Public Participation In Illinois – That is unheard of

What the hell would the public know about their own self interest. Everybody outside of Chicago is just dumb hicks anyways.

Day 29 12/13/13 

Today’s Topic:  Who a potentially affected party must petiton in order to participate in a hearing.

Section 245.270 Public Hearings

The Act’s provision affording public hearings are critically important to ensuring that the public has the ability to fully understand hydraulic fracturing permits that may affect them, and challenge them if appropriate. We are therefore concerned that some aspects of the draft rules governing hearings could potentially undercut the robust public participation envisioned in the statute.

Section 1-50(b) of the Hydraulic Fracturing Regulatory Act says any person having an interest that is or may be adversely affected [by a fracking permit], can petition the Department for participation in a hearing.

But Subsection 245.270(a)(6) of the Rules raises the bar, requiring the request for hearing to be served upon the Hearing Officer, the Department, and the ap

Please For God’s Sake – Recycle the fracking fluid

Why are we even messing around with this stuff. Colorado already demands recycling and Oklahoma make drillers bottle the natural gas. Why are we providing a lower standard of treatment of the Earth then other places.

 

Today’s Topic:  Discrepancies between the law and the rules on how long open-air pits can be used to store flowback.
  • Go to: http://www.dnr.illinois.gov/OilandGas/Pages/OnlineCommentSubmittalForm.aspx
  • Click the button: Subpart H: High Volume Horizontal Hydraulic Fracturing Preparations and Operations (245.800-245.870)
  • In the “Section” dropdown box, click: Section 245.850  Hydraulic Fracturing Fluid and Hydraulic Fracturing Flowback Storage, Disposal or Recycling, Transportation and Reporting Requirements
  • Submit your comment/s (below)
  • Click “Submit”
Section 1-75 of the Hydraulic Fracturing Regulator Act mandates that “excess hydraulic fracturing flowback captured for temporary storage in a reserve pit as provided in paragraph (2) of this subsection must be removed from the well site within 7 days.”
But Section 245.850 of the proposed rules states, “Any excess hydraulic fracturing flowback captured for temporary storage in a reserve pit as provided in Section 245.825 must be removed from the well site or transferred to storage in above-ground tanks for later disposal or recycling within 7 days after completion of high volume horizontal hydraulic fracturing operations.”
Problem:  The amendment of “after completion of high volume horizontal hydraulic fracturing operations” opens the door for the potential abuse of emergency pits.  Storage in closed tanks can be costly for the industry.  An unscrupulous operator wanting to cut costs could simply claim that there was more flowback than expected and end up using open pits for storage for the duration of the fracking process.
The clear intent of the statute is to ensure that wastewater is stored in tanks except in the emergency event of an unforeseeable overflow, in which case it is preferable that the overflow go to a pit than simply spill on the ground. But in such event, the overflow is expressly required in the statute to be removed within a week. Through omission and misinterpretation, the regulations are not implementing this statutory directive.
Section 245.210(a)(11), requires that an applicant submit a Hydraulic Fracturing Fluids and Flowback Plan.  The plan does not include requirements to ensure that tank capacity is accurately calculated. Without such method, there is nothing in the regulations to prevent operators from underestimating the size of the tanks they need, so as to make routine use of the reserve pit for the resulting overflows. Operators presumably have an economic incentive to do so in order to hold down the cost of tank storage.
Compounding this incentive is the Department’s weakening of the statutory directive that fluids deposited in a reserve pit be removed within 7 days (Section 1-75(c)(5). The regulations fail to require such prompt removal, allowing, at subsection 245.850(c), the overflow to remain in the reserve pits until 7 days “after completion of high volume horizontal hydraulic fracturing operations.” Certainly on a multi-well pad, hydraulic fracturing operations can continue for a month or more, meaning that the flowback fluid could be left sitting in the reserve pit, creating environmental risk, for much longer than a week.
Revisions needed:  First, require that drillers anticipate appropriate sized tanks for sufficient storage of flowback and produced water by establishing a method for tank capacity calculation. Second, clarify that wastewater must be removed from the pit within 7 days of the event that triggered the use of the pit rather than 7 days after fracking operations are complete, in accordance with the law.
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Go there and comment. More tomorrow.

