Category Archives: burning behavior

Fracking Wildlife In Illinois – IDNR thinks it is a good thing

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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

  • 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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Bloomington, IL 61701
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Illinois Will Glow In the Dark – After Frackers scatter radiation all over the land

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All fossil fuels contain radiation somewhere in their masses. In other words in any given coal deposit there will be radioactive hotspots. The same is true of oil and natural gas. So with Fracking you can never tell when you will hit on of those hotspots in the shale. What this means is that all disposal sites for all the debris from the fracked wells must have radiation detectors to guarantee that any radioactive materials are deposited in sites designed for such materials.

 

Today (Wednesday, 11/27/13) is Day 13 of the 45-day Comment Period on Fracking.  We hope you’ll take a minute out of your holiday preparations to submit a comment to IDNR about fracking and radioactivity.

Topic – Radioactivity in fracking operations: More loopholes

  • Click the button: Subpart H: High Volume Horizontal Hydraulic Fracturing Preparations and Operations (245.800-245.870)
  • In the “Section” dropdown box, click:  245.850 Hydraulic Fracturing Fluid and Hydraulic Fracturing Flowback Storage, Disposal or Recycling, Transportation and Reporting Requirements
  • Submit your comment/s (below)
  • Click “Submit”

Comment:  Subsection (d)(1) of Section 245.850 provides for testing radioactivity only one time–during the early flowback stage–and only for “naturally occurring radioactive materials”.  The problems with this are identified below.

Problems:

  1. The proposed rules do not include any standards or protocols to follow if testing of flowback water shows unacceptable levels of radioactivity.
  2. The proposed rules do not require the testing of “produced water”, which is the water produced from a well in conjunction with oil or natural gas production.  This is where radioactivity is most likely to show up.  It should be noted that while these Rules have been purported to be the strongest in the nation, PA law requires the testing of produced water at two separate intervals.
  3. The proposed rules do not require testing for added radioactive materials, like depleted uranium, which can be used in the perforation/fracturing operation.
  4. The proposed rules do not test work areas for levels of radioactivity that would call for OSHA standards of occupational safety.

These deficiencies, cumulatively or singly, would pose a significant risk to the public health and safety, property, aquatic life, and wildlife, in violation of section 1-75(a)(2) of the Hydraulic Fracturing Regulatory Act.

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Bloomington, IL61701
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Frackers Could Take Over Your Town – Illinois cedes sovereignty to the extraction industry

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City and county governments?  We don’t care about your stinking City and County governments. Drill baby drill.

 

 

Today (Saturday, 11/23/2013) is Day 9 of the IDNR 45 day comment period on fracking.  You’re all doing a great job sending in your comments.  We’re a fifth of the way through the comment period.  Let’s keep the pressure on. 

Today’s comment is on the Local Control

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

·         Click the button: Subpart A: General Provisions

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

·         Submit your comments (below)

·         Click “Submit”

Comment:

This section states that “when an application is made to frack a well site located within the limits of any city, village or incorporated town, the application shall state the name of the city, village, or incorporated town and be accompanied with a certified copy of the official consent for the high volume horizontal hydraulic fracturing operations to occur from the municipal authorities where the well site is proposed to be located.  No permit shall be issued unless consent is secured and filed with the permit application.”

This is excellent for municipalities but what about counties???

*  The intent of the legislation was to recognize that local units of government should have decision-making power regarding whether to allow fracking in their jurisdictions.  

*  This section demonstrates blatant disregard for the realities of the geography of fracking in Illinois regarding cities compared to counties.  Little if any fracking is anticipated within the cities of Carbondale, Marion, Decatur or other metro areas affected by the majority of fracking land leases.  If prior notification and an intentional process of permitting is important for metropolitan communities, why are the proposed rules silent regarding neighborhoods in counties and the families living there?

*  There is no substantive difference between a municipal or county government in Illinois in its powers other than the issue of Illinois Constitutional Home Rule.  However, the lack of county Home Rule has never preempted a county power to issue permits on mineral or oil extraction.  Numerous county governments have long histories and traditions in the permitting process regarding mineral and drilling industries. As the current fracking law is largely silent on the issue of county control, IDNR rules should err on the side of history and citizen decision-making. 

*  Counties and municipalities of government tax, employ law enforcement, provide social services and infrastructure.  The rules provide no explanation why citizens residing in counties of Illinois should have less input regarding fracking permits.  The regulatory differentiation between the rights of residents in municipalities vs. counties creates a group of second class citizens. These second class citizens have fewer rights in their ability to participate and ultimately determine the type and quality of energy extraction allowed in their neighborhoods.

*  There is no reasonable expectation that the personnel at IDNR have any better or more clear understanding of the will of citizens in counties regarding fracking permits than the residents themselves.  As the proposed IDNR rules envision municipalities empowered to decide fracking sites, what possible argument does IDNR have that it is better equipped or knowledgeable on the needs of residents living in Illinois counties? 

510 E. Washington St. Suite 309
Bloomington, IL61701
United States

 

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Frackers Free To Violate Illinois – According to the State of Illinois

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This was supposed to be the toughest set of regulations in the United States. This is an outrageous lie created by The Chicago Sellouts, better know as the gang of 5, the IEC, the NRDC, ELPC, the Sierra Club, and Faith in Place. They shall pay for this.

 

Today (Sunday, 11/24/2013) is Day 10 of the IDNR 45 day comment period on fracking.  Thank you for all of the comments you’re making!

Today’s comment is on what constitutes a “serious” violation.

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

This section of the rules states that every applicant applying for a permit must disclose to the Department  “all findings of a serious violation or an equivalent violation under federal, Illinois or other state laws or regulations in the development or operation of an oil or gas exploration or production site via hydraulic fracturing by the registrant or any parent, subsidiary, or affiliate of the registrant within the previous 5 years.”

  • What does IDNR define as a “serious” violation?  There is no guideline here making it easy for violators to claim that they didn’t report a violation because “we didn’t think it was serious.”  Instead, applicants should be required to disclose ALL violations alleged by public authorities and any fines or findings therefrom.
  • What is the reason for the 5 year time limitation?  When fracking violations potentially pose a threat to public health and safety, all previous violations and alleged violations should be considered when issuing a permit, regardless of how long ago they occured.

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510 E. Washington St. Suite 309
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United States

 

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A Whole Lot Of Shaking Could Go On – Those old Sky Scrapers could come a tumblen down

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It is true none of the tall buildings in either St. Louis or Memphis are even earthquake resistant let alone earthquake proof. To top that off they are built on alluvial soil. Then there are the bridges across the Mississippi, Nebraska and Ohio rivers.So even a moderate earthquake in the area could be its own little disaster movie.

