Statement from some of No Fracking Ireland on EPA 'consultation' process which ended today.

national | environment | opinion/analysis

Friday March 08, 2013 18:29

by one of NFI

Statement from participants in the No Fracking Ireland Network on the EPA ‘public consultation’ process with regard to ‘Proposed terms of reference for EPA/DCENR/NIEA Research Programme on Environmental Impacts of Unconventional Gas Exploration & Extraction (UGEE)’

We have studied the press release issued by the Environmental Protection Agency in January of this year calling for submissions to a ‘public consultation’ on the 'Proposed Terms of Reference for EPA/DCENR/NIEA Research Programme on Environmental Impacts of Unconventional Gas Exploration & Extraction'. We have also studied with interest the proposed terms of reference for the EPA/DCENR/NIEA Research Programme.

The second line of the press release accompanying the terms of reference document acknowledges the 'need for detailed scientific information' in this area generally. The publication of peer reviewed scientific information on the impacts of fracking lags way behind the vast amount of anecdotal evidence on this subject coming from communities worldwide, in particular from the United States. This body of anecdotal evidence, already supported by some extant peer reviewed scientific studies, indicates that Fracking is a fundamentally flawed process. It threatens the health and sustainability of communities. We take the evidence being made available by such communities extremely seriously. Hence we have been campaigning for a ban on the process of Hydraulic Fracturing on the Island of Ireland for nearly two years.

Why is the Irish Government attempting to fast-track the production of research data in this area, despite - to quote the proposed terms of reference document - the 'small number of published, peer reviewed, scientific studies in the area'? Our view is that the impetus for rapid action in this area is coming from an awareness, on the part of the present government, that the global body of scientific peer-reviewed evidence is currently catching up with the avalanche of negative anecdotal evidence from communities with regard to fracking.

A cynical, anti-democratic exercise

We believe the present FG / Labour government fully intends to facilitate the development of a fracking industry in Ireland. It intends to do so in the face of strong and ever growing community opposition. We also believe that the public consultation 'process' on the EPA etc. draft terms of reference for research in this area was a cynical exercise intended to put a veneer of community consultation on a fundamentally anti-democratic process. This process is intended to open up large areas of the island of Ireland to exploitation by an extremely controversial industry.

Ignoring community concerns

The structure of the research proposed by the EPA etc does not propose to address fundamental community concerns in the area of health in any sustained way.

Not if, but how

Another basic flaw in the proposed framework for research is the stated intent of its serving to 'assist regulators (North and South) in fulfilling their statutory roles regarding this activity'. This is a clear prima facie statement that the intent of this program of research is the development of a framework to regulate this industry. It is not a comprehensive evaluation of whether it is advisable to allow the development of a fracking industry on the island of Ireland.

Ignoring calls from public to ban fracking

A great deal of evidence (petitions with thousands of signatures calling for the process to be banned, local government bans, large public meetings, protests) exists that the communities in areas where exploratory licenses may shortly be issued do not want a 'process' to proceed in this area, and do not want regulation to be developed to facilitate this industry. Rather, such communities want a clear ban imposed on the process of hydraulic fracturing. There have been no consultations whatsoever directly between the government and communities in the firing line with regard to fracking to date. This is despite the significant number of local councils which have voted to ban the practice.

Creating facts on the ground for fracking to take place

With particular regard to the draft terms of reference document - it is clear that the intended outputs of 'Project A1' and 'Project A2' are the putting in place of 'baseline monitoring systems' to monitor water quality and seismic activity. The implementation of such systems only makes practical sense if it is inevitable that such systems will be used. In other words, the development of such systems has no discernible purpose unless fracking is to go ahead in the areas where these monitoring systems are to be developed and deployed.

This is nothing less than the commissioning and pre-emptive development of infrastructure intended to regulate and monitor a fracking industry. The state agency, in effect, is operating as part of the fracking industry. It represents a warlike intention to create 'facts on the ground' in the absence of meaningful community consent. No such consent exists for the development of an infrastructure for the regulation of a widespread fracking industry in the communities concerned.

Despite the preamble to the outlines of 'Section A' and 'Section A1’ of the proposed research mentioning 'water contamination', 'risks to surface water and ecosystems' and 'the importance of geology and hydrogeology in environmental protection and considerations of human health', none of the indicated intended outputs of this section of the proposed research have anything whatsoever to do with these (as the document refers to them) 'contentious issues'. This proposed outline does not map a path for researchers to review and identify the risks of fracking with regard to water quality and potential impacts on human health. Instead, it attends to the development of strategies for monitoring an extant industry in an effective way. In other words, the research outline presupposes the inevitability of fracking on an industrial scale - and sketches out research areas that prioritise the need to develop effective strategies to monitor such an industry. In the words of the draft terms of reference document, what is sought is 'the conceptual model and technical specifications for monitoring'.

