From the letter text:
Dear Sir or Madam:
On behalf of the Center for Biological Diversity, Earthworks, Environmental Working Group, and Sierra Club and their members, we write to urge the Office of Administrative Law (OAL) to reject the Interim Well Stimulation Treatment Regulations proposed by the Department of Conservation, Division of Oil, Gas, and Geothermal Resources (DOGGR), published in the California Register and on OAL’s website on December 19, 2013. The Interim Regulations put public health and safety at risk, and are inadequate to protect California’s air, water, and climate. Furthermore, DOGGR’s interim regulations do not comply with California law. The OAL should reject these interim regulations, and deny further reconsideration until DOGGR revises the regulations to comport with existing state law.
The proposed regulations are designed to implement Senate Bill 4, which takes effect January 1, 2014. The Interim Well Stimulation Treatment Regulations suffer from a fundamental legal flaw: they are based upon an erroneous legal interpretation of SB 4. The Well Stimulation Treatment Regulations proceed on the assumption that well stimulation or fracking can take place without formal permitting procedures and instead can proceed with only “check- the-box” oversight by the California Department of Conservation to determine whether the applicant has submitted an Interim Well Stimulation Treatment Notice with some of the information that an applicant must provide to meet the disclosure requirements of SB 4.
