Commissioners hone comments on proposed Mancos gas development

Include requests for the BLM to explore frack fluid tracers, continue to focus on assimilative capacity

By Crystal Kotowski

The Board of County Commissioners honed its scoping comments for the North Fork Mancos Master Development Plan before the deadline of March 22. Scoping is the process used to determine the appropriate contents of an Environmental Impact Statement (EIS). Scoping begins before any analysis of impacts is done, and it continues until the EIS is finished.

Gunnison Energy is proposing to drill up to 35 gas wells and construct access roads and gas pipelines in Gunnison County, with construction and development activities anticipated to begin in late spring or early summer 2017. Long-term operational life of the project is estimated at 30 years, with expected production of up to 700 billion cubic feet of natural gas.

The scoping letter to the Bureau of Land Management continues its focus on assimilative capacity, so as to not turn the area into a “sacrifice zone,” as deemed by county attorney David Baumgarten in a recent meeting. Assimilative capacity refers to the ability of the environment or a portion of the environment to carry waste material without adverse effects on the environment or on users of its resources. The letter also includes requests to explore frack fluid tracers.

Hydraulic fracturing has been controversial in large part due to the potential for contamination of ground and surface waters. Researchers have developed geochemical methods of tracing fracking fluids in the environment, a tool that could be used to identify hazardous spills and may lead to better use and disposal of fracking wastewater.

“We’ve gotten a lot of comments from organizations and individuals from the North Fork for this development… we did get some comments from the High Country Conservation Advocates on the future feasibility part of the letter,” commissioner Phil Chamberland began.

County manager Matthew Birnie noted the difficulty of evaluating impacts while not knowing the timing of the projects in the North Fork Valley. “If it happens all at once then the impact will be greater than if it were to happen over time,” added Birnie

“What we all agree on is that is that long-term planning is important, but at the same time we should allow development,” added Chamberland.

The comment letter continues to urge that the proposal be analyzed through the frames of the “assimilative capacity” and “carrying capacity” of the North Fork area, and that such analyses include the proposal superimposed on existing projects and anticipated projects. The project location is directly west of the proposed 146-gas well Bull Mountain Development, and is near the 20,000-acre North Fork Coal Mining Area exception to the Colorado Roadless Rule.

For a given region, carrying capacity is the maximum number of individuals of a given species that an area’s resources can sustain indefinitely without significantly depleting or degrading those resources.

Concern over the chemicals utilized in frack fluid mark an addition to the comment letter. “Gunnison County urges that the BLM rigorously explore the current state and availability of non-toxic frack fluid tracers with regard to this proposal—particularly in light of the high, headwaters nature of the proposal and the proximity of both downstream water supplies and agriculture,” the letter reads.

“One of the important things to note—and which is something the Colorado Oil and Gas Conservation Commission does not require—is the idea of some kind of tracing of chemicals. That is a pretty important step if they will do that,” confirmed Birnie, noting Gunnison Energy’s openness to the conversation about tracing chemicals.

“They have not objected to the tracing of chemicals, as the industry has generally resisted this. Gunnison Energy had the opportunity to review the scoping comments and did not ask us to take that out,” said Birnie.

According to Fractracker Alliance, the chemical mixture of frack fluid is complex, varies from well to well, and many of its compounds pose serious health risks depending on the level of exposure.

Currently, there is not one publicly available and comprehensive dataset on frack fluid use and composition in the United States. Well-by-well chemical use data has been documented by environmental organizations, but those datasets exclude proprietary chemicals (trade secrets). The EPA also lists possible chemicals used in frack fluid on its web site, noting “the EPA at this time has not made any judgment about the extent of exposure to these chemicals when used in hydraulic fracturing fluids or found in hydraulic fracturing wastewater, or their potential impacts on drinking water resources.”

“Keeping in mind that these are our comments to the process federally, we still have our own regulatory process. This is not the end,” concluded Birnie.

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