..but because the city has conflicting directives in their ordinance, ….
..but because the city has conflicting directives in their ordinance,
..the same arguments apply that the city is not enforcing #23 to use Best Available Control Technologies (BACT).
For drilling will you enforce #6 or #23 in mandating electric rigs regardless of the absence of a nearby protested use? The protected use definition needs to change to protect humans/receptors (people playing golf or using the country club).
Rolling Hill pic during drilling August 2015-this Helmerich & Payne rig looks like an electric rig? But the way our ordinance is loosely worded, they don’t always HAVE to use electric rigs in Urban Drilling.
For fracking will you enforce #6 and #21? In these pictures, they are NOT in compliance…
photo by Tammie Carson 2/22/16
photo by Tammie Carson 2/2/16
Per our Arlington Gas Well Ordinance (I boldfaced for emphasis)…….
6. Dust, Vibration, Odors. All drilling and production operations shall be conducted in such a manner as to minimize, so far as practicable, dust, vibration, or noxious odors, and shall be in accordance with the best accepted practices incident to drilling for the production of gas and other hydrocarbon substances in urban areas. All equipment used shall be so constructed and operated so that vibrations, dust, odor or other harmful or GAS DRILLING AND PRODUCTION 7.01 ARTICLE VII – 2 (Amend Ord 11-068, 12/6/11) annoying substances or effect will be minimized by the operations carried on at any drilling or production site or from anything incident thereto, to the injury or annoyance of persons living in the vicinity; nor shall the site or structures thereon be permitted to become dilapidated, unsightly or unsafe. Proven technological improvements in industry standards of drilling and production in this area shall be adopted as they become available if capable of reducing factors of dust, vibration and odor. Watering, wetting or other methods or materials must be used to control dust adjacent to residential property.
21. Muffling exhaust. Exhaust from any internal combustion engine, stationary or mounted on wheels, used in connection with the drilling of any well or for use on any production equipment shall not be discharged into the open air unless it is equipped with an exhaust muffler, or mufflers or an exhaust muffler box constructed of noncombustible materials sufficient to suppress noise and prevent the escape of obnoxious gases, fumes or ignited carbon or soot.
23. Rigs. Electric or diesel-electric hybrid rigs must be utilized for drilling a well located within four hundred fifty (450) feet of a protected use. The CD&P Director may authorize the use of alternative rigs in specific cases if it is determined that the project is in substantial compliance with this Chapter.
I also recall the ERG air study representative explaining that if someone is not using the clutch right on a diesel drilling rig that they make unnecessary diesel emissions.
This is a pathetic example of Urban Drilling.