UPDATE (5:27pm ET, 5/16/2012): In Mr. Urbina’s story, he notes: “Nearly a third of the 648 deaths of oil field workers from 2003 through 2008 were in highway crashes…” He goes on to say those numbers were “analyzed by the federal Centers for Disease Control and Prevention.” But it looks as if the numbers for this claim — as well as the one about oil and gas having a fatality rate “seven times” the national average — may have come from this presentation. The numbers and date ranges are nearly identical to what appears in Mr. Urbina’s story. The only problem: the document says up front (emphasis added): “The information in this presentation has not been reviewed by NIOSH or CDC and does not represent any federal government position or policy.” If Mr. Urbina did in fact use this presentation — which was, to be fair, given by employees at CDC’s National Institute for Occupational Safety and Health — then why did he say it had been reviewed by the CDC when it clearly had not? Was it to make it seem like the data was officially issued by the government, and thus give more credibility to his story? Or was it a simple error on his part?

—Original post, March 16, 2012—

In the latest installment of the New York Times‘ “Drilling Down” series, reporter Ian Urbina doubles down on his pre-conceived narrative that oil and natural gas development (particularly from shale) is inherently dangerous.

Facts and data points do appear in print, but their spatiality and lack of context lead readers down a dangerous – and completely disproven – line of thinking: namely, that oil and gas workers and truck drivers who play such a vital role in the process all have an abnormally high risk of being injured, even fatally. At the very least, readers of Mr. Urbina’s most recent attack would be forgiven for thinking – despite evidence showing otherwise – that the industry is dangerous and poorly regulated.

What follows is a summary of the more egregious errors that Mr. Urbina cleverly slipped past his editor in his latest piece:

—

NYT: “But the jobs are also hazardous, with fatality rates that are seven times the national average across all industries. Nearly a third of the 648 deaths of oil field workers from 2003 through 2008 were in highway crashes, according to the most recent data analyzed by the federal Centers for Disease Control and Prevention. By contrast, highway crashes caused roughly a fifth of workplace fatalities across all industries in 2010.”

FACT: The source of Mr. Urbina’s “seven times the national average” claim regarding fatality rates is unclear, a detail that is itself unsurprising given his problematic history with sources. Nonetheless, according to the Bureau of Labor Statistics, the oil and gas industry is not even ranked in the top 25 for highest rates of injuries and illnesses across all industries. In fact, the average national injury incidence rate is three times higher than the rate for oil and gas extraction. For fatalities specifically, BLS data show that the fatality rate for oil and gas extraction is lower than that for aircraft pilots, chauffeurs, fishing, and farming, among many others.

And, according to the Centers for Disease Control – the same source Urbina cites in his story – the highway transportation fatality rate for oil and gas extraction is lower than general truck transportation, logging, and waste management. Even limousine services have higher highway fatality rates than those for oil and gas.

It’s also worth noting that the industry has been and still is making incredible progress in reducing truck traffic. For example, a single 18-mile-long water pipeline in Pennsylvania has removed more than 2,000 truck trips from local roadways. And thanks to advancements in recycling – including on-site technologies – the amount of water needed to be hauled to and from the well site has been reduced considerably, which of course translates to substantially less truck traffic.

If the industry were unsafe, the data would surely reflect it. Unless, of course, you’re not using data, in which case you can claim whatever you want.

–

NYT: “Few workers are unionized, meaning they are less able to complain about safety problems without fear of being fired.”

FACT: Once again, there’s no data to support Mr. Urbina’s claim. Instead, this appears to be a specious talking point that was added merely to advance a pre-conceived narrative about the industry – specifically, that it’s somehow hostile to organized labor (don’t tell that to these guys). And as mentioned: BLS tracks workplace injury statistics. So if the alleged “safety problems” that Mr. Urbina references were real, then it would be reflected in those stats. Unfortunately for The Times, the data simply do not support Mr. Urbina’s opinions.

–

NYT: “An analysis by The New York Times of more than 50,000 inspection reports indicates that as the number of drilling rigs rose by more than 22 percent in 2011 from the prior year, the number of inspections at such work sites fell by 12 percent.”

FACT: The only way this information would be relevant is if the number of incidents at drilling sites rose by roughly the same rate (12 percent) as the decline in inspections. Having both sets of data would allow the reader to put this information into the proper perspective. But Urbina doesn’t provide it. Instead, he cites two pieces of data that seem to suggest a problem – more rigs and fewer inspections – without providing even basic context to let the reader know if the information is (a) valid, (b) connected in any way, or (c) indicative of an actual issue.

What Mr. Urbina is suggesting is that all drilling sites are exactly the same, and thus there should be a one-to-one connection between drilling rigs and inspections. If the number of rigs increases while inspections decrease, Urbina reasons, then that gap represents some sort of danger quotient that will facilitate higher than normal injuries.

This is laughably absurd.

For example: vertical and horizontal wells typically have different permitting requirements, and thus different types and levels of inspections. In addition, there are different techniques and requirements for each target formation in different states. In Louisiana, for example, there are different fee structures based upon well depth and production levels. In Pennsylvania, there are different fees for vertical and horizontal wells, and New York’s Environmental Assessment Form – which is required for all well owners – requests information about each well’s proximity to other regulated areas, such as wetlands or other bodies of water. This information is not just taken down for fun; it’s used as part of the regulatory process, which includes permitting and inspections.

Needless to say, inspections and compliance can vary considerably between two wells in the same state, not to mention the differences between wells operating in different parts of the country. What Mr. Urbina is suggesting, however, is that these differences are not merely unimportant, but that they don’t even exist.

—

The irony here is that all of this information could have been gathered by simply navigating a search engine. Of course, knowing what to type into the search box would have required at least a basic understanding of the industry and the regulatory structure under which it falls, something one would think would be a prerequisite for reporting on it.

But on that, specific to this, one would be thinking incorrectly.

Unfortunately, NPR failed its audience. Reporter Elizabeth Shogren accepted just about everything the CSPH said at face value, and only briefly mentions that its findings have been challenged by local officials and scientists within the industry. The segment conveniently fails to mention why those challenges were made, and what the substance of those challenges were – effectively denying NPR’s listeners a full account of the controversy.

Other news organizations managed to describe the findings and some of the flaws in the CSPH’s paper, in accordance with basic journalistic standards. Among the examples:

The Associated Press – “Energy In Depth has disputed that study’s findings, saying it exaggerates emissions from gas well development by at least 10 times and fails to take into account exhaust fumes from a nearby interstate highway.”

Public Radio International – “[A]n oil and natural gas industry group has mounted an aggressive campaign to point out what it says are flaws in the research. … Among the group’s specific complaints are that the study doesn’t account for pollution generated by Interstate 70, which passes within a mile of the wells.”

Denver Business Journal – “Among the study’s problems, according to Energy-In-Depth and [the Colorado Oil & Gas Association] … air samples for the study were taken between January 2008 to November 2010, but Colorado tightened its air emission requirements for the oil and gas industry in April 2009 … Air pollution from other sources wasn’t considered as a source, even though some of the air samples were taken one mile away from Interstate 70 … The cancer risks outlined in the report are no greater than national statistical averages…”

UPI – “The study used out-of-date emissions data and overestimated by a factor of 10 how long it takes to develop a new natural gas well, the industry group said, adding that the study failed to account for pollution from Interstate 70, a mile away from the gas wells.”

So then, what are the main issues with the CSPH paper? Here’s the short version: CSPH dramatically overstates people’s exposure to gas-well emissions. But even though they assume emissions are more than 10 times higher than real-world conditions, and treat exhaust fumes from Interstate 70 as if they came from gas wells, the authors of the paper admit they could not show a clear correlation between proximity to those gas wells and higher health risks. By deciding the public didn’t need to hear those criticisms, NPR denied Colorado’s oil and gas industry the chance to properly defend itself against the allegations in this flawed research paper.

Of course, beyond the industry, lots of other folks have stepped up and identified serious flaws with the CSPH methodology. Let’s start with Jim Rada, Garfield County’s top public health official. Rada was interviewed for NPR’s segment on the CSPH, but there’s no mention that he disavowed its paper on health risks. After the paper was released, Rada made clear that it wasn’t sanctioned or funded by Garfield County.

