July 14, 2014

Dear Dr. Wheeler,

I am submitting a response to Socioeconomic Effects of Unconventional Oil and Gas Development in NS Communities on behalf of Citizen Action to Protect the Environment (CAPE), a Hants County-based society. Most of our members live within the Windsor-Kennetcook Block and are aware of the challenges to the community from fracking.

We have a number of concerns and comments regarding the material included in this paper:

“Nova Scotia currently faces fiscal and demographic challenges (Ivany, 2014), and is therefore subject to strong pressure to explore and, if viable, develop its unconventional gas resources.”

We, again, question the financial viability of developing unconventional shale gas in NS. In previous responses our group provided links for material from J. David Hughes and Deborah Rogers both claiming that this type of development continues to require more and on-going resources in its “exploration treadmill” and fails to provide good local jobs or energy security.

It is pointed out on page 12 that,

“Changes in land use and reduction in air quality and biodiversity, as well as habitat loss and/or fragmentation, can change both the character of the landscape and its ecological structure and function. In addition, large-scale changes in land use and land cover can affect agricultural productivity, hydrologic patterns, and nutrient retention. These issues may be of particular concern in rural areas where farming, forestry, tourism, recreation, or other land/resource-based activities could be diminished.”

We had expected to find a cost-benefit analysis for the development of unconventional shale gas, and with it, consideration and calculation of the financial impact or loss to the economy from the ramifications mentioned in the above paragraph.

A very recent (July 2014) Ohio study finds there are more costs than benefits in shale gas drilling. While fracking-related employment in Ohio has grown by about 3,000 jobs, this is less than one-tenth of one percent of the state’s total employment, said Woodrum, researcher and author. This number is far fromOhio Oil and Gas Associationsclaims that 40,000 new positions would be created by the industry.

In Carroll County, higher paying jobs related to oil and gas drilling, like construction of pipelines and processing plants, have been mostly going to out-of-state workers following their company’s drilling rig as it moves throughout the country. Ultimately, the report concluded that the economic benefits of fracking fall far short of what was promised and come with costs to safety, the environment, and the community.

http://www.midwestenergynews.com/2014/07/09/ohio-study-finds-more-costs-than-benefits-in-shale-gas-drilling/

Last month, New York general assembly overwhelmingly passed a moratorium on shale gas for an additional 3 years.

http://ecowatch.com/2014/06/17/new-york-fracking-moratorium-senate/

In April 2014, a group of more than 800 local elected officials from all 62 New York State counties, held a press conference in Albany. They spoke of increasing evidence of water contamination, air pollution and a range of other health and environmental harms from fracking. They also noted that the oil and gas industry’s economic and jobs projections from fracking had been significantly exaggerated, and that fracking poses some potentially significant economic costs including road damage, property value declines, and increased crime rates and social impacts.

“Fracking job numbers don’t hold up in reality and they largely go to out-of-state workers, and drilling and fracking jobs have proven themselves to be deadly. In contrast, with renewable energy, we can utilize our strong research universities to create opportunities for our youth here in New York and bring innovative companies into our state—particularly as solar, wind and efficiency technologies make such tremendous strides.”

http://ecowatch.com/2014/04/23/elected-officials-urge-continue-fracking-moratorium/

We question the inclusion of the statement, “However, natural gas emits fewer greenhouse gases when burned, thereby reducing the carbon footprint per unit of energy.”

A major new study (Nov 2013) discounts the whole notion of natural gas as a short-term bridge fuel to a carbon-free economy. Natural gas is mostly methane (CH4), a potent heat-trapping gas. If, as now seems likely, natural gas production systems leak 2.7% (or more), then gas-fired power loses its near-term advantage over coal and becomes more of a gangplank than a bridge.


Fifteen scientists from some of the leading institutions in the world — including Harvard, NOAA and Lawrence Berkeley National Lab — have published a seminal study, “Anthropogenic emissions of methane in the United States.” Crucially, it is based on “comprehensive atmospheric methane observations, extensive spatial datasets, and a high-resolution atmospheric transport model,” rather than the industry-provided numbers EPA uses.

This broad-based study by Scot Miller et al that looked at methane emissions confirms the findings of 2 recent leakage studies covering very different regions of the country:
•NOAA researchers found in 2012 that natural-gas producers in the Denver area “are losing about 4% of their gas to the atmosphere — not including additional losses in the pipeline and distribution system.”

