Comment by pkrein
7 hours ago
Hi HN, author here.
I wanted to address the most common theme in the comments: safety.
The regulatory burdens I've encountered and described were not related to safety requirements. They are procedural questions with no bearing on safety.
Whether an injection well is Class I disposal, Class II oilfield disposal or Class V experimental has no bearing on the (strong and reasonable) safety requirements to protect underground sources of drinking water... the problem is the delay that comes from deciding which class is most appropriate (turns out, Class V experimental).
And ditto, whether a Revoy is a tractor, a trailer, or a converter dolly for the purposes of DMV registration paperwork has no bearing or relation to the (again strong and reasonable) NHTSA FMVSS safety requirements... the problem is the delay on the procedural paperwork.
I think we can all agree that these procedural issues are not "written in blood", but are in fact regulatory bikeshedding that we'd all be better off without.
The issue I see is that companies have limited liability. If they mess up, they can just go bankrupt and sometimes pass the cleanup costs on to society.
Therefore, I think it’s fair that society wants to have a say in what gets done and what doesn’t.
Maybe a way around this would be companies operating without limited liability. Would you be willing to put your entire fortune on the line in exchange for a fast track through regulations?
Edit: to clarify: I’m not arguing that all companies should lose limited liability. I’m suggesting the introduction of a new type of company structure.
> If they mess up, they can just go bankrupt and sometimes pass the cleanup costs on to society.
Or as Dupont, Dow, the Ethyl Corporation et al have shown, don't even go bankrupt and still pass on the cleanup costs on to society.
Indeed. Thank you for writing this and speaking up in public.
Many of the comments here that essentially reply to your article by saying “regulation is good, stop criticizing it”, are deeply depressing. That is a regulatory mind virus that must be destroyed before it kills us.
Casually looking at classifications at https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D...
it seems that you could be hitting an edge case that inconveniences you. On the other hand if the classification were made irrelevant, someone working with Class V "Air conditioning return flow wells used to return to the supply aquifer the water used for heating or cooling in a heat pump;" might be aggravated by being held to the same standard as Class I "Wells used by generators of hazardous waste or owners or operators of hazardous waste management facilities to inject hazardous waste beneath the lowermost formation containing, within one quarter (1⁄4) mile of the well bore, an underground source of drinking water.". Because if the regulations were merged, it would be inappropriate not to use the stricter safety standard of all.