This map shows the location of the parcels No. 39 and No. 42 to the Moab Watershed boundary. (Courtesy Canyonlands Watershed Council)

The reasons Kiley Miller is concerned about two land parcels to be considered for oil and gas development are simple.

“Clean water. Clean air,” she said.

Miller has invited others to join her in expressing concern about potential oil and gas development on Bureau of Land Management (BLM) land south of Moab through a petition titled “Protect the Moab Region Watersheds and Clean Air”. She intends to send the petition to local, state and federal officials.

Miller lives within a half-mile of one of the parcels now under consideration.

“I will be directly impacted,” she said.

Almost all parcels in a lease sale are proposed by oil and gas companies that may be interested in developing in the area.

“If they nominate it, we have to at least consider it,” said Don Ogaard, chief of the Utah BLM leasing support team. “Just because we consider it doesn’t mean it will be offered in a lease sale.”

The BLM Canyon Country District, which includes both the Moab and Monticello field offices, has one oil and gas lease sale each year. Forty-eight parcels that total 79,923 acres from the Dolores Triangle through Lisbon Valley are now under consideration.

“It is highly likely that not all the parcels on this list will make it to the sale,” Ogaard said.

Miller is most concerned about two parcels, No. 39 and No. 42, which are south of Moab and east of Highway 191.

Laurel Hagen, executive director of the Canyonlands Watershed Council, is also concerned about these two parcels.

“There may be no risk, but there may be high risks as well,” Hagen said.

Most of the culinary water in the Moab Valley comes from wells near the Moab City Golf Course that access the underlying Glen Canyon Aquifer, Hagen said.

“The rock that holds the Glen Canyon aquifer is very fractured,” Hagen said. “Potentially we have the bad luck to hit one of those cracks during drilling. Then any pollutant can travel along those cracks to a well. That’s with normal oil and gas drilling, that’s not with fracking.”

Fracking is a method injecting liquid underground to fracture rock and trap natural gas to be drilled.

“The problem is we already have the fractured aquifer,” Hagen said regarding using fracking for natural gas on these parcels. “They could disturb the fractures or make them bigger, and drive polluting liquid through those cracks. That’s the worst case scenario.”

Hagen said that there is no way to know whether oil and gas development on these parcels would pose a threat to the Glen Canyon Aquifer. Hagen said that the United States Congress had begun, but never completed, the process to fund a comprehensive groundwater study for this area.

“We don’t know because we haven’t done a study. Until we have that study, we can’t accurately judge the risk of drinking water contamination from nearby drilling,” Hagen said. “What we do know is that if it does become polluted there’s almost no way to clean it up and we have no other practical source of water.”

Miller now collects rain water and hauls water to her home. She is considering drilling a water well in the future. While the two parcels are adjacent to the Moab Watershed boundary, Miller is concerned that should she drill for water on her property, oil or gas development could directly affect her water.

“It is directly on top of my watershed,” Miller said. “It’s right on top where our water would be.”

The oil and gas sale is scheduled for February 2013. There are several steps to complete before parcels are available for bid. The first step was publicly announcing the parcels for consideration. The BLM invited comments from the public during the scoping period, which ended Aug. 13.

“When we get comments, we have to consider them,” said BLM Moab Field Office Manager Rock Smith. “If the comments have merit, it might change the Environmental Assessment.”

Smith said his office received approximately 40 comments regarding the parcels that are now under consideration. His staff is now preparing a draft EA that will be sent to the state BLM Office for review.

When the draft EA is finally prepared, it is released to the public for a 30-day comment period, Ogaard said. The draft EA should be available by Sept. 21.

“Public comment is most useful it if points to issues with the actual analysis. Pure expression of opinion, such as ‘I hate oil and gas development’, aren’t as useful. Comments that point to specific points and facts are most useful. Statements of preferences and opinion are not something we can really respond to,” Ogaard said.

The comments assist in the drafting of the final EA.

“We’ll take those comments, analyze, prepare responses to comments and modify the draft EA as necessary,” Ogaard said.

The final EA will have the public comments included and should be available by Nov. 16.

When the final EA is available in November, it opens another opportunity for the public to respond. Ogaard said this is the 30-day protest period, which ends. Dec. 17.

The BLM offices will then review the additional public comment before arriving on a final decision for parcels to be available during the oil and gas lease sale Feb. 19, 2013.

“Not every parcel we put up for auction sells,” Ogaard said.

For example, the Salt Lake BLM office had an oil and gas lease sale in Aug. There were no bids on the 19 offered parcels that totaled 33,154 acres.

“Most of the leases we sell are not developed,” Ogaard said. “If some of these leases were issued, there would be moderately to highly restrictive stipulations.”

Those stipulations include: how large of an area can be disturbed, reclamation planning, timing restrictions to protect wildlife, and the need to protect riparian habitats and fragile soils. Ogaard said some leases would have the limitation of no surface occupancy, and an oil and gas company would have to access from somewhere off the lease.

“If sometime before 10 years is up they establish production, the lease is good as long as production is maintained,” Ogaard said.