Then there’s the Colorado Department of Public Health and Environment. At one point, the CDPHE was helping the CSPH find funding for its work, but the agency eventually backed out after criticizing CSPH’s approach. NPR surely knows this, because it interviewed David Ludlam, the executive director of the West Slope Colorado Oil & Gas Association. WSCOGA’s March 20 rebuttal to the CSPH paper specifically cited the CDPHE’s “extremely critical” comments about the project’s methodology.

So, for the record, the health-risk study that underpins all nine minutes of this NPR segment has been criticized by multiple stakeholders, not just the oil and gas industry. The study’s critics also include local and state health officials, which would seem a relevant thing to mention in a nine-minute NPR segment on the study. But it never was. Probably because it didn’t fit with the reporter’s pre-established narrative.

UPDATE III (5:01pm ET, 3/23/2012): In a story for Platts Gas Daily (subs. req’d), Garfield County environmental health chief Jim Rada says the press release announcing the CSPH study “made it sound like there was new information” that was being released. In reality, the data in the study was simply lifted from an earlier draft assessment that was criticized by the state and the industry alike. “One needs to read the entire report to understand the relative risks,” Rada says. “There are significant limitations to the data.”

UPDATE II (1:22pm ET, 3/22/2012): The Colorado Oil and Gas Association (COGA) issued a statement that casts more light onto the flawed assumptions in the CSPH study. COGA states up front that it “appreciates the work being done by Colorado’s institutions of higher education and relies on them for unbiased, non-politicized data and information.” Unfortunately, the CSPH report “does not reach that standard.” COGA adds that the initial study on this subject by CSPH “was critiqued as politically-charged and of questionable scientific merit,” and, unfortunately, “the data from that [initial] report is regurgitated in the current study.”

UPDATE (2:35pm ET, 3/21/2012): David Ludlam, executive director of the West Slope Colorado Oil and Gas Association (WSCOGA), posted a response to the CSPH findings. “WSCOGA agrees that oil and gas operations must be protective of public health and the environment,” Ludlam writes. But Ludlam also notes that this particular report “lacks the necessary supportive data and proper context and represents a basic restatement of the Battlement Mesa Health Impact Assessment — a project that was suspended, in part, due to the State of Colorado’s criticism of the project.” Ludlam adds that the report is “basically a restatement of data already proven to be weak on supportive data and void of critical proper context.”

—Original post from March 20, 2012—

A new paper from the Colorado School of Public Health (CSPH) released this week suggests the development of oil and natural gas in general – and the use of hydraulic fracturing in particular – can cause “serious health impacts” for those who live closest to well sites. But if you look past the ominous headlines that the study launch generated and examine the range of strange assumptions that form the basis for the report, the conclusions are not only rendered fairly predictable, but also unquestionably flawed.

Of course, we’ve all seen first-hand how choices made by a researcher with respect to the inputs he or she uses as part of a study plan can, and indeed will, significantly impact the nature of the results. The infamous Howarth paper from Cornell University, for example, used a global warming potential for methane 45 percent greater than what even the U.N. Intergovernmental Panel on Climate Change says is appropriate. That flawed input, along with the casual use of “inflated leakage” rates, served as the central basis for its deeply flawed (and widely debunked) conclusions.

In some ways, the inputs used by the CSPH researchers are even more egregious than those found in the Cornell report. Below, we identify eight specific assumptions made that, upon closer examination and considered in combination, cast serious doubt on the results produced by the modeling exercise.

Bad Input #1: Out of Date Emissions Data

CSPH: “We used air toxics data collected in Garfield County from January 2008 to November 2010 as part of a special study of short-term exposure as well as on-going ambient air monitoring program data to estimate subchronic and chronic exposures and health risks.” (p. 8 )

• FACT: Colorado updated its regulatory requirements for oil and gas systems in February 2009, which means at least a portion of the data collected by CSPH is from an operating environment that, by law, no longer exists. Among the rules were requirements for volatile organic compounds (VOCs) to be reduced by as much as 95 percent through the use of low- or no-bleed pneumatic devices.

Bad Input #2: Inflated Time to Drill and Complete a Well by as Much as 900%

CSPH: “We assumed a 30-year project duration based on an estimated 5-year well development period for all well pads, followed by 20 to 30 years of production.” (p. 11)

CSPH: “To evaluate subchronic non-cancer HIs from well completion emissions, we estimated that a resident lives ≤ 1/2 mile from two well pads resulting a 20- month exposure duration based on 2 weeks per well for completion and 20 wells per pad, assuming some overlap between activities.” (p. 12)

• FACT: The well development process takes a matter of months, not years. In fact, well development, as defined by CSPH in the same study, “involves pad preparation, well drilling, and well completion” (p. 5). According to the Marcellus Center at Penn State University: “The total time to drill each well is about a three to six weeks depending on the depth and length of the horizontal well, so if there are four wells on a well pad, you could expect the big rig to be there for about three to six months.” The Marcellus Center adds that hydraulic fracturing (i.e. completion) “typically occurs within a few weeks or months of the well drilling, dependent on the project schedule, and may take up to several days for each well to be hydraulically fractured.” API also notes that the process takes “two to five days for the entire multi-stage fracturing operation.”

Bad Input #3: Inflated Small Cancer Risks Due to Lack of Context

CSPH: “The cumulative cancer risks based on the 95% UCL of the mean concentration were 6 in a million for residents > ½ mile from wells and 10 in a million for residents < ½ mile from wells.” (p. 15-16)

• FACT: While these numbers are small, the lack of context suggests they could be significant. But according to EPA’s National-Scale Air Toxics Assessment (NATA), these risks are in line with or even well below the risk for the entire U.S. population. According to a recent EPA report: “NATA estimates that all 285 million people in the U.S. have an increased cancer risk of greater than 10 in one million. 13.8 million people (less than 5 percent of the total U.S. population based on the 2000 census) have an increased cancer risk of greater than 100 in a million. The average, national, cancer risk for 2005 is 50 in a million. This means that, on average, approximately 1 in every 20,000 people have an increased likelihood of contracting cancer as a result of breathing air toxics from outdoor sources if they were exposed to 2005 emission levels over the course of their lifetime.”

Bad Input #4: Assumed No One Ever Leaves Garfield County

CSPH: “We assumed a resident lives, works, and otherwise remains within the town 24 hours/day, 350 days/year and that lifetime of a resident is 70 years, based on standard EPA reasonable maximum exposure (RME) defaults (US EPA 1989)” (p. 11)

• FACT: The study assumes that, aside from a few quick out-of-town weekend trips per year, residents never, ever – ever! – leave the city limits over the course of 70 years. Unless the “town” is actually a prison, this is a fundamentally flawed assumption about the length and extent of exposure.

Bad Input #5: Failed to Account/Control for Other Variables

CSPH: “The GCPH collected ambient air samples every six days between January 2008 and November 2010 (163 samples) from a fixed monitoring station located in the midst of rural home sites and ranches and NGD, during both the well development and production. The site is located on top of a small hill and 4 miles upwind of other potential emission sources, such as a major highway (Interstate-70) and the town of Silt, CO…” (p. 9)

CSPH: “The GCPH collected 16 ambient air samples at each cardinal direction along 4well pad perimeters (130 to 500 feet from the well pad center) in rural Garfield County during well completion activities… All five well pads are located in areas with active gas production, approximately one mile from Interstate-70.” (p. 9-10)

• FACT: When studying concentrations and identifying sources of benzene, it’s probably not a great idea to take samples from areas closer to a major highway than the ambient, control samples. The EPA classifies benzene as one of many Mobile Source Air Toxics (MSATs), and in its Final Rule to Reduce Mobile Source Air Toxics, the EPA notes that “most of the nation’s benzene emissions come from mobile sources. People who live or work near major roads, or spend a large amount of time in vehicles, are likely to have higher exposures and higher risks. People living in homes with attached garages are also likely to be exposed to benzene levels that are higher than average.”

Bad Input #6: Poor Distance Assumptions Increased Uncertainty

CSPH: “The actual distance at which residents may experience greater exposures from air emissions may be less than or greater than a 1/2 mile, depending on dispersion and local topography and meteorology. This lack of spatially and temporally appropriate data increases the uncertainty associated with the results.” (p. 21)

• FACT: Here, CSPH admits that its main basis of comparison – those living within and outside of a half mile zone surrounding a well – may not actually be representative after all. And in a study whose main conclusion, according to its press release, is “air emissions near fracking sites may have serious health impacts,” uncertainty about distance – and thus what defines “near” – means there is also considerable uncertainty about the conclusions.

