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

Richmond, Tom
From: Svein Newman [svein.newman@gmail.com]
Sent: Thursday, June 23, 2011 2:29 PM
To: DNR FracComments
Cc: Richmond, Tom
Subject: Hold a second hearing!
To Whom it May Concern,
Though Sidney is a reasonable place to hold a public hearing on oil and gas, it cannot be a reasonable sole location for a
hearing. As you well know, Montana is a large state. A drive from, for instance, Libby to the Sidney hearing would take
over 12 hours. It is unreasonable to expect landowners, often working farmers and ranchers, to make that drive. And,
when it is their property that would be affected by spills, breaks, etc., it is their voices that deserve to be heard. As fracking
heads west in Montana (as it becomes a more and more prevalent technology, and more and more of the state is leased
for drilling), those voices will increasingly matter.
Given this, a second hearing must be held, preferably in a more central community that can more readily accommodate
travelers- Billings, for instance. As the home of the Board of Oil and Gas, this shouldn't seem like too unreasonable a
request.
I would also like to take this opportunity to lodge some other concerns I have. Prior notification for landowners of all
chemicals that are to be used is critical, as they need to be able to do baseline testing. Any landowners within 1 mile
should be given written notification prior to drilling.
Also, the rules need to be strengthened. "Trade secret" exemptions leave the rules much weaker than they otherwise
could be. You should adopt a process like Wyoming's, where companies have to apply to their Board of Oil and Gas and
actively provide a reason for any trade secret exemptions. Additionally, even if the chemical is listed as a trade secret, it
is still disclosed to the Board of Oil and Gas but not the public.
There's another place where the rules need to be strengthened as well. The exemption from disclosure if the company
posts any information to the IOGCC website or any other public internet repository is a poor one- it risks leaving
landowners hunting in the dark across multiple sources. All chemicals should be posted on the BOGC website.
In short- we need strong rules. No exempt wells (exploratory, wildcat, or otherwise). No blanket trade secrets. No diffusion of data to
the point where it becomes unfindable in practice, if not in theory. No waiting until landowners' water is already possibly impacted
before giving them the information they need to establish baseline data.
Thanks for your consideration,
Svein Newman
44 Alderson Ave.
Billings, MT 59101
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