OAKLAND — Citizen Shale has completed its comments on the Governor’s Marcellus Shale Safe Drilling Initiative draft report on Best Management Practices for Marcellus Shale Development in Maryland.
“Many of you realize that the cart was placed in front of the horse in the development of the BMPs,” wrote Eric Robison, president of Citizen Shale. “The state of Maryland’s decision to compile BMPs before many other studies were completed seems to suggest that the state is moving forward with development of regulations without specific facts regarding the outcome of those studies.”
Robison suggested that a comprehensive way to form the BMPs would have been to fund a risk analysis, which would have guided the studies and scope for each. After those studies were completed, then the BMPs should be compiled, noted Robison.
The report is the second of three reports requested by Gov. Martin O’Malley’s safe drilling initiative. The primary focus of the report regarded environmental protection of potential drill sites.
“There are many areas within the BMPs that have what many would suggest are gold standards, but equally there are areas that lack informed decisions or have established industry guided recommendations,” wrote Robison. “Due to the complexity of the BMPs, Citizen Shale attempted to compile comments on areas that appeared to lack the gold standard approach to development of natural gas in the state of Maryland.”
Should hydraulic fracturing come to the state, one regulation to be implemented will be a mandatory Comprehensive Gas Development Plan to be done by any energy company applying for a permit to drill in the state.
“Though limiting clustered development to certain areas, Comprehensive Gas Development Planning requirements will ultimately create more intensive ‘sacrifice zones’ in the areas where this highly concentrated development takes place,” stated Citizen Shale in its comments.
The CGDP will cover a report on the location a company wishes to drill, how it will construct the well, materials that will be involved in drilling and other aspects in the production of the gas.
During a previous public forum, Christine Conn of the Maryland Department of Natural Resources explained the purpose of the CGDP is to allow the DNR and Maryland Department of the Environment, as well as other stakeholders, to recommend any changes to the company prior to drilling. Maryland would be the first state to mandate a CGDP by a government agency as a prerequisite for applying for a permit.
“There needs to be an external review process from MDE and DNR for permitting, siting, construction and operation of all pipelines and ancillary development outside of the CGDP process,” states Citizen Shale in its comments. “This can be addressed in the 2014 legislative session as a bill for the PSC (Public Service Commission) to adopt permitting for rural gas gathering lines within the state.”
As an organization, Citizen Shale hasn’t taken a position on fracking but has tried to stay within its mission of encouraging dialogue and supporting comprehensive efforts to protect individuals and communities from the wide-ranging impacts of shale gas development, said Robison.
The public comment period for the BMP draft report has been extended through Sept. 10. The report can be found at www.mde.state.md.us and a copy of the draft report is available at the Ruth Enlow Library in Oakland and the Frostburg Community Library.
On behalf of MDE, the Regional Economic Studies Institute of Towson University as part of the Maryland Marcellus Shale Safe Drilling Initiative is conducting a survey and it can be found at http://resisurvey.resiusa.org/surveydata/ContingentValuation.htm
Comments on the BMP can be made to the MDE at firstname.lastname@example.org
To view Citizens Shale’s comments in their entirety, visit http://citizenshale.org/wp-content/uploads/2013/08/Citizen-Shale-BMP-comments.htm.