it is suggested that line 10 of the proposed amendment be stricken and the following be substituted therefor: "consented to the issuance of such certificate: Provided, That the Federal Power Commission shall not issue such certificate unless it finds that the storage of gas as proposed is not likely to result in hazard to persons working in any active underground mine' ".

It is my understanding that your committee desires this report at the earliest possible date in view of pending hearings on S. 525. In the circumstances, we have been unable to ascertain in advance the relation of this proposed amendment of S. 525 to the program of the President. This report, accordingly, does not constitute a commitment respecting the President's program.

Sincerely yours,

F. E. WORMSER, Assistant Secretary of the Interior.

OFFICE OF THE ASSISTANT SECRETARY of Defense, Washington, D. C., June 9, 1954. Hon. JOHN W. BRICKER, Chairman, Committee on Interstate and Foreign Commerce,

United States Senate.

DEAR MR. CHAIRMAN: Reference is made to the request of your committee for the views of the Department of Defense on S. 525, an amendment intended to be proposed by Mr. Hunt to the bill (S. 525) to amend section 7 (h) of the Natural Gas Act.

The purpose of the amendment is to prohibit the acquisition by any natural-gas company of any land or interest in land for storage of gas by contract or eminent domain unless the natural-gas company shall first have a certificate of public convenience and necessity authorizing such acquisition and consent of the State commission of the State in which land is located.

The Department of Defense has no direct interest in the procedural matters covered by the proposed amendment and accordingly refrains from comment thereon.

The Bureau of the Budget has advised that there is no objection to the submission of this report to the Congress. Sincerely yours,

R. A. BUDDEKE (For the Assistant Secretary).

UNITED STATES DEPARTMENT OF THE INTERIOR,

OFFICE OF THE SECRETARY, Washington, D. C., June 4, 1954.

Hon. JOHN W. BRICKER,

Chairman, Committee on Interstate and Foreign Commerce,

United States Senate, Washington, D. C.

MY DEAR SENATOR BRICKER: The report of this Department on the amendment intended to be proposed by Senator Lester C. Hunt to S. 525, a bill to amend section 7 (h) of the Natural Gas Act, was transmitted to your committee on May 20. In view of information that your committee desired an immediate statement of the views of this Department, the report was submitted without clearance through the Bureau of the Budget.

Subsequent to the transmission of the report on the amendment S. 525 to your committee on May 20, we have received a letter with reference thereto from the Bureau of the Budget. A copy of this letter is enclosed for the information of the committee.

Sincerely yours,

F. E. WORMSER, Assistant Secretary of the Interior.

Enclosure.

EXECUTIVE OFFICE OF THE PRESIDENT,

The honorable the SECRETARY OF THE INTERIOR.

(Attention Mr. Elmer F. Bennett.)

BUREAU OF THE BUDGET, Washington, D. C., May 27, 1954.

MY DEAR MR. SECRETARY: This will acknowledge Assistant Secretary Wormser's letter of May 20, 1954, transmitting copies of a report which the Department of has sent to the chairman of the Senate Committee on Interstate and Foreign Commerce on the proposed amendment, introduced by Senator Hunt, to S. 525, a bill to amend section 7 (h) of the Natural Gas Act.

The Federal Power Commission, in a letter dated April 28, 1954, to Senator Bricker, a copy of which is enclosed for your information, has recommended against adoption of the amendment proposed by Senator Hunt to this bill. The Bureau of the Budget concurs in the position taken by the Federal Power Commission.

Accordingly, while there would be no objection to such report as you may deem appropriate, you may wish to know the position taken by the Bureau of the Budget on this legislation.

Sincerely yours,

ROGER W. JONES, Assistant Director for Legislative Reference.

Enclosure: Copy of letter of Federal Power Commission to Senator Bricker dated April 28, 1954.

The following comments were submitted by Mr. J. French Robinson, president, Consolidated Natural Gas Co., 30 Rockefeller Plaza, New York, N. Y.:

(Page numbers refer to original transcript.)