Bad Input #7: Failed to Communicate with Local Environmental Officials

CSPH study author Lisa Mackenzie: Garfield County “did not financially support the scientific paper. We did this on our own. We feel the findings are significant, and we are scientists, and this is the way scientists communicate with each other” (Glenwood Springs Post Independent, 3/20/2012).

• FACT: If that’s how scientists communicate, it’s news to at least one notable health official, namely Jim Rada, Garfield County’s chief environmental health official. Rada said of Mackenzie’s work: “I had no knowledge of what she was studying, or her methods, or the implications of her work.” Rada also noted: “We are not in violation on ambient air quality standards.”

Bad Input #8: Who’s in Charge Here?

CSPH press release: “Garfield County asked the Colorado School of Public Health to assess the potential health impacts of these wells on the community of Battlement Mesa with a population of about 5,000.” (Press Release, 3/19/2012)

• FACT: This is also news to Rada, who said: “We didn’t ask them to do this paper. They were not sanctioned by the county, or paid by the county to do this paper.” As the Glenwood Springs Post Independent reported shortly after the release of the study, the CSPH paper “became embroiled in controversy” about a year ago after criticism by the Colorado Department of Public Health and Environment (among others), and the study “was decommissioned by the Garfield County commissioners in May 2011.”

The whole place reeked — like someone had spilled a giant bottle of nail polish remover. …

Now, no one knows whether the gas drilling has anything to do with the problems at the clinic. It could easily turn out to be something completely unrelated. There’s a smelting plant down the road and old coal mines everywhere. …

So they’ve moved the clinic to temporary offices until someone figures out what’s going on.

If this is supposed to be a piece of investigative journalism, then someone forgot the part where the reporter actually investigates. Because there’s no mention that the odors were first complained about before drilling began, no mention that things are fine in the dental practice on the first floor, no mention of recent construction in the building, and no mention that methane – the primary constituent of natural gas – is colorless, odorless and tasteless. NPR also fails to tell its listeners that the gas well in question is almost a mile from the building, and leaves out the fact that a junkyard and auto repair shop – where cars are spray painted – sits just 350 feet away. Remember, people are complaining of something that smells like acetone, and acetone is a widely used product in spray painting.

Of course, maybe NPR does know about the spray painting that goes on across the road from Cornerstone Care, and other important facts that suggest natural gas development has nothing to do with the odors. But then, disclosing those facts might spoil the “mystery” story that NPR is trying to stand up, with the help of gas industry critics like State Rep. Jesse White.

—Original post from May 14, 2012—

Everyone knows the story of the boy who cried “wolf” – but have you heard the one about the state representative who cried “gas well”?

At Energy In Depth, we’ve investigated and debunked all kinds of slurs, myths and allegations – far too many, and far too frequently, for our liking. But every once in a while, we encounter a rush to judgment that’s more than just wrong – it’s plain silly. Consider the following effort to implicate shale development in the temporary closure of a medical facility in southwestern Pennsylvania, as reported earlier this month by the Pittsburgh Post-Gazette:

Cornerstone Care’s Medical & Dental Plaza in Burgettstown, Washington County, was evacuated Friday for the third time since the end of March due to strong industrial odors that sickened patients and employees.

County and state agencies, and air quality consultants hired by the Cornerstone, can’t find the source of the odors, and Robert MtJoy, Cornerstone chief executive officer, said he will close the medical clinic until they do. …

Cornerstone serves approximately 1,000 patients on the second floor of the two-story building along Route 18 and employs 50 workers. The Cornerstone dental clinic, on the first floor of the building, has not experienced any indoor odors and will remain open. …

Mr. Poister said the DEP air program workers did a “walk through” of the medical facility April 27 as well as the closest Marcellus well a quarter mile away but did not smell the odor at either place. …

Mr. MtJoy said the Cornerstone building is “surrounded” by Marcellus Shale gas operations …

State Rep. Jesse White, D-Cecil, said he expects the DEP to do a better job responding to the odor complaints, and said the department’s oil and gas bureau at the regional office and in Harrisburg haven’t been responsive.

“DEP’s response has been unacceptable,” Mr. White said. “My district just lost one of the only places we have to provide health care and someone needs to provide some answers. Where’s the accountability?” http://goo.gl/0t4CF

The closure of a health facility – even if temporary – is a serious matter, and one that warrants a serious examination of the causes. Such an examination would likely focus to start on the building itself, where recent construction work has been taking place; it might also take into consideration the fact there is no odor in the dental clinic on the first floor.

Another interesting fact: According to several recent news articles, patients had complained about the odor issues in the building before any Marcellus wells were drilled at all. That’s right, people were complaining about the odor before the well was even drilled. We should also mention that the well itself resides almost a mile away from the building – about four times the distance initially reported.

DEP officials have monitored the air quality outside the building and could not detect the odor. DEP officials have also visited the well site and found no evidence that the operations there are responsible for the smell. It’s important to note that methane, the primary constituent of natural gas, is “colorless, odorless, and tasteless,” according to the Energy Information Administration.

But let’s assume for a moment that the source of the reported “lacquer-like odors,” or “acetone or nail-polish removal smell,” lies outside the building. The way these news reports read, a well pad almost a mile away apparently is the only possible outdoor source that could cause these “industrial odors” to exist. But what if we told you there was an auto repair shop across the road with its own junk yard?

And what if the same premises had facilities on-site for painting cars? It’s about 350 feet from the medical center, and it probably uses some acetone-based products, based on this information from Dow Chemical:

As a solvent, acetone is frequently incorporated in solvent systems or “blends,” especially as the low-boiling component of “high-low” blends. Many of these acetone-solvent blends are used in the formulation of “high-solids” cellulose ester lacquers for automotive and furniture finishes. They also are used in acrylic automotive lacquers, particularly when the acrylics are modified with nitrocellulose. Acetone, which has a dilution ratio of 4.5, may be used to reduce the viscosity of lacquer solutions. …  Acetone is widely used in the textile industry for degreasing wool and degumming silk. Also, large quantities are used in paint, lacquer, and varnish stripping compounds, and in nail polish removers. http://goo.gl/Bvrp2

In fact, acetone is used as a thinner that makes it easier to pump automotive paint and lacquer through the nozzle of a spray gun. It can also be used to clean the spray gun after a paint job is complete. Indeed, environmental regulators have encouraged auto body shops to use more acetone because, unlike many other solvents, the fumes from acetone do not contribute to smog formation in the air. That said, acetone-based thinners can still cause acute health impacts if those fumes are inhaled in high concentrations. For instance, here’s the health warning from the Material Safety Data Sheet of one thinning product:

Vapor harmful. May cause dizziness; headache; watering of eyes; irritation of respiratory tract; weakness; drowsiness; nausea; numbness in fingers, arms and legs; depression of central nervous system; loss of appetite; fatigue; hallucinations; light headedness; visual disturbances; giddiness and intoxication; sleepiness; cough and dyspnea; cold, clammy extremities; diarrhea; vomiting; dilation of pupils; spotted vision.

So, to recap: The CEO of the clinic temporarily closes his facility, citing an “acetone-like” smell nearby. His default reaction, and that of his state representative, is to blame the existence of a natural gas well about 5,000 feet away. Notwithstanding the fact that an auto body shop/junk yard where acetone is used in significant quantities resides barely 350 feet away from his front porch. Or the fact that there were complaints about the acetone-like odor before the well in question had even been drilled.

 Of course, only the second floor of the clinic has been hit with the odor, and that’s the only level of the building that faces the road. The first-floor dental clinic, where no odors have been reported, was built behind an embankment that would block any fumes that drift across the road.

Plus, there’s also the possibility that the odor is coming from inside the building if one of the contractors involved in the construction work happened to leave some painting products behind. And yet, almost all the speculation focuses on a natural gas well pad almost a mile away, and the offending odor was first reported before drilling even started at that location.

It sure sounds (or smells) like someone is pushing the “blame a gas well” storyline to the news media. Perhaps someone who’s a critic of the oil and gas industry whose job security depends on getting quoted in newspapers?

