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

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Richmond, Tom<br />

From: Barbara & Tom [archtul@bresnan.net]<br />

Sent: Saturday, June 11, 2011 12:36 PM<br />

To: DNR FracComments<br />

Subject: RE Need for Fracking Transparency<br />

To the <strong>Montana</strong> <strong>Board</strong> <strong>of</strong> <strong>Oil</strong> <strong>and</strong> <strong>Gas</strong> Conservation:<br />

Protection <strong>of</strong> trade secrets should not supersede l<strong>and</strong>owners <strong>and</strong> the public’s right to know.<br />

Allowing drillers to list natural gas fracturing (known as fracking) fluid ingredients as<br />

“proprietary” or as “non hazardous ingredients” is irresponsible at best <strong>and</strong> potentially<br />

criminal in a worse case scenario. It is critical that the State <strong>of</strong> <strong>Montana</strong>, as well as the Federal<br />

government step up to the plate <strong>and</strong> require written notice <strong>of</strong> fracking chemicals to<br />

l<strong>and</strong>owners, as well as public disclosure <strong>and</strong> chemical information to emergency workers.<br />

Wyoming has recently, through a rule‐making process, begun disclosure <strong>of</strong> fracking fluids with<br />

great success <strong>and</strong> few complaints from the industry. This is a common sense protection for the<br />

health <strong>of</strong> our citizens. And if the fracking fluids are safe, as industry claims, disclosure will<br />

show that. And if they are suspected <strong>of</strong> causing a health problem or <strong>of</strong> contaminating a well,<br />

aquifer, or surface water, it is critical that l<strong>and</strong>owners <strong>and</strong> all other affected citizens as well as<br />

local government <strong>of</strong>ficials <strong>and</strong> other government <strong>of</strong>ficials are wholly aware <strong>of</strong> the chemicals in<br />

question so as to be able to formulate the correct remedial response.<br />

In fracking, 435 chemical products are known to be used. Out <strong>of</strong> that, only 5% <strong>of</strong> the specific<br />

chemicals have been publicly disclosed. Fracking fluids have been known to travel 3,000 feet<br />

away from a drilling well. While there is an effort to bring fracking fluids back to the surface<br />

<strong>and</strong> properly dispose <strong>of</strong> them, between 20‐70% <strong>of</strong> the fluids remain underground. It’s possible<br />

that l<strong>and</strong>owners <strong>and</strong> others in a natural gas development area will have to deal with the<br />

repercussions <strong>of</strong> injecting tons <strong>of</strong> hazardous chemicals into the ground long after the gas wells<br />

have run dry. They at least need to know what it is that they may be facing in the future.<br />

Cc: Senator Baucus, Senator Testor, Rep Rehberg<br />

Sincerely,<br />

Tom Tully <strong>and</strong> Barbara Archer<br />

2210 Pryor Ln<br />

Billings, MT 59102<br />

archtul@bresnan.net<br />

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