Comment on FR Doc # 2012-11304

Document ID: BLM-2012-0001-0007
Document Type: Public Submission
Agency: Bureau Of Land Management
Received Date: May 15 2012, at 11:07 AM Eastern Daylight Time
Date Posted: May 18 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: May 11 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: September 10 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 8100f015
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Adequate Interior Department Rules must require the disclosure of the fluids used in hydraulic fracturing prior to the fracturing operation and certify that the proposed stimulation fluids do not represent a threat to health and safety and when spilled, leaked and dumped cause undue degradation of the public lands. The reporting of this information after the frack does not help protect health and safety or prevent the unnecessary or undue degradation of the public lands. Filthy flow-back frack fluid containing hydrocarbons and "proprietary" additives and other components degrade surface and ground water when they are released without treatment. In Colorado, a frack spill, leak or dump occurs most every day totaling over 4 million gallons a year (Colorado O&G Com. filings). Eliminating the threat to our environment is best accomplished by banning and prohibiting the degradation before creation. The Proposed Rules fail to estimate the future benefits of banning toxic and lethal additives and do not include such benefits as avoiding harm to water users that cannot be compensated by later providing alternative water sources. The longer term liability of homes, ranches, farms and water supplies rendered "useless" "unusable" and "uninhabitable" have not been disclosed on Fracker Financials and are not adequately covered by existing Fracker Bonds. Estimates of long term liabilities from toxic and lethal frack additives must consider the migration of sub service frack and the acceleration of this fracking migration through earth tremors (often precipitated by ground/fluid injection). The future liability from the tens of thousands of Fracked Wells filled with migrating toxins may dwarf Colorado's infamous Summitville Cyanide Water Poisoning. Protection of all usable water during drilling operations, not just fresh water is greatly needed and appreciated.

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