February 12, 2014
Sent via email and attachment
Idaho Department of Lands
Boise Staff Office
P.O. Box 83720
Boise, ID 83720-0050
Director Schultz and IDL staff,
On behalf of over 2200 members of Wild Idaho Rising Tide (WIRT), I respectfully offer and request inclusion in the public record of these comments concerning the application submitted to the Idaho Department of Lands (IDL) by Trendwell West, Inc. (“Trendwell”) requesting permits to drill the Smith 1-10 well, the first recently proposed oil or natural gas well in Canyon County, Idaho (LU600553 Trendwell West Application for Permit to Drill 2-12-14).
WIRT activists oppose permitting, drilling, and potential hydraulic fracturing (“fracking”) of the proposed Trendwell West Smith 1-10 well, due to the inadequacy and incompleteness of Trendwell’s plans submitted for public review and the potential impacts of the well and its development on human and environmental health and safety. Considering that corrections to the original, posted application, compelled by Trendwell’s non-compliance with the IDL instructions stated in the application, and additional documents such as the Surface Use Agreement, are currently missing and thus unavailable for public review during the comment period before potential IDL permitting of this application, we request that, if the Trendwell application to drill the Smith 1-10 well is modified or augmented in any way, the Idaho Department of Lands re-open the comment period for this application. Failure to post this revised application and re-open its public review violates section 51 of IDAPA 20.07.02 Rules Governing Oil and Gas Conservation in the State of Idaho.
We are also concerned that permitting and subsequent drilling of the proposed Smith 1-10 well would result in pollution of fresh water supplies, as described in section 50 of IDAPA 20.07.02 Rules Governing Oil and Gas Conservation in the State of Idaho, and thus would require IDL permit denial. Despite the precautions outlined on page 11 of this Trendwell application, entitled Site Preparation and explaining limitations on well and well pad discharges under normal operating conditions, no description appears in this application stating how Smith 1-10 well operators will handle accidental or incidental releases of polluting fluids or emissions that could contaminate the surrounding environment and inhabitants and the active, open, irrigation water canal that flows around three sides of the proposed well and well pad. Trendwell would drill the oil wildcat well, targeting a 5,200-foot-deep reservoir, only 400 to 442 feet from the nearest boundary line or center line of the D Line Black Canyon Irrigation District canal. Such proximity to irrigation structures ensures that any saturated soil conditions or flooding events involving the well pad and nearby irrigation water systems will impact the individual and shared rights and water resources of downstream water users. These potentialities and emergency contingency considerations are addressed nowhere in this application.
More troublesome, if not eventually legally undermining of any split-estate agreements, is the distance of Trendwell’s proposed Smith 1-10 well from downslope and down-gradient structures that substantively determine the value and insurability of the private property overlying subsurface mineral holdings of separate ownership. Trendwell’s apparently exploratory drilling endeavor would impose associated hazards only 450 feet from a domestic water well and 525 feet from an existing residential dwelling. Even in states long ravaged by oil and gas industry snafus, like Pennsylvania and Colorado, responsible local and state agencies have approved minimum setback distances of 1000 feet between wells and these crucial private structures. Considering the ongoing, on-site storage and utilization of chemical additives, caustic soda, and worker respirators, besides the usual slurry of volatile and toxic substances constituting most drilling muds, closer well development displays reckless disregard for peer-reviewed science that recommends half-mile setbacks, and demonstrates a perspective of Idaho citizens as collateral damage.
Obvious to only cursory examination, several components of this Trendwell application to drill the Smith 1-10 well appear absent. Enclosed maps do not show topographic contour lines around private structures and their downhill relationship to the well and possible paths that surface spills could take if they occur. None of the included maps clearly indicate the entire 720.876-acre Trendwell lease stated in the application or describe the position and size of the unit or portion designated for drilling and producing within the overall lease boundaries, as required by the IDL application instructions. Geological profile information is also inexplicably redacted, thus disallowing public deliberation of potential underground interactions between oil, gas, geothermal, and water reservoirs and well structures, which could compromise the integrity and viability of some or all of these resources.
WIRT members also question the placement of Trendwell’s proposed Smith 1-10 well so close to active geothermal resources being developed for electricity generation. Within the subsurface contexts of elevated temperatures over 200 degrees Fahrenheit, why would any driller expect “the potential for significant whole mud losses,…especially in the shallow hole intervals and through any volcanics”? In the fifth most seismically active state, placing well casings and cementing that, on average, typically deteriorate to the point of leaking within 30 years further threatens well integrity and the possibility of nearby groundwater contamination. Omitting descriptions of the locations and present conditions of aquifers and nearby water wells from this application for the proposed Smith 1-10 well could discount and risk pollution of fresh water supplies. Such neglect also violates section 50 of IDAPA 20.07.02 Rules Governing Oil and Gas Conservation in the State of Idaho.
The drilling plans and practices outlined in the Trendwell West application for a permit to drill the Smith 1-10 well ignore and jeopardize the clean water and air and environmental and human health and safety that predicates Idahoans’ vital and cherished quality of life. State agency decisions and officials paid to serve the public’s best interests should not compromise Idaho oil and gas laws to accommodate corporate and state profit and greed in counties without sufficient protective ordinances. Wild Idaho Rising Tide requests that the Idaho Department of Lands rejects, or at least requires revision and extended public review of, this Trendwell application, to ensure the best stewardship of Idaho’s priceless and irreplaceable mineral assets and the private and public resources their mismanagement could impact.
Thank you for your consideration of these comments and your accordingly responsive actions,
/s/ Helen Yost
Wild Idaho Rising Tide
P.O. Box 9817, Moscow, Idaho 83843