How the grinch stole public comment

Who says the Illinois Department of Natural Resources doesn’t have holiday spirit?  They’ve scheduled the public comment period for their huge and hugely problematic set of draft fracking rules to coincide exactly with the holiday season.  The comment period began running last Friday, and ends January 3.  Jingle all the way.

It is, of course, a rather grinchy sort of holiday spirit.  Both the holiday timing and the nature of the planned public hearings appear almost designed to minimize public participation. The Department is offering a total of two two-hour public hearings, one of them on November 26 in Chicago and the other on December 3 in Ina.   First off, November 26 is two days before Thanksgiving.  A time when the vast majority of people – even people who care deeply about fracking – are home with their families making feast preparations.  Second – two hours?  At least a chunk of any public hearing generally involves presentations by the agency – the infomercial part of the hearing.  If the whole thing is two hours long, there realistically isn’t time for much else, unless they drastically limit the time allotted to individual speakers.    And third, there is no hearing scheduled for anywhere in the central part of the state, where a good portion of the high-volume fracking covered by the regulations is expected to occur. 

The Illinois Environmental Council, an association representing the major environmental organizations in the state, is sending a formal request to the Department asking for additional hearings – one more in Chicago that is not smack in the middle of Thanksgiving week, and one in the neglected central region.

In the meantime, for those interested in attending one of the currently-scheduled hearings, here is the information: 


Tuesday, November 26, 2013

6:30pm-8:30pmUniversity of Illinois at Chicago (UIC)

726 S. Halsted Street, Student Center East, Room 302

Chicago, IL 60607


Tuesday, December 3, 2013


Rend Lake College Theater

468 North Ken Gray Parkway

Ina, IL 62846

Concerned citizens can also send their comments in writing.  But the Department has managed to make even that ordinarily straightforward process complicated and inaccessible.  DNR’s web page concerning the rulemaking provides a snail mail address:

Robert G. Mool

Department of Natural Resources

One Natural Resources Way

Springfield IL 62702-1271

But for the many people who will likely want the convenience of electronic submission – particularly since snail mail comments would probably need to be sent in before New Years to make sure they got to DNR in time – the Department has devised a devilishly complicated form requiring that commenters specify the subpart and section of the rules they are commenting on.   

NRDC and others in our coalition will be preparing guidance in the days ahead to assist the public through the overcomplicated comment process.  But honestly, commenting on a rule of critical importance to so many ordinary citizens should not require a law degree and a spreadsheet.  The Department owes it to the public to simplify things.

So happy holidays everyone.  And if you run into Santa before the comment period ends, you can give him that address on One Natural Resources Way and suggest he deliver a great big lump of coal.

About the Authors

Ann Alexander

Senior Attorney, Midwest program

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