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How the grinch stole public comment

Ann Alexander

Posted November 18, 2013

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Who says the Illinois Department of Natural Resources doesn’t have holiday spirit?  They’ve scheduled the public comment period for their huge and hugely problematic set of draft fracking rules to coincide exactly with the holiday season.  The comment period began running last Friday, and ends January 3.  Jingle all the way.

It is, of course, a rather grinchy sort of holiday spirit.  Both the holiday timing and the nature of the planned public hearings appear almost designed to minimize public participation. The Department is offering a total of two two-hour public hearings, one of them on November 26 in Chicago and the other on December 3 in Ina.   First off, November 26 is two days before Thanksgiving.  A time when the vast majority of people – even people who care deeply about fracking – are home with their families making feast preparations.  Second – two hours?  At least a chunk of any public hearing generally involves presentations by the agency – the infomercial part of the hearing.  If the whole thing is two hours long, there realistically isn’t time for much else, unless they drastically limit the time allotted to individual speakers.    And third, there is no hearing scheduled for anywhere in the central part of the state, where a good portion of the high-volume fracking covered by the regulations is expected to occur. 

The Illinois Environmental Council, an association representing the major environmental organizations in the state, is sending a formal request to the Department asking for additional hearings – one more in Chicago that is not smack in the middle of Thanksgiving week, and one in the neglected central region.

In the meantime, for those interested in attending one of the currently-scheduled hearings, here is the information: 


Tuesday, November 26, 2013

6:30pm-8:30pmUniversity of Illinois at Chicago (UIC)

726 S. Halsted Street, Student Center East, Room 302

Chicago, IL 60607


Tuesday, December 3, 2013


Rend Lake College Theater

468 North Ken Gray Parkway

Ina, IL 62846

Concerned citizens can also send their comments in writing.  But the Department has managed to make even that ordinarily straightforward process complicated and inaccessible.  DNR’s web page concerning the rulemaking provides a snail mail address:

Robert G. Mool

Department of Natural Resources

One Natural Resources Way

Springfield IL 62702-1271

But for the many people who will likely want the convenience of electronic submission – particularly since snail mail comments would probably need to be sent in before New Years to make sure they got to DNR in time – the Department has devised a devilishly complicated form requiring that commenters specify the subpart and section of the rules they are commenting on.   

NRDC and others in our coalition will be preparing guidance in the days ahead to assist the public through the overcomplicated comment process.  But honestly, commenting on a rule of critical importance to so many ordinary citizens should not require a law degree and a spreadsheet.  The Department owes it to the public to simplify things.

So happy holidays everyone.  And if you run into Santa before the comment period ends, you can give him that address on One Natural Resources Way and suggest he deliver a great big lump of coal.

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Gerald QuindryNov 18 2013 08:46 PM

I disagree with you on one point -- the vast majority of fracking will occurr in Wayne, Hamilton, Clay and White counties. The meeting in Ina is very convenient to that area, where people actually have skin in the game. Areas more to the north, south or west are not areas where geologic conditions were suitable for petroleum generation in the New Albany Shale. Google "Vitrinite Reflectance" for an explanation. In those outlying areas,the shale is too thin or it is not in the VR 'sweet spot" of 0.6% to 0.7% which is optimal for for petroleum formation. To the north, VR 0.8%, so the hydrocarbons are mostly in the form of natural gas, not petroleum. Given the extremely low price of natural gas, nobody is going to waste time developing that resource, even if it was politically possible. It is not economically feasible. Far too many gas wells have already been drilled elsewhere. Companies are expecting renewed oil activity in the historical oil fields of the four counties mentioned. Incidentally, the county board of Wayne County unanimously approved a resolution supporting the renewal of oil activity in the area, using hydraulic fracturing techniques. There have been oil service companies here with the word "Frac" and/or "Acid" in their company names for many decades.

Gerald QuindryNov 18 2013 08:51 PM

Wow... Wish we could edit comments. Somehow a whole section got eliminated. Maybe because I used the "less than" symbol and the "greater than" symbol. What I intended to say was that the sweet spot for VR is between 0.6 and 0.7%. To the north of the four counties mentioned, the VR is less than 0.5% and not much hydrocarbon was formed. To the south, the VR is greater than 0.8% and that indicates that natural gas would be formed, not petroleum. To the west, the New Albany Shale thins out and is not likely to produce sufficient quantities of hydrocarbon to be worthwhile.

Sam SlaterNov 19 2013 08:37 PM

This is a very interesting article.

Comments are closed for this post.


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