Comments on fracking health study due Oct. 3, 2014
PLEASE WRITE COMMENTS ON MARYLAND's FRACKING HEALTH STUDY. Comments due by 5 p.m., Friday, Oct. 3. The study is here: http://www.marcellushealth.org/
Send emails to firstname.lastname@example.org.Or snail mail to: Environmental Health Bureau, Marcellus Shale Comments, Maryland Department of Health and Mental Hygiene, 201 W. Preston Street, Room 327, Baltimore, MD 21201
Written & email comments on the Health Study for the Marcellus Shale Advisory Commission.
Many personal comments are needed - your personal story and personal concerns. Pick just ONE topic, you don't have to be an expert. You can just be concerned that Maryland use the "precautionary principle" and doesn't approve processes that could cause irreparable harm when we have insufficient data. For example, the FDA is not supposed to approve prescription drugs until they are proven safe. It doesn't say take them because we haven't done studies yet and have insufficient data to prove toxicity. The report outlines many health areas where there is insufficient data now but doesn't bottom this as potentially dangerous. (But construction projects don't seen to have the same standard. The tendency of of some who site "science and engineering " is to proceed because of lack of data to prove toxicity/risk etc.)
See this page for suggestions for submitting comments:
For more background see also:
The scope of Maryland's fracking health study
The draft of the scoping report for the Marcellus Shale Public Health Study was released Dec. 24. We have until Jan. 24, 2014, to make comments on this outline of what health effects the study team will assess. Here is the link: http://www.marcellushealth.org/detailed-scoping-report.html The draft includes a timeline for future reports, focus groups and comment periods. The form for commenting is included at this site. Missing from the scope of this study is an evaluation of the medical costs associated from fracking. The economic study also will not be covering medical costs, so please note that in your comments.
Maryland has a temporary moratorium (till August 2014) on fracking for natural gas while state officials study whether to allow this industrial extraction process in Garrett and Allegany counties. These counties are best known for their beautiful mountains, forests, rivers and streams. Many of us have enjoyed swimming, kayaking and canoeing, hiking and camping there. Of course, some people live, work or farm there year-round. And parts of the Eastern Shore and Southern Maryland lie on top of deeper shale deposits, so much is at stake as we consider how to best to proceed. (See Eastern Shore and Southern Maryland shale deposits on this USGS map: http://pubs.usgs.gov/fs/2012/3075/fs2012-3075.pdf )
The Governor's Marcellus Shale Safe Drilling Initiative Advisory Commission is in the process of conducting economic and health studies on fracking, and we hope also a study on the climate effects of fracking. Even though studies are not yet in, the State officials recently released a report on proposed Best Management Practices (BMP's) for fracking. It seems that we are studying how to frack before safety studies are done.
The state is accepting comments on the proposed BMPs (Maryland how to frack guidelines) until Tuesday, Sept. 10. See sample letter below
We know you value clean water, air and soil and are concerned about climate change, so PLEASE send comments to: Marcellus.Advisory@Maryland.gov
Feel free to use information from the sample comments provided below.
You can read comments submitted so far here.
You can also read more about the BMPs in these posts from our blog, ClimateHoward:
Please be sure to send comments. We’re counting on you to help defend the ecosystem that sustains us all.
Maryland has a chance to study the full effects of fracking before taking chances with our health, air, land, soil, water and climate. The proposed Best Management Practices (BMPs) are a first step toward examining whether fracking can be done safely, but whether they are adequate is difficult to assess because the state has yet to complete its health, climate and economic studies. I encourage the state to revisit the BMPs once all the studies are finished. That said, I see significant short-comings in the proposed BMPs:
1) The setbacks are insufficient to protect the environment and human health. A recent Duke University study found evidence of water contamination up to 1 kilometer (3,280 feet) from drilling sites. Therefore, all setbacks — whether from streams, springs, rivers, wetlands, ponds, scenic byways, reservoirs, schools, homes or shops — should be at least 3,000 feet.
2) Fracking is an industrial activity ideally confined to areas zoned for industry.
3) Maryland should not allow secret, toxic chemicals to be injected into the Earth. The oil and gas industry can be counted on to have numerous accidents. We can’t afford to have toxic chemicals spilling near drinking-water sources, streams that support wildlife and soil for growing food. If the gas industry wants to frack in Maryland, it should be required to prove it is using non-toxic materials.
4) Research shows that fractures created by fracking “communicate” or connect with existing fractures, which can eventually reach aquifers. Maryland is encouraging drillers to place wells close together to protect the land, but will their proximity lead to unforeseen problems involving existing fractures? Clearly, more research is needed on this matter.
5) The BMPs allow flaring for up to 30 days for exploratory wells and place some limits on flaring during drilling. Nearby flaring sounds like a jet engine taking off. It also releases nitrogen dioxides, volatile organic compounds like benzene, and other substances linked to asthma and chronic bronchitis. More stringent flaring regulations should be imposed.
6) Under the BMPs, company emergency plans must include information on specially trained crews that can arrive within 24 hours during blowouts, fires or other accidents. Twenty-four hours is an eternity during an emergency. That BMP is insufficient to protect workers, nearby families and the environment.
7) The well pad, according to the BMPs, must be surrounded by a berm designed to hold at least 2.7 inches of rainfall within a 24-hour period, so that spills of gasoline, oils and other hazardous chemicals won’t run off onto surrounding land. Weather records show more than that amount of rain has fallen in 24 hours on several occasions recently, including during Superstorm Sandy. Climate change will bring more deluges, so this BMP is not sufficient to protect the land, water, human health or wildlife.
8) Several studies show high levels of methane leakage during drilling and from pipelines. Methane doesn't last as long as CO2 in the atmosphere, but while it's around it is much more efficient at trapping greenhouse gases. (It causes 72 times more warming than CO2 over 20 years.) The BMPs should require gas companies to meet a zero percent leakage rate for methane throughout the drilling process
Read more comments at CitizenShale.org: