PA House Bill 2213 Oil and Gas Legislation Pennsylvania

The following are my comments related to PA House Bill 2213 - the full text of the regulations can be found at the following website.

1.I like the provisions for inspections - but does the PADEP field staff have the training they need and do they have the tools and equipment to really inspect a cement seal that is 2000 feet down?  Therefore, the bill should require certification by the driller and a third party inspection service- paid by the Gas Company.

2. Fees should cover the cost of inspections, additional water testing, responding to complaints, etc - the full cost of the program.

3. I am ok with the 2500 foot from the drilling pad, but there are no provisions for the horizontal leg of the well and the 6 month time frame is inadequate. Point groundwater moves slowing - less than 0.1 ft per year to 3 ft per day - I would recommend at least 1 year to 2 years may be better.

For the horizontal leg, the gas companies can create fractures out 100 to 400 feet from the horizontal leg. Therefore, the testing zone should be 2500 foot, plus at least 100 foot on either side of the horizontal leg of the well. This could be adjusted based on the final report for the well when the company reports the extent of the horizontal fracturing.

4. Section 4 - if the specific chemical composition can not be disclosed the trade name should be released, MSDS sheet, and volume of the chemical used. All this information should be disclosed in the permit application and in a well completion report that is submitted for each well in a timely manner.

This information should also be available at the municipality were the well is located- so the public has access.

5. Bonding requirements seem better. Also - I support that no blanket bonds be issued for the Marcellus Shale and each well not drilling pad should be considered as a well.   Therefore, a drilling pad with 6 wells should be six bonds.

6. Local ordinances should be permitted to control or prevent installation of well, temporary structures, or permanant structures in floodplains. Plus local agency should control nuisance issues, road bonding, road use and access, and the accessory development that will likely occur, such as field offices, temporary septic permits, holding tanks, etc.

7. Regulations should apply to Marcellus Shale and other other formations where the development technique is depolyed.

Thanks Brian Oram, PG B.F. Environmental Consultants Inc. 15 Hillcrest Drive Dallas, PA 18612 Thanks for your leadership