Comment on FR Doc # 2012-15557

Regarding proposed Federal regulations on hydraulic fracturing. Dear Sir or Madame, I largely support the proposed new regulations for hydraulic fracturing on BLM and Indian lands. I am an oil and gas professional engineer and have been involved in designing, permitting, and executing hydraulic fracture treatments on a variety of mineral ownerships. The rules being proposed are not very much different than those adopted by the State of Wyoming and others. One item that I strongly agree with is the requirement for a pressure test to the maximum pressure anticipated during the frac treatment. Additionally, documenting the disposition of flowback liquids is a reasonable requirement. I disagree, or would like clarification set out in the regulations, on the following points: 1.Section 3162.3-3(a)(2) requirement for cement bond log. This section appears to require a cement bond log (CBL) of the surface casing and identification of shallow water aquifers. Logging the surface hole interval for fresh water is many times not practical due to the lack of strength in surface casing intervals (typically drilled from 500' to 2000'.) A requirement to observe cement returns to surface would accomplish the same objective and not add potential for "losing the hole." Cement returns not observed at surface could be cause to then run a CBL. A CBL should be required for the casing interval immediately above the reservoir interval proposed to be stimulated (either the intermediate casing or production casing) to verify cement isolation. A minimum requirement could be ~500' of logged cement bond, not necessarily continuous. 2.Section 3162.3 (f)(10) This requirement is redudent to State or Federal laws already concerning oilfield wastes. If this section is required, then a defined 'end' to flowback is needed.1 day?10 days? The rule could be read that any frac'd well's produced water will have to be eternally recorded in sundry forms. Regards, Preston Evans