Run little doggies, run for the hills, but if you are a fish you are pretty much dead.

Today (Saturday, 11/30/13) is Day 16 of the IDNR Comment Period on Fracking.  Thanks for hanging in there with us even on this holiday weekend!

Day 16  USED 11/30/13

Topic:  Definition of “Aquatic Life” is too narrow

• Go to: http://www.dnr.illinois.gov/OilandGas/Pages/OnlineCommentSubmittalForm.aspx

• Click the button: Subpart A: General Provisions

• In the “Section” dropdown box, click:  245.110 Definitions

• Submit your comment/s (below)

• Click “Submit”

Section 245.110 Section 245.110 of the Proposed Hydraulic Fracturing Regulatory Act administrative rules, states: “Aquatic life” means all fish, reptiles, amphibians, crayfish, and mussels.

Problems with this section:

1. This definition is too narrow and does not include many other species that may be important to an aquatic ecosystem.  Aquatic life cannot be understood apart from the larger aquatic ecosystem which sustains it.
2. Freshwater ecosystems (limnology) not only include fauna, but also flora (plants), micro/macro invertebrates, oxygen levels and algae, for example.

Why these are problems:

1. Exclusively focusing on a limited definition of “aquatic life” unnecessarily narrows the impact to the larger ecosystem that sustains it.
2. By the time a fish kill occurs pollution caused by fracking will have reached a critical stage, causing havoc across the larger ecosystem.
3. It neglects the biological criteria for the protection of aquatic life.

Revisions Needed:

1. The definition of “aquatic life” must be broadened to include “aquatic ecosystems”.
2. Specific scientific standards must be developed to include:  a) Biological standards, b) High quality water resources, c) Modified or limited water resources, and d) Stressor identification.

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Go there and comment. More tomorrow/

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