•Another 2013 study from 19 researchers led by NOAA concluded “measurements show that on one February day in the Uinta Basin, the natural gas field leaked 6 to 12 percent of the methane produced, on average, on February days.” The Uinta Basin is of special interest because it “produces about 1 percent of total U.S. natural gas” and fracking has increased there over the past decade.
The comprehensive nature of this new study adds validity to these earlier findings.

The Intergovernmental Panel on Climate Change (IPCC) reported recently that methane is a far more potent a greenhouse gas than we had previously realized, some 34 times stronger a heat-trapping gas than CO2 over a 100-year time scale — and 86 times more potent over a 20-year time frame.

“With methane having both a higher leakage rate and higher global warming potential than previously thought, the notion of methane as a bridge fuel is falling apart.”
http://www.usmessageboard.com/environment/331258-bridge-out-bombshell-study-finds-methane-emissions-from-natural-gas-production-far-h.html

In the Ivany Report we are assured that:

“Nova Scotia has abundant sources of renewable energy, including wind, tidal, geothermal and solar energy as well as agricultural and forest biomass. Using these natural resources to help meet energy demands, while also working toward reducing demand through efficiency, presents a significant development opportunity for rural areas of the province in particular. A prime example of a growing green economy subsector in Nova Scotia is the wind industry, which was in its infancy ten years ago, but today tallies one billion dollars in investment.

Other sectors within the green economy that are also seeing development include sustainable farming, forestry and fisheries. The number of farmers actually grew in Nova Scotia in 2012 – the only province to see an increase. Increasing interest in local food consumption as well as safe and organic food sources holds promise for the farming industry going forward. Sustainable local food production has proven to be a foundation for ancillary economic developments such as artisanal product development, agri-tourism, retail and entrepreneurial incubators such as farmers’ markets.”(p.180)

http://onens.ca/wp-content/uploads/Now-or-Never-Nova-Scotia-Final-Report-with-Research-Engagement-Documentation.pdf

CAPE members question why any industry that puts these sustainable components of this green economy at risk is even being considered, especially when we are aware that,

“Aside from being good global citizens, placing ourselves in a position to develop self-sufficiency and expertise, and having the ability to benefit from eco-tourism, a green economy helps our province remain a wonderful place to live for future generations” p.180 (Ivany report)

http://onens.ca/wp-content/uploads/Now-or-Never-Nova-Scotia-Final-Report-with-Research-Engagement-Documentation.pdf

In a recent article about hydraulic fracturing in Ohio Residents expressed concern about chemical-laced fluids dredged up by the fracking process contaminating local drinking water. Other environmental anxieties included air and noise pollution from the flaring of gas wells and from the drilling itself. Interviewees also mentioned the risk of slurry spills related to pipeline construction and the connection between hydraulic fracturing and earthquakes.

http://www.midwestenergynews.com/2014/07/09/ohio-study-finds-more-costs-than-benefits-in-shale-gas-drilling/

CAPE members were surprised that the increase in number and percentages of traffic accidents wasn’t mentioned in this paper. The financial, health, and community costs associated with these need to be estimated as well.

We suggest that the following statement from page 2 be omitted from the report.

“Elsewhere, the Review Panel has identified baseline monitoring and effective regulations and enforcement as central to protecting human health and the environment (Atherton, 2014; Dusseault, 2014; Gagnon, 2014)”. We have not seen evidence in the discussion papers to support this statement. In fact, in Dusseault’s paper, Towards a Road Map for Mitigating the Rates and Occurrences of Long-Term Wellbore Leakage, co-authored with Jackson and MacDonald, the readers are left with numerous examples of types of hard-to-solve problems and a prediction of increased wellbore leakage:

“Wellbore leakage is a threat to the environment and public safety because of potential groundwater quality deterioration, contributions to greenhouse gas emissions and explosion risks if methane gas accumulates in inadequately ventilated areas.”

“Wellbore leakage will likely only become worse with time as new wells are completed and old wells are abandoned.”(p.1)

http://www.geofirma.com/Links/Wellbore_Leakage_Study%20compressed.pdf

Another very recent report reached the same conclusion.

