Earthworks’ Flawed Eagle Ford Study Is More of the Same
UPDATE (9/23/2013; 3:04pm CT): The Texas Commission on Environmental Quality responded to Earthworks’ report, saying the agency has collected “several millions of data points for volatile organic compounds” in the Barnett Shale and Eagle Ford Shale. “Overall, the monitoring data provide evidence that shale play activity does not significantly impact air quality or pose a threat to human health,” the agency said in a statement. “The TCEQ has a vigorous, effective enforcement operation in the Eagle Ford Shale, and when problems are detected, the TCEQ makes sure they are rapidly fixed.”
Gee, who to believe: a state agency with a legitimate interest in scientific quality, or an organization devoted to stopping shale development by any means necessary?
–Original Post 9/20/13–
Earthworks, an organization that has enthusiastically endorsed numerous anti-fracking campaigns across the country, has just released an ominously titled report, “Reckless Endangerment While Fracking the Eagle Ford,” written by avid anti-fracking activists Sharon Wilson and Wilma Subra. No one should be surprised about what this “report” concluded, because the conclusions themselves were made before the “research” ever began.
To be clear: this is not a scientific report, at least not in the broadly accepted definition of the word scientific. The glossy document is more of the same from Earthworks and its ally ShaleTest, which has been criticized before for conducting scientifically dubious assessments of shale development in other parts of the state. Some folks never learn, it seems.
Let’s have a look at some of Earthworks’ most egregious claims.
Earthworks: “While none of the chemical concentrations exceeded TCEQ’s short-term Air Monitoring Comparison Values (AMCV), benzene at the Kotara Ridley site was 20 times the acceptable long-term AMCV limit set by TCEQ” (p. 22).
FACT: This is classic Earthworks. The team took its own samples over a short period of time and compared the values to the long-term allowable threshold set by regulators – essentially comparing apples to oranges.
This is exactly the same faulty testing method that ShaleTest used in a study of the Barnett Shale in North Texas last January (a study, by the way, done alongside Gasland star Calvin Tillman). ShaleTest’s report claimed to have discovered alarming levels of benzene emissions in a blatant effort to cause a health scare for local communities. Sound familiar?
When the Texas Commission on Environmental Quality (TCEQ) came in to investigate the allegations, they found that the sites did not present the health risks alleged by ShaleTest, and that they were operating within the emissions levels allowed by their permits. A TCEQ spokesman went on to criticize the methodology employed by Shale Test, stating “it is not scientifically appropriate” to compare short-term test results against long-term thresholds. He also pointed out that TCEQ has a network of monitors in the area that constantly test for dozens of chemicals.
Oddly enough, Earthworks admits that it is using ShaleTest’s same flawed method and that it was denounced by TCEQ. From the report:
“Recently when ShaleTest measured benzene levels in the Barnett Shale that exceeded TCEQ long-term AMCV’s, TCEQ stated that it is not appropriate to compare short-term tests against long-term thresholds.”
Exactly. We agree with Earthworks that its conclusions here are scientifically flawed.
Earthworks: Oil and gas facilities “are allowed to release hundreds of tons of air pollutants on an annual basis, including VOCs, hazardous air pollutants, NOx, particulate matter, carbon monoxide, sulfur dioxide and hydrogen sulfide” (p. 26)
FACT: The overwhelming consensus is that there is no credible threat to air quality or public health associated with shale development. The Colorado Department of Public Health and Environment (CDPHE), the Texas Commission on Environmental Quality, and, most recently, the West Virginia Department of Environmental Protection have all come to that conclusion. Reports from the Pennsylvania Department of Environmental Protection have also affirmed that emissions related to shale development are below established health thresholds.
In fact, thanks to the development and utilization of natural gas, emissions of all kinds have been eliminated from the air, which has been an unequivocal boost to public health. It’s not for nothing that the American Lung Association gave eight North Dakota counties — including several that are leading the state in Bakken oil production — high marks for air quality.