COMMENTS ON TESTIMONY GIVEN AT HEARING BEFORE COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE, SUBCOMMITTEE No. 6, ON BUSINESS AND CONSUMER INTERESTS, S. 525, To AMEND SECTION 7 (H) OF THE NATURAL GAS ACT

(Hearing was held in Washington, D. C., on April 2, 1954)

Edward D. Schorr, representing coal producers committee on underground gas storage safety

In the first paragraph on page 94 Mr. Schorr says that, under the Natural Gas Act as it stands today, a holder of a certificate of convenience and necessity under certain conditions may acquire the property that it needs for gas storage purposes by exercise of eminent domain. I do not believe that Mr. Schorr intended to state that the present Natural Gas Act granted the power of eminent domain for gas-storage purposes; instead I think he meant that it granted the power of eminent domain for pipeline right-of-way purposes. We know of no decisions supporting Mr. Schorr's statement concerning underground gas storage.

In the second paragraph on page 106 Mr. Schorr states that he has been advised that it is never possible to accurately determine the location of storage-pool boundaries, or, consequently, the boundaries of the surface of the land under which they lie. It is necessary that the gas company know the limits of the storage reservoir, otherwise it would not be useful for storage purposes. A gas company cannot afford to import gas from the Southwest at the prevailing high prices and pump it into the ground unless it is sure that there is a closed reservoir and that the gas will no be lost. This is a matter of economy as well as one of safety.

In the last paragraph on page 107 Mr. Schorr mentions several methods by which gas may leak into coal mines from an underground storage pool. We have been operating storage pools, some of them in the vicinity of coal mines, for the last 25 years and have never experienced any leakage of gas into a mine. We condition our wells with care and carry on our storage operations in a manner which prevents gas leakage.

In the second paragraph on page 109 Mr. Schorr says, "I repeatedly heard the gas people say there are no uncharted wells." It is no doubt true that, in the area under consideration at the time Mr. Schorr heard the statement made, all of the old wells had been located and mapped by survey. We do admit that there are many wells drilled which have not been located on some particular map, but that does not say they have never been located on any map or that the wells cannot be located and properly mapped. The Peoples Natural Gas Co., operating in the southwestern counties of Pennsylvania, has well logs and surveyed locations of its 4,032 wells (1,212 still active) and logs and surveyed locations of 31,534 wells drilled in the area by other operators. In underground storage fields, whether or not they are near coal mines, it is necessary for us to locate all of the wells that have been drilled into the proposed storage reservoir and either plug them or recondition them for storage purposes; otherwise, the gas that we introduce into the ground at tremendous cost would be lost to us completely. In addition to our interest in the cost of gas by leakage, we too are vitally interested in safety. We are interested not only in the safety of miners but also in the safety of our own employees and that of people living in the storage area. We condition and plug all wells in a storage area in the very safest possible manner consistent with conditions in the area and operate the storage pools in the safest possible manner. We have not had an accident caused by the storage of gas in our 25 years' experience with underground storage.

We know from experience that, when there is complete cooperation between the gas operator and the coal operator and when both use care in their operations, both can operate in the same area without accident. We agree with the conclusion of Henry P. Wheeler, Jr., and William E. Eckard, authors of Underground Storage of Natural Gas in Coal-Mining Areas, Bureau of Mines information circular No. 7654, page 11, second paragraph, “The authors believe that the only satisfactory solution is complete cooperation between the two industries and their mutual enlightenment through free exchange of information."

Information on our storage operations is and has been available to all interested coal operators and we have found them cooperative and equally liberal with information concerning their operations. We have one engineer in our employ whose duty it is to contact the coal operators and to keep a progress map of all coal operations within the limits of our company production, transmission, and distribution operations.

In the last paragraph on page 111 we assume that the reference is to the explosion in the Hubbard Mine on January 2, 1939, which is located near the underground storage operations of the Carnegie Natural Gas Co. We would like to call your attention to the attached copies of the coroner's report, together with a report prepared by a committee appointed by the Pennsylvania Department of Mines to study and fix the responsibility for the explosion. Both the coroner's report and the report of the special committee indicate that the gas storage reservoir had nothing whatever to do with the explosion.

At the top of page 117, Mr. Schorr is quoting from a statement made by Mr. W. Dan Walker, Jr.: "There is also on record instances where gas has entered coal mines from defective gas lines on the surface." We do not know of any case where gas has entered a coal mine from a defective gas line on the surface of the ground. Our lines are carefully patrolled to guard against leakage and when a leak is found it is immediately repaired.

