The whole United States is drought prone now. We dirty up to much fresh waster. We drink alot through inefficient drinking water systems. Springfield’s ancient system wastes as much as it delivers and we just came through a serious drought. Now we want to waste water on fracking? Really? No Way!

Today (Friday, 11/29/13) is Day 15 of the IDNR Comment Period on Fracking.  Please don’t miss making a comment today on the very important topic of water!

Topic – Inadequate Water Plans and Local Control of Water in Permitting Process

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

• Click the button: Subpart B:  Registration and Permitting Procedures

• In the “Section” dropdown box, click:  245.210 Permit Application Requirements

• Submit your comment/s (below)

• Click “Submit”

Subpart B:  Regulations and Permitting

Section 245.210 Permit Application Requirements

Section 245.210 requires permit applicants to submit: a Water Source Management plan: “If fresh water is anticipated to be used in the high volume horizontal hydraulic fracturing treatment, a water source management plan that shall include the following information:” (source of ground or surface water, how much water to be used, months of use, methods to minimize fresh water use, methods used to minimize adverse impact to aquatic life).

Problems with this section:

1. While there is a required water management plan, this plan does not require application to local municipal, water district or other governmental control units requesting use of their ground or surface water resources.  In fact, if fracking is allowed, local government has no authority to deny water to a frack well operator, even in the case of drought.
2. There is no process for sharing the frack operator’s water plan with other state or regional agencies responsible for water usage (e.g. Illinois EPA, East Central IL Regional Water Supply Planning Committee) for their input on whether the plan is adequate, and how usage relates to possible drought situations.
3. There are no minimum regulatory thresholds regarding the amount of water to be used, the impact of water use given drought situations, actual impact on aquatic life, impact on existing human, industrial and agricultural water immediate needs, and potential future impacts.

Why these are problems:

1. The IDNR report The Drought of 2012, March 2013 identified:

1. In 2012, the 12 counties of southern IL–where the majority of fracking leases have been obtained–experienced “D4 drought – exceptional”, the most severe drought rating.  From July to December 2012 the area was in continuous drought.
2. Two of three local areas identified as “at risk public water supply” are in potential frack operation counties (Macon, Johnson, IL).  These counties were identified in an IL EPA 2012 drought report as having Community Water Systems most stressed by the drought.

2. A report by the East Central IL Regional Water Supply Planning Committee identified:

1. Springfield has a greater than 50% probability their water system will be unable to meet projected water use with a drought of record.
2. By 2020, Bloomington and Decatur’s water systems will be inadequate to meet demand.

3. The average water use by a frack operator is significant and will have an impact on water usage.  According to federal EPA, the average frack uses 4.4 million gallons of water.  And wells can be fracked multiple times.

Needed changes:

1. Any governmental unit that involves itself in local or regional water issues must review the frack operator water source management plan with the power to affirm, reject or modify the plan.
2. If a county or geographic area is identified as being in a drought, frack operations will cease.
3. IDNR must develop scientifically based high minimum, specific standards of water usage protecting existing human, agricultural and industrial use.  A frack operator’s water source management plan must adhere to these formal standards.

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