State Rep. Jesse White, quick to upbraid DEP in the press for failing to blame a gas well for the odor, seems to fits that description pretty well. According to AOL Energy, he’s “an outspoken opponent of the state’s gas industry,” and let’s face it, elected officials are always looking for ways to win the media’s attention. Well, it seems some of Rep. White’s constituents already concluded he’s the one pushing this story, based on this statement from his campaign website:

Let’s stop right here for a minute, because I know the response forming in many peoples’ [sic] minds, and I want to address it right here and now. First, I am in no way saying that oil and gas activity caused the problems at Cornerstone Care. I am not a scientist, and although I know a lot more than I did a few years ago about the drilling process, I don’t pretend to be one. Second, I am not trying to whip people into a frenzy to oppose the natural gas drilling. …

So we have a system where the DEP Oil and Gas Unit is the only group who can investigate these types of problems, and although I cannot say with certainty the problems at Cornerstone are related to drilling, no one can say with certainty that they are not caused by drilling. You would think the Oil and Gas Unit would be quick to respond, if for no other reason to dispel any concerns right away, especially for a high-profile public health facility situated in the dead center of the Marcellus Shale boom. …

The odors in the building aren’t the only thing that smells funny here. http://goo.gl/bBnwL

We think that Rep. White doth protest too much. If you read the news clips above, you’ll see he’s absolutely blaming oil and gas activity for the problems at Cornerstone Care, and worse still, he’s demanding that the DEP focus its entire investigation on the oil and gas industry, even though there’s no evidence suggesting that’s where the odor came from (or the fact that the monitoring of indoor air quality isn’t even part of DEP’s job description). Remember, people in the building had reported the odor before drilling even commenced.

Unfortunately, Rep. White seems more interested in pursuing a personal political agenda than finding the actual cause of the problems at Cornerstone Care. By insisting that everyone involved stay focused on the oil and gas industry, at the exclusion of all else, when other culprits are much more obvious and likely, he’s just getting in the way of a real examination by the DEP and the owners and tenants of the building. Sadly, that probably means it will take longer for the problems at the medical center to be identified and fixed, which is something Rep. White’s constituents might be disappointed to hear.

Don Siegel, Ph.D.

Last month, the journal of the National Ground Water Association published a paper by an environmental consultant in Nevada in which the proposition is put forth that the vertical transport of contaminants from the Marcellus Shale formation of southern New York to potable, near-surface aquifers is not only plausible, but likely – brought to us in as few as “three years,” he argues, and all because of hydraulic fracturing.  

It’s an explosive thesis, to be sure – but one that’s also fatally flawed; very good news for those of us who actually live here in upstate New York. Predictably, and perhaps as designed, the paper generated a great deal of attention in the press after ProPublica first reported its conclusions on May 1. But as I attempt to explain below, the physical realities governing the hydrodynamic flow of fluids underground can’t be as Dr. Tom Myers, the report’s author, suggests. I say this as someone who has studied the specific hydrogeology of New York for over 30 years.  

I found a number of fundamental errors in Myers’s model when I gave it a first, cursory review. Some of the most obvious:

Problem 1: Mistaken assumptions on rocks above the Marcellus Shale. 

Among the most significant errors made by Myers was his assuming most of the deep rocks overlying the Marcellus Shale do not consist of dry, dense shale. As explained in E&E News (subs. req’d) earlier this month by my colleague Terry Engelder, that’s just not true; most of the rock above the Marcellus consists of shale. And since shale can’t pass much water, particularly if it is dry and solid, Myers’ computer model cannot calculate proper water flow conditions.

As Engelder explained, instead of being predominantly sandstone, as in Myers’ model, the overburden contains 90 percent shale and only 10 percent sandstone. If the sandstone were replaced by shale within Myers’ model, the time frame required for water movement to shallow aquifers thousands of feet above the Marcellus would increase to 100,000 years, similar in time to what I found two decades ago when I did my own computer model of deep ground water flow in southwestern NY and northwestern PA. 

Because the shale is dense, dry, non-porous rock, companies need to fracture it to begin with; otherwise, there is no way to get the gas out.  Myers also fails to recognize that the brine produced from the Marcellus comes from immediately overlying brine-filled aquifers (also a mile or more deep) into which some of the induced fractures penetrate. This fact is clear from micro-seismicity studies and even more so from the ratios of dissolved elements such as chloride and bromide in the produced fluids. But, there is no local communication of these dense salty water to the surface, because of thick intervening dense and dry rock. 

Problem #2: Mistaken assumptions with respect to movement of groundwater.

It appears Myers does not understand some basic concepts and science behind groundwater movement through sedimentary basins. Water in the Marcellus under the Appalachian Plateau (southern New York and northern Pennsylvania) does not naturally move upward by means of artesian pressure toward the land surface, as Myers assumes.  And because of only this error, his model fails on first principles.  

For more than 60 years, hydrogeologists (if not engineers) have understood that groundwater moves in nested flow systems; regional, intermediate, and local in size. The Appalachian Plateau topographically constitutes the regional replenishment area for long flow paths of deep brines all the way to Lake Ontario, but only along a few focused and rare deep fault systems. It takes hundreds of thousands of years for water to make this journey, if not much longer. The shallow groundwater system from which people get their drinking water on the Appalachian Plateau occurs within the upper 1000 feet (usually far shallower), ubiquitously separated by thousands of feet of dense dry rock, mostly shale, from the deep basin salt waters at the depth of the Marcellus. This understanding of groundwater moving in sedimentary basins has been so well established that every modern hydrogeology textbook produced over the past five decades contains it.

I know of no instance of deep groundwater on the Appalachian Plateau moving upward under artesian pressure toward the land surface, except in glacial cut valleys that penetrate through this thickness. Period. And I’ve see a lot of water level measurement on the Plateau over the years, both in New York and in Pennsylvania. 

Problem #3: Assumed fracture-lengths wildly exaggerated.

Myers suggests that faults or fissures opened by hydraulic fracturing can and will move dense formation water (flowback and produced waters) upward for 1 to 2 miles into shallow, potable waters. It’s an assertion that’s not grounded in either science or experience.

Indeed, there are fractures at shallow depths (generally no deeper than 600 feet) that produce modest groundwater volumes for individual homes and farms.  But these fractures pinch off at depths greater than a few thousand feet.  If they did not, natural gas in the Marcellus Shale would have escaped naturally long before now. Because the shale compacts under the weight of all the overlying rocks, oil and gas firms need to use sand to prop fractures open to create the conduits necessary for the hydrocarbon to flow to the wellbore. Despite this basic fact, Myers appears to be arguing that new fractures in the Marcellus can be opened naturally by the very low energies created from hydraulic fracturing,  and then stay open through more than a mile or more of rock that largely consists of shale, even without the introduction of proppant to keep them open. The suggestion is absurd.   

Myers also fails to recognize that dense produced waters cannot move upward easily into fresh water because they are, well, dense.  For decades, hydrologists using MODFLOW (the model Myers used) have incorporated a mathematical correction called  “effective freshwater head” in their modeling when large salinity differences occur.  Myers assumes the brines in the Marcellus have all the same density as the dilute freshwater at the top. This makes no sense for what he was trying to test.  Indeed, it is extraordinarily implausible (bordering on impossible) to imagine brines moving locally upward into fresh water aquifers owing to the density differences. In contrast, it is easy to move brines downward into fresh water because they weigh more than the fresh water.   

Conclusion

More than anything else, the public needs to know that a mathematical model of groundwater flow, such as the one prepared by Myers, constitutes only a representation of reality—it is not reality itself. Before any math model can be built, a scientifically plausible conceptual model needs to be developed.

As it relates to this particular paper, Myers has developed an implausible model that predictably leads to implausible, and in my judgment, completely wrong results — from simple first principles of geologic and hydrologic understanding, let alone acceptable model development.

Mark Twain said “never let the truth stand in the way of a good story.” A common hydraulic fracturing narrative is that the technology pollutes water supplies. The story goes that fracturing is a mysterious and untested practice, that fracturing fluids are a secret, “chemical cocktail,” that there are innumerable incidents of aquifer and drinking water contamination, resulting even in tap water catching fire, and that “Big Oil” has pressured Congress into exempting the technology from any environmental laws.