Today (Tuesday, 11/19/2013) is Day 5 of the IDNR 45 day comment period on hydraulic fracturing, aka “fracking.” 
We’re asking for a little something extra from you today.  In addition to making today’s comment, which is about fracking-induced earthquakes (see below), will you also sign a petition that would allow Johnson County–which is in the heart of the New Madrid fault zone–to assert its right to local self-government in order to ban corporate fracking?  This would be a test case for Illinois and might open the door to local county governments banning fracking.  They need signatures.  You can sign here:
Today’s comment is on Seismicity: Insufficient Protection, Two Types of Risk
Here’s what to do to make your comment today:
Comment:  In subsection (a), “Applicability”, DNR proposes that this rule apply ONLY to Class II  injection wells, not to any other.  DNR has not proposed any rules for fracking wells.  This is insufficient protection of the population in southern Illinois where citizens are at risk of a major earthquake.  Southern Illinois sits above two active seismic zones: the New Madrid and the Wabash Valley.
There are two distinct earthquake risks: (1) the risks from injection wells inducing earthquakes that would not otherwise occur and (2) the risks of substantial injuries and damages created when the toxic fracking fluid left in the ground, in pipelines, and in wells (injection and otherwise) is let loose as a result of a major earthquake.  There are NO rules establishing guidelines for stopping fracking wells in the event of earthquakes, and NO considerations for siting any wells specifically in active seismic zones.  That omission is a reckless disregard for the safety of Southern Illinois residents, their property, and the ecology of the region.
Furthermore, in light of recent studies (see below), the risk of earthquakes can extend far beyond local areas.  See:
  • http://www.earth.columbia.edu/articles/view/3072 :  A new study is the latest to tie a string of unusual earthquakes, in this case, in central Oklahoma, to the injection of wastewater deep underground. Researchers now say that the magnitude 5.7 earthquake near Prague, Okla., on Nov. 6, 2011, may also be the largest ever linked to wastewater injection. Felt as far away as Milwaukee, more than 800 miles away, the quake—the biggest ever recorded in Oklahoma–destroyed 14 homes, buckled a federal highway and left two people injured.
  • http://geology.gsapubs.org/content/early/2013/03/26/G34045.1
  • http://www.usgs.gov/newsroom/article.asp?ID=3706&from=rss#.UohRF40hRL8  “Why America’s Heartland is Earthquake Country”, United States Geological Service, September 30. 2013
  • “Enhanced Remote Earthquake Triggering at Fluid-Injection Sites in the Midwestern United States”, Nicholas J. van der Elst et al., DOI: 10.1126/science.1238948, Science 341, 164 (2013).
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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510 E. Washington St. Suite 309
Bloomington, IL 61701
United States

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Fracking Will Set Off The New Madras Fault – In Illinois a whole lot of shaking going on

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This whole earthquake thing has me shaking in my boots. No really. The last time New Madras went off the Mississippi River ran backwards and two mammoth lakes in Kentucky were created. There was no St. Louis or Memphis to be devastated. This is a big deal.

USED on Day 2 on 11/16/13

Topic:  Fracking and Seismic Activity (Earthquakes) 

Radio button: Part 240 : Seismicity (240.796)

Use any of the comments below related to when fracking causes earthquakes (“induced seismicity”)

NOTE: Every topic address must be entered as a separate comment.

·         COMMENT:  The Rules contain language about earthquakes and, on a broader level, they also assume that fracking indeed causes earthquakes.  The rules describe a whole series of fracking created earthquake levels of intensity. Why would the state allow any business activity that includes the real possibility of it creating earthquakes when done in an otherwise proper manner – especially in a geography known for major earthquakes?

·         COMMENT:  The rules are silent regarding broader concerns regarding how fracking created earthquakes will affect existing earthquake prone communities.  There is no mention of scientific review or study of the effect of fracking earthquakes within the Wabash Valley and New Madrid Seismic Zones.  The Illinois Emergency Management Agency identifies southern IL with its most severe earthquake zone ratings of “Destructive “and “Ruinous”.  How does IDNR justify allowing any fracking in these areas when industry best practices say there should be no fracking in seismic zones?

·         COMMENT: Rules define various intensities of fracking caused earthquakes by a color code system.  Enforcement doesn’t begin until “yellow light alert”, (a magnitude of at least 3.0 but less than 5.0).  This color coding system does not appear to be used by the federal USGS, the federal agency responsible for monitoring earthquakes. Why would IDNR use a system not used nationally?  What is the purpose of IDNR’s color coded system and what value does it add to protect citizens who might be affected by said quakes?

·         COMMENT: A fracking site can be responsible for creating up to 4 earthquakes up to a level of 4.9 magnitude WITHOUT a mandatory shut-down order by the state. A 4.9 earthquake is a serious and newsworthy event – (USGS description: “Sensation like a heavy truck striking building.  Standing motor cars rocked noticeably.”)  What justification does IDNR to allow this?

