Deadline for Public Comment on Chapter 78 Changes Ends Midnight Tonight

From the Responsible Drilling Alliance Newsletter

The Environmental Quality Board (EQB) of the PA Dept of Environmental Protection (DEP) has proposed changes to Chapter 78 regulations governing drilling in PA’s Marcellus shale. The period for public comment on these new regulations ends at midnight tonight, August 9th. Will you please take 2 minutes right now to make your voice heard on this critical issue?

When it comes to the potentially risky process of gas extraction, tighter regulations are certainly called for. We applaud EQB’s efforts, but do not believe the new Chapter 78 proposals go far enough. In many areas, including cement well casing, incident reporting and air quality controls – far more stringent regulations are needed.

Earth Justice, a non-profit legal advocacy organization, hired environmental and petroleum engineers from Harvey Consultants to study and make recommendation to the EQB about Chapter 78 proposals.

The RDA Board of Directors has studied the Harvey Consulting document in depth and agrees with the 49 recommendations made by Harvey Consultants and set forth in a proposal to the EQB on March 1, 2010. We urge you to contact the EQB to express your concern over challenges that hydrofracking technology and gas development poses to both environmental and human health and safety. In your request, ask EQB to adopt the more rigid standards as set forth in the proposal made by Harvey Consulting.

Send your comments electronically to: Be sure to use subject heading “CH 78 Regulations” and to include your full name and address in the text of the email.

You can read the Harvey Consulting document at:

If you are unsure which points to make, we urge you to simply ask the EQB to include the language proposed by the Harvey Consulting report in the new Chapter 78 regulations.

That one sentence, along with your name and address, can make a difference. Thank you.

Responsible Drilling Alliance

Examples of Harvey Report recommendations:

#1 – Cement. Compared to PA law, Texas requires a 72-hour compressive strength standard for cement of at least 1,200 psi where the well bore passes through aquifers and drinking water. By comparison, PA DEP’s definition for cement sets a 24-hour compressive strength standard of at least 500 psi. Texas has found that standard insufficient to prevent vertical migration of fluids or gas behind pipe. The Harvey report suggests that PA adopt the stricter standards enforced in Texas.

#2 – Protection of Water Supplies. EQB has not made any revisions to set a timeframe for acting upon a complaint filed for pollution of a water supply as a result of drilling or operating a gas well.  Experience tells us that folks without water are often ignored for weeks, as gas-drilling companies deny responsibility for polluting drinking water supplies and tie things up in court. The Harvey recommendations demand a response within 24 hours.

#3 – Blowout Preventer. We need only look to the BP disaster in the Gulf and the recent gas well blowout in Clearfield to know the grave danger of well blowouts.  Injury, fire, explosion, spills, gas venting, equipment damage, water pollution, and other environmental destruction and are possible.  The Harvey report suggests that ALL wells should be drilled with a Blow-Out Preventer.  No exceptions.

Responsible Drilling Alliance, Board of Directors
Ralph Kisberg
Jon Bogle
Robbie Cross
Barb Jarmoska
Janie Richardson


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