The draft specifications for 'Project B' do nothing to dispel the impression that this report is aimed at preparing the ground for the imposition of fracking on communities. There is much emphasis on identification of 'mitigation measures', 'current and emerging practices in the context of avoidance of the use of additives that have the potential to harm the environment', 'identifying best practice for monitoring', 'identification of best practice in self-regulation' and 'validity and range of existing and potential monitoring and mitigation techniques'. The language deployed in the document generally, and in this section particularly, betrays the fact that what is being asked for from those tasked with research is a framework for regulation and monitoring that can be adopted rapidly by the Irish State if (and more likely when) the present government decides to give the go-ahead for exploratory and commercial fracking.

The EPA: working towards a fracking industry in Ireland

Finally the outline for Project C,makes no bones about indicating that what the EPA and its partners want from this research is an identification of ‘all regulatory requirements and best operational practices associated with the establishment and operation of a “UGEE development” in an Irish context’. In other words, this proposed research is intended to establish best practice in terms of the development of a ‘fracking industry’. In terms of the detail of Project C, the draft indicates that potential researchers will be asked to identify ‘detailed information on the regulatory approaches of other countries’, ‘the best practice in relation to UGEE operation’ and best practice in terms of ‘public engagement’ with extant fracking industries.

Despite the patina of concern for the environment visible in this draft terms of reference document - it does not even attempt to outline a framework for research for a thorough evaluation of the environmental and health risks presented by exploratory or industrial fracking. In fact, such concerns are completely marginalised by the document and the framework for research it proposes. Instead, it clearly and consistently focuses on the development of a best practice framework for fracking and its regulation.

A manipulative and anti-democratic approach to public consultation

Asking for input from the public into such a process is putting the cart before the horse. Such a ‘process’ represents a deceptive and anti-democratic attempt to create the impression that public consultation on the basic question of whether a fracking industry would present a significant risk to public health and the environment is actually happening. It is clear from the contents of this draft document - that the bodies involved have no intention of addressing this basic question. The predominant focus on 'regulation' within the terms of reference document indicates that, for the purposes of this exercise, the EPA is in effect operating as part of the Fracking lobby.

The nature of this document should give pause for thought to anyone considering taking part in consultations of whatever kind with the EPA and its partners on this issue. The other basic concern of the document is to outline the type of industrial research that a business seeking to operate in the industry ought to produce. No Fracking Ireland has not participated in this ‘consultation’ process.

The shameful role of the EPA

We believe it is shameful that the EPA has involved itself in the issuing of such draft terms of reference. These terms of reference sideline basic questions about the environmental impact, danger to human health, and fundamental advisability of an extremely controversial process. Instead, they focus on the development of ‘regulation’. Therefore any submission No Fracking Ireland might have made, and any submissions made by others, will be construed as evidence that communities have been ‘consulted’, supposedly in a democratic manner, on this issue.

Any public consultation worthy of the name ought to have happened in public. It would have entailed meaningful and democratic consultations between state representatives and citizens. It would have directly addressed fundamental community concerns on this issue. That would be the most sensible way to deal with the many unknowns with regard to fracking: together with waiting for a clear consensus to emerge from the scientific community worldwide on the issue of its safety.

During the last government an extensive review of the EPA was commissioned by the Department of the Environment. The report produced fifty eight recommendations to improve the agency’s structure and operation. At present the EPA has absolute immunity from prosecution for failure to discharge its statutory functions. The review found this to be no longer acceptable stating that ‘the EPA’s current blanket statutory immunity when carrying out its functions is difficult to justify in a modern context’. We believe these serious issues must also be addressed and rectified before the community could consider engaging in any meaningful consultation with the agency.

What the EPA is in effect facilitating is the State giving birth to an industry that may place established industries in tourism and agriculture at risk, place public health at risk, and unleash environmental destruction - all in pursuit of a fast buck. The precautionary principle should apply.

Rather than participate in a process intended to lay the foundations for fracking in Ireland, we have continued and will continue to work to give public representation to the views of the thousands who have called for a ban on the process of fracking on the island of Ireland.

