10 August 2008
Lionel Milberger
REV = 0, 10 August 2008
CHARACTERISTICS of RRC RULES
1. They are permissive.
2. They are NOT Restrictive. When they are restrictive, there is always a “way out”.
3. They are not limiting of O&G activities.
4. They are vague.
5. They are NOT punitive.
6. They are subject to interpretation in several ways.
7. If there are requirements, the requirements are generally as follows:
a. Inform agency or public officials (not the public or individuals).
b. Put up signs.
c. Send in reports.
d. Make rudimentary calculations.
8. They are inclusive of some basic mapping data.
9. There are some well spacing requirements.
10. Enforcement is almost never included as a requirement. Enforcement, if required, is at the expense and efforts of public individuals.
11. They are NOT inclusive of current best available technology.
12. There is NO Rule that requires citizens complaints made to the agency to be kept confidential.
About Sharon Wilson
Sharon Wilson is considered a leading citizen expert on the impacts of shale oil and gas extraction. She is the go-to person whether it’s top EPA officials from D.C., national and international news networks, or residents facing the shock of eminent domain and the devastating environmental effects of natural gas development in their backyards.
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