Comment on Proposed Rules Proposed to Regulate Fracking in Illinois
On November 15, 2013, the Illinois Department of Natural Resources (IDNR) issued rules that would implement regulations on hydraulic fracturing that were adopted on June 19, 2013.
After reviewing these rules, grassroots organizations and potentially impacted communities believe that these rules are not strong enough to protect Illinois residents from the hazards of fracking. Even those groups that worked on the legislation ultimately passed believe that these draft rules undermine key elements of the law.
Information that follows is intended to provide the tools required to a comment a day on these rules, in order to slow the process and ultimately work for a moratorium on hydrofracking in Illinois. Comments will be accepted through Friday, January 3, 2014.
Your comments can call out very real health and environmental concerns associated with these new rules. They also can “bury the DNR” in comments with the goal of slowing down the process of fast-tracking the rules into law and buying additional time to explore a potential moratorium with the Illinois legislature.
As Sandra Steingraber explained during her keynote address at this year’s Great Lakes Bioneers Chicago’s event, this is the process that proved to be effective in obtaining a moratorium on hydraulic fracturing in New York State.
First … Read the Proposed Rules
Proposed Administrative Rules for the Hydraulic Fracturing Regulatory Act
Proposed Administrative Rules for Seismicity
Then Comment on Rules
Write a comment a day to IDNR on why you believe the rules they released are inadequate to protect Illinois. You can submit as many comments as you like electronically or by mail through the end of the day on Friday, January 3. See “How to Make Effective Comments” below.
Comments must be provided by subpart of the rules. The IDNR is asking that comments made be specific, and limited to one subpart and one issue or concern per comment. However, multiple comments can be made by submitting another comment using their comment form.
Can You Attend a Public Hearing?
Tuesday, Novermber 26, 6:30-8:30pm
750 S. Halsted St., UIC Student Center, Room 302
Click here for hearing procedures and dates, times and locations for other hearings in the state.
How to Make Effective Comments
Know what you are commenting on! Read the rules and the regulations so that you understand the genesis of the suggested comments or concerns provided by each. You can receive a suggested comment each day by Illinois People’s Action for posting on IDNR’s website or go to Protect Illinois From Fracking, where the same comment is posted and your comment will both be directed to the Illinois Department of Natural Resources and be printed for delivery to the IDNR at a press event.
Illinois People’s Action (IPA)
You can receive a suggested comment a day in your inbox by contacting Admin@illinoispeoplesaction.org and asking to be added to their email list for this purpose. This group provides comments that differ from the one below, thereby adding to your understanding of issues and concerns associated with hydraulic fracturing. Illinois People’s Action’s website also includes suggested comments and a portal to the IDNR comments page.
How to comment:
- Go to IDNR’s submit a comment page
- Click the button that relates to your comment (provided by Illinois People’s Action)
- In the “Section” dropdown box, click the applicable section (provided by Illinois People’s Action)
- Add your comment.
- Click “Submit”
The IPA is asking that we also copy comments to the Joint Committee on Administrative Rules of the General Assembly (JCAR). Read more below.
Protect Illinois from Fracking
This group makes it easy to submit a comment. You will be prompted to submit a user name and password as you prepare your first comment. At that time, you will be given the option of giving this group your approval to print and hand deliver your comment to the IDNRHere’s what you need to do to get started:
- Go to http://www.protectilfromfracking.org/
- Read the suggested comment.
- Read the rules.
- Write your own comment, OR click the link: “click here to copy the above comment”.
- Edit the comment to reflect your concern or perspective on the proposed rule.
- Copy your comment to your clipboard, so you can send it in an email to JCAR (see below).
- Remember to come back each day for a new issue to comment on!
Joint Administrative Committee on Rules (JCAR)
The Joint Administrative Committee on Rules is a bipartisan legislative oversight committee created by the General Assembly in 1977. Pursuant to the Illinois Administrative Procedure Act, the committee is authorized to conduct systematic reviews of administrative rules promulgated by State agencies. Click here to see who serves on this committee.
This is the committee that will decide on the rules, and the JCAR can take a wide range of actions – from accepting the rules to filing a prohibition against their adoption. The IPA is recommending that comments submitted to the IDNR also be submitted to JCAR so that they can see the breadth (and number) of public concerns directly (as opposed to seeing a summary from the IDNR).
Copying the JCAR on your comments is easy:
- Copy your comment to your clipboard BEFORE you click submit on the online comment form you are using.
- Open your email browser and paste your comment.
- Paste JCAR@ILGA.gov into the “To” line of your email.
- Add “Comment on Proposed Rulemaking, Hydraulic Fracturing” in the subject line.
- Add the subpart you are commenting on above your comment.
- Add your name and address below your comment, so that JCAR knows you are a resident of Illinois.
- Click send.
The IDNR will review comments and modify the rules before filing for Second Notice. This is likely to take several months. We will post the date of this filing, since it will trigger another opportunity to comment on the modified rules.
November 24, 2013
NOTE: Banner photo: Fracking on Public Lands WildEarth Guardians/Flickr