Our Culture
MAY 6, 2024| Rally Opposing Produce Water Reuse Rule making
“Produced Water” is toxic, radioactive byproduct of oil and gas and poses serious risks to public health and the environment.
Amy Hardberger, a professor of water law and policy at Texas Tech University, said more research and review is needed to determine appropriate uses of produced water. “The Clean Water Act never contemplated this water going into rivers and streams,” she said.
In a forthcoming paper, Hardberger points out that many of the constituents in produced water are difficult or costly to test for and do not have established EPA toxicity standards. These are numerical values measuring the risk presented by exposure to a chemical or contaminant. She compares the EPA’s list of standards for public water supplies, which includes exposure guidelines for approximately 90 contaminants, with the over 1,100 chemicals that have been found in produced water.
And she warned that the science on public safety shouldn’t be rushed to find a quick fix for produced water disposal. “What’s driving the train on this is not water shortage and the potential of an additional water supply,” she said. “What is really driving the change is they are running out of disposal opportunities.”[1]
[1] https://insideclimatenews.org/news/28042024/texas-pecos-river-oilfield-wastewater/?utm_source=InsideClimate+News&utm_campaign=be2c8f9a72-EMAIL_CAMPAIGN_2024_05_04_01_06&utm_medium=email&utm_term=0_29c928ffb5-be2c8f9a72-328394352
There are NO specifications for "appropriate treatment" - this means that the rule as written should fail because there are NO scientific standards to protect human health and the environment.
The law is on our side:
WQCC “shall adopt water quality standards for surface and ground waters of the state based on credible scientific data and other evidence appropriate under the Water Quality Act” (NMSA 1978 § 74-6-4D) and further, that “The commission shall consider, in addition to the factors listed in Subsection E of this section, the best available scientific information.” NMSA 1978 § 74-6-4K. Subsection E states that the WQCC “shall adopt, promulgate and publish regulations to prevent or abate water pollution in the state[.] … Regulations may specify a standard of performance for new sources that reflects the greatest reduction in the concentration of water contaminants that the commission determines to be achievable through application of the best available demonstrated control technology, processes, operating methods or other alternatives, including where practicable a standard permitting no discharge of pollutants.” (emphasis supplied) §E requires further that the Commission consider injury to or interference with health, welfare, environment and property; the public interest; and more.
This rule as written WILL lead to contamination through accidents, spills, and waste generation; workers at treatment plants are especially vulnerable.
Crafting your story
Issue
Produced water
To live in a clean and healthy environment for generations in New Mexico
Our campaign has three demands:
- Don't poison our water. Protect it. Prohibit the discharge, reuse, and disposal of all produced water, treated or untreated, outside the oil field.
- Hold industry accountable for its toxic waste problem. Designate hazardous waste from oil and gas production as hazardous waste.
- Address the root cause of the toxic fracking waste problem. Begin the responsible phase-out of oil and gas production.
Creating a market on produced water which a radioactive by product of oil and gas. The Re-use Radioactive waste water is a determinate to our public health.
Do not Re-use Fracking waste
- Water is life.
- Clean Equitable jobs.
- Healthy Livestock, Healthy Game.
- Plentiful Gardens and Farms.
- Healthy Families.
- Protect NM From fracking waste re-use.
Template
Template for Public Comment
Template to use: 3 Minutes for Public Comment
Good Morning/Afternoon Commission Members,
My name is __(Insert name) _______ and I’m from __(County, State, Tribe)_______
I urge the members of the Water Quality Control Commission to oppose the proposed rule making on water reuse regulations, as outlined as the Ground and Surface Water Protections-Supplemental requirements for Water Reuse.
Water Quality Control Commission should consider the following:
- We need a rule that not only prohibits discharge of untreated or treated produced water into ground/surface water, but also prohibits all produced water reuse off the oil field.
- “Produced Water” is toxic, radioactive and poses serious risks to public health and the environment.
Again, I demand the Water Quality Control Commission to act in its full capacity to denounce the rule making.
Thank you Commission Members for your time and consideration.
Public Comment
In Person Public Comment
Sign up for the Public Comment by emailing pamela.jones@env.nm.gov
COMING SOON!!
Each person has 3 minutes.
Sign up Sheet with Defend NM Water
Join Virtual Hearing on Webex:
Click to join the hearing on 5/13 and 5/14
Use the following link:
Scan QR Code
Written Comments
Water Quality Control Commission
ATT: Pamela Jones, WQCC Administrator
Harold Runnels Building
1190 St. Francis Dr.
Suite N4050
Santa Fe, NM 87505
Docket Number: WQCC 23-84(R). Pursuant to 20.1.6.203 NMAC
Call or Email
Water Quality Control Commission
Ask for Pamela Jones, WQCC Administrator
Telephone: (505) 660-4305
Email: pamela.jones@env.nm.gov
Docket Number: WQCC 23-84(R). Pursuant to 20.1.6.203 NMAC
Letter to Editors
Click the link below to submit your Letter to Editor:
Navajo Times: Email: editor@ntpc.biz
bit.ly/FarmingtonDailyLTE
Ways to Participant
Social Media
Copy this message and tag @nmenvironmentdepartment
We need a prohibition of the discharge, reuse, and disposal of all produced water, treated or untreated, outside the oil field.
#noproducedwaterreusenm
#nmed #waterislife #notoxicjobsnm
Indigenous Women Words of Wisdom
Quotes are from the Hearing & Links are underline. How are you supporting Indigenous voices?
Christina Castro, Founder of Three Sisters Collective, talked about how, as an Indigenous Matriarch, she is tired of speaking out again and again at hearings, trying to protect our water from contamination. This impacts not only Indigenous people, but everyone in our state.
Radioactive fracking waste is not “water” and it cannot be reused. Beata Tsosie-Peña and Eyndia Omega with Breath of my Heart Birthplace spoke on the potential impacts of toxins on mothers and their babies. Elder Kathy Sanchez, Tewa Women United shared a cautionary story on extractive greed.
Reyes DeVore, Program Director of Pueblo Action Alliance stated, “When I think about water, I think about its sacredness, the way it is included in our cultural practices that my Hemish relatives and other Pueblo Indigenous peoples have been living with for centuries now. Over the span of defense to protect it from settler colonialism we continue to remain as people who are fighting to protect it and keep the sustainability of our culture alive.” While Julia Bernal, Pueblo Action Alliance, brought up research on radioactive fracking waste harming workers and contaminating watersheds in Pennsylvania.
As Anna Rondon, Executive Director of New Mexico Social Justice, told the commissioners, “May the holy people guide you to make a good decision.”
Krystal Curley, Executive Director of Indigenous Lifeways, voiced “we are tired of being your toxic waste dump.” As we know
Indigenous and people of color would be the most affected by the outcome of proposed pilot projects that seek to move this radioactive water off the oil field and into agriculture and aquifer recharge.
Resources
Information provided by: Indigenous Lifeways, Pueblo Action Alliance, No False Solutions, New Energy Economy, New Mexico Climate Justice, Defend New Mexico Water
Toolkit Created by: Indigenous Lifeways