·         COMMENT: Mandatory shut-down of a site is based on a patchwork of multiple earthquakes at multiple times with varying intensity.  For example, if an earthquake caused by fracking “causes significant damage” or a magnitude of 5.0 or greater the state will shut-down the frack site.  A 5.0 earthquake is described by USGS as “Felt by all, many frightened.”   The rules use a dangerous, high threshold of earthquake intensity for a mandatory shut-down.  The fracking caused earthquake literally has to frighten people or break something before the state will step in.  What is the justification for such a high threshold?

·         COMMENT: If a shut-down order is made, the fracking company gets a hearing, the purpose of which is to “mitigate induced seismicity events near the permitted well”.  To “mitigate” is to minimize, not eliminate earthquakes caused by fracking.  As with the overall message of the earthquake rules, the intent appears to not eliminate earthquakes caused by fracking but actually permit them.  What does IDNR have to say to justify this?

·         COMMENT:  The penalty for failing to attend an earthquake hearing or continuing to frack after causing a serious, reported earthquake is $50 for a first time violation.  The rules define these violations as “Administrative penalties”.  This amount is a little less than the cost of a dinner and a movie.  Even with 4 or more earthquake violations, the maximum fine is only $500, arguably an acceptable business expense.  How is this justifiable? 

·         COMMENT:  Will fracking companies be held responsible for all monetary damages caused by earthquakes?

·         COMMENT: If the frack site continues to operate in violation of a state order regarding it creating earthquakes the minimum fine is $100.  Who is making up these ridiculously industry-slanted rules?

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McADA Coming To Destroy Illinois – With all their fracking support services

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So what? So I am picking on the frackers by company name now. That is too bad. What have I got to lose?  Here is the second comment that IPA released. I am leaving the dates on their actual emails for authenticity’s sake.

 

Today (Monday, 11/18/2013) is Day 4 of the IDNR 45 day comment period on hydraulic fracturing, aka “fracking.”  Will you please send IDNR a comment today?  It will take less than 5 minutes of your time and we will walk you through the process.  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 the lack of Studies, Reports, or Underlying Data Used to Compose Rulemaking

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

This comment is in reference to Page 3, Paragraph 6 of the Proposed Hydraulic Fracturing Regulatory Act administrative rules, which states: “Published studies or reports, and sources of underlying data, used to compose this rulemaking: None”.

Simply put, the State of Illinois cannot have sound regulation without good data.

There is significant need for further study of horizontal hydraulic fracturing technology prior to it’s use in the State of Illinois. If the technology was as safe as the industry is claiming, why do there continue to be so many accidents and violations in states where fracking is already occuring?

Suggested resources include the twenty-four (24) pages of “References” included in U.S. EPA’s December 2012 Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources.

See: U.S. EPA: Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources: Progress Report, (EPA 601/R-12/011 | December 2012), available at: http://www.epa.gov/hfstudy.

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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510 E. Washington St. Suite 309
Bloomington, IL 61701
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Global Warming Slams The Philippines – Yes I will be the first one to say it

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Climatologists and weather people are always nattering on about how you can’t link global warming and a “particular’ WEATHER EVENT. Well I say that is super silly. This last hurricane to hit the Philippines (one of 4 already this season) was caused by global warming. I mean come on, the most powerful storm ever to strike land. When do adjectives like that add up to – caused by. Does the next biggest “ever” storm = global warming. Does a year of the “biggest” storms ever = global warming. Really when can I drop the parenthesis around all the adjectives and just say it out loud. Well I believe today is the day.

http://au.ibtimes.com/articles/521536/20131112/climate-change-warsaw-global-warming-typhoon-haiyan.htm#.UoJYfOInN5r

Climate Change Talks: Philippine Representative in Tears Over Haiyan, Receives Standing Ovation

By Reissa Su | November 12, 2013 7:51 PM EST

Typhoon Haiyan has dampened the spirits of climate change negotiators in an international talk on global climate change treaty in Warsaw. Delegates from around the world quickly suggested that the monster typhoon that wreaked havoc in the Philippines was enhanced by global warming.