EPA Page with link included to draft TOR document: http://www.epa.ie/researchandeducation/research/ugeecon...40754
Overview of Fracking and Ireland from No Fracking Ireland: http://www.indymedia.ie/article/103388

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Comments (7 of 7)

good to see

by j-ann

Sat Mar 09, 2013 18:04

Great to see this analysis of the 'consultation' process.

Some things worth keeping in mind maybe?

by W Finnerty

Sat Mar 09, 2013 23:51

The Republic of Ireland finally ratified the United Nations Aarhus Convention Agreement on June 2oth 2012, following an unexplained and unconstitutional delay (as I see things) of some 14 years.

The texts in the two sections just below formed part of an e-mail dated August 1st 2012 to Prime Minister Enda Kenny and other members of the Republic of Ireland Government (Executive, Legislative, and Judicial):

==========

The Aarhus Convention appears to be ideal for dealing with the protection of Ancient Heritage Sites (please see at http://tinyurl.com/bttv9s8), "Super Dumps/Incinerators" (please see at http://tinyurl.com/bptq3c7), "Shell Oil" type problems (please see at http://tinyurl.com/cgvrtjb), "Gas Fracking" (please see at http://tinyurl.com/cv8chan), and many other types of environmental issues and difficulties.

Introducing the Aarhus Convention (the excerpts immediately below have come from the United Nations texts on this subject):

"It links environmental rights and human rights";

"It establishes that sustainable development can be achieved only through the involvement of all stakeholders";

"It links government accountability and environmental protection";

"It acknowledges that we owe an obligation to future generations";

"The subject of the Aarhus Convention goes to the heart of the relationship between people and governments ."

==========

The full text of this "CONVENTION ON ACCESS TO INFORMATION, PUBLIC PARTICIPATION IN DECISION-MAKING, AND ACCESS TO JUSTICE IN ENVIRONMENTAL MATTERS" can be viewed at:
http://www.unece.org/fileadmin/DAM/env/pp/documents/cep...e.pdf

==========

Related Link:
Aarhus Convention Agreement, Unconstitutional Activities, Human Rights Ireland ...
http://tinyurl.com/atqmnyo

Can the EPA assess the effects of fracking in Co Leitrim? Not according to scientist Jessica Ernst...

by No Fracking Ireland campaigner

Wed Mar 13, 2013 17:19

Published on 06/03/2012 09:00 in Leitrim Observer

Can the EPA assess the effects of fracking in Co Leitrim? Not according to scientist Jessica Ernst who visited the area targeted by Tamboran Resources last week and held presentations locally.

If you had not heard of Jessica Ernst before last week, you most certainly know who she is this week!

Ms Ernst travelled from Alberta, Canada to Ireland last week to attend a number of meetings around the country, partake in interviews and press conferences and in simple terms to tell her personal account of “Life inside a Frac experiment.”

Despite her scientific background, her experience within the industry and her current multi million dollar lawsuit against gas company Encana Corp and Alberta Government, Ms Ernst pointed out that this is “my personal story.”

She took time out of her busy schedule to speak to this paper on an issue that has recently taken over life, turned her against her neighbours, marked her as an “enemy of the state” “a security risk” and she has even been publicly called “insane,” but despite the local media ban on her in Canada and the personal agony she has endured, she continues her fight against fracking - and more and more international campaigns want to hear her story

Jessica told the paper the area she speaks of is a rural one, with “beautiful high plains” and crop fields, an area once known for it’s agriculture output and tourism, before fracking commenced.

Canada is not new in the oil and gas game, they have over 100 years experience with it but it was 2001 when the extraction came to her home area of Alberta. She said, “We were promised what happened in North America would not happen here - we have the best - world class regulators.”

So what happened? According to Jessica the water got contaminated. But the Government says “It was just natural.”

“It is not what you know you should be concerned about, it is what you don’t know” she warned.

This is coming from a woman who worked for Encanna Corporation. “I worked in the industry, worked for them and they were nasty to me, didn’t care about my community.”

She said aside from the water, the noise of the fracking kept her awake for nights, and the lorries destroyed the roads.

“I saw your roads - they will destroy them,” she warned. Jessica was brought on a tour of the Glenfarne/ Kiltyclogher area where Tamboran Resources are seeking to frack.

She said the company will “divide and conquer the community” by giving money to one half but not the other.

“The EPA can’t assess fracking in Leitrim.” Jessica visited the land, she walked it. She has never felt wetter land. She said “the land here is different to anything in Canada, Australia or South Africa.” She said the amount of water present here has never been fracked before. “How can the EPA assess something that we are being told is brand new?”

