Thank you for the opportunity to comment on the Maryland Department of the Environment’s (the Department) proposed regulations at COMAR Title 26 Subtitle 19 Chapter 1 Regulation .01- .61 (Oil and Gas Exploration and Production) and Title 26 Subtitle 08 Chapter 07 Regulation .04 (Underground Injection Control).1 Please accept these comments on behalf of Earthworks, a national nonprofit organization dedicated to protecting communities and the environment from the impacts of energy development while seeking sustainable solutions.
The best way to protect our communities, environment, and natural resources from the adverse impacts of oil and gas development is to end our reliance on fossil fuels as soon as possible. No amount of regulation makes drilling safe. The Department should simply prohibit all oil and gas drilling in Maryland.
That said, these current proposals substantially weaken the level of protection afforded to Marylanders under the previous Administration (the 2015 regulations).2 For instance, the Comprehensive Development Plan (CDP) process now removes authority from state agencies to approve, deny, or place conditions upon the CDP. Baseline monitoring, once two years for both air and water, is now just one year only for water monitoring. Finally, these regulations should include a standard citizen suit provision,