If Frackers screw up then they should lose their permits plain and simple. And if they lose a number of permits they should lose their ability to operate in Illinois. That is plain and simple.
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We made an error on today’s comment which went out earlier today. The Subpart is K, not A. If you haven’t already sent your comment, please click K, not A. If it’s not too much to ask, and you’ve already sent your comment, could you please do it again with the correct Subpart? Thanks so much! We are very sorry for this inconvenience–just operating on too little sleep!
Today (Moday, 11/25/2013) is Day 11 of the IDNR 45 day comment period on fracking. Thank you for all of the comments you’re making!
Today’s comment is on the need to revoke permits when a fracking company doesn’t follow guidelines in building or testing a well.
Here’s what to do to make your comment today:
- Go to: http://www.dnr.illinois.gov/OilandGas/Pages/OnlineCommentSubmittalForm.aspx
- Click the button: Subpart K: Enforcement
- In the “Section” dropdown box, click 245.1100 Suspension, Revocation, Remediation and Administrative Penalties
- Submit your comments (below)
- Click “Submit”
Comment: Section 245.1100 states that the Department may revoke for a wide variety of infractions:
“The Department may, through the enforcement process set forth in this Subpart, suspend or revoke a high volume horizontal hydraulic fracturing permit, order actions to remediate, or issue administrative penalties for one or more of the following causes…”
The rules are too lax when the violation involves failing to follow guidelines when building/developing a well or testing its integrity. In those circumstances, the rules should require mandatory revocation of the permit.
Rationale. Provisions in Section 1-70 of the Hydraulic Fracturing Regulatory Act (Well preparation, construction, and drilling) require adherence to the American Petroleum Institute (API) standards when developing and testing oil and gas wells. A strong case can be made that these are the most important sections in the law because their objective is to reduce the risks of well blowouts, fires and explosions along with the attendant risks of injury or death to workers, adverse public health outcomes to nearby residents, and the pollution of groundwater, air, and soil.
There are reasons why failure to adhere to section I-70 must result in permit revocation:
- If well operators shortcut the well development standards in Sec. 1-70 or if the well fails any of the required tests in Sec. 1-70, the adverse events cited above become much more likely. Pollution of aquifers is also much more likely and this pollution can be easily overlooked.
- Other states have experienced major problems with some rogue companies that systematically and persistently engage in high-risk, cost-cutting violations of regulations, such as these. If some companies are allowed to violate Section 1-70, others will follow their lead.
- It was the violation of the provisions in Sec. 1-70 that lead to the Deepwater Horizon explosion in the Gulf of Mexico on 20 April 2010. That explosion claimed 11 lives and led to the largest environmental disaster in American History.
Automatic permit revocation for violations of Sec. 1-70 could prove to be one of the more effective ways to insure higher levels of safety and environmental protection in areas where fracking will occur.
If the IDNR is not serious about strict enforcement of Sections 245-520/580, then it has already nullified one of the most important set of regulatory standards for the oil and gas industry.
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