More importantly Ms Ernst said we need to look at the importance of our national water supply. She said clean water is becoming an expensive resource. “What is it worth to you?” she asked. She suggested that in a few years a small bottle of clean water could be worth more than a small bottle of gas. “What is more valuable?”

http://www.leitrimobserver.ie/news/the-epa-can-t-assess...73171

"Short of relocating entire communities or banning fracking, ending airborne exposures cannot be done".

Wed Mar 13, 2013 17:24

"Now that Gov. Andrew Cuomo has stopped the clock on hydraulic fracturing for natural gas in order to give his health commissioner more time to study its potential problems, medical professionals in other states where fracking has arrived have a chance to weigh in. New York can learn from our experiences.

The Southwest Pennsylvania Environmental Health Project meets with patients who believe their health has been, or could be, affected by natural gas drilling. In both home and office visits, we see people with an array of adverse health signs and symptoms that appeared together with plausible exposure pathways to natural gas activities. Typically, neither they nor their physicians know what to do.

Based on our own observations, here are my suggestions for New York State Health Commissioner Nirav Shah and his team as they review possible health impacts of fracking.

First, take a close look at air. When we began our project, I thought that water would be the exposure pathway of highest concern. While contaminated water certainly poses significant risk, I now believe that air pollution is the more likely pathway of exposures in many cases.

There are at least a dozen different sources of uncontrolled air emissions ranging from ponds of contaminated flow back, flaring wells, organic emissions from compressor stations, and dehydration devices, to spills and disposal of silica, frack fluids and flow back water during transportation and at illegal disposal sites.

Of course, the problem with air exposures is this: How do you break the pathway? People cannot choose the air that they breathe.

If an exposure occurs, the proper response is to stop the emission at the source. As we say in public health, "When uncertain, stop the exposures!"

But in the gas extraction and processing industry, once gas production begins and health injury appears, stopping exposures entirely is not realistic.

Short of relocating entire communities or banning fracking, ending airborne exposures cannot be done. People cannot evacuate their homes or farms. Our only option in Washington County, Pa., has been to try to find ways for residents to reduce their exposures and warn them when the air is especially dangerous to breathe.

Second, don't forget about mixtures. Although we are making headway identifying individual agents in water and air near drilling operations, we've also learned that people are exposed to mixtures of chemicals.

The effects of these are not necessarily predictable based on the properties of the individual ingredients acting alone. These chemical mixtures can produce potential synergistic interactions, with new and more severe effects than the effects of the individual chemicals.

Third, keep in mind that physicians typically have little experience with toxic exposures in air or water. Everything hangs on public health services. New York needs to consider the costs of a state and local public health infrastructure necessary to protect its rural population.

And remember this: Pennsylvania is not a model for you.

Pennsylvania has no public health assets working on gas drilling in Washington County. The U.S. Environmental Protection Agency and the Commonwealth of Pennsylvania have conducted very few measurements in air and water, and there is no systematic effort to interpret those findings.

Fourth, there will be accidents, and people will be exposed even with the gas industry's goals for perfection. From what I've seen, accidents are responsible for a disproportionate number of human exposures and injury. Accidents are not trivial events that can be cleaned up or ameliorated.

Yes, they may be rare, as industry claims, if only one activity — such as the transport of fracking water— is considered. But with thousands of wells spread across the landscape, "rare" means that hundreds of accidents will happen over a year.

Wells themselves can fail, and each well has other associated devices that can fail, such as compressor stations. And each well is serviced by thousands of truck trips. Areas will be contaminated and people placed at risk of exposures to hazardous materials.

The most important thing I've learned from our work and would wish to share with you and your team is this: unlike other industries, there is no fence line with drilling and fracking operations. It's an activity that turns communities into industrial zones.

The people often placed at risk are not necessarily benefiting or employed by the gas extraction industry. They are free citizens who have had these risks imposed on them. No one, especially ourselves as public health officials, can assure people who live, work, or attend school near drilling and fracking operations that they are safe."

David Brown is a public health toxicologist with the Southwest Pennsylvania Environmental Health Project,

Read more: http://www.timesunion.com/opinion/article/Assessing-the...p7bSx

"The Endocrine Disruption Exchange measured the presence of volatile organic chemicals —many of which have known health and carcinogenic effects..."

Wed Mar 13, 2013 17:31

"New York is poised to make a decision on allowing natural gas development and production to expand — a decision that was just delayed because the state is still considering the health impacts of moving forward.

As state Health Commissioner Nirav Shah has said, "The time to ensure the impacts on public health are properly considered is before a state permits drilling."