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So Illinois Is Gona Protect Me From Fracking – Not the way it is going

When we got in the faces of the 5 renegade environmental groups, they claimed that IDNR would tighten up things to take in our concerns. So far that ain’t been ahappening. We will just have to see what happens after the comment period closes.
Today (Tuesday, 12/10/13)  is Day 26 of the Comment Period of IDNR.   Getting tired of making comments?  We understand.  But if we don’t fight, the industry will win because their fingerprints are all over these rules.  Fight back.  Make a comment today.
Today’s Topic:  IDNR’s Duties and Responsibilities to Protect the Citizens of Illinois
Comment:
In Section 1-130 of the regulatory statute, the legislature granted IDNR authority to adopt rules to carry out the legislature’s purposes.
There are at least two legislative purposes in the regulatory statute:
  1. To allow horizontal fracking in Illinois,
  2. To approve horizontal fracking conditionally based on the safeguarding of public health and public safety, and the protection of the environment.
This purpose is set forth explicitly in two places in the regulatory statute–Section 1-75(a)(2) and Section 1-53(a)(4).  IDNR has acknowledged 1-75 verbatim, in Section 245.800(2) of the proposed rules: “All phases of high volume horizontal hydraulic fracturing operations shall be conducted in a manner that shall not pose a significant risk to public health, life, property, aquatic life, or wildlife.”
But IDNR has changed the legislature’s language in Section 1-53(a)(4) of the proposed rules, lowering the standard explicitly created by the legislature.  Section 1-53(a)(4) of the legislation states: “The Department shall issue a high volume horizontal hydraulic fracturing permit, with any conditions the Department may find necessary, only if the record of decision demonstrates that: the proposed hydraulic fracturing operations will be conducted in a manner that will protect the public health and safety and prevent pollution or diminution of any water source.”  The key phrase there is”will be conducted”.  Clearly the intent of the statute is that fracking will only be allowed if it is conducted in a safe manner.
IDNR’s proposed Section 245.300 changes the legislative words “will be conducted” to “as proposed, are reasonably expected to be conducted”.  This lowers the standard and is inconsistent with the legislature’s stated purpose.  “Will be conducted” is a mandate; “reasonably expected to be conducted” is not.
If hydraulic fracturing outcomes in Illinois mirror effects of other states, we can “reasonably expect” that the industry will cut corners and violate standards.  There have been over 3000 violations in PA since 2009 and they are not minor violations.  They involve infractions such as:
  • 224 violations of “Failure to properly store, transport, process or dispose of residual waste.
  • 143 violations of “Discharge of pollutional material to the waters of Commonwealth.
  • 140 violations of “Pit and tanks not constructed with sufficient capacity to contain pollutional substances.
The residents of Illinois are depending on IDNR to protect their health, their safety, and the safety of their water, air, and soil.  IDNR needs to return the legislation’s intent and mandate that hydraulic fracturing operations will only be conducted in a manner that will protect the public health and safety and prevent pollution or diminution of any water source.”
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510 E. Washington St. Suite 309
Bloomington, IL 61701
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Go there and comment. More tomorrow thank God.

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

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
Bloomington, IL 61701
United States

 

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Go there and comment, More tomorrow.

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

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
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Go there and comment. More later.

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Fracking Should Be Banned In Illinois – But apparently the frackers have decided to forge ahead

I got an email from Southern Illinois that said 30 big rigs had rolled through town yesterday morning. I figure that that is enough for 2 wells. It seems like some drilling company has decided to “go for it”. Which makes sick and disgusting sense. Many of the leases die at the end of April. I suspect that these will be test wells, because no one knows what is down there. It takes about  7 days to to drill a well and frack it. That would have the wells beginning to come in as the lease expires. This is what I said in print.

Thursday, April 11,2013

Letters to the Editor 4/11/13

Fracking and litter control act

By Letters to the Editor

 

FRACKING STINKS

I am writing to argue for a moratorium against fracking in Illinois (SB 1418). Chicago environmentalists argue that “fracking is going to happen anyway.” That is a total capitulation to the industry. The bill that the environmentalists endorse (HB2615) is amazing in the things it does not prevent. It does not force the frackers to recycle their water, allows for methane flaring, allows wells within 300 feet of water sources, allows wells within 500 feet of a house, does not allow adequate testing of produced waters especially for radiation and then allows that waste to be deep well injected and finally allows for the state to overrule counties and municipalities who do not want fracking or more protective measures.

