Why Are EPA’s Science Advisors Asking the Agency to Prove a Negative?

The Independent Petroleum Association of America (IPAA) has just sent a letter to the Environmental Protection Agency (EPA), which points out that while the Science Advisory Board (SAB) does not ask EPA to change or eliminate its topline finding of “no widespread, systemic impacts” to drinking water resources in its final recommendations, it does ask EPA to do something that borders on the absurd: it asks EPA to prove a negative.  As IPAA Executive Vice President Lee Fuller notes in the letter:

The SAB has now released its final recommendations on EPA’s landmark groundwater study.  Despite producing four drafts coming in at almost 200 pages each, not once has the SAB ever pointed to any evidence that contradicts EPA’s finding that hydraulic fracturing has “not led to widespread, systemic impacts” on drinking water sources. Therefore, the SAB ultimately was not able to justify officially asking EPA to change or eliminate its topline finding in its final recommendations.

The SAB does, however, make a request that borders on the absurd: it asks EPA to prove that there aren’t widespread, systemic impacts to groundwater from hydraulic fracturing. The section of the recommendations that perhaps best illustrates this occurs when the SAB requests that EPA alter its finding that fracturing fluid spills haven’t impacted groundwater because “this major finding is supported only by an absence of evidence rather than by evidence of absence of impact.”

In other words, SAB is asking EPA to prove a negative. The fact that EPA spent five years gathering data and information, and in that time could find nothing to support widespread or systemic impacts on underground sources of drinking water, is indeed evidence of absence. Importantly, the SAB itself provided no evidence to contradict EPA’s topline finding. If SAB has such evidence, then it should release it for public review. Absent any such evidence, however, SAB’s request is unsustainable.

IPAA further notes,

To be clear, there is nothing ambiguous about EPA’s finding. The terms “widespread” and “systemic” are clearly defined and unequivocal.  EPA even offers more clarity, noting that while there were some instances of water impacts (not from the process of hydraulic fracturing itself, but from related activities, such as well casing failures or fluid spills on the surface), the number of these instances “was small compared to the number of hydraulically fractured wells.”

The letter concludes,

If there were anything to suggest widespread or systemic impacts to drinking water as a result of hydraulic fracturing, it would have been uncovered during the past decade of extensive study of the process and the SAB would be able to point to that evidence in its recommendations. The lack of such evidence means the EPA’s conclusion is scientifically sound.

Click here to read IPAA’s full letter.

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