“There is no evidence to suggest that the problem of cement and well casing impairment is abating. Indeed, a 2014 analysis of more than 75,000 compliance reports for more than 41,000 wells in Pennsylvania found that newer wells have higher leakage rates and that unconventional shale gas wells leak more than conventional wells drilled within the same time period. Industry has no solution for rectifying the chronic problem of well casing leakage.”

Schlumberger, one of the world’s largest companies specializing in fracking, published an article in its magazine in 2003 showing that about five percent of wells leak immediately, 50 percent leak after 15 years and 60 percent leak after 30 years. Data from Pennsylvania’s Department of Environmental Protection (DEP) also confirm these initial leakage rates, with a six percent structural integrity failure rate observed for shale gas wells drilled in 2010, 7.1 percent observed for wells drilled in 2011, and 8.9 percent observed for wells drilled in 2012.

http://concernedhealthny.org/category/press-releases/

On page 12, we agree that “Creation, storage, and treatment or disposal of waste – whether contaminated water, land/soil, or other by-products of development – pose a tremendous challenge for communities”. In fact, such a challenge, that CAPE members believe that unless it can be demonstrated in another province or state that these processes can be completed without harm to the environment and health, they shouldn’t be tried here.

Although we have requested in at least two other submissions for specific information on dealing with NORMS concentrations, suggested protocols and safety procedures involved in removing the build up in pipes and tanks, we are still waiting to see inclusion of that information.

Radioactive releases was an area of concern highlighted by health experts and scientific researchers with Concerned Health Professionals of New York when they released on July 10, 2014 a major new compilation of the scientific, medical and media findings on the risks and harms of fracking. High levels of radiation documented in fracking wastewater raise special concerns in terms of impacts to groundwater and surface water. Studies have indicated that the Marcellus Shale is more radioactive than other shale formations. Measurements of radium in fracking wastewater in New York and Pennsylvania have been as high as 3,600 times the United States Environmental Protection Agency’s (EPA) limit for drinking water. One recent study found toxic levels of radiation in a Pennsylvania waterway even after fracking wastewater was disposed of through an industrial wastewater treatment plant. In addition, the disposal of radioactive drill cuttings is a concern. Unsafe levels of radon and its decay products in natural gas produced from the Marcellus Shale, known to have particularly high radon content, may also contaminate pipelines and compressor stations, as well as pose risks to end-users when allowed to travel into homes.
http://concernedhealthny.org/wp-content/uploads/2014/07/CHPNY-Fracking-Compendium.pdf

Although “It may also create a profitable opportunity for business development, as treatment techniques improve, and local capacity increase,” our first priority is protection of our water, air quality, the public health, and the health of future generations. Again, with something as precious as our water resource, we would strongly recommend that the efficacy of any treatment techniques be demonstrated in another province or state before being utilized in NS.

“Absent from our understanding are the potential medium- and long-term community effects of unconventional oil and gas development” and also absent are community effects that are studied when some members of the community become ill from the air and/or water pollution. We would have suggested data from Wise County, Texas, close to where Bob and Lisa Parr have their farm, and Rosebud, Alberta, where Jessica Ernst lives.

We believe responsible decision-makers should be aware of impacts from fracking in both the medium and long-term before making a decision about its use. Health professionals recognized the need to determine community impacts (including health) over time, when requesting an extended moratorium in New York state,

“Given that exposures and illness increase over time and given that many instances of contamination and illness related to fracking never come to light due to non-disclosure agreements with the industry, we cannot accurately quantify the extent of our problems with gas drilling. We do know they are here, and we have every reason to expect that they are not yet fully visible and they are growing.


The gas industry argues that lives are saved by cleaner burning natural gas. Even if there is any truth in that claim, saving U.S. lives from emissions from shamefully antiquated coal plants should not require sacrificing unconsenting children and families to contaminated air and water from fracked wells and the transportation of gas.

CAPE members strongly agree that, “Creating new health hazards to replace the old is unethical when clean, safe, renewable forms of energy exist.”

http://concernedhealthny.org/category/press-releases/

Respectfully submitted,

Barbara Gallagher

Chair, CAPE

Cc:

Premier Stephen McNeil

Hon. Randy Delorey

Hon. Andrew Younger

Maureen MacDonald

MLA Chuck Porter

MLA Margaret Miller