Many states have tried to establish hydraulic fracturing regulations that would allow the industry to drill safely. The problem is regulations do not work. The industry always violates the regulations and when caught pays the fine as part of standard operating procedure. These violations include injecting radioactive water underground, open pit storage of fracking and waste waters even where not permitted, the production of toxic fumes and the sickening of residents, well water contamination and the direct dumping of toxic water into springs and streams. They have gone so far as to sell toxic water to county townships to suppress dust in the summer and to de-ice roads in the winter as if that was safe. Homeowners are duped into selling mineral rights without being told that it will make their houses impossible to sell and wreck their mortgages. In Pennsylvania their violations include:

– 224 violations of “failure to properly store, transport, process or dispose of residual waste.”

– 143 violations of “discharge of pollutional material to the waters of Commonwealth.”

– 140 violations of “pit and tanks not constructed with sufficient capacity to contain pollutional substances.”

This does not include the actual damage that they do to the environment, like damaging the roads where they work, and flaring the natural gas that should be harnessed as a fuel source and the constant noise pollution that the above activities produce. I was visiting a friend in Colorado when such a well was put in and the noise and smell alone were enough to sicken me.

Doug Nicodemus
Riverton

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Go there and read. They did a whole 5 page article on the issue. More later.

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Methane Hydrates – Good for Japan but what about the rest of us

Since the Fukushima nuclear disaster Japan has needed to find new power sources. This could be it and it is in their backyard. This could free up Japan’s stagnate economy because the cost would be so much cheaper and the money would stay in Japan. I need to know much more about how they extract the hydrates, how they process them and how they use them before I can say that this will be great for the rest of us.

http://theenergycollective.com/sbattaglia/200361/methane-hydrate-future-of-energy

Japan’s Methane Hydrates and the Future of Global Energy

Posted March 19, 2013

Authored by:

Sarah Battaglia

Sarah Battaglia has been one of the in-house Copywriters and the Social Media Specialist for Energy Curtailment Specialists since 2011.

All eyes are on Japan as they recently became the first country to successfully extract natural gas from methane hydrate deposits, commonly referred to as “flammable ice,” located nearly 900 feet below the seabed.  For a country that imports almost all of its energy, this discovery could be an incredible asset.

In the aftermath of the Fukushima Daichii disaster, Japan is in the process of moving away from nuclear power, and this new source of natural gas could be just the solution.  Spokesperson for the Japan Oil, Gas, & Metal National Corp. (JOGMEC) Takami Kawamoto stated, “Japan could finally have an energy source to call its own.”  The New York Times described methane hydrate as “a sherbet-like substance that can form when methane gas is trapped in ice below the seabed or underground.”  Even though it may resemble ice, it will burn when heated.  JOGMEC predicts at least 1.1 trillion cubic meters of this substance can be found in the eastern Nankai Trough located off the Pacific Coast.  That could be enough natural gas to last Japan 11 years!  Furthermore, an estimated 7 trillion cubic meters of “flammable ice” can be found throughout Japan’s waters, supplying natural gas for several decades.

When asked about the process, JOGMEC stated, “With specialized equipment, the team drilled into and then lowered the pressure in the undersea methane hydrate reserve, causing the methane and ice to separate.  It then piped the natural gas to the surface.”  The gas can also be attained by heating the solid methane hydrate, but this process uses a considerable amount of energy.

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Go there and read. More later.

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The Insurgents Attack On Algeria Failed – This is much ado about nothing

The insurgents who attacked the Algerian Natural Gas Plant have claimed victory but they were total failures. I am sorry that 40 people or less are dead. For the innocents anyway. Workers really just doing their jobs. But as far as I can see all of the attackers got wacked too. Ultimately I think their plan was to damage the plant and run off with the hostages and neither one of those things happened.  They probably lost many good weapons, many good explosive and many trained fighters. This was a dumb operation.

http://www.telegraph.co.uk/news/worldnews/africaandindianocean/algeria/9816767/BP-Algeria-gas-plant-raid-co-ordinated-by-a-Canadian.html

BP Algeria gas plant raid ‘co-ordinated’ by a Canadian

The BP gas plant raid was “co-ordinated” by a Canadian terrorist and claimed the lives of at least 37 foreign hostages, the Algerian prime minister announced on Monday.

