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Position Statement on Oil and Gas Drilling in Santa Fe County
The Santa Fe Basin Water Association (SFBWA) is a New Mexico non-profit corporation of individuals, acequia associations, and water associations. Since 1973, SFBWA has sought to protect the rights and interests of existing water users in Santa Fe County and surrounding areas. Our primary concern with oil and gas drilling in the county is to protect water users from the potential pollution of groundwater caused by drilling above, in and through the aquifer. We uphold the principle that groundwater pollution must be detected and remediated before it impacts domestic or municipal wells. In particular, county residents must be protected from consuming polluted water. The draft Santa Fe County Oil and Natural Gas Ordinance falls far short of providing these protections.
To protect the health and welfare of residents from groundwater pollution, it is critical that the county make full use of its zoning powers. Pollution poses the greatest threat to water supplies in rural residential communities; municipal well fields; watersheds; shallow alluvial aquifers; and acequias. These sensitive areas should be protected from oil and gas activity by buffer zones in which groundwater is monitored for pollution. A buffer zone must be wide enough to allow pollution to be remediated before impacting the sensitive area. The draft ordinance must be amended to require the prohibition of oil and gas activity in sensitive areas, and adjacent buffer zones.
The draft ordinance allows active wells (both domestic and municipal) to be used as the first detection point of groundwater pollution, and only requires water samples to be analyzed on an annual basis. This means that a well user could be consuming toxic pollutants for up to one year before the pollution is detected in a tested sample. We find this to be unacceptable. In addition to sampling water in active wells, we assert that sentinel wells must be used to monitor the approach of pollution towards active wells. For the same reasons, sentinel wells must also be used in buffer zones to protect all other sensitive areas. Sentinel wells may be abandoned (water) wells, or specially drilled test wells. The draft ordinance must be amended to require that sentinel wells be used as the first pollution detection point for sensitive areas.
Directional drilling and fracturing can impact the surface and subsurface in a wide region around the well head. Pollution can occur anywhere within the impacted region, despite efforts to contain oil and other toxic chemicals. Once pollution occurs, it can be carried in the direction of groundwater flow. Sentinel wells must be placed outside the impacted region and before sensitive areas downflow. Pollution in groundwater flow may pass the location of a sentinel well in the interval between one test and the next. Pollution may also continue moving towards a sensitive area during the period when remediation is planned and executed. Therefore, the width of the buffer zone must be at least the distance groundwater can flow in the test interval and remediation period combined. The flow rate and direction of groundwater at the drilling site should be determined by a qualified independent hydrologist. The draft ordinance must be amended to require the proper placement of sentinel wells and the minimum width for the buffer zone.
The risk of groundwater pollution from an oil or gas facility extends beyond the termination of pumping. Pollutants may continue to permeate slowly through small subsurface fractures for many years before showing up in sentinel wells. During this period the facility owner should be financially responsible for monitoring and remediation. For legal purposes, it will be necessary to specify a cut-off date for this responsibility. The cut-off date for a particular oil and gas facility should be determined by a qualified independent hydrologist from consideration of underground structures and groundwater conditions. The draft ordinance must include provisions for continued monitoring and remediation after a facility ceases operation.
In addition to the pollution issues described above, SFBWA is also concerned about the large quantities of water that are required across the whole lifecycle of an oil and gas facility - including drilling, fracturing, operating, recovery, remediation, reclamation and restoration. Particularly if substantial oil and gas deposits are located, the facility owners may need to acquire the rights to, and availability of, extremely large volumes of water. Water resources are already fully allocated within the county, and aggressive conservation measures have already been adopted (particularly in the city). The draft ordinance must require a project application to demonstrate at the outset that the necessary water rights (with available wet water) have been obtained, and that water conservation measures have been specified, across the whole project lifecycle
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