Information to tell DOGGR to ban Fracking

Information about contacting DOGGR about Fracking

Comments regarding the proposed regulations can be submitted via email to DOGGRRegulations@conservation.ca.gov; via FAX to (916) 324-0948; or via regular mail to the Department of Conservation Office of Governmental and Environmental Relations, 801 K Street MS 24-02, Sacramento, CA  95814, Attention: Well Stimulation Regulations.

DOGGR, The Department of Oil, Gas and Geothermal Resources, (part of the CA Department of Conservation), is holding several public hearings this month about the regulations they are developing in response to Senate Bill 4 (Pavley).  For more information about the practice and regulation of “well stimulation” (fracking), visit DOGGR’s website: http://www.conservation.ca.gov/dog/Pages/Index.aspx

The Sierra Club has suggested that if people are not able to attend they write to DOGGR to express their opinions.   The Sierra Club provided the following talking points for your use:

The agency should declare a moratorium first and foremost.

There is a crying lack of comprehensive science studying the potential impacts to California’s water, air, climate, natural resources, environmental quality, and health goals. The inadequacies of the current and proposed regulatory safeguards demonstrate the clear need for a cautious approach. The Division of Oil Gas and Geothermal Resources (DOGGR) has the authority to implement the precautionary principle and put an immediate halt to well stimulation projects. It should use this authority now.

The proposed regulations fail to protect public health and the environment in several ways, including:

 

  • The proposed regulations are not consistent with SB 4’s expectation of treatments to be regulated. Specifically, "well stimulation treatment" is too narrowly defined. It limits the regulations to only treatments that penetrate a formation more than 36 inches from the well-bore and acid matrix stimulations that utilize more than 7% concentration of acid. These thresholds are arbitrary and could leave potentially dangerous processes under-regulated. SB 4 did not mandate that DOGGR establish a minimum penetration from the well-bore, and therefore this threshold distance appears to be unnecessarily limiting the scope of the regulations and undercutting the intent of SB 4, which is to regulate all forms of well stimulation.
  • DOGGR must adopt a definition covering any process that increases the permeability of a formation, regardless of distance of penetration or acid concentration.
  • The regulations set a precedent that will lead to inadequate protection of important water resources. The term "protected water" is defined narrowly, potentially leaving waters with beneficial uses unprotected.
  • The notification requirements are inadequate. For purposes of public notices, the definition of "tenants" as limited to residents with a written lease is far too limited and would exclude a number of lawful tenants who should receive the notice and information on water testing. 
  • Public disclosure is inadequate.  All notices to stimulate a well must be incorporated into the current Notice/Permit process for drilling and reworking/redrilling and be posted immediately to the Division's website on a daily basis in an easy-to-view format.  The speed at which the South Coast Air Quality Management District  has established online forms, notices, reporting, and databases for their well stimulation regulations demonstrates the capability to act to notify the public quickly.

Water monitoring proposal won’t protect water adequately. The regulations only require that water be monitored if it is within the 1500 foot radius from the well head and 500 foot radius from the vertical projection of a horizontal well. Dispersion of pollutants can and does reach much further than that—up to a mile in the cases of some pollutants.

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