A new report published this month by University of Texas at Austin researcher Rachael Rawlins suggests a link between Barnett Shale development and air pollutants that cause cancer – and state and federal regulations, she argues, are not protective of public health.

Several news outlets have grasped onto one particular aspect of her argument having to do with the city of Flower Mound, Texas.  In 2010, due to concerns about the health impacts of oil and gas development in the area, the Texas Department of State Health Services (DSHS) conducted a study of Flower Mound and found no evidence of a “cancer cluster” in the area.  As the state health department’s epidemiologist explained, “We found nothing in the data to indicate the community is at higher risk for these types of cancers.”

But in her new report, Rawlins – who is a lecturer in the UT School of Architecture – argues that the DSHS is wrong, and that there is 95 percent likelihood that incidents of leukemia and non-Hodgkin’s lymphoma among children in Flower Mound between 1997 and 2009 were linked – somehow, some way – to shale development (which, according to the release accompanying the report, has been categorized simply as “hydraulic fracturing”).

However, in order to make her arguments, Rawlins relies heavily on the research of some of the most outspoken anti-fracking activists in Texas and across the country, to the point that the report almost reads like a literature review of activists’ thoroughly debunked studies.  Let’s have a look at five of the most glaring flaws in the report:

Flaw #1: Uses Earthworks activists as credible sources

Two years ago, as Rawlins was beginning her research, she was actively participating in conversations on anti-fracking activist Sharon Wilson’s blog (Wilson is an organizer for the anti-shale organization Earthworks). In the comments section of Wilson’s October 22, 2011 blog post (which tried to link “fracking” to cancer – notice a trend?), Rawlins asks another commenter where would be a good place to start her research.  From the blog:

Rachael Rawlins June 15, 2012 at 9:32 pm

Christina,

I teach in the graduate planning program at UT Austin and I’m doing some research related to fracking on the Barnett Shale. The state’s health study notes that there was considerable growth in Flower Mound during the time period that reflects the breast cancer cluster (suggesting that perhaps the problem was not home grown). As a breast cancer survivor myself, it occured [sic] to me that it might be possible (and perhaps not that difficult) to locate and ask those breast cancer survivors (or relatives) if they have lived long in Flower Mound? Perhaps you have a “breast cancer community” loosly [sic] linked through support groups, or word of mouth?

If Rawlins was interested in developing a scientific report, why did she think a good place to start would be an anti-fracking activist’s blog? (Wilson also bragged yesterday about how she and Alisa Rich — who was behind the ‘strategy‘ to involve EPA in Parker County — “met with Rawlins quite a while back” and “pointed her” to their favorite studies.)

But that’s just the beginning. In her report, Rawlins actually cites that same blog post, as well as Sharon Wilson’s testimony before the Dallas Drilling Task Force, as resources for her claim that “Barnett Shale residents identified an increase in the total numbers of chemicals detected at one site from 7 to 65 before and after drilling through their own air quality testing” (p. 249-250).

Rawlins also quotes activist Wilma Subra, who is regularly aligned with Earthworks’ shoddy research on shale:

“Although a causal relationship has not been established, William [sic] Subra, a chemist working for Earthworks, conducted a health effects survey of 31 residents in Dish, Texas, and found a correlation between  claimed health effects and the known health effects of chemicals associated with shale gas industry operations. Summarizing the results, she noted that doctors are observing not only respiratory ailments and headaches, but also brain disorders, pre-cancerous lesions, and impairment of motor skills” (p. 230).

If Subra and Wilson sound familiar on the shale/health nexus, it’s because their reputation for dubious research precedes them. Both Wilson and Subra were involved in ShaleTest’s study of the Barnett Shale last year, which claimed to have discovered alarming levels of benzene (which, naturally, the activists used to link “fracking” and cancer). ShaleTest, you might remember, boasts Gasland filmmaker Josh Fox as one of its “advisers.”

But 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 the facilities were operating within the emissions levels allowed by their permits. They also found that ShaleTest was comparing short-term test results against long-term thresholds, which as TCEQ spokesman explained “is not scientifically appropriate.”

Wilson and Subra, however, didn’t learn their lesson: they released another report through Earthworks last year using exactly the same faulty method, this time in the Eagle Ford Shale region of south Texas.  Again, the TCEQ responded that the agency had “several millions of data points for volatile organic compounds,” which once again disproved Earthworks’ claims. “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.”

Yet, for some reason, Ms. Rawlins believes that such clearly flawed and alarmist research has a place in a presumably scientific report.