Typhoon Haiyan has left Vietnam and is now on its way to China at a reduced strength. The super storm has displaced over 600,000 families in the Philippines  leaving most of Tacloban City devastated.

Lead negotiator for an alliance of small island nations Olai Ngedikes said that Typhoon Haiyan should be a “stark reminder” of the lack of action among governments in the world. He said the typhoon should motivate climate change negotiators to push an agreement in Warsaw.

Philippine representative to the UN climate change talks, Naderev Sano said he would fast or refrain from eating in solidarity with typhoon victims or until a meaningful solution will be reached. Mr Sano said the effect of climate change is madness. He added they can put an end to the madness by arriving at an agreement in Warsaw.

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Go there and see the video. Go there and read. More next week.

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Kill The Ocean And Kill Ourselves – Jacque Cousteau said it 60 years ago

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It is as true today as it was then. We are so much closer to the edge today then we were then and it is frightening.

http://news.yahoo.com/business-urged-more-save-oceans-world-bank-study-041032438.html

Business urged to do more to save oceans: World Bank study

Reuters By Environment Correspondent Alister Doyle

OSLO (Reuters) – Businesses should play a bigger role in helping to save depleted fish stocks as part of efforts to prevent irreversible damage to the oceans, a World-Bank backed report said on Wednesday.

The study, by 21 experts including government ministers, academics, conservationists and company leaders, said policies for protecting the oceans from over-fishing, pollution and climate change were often ineffective and fragmented.

It recommended more public-private partnerships involving companies, governments, local communities and others to protect ecosystems that are the main source of protein for a billion people, mainly in the developing world.

“A paradigm shift is needed in how we use and conserve ocean resources to address current inadequacies,” the report said.

The panel, set up by the World Bank, is one of several groups trying to find ways to deal with threats to the oceans. A separate Global 0cean Commission, for instance, is looking at how to safeguard the high seas, outside national jurisdictions.

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Please go there and think. More next week.

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Fukushima – The ongoing threat

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While it is true that this “underground river of water” or what ever it is, is troubling. It is also clear that the bloggers and the fear mongers also want to have an end of the world hissy fit. The truth probably lies in the middle somewhere, BUT the fact that this is 2 and 1/2 years later is both dangerous and unacceptable. I lay this one at the foot of the antiquated class structure of Japan and its notion that deference is the only honorable approach to major social conflicts. This is at its heart a cultural conflict between the business community and the government which the business community wants to win. Such a win could end us all and the fact that the Japanese government is just now catching on is frightening.

http://www.washingtonsblog.com/2013/08/official-tepco-plan-could-cause-fukushima-reactor-buildings-to-topple.html

Official: Tepco Plan Could Cause Fukushima Reactor Buildings to “Topple”

Posted on August 7, 2013 by WashingtonsBlog

Japan’s Nuclear Accident Response Director Warns that Tepco’s Actions Might Cause Reactor Buildings to Collapse

Tepco’s ill-considered efforts to change soil permeability and water flow have caused severe problems at the site … including highly radioactive groundwater bubbling up to the surface.

NHK notes:

The vice governor of Fukushima Prefecture has asked the government to take the lead in handling the matter and stop the leakage. Masao Uchibori told an official from the Nuclear Regulation Authority that some of Tepco’s measures have increased the risk of further leaks.

The Wall Street Journal’s Michael Arnold says:

Obviously this is a massive public health issue … if it gets into the ocean obviously this could be spread throughout the Pacific, could also get into the food supply.

Background here and here.

But there is another – stunning – threat.

Specifically, BBC points out:

Engineers are now facing a new emergency. The Fukushima plant sits smack in the middle of an underground aquifer. Deep beneath the ground, the site is rapidly being overwhelmed by water.

What happens when you pour hundreds of thousands of tons of water (400 metric tons each day times 2.5 years times 365 days in a year equals 365,000 metric tons of water)  onto soil which sits above a massive aquifer?

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Tilting sinking buildings is not good. Go there and read. More next week.

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