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Testimony of Rob Prince/Senior Lecturer of International Studies/University of Denver Graduate School of International Studies to the Colorado Oil and Gas Conservation Commission/Grand Junction Colorado

October 2, 2007

Dear Commission Members:

Thank you for providing me the opportunity to give testimony before your body concerning the request of Noble Energy to drill for natural gas within 3 miles of the Rulison nuclear weapon blast site. And thank you Kim Phillips for your willingness to read my testimony (or part of it) to the Commission.

I teach International Studies at the University of Denver’s Graduate School of International Studies. One of my areas of interest is the political economy of the energy industry (worldwide). Recently, with a colleague from the University of Barcelona, Dr. Aurelia Mane Estrada, I taught a special seminar entitled `Energy Development and Democracy’ that was a combined graduate-undergraduate level course the main focus of which was the structure of the global energy industry – both oil and gas. I have taught a number of courses that looks at energy development specifically in North Africa (Algeria), which is a long time special interest.

I should like to say that 38 years ago in early September of 1969, at a time when I was a graduate student at the University of Colorado in Boulder, that I joined a group of protestors in an effort to stop the detonation of a 43 kiloton nuclear weapon 8426 feet below the surface at Rulison, Colorado. Although it is incidental, it so happens that I met my wife to be at that site, she, who was upset of the effect that the blast would have on `her mountains’. My concern at the time was that any natural gases flowing into the cavity thus created would be contaminated with radioactivity and therefore not viable for commercial use. I was also concerned about the possibility of the blast itself causing earthquakes in the surrounding area. My understanding is that these concerns were justified and remain valid

It was only a few years later that I familiarized myself in some detail with the broader project entailed `Project Plowshare’ of which Project Rulison was simply one small part. As I assume you are aware, there was a four stage program – Project Gasbuggy, Project Rulison, the Rio Blanco Project, and Wagon Wheel – which together were meant to use nuclear explosions to produce commercially viable natural gas. The first three involved the detonation of nuclear weapons; Wagon Wheel, scheduled to take place in S. Central Wyoming was cancelled.

The project was – in every sense – a failure and we – the people living in the Rocky Mountain Region have been living with the consequences ever since.

My request to this board is simple and in two parts:

1. That you deny Noble Energy’s request to drill within the three mile radius of ground zero of Project Rulison
2. That you consider revoking the 19 permits that already exist to drill within the same three mile radius.
3. That the Department of Energy be more forthcoming about the information that it has in its position on the Project Rulison site and that state of Colorado improve its monitoring capacities which seem rather limited.

The basic argument for taking this position gravitates around public safety issues and what I would describe as the need in this situation to put caution before profits.

Drilling within the 3 mile zone is extraordinarily imprudent and opens Garfield County and the surrounding areas to risks of nuclear contamination.

Why play with fire when the stakes are so high, the variables so unclear?

My reasoning is as follows:

1. Some natural gas drillers, unwilling to accept restrictions on their drilling rights are arguing that the 3 mile `danger zone’ is arbitrary and not based upon a scientific known calculation. In a certain way, they are correct. But what is interesting is how they interpret this arbitrary measurement. One could logically argue that because the 3 mile danger zone is not clear that it should be extended to a 5 or even a 10 mile radius, and in so doing, placing caution before greed.

The industry has chosen, it appears, and certainly not for the first time, to go the opposite route and place greed before caution. They want to penetrate the 3 mile danger zone, drilling ever closer and closer to the blast site. As they do, the danger of mining radio active natural gas from the blast site increases considerably.

2. It is simply irresponsible – and cynical – to argue that drilling in the vicinity of the site of Project Rulison site is safe. Fissures (cracks) in the sandstone surrounding the blast site could currently exist, or given the continual movement and motion of the underground structures, possible in the future. Recently local residents discovered a leakage of natural gas (not Project Rulison related) into a nearby creek. The leakage was traced to a nearby drilling site which, it had been argued, was secure. Was the drilling company lying outright about the environmental impact or was it simply that their technical abilities, despite many claims of great advances, simply couldn’t pick it up?

3. There is still no clarity as to how much low level radiation is considered safe.What we do know, thanks to the pioneering work of Rosalie Bertell and others, is that the dangers have been irresponsibly – if not criminally – understated. More and more the scientific community is coming to the conclusion that there are no `acceptable’ amounts of low level radiation. Substances with half lives of a half million years will be toxic for here to eternity, or nearly.

4.Add to that the state’s (Colorado’s) admission that their own monitoring capabilities are lax, how difficult it is to track down federal monitoring results and the `safety’ arguments quickly. It is completely unacceptable that the major monitoring of radiation at the site is done by the commercial enterprises doing the drilling. I’d like to believe that such self-monitoring is serious but experience suggests that independent monitoring – with results shared with the public – is a far more prudent path to take.

5. Given the lack of transparency in monitoring, we simply don’t know how much radiation has escaped from Project Rulison – nor how much might be unleashed in the future.

6. From the point of view of history – not a petty detail – Project Rulison (along with Project Gasbuggy and the Rio Blanco Project – three of the four energy related projects of Project Plowshare to detonate underground nuclear blasts in conjunction with the oil and gas industry) was a colossal failure, nothing less. It was a reckless and ill conceived project that has mauled the mountains in Colorado and New Mexico and would have done untold damage to Wyoming as well had Project Wagon Wheel gotten off the ground which fortunately enough it did not.
The futility (and absurdity) of the program is reflected in the fact that not one cubic foot of gas has been extracted from the three blast sites for commercial uses until the present and that the last phase, Project Wagon Wheel, which in terms of kilo-tonnage would have been the grand finale – was cancelled. It seems – at least in the 1960s and 1970s that customers declined to natural gas contaminated with traces of radioactivity.

Noble Industries should be prohibited from drilling near Rulison and should seek its fortune on more stable grounds. Let us hope that the Colorado Commission on Oil and Gas has the common sense and decency to reject Noble’s request. Wish I could be in Grand Junction on Tuesday to testify, but can only be there in spirit through this testimony

I urge to not to let this genie out of its bottle any more than you already have. There are many other places in the Colorado mountains to drill for natural gas, more safely and without such grave environmental consequences.

Yours Sincerely,

Rob Prince
Senior Lecturer/International Studies
University of Denver/Graduate School of International Studies

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