Appalachian Basin

Cincinnati City Council Lacks Education On Ohio’s UIC Program

Last week the Cincinnati City Council passed a resolution supporting a statewide ban on injection wells, which unfortunately isn’t the first time they have taken aim at disposal wells.  Just last year they passed a resolution to ban injection wells in the city, which is funny because there is not a single producing well in Hamilton County, so why would there ever be a need for a disposal well? But, for some reason, the all-knowing City Council of Cincinnati feels the need to tell eastern Ohioans how they need to live their lives.  On behalf of eastern Ohio, thank you for your concern, but I think you should concentrate on your own problems.

Unfortunately, what we have here is a City Council who is legislating on fear of the unknown, instead of from a basis of fact and real-world data.  For those of us in eastern Ohio, Class II injection wells are nothing new.  In fact, they have been used here in Ohio since the 1960s.  Regrettably, the City Council is getting its information from Food & Water Watch, well-known for being an anti oil and gas development organization.

Usually, when making a decision that could potentially affect the whole state, most organizations would like to hear from both sides before making a decision.  In this case, a one-sided deluge of misinformation and outright lies is enough for the Cincinnati City Council. However, if the city council would like to learn a bit about Class II injection, this post is for them.

In 1983, the Ohio Department of Natural Resources (ODNR) received primacy from the US EPA to permit, regulate, and enforce Ohio’s Class II underground injection control (UIC) program.  In order to gain primacy, ODNR had to demonstrate its rules met or exceeded the federal UIC program. Since that time, Ohio has injected 202 million barrels of brine without one case of groundwater contamination, no doubt a fact that Food & Water Watch left out when lobbying the city council to pass this resolution. Why include facts when falsehoods are much more frightening?

Primacy is also not unique to Ohio.  In fact, more than 40 states also have primacy over their UIC programs. In order for Ohio to maintain primacy, it must continue to demonstrate an ability to effectively manage and regulate the program to the EPA, while also being audited by the US EPA on a regular basis.

In addition to being audited (thankfully not by the IRS, especially nowadays), Ohio takes the lead in promulgating rules and regulations to make sure Ohio has one of the most stringent UIC programs in the nation.  The UIC program rules and regulations have been updated twice in the past three years, thanks in no small part to on the ground enforcement of the program. This has allowed Ohio to actually go above and beyond what the federal government requires for UIC.

This was made clear in testimony provided to the Ohio legislature as it was considering regulatory revisions this spring. The below chart shows just a few of these examples:

Comparison of Ohio’s Class II Brine Injection Regulations with USEPA Regulations

Ohio Division of Oil & Gas Resources Management

United States Environmental Protection Agency

Unannounced inspections on an average of every 11-12 weeks.

One inspection done per well each year by EPA consultant.

Continuous mechanical integrity monitoring or monthly mini-tests to demonstrate continuous mechanical integrity.

Demonstration of mechanical integrity at least once every five years.

Injection volumes greater than 200 barrels per day require a ½-mile area of review of all other wells. Less than 200 barrels per day is a ¼-mile radius.

All Class II wells shall be cased and cemented to prevent movement of fluids into or between underground sources of drinking water.

ODNR has the authority to require seismic testing and monitoring.

Federal code does not specifically address seismic testing and monitoring.

Again, these are details that Food & Water Watch probably left out when discussing Ohio’s UIC program with Cincinnati City Council. 

Vice Mayor Roxanne Qualls, who introduced the resolution, should have probably done a little more research before passing such an uneducated resolution.  Maybe next time she would see there are no short term windfalls with oil and gas development, but only providing resources that create jobs and help her city prosper.

If there were no oil and gas development, companies like Procter and Gamble, Ashland, LyondellBasell, Rohm and Haas and even Duke Energy would lack the feedstock that help make these companies employ Cincinnati workers.  I am sure she didn’t think about these companies when she decided oil and gas development has no place in her city, though most folks who claim to oppose oil and gas development don’t think about what our economy actually requires to operate. Or simply don’t think, period.

Oil and gas development is responsible for over 6,000 products we use in our everyday lives.  If Vice Mayor Qualls would like to stand behind her resolution, then she should also ban any products that use oil and gas in the City of Cincinnati.  So I guess the question is, would the City Council be willing to give up any of these products?  I think not.


In the end, Cincinnati should stick with legislating issues that affect them and not trying to tell eastern Ohioans how to live their lives.  I know they would not like it if we started passing resolutions banning Skyline Chili, and frankly, that would be silly anyway — not unlike trying to ban energy development.

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