Stream Depletion Impacts Associated with Coal Bed Methane Extraction: Rule-Making for the Raton Basin
On behalf of a group of water rights holders, SSP&A was asked to evaluate mapped stream depletion impacts and a proposed line of demarcation for "non-tributary" groundwater; that is, groundwater that could be withdrawn in conjunction with coal bed methane extraction without concern for the replacement of stream depletions, in accordance with State of Colorado statutory limits. A consultant team working on behalf of petitioners representing the extraction industry had prepared a complex 3-dimensional groundwater model for this purpose; SSP&A reviewed the model and provided written testimony on behalf of the protesting parties which led to the applicant's withdrawal of the model.
After additional work, the applicant submitted a new model in support of their proposal that the basin be declared "non-tributary" for future extraction activities. SSP&A reviewed the new model and provided written testimony again noting a flawed analysis and contesting the proponent’s conclusions. Prior to the planned rule-making hearing, the proponent’s revised their claim to the satisfaction of the protesting parties.