Sabine Shurter
Jemez Springs, NM 87025
Geothermal EIS Project, Santa Fe National Forest
11 Forest Lane
Santa Fe, NM 87508
June 6, 2015
Dear Sirs,
I would like to thank you for considering my comments on your Geothermal EIS Project Proposal to allow large scale geothermal leasing on the Santa Fe National Forest.
I am concerned about this proposal. I believe that several issues not addressed in the EIS should be considered for making an appropriate decision on the geothermal leasing proposal. I am also concerned that the NEPA process has not been followed by presenting a lacking and insufficient EIS and not scheduling a public input meeting for residents in the southern part of the project area.
EIS-specific issues
- Provided material/information/maps
In my opinion the presented geothermal project EIS is lacking important information. The maps are partially illegible (low resolution), are missing landmarks or are mislabeled. This makes it more difficult to understand the proposal and its ramifications.
- No Surface Occupancy provisions
Most No Surface Occupancy Stipulations can be easily overridden by so-called exceptions either suggested by the operator or NM state agencies. Some No Surface Occupancy Stipulations can be overridden without asking for public input. In the present form, the format “No Surface Occupancy Stipulations allowing Exceptions” appears to be a rather weak tool for the SFNF when trying to protect the surface features for which the agency is responsible. Please consider not allowing any exceptions for No Surface Occupancy Stipulations to enable the SFNF to truly hold harmless the surface areas under the protection of the USFS.
- Valles Caldera National Preserve
The Valles Caldera National Preserve is bordering the EIS project area on three sides. It cannot be assumed that geothermal exploration and production along its boundaries will not impact the geothermal features of VCNP and the VCNP’s environment and mission. Please make the VCNP/Park Service a cooperating agency in order to recognize the impact of this proposal on the VCNP and to utilize this agency’s expertise with respect to the environmental impacts of this complex project.
- No Public Meeting in the southern/southwestern project area
No public meetings have been scheduled for the residents living in the south of the project area (south of the VCNP/JNRA and east of Jemez Springs). The argument has been made that there will be very little potential exploration in that area due to No Surface Occupancy Stipulations and that, at this point, only the Cuba Ranger District will be affected. However, many of the No Surface Occupancy Stipulations may be overridden without any public input. It is not unlikely that residents of Jemez Springs and along the Hwy 4/Hwy 126 corridors may find themselves in the middle of geothermal exploration/production and its resulting infrastructure projects/impacts without having been able to have their area specific concerns heard at a public meeting in their area. Please include Jemez Springs and nearby communities in your public meeting schedule.
Technical issues
The EIS does not address the nature of the Enhanced Geothermal Systems to be employed in the proposed project area. Depending on the system employed, certain challenges and problems will arise none of which have been addressed in the presented EIS. Please address the following issues and include them in your decision process.
- Truly renewable energy extraction?
It is unclear whether this project area will be able to provide truly renewable energy or whether economically feasible energy extraction will be short-lived. It is unclear how geothermal features such as hot springs in the project area will be affected by the project, i.e. the potential of substantially cooling down hot springs. Without exploring this potential issue, irreversible harm can be done to geothermal features inside and outside the project area, including the Valles Caldera National Preserve. Please ensure that this issue will be investigated in a comprehensive and scientifically valid way.
- Drilling depth
At the Fenton Hill HDR (Hot Dry Rock) project site it was determined that a drilling depth between 3 – 5 km deep is needed to locate temperatures between 200 and 300° C that are likely to be suitable for electricity generation. The suggested No Surface Occupancy Stipulation around water bodies including hot springs appears to be way insufficient considering potential drilling depths.
- Water usage
At Fenton Hill fluids (i.e. water) were injected into the ground for steam well production. Large areas of the rock must be adequately hydrated to result in heat transfer. The availability of water for this process in the arid project area cannot be assured unless operators are allowed to access water currently allocated to other users (agriculture/irrigation, community, domestic or commercial wells, surface waters belonging to other communities/states/countries, etc.). New Mexico’s water is already over-allocated, i.e. more water rights have been granted than water is available to users. The NM Office of the State Engineer is responsible for the distribution of the scarce water resources in New Mexico. Has OSE been consulted about water issues? Why are the BLM and the SFNF considering introducing a project with potentially high water requirements on lands administered by the Federal Government in the arid and drought-ridden State of New Mexico? Is it possible that other water users will be deprived of their water rights in order to provide the required water resources for this project?
There is no reference in the EIS to the problem of potentially unsustainable production due to excessive water use/loss, water rights issues, water availability, etc. Also, the proposed No Surface Occupancy buffer surrounding, for instance, hot springs appears to be way too small.
The contemplated exploration area (which is unknown to me at this point) must be hydrologically isolated from major faults and nearby natural hydrothermal reservoirs. Drilling too close to geothermal features such as a hot spring or near major fault lines may result in water losses making the project unsustainable.
- Potential of man-induced earthquakes
Depending on the location of the drilling sites, significant volumes of water can be lost and accumulate downhole. This could result in damaging earthquakes as the existing faults are being lubricated and start slipping. The potential of earthquakes induced by geothermal drilling should be considered by the decision makers as major damage could occur to above-surface features for which the SFNF is responsible, on private lands, including businesses and residences located on private lands, and to facilities of Los Alamos National Laboratory.
