With the recent spike in energy prices, shallow well drilling activity for Antrim Shale gas deposits has also markedly increased in recent months. Merit Energy, which took over from Shell the deeper Niagaran Reef operations within the original "Consent Order" agreement portion of the Pigeon River Forest, agreed not to pursue Antrim Shale gas.

However, a number of more recent developments have us all worried. One is the fact that some companies are pursuing state permission to "double dip" as it were, by drilling new Antrim wells from existing Niagaran well sites. If Merit were to pursue this course, it would prolong the gas & oil industry's presence within the forest for many more years. We are determined not to let this happen.

The second worry concerns lands added to the forest since the "Consent Order" agreement -- particularly the Green Timbers tract on the west side of the forest and the Blue Lakes tract on the East. The Fontinalis Club property, which reaches deep into the heart of the Green Timbers, already has twenty-some Antrim wells, most of the them placed as close as legally possible to the borders of the state-owned property. Although not all the mineral rights to the Green Timbers are owned by the state, most of that tract -- which is closed to all motorized vehicles -- has not been leased for any drilling activity. However, there is likely to be a move to change the status of the properties around the edge of the tract to "non-development leases", so that the state will receive the royalties that are justly due from the gas that is being most likely drawn from under state land when wells are placed so close (in many cases within 300 ft.) of the boundaries. This concern sounds reasonable enough until one remembers that what sometimes gets leased as "non-development" (as has been the case in some of the northern regions of the Pigeon River Forest) for one reason or another gets reclassified as open for development. This too should not happen.

Unfortunately, the state was not able to acquire the mineral rights to the Blue Lakes tract when it was purchased back in the late 1980s. In the late 1990s, a firm representing the mineral rights holder announced it intended to develop an Antrim well field within the tract as well as the square mile of privately-owned land to the south (just north of the Town Corner Lake campground). At the time, the Advisory Council put up great resistance, especially since the Blue Lakes tract had also been set aside as a largely (with the exception of snowmobiles) non-motorized quiet area. Because of the Council's resistance, the difficulties involved in getting permission to cross the Black River with a pipeline, and the questionable profitability of trying to develop an Antrim field that far north of most of the other Antrim field activity, the effort was abandoned, and the hint dropped by the potential operator that perhaps the state would be better off treading some mineral rights on other state-owned land where drilling prospects looked more promising in exchange for the Blue Lakes mineral rights. However, apparently the hint was never pursued -- probably because it has become the state's policy to avoid separating any of its existing mineral rights from its land ownership. If so, now it may be too late, as a new Antrim field is being developed just east of Blue Lakes across the Black River on private properties.

All this suggests two things: First, there would seem to be a great need that new "updated" Concept of Management of the Pigeon River Country Forest specifically forbid any reclassification of "non-development" leases within the forest lands to the "development" category. Second, that the "update" must include a either a mandate that the state must do all that it can to acquire the mineral rights within the present forest boundaries, or, develop new well operation

requirements, such as restriction of wells to one per quarter-section (160 acres) -- something the prospective operator on the Blue Lakes tract admitted they could live with -- and the location of any compressor stations only after extensive consultation with the Advisory Council and other affected parties.