More than two years after the Rayzor Ranch wells opened our eyes to our broken ordinance, we now have a band-aid for it. I appreciate the hard work by citizens, Council, Staff, Task Force members, and experts. But somehow we have all failed to put together a set of rules that protects health, safety, and welfare. It’s not too late to fix this. There are two steps involved: a.) point out remaining inadequacies; and b.) propose alternatives to remedy the shortcomings.
DAG is going to over-track the ordinance to accomplish the second objective. Let me here just point out some of the most glaring shortcomings. This is only a selection. It sticks to Task Force recommendations and shows how even those are not adequately reflected in the draft. This does not even mention all the other viable ideas out there (many currently in ordinances from other cities) that are not in the draft ordinance.
1. Vapor recovery units (VRUs): This was a DAG and Task Force recommendation. It has found its way into the ordinance but VRUs will only be installed on wells emitting more than 137 pounds of VOCs and other pollutants daily. That will not cut it.
2. Green completions: This was a DAG and Task Force recommendation but it is nowhere to be found in the draft. The draft prohibits venting and flaring EXCEPT when allowed by the RRC or TCEQ or when a variance applies. This is a running mantra in the draft – Exceptions, Exemptions, Variances, Loopholes, Caveats. Let’s put some spine into our City laws.
3. Compressor stations: DAG recommended banning them from the City (or at least zone them industrial). The Task Force recommended “regulating” them. The ordinance is silent on this matter. Actually, it’s worse: an over-tracked comment suggests that there is a line addressing this item, but that is misleading. The line actually refers to lift compressors and those are not the same thing.
4. Private water well testing: DAG and the Task Force recommended this. The ordinance is silent, again. Are you starting to detect a pattern here?
5. Closed loop systems: DAG recommended closed loop systems and no open pits. The Task Force recommended closed loop systems. The draft only requires closed loop MUD systems and still allows many different kinds of open pits.
It is starting to feel like wool is slipping over our eyes. Let’s stay alert. There is much yet to be done.