Oral comment on scoping document for EPA study, 9/15/10, Binghamton, NY:

I own 200+ acres. I was offered a lease, and experience the difficult consequences of both long- and short-term economic trends.  Yet this is not another plea for gas extraction.

The first problem with this scope is its foregone conclusion, found in its very first sentence.  “Natural gas plays a key role in our nation’s clean energy future.”  Two biases in twelve words! – the second of which is downright false: natural gas is NOT clean energy.  What a way to begin a study!  The sentence continues, “…and the process known as hydraulic fracturing is one way of accessing that vital resource.” Nowhere is the question asked:  With present technology and the limits of human performance, CAN natural gas extraction proceed with guaranteed safety, including in a low-impact, non-industrializing manner?  These assumptions and omissions are serious flaws.

Next, to avoid conclusions that are theoretical, nebulous, and open to manipulation, an essential aspect of data gathering is the close scrutiny of all records of all state regulatory agencies for problems associated with the full spectrum of natural gas extraction processes.  Yet this channel of investigation receives little if any mention in this document.  To the point, such records are difficult to find. In response to a 2009 FOIL request, the New York State DEC admitted that the agency does not compile a record of drilling problems requiring follow-up.  In fact, for decades, regulatory agencies everywhere have had very cozy relationships with the industries they regulate.  The result: a dearth of official documention and recognition of the fact that, as the tail follows the dog, groundwater pollution follows natural gas extraction whereever it goes.

Therefore, this study must:
1) dispense with foregone conclusions and biases
2) examine case histories and regulator records unflinchingly and in detail
3) provide a frank assessment of the effects of industry influence on regulators’ record-keeping
4) avoid all such influence itself

Thank you.