Microsoft Office Outlook - Memo Style - Montana Board of Oil and Gas
Microsoft Office Outlook - Memo Style - Montana Board of Oil and Gas
Microsoft Office Outlook - Memo Style - Montana Board of Oil and Gas
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Sent via email to: FracComments@mt.gov <strong>and</strong> US Postal Service<br />
June 20, 2011<br />
Tom Richmond, Administrator<br />
<strong>Montana</strong> <strong>Board</strong> <strong>of</strong> <strong>Oil</strong> <strong>and</strong> <strong>Gas</strong> Conservation<br />
2535 St. Johns Avenue<br />
Billings, MT 59102<br />
RE: Notice <strong>of</strong> Intent to Consider Adoption <strong>of</strong> New Rules I through V Regarding<br />
<strong>Oil</strong> <strong>and</strong> <strong>Gas</strong> Stimulation<br />
Dear Mr. Richmond,<br />
On behalf <strong>of</strong> Trout Unlimited National <strong>and</strong> <strong>Montana</strong> Trout Unlimited’s 3,400<br />
dedicated members, we would like to thank you for the opportunity to comment on the<br />
proposed rule changes to well stimulation rules. Further, we appreciate your willingness<br />
to address potential rule changes, as these issues have been a topic <strong>of</strong> considerable<br />
discussion during this past year’s legislative session. In addition, the concerns about well<br />
stimulation are now gaining national attention <strong>and</strong> TU National <strong>and</strong> <strong>Montana</strong> Trout<br />
Unlimited (collectively referred to as “TU”) appreciate that the <strong>Montana</strong> <strong>Board</strong> <strong>of</strong> <strong>Oil</strong><br />
<strong>and</strong> <strong>Gas</strong> Conservation is getting out in front <strong>of</strong> this controversial topic.<br />
TU is interested in these rule changes because any activity associated with drilling<br />
for oil <strong>and</strong> gas presents potential contamination issues. Well stimulation, or hydraulic<br />
fracturing, is one element <strong>of</strong> the many phases in oil <strong>and</strong> gas drilling <strong>and</strong> as it should be<br />
with all drilling activities, fracturing must be done safely. Concerns about human health<br />
issues related to contaminated drinking waters <strong>and</strong> impacts to our state’s exemplary fish<br />
<strong>and</strong> wildlife resources remain high with the public. TU strongly supports rules that<br />
provide for public safety, while also protecting our great outdoor heritage <strong>and</strong> its unique<br />
resources.<br />
TU is closely monitoring the exp<strong>and</strong>ed use <strong>of</strong> hydraulic fracturing or “fracking”<br />
across the country, from the Marcellus Shale development in the East Coast to the<br />
Barnett Shale in North Dakota, <strong>and</strong> to the newest discovery in the Niobrara Shale in<br />
Wyoming <strong>and</strong> Colorado. We are also monitoring states that have adopted or are in the<br />
process <strong>of</strong> adopting fracking rule changes to their <strong>Oil</strong> <strong>and</strong> <strong>Gas</strong> Conservation<br />
Commissions, such as those Wyoming adopted last year (September 2010). Clearly, the<br />
1 Trout Unlimited Comments to BOGC on Hydraulic Fracturing Rules
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