Judging from the tenor and content of the comments that have been filed on the revised hydraulic fracturing (fracking) rule, the Interior Department’s Bureau of Land Management (BLM) may have to go back to the drawing board on the draft rule for a third time.

“While the revised proposed rule makes several improvements upon the May 2012 original proposed [fracking] rule, many shortcomings remain and the BLM should not finalize the rule as currently proposed,” said the American Petroleum Institute (API), which represents major oil and natural gas producers, as well as other sectors of the industry, in its comments on the second draft rule. The cost burden of the proposed rule and benefit shortfall was cited by producers as the main drawback.

“Although we firmly believe that this proposed rule is unnecessary, we recognize that it is possible BLM will proceed with the rulemaking. It is therefore our responsibility…to address our numerous concerns regarding both the technical requirements that the rule would impose and the cost-benefit analysis for the proposed rule,” said the API and other energy groups.

The latest proposed fracking rule, if implemented, would “significantly conflict” with existing federal and state regulations of fracking; exacerbate delays in permitting and production on public lands; and would establish “vague and conflicting guidelines” that would result in costs ranging from $30 million per year to $2.7 billion a year, API said.

The Independent Petroleum Association of America (IPAA), which represents small to mid-sized producers, cited several concerns with the proposed fracking rule: it would impose a costly burden of requiring operators to identify all usable water zones, rather than the zones being identified by state agencies and BLM field officers. This requirement could cost as much as $310 million a year without any appreciable benefit to the public or protection of water resources, the producer group said.

“Currently state oil and gas agencies and BLM field offices identify the formations that must be protected. This is effective and cost-efficient and should not be changed,” IPAA told BLM.

IPAA said that it still opposes the proposed rule and asked Interior to withdraw the regulation. It said BLM has underestimated the cost of the rule. IPAA believes it will cost about $345 million a year or more, and $96,913 per well.

There is one part of the draft rule that IPAA and other producer groups support. “We support that part of the proposed rule that requires operators to report [fracking] fluids and additives used in hydraulic fracturing operations on the FracFocus website.”

But trade secret protections should be expanded when reporting fracking fluids, according to IPAA. “The proposed rule affords trade secret protection, however, only to information that would be submitted after a hydraulic fracturing operation. We request that BLM expand the trade secret provisions to information required to be submitted in the notice of intent, such as fracture length and orientation data.”

Environmental groups simply want fracking outlawed. A coalition of 275 environmental and consumer organizations — including Americans Against Fracking, the Center for Biological Diversity, Food & Water Watch, CREDO Action and other groups — delivered more than 600,000 comments from members to President Obama and BLM asking the federal government to ban fracking on all public lands.

API railed against the proposed rule, saying it would “significantly conflict” with existing federal and state regulations of fracking; exacerbate delays in permitting and production on public lands; and would establish “vague and conflicting guidelines” that could cost the industry between $30 million per year to $2.7 billion a year.

“We ask that BLM carefully consider the concerns discussed in these comments. We request that BLM rescind or significantly amend the proposed rule to eliminate requirements without a sound technical foundation, reduce overlap with state and tribal requirements, and better balance costs and benefits,” the producer group said.

The Department of Interior “cannot demonstrate that states are not adequately regulating or that federal regulation is more effective,” said Kathleen Sgamma, vice president of government and public affairs for WEA in Denver.

Interior “already struggles to meet its current obligations, and has neither the resources nor the expertise to implement this very prescriptive, complex rule. The rule will further disadvantage the West, as development, jobs and economic activity will continue to migrate to areas without federal lands,” she said.