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Prep Call: No to Produce Water Reuse


May 9th, 2024 at 5:30 p.m. - 6 p.m.

Join a virtual prep call to learn how to tell your story and give public comment. Learn when and where the Water Quality Control Commission hearing will be! 

Virtual Prep Call via Zoom, YouTubeLive or Facebook on Pueblo Action Alliance platforms 

Thursday, May 9, 2024 5:30pm-6pm MST

Indigenous Lifeways will be facilitating the Storytelling and Public Comment Toolkit to help prep you for the hearing.

  • In Person Public Comment:

Sign up for the Public Comment by emailing

May 13th 12PM and 5PM

May 14th at 9AM and 1PM

May 15 & 16th TBD

  • 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 NMAC

  • Call or Email:

Water Quality Control Commission

ATT: Pamela Jones, WQCC Administrator

Telephone: (505) 660-4305 Email: 

Docket Number: WQCC 23-84(R). Pursuant to NMAC

For any updates on the hearing visit this website

We support a rule that prohibits any discharge, disposal or reuse of treated or untreated produced water off the oil field. 

1. The difference between domestic wastewater and toxic radioactive fracking waste - conflate these as both waters. 

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]

2. 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. 

3. 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. 

More information can be found at

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