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Microsoft Outlook From: Bill Brown <bill@brownenviro.com> Sent: Monday, November 13, 2017 4:47 PM To: Sidney Hill Subject: Comments on the Proposed Sandoval County Oil and Gas Ordinance Attachments: Sandoval county oil and gas comments WJB.pdf Here are my comments Thanks Bill Brown 1 November 13, 2017 shill@sandovalcountynm.gov To: Attention: Sandoval County Commission Sandoval County, New Mexico From: William Brown, P.G. 15 Snow Peak Road Placitas, New Mexico 87043 RE: Comments on the Proposed Sandoval County Oil and Gas Ordinance Introduction The recently proposed “Stoddard Ordinance” in its current form poses a potentially serious threat to the long-term drinking water supply for the citizens of Sandoval County and potentially surrounding counties, pueblos, and municipalities, including the City of Albuquerque, the City Rio Rancho, and the Town of Bernalillo. As part of the Comprehensive Zoning Ordinance of the Sandoval County, NM " SECTION 2. PURPOSE. “The provisions of this Ordinance are designed to promote health and the general welfare of the County; to secure safety from fire, flood, and other dangers; to protect local water resources; to facilitate adequate provisions for transportation, water and wastewater systems, schools, parks and other community requirements; to conserve the value of property; and to provide for the compatible development of land and other natural resources in Sandoval County." The Stoddard Ordinance does not adequately meet the stated purposes of the Zoning Ordinance. Hydrogeologic Setting Sandoval County straddles several major geologic provinces including the San Juan Basin on the west and the Rio Grande Rift in the east. The San Juan basin is characterized by a broad depression with a relatively simple geologic environment. The attached Figures 1 and 2 highlight the geologic setting in the eastern and more densely populated portions of the County. The Rio Grande Rift is characterized by numerous north-south trending normal faults which have resulted in the sediment infilled Rio Grande basin bounded by the uplifted Sandia mountains to the east. Tertiary and Quaternary basin fill sediments (shown in orange and brown on the attached maps), are the primary source of the Santa Fe aquifer. This aquifer provides drinking water for over half a million people in Sandoval, Bernalillo, and Valencia Counties. Proposed oil and gas exploration would penetrate these shallower aquifer zones and extend into the deeper Mesozoic and Paleozoic bedrock formations (shown in blues and greens on Figures 1 and 2). These underlying bedrock zones would likely be “fracked” as part of the oil and gas exploration/production well drilling process. Potential Threats to Water Supplies As can be seen on Figures 1 and 2, numerous faults are present in the vicinity of Bernalillo and Placitas areas. Implementation of Fracking in the proximity of these complicated and extensive fault zones poses a threat to overlying groundwater zones. Because of the highly complex large-scale nature of faulting in the area, the effects of fracking (and subsequent grouting) cannot be fully predicted. Horizontal fracking of bedrock adjacent to faults can result in facilitated migration of hydrocarbon contaminants (both oil and gas) along the fault zones to overlying groundwater zones. It should be noted that only the large-scale faults are shown on Figures 1 and 2; numerous smaller faults and fractures are present in the subsurface which are not shown on the maps/cross sections which further complicate the hydrogeology of the area. Aquifer sensitivity to oil and gas production in the County generally increases from west to east. This is especially true in the vicinity of Placitas. Faulting in the Placitas area has also juxtaposed Mesozoic and Paleozoic (targets for oil-gas exploration) geologic formations