EPA hearing comment: “Agencies appear to be captured by an industry they’ve been tasked to regulate”

Comments to the EPA Hearing on Horizontal Drilling /High-Volume Hydraulic Fracturing

September 15, 2010BinghamtonNew York

Good evening.  My name is Joan Tubridy; I am the daughter of a NYC Fire Captain, a former farmer for 23 years, and a middle school Math and English teacher for the past 16 years.  I am also a member of CDOG (Chenango Delaware Otsego Gas Drilling Opposition Group). I wish to thank Mike Bernhard of Chenango County for his significant contributions to my remarks.

I grew up believing that state agencies with names like the Department of Environmental Conservation, the Department of Environmental Protection, the Arkansas and Louisiana Departments of Environmental Quality, the Ohio Environmental Protection Agency, and the Texas Commission on Environmental Quality were all obligated to fulfill the mandates of their chosen titles.  Over these past two years, I have had a disappointing education.  These agencies appear to be captured by an industry they’ve been tasked to regulate.

For example, just this past Tuesday, Governor Ed Rendell of Pennsylvania said that the state Office of Homeland Security, which has been sending information about anti-gas drilling groups to law enforcement and drilling companies, will no longer do so.  Should we feel reassured?

Furthermore, spokespersons for the Oil and Gas Industry have obfuscated the truth so often that they have apparently deceived pro-gas coalitions, members of Congress, and agencies with “Environmental” in their titles.  The industry has repeatedly stated that the horizontal-drilled, high-volume hydrofracturing (HD/HVF) technology that makes the Marcellus Shale such a plum for gas corporations, has been going on safely for decades.

In fact, there has not been one HD/HVF well in the Marcellus or any other shale body in New York. Ever. Two current drilling practices (drilling horizontal wells in sandstones, and fracturing vertical wells in shale) have been co-mingled as if they “added up” to horizontal-drilled, high-volume hydrofractured wells in the Marcellus Shale (HD/HVF). They don’t and here’s why:

The Herkimer sandstone formation in Chenango County, New York, for example, is a porous stone which produces no methane, but which has – over geologic time – absorbed methane from neighboring shale formations. Though horizontally-drilled, these sandstone wells require no fracking. A single square mile filled with 80-acre Herkimer drilling units would not require one drop of frack fluid, nor produce one drop of toxic flowback. But a single square-mile HD/HVF Marcellus drilling unit, containing typically eight 4000-foot well bores on one pad, would require 32,000,000 gallons of fracking fluid.

A sandstone well is drilled once, never fractured, and the gas is gone; shale wells can be fractured multiple times, using increasing amounts of fracking fluids each time, to get decreasing amounts of gas.

Similarly, vertical wells drilled through the thin Marcellus shale encounter only about 150 feet of shale available for fracking, and are legally limited to using 80,000 gallons of fracking fluid per well. So, a fully built-out square mile of vertical Marcellus wells at the legal 40-acre spacing, will therefore yield about 2400 feet of frackable shale and be legally limited to using 1,280,000 gallons of fracking fluid. Compare this with horizontal well bores in that same thin layer in Pennsylvania which are commonly 4000 feet long on an eight-well pad: a total of 32,000 feet of frackable wellbore, requiring 32,000,000 gallons of fracking fluid.

Horizontal-drilled, high-volume hydrofracturing (HD/HVF) in the Marcellus Shale creates twenty-five (25) times the length of frackable wellbore as those created by a fully built-out vertical Marcellus field. That’s twenty-five times the drill cuttings, twenty-five times the flowback wastewater, twenty-five times the truck-traffic for water haulage, and twenty-five times the flowback disposal.

Horizontal-drilled, high-volume hydrofracturing (HD/HVF) in the Marcellus Shale requires fracking fluid that is thirty-five (35) times the legal limit for vertical shale wells, ignoring subsequent re-fracturing. The no-frack Herkimer sandstone experience is irrelevant to the discussion at hand today, though industry would like us to believe that horizontal-drilled, high-volume hydrofracturing (HD/HVF) has been going on for decades.

Another industry obfuscation was recently employed in Pennsylvania when a Chesapeake spokesperson attempted to shift the blame for recent water well problems following gas drilling, to poor construction and drilling of water wells.  In his August 22, 2010 letter to the editor of the Sunday Review, Thomas Cummings, a water well driller in Towanda, Pennsylvania refuted this claim by Chesapeake and defended his practices and reputation.  Several local homeowners contacted Mr. Cummings regarding disturbances in their water wells that began after nearby gas drilling activity had started.  Mr. Cummings states, “The excitement of gas lease funding and large drilling rigs coming to our area has been replaced by damaged roads; delayed travel and traffic snarls; streams sucked dry by convoys of trucks driven by persons foreign to our area …  residential sweet water invaded by methane that is blowing off well caps; local families displaced by gas workers; and other changes affecting our work and lifestyles. Our drinking water is being affected and millions of gallons of water are being extracted from our streams, rivers and municipal wells with insufficient recharge.”

I urge you, the Environmental Protection Agency:

1. to be wary of industry’s deliberate deceptions and to examine those mentioned above, and

2.  to find individuals who have suffered contamination of their homes by the gas industry, and who have been silenced by money, trucked-in domestic water, and nondisclosure agreements.  Legally challenge these nondisclosure agreements and seek out the stories these families have to tell about how their lives have become desperately focused on what most of us take for granted – a healthy home environment for our families.

I urge the Environmental Protection Agency to fulfill the grave obligation imbedded in your name.

Thank you.