William B. Jamison, vice president, Jamison Coal & Coke Co., Greensburg, and chairman, Safety Committee of the Northern West Virginia Coal Association Page 126: Mr. Jamison appears to have a very good understanding of the problems involved in the operations of underground storage and coal mining in the same areas. We believe, however, that his comparison of the problem involved in the Herscher Dome underground storage area, where he quotes Mr. Remick McDowell, is not a comparable storage condition to that which we have in the Appalachian area since the Herscher Dome storage is in a waterbearing sand and not in a natural reservoir, and productive of oil or gas. We would also like to comment on some other statements made by Mr. Jamison as follows:

In the first paragraph on page 129 Mr. Jamison is referring to uncharted wells and the hazard which they create to coal mining. While it is admitted that uncharted wells have been encountered in coal mining it can be questioned as to what effort was made to chart the so-called uncharted or lost wells in the vicinity of the coal mine in question. It is a know fact that charted wells which are still producing gas and are quite visible on the surface have been cut into by mine operations. I have in mind one specific case where, at the time

an operator proposed to drill a well for natural gas and made a formal application to the operating coal company in the vicinity for a permit to drill the well, he was granted a permit and operations had commenced to the extent that he had constructed his derrick and was about ready to drill. At this stage in his operation he was notified by the coal company that the drilling of a well in the proposed location would materially interfere with their projected workings and it would be highly desirable to have the location moved some 150 feet or more to accommodate their proposed workings. The well was relocated by the engineering department of the coal company in the field and the coal company engineers even drove the stake to mark the location of the well. The gas operator tore his rig down, moved it to the changed location and completed the drilling of his well. The well produced gas for several years and suddenly ceased to produce. The gas operator was puzzled as to the cause of nonproduction so opened up the well to determine the cause. When he was unable to get the drilling tools below the coal horizon, he proceeded to pull his casing and found that the casing had been partially cut off by a coal cutting machine. The production of gas through the well was stopped by the pouring of concrete into the casing. This incident occurred and developed to this point without any notice of any kind being given to the gas operator by the coal company. My only purpose in relating this incident is to definitely illustrate that hazard from the coal company cutting into wells is not limited to the so-called uncharted wells. In this case, as previously stated, the location of the well was not only approved by the coal company but was actually made by it. If there ever is any question as to the accuracy of locating wells this one should have been accurately located and accurately mapped on the coal company's maps by their own engineering department. Furthermore, I think there is a clear indication in this case that the best solution to this entire problem is careful operation and complete cooperation of both industries. It is not a case of where one industry is entirely at fault and the other industry entirely innocent. There certainly would be a minimum of so-called uncharted wells if there was complete cooperation between the two industries and their combined information pooled and accurately mapped on a map which could be used by both industries in their future development in the area. This is especially true where underground storage of natural gas is involved with coal operations.

Further commenting on Mr. Jamisons' statements in the second and following paragraphs on page 129, relative to the improper plugging of gas wells, it is admitted that all wells have not been properly plugged; however, it is not admitted that all wells, within a gas storage pool, have not been properly reconditioned or properly plugged because, as previously stated, the gas company is as interested in the safety of miners' and other people's lives as anybody else and does everything necessary to make the underground storage of natural gas safe. The statement has been made by people who are familiar with the preparation and operation of a gas storage pool that "they would feel safer working in a coal mine located over a gas storage pool, where the wells had been located, reconditioned or plugged, than to work in a mine over an old gas field where no special effort had been made to locate, recondition or properly plug the wells."

On page 130 Mr. Jamison suggests that a well plugged by any but the most responsible parties should be drilled out and reconditioned if it is to be located within the pressurized area of a gas storage pool and we agree with Mr. Jamison. In reconditioning a well for storage purposes this company always cleans the well out to the bottom of the hole, installs the necessary strings of new highest grade casing and cements the producing string from the bottom to the top of the hole by the circulation method of cementing which insures a continuous column of concrete around the outside of the producing string. If a safer method of conditioning wells for storage areas is ever developed we will surely use that method, as safety not only to miners but also to anyone else is our first thought.