Flaw #2: Hinges on a “reanalysis” by a Montana professor that is not publicly available

Rawlins’ contention that there is a 95 percent chance that incidents of cancer in Flower Mound are linked to shale development relies on a single “reanalysis” conducted by Dr. Maria Morandi of the University of Montana.  As the Dallas Morning News reports,

“The reanalysis of the Flower Mound data was conducted by Dr. Maria Morandi, a former research professor from the Center for Environmental Health Services at the University of Montana, said Rawlins, who has a law degree and is not a scientist or statistician.

“‘The reanalysis found, with 95 percent certainty, that rates of childhood leukemia and childhood non-Hodgkins lymphoma in Flower Mound are significantly higher than expected,’ she said. ‘There is only a 1 in 20 chance that the difference is random.’”

Eager to read this “reanalysis,” we thumbed through the footnotes of the report, only to find that it exists solely in numerous emails between Rawlins and Morandi that are “on file with author” and therefore not publicly available. So I guess we’ll just take them at their word, right? Right.

Meanwhile, what have publicly available studies found?

• A study on emissions in the Barnett Shale by the Houston based ToxStrategies concluded, using data from the Texas Commission on Environmental Quality (TCEQ), that there is no credible health risk associated with shale development. As it states: “The analyses demonstrate that, for the extensive number of VOCs measured, shale gas production activities have not resulted in community-wide exposures to those VOCs at levels that would pose a health concern.”

• The Texas Commission on Environmental Quality conducted months of testing in the Barnett Shale area, and its samples showed “no levels of concern for any chemicals.” TCEQ added that “there are no immediate health concerns from air quality in the area.”

• A study by the West Virginia Department of Environmental Protection (DEP) found no major health threat from shale development, concluding, “Based on a review of completed air studies to date, including the results from the well pad development monitoring conducted in West Virginia’s Brooke, Marion, and Wetzel Counties, no additional legislative rules establishing special requirements need to be promulgated at this time.”

• The Colorado Department of Public Health installed air quality monitors at a well site that activists complained about and concluded in its study of the data: “The monitored concentrations of benzene, one of the major risk driving chemicals, are well within acceptable limits to protect public health, as determined by the U.S. Environmental Protection Agency. The concentrations of various compounds are comparatively low and are not likely to raise significant health issues of concern.”

• A draft report by Public Health England (PHE), an executive agency of the UK’s Department of Health, concluded: “The currently available evidence indicates that the potential risks to public health from exposure to the emissions associated with shale gas extraction are low if the operations are properly run and regulated.”

• The Pennsylvania Department of Environmental Protection (DEP) conducted air monitoring northeast Pennsylvania and concluded that the state “did not identify concentrations of any compound that would likely trigger air-related health issues associated with Marcellus Shale drilling activities.” A similar report for southwestern Pennsylvania came to the same conclusion.

• A peer-reviewed study looking at cancer incidence rates in several Pennsylvania counties found “no evidence that childhood leukemia was elevated in any county after [hydraulic fracturing] commenced.”

Also of note: while Rawlins relies almost entirely on the opinion of a researcher in Montana, the city of Flower Mound didn’t even know that she was conducting a study. As the Dallas Morning News reported, Town Manager Jimmy Stathatos said:

“Unfortunately, the town was not made aware of the new findings until a news article was released.  Therefore, we are working to understand the re-analysis of the data as quickly as possible. We have also reached out to the researcher so we can better understand their findings and recommendations.” (emphasis added)

Which leads us to the question: why would Rawlins push this study out to the media before making the city of Flower Mound – the subject area of her research – aware of the findings? Sounds like another flawed study we saw in Colorado – which also dubiously linked cancer to shale development.

Flaw #3: Al “crucify them” Armendariz is key source for ozone claim

Rawlins writes,

“Nine counties around the cities of Dallas and Fort Worth, four of which have substantial oil and gas production, are failing to meet the National Ambient Air Quality Standards for ozone and have been designated as ozone nonattainment areas by the EPA”  (p. 231).

The source for this claim is a report released in 2009 by Al Armendariz, who later became Region 6 Administrator for the U.S. Environmental Protection Agency.  In the report, Armendariz alleges that emissions of ozone precursors from oil and gas operations in the Barnett Shale were more than twice those emanating from mobile sources (i.e. cars and trucks).  The problem with Armendariz’s study is that it relied on a modeling exercise that extrapolated an outlier of data into a broader trend.  Subsequent data from the TCEQ’s state-of-the-art air quality monitors show this is not the case: they show that emissions from mobile sources are a larger contributor to smog and that oil and gas operations have a minimal-at-worst impact.  And as the Barnett Shale Energy Education Council explained,

“If [Armendariz’s] study’s conclusions were correct, then the Dallas-Fort Worth region would have seen a dramatic rise in ozone levels over the past several years during the time that the number of gas wells has grown … [This chart], using ozone data from the North Central Texas Council of Governments, shows that the opposite is true.”

