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Communication #8

Dear Friends,

The Flagstaff Water Group published an important editorial in Saturday's AZDaily Sun on a permit request to conduct acid-fracking operations in the Little Colorado River Basin in areas over the Coconino Aquifer, thereby potentially affecting Red Gap Ranch water, a potential future water source for Flagstaff.

Although this is very short notice, the issue is extremely important and we urge you to read the editorial statement (below) and send your comments to greenslade.maribeth@azdeq.gov. NO LATER THAN EARLY A.M. AUGUST 26th.

Sincerely,
The Board of Friends of Flagstaff's Future

COCONINO VOICES

Coconino Voices: Mining permit could affect Red Gap Ranch water quality

FLAGSTAFF WATER GROUP Aug 21, 2020
The proposed ADEQ Permit No. P-513196 for Prize Energy Resources (PER) is open for public review and comment through Aug. 26, on which date ADEQ will meet to make their decision. We urge Flagstaff and regional citizens to review and comment on the proposed permit in order to protect the water quality of and the City’s investment in Red Gap Ranch. Your comments should be submitted to greenslade.maribeth@azdeq.gov.

The proposed permit would allow PER to conduct acid-fracking operations in the Little Colorado River Basin in areas over the Coconino Aquifer, thereby potentially affecting Red Gap Ranch water, a potential future water source for Flagstaff. You may see the full text of the proposed permit at https://powaz.org/wp-content/uploads/2020/07/Aquifer-protection-for-Apache.pdf.

Our concerns are:

• ADEQ is mandated to require mining companies to have site-specific geology for each permitted mining site; however, geologists we’ve worked with cannot find specific geology mapping of the proposed drill sites. We anticipate that PER is extrapolating from wildcat boreholes, but such data would be suspect as to its quality. We feel that ADEQ has failed to comply with its own regulations to assure that professional geological mapping of each mining site provides the necessary information for evaluation of compliance with ADEQ’s regulations. Most of the mine sites are not specified. This is particularly important in determining whether there is the potential for metals and other compounds to pollute the Red Gap Ranch section of the Coconino Aquifer. The proposed drill sites (Section 2.1) are available in the above URL.• Given that the Holbrook/Winslow region is a basin, it would seem appropriate to have seismic data to determine the location of fault lines and the geologically relevant seismic history. Acid-fracking is difficult to manage in simple and stable geologic strata and the presence of fault lines would of course make it even more challenging to control. We believe the State and applicant must determine whether such fault structures exist and whether they could affect the migration of acid-fracking compounds.

• Section 2.2.2 of the above URL identifies the Helium extraction stratum as the Shinarump member of the Chinle Fm., a layer known to contain numerous metals. It’s further stated that a minimum of 100 feet of the Moenkopi layer will serve as the buffer between the mining level and the Coconino Aquifer. This is a minimal barrier that could be compromised by the hydrofluoric and hydrochloric acid-fracking, thereby failing to protect the potential Flagstaff future water source and taxpayer investment.

• The permit (cited above) is required to have “Points of Compliance” to measure downstream impacts from the acid-fracking; however, there is no indication that POCs will have monitoring equipment (section 2.7.1). Further, the permittee is responsible for all monitoring, recordation, interpreting the best action and reporting of spills and leakage. We are skeptical of the permittee‘s diligence and ability to monitor its own operations and recommend that task be assigned to an independent third party.In light of these and other concerns, we strongly urge you to email greenslade.maribeth@azdeq.gov by or before early morning Aug. 26 to request that ADEQ table their Aquifer Protection Permit No. P-513196 until such time as the above and other potential concerns are addressed to the standards set forth in ADEQ’s regulations.

Thank you for acting to protect the interests of Flagstaff.

Bryan Bates, Rob Vane, Ward Davis, George Kladnik and John Nauman wrote this representing the Flagstaff Water Group.