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The STRONGER Board of Directors seeks your input on the attached draft of guidelines for state regulations governing hydraulic fracturing of oil or gas wells. These guidelines would supplement the Guidelines for the Review of State Oil and Natural Gas Environmental Regulatory Programs, which are used by STRONGER and its stakeholder review teams in evaluating the oil and gas environmental regulatory programs of states that have volunteered to be reviewed. The Interstate Oil and Gas Compact Commission (IOGCC) originally adopted the Guidelines in 1990, with the understanding that they would be periodically reviewed and updated. The IOGCC adopted revisions to the Guidelines in 1994, and, in 2000, the IOGCC accepted revisions to the Guidelines developed by STRONGER, the independent stakeholder organization newly formed to administer the state review process. Subsequently, STRONGER developed revisions addressing emerging issues, including storm water control, spill risk management, and program performance measurement. The Guidelines have served the state review process as an effective tool for documenting the success of states’ oil and natural gas environmental regulatory programs, and for making recommendations for program improvement. Earlier this year, STRONGER convened a stakeholder workgroup (see attachments below) to consider the need for guidelines addressing hydraulic fracturing. In accordance with its charge (see attachments below), the workgroup met several times over the last few months, reviewed the issues surrounding hydraulic fracturing, and drafted a new set of guidelines addressing those issues. The draft guidelines are captioned “Section X. Hydraulic Fracturing.” This caption does not denote that the hydraulic fracturing guidelines will be “Section 10” of the Guidelines, but is merely a placeholder until the STRONGER Board determines whether these guidelines should appear as a separate section of the Guidelines or be incorporated into an existing section of the Guidelines. The draft guidelines are structured similarly to some sections of the existing Guidelines and refer to specific sections of the existing Guidelines where applicable. A copy of the existing Guidelines may be found on the STRONGER website (www.strongerinc.org). Please note that the guidelines do not establish specific numerical criteria or prescriptive regulatory standards for states. The states vary too much in climate, geology, hydrology, topography, and other factors to be amenable to one-size-fits-all regulation. Instead, the guidelines outline the key elements of effective state oil and gas environmental regulatory programs and establish environmental goals or objectives for those programs. The guidelines are designed to be used by stakeholder review teams as a yardstick by which to evaluate state programs, identify program strengths, and make recommendations for improvement. To give you some background on the state review process and put the draft guidelines into context, we are distributing with the draft guidelines a report recently prepared for the STRONGER Board on the history, accomplishments and challenges of the state review process. The STRONGER Board appreciates your assistance in reviewing the draft guidelines. The Board wishes to make the guidelines available for use in reviewing state programs as soon as possible, so please submit your comments by December 16, 2009 to Mike Nickolaus at mnickolaus@gwpc.org or: Ground Water Protection Council 13308 N. MacArthur Blvd. Oklahoma City, OK 73142 Sincerely,
Hal Fitch, Chairman STRONGER, Inc. Attachments: |
