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
Sincerely,
Heather Dziedzic
Consumers Energy
Environmental Regulations & Strategy
Senior Environmental Planner: Land & Water Management
1945 W. Parnall Rd, P22-326
Jackson, MI 49201