The truth is not as exciting. Hydraulic fracturing involves the injection of fluid consisting of approximately 99.5% water and sand (the rest consists of common industrial or even household chemicals or materials) through wells constructed with protective casing and cement, into producing shale formations. The formations are thousands of feet below drinking water aquifers, separated by impervious rock.

While the technology has evolved and is used more frequently, fracturing is not new, is heavily regulated at the state level, and enjoys no blanket exemption from environmental laws. There is no credible data indicating that fracturing of shale formations has ever contaminated drinking water.

Fracturing proponents have struggled to gain the high ground in the debate on water quality, even as they debunked the myths time and again with facts and data. Fortunately, the groundwater issue may be losing traction, at least concerning some high-profile cases where the regulators recently have retracted allegations or reconsidered data.

This is why the thrust of the manufactured narrative that fracturing is a menace to the environment is now shifting to air quality. The time is now to separate fact from fiction in the public consciousness, and to demand transparency on the part of those who oppose fracturing and would have it banned or regulated into oblivion.

On April 17, 2012, EPA issued new rules requiring operators to use special equipment to separate and capture the gas and liquid hydrocarbons from the flowback that comes from the fractured wells. Fracturing opponents have already complained that the new rules have a phase-in period, allowing companies to pour “clouds” of pollution into the air. This fails to recognize the oil and gas production already was subject to extensive federal and state air quality regulations before the new rules. Also, EPA’s estimates of emissions from well-completions probably were overstated. Further, the new regulations adopt an across-the board, “one size fits all” approach that do not adequately consider the wide variability in oil and natural gas production operations and emissions. In addition, some states already impose the “green completion” requirement for fractured wells, and there is ample legal and practical justification for leaving this issue to the individual states.

The point is not that capturing emissions in a cost-effective and technically feasible manner lacks any merit or that the industry should grouse about regulation. Rather, the public should know that air emissions associated with hydraulic fracturing (where they exist) remain a small part of a very large and complex issue, that the oil and gas production industry has long done its part to reduce air emissions from a variety of sources, and that reasonable minds can differ about whether the new regulations make sense as adopted.

This will not stop fracturing opponents from casting a dark cloud over fracturing based on air quality hysteria, just as they did regarding water quality. Already, sound-bites from well-orchestrated anti-fracturing forces tell us that these regulations prove that that emissions from fractured wells are the cause of smog and are “cancer causing.” These allegations grossly oversimplify complex scientific and health matters. Smog is a regional concern involving many large sources, vehicles, and meteorological factors. It is meaningless to say that something can cause cancer without extensive baseline data about dosage, proximity, exposure and other factors that fracturing opponents never discuss.

The one important fact is that fracturing of an individual well emits relatively small amounts of volatile compounds, the material of concern, and some wells emit none at all.

Yet it does not end there. One university scientist even wrote a paper alleging that greenhouse emissions from shale gas production are worse than the burning of coal. While both coal and gas play important roles in our energy future, and there is another agenda to regulate coal-fired power plants out of existence, the claim is contrary to the well-accepted fact that the greenhouse gas impacts of burning natural gas are less than coal. The paper was debunked in a wide-variety of scholarly journals, by the Department of Energy, and even criticized by some environmental groups. Yet the story was a good one, so it got reported while the truth was pushed aside.

As the narrative shifts to air quality, it is also important to open a sincere dialogue about the motivations off the anti-fracturing movement. Is opposition to hydraulic fracturing really about the alleged risks of the actual practice of fracturing, is it about opposition to fossil fuels generally, or do opponents simply not want development in their backyard? These are all very different issues. It is perfectly reasonable to have a debate about any of them, and the life-cycle of a well is not without some environmental risks that are worthy of discourse. But it is not productive to demonize fracturing as a means to a different end, such as elimination of the fossil fuel economy or promotion of “alternative energy.” Nor is it beneficial to address the supposed risks of fracturing without acknowledging the critical role it plays in allowing the economical recovery of massive quantities of natural gas and oil from unconventional shale resources.

Fracturing is conducted on more than 90% of wells drilled today. The practice benefits the economy, has kept natural gas prices at historic lows, and reduces our reliance on foreign energy supplies. Opponents of fracturing should be asked how they intend to duplicate these results, how they intend to find near and long term substitutes, and whether their position is in the best interests of lower-income Americans who benefit from affordable energy.

Clearly, oil and gas development poses environmental issues that need to be managed. Equally clear is that the industry is subject to heavy environmental and safety regulations. Oil and gas does not have a perfect compliance record, which is impossible. The problem is that, increasingly, fracturing itself is wrongly blamed for every problem and complaint that arises in the vicinity of a well. We know this from the experience with water quality.

There have been a few issues related to other phases of drilling, such as improper casing or cementing of a well or leaking wastewater pits. These are not fracturing issues. There are well-documented cases where drinking water wells have been contaminated by naturally occurring methane. This is not a fracturing issue. Yet the industry is being held to a standard it cannot meet: prove that fracturing did not cause these problems. Proving a negative is impossible, especially in an atmosphere of misinformation or even scaremongering, and especially when the burden is on “Big Oil.” With air quality, there is a new opportunity to avoid this dilemma. Opponents using air quality as a sword should be met with industry transparency and listening, public outreach and context, good science, dialogue about energy policy and natural gas, and hard questions about the motives behind the anti-fracturing movement. The hydraulic fracturing storyline about supposed environmental catastrophe should no longer get in the way of the truth.

Colin Harris is an attorney with Bryan Cave LLP. For over twenty years, Colin has served the energy and natural resources industry in environmental, public lands and related matters. He has extensive experience in matters pertaining to the Clean Air Act and Clean Water Act.

“A second scientific report in as many weeks will be presented to Erie’s elected officials challenging the notion that natural gas drilling operations in town are spewing unhealthy levels of emissions into the air.” http://goo.gl/OClPQ

This is the second time that Erie town officials have sought independent scientific advice to check the claims made by Brown and Erie Rising in February. It’s also the second time that outside experts have concluded Erie’s citizens are safe, and exposed just how flimsy and irresponsible those claims really are.

According to the Daily Camera, Erie Mayor Joe Wilson believes the town’s Board of Trustees were given distorted information before they voted for a 180-day moratorium on new oil and gas development:

“Wilson said the studies that have been commissioned by the town staff in the last few weeks to interpret and give meaning to the NOAA data indicate the agency’s findings were used by some drilling and fracking opponents ‘politically and inaccurately’ to cast Erie in a bad light. …

‘What we want to do is put this stuff in context, which it wasn’t before,’ he said. ‘As people get more educated, we’re seeing them becoming more accepting of oil and gas operations.’”

Let’s hope the facts will continue to drive the debate in Erie – and elsewhere – over the best ways to develop America’s abundant energy resources.

 —Original post from April 30, 2012—

“One of the basic foundations of modern science … is ‘peer review.’ Peer review means new scientific discoveries, ideas, and implications are not accepted or considered valid until they have been scrutinized, critiqued, and favorably reviewed…”

 National Oceanic and Atmospheric Administration (NOAA)

“…I don’t really have time to take you through the details of an analysis like this. I’m just going to ask you to believe what I tell you…”

Steven Brown, NOAA Employee

The development of homegrown American energy is giving communities across the country a fighting chance to overcome our current economic malaise. By one estimate, oil and natural gas development supports 9 million U.S. jobs and contributes more than $1 trillion to the economy every year. That said, the communities blessed with oil and gas resources often have reasonable questions about how energy production will proceed.

Here’s the good news: the independent companies that develop the vast majority of oil and gas wells are good neighbors with a strong record of responsible development, and interlocking state and federal environmental laws ensure the industry’s operations are tightly regulated. That’s not just the industry’s view – it’s also shared by the energy and environmental experts who enforce those laws.

Still, some communities want to hear from other folks, including scientists. That’s perfectly reasonable, too, as long as anything presented as “science” meets some basic scientific standards. The first and most important of those standards is rigorous and effective peer review. Without it, anything a scientist says is just an opinion, not the kind of hard evidence that’s needed to craft effective environmental laws and regulations.

