First the Present. I woke up this morning thinking about what to post for this week’s blog and after the first couple of sips of my coffee it dawned on me that we were in the middle of the comment period for the new fracking rules here in Illinois. I also quickly realized that Illinois People’s Action had been putting out these great cut and paste comments  and that they would be a valuable basis for any anti-fracking campaign in other states. I also realized that I could use it to get other fracktivists to come to IDNR’s web site to add their voices to the chorus. But first no matter what, you want your comments to count, and rumor has it that in other states email comments have been lost. Well there is a site that will print a copy of your comment and take it to IDNR so we will not run into that problem here. If you go to the site listed below you will see a place to copy your comment and if you scroll to the end of the page you will see the option for print a copy of my comment. Make sure that is checked and click submit.

http://www.ilagainstfracking.org/

Second the Past. I can forgive myself for coming to this party on day 19 because I was busy talking about global warming and the weather for the Philippian disaster and the Washington Illinois disaster. But also because there are roughly 25 days left to comment . For those of you who do comment please note the IDNR will take one comment about one part of the law at a time so when you go to the website listed below please note that you must click on a PART of the bill as a title and then make a relevant comment. Then you click submit. I am starting with day three because I did not save the first two, but I am sure IPA will send me those if i request it. For now I am just putting up as many days worth as I can so hopefully I will get all 45 up for the viewing public before the commenting period is over.

Today (Sunday, 11/17/2013) is Day 3 of IDNR 45 day comment period on hydraulic fracturing.  Will you please send IDNR a comment today?  It will take less than 5 minutes of your time.  We are also working on putting together a website to make this process even easier.  But in the meantime, we ask that you bear with us as we send you an e-mail each day.  If you are opposed to fracking and worried that the weak regulatory bill will not protect Illinois residents and the environment, please take action.

Today’s comment is on IDNR’s inadequate definition of a well site. 

Here’s what to do to make your comment today:

• Go to: http://www.dnr.illinois.gov/OilandGas/Pages/OnlineCommentSubmittalForm.aspx
• Click the “radio button”: Subpart A: General Provisions
• In the “Section” dropdown box, click 245.110 Definitions

Comment:

According to IDNR’s definitions, a “Well site” means surface areas, including the surface location of the well, occupied by all equipment or facilities necessary for, or incidental to, high volume horizontal hydraulic fracturing operations, construction, drilling, production, or plugging a well. (Section 1-5 of the Act)

While this definition might be appropriate for a well that drills straight down, as wells once did, it is not appropriate for horizontal hydraulic fracturing wells.   Horizontal hydraulic fracturing operations involve an initial drilling site that then grows to include horizontal legs radiating out from the site. Leaks or ruptures, the well’s proximity to water sources, and/or to real property are not adequately imagined by the well site definition that underpins so much of the IDNR’s approach to these regulations.

The well site definition should be expanded to include the surface area above any and all horizontal or vertical legs of the well. The current narrow definition does not adequately protect the health, safety and well-being of Illinois citizens, nor will it adequately sequester water used for human or animal consumption from accidents that can occur anywhere the drilling occurs.

A useful way of thinking of a hydraulic fracturing well site would be to compare it to an iceberg, where the small amount of ice visible at the water’s surface gives no hint of the size of the area occupied by the iceberg below the water line. The potential surface area that can be detrimentally affected by a hydraulic fracturing operation includes all land within 500, 750, or 1500 feet of a hydraulic fracturing leg (to use the IDNR’s own measurements), regardless of the leg’s horizontal or vertical relationship to the earth.

This definition is critical because setback requirements are based on IDNR’s inadequate definition of a well-site when they should, at a minimum, be based on the distance from any part of the well, including all underground horizontal legs of the well.

To adopt the current definition of well site is to apply an old understanding about what constitutes a well to an approach to drilling that has grown much more complex. The IDNR needs to reflect its understanding of the inherent and possible dangers of hydraulic fracturing by recognizing that the well site for such an operation has much greater breadth than the current definition envisions.

We would love it if you would let us know if you made a comment today!  And please feel free to call us with questions, comments, or to volunteer your time at (309) 827-9627.  Please share this with others you know and encourage them to make comments too.

In solidarity in the struggle for environmental justice,

Your friends at IPA

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Got there and tell the state to protect your health and safety. More today and for awhile.

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