Mon 30 Dec 2013
Just take a look at all the gaping holes the other extraction industry have left in Illinois. Their are parts of Illinois that look like the 10,000 lakes area in Minnesota that used to be valuable farmland. This will be no different.
Day 46 12/30/13
Topic: Topsoil Replacement Requirements
- Go to: http://www.dnr.illinois.gov/OilandGas/Pages/OnlineCommentSubmittalForm.aspx
- Click the button: Subpart D: Well Site Preparation
- In the “Section” dropdown box, click: Section 245.410 Access Roads, Public Roads and Topsoil Conditions
- Submit your comment/s (below)
- Click “Submit”
Sections 1-70(b)2 and 1-95(c) of the Hydraulic Fracturing Regulatory Act state that stripped topsoil is to be replaced with similar soil and the site returned to its pre-drilling condition.
Section 1-95(c) of the Act specifically states: “The operator shall restore any lands used by the operator other than the well site and production facility to a condition as closely approximating the pre-drilling conditions that existed before the land was disturbed for any stage of site preparation activities, drilling, and high volume horizontal hydraulic fracturing operations.”
When drilling is anticipated to be completed in less than a year, Section 245.410(d) of the Rules stipulates that the topsoil is to stockpiled and stabilized to prevent erosion. However, “In the event it is anticipated that the final reclamation shall take place in excess of one year from drilling the well, the topsoil may be disposed of in any lawful manner provided the permittee reclaims the site with topsoil of similar characteristics of the topsoil removed.”
What is missing, and needed, in this section of the Rules is the stipulation that the replacement topsoil will be not only similar in characteristics of the topsoil removed, but also match the removed topsoil in VOLUME. In fact, there is no place in the rules that requires measurement of the topsoil removed or measurement of the replacement topsoil. Without such a requirement, it would be easy for an unscrupulous operator to replace the topsoil with smaller quantities than were originally removed.
Revisions Needed: When final reclamation is anticipated to exceed one year and topsoil is removed from the site, Section 245.410(d) must require measuring the volume of the removed topsoil and stipulate that the replacement topsoil will match both the quality AND quantity of the removed topsoil.
Bloomington, IL 61701
Go there and comment. More tomorrow.
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