmental Assessment for the OXY Sheep Mountain wells 7-15-I and 8-15-D.  It was signed on September 16, 2014.  Our comments are addressed on page 3 and as Appendix A at the end of the Assessment.

Environmental Assessment Sheep Mountain 7-15-I, 8-15-D 

The two wells have a status of XX with the Colorado Oil and Gas Conservation Commission (COGCC).  XX signifies that "APPROVED PERMIT TO DRILL WELLBORE: NOT YET REPORTED AS SPUD; INCLUDES EXPIRED PERMITS."
"Reported as Spud" would mean drilling has commenced.

Some good points were made to the BLM within a time-frame of less than one week to prepare comments.  As a rule, we are learning that regulatory agencies and operators do not communicate effectively with the public.  As in this situation where the receipt of comments were never directly acknowledged nor was the outcome sent to us.  We had to dig it up on the BLM website in something called the NEPA Archive. NEPA ARCHIVE 

Thank you for signing the Green Rockies Emerging Ecology Network (GREEN) petition.  It was an ad hoc or spur-of-the-moment response to an opportunity to comment in a matter of days.  Perhaps we can go GREEN again should the need arise. 

Our Comments to Bureau of Land Management

Mr. Aaron Richter

Environmental Assessment Preparer

United States Department of Interior

Bureau of Land Management

Royal Gorge Field Office

3028 E. Main Street

Canon City, CO 81212
arichter@blm.gov

Joseph Edes

Spokesperson

Green Rockies Emerging Ecology Network

P.O. Box 1095

La Veta, CO 81055

719-742-3110
dextergardener@yahoo.com

August 22, 2014

Dear Sir:

In the matter of public comment on Sheep Mountain Unit Wells 7-15-I and 8-15-D, we submit the following. Because the CO₂ sources under consideration are Federal land, we have expectations of Federal leadership in addressing emerging issues of changing demographics, land use, and greenhouse gas climate change.

Background

With only a few exceptions, Sheep Mountain Unit activity has been fairly routine and innocuous for about three decades. There was an incident early on where a well blow-out was out of control, and there has been extensive litigation over royalties paid to mineral rights lessors. The most visible impact is the paint scheme on the buildings, which makes them stand out against the darker background in this nearly pristine valley.

 

Sheep Mountain Unit and associated pipelines also have been a significant source of ad valorem tax revenues and mineral lease royalties in Huerfano County.

The Sheep Mountains are intrusive volcanic formations that erupted through folded and fault-weakened zones immediately east of the Sangre de Cristos mountain range about 25 million years ago. Acidic magma encountered sedimentary limestone and formed CO₂ gases, which were entrapped and sealed beneath the Sheep Mountains.

Three Main Concerns

We have three main concerns with this Environmental Assessment draft and the Finding of No Significant Impact draft.

1. Cumulative Impact

Our concerns arise from the world-wide recognition that greenhouse gas emissions and accumulation in the atmosphere are an imminent and future threat to human health and safety. First, we observe in this assessment the argument often repeated that the impact of this project is insignificant on all levels. Internet satellite images of gas and oil well pads and access roads in neighboring Las Animas and other Colorado counties, and in neighboring states, attest to the alarming cumulative impacts from denudation of surface vegetation and habitat. It is unacceptable for the Federal government to dismiss as insignificant the addition of yet another two wells in the march to mass despoliation of the earth's surface.

2. CO₂ Extraction Consequences

Second, the extraction of CO₂ from these 25-million-year-old sources in effect is letting the genie out of the bottle, full of unforeseen consequences. The boons of Enhanced Oil Recovery are countered with the burdens of produced saline water and attendant difficulties of placing these waters and CO₂ gas back beneath the surface. Produced water injection wells have caused earthquakes in Las Animas County, Oklahoma, Texas, and Ohio, for instance. Also problematic is the chronic need for monitoring of CO₂ sealed beneath the earth's surface and the potential acid corrosion of cement casings.

3. Inadequate Factoring of Social Costs

Third, we observe in this Environmental Assessment an inadequate factoring of the greenhouse gas impacts of the petroleum produced using Sheep Mountain CO₂ for Enhanced Oil Recovery. On June 27, 2014, Denver Federal District Judge R. Brooke Jackson pointed out the failure of Federal regulators to consider the social costs of atmospheric carbon in their environmental review of the West Elk coal project. Judge Jackson ruled that despite the claim by Federal regulators that, “Predicting the degree of impact of a single emitter of (greenhouse gases) may have on global climate change, or on changes to biotic and abiotic systems that accompany climate change, is not possible at this time. (and) As such... the accompanying changes to natural systems cannot be quantified or predicted at this time.”

“But such a tool is available,” Judge Jackson countered. It is “the social cost of carbon protocol... expressly designed to assist agencies in cost benefit analysis...” Judge Jackson's ruling is 36 pages, and in our view, any Environmental Assessment henceforth including this one should use the social cost of carbon protocol to adequately address pressing environmental problems.