It’s also worth stressing: This is textbook Earthworks. The organization throws around inflammatory terms like “benzene” and “carbon monoxide,” but provides no meaningful context on the actual risk. Regulators and health experts have worked for decades to establish allowable thresholds, above which emissions of certain compounds pose health risks. Those thresholds exist because many compounds appear naturally, and background doses are not associated with health impacts. Earthworks would have us believe that the mere presence of any compound that sounds dangerous is a reason to be scared. But inflating fears based purely on inflammatory language is not science, nor is it particularly helpful in understanding risk.
Earthworks: “In 2010, the Colorado School of Public Health published a study indicating higher risks for cancer and other health problems from poor air quality near gas wells that were hydraulically fractured” (p. 7).
FACT: EID has a thorough debunk of that study here, but just to emphasize a few key points: The cancer risks identified in that study are actually in line with or well below the risk for the entire U.S. population. The study used out of date emissions data and inflated exposure times by as much as 900 percent. It also failed to account for additional exposure pathways for compounds such as benzene, including a nearby interstate highway, which the U.S. EPA identifies as the largest source of benzene exposure.
Further, the state Department of Public Health installed air quality monitors near a well site that had come under intense scrutiny by activists to answer questions about health impacts. The state concluded:
“No significant concentrations were recorded that could be directly attributed to well completion operations at this well pad.”
The CDPHE monitors also checked the background levels of benzene, which activists claimed were astronomically high and discovered:
“The monitored concentrations of benzene, one of the major risks driving chemicals, are well within acceptable limits to protect public health, as determined by the U.S. Environmental Protection Agency.”
Earthworks: “Early results from a long-term study in Pennsylvania suggest that air pollution from Marcellus Shale gas operations in the state may be contributing to a host of symptoms including breathing problems, headaches, dizziness and eye irritation” (p. 6)
FACT: Who conducted that study? That’s right, Earthworks. It would have been easier (and more honest) if Earthworks would have just said, “We’ve made similar criticisms elsewhere in the country.”
So, what’s really going on with air quality around the Marcellus Shale in Pennsylvania?
An Oakland-based environmental think tank, The Breakthrough Institute, found that Marcellus Shale development and increased natural gas use “have dramatically reduced emissions across Pennsylvania,” while the Pennsylvania Department of Environmental Protection found that over 500 million tons of emissions have been removed from the Commonwealth’s air because of the increased use of natural gas.
Earthworks: “Government bears no small share of the blame for these releases because – without exception – rules governing oil and gas development are inadequate to protect the public” (p. 4).
FACT: This quote gets high points for drama (without exception!) and low points for accuracy. But alleging that oil and gas producers are allowed to run amok free of meaningful oversight is simply false.
In the past, whenever such wild claims have been made by activists in Texas, the Railroad Commission and TCEQ have taken them seriously and investigated them thoroughly by employing real scientific methodologies they are required to employ under Texas and federal law. With few if any exceptions, they have always concluded that the claims were false. In reality, oil and gas producers are highly regulated at the federal, state, and often local level – often at all of these levels simultaneously.
A more in depth look at the federal laws that apply to shale development can be found here. What anti-fracking groups like Earthworks are really saying when they say the existing labyrinth of rules are “inadequate” is that the existing rules actually allow for safe development. Since they oppose development, it doesn’t matter how many new restrictions are placed on American energy. They will spout nonsense about “inadequate regulation” until they’re blue in the face or oil and gas development is banned.
Not about Public Health
Even after all of its “research,” Earthworks can only conclude that hydraulic fracturing “likely” or “could” impact health in south Texas. They clearly have no scientific evidence to back up these claims, so they’ve resorted to speculative conclusions that were, again, determined before the research ever began.
The facts show that shale development is protective of public health, and in many cases it’s contributing to cleaner air and a healthier population. Not for nothing, the Eagle Ford Shale is projected to produce more than one million barrels of oil per day next year, outpacing OPEC member Oman’s production, and it supports 116,000 jobs. The overall economic impact of the Eagle Ford is estimated to be over $60 billion.
These important details aren’t highlighted in the Earthworks report, no doubt because they didn’t fit the organization’s preconceived narrative.