April 5, 2024

The Glacier-Two Medicine Alliance (GTMA) submitted comments to the Environmental Protection Agency (EPA) opposing two disposal well permits for Montalban Oil and Gas Operations Inc. at the Jody Field 34-1 and 34-2 sites. We raised significant environmental and ecological concerns, particularly regarding potential harm to threatened and endangered species like grizzly bears and piping plovers. We argued that the increased truck traffic and industrial activities could disrupt critical wildlife habitats, potentially causing mortality or forcing animals into less secure areas.

Our comments also highlighted serious water contamination risks. GTMA is concerned about the potential for groundwater and surface water pollution from wastewater injection, especially given the area's importance as a water source for local communities and downstream regions. We pointed out the lack of comprehensive geological assessment, earthquake risk evaluation, and insufficient disclosure of the chemical content of the wastewater. Additionally, we criticized the potential burden on Pondera County, which would bear the infrastructure and safety costs without receiving any financial benefits.

Ultimately, GTMA urged the EPA to deny the permits, emphasizing that a better alternative exists. We recommended that Montana Renewables expedite the construction of a wastewater treatment facility instead of using injection wells. GTMA argued that this approach would better protect wildlife, water resources, and local communities while supporting renewable energy goals. We also raised concerns about the lack of meaningful tribal consultation and the potential for cumulative environmental impacts from future well conversions.

GTMA submitted additional comments and suggestions in our letter to the Environmental Protection Agency. To learn more about our views, read the full comments here.