The comment process available to the public about public lands is ignored by many and inappropriately used by others who simply complain rather than contribute to an informed conversation. I thought I’d share the following letter on a current issue because not everyone has time or the interest to attend information meetings. The local BLM staff throughout the process have been professional, patient with the many citizens who come for the first time and ask questions already answered in many prior meetings, and themselves are concerned about both properly managing their duties while they share a value of our natural resources, like others of us who live in the San Luis Valley.
This letter is a comment on the preliminary oil and gas drilling analysis for the proposed exploratory oil and gas well planned by the Dan A. Hughes Company. I am grateful for the services performed by the local BLM offices to keep the public informed of our rights and opportunities regarding these land use permits. I understand that the BLM operates under the directive to preserve public lands and the resources therein for multiple uses. The resources I would like to comment on, as potentially affected by the permit, include water, fossil fuels, animal habitat, and wilderness recreation.
I understand that oil and gas wells can be responsibly constructed in a way that minimizes risk of groundwater contamination. I urge the BLM to apply any possible measures that would increase the likelihood of consistent and frequent monitoring of the drilling process to ensure that the planned safeguards of casing depth and strength are put in place by the Dan A. Hughes Company, as private companies have been known to “cut corners” in an attempt to save costs, which presents a threat to the integrity of the proposed safeguards. I understand that open evaporation pits are not proposed by the company, and I appreciate that this protects wildlife habitat from potential contamination. I urge the BLM not to allow underground injection of produced water, as the area’s groundwater flows toward an aquifer used for agriculture and household use.
In addition, the current drought conditions pose a question as to the safety of venting and flaring, should methane be encountered as the drilling proceeds. Although it poses an extra expense to the company, I believe there is a justification for requiring the company to secure the equipment necessary to capture methane, which equipment is used by some but not all drilling operations. The argument for this is first that flaring would be an obvious fire hazard. Venting also seems to pose a potential fire hazard, as any stray spark, such as from a cigarette or mechanical friction, could turn the venting into a flare.
Second, methane is a valuable resource. Because this is a government-leased property, this resource should not be wasted by flaring nor wasted by venting, which contributes to the growing greenhouse gasses that arguably contribute to global warming. The allowance for resource development should at the same time curtail the waste of finite and valuable fossil fuels on public lands. The company may recoup the cost of the extra equipment by selling the product.
I urge the BLM to continue to implement safeguards to protect nearby animal habitat and the use of the nearby wilderness for recreation purposes. Hunting, fishing, and other wilderness recreation in Southern Colorado provide tourism revenue and thus provide a livelihood for many Colorado residents that should be an important consideration.