Citizens Allied for Integrity and Accountability

2 weeks ago

911 CALL TO ACTION - JUST 2 DAYS TO RESPOND!

FIRST:

This Tuesday, April 9 has been set as a deadline for submitting comments to the Idaho Department of Lands (IDL) regarding any objections folks have against forced pooling (being forced to allow drilling and fracking under their property against their will) for oil and gas within our Idaho communities. Even if you don't live at ground zero for current drilling operations, your home/neighborhood is still vulnerable to future activity so your input counts! We desperately need to flood their mailbox with emails over the next 2+ days. The deadline is end of day, Tuesday, 4/09 (not sure if that's 5 pm or midnight so please shoot for the earlier time just in case). Sorry for the late notice but this is typical for the timeline the state gives us to respond.

Email your comments to Kourtney Romine with IDL at kromine@idl.idaho.gov

If you can, please BC me at sb-caia@hotmail.com on your submission so we can document that these comments were sent to IDL. This is important. Thank you!

I have included a list of bullet points for you to pull from to write your letters (see below). They don't need to be long or elaborate - just pick a couple of these issues you feel most strongly about and feel free to use them, or come up with your own ideas. Thanks to our wins in court, the commission is now charged with establishing what 'just and reasonable' terms are for forcing Idaho citizens to allow drilling and fracking under their property and the extraction of the oil and gas these residents own against their will, with inadequate compensation for the profound risks they are being exposed to. These bullets are some of the most compelling requirements we will be pushing for through rulemaking in order to define 'just and reasonable'. Saying you flat don't want to see any drilling or fracking here won't carry as much weight as saying that if they're going to operate here you require the following stipulations "....". We also encourage you to ask that the changes be set through formal rulemaking as that process is ultimately what we want to see happen for several key reasons, which I won't take the time to elaborate on.

SECOND:

On April 23, at 1 PM in room EW 42 of the Capital building, the IOGCC will hold a hearing regarding CAIA's winning federal lawsuits and how the commission should proceed with future forced pooling applications based on Judge Winmill's rulings. We are working on some formal responses to this hearing with our attorney James Piotrowski and he encourages us to pack that room for the hearing - the same way we did when we filled the federal courthouse last August! We will push hard to get media there as this is our chance to really expose what's been going on with oil and gas here, the dire state of Alta Mesa's financial condition, the fact they've been acid fracking without permits and the 2 class action lawsuits filed recently against them. Please try to make it and encourage everyone you can to come too! You will be given an opportunity to testify (3 min limit), but even if you don't want to speak, just having a lot of bodies there will send a strong message to Alta Mesa, the commission and the media that we object to them continuing to use our tax dollars to fund their weak regulatory enforcement of the illegal activities of this and other operators.

This could be a defining moment in oil and gas development here in Idaho if we get enough letters in by 4/09 and bodies there on 4/23.

Thanks for your enduring support!

Shelley Brock
Citizens Allied for Integrity and Accountability (CAIA)

Kourtney Romine
Administrative Assistant, IDL
300 N. 6th St., Suite 103, PO Box 83720
Boise, ID 83720

To whom it may concern,

As a long time Idaho resident, healthcare worker, grandmother and President of CAIA, I would like to submit the following recommendations regarding how the Commission should determine terms and conditions for integration (forced pooling) orders that are ‘just and reasonable’.

On behalf of my family, fellow CAIA team members and every other Idaho resident who could potentially be impacted by oil and gas activities in close proximity to our homes, our kids’ schools, our farms, businesses, churches, parks and rivers, I would advise that the following requirements be mandated for all Idaho property owners through a formal, public rulemaking process:

All property owners shall receive permission in writing from their mortgage company prior to the start of any seismic or extraction activities or placement of supporting infrastructure

All property owners shall receive permission in writing from their insurance company prior to the start of any seismic or extraction activities or placement of supporting infrastructure and guarantee in writing that premiums won’t increase as a result of oil and gas development

All property owners shall receive pre-drilling baseline property inspection and appraisal by a licensed independent third party at operator’s expense prior to any seismic or extraction activities or placement of supporting infrastructure

All property owners shall receive pre-drilling baseline water testing with complete hydrocarbon panel to be collected and performed by an independent third party at the operator’s expense prior to any seismic or extraction activities or placement of supporting infrastructure

All property owners shall receive post-drilling water testing with complete hydrocarbon panel to be collected and completed by an independent third party at the operator’s expense at regular intervals during the life of the well and after it is plugged and abandoned

Options of hydraulic fracturing, acid fracturing and horizontal drilling shall be removed from all leases. (Alta Mesa received 2 violations in the past 4 months for recompleting one well and acid fracturing another with no permits. What guarantee can IOGCC and IDL give that they will follow laws and rules going forward?)

Publicly available documents shall show all chemicals used - with no exemptions for trade secrets - and shall provide proof that all drilling and fracking fluids are disposed of and accounted for as safely as possible

Non-radioactive chemical tracers or tagging agents unique to every well shall be used in all fluids for drilling, treating and fracking. (If groundwater contamination occurs it will destroy property values and threaten public health. Contamination must be traceable to its source and property owners should have grounds to litigate for damages. Alta Mesa has proved they will acid frack and recomplete wells without pulling permits so we require the use of tracers as standard policy in all those wells to protect citizens’ health and property values)

Stricter liability insurance and indemnification shall be mandatory with no exemptions for wells that are chemically treated whether through hydraulic fracturing, acid fracturing or any other form of well stimulation

Bond amounts shall be sufficient to cover damages for entire neighborhoods in the event of fire, explosion, water contamination and negative health impacts from flaring

Right-of-way for dangerous pipelines shall be removed from integration contracts. (It’s not just and reasonable to tell property owners they are going to pay them 12.5% royalty and then force them to accept a pipeline or other volatile infrastructure through their property too)

No hydrocarbon wells that have been drilled and abandoned may be used for class II injection of wastewater. (State regulators have repeatedly told us they will just be putting the naturally occurring water that comes out of these wells back into the porous rock reservoir where it came from. Now the state’s own public records prove this produced and flowback water is laden with toxic chemicals that pose a threat to our aquifers, surface waterways and soil. How can we trust state regulators to safely monitor the protection of our water resources and disposal of wastewater when they have been ineffective to this point?)

Property owners demand a guarantee that any delay or discrepancies in the reporting and payment of royalty payments due them by any operator shall result in the immediate shut down of those operations, unless and until the discrepancy is resolved to the satisfaction of the property owner. Repeated violations of this requirement shall result in termination of the operator’s license to do business in Idaho. (How can we be guaranteed full payment for our royalties when the IOGCC has failed to hold Alta Mesa accountable for accurate and complete production records since they first started operating here? The current class action lawsuit filed recently against Alta Mesa by Payette County property owners is the third in just 17 months against this company and 2 of those are for alleged underpayment or non-payment of royalties including 1 for alleged fraud, RICO and deceit; the third is for allegedly deceiving shareholders)

Thank you for entering these recommendations into the public record.

Sincerely,
Shelley Brock
President, Board of Directors - CAIA
Citizens Allied for Integrity and Accountability
PO Box 2622 - Eagle, ID 83616
www.integrityandaccountability.org/ ... See MoreSee Less

Photo