Abdelmalek Sellal told a press conference in Algiers that a further five foreigners remained unaccounted for in the wake of the siege which ended when Algerian special forces stormed the remote Saharan plant on Saturday.

A total of 29 terrorists were also killed, with three others captured alive, he said.

Mr Sellal said the plot had been hatched in Mali and that the attackers had travelled through Niger and Libya before slipping into Algeria. He said that one of the hostage takers was believed to have been Canadian “judging by his English accent”. “He was co-ordinating the attack,” he said.

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Go there and read. More later.

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Most Diesel Engines Will Switch To Natural Gas – It is cheaper and cleaner

This has been so needed for so long. America pivots from gasoline to natural gas. When will we get over that to something that makes sense?

http://www.chron.com/business/article/Natural-gas-wins-place-as-oil-field-fuel-3900742.php

Natural gas wins place as oil field fuel

By Zain Shauk | Thursday, September 27, 2012

The biggest, baddest engines in the world, long chained to diesel fuel, are on the verge of a mass transformation because of cheap natural gas – with oil field equipment holding particular potential, executives said Thursday during a summit of heavy fuel users and producers.

“Here’s the first reason that large engines are going gas,” said JoelFeucht, director of gas engine strategy for Caterpillar’s energy and power systems division. “Large engines burn the most fuel. I could try to make it harder, but that’s pretty straightforward.”

Oil companies alone use nearly 1.2 billion gallons of diesel fuel a year just for pressure pumping equipment that supports hydraulic fracturing, said David Hill, vice president of natural gas economy operations for Encana Corp. Adding the diesel used to power drilling rigs themselves, the total is more than 2.8 billion gallons annually, said Pierce Dehring, a project engineer for Baker Hughes.

 

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Go there and read. More next week.

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Energy Deathprint – One of those pesky externalities you never hear about

This article is both disturbing and self explanatory.

http://www.forbes.com/sites/jamesconca/2012/06/10/energys-deathprint-a-price-always-paid/

How Deadly Is Your Kilowatt? We Rank The Killer Energy Sources

 

James Conca, Contributor

Everyone’s heard of the carbon footprint of different energy sources, the largest footprint belonging to coal because every kWhr of energy produced emits about 900 grams of CO2. Wind and nuclear have the smallest carbon footprint with only 15 g emitted per kWhr, and that mainly from concrete production, construction, and mining of steel and uranium. Biomass is supposedly carbon neutral as it sucks CO2 out of the atmosphere before it liberates it again later, although production losses are significant depending upon the biomass.  Carbon emissions and physical footprints are known as externalities and are those vague someone-has-to-pay-eventually kind of thing it’s hard to put a value on. Proposed carbon footprint taxes are in the range of $15 to $40/ton of  CO2 emitted, but assigning a physical footprint cost depends on the region, ecosystem sensitivities and importance. A hundred-acre wetlands to be flooded by a new dam is worth more to the planet than a barren hundred-acre strip under a solar array in the Mojave (P. Bickel and R. Friedrich, 2005).

But an energy’s deathprint, as it is called, is rarely discussed. The deathprint is the number of people killed by one kind of energy or another per kWhr produced and, like the carbon footprint, coal is the worst and wind and nuclear are the best. According to the World Health Organization, the Centers for Disease Control, the National Academy of Science and many health studies over the last decade (NAS 2010), the adverse impacts on health become a significant effect for fossil fuel and biofuel/biomass sources (see especially Brian Wang for an excellent synopsis). In fact, the WHO has called biomass burning in developing countries a major global health issue (WHO int). The table below lists the mortality rate of each energy source as deaths per trillion kWhrs produced. The numbers are a combination of actual direct deaths and epidemiological estimates, and are rounded to two significant figures.

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Go there and read. The numbers are disgusting. More tomorrow.

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