SUBMITTED via ELECTRONIC MAIL
September 10, 2012
Bureau of Land Management
Re: Comments on Proposed Rule on Oil and Gas; Well Stimulation, Including Hydraulic
Fracturing, on Federal and State Lands
Dear Acting Director Pool:
Please accept these comments on the Bureau of Land Management’s proposed rule to
regulate hydraulic fracturing on public land, Indian land, and private land overlying
federal minerals, published in the Federal Register on May 11, 2012 at 77 Fed. Reg.
27691, on behalf of Earthworks.
Earthworks is a nonprofit organization dedicated to protecting communities and the
environment from the impacts of irresponsible mineral and energy development while
seeking sustainable solutions. The organization fulfills its mission by working with
communities and grassroots groups to reform government policies, improve corporate
practices and influence investment decisions. Earthworks has been working specifically
on hydraulic fracturing issues for more than a decade.
Attached, please find two documents. First, comments prepared for Earthworks by Mary
Ellen Denomy, CPA, certified petroleum accountant, that address the issue of the
potential compliance costs associated with the proposed rule. Second, a copy of Ms.
Denomy’s CV is also attached.
Thank you, and we look forward to seeing a revised final rule that fully addresses the
P.O. Box 1102
Durango, CO 81302