What do we want a Bhopal right here in the Midwest? In Illinois?

Today (Friday,12/7/13)  is Day 22 of the Comment Period of IDNR. 

Today’s coment is on Regulatory Exemption of Fracking Operations Predating the Passage of the Hydraulic Fracturing Regulatory Act

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

Click Radio Button: Subpart 245.100

Section: 245.100 Applicability

Problem:

The draft rules (Sec. 245.100) apply only to fracking operations occurring since June 17, 2013, while the original regulatory act clearly mandates that the provisions in the act apply to past, current, and future wells.

Specifically, Section 1-20 of the Hydraulic Fracturing Regulatory Act passed earlier this year states that the Act “applies to all wells where high volume horizontal hydraulic fracturing operations are planned, have occurred, or are occurring in this State”.

The existence and presumed necessity of the rules is clear evidence that unregulated fracking poses a significant risk to the health and safety of Illinois citizens and their environment. Hence, it makes no sense for IDNR to intentionally limit the scope of the rules to apply only to new fracking operations, while bypassing regulations on old wells. One might even argue that older wells–given both their age and the lack of regulations at the time of their construction– would merit greater attention from regulatory agencies.

Revisions Needed:

1. Require all fracking companies to report any prior fracking activities that fall under the definition of “high volume hydraulic fracturing”, regardless of when the activity occurred.
2. Ensure that past operations comply with the regulations outlined by IDNR to the furthest extent possible. For example, while it would not make sense for an operator to go back and re-perform drilling activities that did not conform to the Act, it should require compliance of ongoing obligations mandated by the rules – such as air emissions control requirements associated with production, post-frack testing and reporting, etc.

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