Illinois Drilling Rules Comments

September 13, 2013

The Honorable Members of The Joint Committee on Administrative Rules

Dear Member:

My name is Douglas Dougherty. I am President and CEO of the Geothermal Exchange Organization (GEO). GEO is the national trade association representing the geothermal heat pump industry. With over 300 members representing thousands of employees, many employed here in Illinois, we deploy a technology that the U.S. EPA and the U.S. DOE recognize as the most efficient method to satisfy the thermal loads of buildings. Illinois, however, is set to adopt a Rule (JCAR770902-1217308r02) that would impede the deployment of this energy efficient technology.

GEO respectfully requests that the adoption of the Rule be delayed until the December meeting of JCAR to allow for a workshop for interested parties to recommend changes to the proposed language. Specifically GEO is concerned that there is no definition for thermal enhanced grout which is a mixture of bentonite and sand and is the industry standard. Lack of this definition carriers forward to impact the practicality of the language contained in Section 920.180 a) Construction of Closed Loop Wells.

A number of the setback requirements listed on Table C would preclude the installations of geothermal heat pumps in metropolitan regions of Illinois. Generally, setbacks for closed loop wells are not needed as no contaminants are used in the construction or operation of these closed loops of polyethylene pipe. Footnote 4 on Table C should not apply to closed loop wells as geothermal heat pumps are housed in the building.

The geothermal heat pump industry recently applauded the Illinois General Assembly for the passage of SB 1603 which changed the definition of energy efficiency used by electric utilities to include geothermal heat pumps. New regulations for the construction and operation of a loop heat exchanger are welcome if done properly. The proposed Rule before you needs several modifications to ensure the geothermal heat pump industry expands in Illinois and we ask you for additional time.