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

Richmond, Tom
From: Christine O'Connor [oconnorc@gvsu.edu]
Sent: Tuesday, June 21, 2011 1:07 PM
To: DNR FracComments
Subject: Comments on the new rules
Please consider the following regarding the proposed new rules regarding hydraulic fracturing
for coal bed methane extraction.
First: Land owners adjacent to a proposed drilling site should be given notification a
reasonable time prior to the onset of drilling.
This will give land owners an opportunity to have their water or wells tested and thus
provide a base line as to their water’s quality prior to drilling.
Secondly: The rules for disclosure of compounds in the drilling fluid are not sufficient to
protect the public. Under the proposed rules an operator has simply to claim the compounds
are “trade secrets” to keep them under wraps except under the complex conditions of Rule 3.
It is hard to believe that the compounds give a significant competitive edge to an operator,
and seems much more likely that the “trade secret” exception is simply a way for operators to
keep the public in the dark. The chemicals used should be made public.
Montana is in a position to regulate hydraulic fractioning in a manner that will allow the
industry to profit, provide fuel for the nation, AND protect the public; but the currently
proposed new rules do not do enough to protect adjacent land owners, our water table, and the
general public. If the industry is to thrive, it needs public support but that will not be
forth coming unless the industry is more transparent about its operations.
Thank you for your consideration,
Chris O’Connor
1413 Ash Drive
Bozeman, MT
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