Unfortunately, that lesson was completely ignored recently in Erie, Colo., a small town nestled in the northern suburbs of Denver. A single government scientist – Steven Brown of the National Oceanic and Atmospheric Administration – appeared before the town’s Board of Trustees at the behest of activist groups that oppose oil and gas development. Armed only with a slide presentation, Brown swayed the board into approving a six-month ban on new oil and gas development in Erie.

Energy in Depth wants to set a few things straight about Brown’s presentation, the way it’s being spun by activists and how it’s been covered by the news media. EID’s concerns are serious, and we hope they’ll be taken seriously by the Town of Erie, NOAA and anyone else with an interest in sound science and the responsible development of America’s abundant oil and gas resources made possible by the combination of horizontal drilling and hydraulic fracturing.

The Town of Erie acted on opinion, not science

Brown’s central claim goes something like this: During a one-month research project in the winter of 2011, a NOAA observation tower in Erie recorded higher levels of propane in the air than are usually seen in Pasadena, Calif., and Houston. Brown surmised that the propane emissions came from oil and gas development in the Denver-Julesburg Basin.

Brown’s Feb. 21 presentation, which can be accessed here, was highly technical in nature, especially the section that tied those propane emissions to oil and gas development. But rather than explain it fully, Brown told a group of elected officials who were poised to act on his findings:

“What you can do with a set of data like this is to break it down into what the likely sources are. I don’t really have time to take you through the details of an analysis like this. I’m just going to ask you to believe what I tell you about the ranking of these compounds…”

Brown’s presentation played perfectly into the communications plan of environmental groups, including the local activist organization Erie Rising. Together, they have been trying to frighten Erie’s citizens and elected officials into banning new development with unsubstantiated health and environmental allegations. Here’s a sample of the press coverage generated by Brown’s presentation to the Board of Trustees:

“A study showing that Erie exceeds Houston and Los Angeles in the levels of certain air pollutants commonly connected to oil and gas activity became a point of concern for several trustees Tuesday night during a meeting held to formulate local rules for resource extraction.” http://goo.gl/50TgA

“A National Oceanic and Atmospheric Administration study said the propane levels in the air in Erie are worse than in Los Angeles and Houston.” http://goo.gl/eyhkz

Air pollution worse than Los Angeles and Houston? That would strike fear into the heart of any elected official in a town where the median age is 33, the median household income is a touch under $100,000 a year, and officials brag about “educated, affluent, diverse and dynamic” residents and their “close proximity to world-class research and academic institutions.” Scarier still, it’s politically perilous for local officials to challenge Brown’s opinion because he works at one of those revered institutions – NOAA’s Earth System Research Laboratory, which is just a few miles west in Boulder, Colo.

So, on March 7, a little more than two weeks after Brown’s presentation, the Erie Board of Trustees voted unanimously for an “emergency ordinance” that imposed a six-month moratorium on new oil and gas development. But nine days later, NOAA revealed that the town had passed a local law based on the opinion of a lone scientist and the alarmist claims of environmental activists. In a March 16 notice on its website, the federal agency said:

“Please note that analysis of the data from this study is in progress. When a peer-reviewed paper is published, we will make it available to the public.” http://goo.gl/zWL6b

Brown didn’t get his conclusions peer-reviewed before presenting them to a local government. No peer review. No hard scientific evidence. Just an opinion. But that opinion, when it’s part of a concerted campaign of fear-mongering from activists, was powerful enough to get a local ordinance passed that was designed to shut down an entire industry within the town’s limits for at least six months. This wasn’t democracy in action. It was a mugging. Not just a mugging of an industry and its workers, but of the town’s elected leaders and the citizens they represent.

Of course, the Town of Erie’s authority to enforce such a ban is questionable, since state governments usually have jurisdiction over oil and natural gas development, not local governments. But that’s a discussion for another day.

The Denver area has better air quality, not worse, than Los Angeles and Houston

Brown’s presentation focused on propane and other volatile organic compounds, or VOCs, which can contribute to the formation of ground-level ozone, which causes smog. Other sources of smog-forming pollution include factories, power plants, car and truck exhaust fumes, gasoline vapors from vehicle refueling and chemical solvents, according to the EPA.

Both state and federal environmental regulators monitor ozone levels very closely, so it’s possible to make comparisons between different metropolitan areas.

According to EPA data, ozone levels in the Denver metropolitan area – which includes Erie – are 34 percent lower than those in Los Angeles and 15 percent lower than the levels in Houston. The same EPA ozone statistics show Denver and Erie have better air quality than 37 other major metropolitan areas.

Erie’s air quality has improved as natural gas development has expanded

When natural gas starts flowing from a newly developed well, VOCs can develop. And if they aren’t captured or flared, they can combine with other ozone-forming emissions from cars, trucks, power plants and factories and make an existing smog problem worse.

But that’s not happening in Erie. Colorado’s Air Pollution Control Division has a statewide network of monitoring stations that continuously measure air quality. These long-term monitors provide a much clearer picture of air quality than the month-long snapshot in Brown’s research.

One of those APCD stations is located just west of Erie, in Boulder, and another is placed in Greeley, about 40 miles to the northeast. Both the Boulder and Greeley stations are well placed to measure emissions from natural gas development, as well as all the other forms of pollution that exist in a major metropolitan area.

Ground-level ozone levels have fallen at the Boulder and Greeley monitoring stations in the past five years, according to Colorado APCD reports and data. Boulder’s maximum concentration under the federal 8-hour ozone standard has dropped by 6 percent, and Greeley’s has fallen by 10 percent. During those five years, natural gas production in Weld County – which takes in parts of Erie – climbed 25 percent, according to data from the Colorado Oil and Gas Conservation Commission.

That’s some feat. It should be a source of pride for the companies that develop oil and natural gas in Colorado, and the state’s regulators, who have worked together for nearly a decade to reduce the industry’s VOC emissions even as production grows.

Nobody is arguing that Erie’s air quality is perfect – it’s not. In 2007, Denver and its suburbs were deemed an ozone “non-attainment” area by the EPA. Since then, ozone levels have fallen, according to the EPA, but the Denver area remains in non-attainment. That’s because in 2008, the EPA ratcheted down the national ozone standard from 80 parts per million to 75 ppm. Even so, Weld County’s air quality compares pretty favorably to other areas of Colorado. The American Lung Association keeps tabs on 17 Colorado counties, and only five score better than Weld County.

But one thing is crystal clear from all this data on VOCs, ozone, smog and natural gas production: Erie Rising and other activist groups don’t have a leg to stand on when they argue air quality in the Denver area is getting worse and new natural gas development is the culprit.

Denver is a major metropolitan area with many sources of pollution

By his own admission, Brown failed to explain why he blames oil and gas development for the VOC readings at the NOAA observation tower. Remember what he told the Board of Trustees – “I’m just going to ask you to believe what I tell you.”

As mentioned earlier, oil and gas development is but one source of VOC emissions. According to the EPA:

“VOCs are emitted from a variety of sources, including motor vehicles, chemical manufacturing facilities, refineries, factories, consumer and commercial products products, and natural (biogenic) sources (mainly trees)…” http://goo.gl/woJlX

 As it turns out, nature is responsible for 72 percent of the VOC emissions in the air. Here are some of the sources that make up the remaining 28 percent: 

“…coal-, gas-, and oil-fired power plants and industrial, commercial, and institutional sources, as well as residential heaters and boilers … cars, trucks, buses, and motorcycles … construction equipment, lawnmowers, chainsaws, boats, ships, snowmobiles [and] aircraft.” http://goo.gl/woJlX

Nationwide, the largest source of VOC emissions are cars, trucks and other mobile sources. That’s also true in Colorado, where mobile sources generate 13 times more VOCs than oil and natural gas development, according EPA data. 

That should have mattered a great deal to Brown, because Interstate-25 is located about one mile east of the NOAA observation tower. According to Erie town officials, 91,000 vehicles a day use the stretch of I-25 nearest to the tower site. Even NOAA has warned of the impact of I-25 on the readings from the observation tower:

“I-25 lies to the east of the tower so winds form [sic] the NNE to SSE are likely to influence the tower measurements, depending on boundary layer conditions.” http://goo.gl/XR13Y

That’s hugely important, because besides propane, Brown also says the VOC benzene was detected at the observation tower. He calls benzene a “natural gas tracer,” and concludes it must have come from oil and gas development.

Care to guess what the biggest source of benzene is, according to the EPA? 