In the first paragraph on page 132, where Mr. Jamison is quoting Mr. Remick McDowell, vice president and secretary of the Peoples Gas, Light & Coke Co. of Chicago, in his article in the November 1953 issue of the magazine Better Heat, Mr. McDowell says: "Such leaks are nothing new in oil and gas fields and in fields for storage. They happen now and then despite the best drilling techniques and the utmost vigilance." We would like to say that this has not been our experience in our 25 or more years of reconditioning and operating underground gas-storage pools.

On page 133 Mr. Jamison says that it is fortunate there are no coal mines in the Herscher area as the volume of leakage was such that the operation of

a mine in the vicinity would have been endangered seriously. It does not necessarily follow that a coal mine would be endangered by a gas leak of the nature mentioned by Mr. McDowell. It is entirely possible that the leakage would find its way to the surface as easily as it would find its way into a coal mine. We know that the gas would seek that escape route which would bring it in opposition to the least amount of pressure resistance.

In the third paragraph on page 133 Mr. Jamison says: "During the early days of gas production before the gas pressure had fallen, there were a number of instances of leakage from producing wells into operating mines. I have records of 4 explosions resulting in 6 deaths from this cause."

We have no way of knowing what accidents Mr. Jamison refers to or what the conditions were which caused these accidents. We do not question Mr. Jamison's statement but merely wish to point out that he says these accidents occurred in the early days of gas production, which could have been almost 100 years ago, and we are wondering if the cooperation which now exists between some of the gas and coal companies in same areas and care in operations have not been responsible for the lack of similar accidents in later years. We contend that careful operation and complete cooperation on the part of both industries can do more to promote safety than all of the safety legislation which can be passed by either the Federal or the State governments.

In the first paragraph on page 135 Mr. Jamison is talking about drilling wells through coal for the sole purpose of releasing the gas from beneath the coal seam to make the mining of the coal safer. It has been pointed out in many places in Mr. Jamison's statement that wells producing gas through coal have made mine operations hazardous. It seems to me that there is an inconsistency in his argument that coal companies often deliberately drill wells through coal veins and tap a reservoir sealed by nature for the sole purpose of relieving the gas from that sealed reservoir to be produced through the very wells which Mr. Jamison insists make coal mining hazardous. It is a little hard for me to understand why a coal company would go to the expense of drilling gas wells through their coal 1 day, then argue the next day that the producing of gas through a coal vein makes mining hazardous.

In the next paragraph Mr. Jamison is talking about ventilation being the main factor affecting the safety of coal mines and suggests that it would be impossible to conduct a sufficient quantity of fresh air to the working face of the mine where methane is encountered in large quantities to make the gas harmless. I must repeat again that it seems to me there is one factor in the safety of mine operation almost as important as the ventilation which he mentions, and that is core in mine operations with due regard to the locations of the wells mapped, to assure that they will not be cut into during the mining operations. If the gas well is not cut into, then it will not be necessary to worry about bringing enough fresh air to neutralize the gas which might have escaped if the well were cut into.

In the second paragraph on page 136, in talking about how wells are located, plugged, and reconditioned for storage pools. Mr. Jamison says that it appears the gas people have described these operations with the purpose of impressing the coal industry with the care and skill used in actually creating and activating a storage pool. I don't believe that the description of the thorough search for old wells or the plugging and reconditioning of these wells was made to particularly impress the coal industry or anyone else. These descriptions are of actual operations, and no doubt they are impressive to those people who are not familiar with the conditioning of a gas reservoir for underground gas storage purposes. In one instance, a company operating in western Pennsylvania bought a house, at the owner's price, tore it down, and plugged an old abandoned well which had been drilled on the site before the house was erected. It was necessary in another case to arrange for the temporary removal of one wing of a large commerial greenhouse so that an old well con'd be located and plugged. We insist that all of the old wells must be located and plugged or reconditioned before a storage reservoir is ready to be used for underground cas stěraze This search for old wells has been carried on in an area where there are no enal operations so you can see that the gas companies are interested in the safety of their storage operations even outside of coal-mining areas. We have to admit that finding old wells sometimes is like looking for a needle in a haystack, but as the wise old Chinese philosopher once said, "The only thing that is required to find the needle in the haystack is to search patiently, and it will be found.”

In the first paragraph on pace 187. Mr. Jamison says: "Another argument ofter heard is that to the present time there has been no disaster such as some