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Public Hearing on Double Drilling
November 19, 2018 @ 9:00 am
Special Hearing: Hilcorp’s Double Drilling Request
Monday, November 19th, 9 am
New Mexico Oil Conservation Commission
Porter Hall, 1st floor, Wendell Chino Building,
1220 South St. Francis Drive, Santa Fe, New Mexico
As you may have heard, Hilcorp is requesting approval from the State of New Mexico’s Oil Conservation Commission to double the density of allowable wells in the Blanco-Mesaverde Gas Pool in San Juan and Rio Arriba Counties. That could mean an additional 8,000 new wells and recompletions in northwest New Mexico. Communities in San Juan and Rio Arriba counties already are overwhelmed by oil and gas. Northwestern New Mexico is home to more than 40,000 oil and gas wells as well as ancillary compressors, processing plants and pipelines.
No analysis has been done on the impacts of doubling the well density. We’re additionally concerned because approval of this request would circumvent the current public process required when an exemption to the well density is requested.
What can you do?
Come to the meeting! Speak out against this request! There will be apublic hearing on the issue November 19th where the New Mexico Oil Conservation Commission will be making their decision. The public is invited to provide comment and San Juan Citizens Alliance will again be attempting to persuade the commission not to approve Hilcorp’s request. It is critical for the commission to get feedback from the public.
Can’t make it? Submit comments against the proposal to firstname.lastname@example.org. Below are some suggestions for talking points. Please edit and adapt as you see fit.
These are some suggestions for public comments either in person at the hearing or to submit via email to email@example.com.
As a public agency, NMOCC has both the regulatory authority and the duty to consider the concerns of the public about applications brought forth before the commission.
- As a member of the public I am deeply concerned about how this application would affect public health and the environment. In particular, I am concerned about the potential of this proposal to impact water resources, to create additional surface disturbance and landscape fragmentation, and to negatively affect to air quality and contribute to climate change. Disregarding the concerns of San Juan and Rio Arriba county citizens by NMOCC concerning the magnitude of Hilcorp’s well density change application would be extremely troubling.
- San Juan County is already on the cusp of exceeding safe ozone levels and oil and gas development is a major contributor to the Delaware-sized methane hot spot that is a black eye on New Mexico, the oil and gas industry, and the nation as a whole. I am concerned about whether Hilcorp is taking adequate steps to capture methane while drilling new wells or doing recompletions. Doubling drilling will certainly result in declining air quality that will affect 13,000 kids and adults in San Juan County who struggle with asthma.
- *If you are a resident of San Juan or Rio Arriba Counties, include specifics about how you have been impacted by oil and gas. The NMOCC is particularly interested in hearing about impacts to property.
Lack of Impact Analysis
The Bureau of Land Management’s 2003 Resource Management Plan for the Farmington Field Office is out of sync with this proposal for double drilling in the Blanco-Mesaverde gas pool. This proposal warrants a new process of comprehensive environmental review and public consultation to ensure that any negative impacts to communities, correlative rights, environmental and cultural resources are mitigated.
- Hilcorp is a bad faith actor with a history of violations in other states. In New Mexico, I am deeply concerned about whether Hilcorp’s recompletions in the Blanco-Mesaverde are in compliance with EPA rules that require green completions to capture methane.
- I am concerned about whether OCC provided enough public notice for those members of the public who are affected to know about and be able to attend this hearing or the September 13 hearing. Since then, Hilcorp has made misleading and confusing statements in the media about the scope of this application. Hilcorp has suggested that this application is only about re-completions, but there is nothing in the application that limits Hilcorp or other operators to recompletions. We know that new wells could be drilled as a result of this proposal, and Hilcorp’s attempt to conceal this from the public is troubling.