Microsoft Office Outlook - Memo Style - Montana Board of Oil and Gas

Richmond, Tom
From: Scot Donato [sdonato@billbarrettcorp.com]
Sent: Monday, June 20, 2011 10:09 AM
To: DNR FracComments
Subject: Comments RE: New Frac Rule
Please accept these comments from Bill Barrett Corporation (BBC) to your proposed Rules I through V regarding oil and
gas well stimulation.
NEW RULE I WELL STIMULATION ACTIVITIES COVERED BY DRILLING PERMIT (1)
Well completions which include hydraulic fracturing, acidizing, or other chemical stimulation
done to complete a well are considered permitted activities under the drilling permit for that well
only if the processes, anticipated volumes, and types of materials planned for use are expressly
described in the permit application for that well.
(2) For wildcat or exploratory wells or when the operator is unable to determine that hydraulic
fracturing, acidizing, or other chemical treatment will be done to complete the well, the operator must
obtain prior written approval of such activities from the board's staff at any time prior to commencing
such activities
BBC Comment:
This can be very difficult in an ‘exploratory’ program as frac programs can change quickly depending on recent results
from other wells or operators. Frac crews are is short suppy in general, and especially in exploratory areas where crews
may not be readily in the area, thus, scheduling is very difficult and cannot be changed on short notice.
NEW RULE II DISCLOSURE OF WELL STIMULATION FLUIDS
(4) The administrator may waive all or a portion of (2) or (3) of this rule if:
(a) the owner or operator demonstrates that it has provided information to the Interstate
Oil and Gas Compact Commission/Groundwater Protection Council hydraulic fracturing web site;
or
(b) other Internet information repositories that can be accessed by the public.
BBC Comment:
Many companies, including hydraulic frac companies, have invested significant time and money into the ‘Frac Focus’
program which provides easily accessible, appropriate, and uniform chemical disclosure information for the public. We
believe strongly that this meets or exceeds the intent of the proposed Rule for post frac reporting and it should be
clearly stated that this is an acceptable alternative to the requirement for this rule.
In addition, BBC supports and concurs with the comments to be submitted by the Montana Petroleum Association.
Thank you.
Scot A. Donato
Scot A. Donato, P.G.
Manager, Governmental Affairs
Bill Barrett Corporation
1099 18 th Street, Suite 2300, Denver, CO 80202
303‐312‐8191 – sdonato@billbarrettcorp.com
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