Comments on ERO 019-7507…

Comments on ERO 019-7507 Proposed Oil, Gas and Salt Resources Act regulation changes for special projects and well security

We received the letter dated Sept. 1, 2023 concerning proposed changes on the proposal referenced above but nowhere on the letter did it state the end date of the comment period.

I realize that 45 days is often the usual comment period time allowed but other comment periods on the ERO have been longer in my experience of commenting on the ERO. This proposal should have a longer comment period.

But more importantly, if private natural gas well owners do not know about this proposal how can they comment? How has this proposal been advertised for the many private natural gas well owners across Ont? I have not seen any other way of informing our group of the proposed changes and the ways to comment. No Ministry ads in the local papers. No Ministry public in-person meetings across the province. How many private gas well owners were sent the letter? I doubt very much that all of the owners have been notified therefore many of the owners who would be affected by this proposal are not even aware of it. That is not the way a democracy is run. I believe the big word now is “transparent” and the fact this proposal is not informing many of the affected owners is certainly not being transparent.

A security fee has never been a requirement for private natural gas wells and should never be in the future.

Under Regulation Ontario Regulation 245/97 and the Private Gas Well Policy, private natural gas wells have always been excluded from requiring a security as shown below in the quote from Ont Reg 245/97:
“16. (3) …. well security required for each operator is,
(b) $0 for each private well;”

Private natural gas wells are well looked after and are not part of the problem of leaking or abandoned gas wells that the Ministry is trying to solve.

The security requirement for private natural gas wells must be removed from this proposal.