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Amendments to 25 Pa. Code Chapter 78 and Chapter 78a, Subchapter C

Thank you for the opportunity to submit comments on the final draft regulations for oil and gas surface activities (amendments to 25 Pa. Code Chapter 78 and Chapter 78a, Subchapter C). We also appreciate the willingness of the Department of Environmental Protection (DEP) to extend the comment period and conduct public hearings on the final draft regulations.

Earthworks is a nonprofit organization dedicated to protecting communities and the environment from the impacts of mineral and energy development while seeking sustainable solutions. For more than 25 years, we’ve worked to advance policy reforms, safeguard land and public health, and improve corporate practices. Our Oil & Gas Accountability Project works with local communities, partner organizations, public agencies, and elected officials to advance these goals nationwide, including in Pennsylvania.

DEP has clearly strengthened important aspects of the regulations since the first draft was issued in early 2014. Such progress reflects the fact that the Department received more than 25,000 comments—many of which expressed grave concern over the continued negative environmental and health impacts of gas and oil development being experienced by communities across Pennsylvania.

Earthworks has signed on to the extensive technical comments on the proposed revisions to Chapter 78a submitted by Earthjustice on behalf of a number of environmental and citizens organizations. In the following pages, we submit additional comments focusing specifically on waste management, public resources, and orphaned and abandoned wells.

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