With two Oil or Gas Wells already permitted in Rio Grande County by the COGCC, I want to mention a few points that still may not be clear.
1. The main determination of the Rio Grande County Hydrogeologic Study is that the depth the Surface Casement must be to protect water in the Conejos Formation. This is based on “evidence that no highly impermeable, continuous formations exist in the area that would serve to hydrologically separate the underlying petroleum-bearing source and reservoir rocks from the shallower fresh-water aquifers used by water wells in the area.”
2. In January 2011, Allen Davey, Davis Engineering, and Craig Cotten, Colorado Division of Water Resources, suggested to Mark Weems, COGCC lead engineer signing off on both wells, that the surface casements should be approximately 4000 feet deep to protect Conejos Formation water. Mr. Weems offered to work with both men when evaluating the Hughes well permit but has now approved both wells with shallower surface casement requirements of 1100 and 1200 feet respectively.
3. When local water experts and commissioners became aware of this, funding was arranged for the RGC Hydrogeologic Study. January 7, 2013, after months of work and $100,000.00 spent, experts Robert Kirkham and Allen Davey presented their findings with the same determination on protecting Conejos Formation Water. They recommend the surface casement go through the Conejos Formation into the next formation. This is the accurate casement description. The 4000-foot depth is an approximate depth at the two permitted well locations. The actual Study determination is “ through the Conejos Formation” not 4000 feet because the Conejos Formation varies between 2500 feet to >6000 feet in the study area. Following the presentation Mr. Weems said that he likes to work with local experts but never agreed to change casement depths on the permitted wells.
4. The COGCC sets required surface casement depth on applications to drill not local governments so even if County Commissioners want to require the scientifically supported casing depth through the Conejos Formation aquifer, they aren’t allowed.
5. The COGCC already required deep surface casing on a proposed well in the BACA Wildlife area to protect water there. According to Halliburton, a leader in oil and gas development, surface casing depth must go through deepwater aquifers.
6. Justifying a 1200 ft casement on the FLE well, drilling representatives and the COGCC say they don’t think they will hit water during the drill. However, a COGCC report on the Jynnifer well, near the FLE well, produced 2100 gallons of water a day even when out of production. The FLE permit requires extra mud onsite to control water if they hit it. The Wagoneer-Baldridge well near the proposed Hughes well produced water enough to wash out the road. The Hughes permit includes 6-8, 500 barrel tanks for the water it may hit. The Hydrogeologic Study states clearly when drilling into the Conejos Formation you will most likely hit water and the water needs to be protected.
7. FLE representatives say, “ If we do leak oil it won’t go very far”. Because the Conejos Aquifer is like a slow moving, underground river and the hydrogeology is varied and unique, how far contamination will go is a guess at best. It is more expensive for drillers to case at a greater depth. But, once the aquifer is contaminated, the only way to clean the water is to treat it after it comes out at the water well source. We, the end users of the water, will have to pay for the clean up then, not the drillers.
8. Both the FLE and the Hughes applications are for single wells each. But, mineral owner Mr. L.G. Mosley leased 1080 acres to FLE for this well and Mr. Hughes leased approximately 3000 acres from federal, state and private owners. But company representatives and the COGCC maintain that there is no plan for more wells “We need to see if the permitted well is a producer before we move forward with a master plan”. And so impacts from multiple wells cannot be assessed or anticipated.
A gas field is a real possibility in Rio Grande County. The water in the Conejos Formation affects the water of the entire SLV. Protection of the Conejos Formation must be done according to the Hydrogeologic Study and must be set as a requirement by the COGCC for all wells drilled into the Conejos Formation. Please tell your Commissioners, The State and Local Water Authorities and the COGCC to protect your water with the proper surface casement as stated by The RGC Hydrogeologic Study.