“…most of the nation’s benzene emissions come from mobile sources. People who live or work near major roads, or spend a large amount of time in vehicles, are likely to have higher exposures…” http://goo.gl/SOuqd

That’s right – the biggest sources of benzene are cars, trucks and the major roads they use. A major interstate highway with a traffic count of close to 100,000 vehicles a day more than meets that definition. Hopefully, the experts who peer review Brown’s presentation – if it ever gets that far – will ask some tough questions about this. 

There are other sources of propane and the levels detected aren’t dangerous

 A bigger question for Brown’s reviewers, though, is how he managed to blame oil and gas development so quickly for the high propane readings recorded at the tower. As with benzene, Brown simply concluded that because propane can be released from oil and gas wells, it must have come from oil and gas wells. But, of course, propane is a widely used fuel and Brown failed to explain how he excluded other possible sources. We are all just supposed to “believe” he knows where it came from. 

Brown may have overlooked the fact that the tower readings were taken during a month-long period during the heating season (Feb. 16 to March 13, 2011). Did he bother to check how many homes, businesses, industrial facilities, municipal buildings, universities and federal offices in the area are heated with propane, or use it in other ways? We don’t know because he didn’t bother to explain.

Among other sources he may have overlooked: propane-fueled vehicles. Erie is located right in the middle of two alternative-fuels programs spanning more than 40,000 square miles around Denver and Northern Colorado. Those programs promote the use of propane and other fuels. In fact, across the two programs, propane fueling locations are only outnumbered by electric charging stations and ethanol pumps. Within 50 miles of Erie, there are 34 propane fueling stations alone, according to the Department of Energy.

Of course, the failure to investigate the actual source of this propane wasn’t even most alarming part of Brown’s presentation. It was the levels he reported. They alarmed the Board of Trustees and no doubt many citizens of Erie, but in the notice it sent to the board, NOAA refused to put those levels into their proper context:               

“Some VOCs have known health risks. NOAA’s Earth System Research Laboratory does not have health risk expertise. Health information is available through other agencies…” http://goo.gl/zWL6b

Thankfully, though, rather than let activists continue to scare people with tales of toxic propane pollution, Erie officials sought to end the speculation. Perhaps stung by their experience with Brown, they “engaged in an independent, peer-reviewed” analysis to “determine what (if any) health effects would result from exposures to the levels of propane as presented.” The result? 

“The scientific analysis of the data concludes that: ‘The levels of Propane in the NOAA study are 1,000 – fold or more below those considered to be of a health concern.’ The average level of Propane as presented by NOAA was 20 ppb (parts per billion) and the maximum level was 115 ppb. According to the analysis: ‘Propane at 115 ppb (the peak level found) does not present a health concern to the citizens of the Town of Erie.’” http://goo.gl/nl7PZ 

To review: A peer-reviewed, scientific analysis of the central finding in Brown’s presentation – high propane emissions – concludes they are 1,000 times lower than the level that would cause health concerns.

Was Brown’s collaboration with activist groups appropriate?

After Erie’s elected officials approved the six-month moratorium last month, Erie Rising sent out a press release taking credit for both “remarkably discovering an unknown NOAA study” and for the vote itself. The release had all the hallmarks of a fundraising pitch, and made it clear the group’s ambitions extend well beyond Erie’s town limits:

“Founded by accomplished women, mothers and business owners, Erie Rising is positioned to become an exceptionally effective national grassroots mom-powered organization bringing awareness to the issues at hand.” http://goo.gl/GVx1C

Separately, a spokeswoman also bragged to a reporter that the group was directly involved in the preparation of Brown’s presentation and in arranging his appearance before the Board of Trustees:

“The study was never made public and it’s only through [Erie Rising’s member April] Beach’s curiosity that it came to light at all.

 ‘I had no clue what I was looking for’ when she called NOAA asking if anyone had studied air pollution in Erie, she said. She called Brown, whose name she found on the NOAA website, on something of a whim. He sent back pages of technical data indecipherable to most laymen and it took some back and forth with him to have it interpreted. When she showed the study to Erie Town Administrator A.J. Krieger, she said he urged her to have Brown present the trustees with the results.” http://goo.gl/uYIwW

Are we supposed to believe that Brown was innocently and unwittingly recruited to serve the interests of Erie Rising? Are government scientists supposed to engage in a “back and forth” with activist groups as they create propaganda that scares the public and helps them bully local officials into making hasty decisions? Does presenting data that has not been peer reviewed to a government body, when that information will be used to make policy, breach NOAA’s standards or federal data quality guidelines? Should a federal employee use taxpayer-funded research to help an activist group lobby elected officials, and collaborate with members of the group on how the research is presented?

We don’t know the answers to these questions. Hopefully now, though, we won’t be the only ones asking.

Sue Mickley

Uni Blake
Environmental Consultant – Toxicologist
Master’s Degree in Environmental Toxicology – American University

Last week the Institute of Medicine held a roundtable discussion to examine the “public health impacts” of natural gas development from U.S. shale resources.  Unfortunately, as is the case with most events concerning natural gas, it seems the outcome was determined before the first word was spoken.  This is clear by a quick review of the agenda which lists the meeting’s second objective as the “application of health impact assessments to identify ways to mitigate adverse health effects.”

As public health researchers we were surprised to see “adverse health effects” readily accepted as a key assumption. Especially considering the evidence supporting this is a collection of anecdotes refuted by international experts and past experience.

Given this background, some context is needed on the events leading to the roundtable, as well as to why the assumption of “health impacts” is problematic.

As natural gas development has moved into new areas, a small group of voices, most with ties to anti-natural gas advocacy groups, has stated the process negatively impacts public health.

Born in the northeast U.S., and finding other supporters across the nation, these actors have claimed natural gas operations have led to health impacts including symptoms such as nosebleeds, sores, nausea, and disorientation among others. These claims, many of which have been disproven, have largely surfaced in just the past few years, despite the 100 plus year history of oil and natural gas development in the United States, over 60 of which have involved the use of hydraulic fracturing.

Make no mistake, health impacts from natural gas production are not a foregone conclusion. Accepting them as one, in our judgment, is irresponsible and is a critical flaw that served as the foundation of this gathering.

The most well known “study” supporting the narrative of negative health impacts, in animals, has received heavy criticism by some of the world’s most respected scientists.  For example, in commenting on the study Dr. Ian Rae, a professor at the University of Melbourne in Australia and a co-chair of the Chemicals Technical Options Committee for the United Nations Environment Programme, stated “It certainly does not qualify as a scientific paper but is, rather, an advocacy piece that does not involve deep…analysis of the data gathered to support its case.” (emphasis added)

However, even more concerning than the acceptance of these “health impacts” was the anti-natural gas advocacy affiliation of many conference participants. Attendees were required to identify themselves before offering inquiries to panelists.  As part of this disclosure, it became clear that a majority of attendees not representing media or federal agencies were from anti-natural gas advocacy groups.  In fact, the amount of veterinarians from New York and researchers from Ithaca was astounding. Taken together, their presence was large enough to form a significant percentage of attendees, especially those most active in the proceedings.

In fact, one of the more active participants was Jeff Zimmerman.  Mr. Zimmerman identified himself as a representative of Damascus Citizens for Sustainability.  What we didn’t know at the time was Jeff Zimmerman is a Washington, D.C. based attorney actively litigating against natural gas producers.

It was disconcerting that critical assumptions were made without supporting data, and local activist groups and their litigating counsel, were shaping discussions at what was promoted as an unbiased dialogue on emerging energy sources.

But this important background aside, a closer examination, using experience and comprehensive data as opposed to assumptions, continues to suggest the assertions regarding negative public health impacts from natural gas development are unsupported and unsettled science.

Areas Experiencing Largest Development See Increases in Health Across all Parameters

We took a look at public health assertions last October in response to a letter submitted to New York Governor Andrew Cuomo. Curious about the validity of these claims, we turned our attention to the Forth Worth, Texas area (the nation’s 4^th largest metropolitan statistical area) where more than 16,000 natural gas wells have been developed over the past decade.

What we found was pretty interesting.  Community Health Status Indicators (CHSI) from 2000 – 2008 show every major health indicator improved at the same time natural gas production rapidly expanded.