Document Errors

1. The Finding of No Significant Impact draft seems to erroneously imply that both wells at the surface are on private (fee) land. This is contradicted by the map of Well 8-15-D in the Bureau of Land Management Environmental Assessment and on the Form 2 application to drill filed with the Colorado Oil and Gas Conservation Commission. The significance of this is that Well 8-15-D is entirely on Federal land and, as such, the Bureau of Land Management can take the lead using this particular well as an example by applying the No Action Alternative.

2. We would also comment that the Bureau's assertion, “...that under this alternative the facilities would still be constructed on entirely private property and the impacts...would be the same.” This is a morally unsupportable position. Two wrongs do not make a right.

3. Another error is the characterization of the land surrounding Sheep Mountain unit as having a, “...high degree of alteration in the form of agricultural fields and roads.” Aerial photos and landscape photos do not support this statement. In the photo below, to the left we do see a high degree of alteration, but to the right in the vicinity of Sheep Mountain Unit, no such alteration appears.

In fact in the next photos we can see the reality of this nearly pristine and beautiful area in question.

New Demographics

Finally, while the Sheep Mountain CO₂ Unit began somewhat innocuously in a traditional grassland ranching setting, much of the scenic ranch land of Huerfano County has been subdivided into smaller holdings 35 acres or larger. The result is a clash between open range old west mindsets and the new reality, which is a consequence of real estate sales and sub-division. New land owners who have come here for quality of life reasons find themselves up against the contradictions of split estate surface and mineral rights clashes. Whether there was a lack of due diligence by buyers or lack of ethical disclosure by sellers, the situation is becoming critical with demands for local control of impacts of industrial oil and gas development.

Again, we appeal to the Federal government to take the lead in adjusting to the new demographic realities in scenic and rural Colorado. Newcomers have enriched the area by purchasing land, building houses, starting small businesses, serving tourists, and employing tradesmen or becoming tradesmen themselves. They have come here to experience quality of life and to enhance quality of

life. What they do not want to experience is the fate of neighboring Las Animas County. In the photo below we see some of the 6,000 plus well pads and service roads (inset) that pepper that county's land, surround the Spanish Peaks State Wildlife Area, and abut the Spanish Peaks National Wilderness Area.

 

Aquifer Concerns

Also, the proposed Sheep Mountain Unit wells will be drilled through multiple underground folds of sandstone aquifer. If well casings breech, the aquifer is at risk. Sandstone outcrops adjacent to the Huerfano River attest to the proximity of the aquifer in question. The consequences of a well casing breech are incompatible for present and future needs for pure aquifers.

 

 

National Scenic Treasures

As can be seen in the Sheep Mountain Unit Environmental Assessment map, the unit is in the midst of several national wilderness treasures. For this reason, it is even more appropriate and in keeping with the emerging realities that these wells be denied.

Summary

Sheep Mountain CO₂ production unit is in the cross-hairs of global climate change. Were the CO₂ being obtained from the smokestacks of coal burning electric generation plants, then at least the amount of CO₂ captured would mitigate the CO₂ released when Enhanced Oil Recovery petroleum is burned.

However, what we see is the taking of naturally sequestered CO₂ deep beneath the earth and running it through pipes, pumps, and valves and back into oil fields where the retention of the CO₂ is less sure. And when the recovered oil is burned even more CO₂ is produced. Thus, we have a multiplying of CO₂ entering the atmosphere with consequences thereof.

In light of these comments and of worldwide calls for positive climate action, we suggest and request that the extraction of all CO₂ on Federally owned lands in Huerfano County be denied and otherwise curtailed. A small beginning perhaps, but it is the right thing to do.

Thank you,

Joseph Edes and the Green Rockies Emerging Ecology Network

Following to be added to final submission:

Below are co-signers gathered since August 16, 2014, which is two days after we were notified in the La Veta, Colorado Signature newspaper of this comment deadline.

GREEN ROCKIES EMERGING ECOLOGY NETWORK (GREEN) Welcome Aboard

Petition Background

CO2 EOR is a tertiary method of oil recovery. The secondary method is forcing oil upward by water flooding. After EOR, oil companies attempt to retain the CO2 beneath the earth in a process called Carbon Capture and Storage (CCS). The current trend is to gain Federal tax credits for CCS, and in some cases, plan to trade carbon storage credits for cash. CCS is a complex and difficult process due to the corrosive effects of CO2 on cement casings, metal valves, and pipes. Tell the BLM to leave the CO2 in the earth where it has safely existed for 25 million years, instead of using it to produce even more oil, which in turn creates even more CO2 greenhouse gas when the oil is used. Thank you for aiding Green Rockies Emerging Ecology Network (GREEN) in our efforts to protect the environment.