June 21, 2019  
Director Adam Wygant  
Oil, Gas, and Minerals Division  
Michigan Department of Environmental, Great Lakes, and Energy  
525 West Allegan Street  
Lansing, Michigan 48909-7756  
RE: Oil and Gas Operations 2019-001 EG Rule Set  
Dear Director Wygant:  
The Michigan Oil and Gas Association, on behalf of its nearly 850 members, supports the  
Oil and Gas Operations 2019-001 EG proposed rule set.  
Michigan’s home state oil and gas production provides safe, affordable and reliable  
energy that keeps homes and families warm and safe, and fuels industry and business. In  
addition, our industry contributes to approximately 47,000 jobs and a $13 billion economic  
impact in Michigan.  
This rules package will ensure that the State of Michigan has an equally effective  
program for protecting underground sources of drinking water (USDW’s) compared to federal  
standards by expanding and strengthening the definition of USDW’s. Under the new rule set,  
fresh water is defined as water contains less than 1000 milligrams per liter of total dissolved  
solids. While mineral water is defined as water that contains 1000 milligrams per liter or more of  
total dissolved solids. These definition changes provide protection for additional sources of  
water, beyond what was previously defined in rules as “fresh water” and make certain that the  
Michigan program covers the same USDW’s as the federal program.  
The proposed rule set puts in place additional safeguards for Michigan’s fresh water  
resources and gives the Michigan Department of Environment, Great Lakes, and Energy another  
tool it needs to protect drinking water and safely regulate Class II injection wells. The changes  
ensure Michigan follows the high standards set by the EPA.  
Respectfully,  
Erin D. McDonough  
President  
A CMS Energy Company  
July 11, 2019  
Oil, Gas, and Minerals Division  
Michigan Department of Environment, Great Lakes, and Energy  
Attention: Adam Wygant  
525 West Allegan St  
Lansing, MI 48909-7756  
RE: Consumers Energy Company’s response to proposed rule revisions under Part 615 (1994 PA 451, § 324.61501)  
Consumers Energy Company is one of Michigan’s largest combined gas and electric utilities, serving over 6 million of  
Michigan’s 10 million residents. Thus, Consumers Energy (Consumers) appreciates the opportunity to comment on  
the proposed rule set (2019-001 EQ), outlining the State’s anticipated primacy for Class II wells, under the  
Underground Injection Control (UIC) program and other proposed amendments to Part 615. Consumers recognizes  
that these comments are being submitted after the published deadline of July 5, 2019 and respectfully requests  
their inclusion in the record for the proposed rule changes. Consumers has reviewed the revised, published rule set  
and offers the following comment:  
R324.102 (z) – The revised rule defines “Mineral Water” as “water that contains 1000 milligrams per liter or more of  
total dissolved solids.”  
Recommendation – This addition seeks to numerically define and protect potential Underground Sources of  
Drinking Water (USDW), as articulated in the proposed rule documentation and defined by 40 CFR 144.3. However,  
the definition provided at Rule 102(z) does not include an upper milligram per liter limit. This could result in brines,  
common to oil and gas operations, being interpreted as mineral water, which is unlikely the intent of the proposed  
revision, as brines are regulated separately throughout Part 615. Therefore, Consumers recommends that this  
definition be revised to reflect the intent of the rule to protect USDWs. A potential revision is: (z) “Mineral water”  
means water that contains 1000 milligrams per liter or more, but less than 10,000 milligrams per liter total dissolved  
solids.  
Thank you for considering our comments. Consumers Energy supports the State and the Department of  
Environment, Great Lakes, and Energy in their effort to obtain primacy for the UIC Class II program.  
We welcome the opportunity for further dialog should you have questions or desire further clarification. I can be  
contacted at 517-788-1285, or heather.dziedzic@cmsenergy.com.  
Sincerely,  
Heather Dziedzic  
Consumers Energy  
Environmental Regulations & Strategy  
Senior Environmental Planner: Land & Water Management  
1945 W. Parnall Rd, P22-326  
Jackson, MI 49201  
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