Appalachian Basin

Ohio “Ban Fracking” Activists Pen Fact Free Letter to EPA

Recently, representatives from 23 known anti-fracking groups including Frackfree Mahoning Valley and the Frackfree America National Coalition, wrote a letter to the U.S. EPA Office of Environmental Justice.  The groups claim to have found illegal activities, but as would be expected, their argument falls apart under closer scrutiny.

More specifically, the coalition, led by author Teresa Mills, of the Center for Health, Environment and Justice, claimed “clear environmental justice abuses cognizable under Executive Order 12898.”  The group is alleging that Ohio’s Class II Underground Injection Control (UIC) program for injection wells calls into question Executive Order 12898, a 1994 order signed by President Clinton, which aims to address federal actions pursuant to environmental justice in minority populations and low-income populations.

While the authors make a number of erroneous claims, we’ll focus on the top three, followed by the facts.

Claim #1: “The Profoundly Weak Federal Requirements for Class II Injection Well Delegation under Section 1425 of the Safe Drinking Water Act.”

Fact: As EID has reported time and time again, the allegations that the Class II UIC program in Ohio is neither safe nor regulated is simply not factual. Ohio has some of the most stringent regulations in the country. Ohio has been regulating the process since 1983, when EPA gave the state primacy over its program. According to ODNR:

“Managed by ODNR since 1983, the state’s Underground Injection Control (UIC) Program has successfully injected large volumes of oilfield wastes, protecting underground sources of drinking water and our ecosystem. Fees raised by injection wells support permitting, certification, and inspection of wells and service operation.”

In 2012, ODNR updated its Class II injection well regulations, which go above and beyond what EPA regulations require. The updates include testing requirements and reporting standards. Also from ODNR (emphasis added):

“Class II injection wells require at least four layers of protective steel casing and cement, which safeguards underground water aquifers. The injection zone is always below a layer of impermeable formation, which keeps the fluids trapped deep in the porous formations below.

All aspects of the drilling and construction of Class II injection wells and surface casing are witnessed by an inspector. After deep injection begins, inspectors continue to monitor the well on a regular basis for mechanical integrity. Each well is inspected about once every 10-11 weeks.”

Watch the following short video from ODNR to learn more about their stringent regulations.

Claim #2: “Disproportionate Impacts on Ohio’s Low-Income Appalachian Communities”

Fact: The letter claims that most Class II injection wells in areas of historical geographic isolation and economic depression, alleging that these counties are being “dumped on”:

“The federal Appalachian Regional Commission has officially recognized thirty-two Ohio counties as being part of Appalachia due to their history of geographical isolation and economic depression. These thirty-two counties comprise 36% of Ohio’s eighty-eight counties…Of these 199 active wells, 149—or 74.9% of the total—are located in Ohio’s thirty-two Appalachian counties.”

While it’s true that there more injection wells in Appalachian counties, this is simply due to the fact that these counties also happen to be the most prolific natural gas developing areas in the state.

The authors do not account for the number of conventional and unconventional wells drilled in the same region, where 441 horizontal wells have been completed-or 89.6% of the total-are located in Appalachian counties. Take a look at the map, quantified from ODNR:

Jackie wells

In fact, those 441 horizontal wells are bringing enormous economic benefits to the Appalachian counties, which bring us to our next point.

Claim #3: “Nearby communities experience the brunt of these risks while receiving no economic benefit.”

Fact:  It is simply absurd to suggest there is “no economic benefit” in the counties that have experienced the lion’s share of the $28 billion in investment from the oil and gas industry, have had millions of dollars flood their county coffers in tax benefits, and realized a 66 percent decline in unemployment.

Realistically, the oil and gas activities taking place in these communities have helped create jobs, generate tax revenues, and resulted in greater wealth overall in Appalachia.

Carroll County, for example, which is home to a multitude of injection wells in addition to natural gas production, has seen tremendous tax revenues generated from the oil and gas industry. That amount totaled $3.8 million in revenue in 2014 alone. Leroy VanHorne, former Carroll County Auditor said,

“Five years ago this county was struggling financially we had to reconvene our elected officials to make sure we had enough money to pay our bills and so we wouldn’t finish the year in the red,  cuts to the Local Government Fund and other cuts from the state, left us with practically nothing. Now, with the gas play, we have sufficient funds to support all necessary government services once again.” (emphasis added)

Or what about the impacts to the Carrolton Exempted Village Schools?  Thanks to new revenue generated by the oil and gas boom and grants from the state, a new training center has been built and plans are underway for a new K-12 building.  Local and school officials attribute the growth to oil and gas development.

Carroll County Commissioner Robert Wirkner said the county is a place of hope and opportunity. “We truly are turning the point of moving forward for prosperity for all,” Wirkner said.

Columbiana County, also located in Appalachia, had tax revenues jump 40 percent from 2010 to 2014, going from $11.7 million to $16.3 million. Mike Halleck, Columbiana County Commissioner and President of the Ohio County Commissioners Association said:

“Our sales tax has exponentially increased as a result of the oil and gas development in Columbiana County over the last 4 years. Since 2009, our sales tax revenues have increased by 40%. Columbiana County has continued to see increases in sales tax revenues year-to-year, and 2014 continued that trend, as revenues reached over $16 million. These numbers are a sign of real economic impact to our region.”


Anti-fracking activists clearly don’t have the facts or the science on their side, so in their attempt to stop development in areas that need the most help, they are throwing spaghetti to the wall to see if anything sticks.   But the reality of the situation is perhaps best summed up by the Wall Street Journal, which wrote that “the natural gas boom may be America’s best antipoverty program.”


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