[fracking] mechanisms have led to widespread, systemic impacts on drinking water resources in the United States.”
But EPA bases its conclusion on a shockingly insufficient amount of data. It needs to take the time necessary to collect and analyze all relevant data in order to make an informed, scientifically valid assessment.
EPA’s Science Advisory Board (SAB) is now conducting a peer review of the study through its Hydraulic Fracturing Research Advisory Panel, and has scheduled public teleconferences on September 30 and October 1, 2015, and public face-to-face meetings on October 28-30, 2015. Based on this schedule, EPA has announced that all public comments on the study be submitted no later than August 28, 2015, so that the information may be made available to the SAB Panel sufficiently in advance of the teleconferences and meetings for the Panel’s consideration.
RtE encourages its members and concerned citizens to comment on these key issues:
- 1. Because as EPA admits repeatedly, it does not yet have sufficient information to reach a conclusion, EPA’s conclusion that it “did not find evidence” of “widespread, systemic impacts on water resources” is an improper standard by which to assess such impacts. The study contains dozens of EPA admissions that the report is based on very limited data, stating such things as “due to a lack of available data, little is known about the prevalence and severity of actual drinking water impacts” (p. 5-42);
2. EPA also states that the study “does not discuss the potential impacts of hydraulic fracturing on other water sources (e.g., agriculture or industry),”even though runoff water from agricultural use is a primary component of surface and drinking water, and therefore the study should include these “other” water sources.
3. Since Congress mandated that EPA produce this report, EPA should request Congress to fund a comprehensive research program to investigate all of the data gaps identified throughout the study in order to enable EPA to analyze ALL relevant information before issuing any conclusions as to an assessment of drinking water impacts from fracking operations. Industry should substantially contribute to such funding, until a scientifically-valid conclusion can be reached based on sufficient data, especially since those promoting fracking should bear the burden of proving that fracking does not impact drinking water, rather than forcing others to prove that is does.
4. It is obvious that the study is premature and incomplete, with so much relevant data not yet even collected, much less analyzed. Having found the “potential” for drinking water pollution in several different ways, and having now documented actual instances of drinking water contamination, the catastrophic risks to public health and environmental degradation are far too serious to not take the time necessary to gather and analyze in a scientifically-valid manner all relevant information, including that identified by EPA as missing from its assessment.
5. In light of the fact that EPA states that “evidence of any fracturing-related fluid migration affecting a drinking water resource … could take years to discover” (p. 6-56), EPA must request from Congress a much longer time period for this study in order for it to be based on a complete record of data.
6. While EPA takes the time needed to create an appropriate database of information upon which to assess drinking water impacts, EPA should issue preventive regulations to better protect water resources from even the potential of contamination from fracking activities, especially given the severity of possible harm to the environment and public health from fracking operations.
To comment by email for the Science Advisory Board Review of EPA’s Assessment Report on EPA’s Research on the Potential Effects of Hydraulic Fracturing on Drinking Water Resources, go Here.
You can also mail your comments in the form of written statements, with a subject line identifying Docket ID No. EPA-HQ-OA-2015-0245, to the following address:
Office of Environmental Information Docket (Mail Code: 28221T)
Docket ID No. EPA-HQ-OA-2015-0245
U.S. Environmental Protection Agency
1200 Pennsylvania Ave. NW.
Washington, DC 20460
If you have any questions about comment submission, the phone number is (202) 566-1752).
Rock the Earth’s August 21, 2015 Comments to EPA’s Assessment of the Potential Impacts of Hydraulic Fracturing for Oil and Gas on Drinking Water Resources can be found here. For the latest on this issue, please see the Rock the Earth Fracking project page.