Fracking safely requires a minimum of about 0.5 km (0.311 miles or 1,640 feet) BELOW the water-bearing Mancos Shale, Dakota Sandstone and Morrison Formation .
In the Rios Gallina & Chama Watersheds, shales and confining layers were largely stripped away, right down to remaining Mancos Shale, which was then crushed and flushed by repeated glaciation and melt to yield water.
Oil & gas exploration, therein, has produced mostly water.
BLM's plan ignores the fact that the Mancos Shale IS the surface in much of Rios Gallina and Chama Watersheds.