P.O. Box 339 Sidney, Nebraska 69162-0399 Re: Case Number 14-14: In the matter of the application of the Terex Energy Corp for approval to convert the Laucomer 13-1, located at 25N/56W in the NE NW Corner of Sec. 13, in the Spotted Tail Creek Field in Sioux County, Nebraska, for use as a salt water disposal well, in accordance with Chapter 4 of the Rules and Regulations of the Nebraska Oil and Gas Conservation Commission. Dear Commissioners: Thank you for this opportunity to comment. This letter is to convey my position that the Commission should not take action on this application until all of the relevant factors have been taken under consideration. This well is located in an environmentally sensitive area in Nebraska. As a Commission you have not been presented with a case that involved the great volume of produced water proposed to be injected into the subterranean in Nebraska as will be done by this proposal. It is incumbent upon the Commission to perform due diligence that this application will not have a long term adverse impact on the precious water supply in western Nebraska. This involves the safety of both underground water and surface water supplies now and in the future. I am very concerned that the Commission has no means to fund the monitoring that will be required for the future to assure the safety of the ground water. Moreover, how would any repair of future environmental damage be accomplished and any clean-up funded? The second major concern raised by this application is the truck traffic, and damage to Nebraskas roadways and public safety issues raised by the proposed route through several cities in Nebraska. It is estimated by the Nebraska Department of Roads that it will require some $6.5 million dollars to address the roads problems. The Commission should have clear authority to address these concerns as it addresses this application.
Considering these issues, I will introduced a study resolution in the Nebraska
Legislature to consider the adequacy of the Oil and Gas Commissions statutory authority in the area of the disposal of waste water. The Natural Resource Committee and its staff will be given the authority to study, investigate and make recommendation concerning the Oil and Gas Commissions authority and role in these critical decisions. I look forward to working with the Commission, the Commissions staff and other parties. The product of this study will, if found necessary, be recommendations for new statutory authority to regulate produced water disposal wells. This study will address what should be done to protect the environment, our surface and underground water supply and public safety.
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