against younger Tertiary and Quaternary Santa Fe aquifer formations. Fracking in these areas is even more problematic and potentially threatening to the areas water supply. Conclusions Oil and gas exploration and production is not an exact science and many things can go wrong during drilling, fracking, and grouting processes in complex geologic environments. This has been documented at numerous locations throughout the United States. The current rush to approve what is a short-sighted and flawed policy towards oil and gas production in Sandoval County oversimplifies a complex problem and ignores the long-term needs of the Citizens of Sandoval County. The County Planning and Zoning Director does not currently have the expertise or the resources to make decisions which may drastically affect the long-term water supply for thousands of people. At a minimum, Sandoval County should specify wellhead protection areas limiting or preventing oil and gas production within portions of the County based on aquifer sensitivity and land use. This is especially true in the eastern portions of the County and Placitas in particular due to its highly complex geology and potential aquifer sensitivity. No other water supply is available to the residents and municipalities in these critically sensitive areas. Historically, Mitigation of oil-gas exploration contaminants to drinking water aquifers is cost-prohibitive and generally impractical. Long-term litigations are usually the result. Implementation of a more comprehensive approach to oil and gas exploration in Sandoval County can effectively mitigate these potential problems. William Brown, P.G. Hydrogeologist Placitas, NM PLACITAS QUADRANGLE - NEW MEXICO NMBMMR Open File Map Series NEW MEXICO BUREAU OF MINES AND MINERAL RESOURCES OF–GM–2 and OF–GM–16 A DIVISION OF NEW MEXICO INSTITUTE OF MINING & TECHNOLOGY Map last modified 17 February 2000 PLATE I of III. ines & Mine (BERNALILLO NW) f M ra o l R MEX u e a s IC e o W BERNALILLO QUADRANGLE r u E O u r . B c N NEW MEXICO e (SAN FELIPE M s PUEBLO NE) N B ° (SANTA ANA PUEBLO) SANTA FE 39 MI New Mexico Tech 106 37' 30" 3 000m 3 3 3 3 3 3 106°30' 106°22'30" 53 E. 54 55 56 35' 57 R. 3 E. R. 4 E. JEMEZ CANYON DAM 2.7 MI. 32' 30" 61 420 000 FEET 63 364 5 E. LAS VEGAS 105 MI 366000m E. 367 R. 4 E.27'30" R. 5 E. 368 (SAN FELIPE PUEBLO) 370 371 25' 372 373 374 460 000 FEET • •• 35° 22' 30" Luce fault • 35°22'30" • Qay ˇcp S QHa 10 • Qre Tsla? QToc(?) QHa Qae QTob Qao Qrp QHa • P5 QTsp s 13 Jt QHa QHa 77 • • l • QTob l QHa QTsa • 11 QHa E T P 4 • QHa • ? QHa 6 a y Qao • r Qay Qay Qe 13 • Tbsa • • r 2 82 • t u QHa • Qls h t A 67 75 QTob QHa 1• • Je Qrp Qre • l Tsp n • s S A • Qls l c e Qe • 2 Qrp • QHa Qpm1 QTspcs • j Qpm ie t C T 9 • 5 n s 5 QHa • ce 1 • • 2 • • for the E M QHa • QHa Qpo3 5 QTob • • • • • • QTob QHa • • 6 QHa QHa • l l QTsa Qpo3 3 QToc(?) QTob • ••• • 39 • Qe af • QTsa QTsps • • QHa ˇcp 15 QTob Tp • QTob • ault • Tsp c QTsp •• Qpm sm Qay • Qre • QTob f • • • Dr. Paul W. Bauer 3 • QTob • l l Qpm2 15 QHa 4 • 1 • af • Tsp • Qrp s • • af 4 • Qpm • Dr. Peter A. Scholle Qca • l Tsla? • 6 • Qls1 l • • QTob QTsp 1 590 000 • Tobc • ? s • • • 6 • • QTob Geologic Mapping U D • QTob 3 • Qrp • 1 af • • 88 • l • • Qcb Qpo QHa • l w 3 10 FEET Director and State Geologist • Qe • • QHa QTob • Qre af 85 Qao • Qrpr e • • • • i • • • Program Director Qay • Qpm2 • • • 39 000m af • • • Qre V 4 • • 15 N. • • • 5 • • P6 U 14 • • • • • 4 Qae • Qay T. 13 N. • 70 l • QHa • Tsp • 6 • QHao Qre l QTsa D s 18 • • QHao Qpm • 2 • • ? • • • • QHao Qpo3 85 Qao • QTsa • • • QHa • • QTs t • ˇcp • Qre • y • • • 3 • 8 • 22 • • Qpo • • RWP-17 • Qpm QTsa e • • • l • • • 3 • l l • QTsp Qpo s • • • QTob Qao • l • 18 • • Qre ?• Tsp cs QTob • • B1 • • a • • QTsp 7 62 • • s • 8 • • 12 • • V • • • 4 6 I • 3 l • QHa • 37 • Qss •• I 23 l • 15 QToc(?) 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