- Equipment failure and potential for pollution
The hot waters produced by the natural geothermal activity in the Jemez are loaded with geochemicals. The problem may be acerbated when reservoir rocks are dissolved during the geothermal power generation process. This may cause scaling of equipment and/or corrosion of piping which could render the production process unfeasible. Corrosion can also result in pipe/equipment failure leading to ground and air pollution outside the production area (even a closed loop system can fail in such a corrosive environment). Please consider the threat of pollution to soil, fauna and flora, air, ground or surface water when making your decision on this project.
Remediation issues
- Operator’s responsibilities after ceasing exploration drilling/production
What will happen if an operator decides to cease exploration/production? Will there be sufficient funds posted by operators to restore the project areas to their condition before exploration/production commenced? What will happen if an operator goes bankrupt or decides to abandon its business activities? Will the tax payer have to foot the bill? Will it be deemed acceptable to have a huge mess left behind from the days of geothermal exploration/production in the Jemez such as unsightly plant ruins, abandoned power transmission lines and roads to nowhere?
I am aware about two projects within the SFNF with less than satisfactory remediation results - the rather unsatisfactory remediation results of pumice mining activities along Hwy 4 and the inability to get the responsible movie producers to restore the location of a movie set in a riparian area at the Las Conchas trailhead to its original condition. Without satisfying answers to these questions and the ability to enforce appropriate remediation, this proposal should probably not be contemplated by the SFNF.
Infrastructure
The EIS mentions additional infrastructure requirements such as roads, power transmission lines, and plants if geothermal energy generation becomes a reality.
- Roads
Exploratory drilling and potentially subsequent large scale industrial developments within the National Forest will require extensive road construction to accommodate traffic and equipment transport to the geothermal sites.
- Power transmission lines
Power transmission lines attached to tall pylons will have to be constructed to transport the generated electricity to population centers. They will be very hard to hide from view. Apparently the possibility of underground transmission lines was mentioned at one of the meetings which I could not attend. I do not believe that this is a feasible solution. Underground transmission lines are costly and more difficult to construct and their construction is very disruptive to the land. Unstable slopes and bedrock formations must be avoided. Man holes and splice boxes must be installed along the underground line. Outages may last much longer as the line must be unburied. Large “riser structures” with large attachments are needed at the locations where the line transitions from underground to overhead. For these reasons, underground transmission lines are in most cases only considered for airport or downtown urban areas with no viable overhead corridor and are not a feasible solution for miles of power lines traversing the forest. This will leave operators with the only option of installing of overhead transmission lines which will require the clear-cutting of many acres of forest on both sides of the lines and running roads to maintain these lines. This will tremendously enlarge the footprint of a geothermal power project and will probably make it impossible to operate if the No Surface Occupancy Stipulations are taken seriously. On the other hand, not clear-cutting the forest along these lines will pose an added risk of wildfires caused by trees falling into the power lines. Hopefully, the SFNF is not considering adding that risk to the already high wildfire risk in the drought-stricken forests of the Southwest.
- Geothermal power plants
Geothermal power plants will have a large footprint in the forest and their stacks will belch water-vapors and potentially dissolved geochemicals into the air which will be visible from a long distance. Such a scenario will distract from the natural and scenic beauty of the entire area and maintaining an undisturbed attractive view shed appears to be impossible under such conditions. Also, the potential of offensive odors and environmental, health and safety problems caused by poisonous, corrosive, flammable and explosive hydrogen sulphide (causing the “rotten egg smell”) in the released vapors needs to be addressed.
Socio-economic issues
- Impact on tourism
The proposed project area encompasses a highly valued recreation area for New Mexicans and tourists from the rest of the U.S. and around the world alike. The Valles Caldera National Preserve and the Jemez National Recreation Area are in the very middle of the project area and stand to be affected by any large scale industrial development in the adjoining National Forest. I would like to urge the decision makers to carefully weigh the potential benefits of the proposed geothermal project against the proven benefits of tourism, a clean industry which has been carefully groomed and developed by many small area businesses over the years and may be badly affected by industrial activities in the neighboring National Forest.
- Impact on communities
If an industry comes into a community, it may generate jobs and offer an improved tax base but it may also change the social fabric of the community with unexpected and undesirable results. More public services such as schools, law enforcement, EMS services may be required which the community may not be able to provide on short notice. The community may be unable or unwilling to quickly expand its service base because of lack of funds or due to the fear of being left with a ghost town once the boom is gone and the bust has set in. Any large scale industrial development relying on one or a few operators is liable to produce such undesirable results once these operators have determined that they would like or have to cease production and move on.
I believe that the proposed geothermal project area is unfit for geothermal production on a large scale. This area is an ecologically sensitive high desert environment with scarce water resources and extreme proneness to erosion and soil degradation in many areas. The area is valued by visitors and residents alike for its natural and scenic beauty which stands to suffer greatly once large scale industrial development has been allowed into the area.
Please consider refusing to allow leasing for any development in this area. If a plan moves forward, please ensure that water bodies, natural geothermal features, Inventoried Roadless Areas, cultural resources, habitats of endangered species and other important features/places are fully protected. This would require ample use of the No Surface Occupancy without Exception Stipulation, a much larger buffer around water bodies, and ensuring that the final decision document stands and cannot be altered upon the request of the Industry and State agencies.
Thank you very much for your attention!
Sincerely
Sabine G. Shurter