What is likely to happen and why is the Alliance worried about drilling and gas production within 1.5 miles of the Fruitland Outcrop as proposed by the Forest Service, Bureau of Land Management and the Colorado Oil and Gas Conservation Commission?

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When gas production begins, the Final Environmental Impact Statement (FEIS) tells us to expect the near surface ground water to drain down into the Fruitland Formation. This will be the result of Petrox shattering (called "fracing") the coal layers and pumping water out of them. Petrox must do this in order to allow the gas to flow up the coal bed methane (or "CBM") well pipes. We believe natural fractures in the Fruitland coal extend up through the formation to a point near the outcrop where near surface ground waters may be easily drained down to and up the well bores. Additionally, based on the experience of our petroleum engineer, we expect in time that the entire width of the 1.5 mile Setback could be drained by water going down through natural fractures and porous geologic and soil materials into the Fruitland. This is called "ground water depletion."

These are the results of ground water depletion:

a.) When the water table is lowered, we can expect streams near the outcrop to have lower flows, wetlands to dry up and worst of all, domestic water and irrigations wells may become dry. This data is also the opinion expressed in the FEIS.

b.) When water is gone, voids are left in the Fruitland coal layers near the surface. If the right amount of air flows through natural fractures or coal mine shafts into these voids and the percent of oxygen rises to between 6 and 16 percent, and if the temperature in the voids also rises to between 104 and 140 degrees Fahrenheit, pyrites in the coal can spontaneously combust starting a subsurface coal fire.

There are four fires burning out of control in La Plata County according to the FEIS and another at an active mine on the New Mexico border, all on the outcrop. US Highway 160 and Squaw Creek cut through the outcrop between Mile Posts 116 and 118 near the base of Yellowjacket Pass. There are two abandoned mines and signs of past coal fires there on the outcrop. There is a chance that air may enter these shafts causing a subsurface coal fire in this area of the outcrop once nearby, proposed CBM wells deplete the ground water underneath the mines. Hwy.160 and the11 buildings including 5 homes that surround this area would be impacted. There are at least six abandoned mines along the outcrop.

c.) If too little air enters the voids and instead, methane rises into them, then anaerobic bacteria can produce toxic hydrogen sulfide gas. Seeps of this gas are increasing on the Reservation due to CBM production according to the FEIS.

d.) Once most of the water has drained down through the fractures of the Fruitland as well as through fractured or porous geologic and soil materials from above the Fruitland, then methane can rise up through these same passageways to contaminate the remaining water wells, enter dry well pipes or go up through the soil into homes as described in the FEIS.
Four homes near the outcrop in La Plata County have been abandoned and razed, and a fifth burned to the ground during the Summer of 2005. An untold number of homes in the Texas Creek and Pine River areas have methane in their well water which has to be filtered and vented at a significant cost to prevent it from accumulating inside.

Does there need to be that much concern about these hazards. We thinks so, and so do the people along the outcrop. Here are the facts:

a.) There are a total of about 75 buildings that are on or within the 1.5 mile-wide outcrop Setback.

b.) Forty-seven of these buildings are on or within 0.5 mile of the outcrop, an especially hazardous section of the Setback.

c.) And of the total of 75 buildings, at least 25 are residences at the edge or on the outcrop. These residences are expected to be the first to be impacted by methane contamination of water wells or well losses, hydrogen sulfide seeps, coal bed fires or potential forest fires caused by CBM activities.

The FEIS is very frank about the hazards within the Setback and that most agencies and even the public are fully aware of them. Therefore, we are very perplexed as to why our State and Federal governments have approved or plan to approve the 48 wells within the so-called 1.5 mile setback designated by the Forest Service and Bureau of Land Management. We believe it is a disaster waiting to happen.