From the letter
John Ryder, Director of District Oil and Gas Operations
Department of Environmental Protection, Bureau of District and Oil and Gas Operations
Rachel Carson State Office Building, 15th Floor
P. O. Box 8765, Harrisburg, PA 17105-8467
ra-epoilandgas@pa.gov
Re: Comments on Standards and Guidelines for Identifying, Tracking, and Resolving Violations
Dear Mr. Ryder:
On behalf of the undersigned organizations, thank you for the opportunity to comment on the substantive revisions to the Standards and Guidelines for Identifying, Tracking, and Resolving Violations recently issued by the Pennsylvania Department of Environmental Protection (hereafter the Department).
As you know, our organizations have been actively involved in research and ongoing discussions with Department staff about policies and procedures, in particular water testing protocols, contamination investigation processes, approaches to enforcement, and citizen communication and response. With this experience in mind, we offer the following comments on numerous aspects of the Standards and Guidelines (hereafter the Guidelines).