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

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Richmond, Tom From: Peter Fox [colfox@tds.net] Sent: Tuesday, June 21, 2011 6:40 PM To: DNR FracComments Subject: Comment on new rules for oil, gas well stimulation Attachments: Peter Fox_New Rules I through V regarding oil and gas well stimulation_6-21-2011.pdf; ATT00001.txt Please accept the attached comments. Peter D. Fox 1
Mr. Tom Richmond Department of Natural Resources and Conservation 2535 St. Johns Avenue Billings, MT 59102 Via e-mail to: FracComments@mt.gov 157 Falls Creek Road Livingston, MT 59047 June 21, 2011 Please accept these comments regarding the adoption of New Rules I through V regarding oil and gas well stimulation as noticed in MAR Notice No. 36-22-157. I will directly address the proposed rules and wish to make an additional comment at the end of my this communication. New Rule I: I support the rule as written. New Rule 2: I do not support the inclusion of Paragraph (4) and the subparagraphs (a) and (b). In the interests of the most complete public access to pertinent information, there should be no waiver provision. Additionally, a Montana state government Web site (preferably maintained b the Montana Department of Natural Resources and Conservation) should be the primary site for Montanans to access Montana-specific information. While the sites maintained by the Interstate Oil and Gas Compact Commission/Groundwater Protection Council are significant, a Montana state government site should be the primary repository. New Rule 3: I object to this rule in its entirety. There should be no trade secret provision. However, it would be marginally acceptable to require disclosure of a specific chemical presence but allow the withholding of the exact percentage of content within the total hydraulic fracturing fluid volume. The requirement for a health professional to agree to a non-disclosure provision is, in my mind, unethical and morally repugnant. I also believe an unintended consequence of this provision may be to invite legal challenges and subsequent costs to be imposed on Montana state government. To put the non-disclosure provision in another context, if a citizen group or municipality is interested in monitoring its water sources for safety reasons, keeping the identity of a particular chemical(s) would completely thwart this public health safeguard because the community would not know for which specific chemical(s) to test. New Rules 4 and 5: I support all efforts by DNRC to ensure the integrity of well casings. As an additional comment, I urge that consideration be made in future rule-making in require or otherwise encourage closed-system drilling methods as means of protecting surface environments, protecting aquifers and conserving water resources required in hydraulic fracturing. The industry itself is embracing this technique.
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Page 186 and 187: Tom Richmond, Administrator Montana
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Page 202 and 203: Comments regarding New Rules I thro
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Page 246 and 247: NEW RULE I WELL STIMULATION ACTIVIT
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(c) the amount and type(s) of mater
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NEW RULE V WORK-OVER, RECOMPLETION,
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June23,2011 Submittedviaemail:FracC
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WesternEnergyAllianceCommentsNewrul
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Richmond, Tom From: Becca Fischer [
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Deep Gas Drilling in Sweet Grass an
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New Rule IV - Safety and Well Contr
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LegendGas Leases 2008 - 2010 Privat
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Clay Treat LT PH-16L Superior Well
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since traced the methane in the aqu
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Bradley B. Shepard -- Brad Brad She
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Richmond, Tom From: Kate Rossetto [
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