Indeed, TCEQ data show that between 1999 and 2009, when gas production in the Barnett Shale region increased more than 40-fold, eight-hour ozone values actually declined by about 15 percent. A memo from TCEQ on this same subject noted that mobile source NOx emissions in the region “are approximately 15 times higher” than what’s generated by oil and gas development.

Of course, when Armendariz joined EPA, anti-fracking activists cheered.  But that’s not surprising, considering that Armendariz would later make himself famous by proclaiming that EPA’s “general philosophy” was to “crucify” oil and gas producers.  As he put it,

“But as I said, oil and gas is an enforcement priority, it’s one of seven, so we are going to spend a fair amount of time looking at oil and gas production. And I gave, I was in a meeting once and I gave an analogy to my staff about my philosophy of enforcement, and I think it was probably a little crude and maybe not appropriate for the meeting but I’ll go ahead and tell you what I said. It was kind of like how the Romans used to conquer little villages in the Mediterranean. They’d go into a little Turkish town somewhere, they’d find the first five guys they saw and they would crucify them. And then you know that town was really easy to manage for the next few years. And so you make examples out of people who are in this case not compliant with the law. Find people who are not compliant with the law, and you hit them as hard as you can and you make examples out of them, and there is a deterrent effect there. […] So, that’s our general philosophy.”

Flaw #4: Relies on the testimony of Gasland star Calvin Tillman

Rawlins writes,

“Calvin Tillman, the former Mayor of the small town of Dish, decided to move his family after his two boys began experiencing nosebleeds that coincided with the presence of strong gas odors. One of Tillman’s sons was diagnosed with asthma and it was reported that the air quality conditions exacerbated his symptoms” (p. 230).

Tillman, who is perhaps most famous for his appearance in Gasland and his ongoing work with filmmaker Josh Fox, was also involved in the studies conducted by ShaleTest (along with Sharon Wilson and Wilma Subra), which we explained above.

The Texas Commission on Environmental Quality (TCEQ) looked specifically into Tillman’s claims on benzene in the town of Dish. The agency found that the “highest potential 1-hour maximum benzene concentration is below the health effects level.”  In addition to the TCEQ’s findings, the Texas Department of State Health Services (DSHS) later collected blood and urine samples from residents in and around the town to assess whether Tillman’s claims were accurate. DSHS concluded:

“Although a number of VOCs [volatile organic compounds] were detected in some of the blood samples, the pattern of VOC values was not consistent with a community-wide exposure to airborne contaminants, such as those that might be associated with natural gas drilling operations.”

Flaw #5: Leverages opinions of anti-fracking activist Theo Colburn

Rawlins writes,

“Emissions include VOCs released during drilling and hydraulic fracking (where fluids including toxic chemicals are injected under high pressure to fracture and release gas from the underlying formation), combustion byproducts from mobile and stationary equipment, VOC’s released from chemicals used to maintain the well pad and equipment, and numerous non-methane hydrocarbons that surface with the raw natural gas” (p. 229).

Her source is a study done by Theo Colborn. EID has the full debunk here, but we’d like to point out that while the authors billed that research far and wide as proof natural gas production was responsible for air quality concerns, in that same study Colborn et al. admitted: “The chemicals reported in this exploratory study cannot, however, be causally connected to natural gas operations.” Further, many of the measurements that they made showed emissions levels that were not above public health thresholds.

Perhaps even more telling is that Colborn’s organization, the Endocrine Disruption Exchange, actually likens oil and gas development itself to cancer, explaining,

“[T]he gas industry is steamrolling over vast land segments in the West.  From the air it appears as a spreading, cancer-like network of dirt roads over vast acreage, contributing to desertification.”

Ms. Colborn has also been adamant that anti-fracking activists need to be working the press to get the most destructive narrative about hydraulic fracturing into the headlines. Speaking at an anti-industry event recently, Colborn stated:

“Somehow, some way, we need to get drilling and all the other sources of the pollution into the headlines, along with fracking. We’ve got to work on the media on this.”

In other words, Colborn’s goal is clearly to ensure that cancer is associated with development – from the metaphors on her organization’s website to her explicit call to emphasize alarmism with reporters.

Unfortunately, generating headlines designed to scare people into opposing fracking – without the scientific evidence to back it up – seems also to be the goal that this latest report is trying to achieve.

Finally, it’s worth reminding everyone that the Associated Press recently looked into the “cancer” claim as it relates to shale development in north Texas. A professor at the University of Texas Southwestern Medical Center in Dallas, an epidemiologist at the Texas Cancer Registry, and even the vice president at Susan G. Komen for the Cure all disputed the claim that cancer rates had spiked due to shale development.