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Testimony: Fracking (Ohio Senate Bill 21)

Ohio Environmental Council, September 1, 2011

We thank Senator Skindell for his leadership in proposing a moratorium (Ohio Senate Bill 213) on horizontal hydraulic fracturing (HHF or fracking) of oil and gas wells until the United States EPA completes its study of potential risks to drinking and ground water resources posed by HHF and the Ohio Division of Oil and Gas Resources Management issues a report analyzing how Ohio’s rules address issues raised in the USEPA report.

It is altogether reasonable, appropriate, and urgent to call a timeout on Ohio’s black gold rush.

Horizontal hydraulic fracturing involves the use of millions of gallons of water and hundreds of chemicals, including many toxic chemicals.

It produces a toxic hit parade of dangerous emissions and byproducts, including benzene, toluene, ethyl-benzene, xylene, volatile organic compounds, particulate matter, radon, uranium, hydrogen sulfide, arsenic, lead, and mercury.

If not properly controlled, air emissions, alone, could turn the Ohio Valley into an ozone alley.

We are not alone in our concerns.

According to the United States Secretary of Energy Advisory Board, Natural Gas Subcommittee interim report issued Aug. 11, 2011:

“Intensive shale gas development can potentially have serious impacts on public health, the environment and quality of life – even when individual operators conduct their activities in ways that meet and exceed regulatory requirements. The combination of impacts from multiple drilling and production operations, support infrastructure (pipelines, road networks, etc.) and related activities can overwhelm ecosystems and communities.”

Bottom line: Ohio needs the most protective safeguards in place to guide the safe, responsible development of Ohio’s deep shale gas resources.

This moratorium does not forever say no to shale gas development. This moratorium says, slow down, get the best available science, and adopt the most protective safeguards to protect Ohio’s priceless air, land and water resources.

The OEC acknowledges and thanks Ohio EPA Director Scott Nally for banning the disposal of brine or flow-back water at municipal wastewater sewage plants. This is a very good start. But the Ohio EPA and Ohio DNR need to do more.

The old saying, “Measure twice and cut once” couldn’t be more apt when it comes to horizontal hydraulic fracturing.

Now is time to get the technology, safeguards, and regulations in place, sooner rather than later and safer rather than sorry.

Consider the following:

At the request of Congress, the United States EPA is beginning a study of any potential impact of hydraulic fracturing/fracking on the environment and human health, particularly on water quality and drinking water. Initial study results are expected by the end of 2012.

Among other things, the study will consider:

  • What impact does removing the large amounts of water needed for high-pressure drilling have on a watersheds and aquifers?
  • What are the potential impacts of the chemicals used in drilling and the hydro-fracturing process, wastewater, and fractured geology have on water quality and underground drinking water supplies?

In addition, according to the United States Secretary of Energy Advisory Board, Natural Gas Subcommittee interim report issued on Aug. 11:

  • “A recent, credible, peer-reviewed study [published in “Proceedings of the National Academy of Science”] documented the higher concentration of methane originating in shale gas deposits into wells surrounding a producing shale production site in northern Pennsylvania.”
  • Measures should be taken to reduce emissions of air pollutants, ozone precursors, and methane as quickly as practicable.
  • Adopt best practices in well development and construction, especially casing, cementing, and pressure management.
  • There is no economic or technical reason to prevent public disclosure of all chemicals in fracturing fluids, with an exception for genuinely proprietary information.
  • Each relevant jurisdiction should pay greater attention to the combination of impacts from multiple drilling, production and delivery activities (e.g., impacts on air quality, traffic on roads, noise, visual pollution), and make efforts to plan for shale development impacts on a regional scale.

According to the 2010 STRONGER (State Review of Oil and Gas Environmental Regulations) review of Ohio’s oil and gas oversight program:

  • “DMRM [the Ohio DNR Division of Mineral Resources Management] is in the beginning stages of revising OAC Chapter 1501:9 to reflect SB 165 changes. The review team acknowledges this rulemaking effort and encourages the expeditious completion of those portions necessary or appropriate to implement the hydraulic fracturing provisions of SB 165.”
  • “DMRM should consider whether they will be getting all the chemical information they will need for investigations from the MSDS [Material Safety Data Sheets]. An MSDS does not always contain the specific chemical constituents of a product. Also, the state should ensure that information on chemical constituents of fracturing fluids is available to medical personnel in the event of a medical emergency.”
  • “.in light of the anticipated development of the Marcellus and Utica Shales in Ohio, the state should continue to evaluate the need and availability of surface and ground water for hydraulic fracturing in the context of all competing uses and potential environmental impacts resulting from the volume of water used for hydraulic fracturing.”