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

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Bradley B. Shepard -- Brad Brad Shepard, PhD Senior Aquatic Scientist Wildlife Conservation Society - Yellowstone Rockies Program Affiliate Assistant Professor - Montana State University-Bozeman 65 9th Street Island Drive Livingston, Montana 59047 t + 1 406.223.3011 bshepard@wcs.org shepard.brad@gmail.com 2
Mr. Tom Richmond 65 9 th Street Island Drive Department of Natural Resources and Conservation Livingston, Montana 59047 2535 St. Johns Avenue shepard.brad@gmail.com Billings, MT 59102 June 22, 2011 Via e-mail to: FracComments@mt.gov Enclosed are my 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 want to stress that I am commenting as a private citizen who lives in Park County, Montana. NEW RULE II – I believe disclosure of each chemical constituent used should be required in ALL cases. I think these should be listed in an “easy-to-find” web site location that is either housed in a Montana government website or is clearly linked via a Montana government website and can be easily searched to find it. NEW RULE III – I do not support the option of a company choosing NOT to disclose a chemical compound. I strongly believe that public safety and our Montana constitutional “clean and healthy” environment rights demand full disclosure. I believe it is reasonable to require all companies to disclose the constituents of any compounds they use, but not require them to reveal the exact make-up of these compounds. This would allow companies to maintain proprietary compounds while allowing the public and government regulators to know what chemicals to sample for to investigate for potential environmental contamination and to protect human health. NEW RULE IV – I fully support maintaining the structural integrity of all well casings and believe this is an important rule. I have several additional comments. First, I think that Montana should require companies to use “closed” systems for all projects that can use make-up water, but that does not allow for fluid ponds in an open environment. Pond seepage and pond failures have occurred, allowing fracturing fluids to leach into ground and surface waters that may be used for domestic, agricultural, or municipal purposes. Secondly, I recommend that bonding of both exploratory and commercial natural gas fracturing operations be done at a level that ensures sites could be totally reclaimed. Lastly, I believe it is imperative that additional public hearings be held throughout other areas of Montana. A single hearing in Shelby, Montana is woefully inadequate to address the concerns of the citizens of Montana. Thanks for your consideration. Sincerely, Bradley B. Shepard
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issue of fracking has garnered a gr
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Montana should be taking a more pro
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Tom Richmond, Administrator Montana
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Comments regarding New Rules I thro
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NEW RULE I WELL STIMULATION ACTIVIT
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(2) Prior to initiation of fracture
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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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Microsoft Office Outlook - Memo Style - Montana Board of Oil and Gas

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