Yet years after the shale gas boom began, scientific studies are just now being conducted and reported. We can only hope that the Health Department and its appointed panel of experts takes the time necessary to thoroughly analyze this critical issue before reaching any conclusions.

New research in places where gas drilling is already a fact of life increasingly shows associations between industrial gas operations and facilities and health concerns.

For example, in a recent first-of-its-kind, yearlong study, scientists from what's known as The Endocrine Disruption Exchange measured the presence of volatile organic chemicals —many of which have known health and carcinogenic effects — in the air in a neighborhood situated within a natural gas production area in rural western Colorado. Within a mile radius of the sampling site, there were already 130 wells.

Almost five dozen volatile organic chemicals showed up at varying levels in weekly air samples. Methane, ethane, propane, toluene, formaldehyde and acetaldehyde appeared in every sample. All are known to be associated with gas operations. Concentrations of some of the other volatile chemicals known to come primarily from other sources (such as traffic) were much lower.

At the same time, but thousands of miles away, the environmental group Earthworks was gathering more than 100 health surveys in several rural counties in Pennsylvania that have seen a surge in gas development. Earthworks also conducted air testing near gas facilities, at the homes of many of the survey participants. Results showed the presence of 19 VOCs, with considerable consistency in the chemicals detected across samples taken at far-flung locations.

Although the projects were completely independent of each other, both ended up traveling down the same road when assessing the potential hazards associated with the detected chemicals. TEDX found more than 30 chemicals in its samples that can affect the brain/nervous system, the liver/metabolism, and the endocrine (reproductive and developmental) system, and more than 20 that affect the immune system, cardiovascular/blood and the sensory/respiratory system.

Earthworks compared the known health effects of the chemicals detected with symptoms reported by members of the households where the air testing occurred, finding an overall match of nearly 70 percent.

Most striking were the much higher rates of symptoms, such as throat irritation, sinus problems and headaches, reported by survey participants living closer than 1,500 feet to facilities — wells, impoundments, and compressor stations — than by those living farther away.

The most important result in the TEDX study was that concentrations of the polycyclic aromatic hydrocarbons were three times higher than those found in the inner city of New York, where babies exposed prenatally are being born with small head circumference, lower developmental scores at age 3 and lower IQ scores at age 5.

Without proper consideration for air pollution as well as water pollution, New York could create a scenario where even rural areas will have air as hazardous as that found in inner New York City. New York is in the envious position of being able to prevent this catastrophe and set a precedent for the nation.

Industry and proponents of unfettered gas development have been able to make claims of safety because they have simultaneously downplayed many studies for not establishing definitive "cause and effect."

Yet science is not based on absolute proof, but on associations that reflect real trends that can collectively build a strong body of evidence.

Those who work to protect health and the environment often base their actions on the principle of preventing harm, even in the face of some uncertainty. Decision-makers contemplating the expansion of gas development — while also being responsible for protecting the public — should do no less."

Theo Colborn is president of The Endocrine Disruption Exchange, www.endocrinedisruption.com. Nadia Steinzor works for Earthworks.

Read more: http://www.timesunion.com/opinion/article/Beware-impact...KJo6O

The great oil swindle

by Crazy Cat

Sat Mar 16, 2013 12:39

Article from le Monde Diplomatique about the very bad economics of fracking

http://mondediplo.com/2013/03/09gaz

Fracking debris considered too radioactive even for waste site

by T

Fri Apr 26, 2013 21:47

Interesting report on RT.com about waste coming out of fracking wells which is radioactive which is not surprising because by opening cracks in the rock, a vast surface area is exposed which flushes out any natural radioactivity locked in the rocks for millions of years.

A truck carrying drill cuttings from a fracking site set off a radiation alarm at a landfill in Pennsylvania. Emitting gamma radiation ten times higher than the permitted level, the waste was rejected by the landfill.

After the alarm went off, the MAX Environmental Technologies truck was immediately quarantined and sent back to the Marcellus Shale fracking site it had come from in Greene County, Va. The 159-acre Pennsylvania landfill site accepts residual and hazardous waste, but the cuttings were too radioactive for the site to safely dispose.

The Pennsylvania landfill, located in South Huntingdon, rejects waste that emits more than 10 microerm per hour of radiation. The fracking materials were found to emit 96 microerm per hour of Radium 226 – a rate that is 84 times higher than the Environmental Protection Agency’s air-pollution standard and ten times higher than the landfill’s permitted level.....

Full report at link:

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Statement from some of No Fracking Ireland on EPA 'consultation' process which ended today.

Comments (7 of 7)