For example, in 2009 natural gas production in the Barnett Shale had increased by 2,144 percent from 2000 levels.  In just nine years, technological advancements enabled 22 times as much natural gas to be produced as was produced in 2000. As production occurred and expanded, the health of the population of those counties simultaneously increased.

Below find a chart that compiles health data obtained from the CHSI.

Denton County Texas Key Health Indicators 2000-2008

We brought these findings to the attention of Christopher Portier, Director of the National Center for Environmental Health and Agency for Toxic Substances and Disease Registry.  He was quite surprised.  It was as though the idea that natural gas development brought public health benefits never occurred to him.

His response was not unique. In fact, the entire conference seemed dominated by a frantic rush to identify negative outcomes. This left the attendees missing some very real, and shared, benefits occurring in communities where natural gas development is taking place.

Most Informing Presentations Seemingly Lost Among Clutter of “Health Effects” Speculation

A large part of the conference involved questions that seemingly had no answers, unless you know where to look.  From this perspective, the most informative presentation was provided by Michael Honeycutt, Ph. D, Director of the Toxicology Department of the Texas Commission on Environmental Quality. Dr. Honeycutt was the only panelist with direct regulatory experience and he presented data his department has collected on natural gas development over the past two decades.

His presentation reviewed data from the most extensive natural gas emissions monitoring program in the nation, including data from over 1,126 fixed and mobile monitoring stations and over 2,100 site surveys using emissions finding infrared technology.

These findings showed that as natural gas extraction increased exponentially, harmful air emissions like benzene and other volatile organic compounds decreased. Further, the data showed the area hadn’t seen an increase of pollutants, or public exposure to pollutants at levels that would cause public health concerns, due to natural gas development in nearly twenty years of production from shale resources.

Another informative presentation was provided by Dr. Charles Groat from the University of Texas-Austin. As background, Dr. Groat served as the 13^th Director of the U.S. Geological Survey and currently serves as the Director of the Energy and Earth Resources Program at the University of Texas-Austin.

Dr. Groat presented findings from his study which reviewed historical data to determine if hydraulic fracturing has impacted groundwater resources.  The study found, “no direct evidence that hydraulic fracturing itself — the practice of fracturing the rocks — had contaminated shallow groundwater.”

In making this determination, the study examined, among other items, the degree to which any documented environmental violations actually impacted human health. In the review, 58% of violations were procedural in nature and had little or no impact on the environment. The most prevalent violations were generally preventable and the study found no evidence of a contamination pathway for the transport of chemicals that would cause public health concerns.

The Difference Between Relying on Experience and Assumptions 

One of the more glaring discrepancies of the conference was the pairing of Dr. Honeycutt’s presentation with that of Dr. John Adgate, Chair of the Department of Environmental and Occupational Health at the Colorado School of Public Health (CSPH).  Dr. Adgate presented findings from a controversial public health impact assessment based on assumptions, and limited observational data, rather than comprehensive data and experience.

The pairing of Dr. Adgate and Dr. Honeycutt seemed to serve, likely inadvertently, as a summary of the “public health impacts” discussion to date.  Studies based on experience show no areas of concern while those focusing on assumptions, and limited data sets, elicit speculation of significant public health impacts.

In this case, the CSPH study found that residents living near natural gas operations were at a greater risk of exposure to harmful air pollutants including benzene, and thus had greater exposure to cancer causing contaminants.

One of the problems with this finding, and the overall assessment, is that it’s based on a study using a limited number of air monitors, all of which were located within a mile of a major interstate.  From the study:

 CSPH: “The GCPH collected 16 ambient air samples at each cardinal direction along 4well pad perimeters (130 to 500 feet from the well pad center) in rural Garfield County during well completion activities… All five well pads are located in areas with active gas production, approximately one mile from Interstate-70.” (p. 9-10, emphasis added)

The location of the study’s limited sampling data sacrifices the study’s findings. Especially, considering EPA, in its Final Rule to Reduce Mobile Source Air Toxics, notes that “most of the nation’s benzene emissions come from mobile sources. People who live or work near major roads, or spend a large amount of time in vehicles, are likely to have higher exposures and higher risks (emphasis added). Meanwhile, the study’s control samples were three miles removed from that same interstate.

At the same time, the study made unrealistic assumptions on exposure times to the flawed data sets that only exacerbated errors in the study’s conclusions.

Oil and Gas Workers Viewed as “Sentinels” and Key Focus of Discussion

Much attention was rightly paid to the plight of workers in the nation’s oil and natural gas fields.  Here too, it seemed alarmism drove the conversation rather than data born from experience and fact.  One federal official asserted “that oil and gas drilling in general is one of the most hazardous occupations in the United States. The fatality rate in that industry is multiples of the private sector, upwards of seven times higher.”

That official failed to cite the data they were referencing.  This is especially relevant considering data collected by the Bureau of Labor Statistics (BLS) shows the oil and natural gas industry is quite safe. According to the BLS data the oil and natural gas industry is:

• not in the top 25 of industries with the highest rates of injuries and illnesses,
• has an injury rate three times below the national rate, and
• doesn’t even make a national list of industries whose employees require significant days off from work due to injury, illness and other factors.

The key focus of worker safety however was a presentation by Eric Esswein, senior industrial hygienist at the National Institute for Occupational Safety and Health (NIOSH) at the Centers for Disease Control and Prevention.  Esswein highlighted his study which examined exposure of workers on hydraulic fracturing sites to silica pollution.  The study, which was widely acclaimed as the largest breakthrough of the proceedings, found workers in multiple states exposed to significant levels of silica above federal standards.

In fact, the findings led one participant to proclaim “I saw a picture from NIOSH that made me think of the Gauley Bridge and the tragedy that happened in our country when we were fiddling around with silica.” The participant was referring to a 1935 incident where hundreds of workers died within months of silica exposure.

Hydraulic fracturing has been widely used since the 1990’s without one known death occurring due to silica exposure.  This, however, didn’t keep the media from raising alarms (sub’s reqd.) centering on the finding. The good news, which was not reported, is that technology currently exists to immediately halt this exposure. Specifically through the use of bagger systems which collect errant silica dust before it is able to enter the environment and impact humans.

But more troubling is the idea that, as the CSPH study declared, those living in close proximity to natural gas operations are at a higher risk of developing cancer than the general public.

The CSPH study provides these individuals with a higher rate of developing cancer than workers who are at a natural gas well sites often in excess of over 60 hours a week.  This is noticeable in a previous report from the Australian Institute of Petroleum which reviewed 18 years worth of health data and found the cancer rates of oil and gas workers to be no different from the general population.

From the report:

“The age-adjusted death rate in men [in the oil and gas industry] is significantly less than in the general Australian male population. Death rates in all major disease categories – heart disease, cancer, respiratory disease, diseases of the digestive system, and external causes (accidents, violence etc) – are also significantly less than the corresponding rates for the male population.”

“The chance of getting most types of cancer is the same for men in this industry as for all Australians.”

While the report did find elevated cases of mesothelioma, melanoma and prostate cancer among the sample of workers these were attributable to other causes. In regards to mesothelioma, the study found significant numbers of participants had prior exposure to asbestos in previous employment.  For melanoma and prostatic cancer the study found, “the rate did not increase with increasing duration of employment or with increasing exposure to hydrocarbons. On this basis and from what is known of the causation of these two cancers, it is therefore unlikely that either is caused by a factor in the workplace in this industry.”

What We Learned- Unbiased Health Professionals Seemingly in Short Supply

Overall, the conference showed there is a good amount of speculation occurring at all levels in regards to the “public health impacts” of natural gas development.  What was clear is that decades of experience, data and studies are currently being ignored as a borderline hysterical conversation takes place. Those involved in the discussion are seemingly approaching it at a frantic pace with little forethought into what data already exists to provide clarity to the frightening claims made by a few.

We were alarmed by what we saw and think it’s critical to approach this conversation in a rational manner based on sound science and hard data.  This simply can’t be accomplished when groups accept key assumptions as fact when data and experience show a much different reality.

For this reason, and others, we are working to form a nation-wide network of health care professionals who will seek to contribute to this discussion based on the wealth of data and experience that exists.  We will highlight the positive benefits of this development, and take a hard look at any potential negative health consequences, but will do so using existing data and sound science while avoiding the politicization of poor study assumptions that lead to good sound bites and bad science.