NCCN comment letter: fracking stormwater rule

The comment period just closed (Aug. 1) for public input on the NC Environmental Management Commission's proposed rules to manage stormwater at shale gas development (fracking) sites.  The main package of fracking rules - proposed by the NC Mining & Energy Commission - remains open for comment through Monday, Sept. 15.

In brief, our comments urge the EMC to:

• sharpen the distinction already in the proposed rule between stormwater and wastewater; 
• extend 'good housekeeping' requirements for the life of a well; 
• set a stronger design storm; 
• add provisions to guide repair of structural practices that become contaminated; 
• provide for stronger state oversight;
• provide for public comment on permits; and 
• retain aspects of the proposed rule that will help guard against poor implementation. 

Our full comments are here.