IOGA provides the example that to mandate public hearings when there is no request to have one unnecessarily delays projects that pose no significant environmental risk. Requiring meetings is not in the public interest. The example provided is not the result of an oil and gas policy requirement. We are not aware of any mandatory public meeting requirements in Bureau policies that apply to permits for oil and gas operations. We agree with the comment and believe the bureau does exercise discretion when necessary to maintain the intent and goals of the specific requirement.
Updates are underway.
See the last section of this report. Changes may be made once we reach agreement with EPA on this delegated program. IOGA commented that a general permit for brine spreading as a beneficial use would provide standards for more consistent reviews at the municipal level. The Department should finalize this general permit. To facilitate operator compliance and eliminate unnecessary costs, they suggest the permitting policy be revised to accommodate permit revisions.