Mr. Russell Harding
Director
Department of Environmental Quality
PO Box 30473
Lansing, MI 48909-7973

Dear Director Harding:

The Michigan Energy Reform Coalition is a statewide alliance of environmental organizations and local governments representing over 100,000 citizens. The goals of the Coalition are to strengthen oversight of the oil and gas industry, reduce environmental damage from development, and increase economic returns for communities and property owners.

Terra Energy, Ltd., a subsidiary of CMS Energy, has proposed to drill two Antrim shale natural gas wells within the boundaries of the Jordan River State Forest located in Antrim and Charlevoix counties. The Real Estate Division of the Department of Natural Resources has already leased two state-owned parcels adjacent to the proposed well sites, and the staff of the Geological Survey Division of the Department of Environmental Quality has recommended approval of the two well permits.

The Michigan Energy Reform Coalition opposes the approval of these permits and the leasing of adjoining state-owned minerals. We do so on the basis that allowing natural gas development in the Jordan River State Forest is shortsighted and irresponsible resource management policy that would:

1. Directly violate the Jordan Valley Management Plan, and contradict the general management philosophy of the valley.
1. Degrade one of the finest remaining wilderness areas in the lower peninsula.
2. Threaten local economies which rely on the recreational tourism the State Forest attracts.
3. Set a damaging precedent for further mineral development within the Jordan Valley.

The two gas wells recommended for approval by the Geological Survey Division are located on the east side of the Jordan River State Forest. A third well proposed by Terra Energy was denied due to its close proximity to wetlands. It is our understanding the recommendation of the Geological Survey Division regional office to approve drilling these wells is under review by the Division Chief, Mr. R. Thomas Segall. A map illustrating the area of the proposed development is enclosed.

The mineral rights beneath the two parcels proposed for development are privately owned. According to the DNR Forest Management Division there are approximately 39 additional 40-acre parcels within the Jordan River State Forest boundaries held by private mineral owners. Approval of these two wells would set a precedent that could lead to further development of private mineral inholdings and could eventually bring widespread gas development in the valley.

The DNR Real Estate Division’s lease of the two state-owned parcels next to the proposed well sites enlarges the planned development area. Inclusion of these adjacent state parcels would allow Terra Energy to place the two wells close to each other while still complying with the 80-acre spacing requirement. The state-owned parcels were leased as non-development and therefore are not a violation of the Jordan Valley Management Plan, however it should be recognized that by leasing these parcels the State has already encouraged the industry to develop within the Jordan Valley.

The Jordan River Valley is one of the most valuable and unique stretches of wild land in the lower peninsula. It comprises 22,000 acres of forested hills surrounding a picturesque river as close to its natural state as any in Michigan. The Jordan Valley Management Plan developed by the DNR in 1975 establishes that the overriding goal for the forest is to preserve its natural character. The management method outlined in the plan is focused on preserving the key values of the valley by prohibiting conflicting uses such as off-road vehicles, and heavy timber cutting. The plan clearly identifies mineral development as a conflicting use of the forest.

The following is an excerpt from the Jordan Valley Management Plan: