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

Richmond, Tom
From: Kathleen Williams [kathleen-home@bresnan.net]
Sent: Thursday, June 23, 2011 4:28 PM
To: DNR FracComments
Subject: comments on frac'ing rules
Tom – Thanks for your work getting draft frac’ing rules out for public review and your and
the Board's willingness to pursue this policy. I have a few comments that I hope will be
helpful.
1) Please compare your hearing and public involvement process with “best
practices” of other agencies/boards on rule‐making on controversial topics. I have heard
concerns that one hearing far away from many who would have liked to provide oral comments,
beginning at 10 am in a locale where overnight accommodations were difficult to come by, was
not a preferred manner to foster needed public input across the relevant geography. Please
evaluate approaches by both DNRC and DEQ (Board of Environmental Review), and adjust your
process accordingly. Examples may include metal mine rules, mercury rules, etc.
2) I understand improved frac’ing processes require a significant amount of
freshwater to conduct. I am not clear whether the fresh water and additional constituents
stay in the ground after frac’ing, or are withdrawn. If the latter, I would assume the
resulting water would require treatment. It would seem beneficial both for government
efficiency, landowner information, and community and natural resource planning if both the
source of the frac water, as well as the treating entity were disclosed in the permitting
and/or development process. Please include such disclosure in the rules, if that information
is not already disclosed, or explain why doing so is not a net benefit to the state, its
citizens, and industry planning.
3) In conversations about the frac’ing and drilling process, I understood that
the way the location of potable water supplies is determined (so as to avoid risk in the
frac’ing process) was the use of well logs. I don’t know if those are oil and gas well logs,
or water well drilling well logs. If the latter, I have often heard this information varies
widely in its reliability. I also understand that it is not exceedingly difficult to
determine where water (or porous rock that may contain water) is encountered during drilling.
I suggest, then, that it would help many in Montana to use the oil and gas drilling process
to learn more about subsurface aquifers, and I suggest depth and thickness of permeable/water
zones be disclosed by drillers in the drilling/frac’ing process, and that including such
disclosure in the rules be evaluated.
4) Last, I understand that if diesel is one of the constituents in the
frac’ing process that additional permits may be necessary. Please consult with EPA and
clarify this in your rules where necessary to ensure the process is clear and ensures a
predictable business climate.
Thank you for your consideration. I would welcome learning more about the oil and gas
resources and opportunities in Montana, as well as the frac’ing process in a public meeting
more accessible than the Sidney location. Whether such a meeting is required may not be as
important as whether it would be beneficial to both citizens and industry.
I look forward to your response to my suggestions.
Kathleen Williams (Bozeman)
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